IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA
CIVIL ACTION NO.: 5:09-cv-69
Download the full West Virginia KBR Complaint
DALE GALLAHER; ROBERT WILSON;
RUSSELL POWELL; ANDRU KELLER;
ERIC HEID; JOHN HEADLEY;
and BRADLEY EBERT,
Plaintiffs
vs.
KBR, INC.; KELLOGG, BROWN & ROOT SERVICES, INC.;
KBR TECHNICAL SERVICES, INC.;
OVERSEASADMINISTRATION SERVICES, LTD.;
and SERVICE EMPLOYEES INTERNATIONAL, INC.
Defendant.
COMPLAINT
NOW COMES the Plaintiffs, by and through the undersigned counsel, and for their Complaint against the Defendants, state and aver as follows:
Plaintiffs, Dale Gallaher, Robert Wilson, Russell Powell, Andru Keller, Eric Heid, John Headley, and Bradley Ebert (together, “West Virginia Guardsmen”) file this Complaint against Defendants, KBR, INC., KBR TECHNICAL SERVICES, INC., KELLOGG BROWN & ROOT SERVICES, INC., OVERSEAS ADMINISTRATION SERVICES, LTD., AND SERVICE EMPLOYEES INTERNATIONAL, INC. (“together, “KBR”), and would respectfully show the following:
FACTUAL BACKGROUND
1.
KBR, a private company, and its operating subsidiaries (including Cayman Island subsidiaries set up by KBR for various purposes described further below) received billions of dollars of no-bid contracts for work in Iraq in 2003. This suit arises from one of the projects KBR was charged with safely completing, a project involving the restoration of the Qarmat Ali water plant in southern Iraq so the facility could resume pumping water down into the Iraqi oil wells for more consistent oil flow. After major combat operations ceased in southern Iraq, KBR, a self-proclaimed expert in overseas infrastructure projects, was responsible at Qarmat Ali for proper site survey before and as work progressed. For allegedly timely completing the Qarmat Ali project, KBR received not only base contract payments but also retrospective “award” payments after Qarmat Ali was back on line.
Download the full West Virginia KBR Complaint
