JO-CV-1 Rev. 10-09 C.G.S. §§ 51-346,51-347,51-349,51-350, 52-45a, 52-48,52-259, P.B. Sees.

3-1 through 3-21, 8-1

SUMMONS - CIVIL

STATE OF CONNECTICUT

SUPERIOR COURT
www.jud.ct.gov

See page 2 for instructions

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"X" if costs "X" if costs "X" if

amount, legal interest or property in demand, not including interest and is less than $2,500. amount, legal interest or property in demand, not including interest and is $2,500 or more. claiming other relief in addition to or in lieu of money or damages.

TO: Any proper officer; BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby commanded to make due and legal service of this Summons and attached Complaint.

Address of court clerk wherewrit and other papersshall be filed (Number, street, town and zip code) (C.G.S. §§ 51-346, 51-350) 235 Church Street, New Haven 06510 G.A. New Haven

Telephonenumberof clerk
(with area code)

Return Date (Must be a Tuesday) September
Month

(203)

503·6800

20
Day

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011 ----year90

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JudicialDistrict Housil}gSession

D Number:
CT 06904

IAt (Town in which writ is returnable) (C.G.S. §§ 51-346, 51-349)

Case type code (See list on page 2) Major: T Minor:

For the Plaintiff(s) please enter the appearance of:
Name and addressof attorney,law firm or plaintiff if self-represented (Number, street, town and zip code) 184 Atlantic (203 ) St. Stamford Telephonenumber (with area code) 325-4491 1 IJuris number (to be entered by attorney only) 417769 Signatureof Plaintiff (If self-represented)

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Number of Plaintiffs: Parties First Plaintiff Additional Plaintiff First Defendant Additional Defendant Additional Defendant Additional Defendant

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Number of Defendants:

2

ID

Form JD-CV-2

attached

for additional

parties P-01

Name (Last, First, Middle Initial) and Address of Each party (Number; Street; P.O. Box; Town; State; Zip; Country, if not USA) Name: Le, Estate of Annie, by Glorie Romaniello, Administrator Address: 141 East Main Street, Waterbury, CT 06702 Name: Address: Name: Yale University Address: Agent of Service: of the Estate

P-02

0-50 Dorothy Robinson, 2 Whitney Ave., 6th Floor, New Haven, CT 06510 0-51 Robinson, 2 Whitney Ave., 6th Floor, New Haven, CT 06510 0-52

Name: Yale School of Medicine Address: Agent of Service: Dorothy Name: Address: Name: Address:

0·53

Notice to Each Defendant
1. YOU ARE BEING SUED. This paper is a Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making against you in this lawsuit. 2. To be notified of further proceedings, you or your attorney must file a form called an "Appearance" with the clerk of the above-named Court at the above Court address on or before the second day after the above Return Date. The Retum Date is not a hearing date. You do not have to come to court on the Return Date unless you receive a separate notice telling you to come to court. 3. If you or your attorney do not file a written "Appearance" form on time, a judgment may be entered against you by default. The "Appearance" form may be obtained at the Court address above or at www.jud.ct.govunder "Court Forms." 4. If you believe that you have insurance that may cover the claim that is being made against you in this lawsuit, you should immediately contact your insurance representative. Other action you may have to take is described in the Connecticut Practice Book which may be found in a superior court law library or on-line at www.jud.ct.govunder "Court Rules." 5. If you have questions about the Summons and Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on legal questions. Signed (Sign i11l!i..2r' proper box)

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Com"'!issionerof the SupenorCourt L J AssistantClerk

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Nameof PersonSigningat Left Paul A. Slager
••..•.•••.. )'.V>

Datesigned 9/6/2011

If this Summons is signed by a Clerk: a. The signing has been done so that the Plaintiff(s) will not be denied access to the courts. b. It is the responsibility of the Plaintiff(s) to see that service is made in the manner provided by law. c. The Clerk is not permitted to give any legal advice in connection with any lawsuit. d. The Clerk signing this Summons at the request of the Plaintiff(s) is not responsible in any way for any errors or omissions in the Summons, any allegations contained in the Complaint, or the service of the Summons or Complaint. I certify I have read and understand the above:

(Only····

File Date

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Signed (Self-Represented Plaintiff)

I Date

Nameand addressof personrecognizedto prosecutein the amountof $250 Mark Katz, Esq., 196 North Signed (O~king Street, Stamford, CT

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recognizance; 'X" proper box)

(Page 1 of2)

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Commissionerof the SuperiorCourt AssistantClerk

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Date

Docket Number

RETURN DATE: SEPTEMBER 20,2011 SUPERIOR COURT

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GLORIE ROMANIELLO, ADMINISTRATOR OF THE ESTATE OF ANNIELE V. YALE UNIVERSITY AND YALE SCHOOL OF MEDICINE

JUDICIAL DISTRICT OF NEW HAVEN AT NEW HAVEN

SEPTEMBER 6, 2011

COMPLAINT 1. On September 2,2011, Glorie Romaniello, was appointed by the State of

Connecticut Court of Probate, New Haven Probate District, as Administrator of the Estate of the decedent, Annie Le. A copy of this Probate Court Certificate is attached as Exhibit 1. 2. On and before September 8, 2009, Annie Le lived in New Haven, Connecticut. At

the time of her death, Ms. Le was twenty-four years old, and a female doctoral student at Yale • School of Medicine's Department of Pharmacology . 3. On and before September 8, 2009, defendant Yale University was a private

university with its campus located in New Haven, Connecticut. Defendant Yale School of Medicine was a medical school affiliated with Yale University, which was also located in New Haven, Connecticut. (Defendants Yale University and Yale School of Medicine are collectively

referred to in this Complaint as "Yale.")

4.

The Yale Department of Pharmacology was a department within the Yale School of

Medicine with research programs encompassing areas of neuroscience, drug development, signaling and structural biology. 5. • Prior to September 8, 2009, Yale had long taken inadequate steps to ensure the

safety and security of women on its campus. Sexual attacks on and harassment of women at Yale had been a well-documented and longstanding problem, and there was a widespread belief that Yale repeatedly failed to impose meaningful discipline on offenders. As a result, Yale created a culture of tolerance that allowed and encouraged aggressive male behavior towards women. 6. Indeed, Yale's persistent tolerance of sexual harassment and sexual assaults on

campus caused students to file a Title IX Complaint against Yale University, which highlighted Yale's failure to adequately prevent and respond to sexual harassment and sexual assaults on female students at Yale. A federal investigation of Yale's conduct in this regard is ongoing. 7. • On and before September 8, 2009, Ms. Le regularly performed research work and

studies related to her doctoral studies in a research lab owned and operated by Yale, which was located in the Amistad Street Building, a 120,000 square foot building located at 10 Amistad Street, New Haven, Connecticut.

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8.

At all times pertinent to the claims in this case, the Amistad Street Building was

owned, operated, managed, secured and maintained exclusively by Yale and its authorized
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employees agents and representatives.

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9.

On and before September 8, 2009, Yale had a duty to provide Ms. Le and other

students who worked in the Amistad Street Building with a safe and secure work environment. 10. To fulfill this duty, the Yale security staff at the Amistad Street Building was

required to restrict access to the building in part by requiring entering individuals to swipe a security card before entering. This allowed the Yale security staff to carefully monitor the identities of those who entered the building, along with the times of entry. 11. In addition, only authorized persons were permitted to enter certain laboratories in

the Amistad Street Building. Access to these laboratories was restricted to authorized users whose security card permitted entry, and swiping the security card was required to unlock locked doors that provided access to the laboratories. When an authorized user swiped her card to gain • entry to a restricted area, Yale had a record both of the identity of the person who entered and the time of entry. 12. At approximately 10:09 a.m. on September 8, 2009,just five days before Ms. Le

was to be married, Ms. Le entered the Amistad Street Building and proceeded to her laboratory,

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which was located in Room G-13 of the building. Room G-13 was a restricted laboratory, and Ms. Le was required to swipe her security card to gain access to the room.
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13.

Unknown to Ms. Le, a laboratory technician employed by Yale, Raymond Clark,

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was also present and working unsupervised and alone in or near Ms. Le's laboratory. 14. Also unknown to Ms. Le, Clark had previously demonstrated aggressive behavior

and a violent propensity towards women. 15. On and before September 8, 2009, Yale, by its authorized agents, representatives

andlor employees, knew or should have known that Clark posed a potential threat to the safety and well-being of others who worked in the Amistad Street Building, including Ms. Le. 16. In fact, Clark's own sister and brother-in-law also worked for Yale as laboratory

technicians in the Amistad Street Building on and before September 8, 2009. Both were well aware Clark's past behavior raised concerns that he was a threat to the safety and well being of others, including Ms. Le . • 17. At approximately 12:55 p.m. on September 8, 2009, a fire alarm in the Amistad

Street Building was engaged. Although people present in the building were required to vacate the building in response to the fire alarm, Ms. Le was not among those who left the building in response to the alarm.

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18.

Representatives of Yale who were responsible for the safety and security of those

in the building failed to search Room 0-13 or the other rooms where Ms. Le was known to be
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working despite the facts that: the fire alarm sounded and all people in the building were required to vacate; Ms. Le was not among those who vacated the building; and, Yale knew or should have known Ms. Le had been working in Room 0-13. 19. At the conclusion of the workday and into the evening hours of September 8,

2009, Ms. Le still had not emerged from her laboratory in the Amistad Building. 20. Despite the fact Yale was aware Ms. Le had entered the building at around 10:09

the morning of September 8, and was not seen or heard from by anyone through 10:30 p.m. that evening, Yale did not investigate her absence. 21. Eventually, when Ms. Le did not return home that night, her housemate called the

authorities at Yale at around 10:40 p.m. to report her missing. 22. Even after Ms. Le was reported missing to Yale representatives on the evening of

September 8, Yale did not investigate her absence in earnest until the following morning. 23. While in the Amistad Street Building, Ms. Le was brutally attacked, strangled and

murdered by Yale's employee Clark.

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24.

From September 8 through September 13,2009, Ms. Le was known to be missing

and her whereabouts unknown. 25. On September 13, 2009, the day Ms. Le had been scheduled to be married, Ms.

Le's battered and dead body was found by police inside a basement wall near her laboratory in

the Amistad Street Building. 26. An autopsy performed on Ms. Le's body by the State of Connecticut Medical

examiner revealed that Ms. Le had been badly beaten, and that she had suffered a severely fractured mandible (jaw), fractured clavicle (collarbone) and severe bruising and bleeding. 27. On September 17, 2009, police arrested Clark, a Yale employee, on suspicion of

murder. Clark later pled guilty to the murder of Ms. Le and entered an Alford plea on the charge of attempted sexual assault of Ms. Le. He is currently serving a lengthy prison sentence. 28. Yale, by its authorized agents, representatives andlor employees, was negligent

and failed to use reasonable care in one or more of the following ways:

a.

by hiring Clark for a position that allowed him unsupervised access to students and staff, including Ms. Le;

b.

by retaining Clark in a position that allowed him unsupervised access to students and staff, including Ms. Le;

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c.

by failing to adequately supervise and monitor Clark's activities in the Amistad Street Building;

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d.

by permitting Clark to work alone in remote areas of the Amistad Street Building with Ms. Le and others;

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e.

by failing to inform and warn Ms. Le about the potential threat posed by Clark;

f.

by failing to take reasonable steps to provide a safe and secure environment for Ms. Le at the Amistad Street Building;

g.

by failing to maintain a properly qualified and trained security staff at the Amistad Street Building;

g.

by failing to properly respond to the fire alarm in the Amistad Street Building by searching Room G-13 and other rooms in the vicinity to ensure the safety of Ms. Le;

h.

by fostering an atmosphere of tolerance of sexual harassment and sexual assaults that emboldened Clark and left Ms. Le vulnerable to his attack;

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1.

by failing to promptly and adequately investigate Ms. Le's unexplained disappearance; and

J.

by failing to detect, prevent or intervene in Clark's brutal attack and murder of Ms. Le.

29.

As a result of the negligence of Yale, Ms. Le endured a brutal physical and sexual

attack, resulting in significant conscious suffering, as well as painful physical and mental injuries before her death. 30. As a result of the negligence of Yale, Ms. Le suffered terror and fear for her own

well-being, including fear of serious injuries and imminent death. 31. As a result of the negligence of Yale, Ms. Le was brutally beaten, resulting in

serious and painful injuries before her death, including but not limited to a fractured mandible (jaw) bone, clavicle (collar) bone, as well as severe bruising and bleeding. 32. As a result of the negligence of Yale, Ms. Le was violently strangled and

murdered at the age of twenty-four years, and was deprived of the rest of her normal life expectancy. 33. As a result of the negligence of Yale, Ms. Le suffered a loss in her ability to enjoy

all of her life's activities, including but not limited to her wedding and marriage that had been scheduled to take place on September 13,2009.

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34.

As a result of the negligence of Yale, Ms. Le suffered lost earnings and a total loss

of her earning capacity.
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BY PAUL A. SLAGER SILVER GOLUB & TEITELL LLP 184 ATLANTIC STREET P.O. BOX 389 STAMFORD, CONNECTICUT 06904 (203) 325-4491 JURIS # 58005

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OF COUNSEL: JOSEPH TACOPINA * TACOPINA SEIGEL & TURANO, P.C. 275 MADISON AVENUE, FL 35 NEW YORK, NEW YORK 10016

TO THE CLERK: PLEASE ENTER THE FOLLOWING APPEARANCE FOR THE PLAINTIFFS: SILVER GOLUB & TEITELL LLP P.O. BOX 389 STAMFORD, CONNECTICUT 06904 (203) 325-4491 JURIS NO. 58005

*Not admitted in Connecticut.

Plaintiff intends to move for his admission pro hac vice.

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PRAYER FOR RELIEF WHEREFORE, plaintiffs pray for relief from the defendant in the form of compensatory damages of an unspecified amount significantly greater than the jurisdictional minimum of $15,000.00, exclusive of interest and costs, as well as attorneys fees, costs and any other relief • the court deems just and proper.

THE PLAINTIFF,

BY__

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~__::_ _ PAUL A. SLAGER SILVER GOLUB & TEITELL LLP 184 ATLANTIC STREET P.O. BOX 389 STAMFORD, CONNECTICUT 06904 (203) 325-4491 JURIS # 58005

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• OF COUNSEL: JOSEPH TACOPINA * TACOPINA SEIGEL & TURANO, P.C. 275 MADISON AVENUE, FL 35 NEW YORK, NEW YORK 10016

*Not admitted in Connecticut.

Plaintiff intends to move for his admission pro hac vice.

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EXHIBIT 1

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DEC:REE GRANTING STATE OF CONNECTICUT AOMINlSTRATION OR PROnATE OF WILL COURT OF ~RODATE PC-260 REV. 10/05 COURT OF PRonATE, New Haven Probate District ESTATE OF
Annie Le (11-090 1)

.-.eCOlilll:!D:

DlSTRICT NO. PD38

PIDUCIAn.Y'S NAME AND ADDlU3SS
Glorie Romaniello, 141 East Main Street, Waterbury.

POSITION OF TRUST CT 06702
Administrator

At a court of pro bare held at the place and time of hearing sec by the Court, together with any continuances thereof, as of record appears, on the petitioner's application for letters of adm1a.isttation be granted on said estate, all as in said application more fully appears. PRESENT: Hon. John A. Keyes, Judge After due bearing, THE COURT F1NDS that: Tbe above-named decedent died Oll me 8th day of September, 2009, domiciled at the time of death at 188 Lawrence Street. New Haven. CT 06511 and having estate whereof admlnlstradon appertains to this Court, and administration of said estate ought to be granted. Notice is excused for cause, found. The fiduciary named above has accepted the position ofttust designated above. and

And it is ORDERED AND DECREED that: The said application is approved. administration of said estate is granted Cothe fiduciaty named above, and leners of administration are hereby issued to said fiduciary. PROVIDED HOWEVER that the fiduciary is authorized only to handle litigation in all respects. The Court dispenses with the requirement of a probate bond at this time. N,B, HEARING WILL BE HELD ON SEPTEMBER 15. 2011 AT 2:15 PM TO CONFIRM THE APPOINTMENT OF THE FIDUCIARY. Said hearing will be held at the New Haven Probate Court, 200 Orange Street. First Floor, New Haven, CT. T.he fiduciuy (or counsel for the fiduciary) shall auend. All oihc=.:r parries on notice are hlvired to attend, but are not required
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do so.

And it is further ORDERED AND DECREED that; Two
llliJllths from the date hereof. be and the same is allowed said fiduciary within. which to make a true and complete inventory of all property of the estate of said deceased.

Twelve months from the date hereof, btl and the same is allowed said fiduciary within which All claims against f:heabove estate be prese-nted pursuant
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to

settle said estate.

the provisions of C.G.S. Ch. 802b, Part VII.

Nostc« oflhis decree be given Uy the judge, cLerk. or assistant clerk:by regular mail, not mosetnan TEN days from the dare hereof Dated at New Haven, Connecticut,
!his 2nd day

of September, 2011. John A. Keyes, Judge

As used in iliis decree, the word fiduciary includes me plural, Where !he COJl~xtso requlrea,

DECREE GRANTING ADMINISTRATION OR PR.O:BATE OF WII..L Z0/Z0 39'i1d

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