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Robinson.complaint

Robinson.complaint

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Published by Helen Bennett
Lawsuit filed in death of Erika Robinson in New Haven
Lawsuit filed in death of Erika Robinson in New Haven

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Published by: Helen Bennett on Mar 04, 2014
Copyright:Attribution Non-commercial

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03/27/2014

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RETURN DATE: APRIL 8, 2014 : SUPERIOR COURT ESTATE OF ERIKA ROBINSON : J.D. OF NEW HAVEN VS. : AT NEW HAVEN FUNN HOUSE PRODUCTIONS LLC : FEBRUARY 26, 2014
COMPLAINT
1.
 
On December 17, 2013, the State of Connecticut Probate Court for the District of West Haven, District PD39, appointed the Plaintiff, Celeste Robinson Fulcher, to serve as the Administratrix for the Estate of Erika Robinson
 
(hereinafter referred to as “the
Decedent 
”).
 Attached, as
Exhibits
 A and A-
1 are copies of the Fidicuary’s Probate
Certificates. 2.
 
At all relevant times mentioned herein the Decedent, Erika Robinson, was an individual residing in the City of West Haven, State of Connecticut. 3.
 
On or about October 26, 2013 and at all times mentioned herein, the Defendant, FUNN HOUSE PRODUCTIONS LLC, was a corporation organized and existing under the laws of the State of Connecticut with a principal place of business at 85 St. John Street, New Haven, Connecticut. 4. On said date and at all times mentioned herein, said Defendant and/or its agents, servants and/or employees owned, operated, managed, conducted and/or controlled said premises and the establishment known as at the Key Club Cabaret.
 
 
5.
 
On or about October 26, 2013, the Decedent was a patron and business invitee at the Key Club Cabaret located at 85 St. John Street, New Haven, Connecticut. 6. The Defendants, FUNN HOUSE PRODUCTIONS LLC, acting by and through its agents, servants, and/or employees, did invite members of the general public to enter and patronize the Key Club Cabaret and to consume food and/or liquor. 7. On or about October 26, 2013 Adrian Bennett was also a patron and invitee of said Key Club Cabaret. 8. On the aforesaid date, the Decedent was physically assaulted by patron Adrian Bennett, who possessed a weapon on said premises which discharged and fatally injured the Decedent at the Defendant
’s establishment known as Key Club Cabaret
 9. The Decedent
’s injuries were proximately caused
 by the negligence and carelessness of the Defendant, FUNN HOUSE PRODUCTIONS LLC acting by and through their agents, servants, managers, supervisors, and/or employees, in one or more of the following ways, in that they: a. allowed Adrian Bennett to remain on the Defendant premises, after he exhibited disorderly, disruptive, argumentative, angry and/or agitated  behavior toward patrons;  b. failed to take reasonable measures to protect patrons and invitees including the Decedent from violence after they were notified and warned of disruptive, annoying, disorderly, and abusive behavior of Adrian Bennett; c. ignored and tolerated disruptive, disorderly, argumentative and/or threatening  behavior of Adrian Bennett; d. failed to institute and disseminate to its employees procedures and guidelines for responding to persons who were disruptive, argumentative or behaving improperly toward other patrons;
 
 
e. failed to train its agents, servants and/or employees in proper procedure for responding to disorderly and disruptive persons on the premises who behaved improperly toward other patrons; f. failed to take reasonable and necessary measures so as to avoid the risk of foreseeable harm posed by Adrian Bennett to patrons and invitees of the  premises, including the Decedent; and g. failed to have reasonable and adequate security on the premises to keep the  premises safe for patrons including the Decedent. 10. As a proximate result of the negligence of the Defendant through its agents servants and/or employees, the Decedent sustained the following injuries: a. gunshot wound that caused her death 11. As a result of these injuries, the Decedent
’s injuries are permanent in nature,
she suffered and will in the future be unable to participate in the many activities in which she previously engaged. 12. At all times mentioned herein, the Decedent was gainfully employed and as a further direct and proximate result of the negligence as aforesaid, the Decedent will lose wages from employment and suffered total economic loss in the form of lost wages.

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