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Case 5:18-cv-05056-JLV Document 1 Filed 08/03/18 Page 1 of 6 PageID #: 1 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA 2 WESTERN DIVISION 3 KATHLEEN HANLINE‐LEWIS, 4 CIV. NO.: ________________5:18-cv-5056 Plaintiff, 5 6 vs. 7 ROLAND SANDS, an individual, BUFFALO COMPLAINT CHIP CAMPGROUND, LLC, and POLARIS 8 INDUSTRIES, INC. dba INDIAN 9 MOTORCYCLE COMPANY, 10 Defendants. 11 Plaintiff Kathleen Hanline‐Lewis, by and through her attorneys BEARDSLEY, JENSEN & LEE 12 in the above‐entitled matter and for her Complaint against Defendant states and alleges as 13 14 follows: 15 PARTIES 16 1. Plaintiff Kathleen Hanline‐Lewis is a resident of Las Vegas, Clark County, 17 Nevada and was visiting Sturgis, South Dakota for the Sturgis Motorcycle Rally in August, 18 2016. 19 20 2. Based upon information and belief, Defendant Roland Sands is a resident of 21 Long Beach, Los Angeles County, California. 22 3. Based upon information and belief, Defendant Buffalo Chip Campground, LLC is 23 a limited liability company organized under the laws of South Dakota with its principal place of 24 25 business in Sturgis, South Dakota. 26 4. Defendant Polaris Industries, Inc., registered in South Dakota as a foreign 27 corporation, purchased Indian Motorcycle Company in April, 2011 and continues to operate the 28 1 Case 5:18-cv-05056-JLV Document 1 Filed 08/03/18 Page 2 of 6 PageID #: 2 1 business as Indian Motorcycle Company with its principal place of business in Medina, 2 Minnesota. 3 5.
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