Professional Documents
Culture Documents
MM~NS -CIVIL
JD~c~-~ aey. 9~a
STATE OF CONNECTICUT
SUPERIOR COURT
www.~ud.ccgov
628,62269,P;9,Secs.31~rough35z9se~5a,
X" if amount, legal interest or property In demand, not including interest and
costs Is less than $2,500.
"X" if amount, legal interest or property in demand, not including interest end
x costs Is $2,500 yr more.
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Adtlress of court cle w ere w t and oNer papers sAali be flied (Number,street town eod z/p coda) Telephon9 Lumbar Of__~--cleric(wNh
(C.G.S 57.3AB, 51.350)
6ae Cod9)
~(203 )ZO7-8600
I A~ gown ie wnicn wnt ~s retuineoreJ (c.G.S~ 9 57.346, 50398)
Danbury
Number.
For the Plaintiffs) please enter the appearance o4:
Name and adtlroes o~ attorney,!aw firm or plalntl(t If 8eit cepreaented
McJor, T
Minor; 90
428746
(203) 6a2,3988
The attorney or law firm eppeadn9 for the plalnUA, or the plainGfl If
setf.rep~eaented, agrees to accept papas(~ervlce) elechonlcalty In
thla case u~dar 5ac6on 10.13 of the Conneellcut PractJee Book.
Number of Plaintiffs: 2
Q NO
Number of De(endents: 3
Name (Lear, FJrs~ Mldd/e /niUal)a nd Address of Each parry(Number;St/eefl P.O.f~OX; Town;State;Dp;~ou~Jtry, itnOt US/U
Namr The E~tato of Jesse Lewis, Scerlett Lewis as Administratrix
P-01
Addreee:6 Great Rtng Rd.,Sandy Hooky CT 06482 .
Parlles
Fast
PlaUtltt
Defendant
Addldonal
Defendant
Addltlonal
Pfaint{ff
Ff~st
Additional
Defendant
Additional
Defendant
Address:
D-o3
Name:
p.pq
(~
r~~,,,,n~;.
Notice!o each Defendant
~L~+W ~ux~
1, YOU ARE BEING SUED.This paper Is 8 Summons in a lawsuit. The compiglnt eKeched to
klna
Court address on or before the second day after the above Return Date.The Return Date Es not a hearing date. You do not have to come to court on the
Return Oate unless you receive a separate novice tailing you to come to court
3. tf you or your Attorney do not file a w~1Ken "Appearance"tOm1 on time, a]udgment maybe entered against you by tlefault. The "AppeardnCe"form may De
t2.12.2014
For Court Use Onl
e. The signing has been donee So the!the Pleintiff(s) will not De Oenled aC~ess Oo the cpurfs,
b. it Is the responslbUity of the Plafnt(ff(5) to sea that service is made in the manner provided by law.
c. The Clerk Is not permitted to 91ve any lapel advice fn connection with any lawsuit.
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in the Summons, any eliegetions eonlaie@d In the Complaint, ar the service ofthe Summons or Complaint
AID
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~P~irficid tv;n:rry
gnhce
;7~aro"A
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~~
Do~J(et Number
72.122014
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In'struct'rons
?. Type or print legibly; sign summons.
2. Prepare orphotocopy a summons fvr~ach defendant
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if tAere are more then 2 plaintiffs o~ more than 4 defendants prepare form JD-CV2and attach it io the original and al!copies
ofthe comp/ai~t.
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(a)Family matters (for ex8mple divorce, child
support, custody, paternity, and visitetlon
matters).
(b)Summary process actions.
(c)Appllcetions forchange ofname.
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Case Type Codes
Minor Descrlptlon
Ma)or Description
Md~~
C011t~'aCffi
Coo
C 10
G 20
C 3o
C d0
C 90
Eminen! Domain
E OD
E 10
E 20
E 3o
E 80
Mlscellanecus
Moo
M 10
M 20
M 30
M 82
M 83
M ea
M 90
~n)unction
Recetverehip
Mandamus
Habeas Corpus (exlratliuon, release from Peal
IrtsUtuUon)
ArbltratWn
OecJaraory Judpmant
Bar Dis~pllne
Department o/labor Unemployment COmpeneaUon
Fnfocemo~t
9ar DieCipiine -Inactive Staves
Munldpal ordlnanm end Regulation Enforcement
Foreign Clvii Judgments -C.G.S. 52.90a g ~,~,5,
SOa-30
Nouslnp Clvn Mepere
Small Clalma 7renetgr to ReO~~aP Docket
Foreign Protective Order
All other
Poo
P ~0
P 20
P 3o
P 90
Foreclosure
PaNtlon
Quiet Tltle/Dlscharye of Mortgage or Uen
Asset Fortalivre
All ot~ar
MAO
M 50
M 83
M 86
M 6e
M 70
M 80
Prop911y
M9jor Desctiptio~
M~~
Torffi(Other than
Vehicular)
T 02
703
T 17
T 12
720
T 28
729
7'30
74o
T 50
7'g~
T68
T 7o
T7~
T Bo
Vehicular Torts
V 07
V 04
V 05
Y 06
V 00
V 10
V 20
v 3o
V 40
V eu
W 10
W 90
WIUs, Esfatss
and Ti'u8ta
MIno1'Description
dD-Cv-1 Rev.9.14(BacWPage 2)
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SU~'~~tSOR COURT
J.A. OF DANBURY
V.
AT D~NBURY
DECEIvII~ER 12,2014
COMPX.AYN'T
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5. At all matcr_ial. times herein the superiutcudcnt was an went,servaa~, et~paoyee, or other
representative of the ~7efendant,THE BOAItA,and/o= THE TOWN Or NLW~'O'IWN.
6. At all material Humes hczein the Defeuda~C,THE BOt~RD,was under a legal a~ad ministerial. duty
to czeate, enforce, and abide by a collection of rules and regulations eo~cexaing v~ous
cm~loyee and student conduct, ali.egations,investigations, penalties, and to ensure student safety
a~ad well-bung under C.Cy.S. 10-233,10-22Q 10-220f, and 10-22x,and ruled to do so under
C.G.S.52-557.
7. At aU. maultimes herein the Defessda~.t, THE BOART~,under the requirements o CGS '10220Einstituted achooX safety policies and proceduze~ which left no azea for discretion by its staff
and/ox agents, cone~.tuing the safety of the schodLs ixl the Newtown Public School District
includi.~g the"lockdown" and evacuation plan Qxeviously practiced, but never itnp~exuer~ted oa
December 14, 2012, by the SANUX SHOOK EI.F1viENTARX staff; the fail ice of which to
implement resulted ixa t1~ae death of twenty(20) students, i~tac~udingrESSE LEWIS.
8. The Defendant,~E B4ARD,failed to provide the staff ofSANDY HOOTC ~:T.F.MFN'I'~^Y
SC~.00L with the necessazp uafo=matioa, tools, and ~ainiag to pzopezly implement the safety
pzotocols previously established by THE TOWN OF NEWTOWN,~BOARD and
SAN,DX I~OOIC ELE[vIENTARY SCHOOL,tb,eieby making it so that the SA1~T1~Y ~-TOO.K
F..,X,~].VI~N'!'ARY SCHOOL staff~o, rooms eight(8) and tea (10) were unable to implement said
obligatory safety protocols on December 14,2012 when a~,in~uder,ADAM LANZA entered
the building,
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leuviag anon-security glass vPindow, with measuremeat~ of nearly three (3) feet wide by four (4)
eet high clirectly next to the locked doors of t}ae school essentrally =en.dering the locking ofthe
school doors at the outset of the school day itcelevant and impotent in the effectuation of the
school"lock-down" plan.established by the ~'OV~IN OF NED~!'OWN,THE BOARD,and
THE SAN~X ~IOO.YC ~~EM~NTARY SCFi00L,in violation of C.G.S. 52-557n.
12. The Defendant,'~'~XE BO.A1tD as agents and employeCs ofTHE TQWN OF NEWTOWN,
was negligent in that at wiled to follow or provide its sehool~ systems with ehe necessazy tools to
implement the security and safety guidelines which THE B(~A,~I~,~-I~ TO~UN OF
N~WT~WI~T and T~ SANDY HOOK
intcudez gained access to the school mounds,and tbe=eby made ~. m~iniste~xial duty that left no
=oom For discretion by the S.A,NT~Y HOOK ELEMENTAR~C SCHOCIL teachers andJo=staff
to effectuate in a time of emergency; hencefortb violating the minisce~ial duty created by THE
'OWN',THE BOAIZT7,and SANDY HOOK ELE;~v~ENTARY SC~i00L to provide a safe
school envuonmen~,which all volua~tily wadettook when the "lock down" and eoaeuatior~ plate
was created, but which was rendered impossible to follow,with so many key components
missing foz a successful i~apJ,cmentation, after eating the miz~dstGcial duty to do so, all.in
violation of C.C'r.S. 52-557n.
33. The details and ~roscciptioas of this plan left no discretion to the teachrss or other em~logees
and were to be followed as outlined for the safety' oEtlae childrea at SANDY HOOK
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17. JESSE Z,~WIS was located within the school. bv~ildis~g at 9;30am on December 14,20x2,iri
classxoom (10), his first ~xade cL~,ssroom fox the school hours ofthe day, as a student o the
SAI~TDY HOOTS E~EMLNTARY SCHOOL,which is a pubic school.
18. At approxiz~natelp ~c35am ADAM T.ANZA shot out t}~e window located next to the locked
school doo=s, and gained easy a~~ess to SANDY HOOK EL~~.v,CF.IV~"ARY SCHOOL.
19.'fie rc~ain of5ce staff reported hcaxing glass brealdug and gunshots at appzoximatelp 9:35 am and
saw a wl~uit~ mile with a hat and sunglasses,I~tet identified as ~1D.AM LANZA,come into the
bvildin.g with a rifle-type gun; and was ~ees~, shooting the rifle down the ha]lway where JFSSE
LEWIS'loss=oom ~+ns aoca.ted.
20. ADAM LANZA shot down nc~ hallway at the principal and othex sta~'at this time anal killed the
prinicipal and the school psychologist wb~o bad exited conference room,9 at the end of the
ba].lway to see what the loud bangirg ~fi=e)noises were; all Wex~ attending a pL~nning and
placement meeting with gth~t staff members and a stud~n~s parents,
21. A s~ff m~mbear standing behind rha ~riueipal and school psychologist ~vs~ shot in the leg; but
remained prone on the gxound foz a moment before crnwling bAck into conference zoom nine
(9)smd made a call to 9-1-1 aL~o iz~ediately turning on the sel~ool intercom system t}.uough the
phone located an room nine (9), which,allowed othex areas of the school to heaz what was going
on in the building.
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22, ADAM LAN7.A then entered tb~e m~ia office to the school, ve~he~e all staff members we=e
hiding within the office; AD,A~IvZ LANZA exited the school ofxce; and then be entered the
school office again; dosing whdrb. time no shots we=e fired as~d thcxc teas ~ lullin the gunfue.
23. ~Fter ADAM T~t1N7rA'S second rxit from the main office, the oficc s~ffimmediately called 91-7..
24..AX7.AM LANZA then entezed the w~locked doors of classrooms eight(8) and then ten (~0), the
firse made cL~ssrooms ofSANDX HOOK ELEMENTARY SC~IOOZ,.
25. At the time AD~NI LANZA entered th~sc xooms, no doo=s had been locked,gone othe
childtez~ bead been moved to a safe location,like the bat}~zoom located inside both of these
classrooms; bathrooms which,could be locked fzom the inside.
26, Neither elassxoom ei~h~ (8) nor classroom ten (10) had i,~ternal locks to their doozs;the only
~vay to lock these doors was to Iock tkxe~ fYoin the outside with a key; despite heating the
gunshots tba~ broke the glass window,the gunslaoCs that killed the principal aad school
psychologist;the gunshots tk~at wounded the other staff member who opened tie intezcorra
systems fxom conference room nine (9); or the lull in gunf~e that ttan.spired in the time that iL
took the ine=uder, ADAM LANZA,to investigatE the main office before re-entering the hallway
and opening the unlocked doors to classrooms eigiat(8) and tcn (10); thereby efFectively no
classroom doors were locked in accoxdauce rvirh the aforementioned lock-down or evacuation
procedures establisb~d by T~T~ TOWN OF NEWTOWN,T~EIE ~30ARA OF E17UCA.T.[ON,
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b.
The PlaintiFf brings this action puxst~aat to 52-555 of dse Connecd~ut CYene=al
Statutes,
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c.
'~'ktey failed to t=aro and supervise the staff at SANDY KOOK F.LEN~NT.A,RX
SCkI00L on the pxopct wap to implement the "lock down" and evacuation
~roceduses as instituted by,'~E BOARD THE TODUN QF;NEWTOWN ANA
TFI~ SANDY HOOK ELEMENT.AxtX SCHOOL for sicuarioz~s precisely like the
one that presented itself on Decesn~brar 1~,2412,iu violation o~ C.G.S. 52-557n;
d.
They failed to provide certain. teachers with keys to the dass=oomis or training or
information concemiag the "~oClc doom procedure" rh~ebp mal~n~ itimpossible to
even attempt to lock the doors to the classroom,^which could only be ~o~ked f=om
the ourside with a key,in violation of C.G.S. 52-557n;
e.
They failed to pzovide a secuaty gvarc~ oz a~oy other type of L~.w q~tforcement
Q~soxu~el to assist in the impl,em~eatatiou of the policies and procedures should au
i~teuder enteL the building, while leaving a ]ar$e enougLt x~on-safety $]ass window
directly to the tight of the locked outer doozs of the school; making access to the
building relativelq simple,and successful "lock down" of the building virtually
They left the school ra.-terio= unprotected frvno intruders b~ l~avir~g a three (3) foot
wide by fowl(4)foot high non-security glass window Ioeated directly to the right of
the locked exterior doors o~ the school; essentially rendeang the locltiug of the
school doors; a xnaadated =e9uirem,~.nt instituted by TIDE BOARD,THE 'OWN
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They failed to follow their own g~tidelibes segarcling school safetp wlu~h TT~~
B011RA T'~ZE TOWN,and THE SAlVT~Y HOOK ELEMENTARY SCI~OQL
established in accordance wieh Connecticut General Statutes 10-220,10-220f and
10-221, which then became ministerialin nature once established to all agents,
employees,and members of the BOARD and THE SANDY HOOK
ELEMENTARY SCHOOL,by failing to provide adequate equipment and training
to the stiff and p~tso~el ofTT~E SANT7~Y'T~OOY~ ET.EM~NT.ARY SCXTOOL on
know to successfully implez~r ent the "lock down" and evacuation security plan,in
violation of C.G.S. ~ 52-557x;
h.
They lefe the teachers and staff witl~ no discretion in implementing the polices and
p=oceduies Fora `9ock-down" and evacuation if an in~uder entered SANDY
HOOK ~NT.A~.tY SCHOOL,bue failed to p=ovide the same individuals with,
rho pxope~ cgvipxaent, buildi~og ~ccuxity, and tc~iaing to effectuate the misiisterial
duty of following the safety pzotocols,in violation of52-557n;
i.
The harm to Which JBSS~ L~WIS was exposed was imminentin that it was isolated
to the collection oftimes from when the shooter shot ont the f=ont window until. be
ultimately committed suicide; anti was geog=aphicaliy restricted to the azea in which
JESSE LEW1S and his classmates were located in weir classrooms;in that the
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teachers aid staffin his classroom wexe wcll-aware of this irr,,;nent hattn as gun
sk~ots bad been firing down.the hallway outside the door to ~ESS~ LEWIS'
classroom killaug both the school principal at the end of the hallway, the school
psychologist at ~tkae end of the hallway,and injuring at least one staff mcttaber at the
end of the hallway; thcz~foxe the teachec~s)in JESSE L~W~S'classroom were on
notice that an imziunent hams was present to the xderrti~able victims in rbe
classroom but could nocimplement the mandatory secuaty guideLiza~s because the
IiOARD failed to provide adequate equi~me~t and resources to do so auu violation of
C.C.S. 52-557n; and
The danger was apparesst to JESSE LE~WIS'teachers)iti that it was e~silq observed
and understood that gunfire down the hallway outside the classroom doo=would
expose the c~i].dteo,inside to au immediate and wade~iable danger, and t1~e teacher's
failure to act to lock rho door,iva part because the substitute teas not provided with a
key to do so, oz otherwise follow the "dock-down" and evacuation pzocedure, of
which t}ae substitute teacher had.zoo knowledge,training or ~xpetience, would place
the studc~ts,including JFSSE LLWT5,;tn immediate danger, but the teachers and
owe= s~ff, agents anti employees cocild notimplement the mandatory security
guidelines because the BO~tD failed to provide adequate equipment and resources
to do so.
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31. As a result di=ed ofthe failure to provide the uecessarp equipment aad ~ainins to follow the
safety and secuaty guidcliaes established by THE TQWN OF NEWTOWN,TIC ~Oti~tD,
and TFiE SANAY HOOK ~X,LMEN'YAIZ.~'SCHOOL,the us~udet was able to c~~aia access to
JESSE LEIXIZS' classroom s~.ud same .~ailuze aesulted in the shooting and failure to Follow the
~xoscribed prococols,thereby leading to JESSE LEWIS suffe~g massive fatal,injuries and
death.
32. JESSE LEWIS suffered both physically and mentally ~.r~or to lus untimely death.
33. THE ES'T'ATE OFJESSE LEDUIS incurred both m~di~al expenses and burial aid funeral
expenses, as a zesult of the events following the shooting;
34. Because of his death,JESSE.T..EV~S' capacity to enjoy life's attiviiies and have a family were
completely and p~anendy ~xtiuguished; astd
35. JESSE LEWIS was a studious and dedicated student wbo's life was cup short beFore be could
finish his education, begin a career, aad he thesefoxe lost a Iifetizue of potential earnings, and the
oppozCunity ox the participation in a ]ietime ofex~~tiences and eztjoyment:
SECOND COUNT ('X'HE ESTA'Z'E OF JESSE LEWIS,SCARLETT X,EWIS A$
ADMINXSRATRIX,NEIL HESLIN AS CO-ADMINIS'xRATOR,agaiast T.'f~E TOWN
OF NEWT'OWI~
1. PLlintiff, SCEIRT.ETT LEWIS is the duly appointed Admicxiscratrix ofthe Esmte of her son,
,~ESSE LEWIS surd NEIL FZ~SLIN is co-adaunistrator of the estate (hereinafter,"JESSE
LE1WZS'~,
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SANDY fi00~~ ~.L~MENTARY SCHOOL and was also responsible for the ~g~ t~ai~aiug~
supervisXon, pzofcssional development and genexal guidance of the Newtown,public schools'
teachers, educational assistants and employees as dictated bp'Z'HE BOARD th=ough the
~ ~i
4. At all xnate~ial, times herein,I~A~ID FLEISHM~N,as the TOWN'S superintendent was
responsible for the operativz~, supcxvision, control and safety o~ students and for managing the
entire TOWN'S Public School spste~n, ovrs~ecing school admiaistratozs' managrmcnt of day-to-
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to
and/or control, ofthe NEWTOD~N PUBLIC SCHOOLS,as delegated by tl.~e Defeadau~ THE
~~!
S. At all material times hexe~,n the superintendent was ~ agent, servant, em~lopee,oz other
representative of the Defendant,THE B01~i,D,and/or the Defendau~ THE TOWN.
G. Ac all material rimes herein the Defendant,'~'HE TOWN,acting th=ough its agents at the
DeEendan~ THE BOARD,was under a legal aad ministerial duty to cceatc, enforce, and abide
by a coIIection of Hales and =e,~ulations concerning various employee avd student conduct
allegations invcstig~.tions, pe~ualties, and to ensure student safety and well-being under 10233,10-220,10-220f, ~7~101,10-2224, and.10-221.
7. Az all material. times hcxein,the Defendau~ THE TOWN,acting through its agents at the
aJeen~dant,'z'HE BOARD,and along with the Defendant THE SANDZ''NOOK
RT.F.MENTAR'Y SCHOOL.,under tlae regviceaients of CGS 10-220finsdeueed school safety
policies and procedures which left no area for discretion by its i~aplementers, concerning the
safety ofthe schools in the NEWTOWN I'UB~,IC SC~OOI,district, including the "lockdown." and e~vacuatio~t ~J.an previously practiced in a "drill" setting, but nero~ex be~ose
implemented by the SANDY TOOK FL.El~EN~'ARX staff; prior to nor on the Decembrr 14,
2012 incident at TFiE SANDY HOOK ELEM~TARY SCI~(30L the failure of which to
i~zz~plement same,resulted in. the death o~ twenty (20) students,including,~ESS~ X,EWIS,in
violation of C.Cr,S. 52-557n.
1.5
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21. The befendant,T.I~~ TOWN,actixtg through its ag~ts at the Defendant,THE BOARD,failed
co provide the S~N~7Y HOpI~ ~LEMENT.AR"St SCHOOL w:ttkl a secuze fxont entrance,
leaving a ~.on-security glass window,witki measufemrnts of nearly rh,~ee (3)feet wide by foot(4)
eet high directly next to the locked doors ofthe school; essentially read~xiug the locici~ng ofthe
school doozs ir=elevaat and impotextt iu the school"dock-down" plate,in violation o C.G.S.~52557a.
12.'rhe Dcendant,THE TOWN,actimg through its agents at the Defeadan~ TT~iE BOAR]:),failed
to follow or p=ovidc;its school systems with the necessary too] to implement the security and
safety guidelines w}uch THE BOARD,~'~IE TOWN and SANDY Fi00I{ELE1I~~NTARY
5CHOOL implemented and made a ministpnial duty that left no room foz tlisczetion by the
S.ANDX HOOK ~MENTAR'~'SCHOOL teact,ers and staff to effectuate im a time of
emergency,thezeby violating'Y'F~E BOARD'S,TOWN'S acid SCHOOL'S own.ministeaal duty
to provide a safe school envi=onmea~ which ie volnntatily under=ook but failed to follow after
implementing a minisLeria~, duty to do so.
13. The details of the Aefendan~ ~iE TOWN,acting through its agents aL the Defeadsunt,THE
BOARD,iz~isterial ~l~ were reduced to watin$ and bung on the i.~side of classzooms vvithiu
SANDX ki00K ELEMENTARX SCHOOY,on December 14,2012, but vacre impossible to
o~low because the DefendaaC,TH$SOWN,acting tl~uoug~i its agents at the Defendant,'ZT~
BOARD,had violated the conditions of san4,e by failing to ~=ovide adequate wining,
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su~esvision, and equipzz~esxt to implement said seGuritty pxocedu~es, thereby violating C.G.S.52557n.
14. The details o this plan left no discretion to the teachers or other employees and were to be
followed as outlined for the safety of th e ch~ilck~n at SANDY HOOK EI.EIvI~NTARY
SCHOOZ.,by mandate of the Defeudan~'~'~-IE TOWN,acting th=ough its agents ~t the
Defendan.~ T1TE BOARD,.
1.5. The Defendant bad a ministerial duty to take whatever p=ecautious necessary to protect the
P]aintifffrom his wrongful death ot~ December 14,2012 due to tbeit ow~a internal policies
codified in the Board oEducation's internal handbooks,polities, Qsocedntes, and other
codified rules and regulations conceauug student safety mandaeed under CGS 233x, ss~d due to
their acute lmotvledge and the spedfic danger the shooter presented to ehe identifiable victims of
the SANDY HOOK ELEMENTARY SCH40L when he shot out the front windows atad the
fact an intrude= was present o. tha school premises became appa=et~t
16. On December 14,2012, at appzo
FTFMF:NTARY SCHOOL weze ~ockcd fox the beginning ofthe school day tv secure tb,c
school as they typically weze o~ e~*cty other day.
~7. Z,ocated directly to the right side ofthe locked fro~tt doozs of the school was anon-safety glass
window wiCh dimensions of appzoxymately three (3) feet in width and four(4) feet in hei~lit.
18
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c]assxoom (10), his First gtad~ elassxoom fo= the school boo=s of the day, as a student ofthe
SANDY HOOXC F,~EIVC~Nx'AR"~'SGHOOL,which is a public school,
19. At approximately 9:35pm ADAM LAN7..A, shot out ehe window located next to ehe locked
school. doors, and wined easy access to SANDY HOOK ELEMENTI~,RY SCHOOL.
20. The main office staff reported hearing glass breal~iug aid guns}aoty at app~coxizrxately 9:35 ate, and
sary a wl~te wale with a hat and sungL~sses,later identified as ADAM I.ANZA,come into the
buildxc~g with a zifle-type gusx;}ae was seen shooting the rifle down the hallway where JESSE
LEWIS'classroom was located..
21. ADAM LANZA shot down the ballwap at the principal and o~hes sb.ff at this time and killed the
pxiaapal and the school Psycholog~.st who ]gad e~ated conference room 9 at the end of'the
hallway to see what the loud banging (gu~.fixc) noises were; a]l were attending a ~Lznnin~ and
pLlcement mcetin~ with other staff members and a student's parents.
22. A staff z~,e~nabez standing behixxd the priu~ipal end school Qsycholo~st was shot in. the leg; but
remained prone on the ~rvund for a moment befo=e crawling back into conference room nine
(9) and made a call to 9-1-1 also immediaCely t~us~iug on the school isatescozsi system through the
phone located is room nine (9), which a]Iowed orizer areas of the school to hear what was going
on in the building.
19
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23. ~1D1~M LANZA then entered the mama office to the school, vrhese all srafznembers wexc
k~idiug wiehin the of~ice;11DAN~ I.ANZA exited the sc}~ool office; and t~en he entered the
sek~ool office a,~ain; duritlg which biq~e no shots were fined and thef~ was a lullin the ~v~lfire.
24. After ADAM LANZA'S second exit from the ~aair~ office, the o~bice stiffimmediately callc;d 91-1,
25. ADAM LAN7..A then entered the unlocked dooxs ofclassrooms eight(8) and thin ten (10), the
fit~t grade classroou~ ofSANDY I~OOK ELEMENTA~tX SCHOOT..
26. At the time 11ll.A1VX X.ANZA ente~ted these rooms, no doors bad been.locked, none of tlae
children had been moved to a safe location,like the bathroom located inside both of these
classrooms; batluooms which could bo ~oc3ced from the inside,
27. Neither classroom eight (8) non classroom ten (10) had ~utemallocks to their doors; the only
way to lock these doozs was to lock them from the outsxtle with a key; despite hearing the
gmashots that broke tl~e glass window,the gunshots tlxat 1~lled the principal and school
psychologist; the gunshots that mounded the othear Stuff member ~w~o opened the ~rttercom
systeiu from confe~zence room Witte (9); oz the lull in gunfire t]~at tzar~spi=ed in the time ghat it
took the intruder,~A1V,[ J_,ANZA, to investigate. the main office before re-entering the hallway
and opening the unlocked doors Co classrooms eight(8) and ten (10); thereby effcctivelp no
classroom doozs were locked in accordance with the aosementioned Iock-down ox evacuation.
pxocedutes established by THE TOWN Off' NEW'TOWN,T IE BOARb OF EDUCAT.~ON,
20
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and TIDE SANDY NOOK EI,~,MENTARY SCHOOL,aad weze the=eFo=e not followed in
classzoozns eight(8)and tca (10).
28. Class=oom eight(S) was occupied by a substitur.~ tcachet who ~.d neithex a key to lock the door,
nor aup l~uowledge or ~ainitig =egatding the aoremcniioncd safety and securiry pzotocols
xec~ady rehearsed at SANDY HOOK F~.F~M]ENTIIRY SCHOOL in case an intruder or other
dangerov.s individual wined access to the school
29. Upon entering classrooms ei~zt(8) and ten (10) the.ADAM LANZA lolled twenty students and
four adults befo=e tal~ng }vs own.]ife outside classroom ten (10).
30.,~~SSE LEWIS was one of the twenty(20) students killed.
31. On ]~eccmb~ 14,207.2 THE TOWN,acting through its agents at the Defeadan.~'I~L
S0~1RD,failed to adhere to the maudatorp safety policies a~sd pxoceduzes which they
implemented, making them ~ix~3.ste~aai ~.natu re, in oz~c ox moxc o the following ways rbereby
causing the w=ougful death ofJESSE LEWIS and ohher damages set Forth herein:
a.
ThCy ailed to pzov~ide SANUX ~OOIC ~',L$MI;N~'.ARX SCI~OOL with doo=s chat
could be locked from the inside.
b.
The Plaintiffs bring this action pursuant to 52-555 ofthe Connecticut Genexal
Statutes.
c.
They failed to train and supervise the staff at SANDY HOOK ~T.EM~NTARX
SCHOpL oa the proper way to implement the lock dawn and evacuation
27
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They failed to provide certain teaehe~s with keys to the c]assxooz~cas to at~empt co lock
tbic dooxs to the classroom,wku~h eould only be locked from the outside with a key;
e.
The failed to pzov~ide a security guard, or anp othe~c tyke of]aw eafo=cement
personnel to assist:~ the implementation of tb~e policies and procedures should an
intruder entcz the building;in violation of CGS 52-557n
f.
They left the school exterior unprotected from intrude=s by leaving a three (3)foot
wide by four (4) foot high non-security glass window located directly next to the
locked doors o t}~e school; essenriallp rende~ot~ng the locking of the school doors; a
cz~,andated requitement instituted by the Defendant 7HE TOWN through its agents
at the nefendanr,THE I30A~iA, a useless and purposeless gesture ~.violation of
CCS 52-557n;
g,
They failed to follow their own g~uideiiaes receding school safety which they
established in. accordance ~vich Connecticut General Statutes 10220, 10-220f and
10-221 ~vk~zch became ministerial in nattue once established, by failing to provide
adequate equipu~ent and training to the staff and personnel ofSANDY NOOK
ELEMENTAItX SCli00L in violation of CGS 52-557n;
b,
'~cp let the teachers and staff with. r~o discretion in implementing the policies and
psocedv=c~ for a Iock-down and evacuation if an intzuder entered SANDY HOC7K
22
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'Y'he harm to which JESSE LEDJZS was exposed was imminent in that xt was iso]ated
to the collection of minutes from why the ADAM LAN7..A shot out the front
window uati~, he ultimately committed suicide; and vc~as restricted to Chc area in which
JESSE LEWlS and lus dassm~,ces wcre located in chefs classrooms in that tlYe
teachers aad staffin his classzoom were we11-awaze ofthis irr,rr~e~t ha~a as guar
shots had Veen firing down the hallway outside the door to JESSE L~WIS'S
cla.ssroozn lolling both. the school principal at rlae cnd of the hallway,the school
psychologist at tlac end o~the hallway,and ir~Jurin~ at least one shaftmembcz at the
end ofthe hallway; therefo=e the teachers) i~a JESSE LEWIS'S classroom ~rere on
notice that an imminent Kama was present to the idextifiable victims ~ the
classroom but could notimplcmmt the mandatory s~cw~ty guidelines because TXTE
TOWN through its agents at t}~e Aefeadanr,THE l',OARD failed to provide
adequate equipment and resources to do so in violation o CCrS 52-557n; anti
j.
The danger was apparent to JESSL~ LEWIS'S teacb.er(s) iu that it was easily observed
and understood that ~unfirc dowzx the hallway oatsic~e the classroom door would
expose the ehildcen inside to au immediate and Lu~;deniable danger, and the teacher's
failure to act to lock the door or otherwise follow the lock-down,procedure would
23
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31. As a result ofthe shooting and failuze to Follow the proscribed pxoLoco~s,J~55~ LEWIS
suffered massive uajuties and death.
32, J~SS~ L~VrItS svfcxed both pk~y~itcally and mentally prior to his untimely death.
33. THE ESTATE OFJL~SSE LEWIS in.~arted both medical expenses and burial and funeral
e~cpeuses, a~ a result of the events Following the shooting
34. Because oFlus death,JESSE T.~WIS' capacity to enjoy life's activities and have a family were
completely and petcnanently excitnguis)aed; and
35. JESSE LE'~!S was a studious and dedicated student who's life was cut shore befoze he could
~ii3h kus educauor~, begin a career, as~d he thexeoze lost a lifetime of ~otearial ear~i~ags, and the
opportunity for the participation in a lifetime ofexperiences and enjoyment
1. Plaintiff, SCA1t~,~TT L~WIS is rho duly a,~~ointed Administxatcix of the ~st~tc o her son,
JESSE L~WIS,NAIL HESLIN AS CO-ADMINISTRATOR ofthe estate (hereinafter,"JESSE
LEWIS'~.
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Fr.FMFNT,ARY SCT~OOL were locked for the beg~mning ofthe scb,00l day as putt of the
afozementioned safety policy established by the'SOWN,TIDE BOARD.and.THE SCI~OOL.
3. T.ocated di=ecrly to the rig~e side of the locked front doors of tlae school vvas anon-safety glass
window with dimensions of app=oxim.1tely three (3)feet in width and four (4} feet in height,
9. JESSE LEWIS was located wit}vn the school building at 9:30am ova December 14,2012,iai
classzoom (10}, l~s Fi=st evade classroom foz the school hours of the day, as a stud~t of the
SANDX HOOIC F,I,EMENTARY SCHOQL,which is a public school.
10. At approximately 9:35am ADAM X.ANZA shot out the window located next to the loGlcec~
school doozs, and gained easy acee~s to SANDY NOOK EI.EM~NTARY SCHOOL.
11. The znaiu office Staffreported bearing ~as~ bzeal~ng and ,gunshots at a~pzoa~mate~y ~~35 am and
saw a white male with. a bat and atu3glasses,]ater identified as ADAM LAN'ZA,,come ixxto the
buildingwith arifle-type gua; and buns seen shooting the rifle down the hallwaq where~ESS~
LEWIS'cL~s3;oom was located.
12. ADAM LA.N7~A shot down the hallway at the principal and other staFf at this tame and ]vAed the
principal azid the school psychologist who had sited conferr~ce room 9 at the end ofthe
hallway to see what the loud banding (gwzfire) noises were; all were attending ~ planning and
placement meering with other stafEmembets and a student's parents.
13. A staff member standing behind the principal and school psychologist was shot in the 1~eg; but
remained prone on the ground for a moment before crawling back into coxaference xoo~m nine
26
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s~ztiocz~oz:
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(9) and made a call to 9~1-1 also immediately tuaniag on the school iutexcom system through rbe
phone located in room nine (9), which allowed other areas of the school to hear what was going
on in the but~ding.
14. ADAM I.ANZA t1~en entered the main of6ee to r]l~ school, where all staff membexs wexe
hiding within the o~5.ce; A:p~ T~A.~7rA recited the school office; and.then be entered the
sclaooa office agaita; during v~rhich Lime no shots were fired and these was a lulliu the gunfue.
15. Aftex AY~AM LANZtI'S second exit from the.main office, the office staffiuunediately called ~1-1.
16. ADAM LANZA then entered the unlocked doors of cLl~srooms eight(8) and then tea (10), the
first grade classrooms ofSANT~Y HOOK ELEMENTARY SCHOOL.
17. At tk~e titre ADAIv~ LE~NZA aater~d these rooms,no doors had been locked, none ofthe
children had been moved to a safe location,like the batbsoo~tn. ~oc~ted absidG both of these
classrooms; bathrooms which could be locked from the inside.
18. Neither classzoom eight(8) nor c]assroom tea (10) had int~allocks to their doors; ttae only
wap tolock these doors was to lock them.from the outside with a key; despite hearing the
gunshots that broke the glass window,the gunshots that killed the principal and school
psyeholo~st; the gunshots that tixrounded the other staff member who opened the intercom
system from conference room nine (9); or the lull itz gunfire that transpired iu the time that it
took the shooter to investigate the main office before ie-entering the hallway and opening the
unlocked doozs to cla~szoom~ tight(8)and tcn (10); thrseby effectively no eL~~~zoom doozs were
27
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They failed to dock the doors to tb,e classrooms eight(S) and ten (10) to p=e~r~~t the
ADAM LANZA access to those looms yn violation of Connec~.cut General Statutes
52-557n.
28
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b.
The Plaint~'f brings t~sis action pu=suaut to 52-555 of tb~e Coattecticu~ General
Statutes;
c.
They faiJ,ed to take the students to a safes location,witbau t}~e class=oom, such as the
batl~soom; vahicb. had an ixatez~aallvcl~n~ mechanism to tb,~ dooz;in violation of
C.Cr.S. 52-557n;
c1,
They did not or could not take tlae necessazy efforts to follow the man;d~tory "lockdown" or evacuation ~xotocols, xr~ violation of C.Cr.S. 52-557n;
e.
'they load run drylls days ear]ier to prep~xe fox such a contingency and did aotfo~ow
the p=otocoJs and pxo~eduzes outlined.in the manda.torp safety pzocedures, or
practiced in the dxills, despite having no disc.Letion in enacting Ck~ese proscribed
safety measures,in violation of C.G.S. 52-557p;
They did not, ox were unable, to take steps to ~rotGc~ secure, or otherwise prevent
the ~dlling of ehe decedent, despite bavistg adequaxe notice th~z as intrudez way on
premises and inflicting morn],wounds to staff and personnel pf S.ANDY HOOK
FT.~ME~7T'ARY SCHOOL;despise having a lull in the shooting within which the
"lockdown" proccduxe touid have been effectuated as demaaded by the p=otoco~
and despite having a ~Lv~.in place for just such a contingency,ire violation of C.G.S.
52-557n;
g.
By failing to pzovide the scaEf and other agent o SANDY HOOK E~EN~NTARY
p to itnplemerit Che safety PrOLocp13,
SCHOOL with tie necessary tools and rr.:~+ni
29
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such as keys to the doors iu order to lock same,the "lockdown" and evacw1t~or~
plan itself, a secure building without access fo= trespassers once the dooxs were
locked, ar~d va~idvs otbiex tools and information which would lave allovced the
teachers and staff ofS.ANDYHOOK ~.T.,EMENTAI~Y SCHOOL iu rooms eight(8)
and tea(10) to follow the proscribed safety and lockdowny pxoceduzes,is violation
of C,G~.S. 52-557n
b.
i.
The teachers had no disetetitr~a .im enacting the policies and p=oceduies fox the safe
"lock down" and evacuation of the schoolif a trespasses or other dangerous and
improper individual entered school p=opertp by ehe mandates o tt~e safety policies
and procedures set forth by THE TOWN Off' NEW~'OWN,THEI30ARD OF
EDUCATION and THE SAN17Y TOOK F..I,~MLNTARY SCHOOT..;
j.
The hams to which JESSE I.EWIS was exposed was ~rn*~~++~~nt is that it was isolated
in time to the coIIection of minutes from when AT3AM LAN7~A first shot out the
front window unto he vltimatelp took his own life; and was restricted to the azea in
which JESSE LEWIS and lus classmates weave located iu their classrooms;in that the
tc~ch~rs and other staffin his class=oom vc~ere wr11.-aware o this immiuen~ basin ay
IC11]
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guu sk~ots h~,d been fisiag down the hallway outside the door co]ESSE LEWIS'
classroom killing both the selzool purtcipal at the end of the hallway, tb,e school
psychol.vgist at the end of the hallway, and injuring at least ozze staff member at the
end o the hallway; therefore the teachers)in JESSE L'~VV~S' classroom were on
notice that az~ imnunent ham was p=went to the identiflble victims in. their
classroom; ar~d
k
The flange= was apparent to,~ESS~ LEWIS'teache=(s) and orhex st~f iti his
class=oom in that it was easily obsetro'ed and understood rh3,t gunf~e down the
hallway outside the classroom door would expose the c}a~ildren inside same classroom
to an immediate and uudeuiable danger, and the shf{'s fstil~ure or inability to act, to
lack the door or otherwise follow the lock-do ves pzoceduse would undeniably place
the studer~.ts, includingJESSE LEWIS,in immediate danger.
2~. As a xesuit of the shooting and axtuxe by the TbWN OF NEWTOW~T,NEWTOWN BpARD
OF ~Y,JCA~ON and St1NDY HOOK F~.~MEN'Z'A,~LX to foIlow the proecdbed p=otocols,
JESSE LEWIS suffex~d massive injuries and untimely death.
22. ~'~SS~ LEWIS suffered both physxcaUy ar~d mentally prior to his unxime~p death,
23. T'HE ESTATE OF JESSE I.EWIS incurred both medical expenses and bw9a1 and funeral
expenses, as a result of the events following the shootyng.
31
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24. Because oflus death,JESSE ~EWIS'capacity to enjoy life's activities and have a family wezc
completely and pe~anendy cxtingvished; and
25. JESSE LEWIS was a studious aad dedicated studanz whose life was cut short before he could
Fnis~ his education, and/or begin a cazees; at~d he therefore Iost a lifetime o~ potential earnings,
and the opportuuitp for the participation in a lifetime of cx~etieaces and enjoyment.
32
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SANDY
public schools'
ofstudents
ovetse~ing
incluclizag,
l
school adz4inistrators' m~+nagcmeut of day-today opesati,ons ofindividua schools,
SANDY HOOK ELEMCNTARY SC~IOOL,and acting as liaison between
the individual
s, or repzesentativ~s,
PLT$LIC SCHOOLS'
esn~loyee, or other
OF NEWTON.
al duty
33
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to do so vt~der
and well-bung under C.G.S. 10-233,10-220, 10-220 and ~0-221, ~d failed
C.G.S.52-557n.
iremeA~ of CGS ]0-
discretion by xts
220finstituted school safety policies and proceduzes which let no uea foz
staff
including the "locl~-dowta." and evacuation pLzu pxeviouslp practiced, but nev'ex
Deceu~bcr 14,2012, by the SANDX Ii00K F~.EMENTA,R'Y st~.FE; the
imQlemeuted on
~ail.uie of wltick~ to
ER
ivaplement resulted in. the death of twenty (2Q) students,including NO.A~I POZN
SANDY HOOK
8. The Defendant,l~iE BOARD,failed to provide the staff of
SCHOOZ.with the necessary iufoanat~on, tools, a.ad training Co properly
ELEMENTA~Z'Y
B01~1RD and
FIOOK
~izovide a substitute
~s,
9. 'x'lae Defendant,'~~ BOARD,thxoug~i.its agcat~ and employ~ failed to
teach,or teacbex,in classroom eight(8) or test (10) wirh a Jeep to lock the door to said
evacuation plan the
classroom, or the proper traiuuag zcgarding the mandatory "lockdown" amd
teachers were to follow should au iauude= eutex the school prez~tises, ma]~ng
it is:xpossible for
said substituee teacher oar t~achex to follow the mirvstezial duty ofimplem
34
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HOOK
and the
nt and
daagex to the idendfaable class ofvicrims in rooms eight(8) and ten (10) beca~o.c ~~+*n~ne
L.
OF NEDilfOW1~T,
to the even
ttxe innvdes,
s
the mivai.sterial duty dflocking dowrx the school and evacuatung st,~dent when
ADAM I,AN7.~A'S, pxeseuce became unmistakably know,x,and ehe dangex to
the identi5abl
t to the
class ovictims in rooms ei~he~(8) and ten (10) becAmc +r+rr+~nent ar~d readily apparen
n.
O~ NEWTOWN,
ailed to provide the SANDY HOOYC ~tEMENTA.RY SCHOOL with a secure front
leaving anon-secutity glass window,witb~ measurements of nearly three(3)
eet high directlp next to the locked doors of the school; essentially zendesiag the
school doors at the outset ofth e school day iaelevant and impotent in the
entrance,
locking of the
effectuation of the
A,and
n.
35
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OF NEWTO'W~T,
implement the yecw~.ty and safety guidelines wbi~ch THE I30ARD,THE TOWN Off'
atcd in case an
intruder gained access to the school ~xounds,and thereby made a ministerial duty' tk~at left
no
staff
eva.cu~tion flan
nts
w~s created, but which vcas rendered itnpossible to fouo~uv, with soma p key compone
missing for a successful implementation, after cseatin~ the ministerial duty to do so, all
in
cmployces
and were to be followed as outlined foz tl~e safety of the childtcn at S1~1NDY HOOK
~IpOK
~I;EM~NTARY SCH04L,by mandate ofTI-i~ BOARD,~iE TOWN and SANAX
ELEMENTARX SCHOOL.
74. The Defendant had czcat~d a ministerial dutp for all employees, agents and members to take
whatever precautions necessary and enumerated is~, the safety procedures set forth by TkIE
BOARD,THE TOWN OF NEWTOV~N,and'I'IIE SANDY HOOK FZ.F.1ViENTARY
SCHOOL,to protc~t the Plaintifffiom his wrongful death om Deccmb
36
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~xeation of they ovva intealal polZcies codified vn the Board oEduca~on's internal handbooks,
polieies, procedt~es, and othez codified rules and regulations ~onceming student safety
mandated udder CGS 233x,and due to t}~teir acute 1~lowledge of the imminent and apparent
harm the intxudes ADAM LANZA p=eseated to the identifiable victims ofthe S,E~NDY HOOK
ELE~EI~TTARY SCHOOT.when he ~xst shot out tlae coat windows o the school on
Deccmbec 14,2012; at which time the fact an intzudcz was present ort t ie school premises, and
the fact that the identifiable vaet:ums were in an uuminent bazm became appaze~t to tk~e staff,
agents, employees and members ofT IE SANDY HOOK EL~N~IVTARY SCHOdL.
15. On December 14,2012, at approximately 9:30am,the front doors ofSANDY FxOOIC
ELEMENTARY SCHOUT..weze locked for the beginning of the school daq sus part of the
aforementioned safety policy established by the TOWN,TF~E BOARD and THE SCHOOL.
16. Located directly to the right side of the locked -~ont doo=r ofthe school was anon-safety glass
window w~tth dimensions of approximately three (3)feet in width azrd font(4) feet in height.
17. NOAH nOZNER was located within th,e school building at 9:30am on December 14,20 2,in
classroou~ (S~, his Fi=st grade class=oom for the school hours of the daq, as a student of the
SAN]JX NOOK ELEMENT'AttY SCHOOz.,which is a public school.
18. ~t approximately 9:35am AllAM LANZA,shot out the wvadow loc~.ted _next to the locked
school doors, and gained e~y access to SANDY BOOK ET,EMENTAItY 5CHUOL.
19. ~'he main office staff reported hearing glass bxeal~ng and gunshots at appxo~mately 9:35 am as~d
saw a white male with a hat and sunglasses,later idenrified as ADAM LANZA,come into the
37
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:wd~ti:z~:5i-so-~o
located,
other staff at this time and killed the
principal aad the school psychologist who had exited confere~acc room
hallwap to see what the loud banging (gvn&te) noises were; alI were
on in tk~e building.
22. ~AAM Y.ANZA then entezed tl~e mai~,~. vfhce to the school, where
hiding ~vit~iiu the office; ADAM Y.ANZA exited the school office;
school office agutt; during which time no shots were fired
23. After ~D.AM I.AN7A'S second exit from the main of5ce,
~,-1.
oms eight(8)and rhea teas (10), the
.RY SCHOOL.
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way to lock these doors was to lock them zom the outside with
~u~;s]~ots tJiaz broke t}ae glass window,the gunshots that killed
~4A1t1D OF EAUCATION,
four adults before tai~ng his own life outside classroom ten (10).
39
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~~ZtiOLZ~OZ~
,WdLb~Z6,96-60-d0
to
SA,Np''Y
causing the
wrongful. death of NOAH POZN~R and other damages set forth hex~iu:
~.
They failed to provide SANDY HOOK ~.I.F~NTARX SCHOOL with doors that
could be locked froze the iaside thereby malting the "lock down"portion of tl~e
safety protocols virtually impossible to follow,in violation of C,G.S. X52-557n.
b.
The PL-~ara~iff brings this action pursuant to 52-555 ofthe Con~aecrieut Gen.esal
Statutes.
c.
FN7'~y
They failed to train and supervise the staff at SANDY HOOK F'.r:~M
SCHOOL on the Qrope= way to implement the "dock down" and evacuatio.
proceduLes as iastitutcd by,TIE BOATtD THE TOWN OF NEWTOWN AND
'Z'HE S11NDY KOOK ELEMEN'Z'Al2Y SCHOOL for ~atuations precisely life the
one that presented itself on Decembez 14,2012,in violation o~ GG.S. 52-557n;
d.
They sailed to provide ceztain teachers with keys to the classrooms or uai~~g oz
info~atiot~ coace+~ir,g the "lock down procedure" thexebq mal~ng ifi impossible to
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,~
even attewpt to loc1~ the doozs to the cL~.sstooz~, which could os~lp be ~o~lced from
They Failed to pzovide a security guaid, or anp othtx type of Lzw enforcement
personnel.to assise in the implementation oftie policies and procedures should an
intruder enter the bca:tld~ng, while leavi~ag a Loge enough non-safety glass window
dixecdy to the right of the Locked outer doozs of the school; making access to the
building ielativelp sisx~pJ.e, and successful "lock down" of the building v~rruallp
impossible,in violation o Q.G.S. 52-557n;
f.
They ~et the school exterior unprotected fto~ intruders by leaving a slvrec.(3) foot
wzde by four(4)foot high non-secuzity glass w.iadow located directly to tla~ .tight of
tl~~ locked exterior doors o the school; essentially rendean~ the locking o the
school doo=s; a mandated requirement icastituted by THE BOARD,THE TOWN
OF NEWTOWN az~d SANDY HOOK EL~,MEN"rA~Y SCHOOL a useless and
purposeless gestuze in violarion of C.C.S. 52-557n;
~.
Tbep failed to follow their own guidelines re~azding school saetq which THE
BOARD THE TOWN,and THE SANDX H40YC ~T..EMENTARY SCHOOL
established in acco=dance with Connecticut General Statutes 10-220, 10-220fand
10-221, which then became ministezial in nature once established to all agents,
employees,and meuabexs of the BOARD ~t~,d TF~E SANDY HOOK
ET.EMLNTA~iY SC~IOOL,by faiiiug to p=o.+ide nd~qu~xe equipa.~eac axial oraicung
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Thep left the teachers arad staff with no discretion in implem~.txng the policies and
procedures fora "loch-down" auc~ evacuation if an vntrudex cntesed SANDY
~IOOXC ELEMEN'Z'.A~fiY SCHOOZ,,but failed to provi,dc the same individusils with
the p=Dyer equipmenr, building security, aid trai~.iwg to effectuate the ministeria).
duty of following the safety protocols,in violation of g52-557n;
i.
The harm to which NOAH POZNER was exposed was immis~erat in that it was
isolated to the collection o times from w~ea the shooter shot out the front window
until he ultitnatcl~ committed suicide; and wras geogzaphically =estdeted to the area in
which NOA~k~ r0"LNER and his classmates we=e located in their classxoozc~.s;in that
Che teache=s and stafin lvs classroo~a were well-aware of tlias~ +**+TM+~~eat hazm as gvn
shots had been 54ting down the hallway outside the door to N4A~ POZNER'S
classroom killing both the school principal ~t the end of the ballwa~r, the school
psychologist at the end of the ha]lwap, and injuring a~ least o~ae staff member at the
~z~d a the hallway; therefore the teachers) is~. NO.AF~ POZNER'S clrassxoom were
on notice that a~a imminent hazm was pzesent to the identifiable vicrivas in the
classroom but could not itnplcment the maudatorp security gnideliaes because the
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n of
The daugcr was appaxent to NOA~i POZN~It'S teachers)in that it was easily
om doo=
observed anal understood that gunfire down the hallway outside the c]asszv
would expose tk~e children inside to a~.immediate and undeniable daaer, and the
teac~zer's failure to act to lock the door,iu. pmt because the substitute was not
pzovided with a key to do so, or otherwise follow the "lock-down" axed eva~tion
~ce,
the
teachers and other staff, ag~ts and employees could ~.otimplement the mandatory
sc;cwity guidelines because the BOA1Zb failed to pxovide adequate equipment and
z~sou=ces to do so.
follow tt~.e
31. 1~s a result direct o~the failure to provide the necessary equipment and wining to
,
to gain access to
NQAH POZNER'S classroom and same ~ilute resulted in the shoot~ag and failure to
follow
the prosc~tbed protocols,thezeby leading to NOAH POZNER suffezing massive fatal injuries
and death.
32. NOA~iPOZNE~t suffered both physically aid mentally prior to his unrimely
death.
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~ttD POZNER AS
FIFx'~~OUNx ('rX-~E ESTATE OP NOA,~X POZNE~,LEON
~
O'ViT
NEWT'
ADI4SINTSktATROR,against T~TE'~'OWN OF
r o the Escate of his son,
isrrato
1. Plavitif, LEONARD POZNER is the duly appointed Acivaia
NOAH POZN~t,(heseinaftex,"NOAH ~'O"LNER'~.
ed to as "T~I~
chiidrea located rhe=e~u from grade sclsool through high school; as~d
101.
3. A.t ell mate~al tix~aes herein, DAVID FLEISI~.A.N was the
'OWN OF N~W~'UWN'S
nating,imp~cmeutiu~, anti
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i ~~
supNxwision, operation,
rep=esenretives, who wexc responsible oz the c=eatioz~, maintenance,
rd by the Defendant,THE
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~WdLti~Zl~96-60-LO
allegaroions, investigations, penalties, and to ensure student sa~ery and well-being under 10233, 10-220,10-220f,17a-X01,10-222d, and ~0-221.
at the
7. At all material times hexein the Defendant,THE TOWN',acting through xts agents
Defendant,THE BOAR'['),and along with the Defendunt'z'HE S~N'DY HOOTC
ELEMENTARY SCHOOL,ua~der the requirements of CGS 10-220~Einsdtu~ed school safety
policies and procedures which left no area fox discretion by its amplementess, concerning the
safety of the schoolszn the NEWT'OV~10T p'UBLIC SCI~OOL distact,iricludiztg the "lvckdown" and evacuation pL~,~o. previously practiced in a "drill" s~tti~ng, but never befoae
imple~cnted b~ the SANDY HOOK FZF1viENZ'.A.RY staff; prior to noz o~ the I7~cember 14,
2012incident at7HE SAN]~X ~IOOTC EI,EIv~ETARY SCHOOL the failure of which to
in
impleme~.t scene, resulted in the death oftwenty (20) students,in.duding, NOAH POZN~.R,
violation of C.G.S. X52-5S7n.
8. The Defendau~ TliL'Z'O~T,acting th=ough as extension ofitself, the Defendant,THE
BOARD,filed to provide the staff oSAl~TT~Y HOOD ELEMENTARY SCHOOL with xbe
necessary informarion,tools, and uaiaing to properly implement the safetp pxotocols previously
established by ~i~ BOATtD,THE'Y'OWN .A1~17 THE SANDY HOOK ET.EMNTARY
SCHOOL iegazding intxudexs on the SANDY Ii00~C.F~.EMENTARY SCkI00L grounds,
making it so that TF3E SAt~TDY HOOK ~,LEIvi~NT1~RY SCHOOZ.staffwas unable to
implement said secarity protocols on December 14,207.2 when the intruder entered the
btti~dv~g,as violation of C.G.S. 52-557n~.
a~
as ion #
E~ZbOLZ~OZ~
,~vdc~:z~:~~-so-io
BOARD,failed
9. The Defet3da~at,7'fiE TOWN,acting throvglx its agents at the T~efend~.nt, TIC
to Qrovide a substitute reacher, of teacher,in classroom eight(8) ox ten (10) with a key
to lock
the doox to the classroom, oz the proper fxaining =egarclis~.g the mandatory "lock-down"
and
evacuation plan the teac,~cxs were to follow should au intzuder enter the sebool pzemises,
mal~ng it impossible fo= said teacher to follow the ministerial duty ofimplementing the safety
protocols Wbet~ the intruder's prc3ence became known,in violation off'C.G.S.52-557n
r,2HE B01~,wiled
d
to provide the SANDY HOOK F~T.~.MENTARY SCHOOL vrich doo=s to the eves. n,smbere
classrooms that could be locked from the inside, and bad to be Iocl ed from the outside by use
of a key, thereby m~lan~ it impossible o= the teacker3 ofSANDY H40K ELEMENTARY
SCHOOL'to follow the miz~isterial duty ofdocking down the school and evacuating studct~ts
.
wk~en the intn~der, AI~.P~M LANZA's,presence became ~oavn in violation of C.G.S. 52-557n
by font(4)
ect Iugh directly next to the locked doo=s o~the school; esses~tiallp x~ndcriag the Ioci~n~;ofthe
School doors irrelevant aa~,d impotent in the school"lock-down" plan,in.~ioladon of C.G.S.52557n,
,failed
~2. The Defendant,~E TOWN,acting rbsov~gh its agents at tlae T~efendant,THE BO1~Ii.D
to Eollow os pxovid~ its school systeu~.s wzth the necessary roofs to implement the serenity
and
47
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ELEMENTAS~Y
te in a time of
impossible to
the Defendant,THE
adequate training,
C.G.S.52-
557x.
es ar~d wece to be
14. The derails of this ~]an left no discterion to rb~e teache=s os vthet employe
ENTARX
followLd as ontli~ted fox the safety of tkxc children at SANDY HOOK 1~1.LM
the
T7efendant,THE B01~RD,.
15. 'Z'he T~efendar~t had a ministezial duty to take whatever ~recautio~ng
izitc~nal policies
Plaintiff from his wrongful death on December 14,20 2 due to their own.
es, afld other
48
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mandat
codifed rules and xeglilations coacerning student safety
a~pazent.
class=oosn {8), his rixst fade classroom for the school hoots of
school.
Z0. The main office staffzcported heaaiug glass b=eaking and gunsho
prindpal and the school psycholog~t who had e~eed confr~ence room
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,WdL~~zl~~~-60-10
,.
haU.way to see wk~~t the loud baug~g(gunfire) noises were; all were attending
a pLw.ning and
22, A staff member st~.a.ding behind the principal and school psyc.~.ol
rem~ed pzone on the ground foi a mozzaent before crawling back into
(9) and made a calf to 9-1-1 also immediately t'uming on the school interco
phone located iu rootxa zaine (9), which allowed otlaeic areas of the
hiding within the office; ADAM I.AN7~.A exited the school office; and
school office again; dutis~g which time no shots we=e feed snd rhete was a
24. After ADAM LAN7A..'S second eat tom the maim office, the office
fire.
dullin the
stiffimmediately called 9-
~-1.
25..AI~AM T~T7A then enee=ed tb~ unlocked dvoxs of elass=ooms eight(8)
L.
2G. At the time.ADAM I.ANZ.A entezed these zooms,no doors had been locked,
children had been moved co a safe location,]ike the bat~hxovm located inside
none of t}~e
both of these
the only
gunshots that broke the gLnss window,the gunshots that 1~lIed the priuci~a
SO
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~WdLb~Z6~~~-6Q-LO
~e
psycholo~sr; the gunshots that ~vouz~.dcd the otb.ex etaffznerabex wk~o opened the intercom
system frozxa cox~~ezeace room nine (9); or the lull i,~ gunze that ti:a~spired in the time that it
took the in~udes,ADAM I.t1NZA, to investigate the main office before re-cntcting the hallway
and apexaixag the valocked doors to classrooms eight(S) and ten (10); thereby effectively no
classroom doors were locked in accordance with tl~e aforementioned lock-down o= evacuation
p=oceduces established by T'I~ TOWN OF NE~'I`OWN,THE BOARD OF EDiTCATION,
and TFIE SANDX HOO~C ET,EM~N~'1~~tX SCHOOL,aid weze t}aerefose not followed in
classrooms eight(S) anti ten (~.0}.
28. Classroom eight($) was occupied by a subsritute teacher ~xrho }gad neither a kep to lock the door,
nor ax~.y I000wXedge or tzaining regarding the aforementioned safety and security protocols
recently teh~azsad ~t S,P~NDY HOOK ELEN~EN'Y'ARY SCHOOL is case an intruder or othez
dangerous indinidU.~].gainEd access to the se~ool.
29. Upon entering classrooms eight(8) and tea (10) the AbAM Z.AN7.~A lti]Xed twenty students anti
four adults before taking his own lift outside c~.sszoozn, tea (~0).
30. NQAH POZNER was o~ae ofthe twenty(20) students ki]led.
31. Oa December 14,2012 TOTE TOWN',acting through its ageanrs at the Deendattt, THE
~iOARD,piled to adheze to the mandatory safety policies and procedures which tG~y
implemented,malsin$ them au~istcrial. ~iz~ z~atuzc, in one or more ofthe following ways thereby
causing the wroagfiYl dcaCla of NOAH POZNER anti other damages set forth here in:
S1
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a.
b.
The P]aiatiffs bring this action Qutsuant to 52-555 of tlac Connecticut G~nesal
Statutes.
c.
Tb;ey failed to tc~iu and supervise the staff at SANDY HOC7K ES.EMENTA.lt'S(
SC~IOOL o~. the p=open way to implemexat the lock down.and evacuation
procedures as prosczibed by the Defendant,T~I~ TOWN through its a~euts at the
Defendatt, THE BOARA;in violation. of CGS 52-557n
d.
They failed to provide certain teachers with keys to the cLnssrooms to atteiupt to lock
the doozs to the classroom, which could only be locked from the outside with a key;
e.
The Wiled to provad~ ~ security guazd, or aap ot]aGx type oflaW e~afozcement
personnel to assist in the rmplemesttation of the policxos aad p=oceduxes should an
inuvdex enter the building,ita violation of CGS 52-557n
f.
They left the school e~ztetio= unpzotected from intruders Up leaving a tkuee (3) foot
vcrtde by four (4)foot high Hors-~e~urity g]ass wuadow located di=ecdy next to the
loclted doozs of the school; essentially rendering the Iockit~,g ofthe school doors; a
mandated requirement i~stitutcd by the Deeadant,'I~iE TOWN thtouc*h its agents
aC the l~efendas~t,T.FL~ BOARD,a useless and purposeless gesture in violation o
CGS 52-5S7n;
52
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g.
They Failed to Follow their own guidelines regazding school safety which they
cscablished in accordance with Cons~ectitut General Statutes ~ 10-220, 10-220f and
~0-221 which became z~~oist~cial in nature once established, by ailing to provide
adequate equipzz~eat and training to tk~e stiff and perso~cl o~SANDY HOOK
ELEMENTARY SCHOOL ~ violation of CGS 52-557n;
h.
Thep left tk~e t~achets and stafFwitk~ zoo discretion in iza~p~emeudng the polices and
p=oceduces fox a lockdown and evacuation if an in~ude~ entered SANDY Fi00~C
EL~N,C~NTI3RY SCHOOz.,but failed to p=ovitde r}~e same individuals with the
~soper equipment a~ad training to effectuate the ministerial duty of following the
The hazm to which NOAH POZNER bras exposed was i~taminentin thatit was
isolated to tiaG collection of ~iuutes fsc~m when t1~e AAAM LAN7~1 shot out the
coat window until he ultimately committed suicide; and was restricted to the area in
which NOAH POZIVER and his classmates were located in then classrooms in that
the teachers and staff ~. his classroom were well-aware of rbis imuw~c~t haz~m as gun
shots had been firing down.the hallway outside the door to NOAH POZNER'S
classsooxu lolling both the scUool principal at the anti of tb,e hallway, the school
psychologist at the cad of the hallway, and injuring at least one scoff member ae ehe
end of the hallway; thereoxe the teaches(s)in NOAH P~LNER'S classroom were
on police chat an imminc~,t harm was p=esestt to the identifiable vicdz~as in the
53
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c]assroom but could ~aotimplement the mandatory security guidelines because T.I~E
TOVt/N though its agents at the Acfendaut,THE B01LRD famed to provide
adtc~uate equipu~cnt and sesouxces to do so in violation oCGS 52-557n; at~d
j.
'The danger vas a~paseat to NOAH P07NER'S tea~bet(s) in that it vvas easily
ob.sezved and understood that gun5xe down the hallway outside the classroom door
would expose the children inside to az~,,immediate as~d undeniable dangex, and the
teachex's failure to act to lock tY~e doo= oz orherwise Follow the lockdown pzocedure
would place the students,includizxg N01\H PO~NER,iu imzxaediate danger but the
teachers could not umplement t1~e mandatosp security guides because TILL
TOWN through its agents at the Defendaut,'I~ZE BOARD ailed to provide
adequate equi~meut and xesouices to do so in violation of CGS 52-5S7n.
31. As a zesult ofthe shooting and failure to foIlow the proscribed protocols, NOA,~ T'OGNER
suffered massive injuries a~ad death.
32. NOSPOZNER suffccecl both physically asd zaennlly prior to his untimely deatki.
33. THE ESTATE ~F NO,AIi T'OZNER inc~ced both medical expenses and burial.and funeral.
expetlses, as a result o tlae eveut~ follovv~ng the shooting;
34. Because ofhis death, NOA4H PO~N~R'S capacity to enjoy 7ifds acrivities sand 2~.ve a family
were completely and peu~anendp extingv~isbed; and
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35. NOAT~ POZNER was a studious and dedicated student who's life vas cut short Uefore be
Could .finish his education, begin a career, and he r3z~reforc last a lifetis~ae of potearial earnings,
and the opportwlity fo= the partidpation in a lifetime of experiences and enjoyment
SS
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5. The details of this plan wcse rclaycd to school pessouzacl prior to December 14,2012, attd load
been rehearsed and practiced by sta and srudeuts days/weeks earlier in a "drill" fashion.
6. The decsi7s of this plan left no discretion to the teachers ox other employees ofSANDX ~I04XC
T,LEMNTARY SCHOOL a~ Co how it was to be ca:r~cd out and was to be followed as outlined
for the safety of the children at SANDY HOOK ELEIVIEN~'ARY SC~TOOL,as developed by
'Y'HE TOWN O~ NEWTOWN,THE BOARD OF EDUCATTOIV,and THE SANDY
HOOK ELE1V.[~,NTt1RY SCHOOL.
7, On Dcc~mber 14,2012, at appzo~omatc~ly 9:30an~, tYie Boat daozs of SANDY HOOK
ELEM~.N~'ARX SC~IOOL were locked foz the beginning of the school. day as dart ofthe
afo=emes~tioned safety policy esrabiished by the TODUN,THE BOARD and TIIE SCHOOL,
8. T.ocated directly to the right Side ofthe locked fzo~t doors of the school vas a aort-safety glass
window with dimensioas o appzo~dmately rluee (3)feetin width and four (4)feet iu height,
9. NOA,k~ POZNLTt was located within tlae school Uuilding at 9:30ami ot~ Z?~Gember 14, 2012,in
classroom (8), his F1cst grade classxoam for the school. hours of the day, as a stud~ut ofthe
S1iNDY HOOK ET_,LMM~NTA'F~Y SCHOOL,wYuch is ~ public school
10. At approximately 9:35am..ADAM LANZA shoe out the cviudow J.ocs~.ted next to the locked
sek~ool doors, and wined easy access to SANDY HOQK ELEMENTARY SCHOOL.
11. The main office staff reported bearing gloss breaking and gunshots at approximately 9:35 am and
saw ~. tvhitc male with a hat and sunglasses, Liter ideAdfied as.AD1~N1 LANZA,come into the
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s~ztioczsoz:
.WdLti:z~:~~-so-~o
building with arifle-type ,gun; and was seen shoovug the rifle down hhe hallway where NOAH
POZNER'S classxoosx~ was located.
12. AT7AM LANZA shot down tie hallway a~ the principal and other staff at this time and lfllled the
principal aad the school psychologist who had exited conference zoom 9 at the end of the
hallway to see ~l~at t}ae Loud banging (gun.6=e} noises were; all. were attendiuc~g a pla~ani~og as~,d
placement x~eeting with other staff members and a student's parents.
13. A staff member s~,ndiag behind the principal and school psyelaologist eras shot i~ai the leg; but
zPmn;,,ed prone on the ground for a moment be~oxe crawling back into conference room nine
(9) and made a call to 9-1-1 also imt~ediately turning on the school intercom system ttuough the
phone located in,zoom ni.a~ (9), Which allowed other azeas of the school to beaz what was goislg
on in the building.
14. t1DAM LANZA then entered the main o~fte~ to the school, where all staff members were
hicling verithin the office; ADAM LANGA exited the school office; ar~d then he entered the
school office again; during which time no shots were feed and these was a lull in the gunfire.
15..Ater ADAM LAN7~4'S second exit from the main office, rl~e office staffimmediately called 91-1.
1G. A~AAI1~ ~.t~T7~? them ez~texed the wn].ocked doo=s of classrooms eight(8) and then ten (10), the
57
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17. llt the.titnc.ADAM I.AN7r,A entered these zooms,no dooxs had been locketJ,~oae of the
children Ia~d been moved to a safe location,like the batluoom located inside botb~ o~ these
cL~,ssxooans; bahhxootx~.s which could be lo~tced from tl~e inside.
18. NeithNat classroom eight(8) nor classroom ten (10) had internal locks to tkxe~z doo=s; the otlly
way to lock these doors was to lock tlacm from the outside with a key; despite hearing the
gunshots that broke the ]ass window,the gunshots that killed tl~ze pzincipal and school
psychologist; the gunshots chat wounded the other staff st~ember who opened the intercom
system fronx conference room nine (9); of the lull in ~nwfue tb.~t transpired iu the time that it
took the shooter to inwesdga,te the main office before xe~entetiug the h~llwap and opeuirtg the
unlocked doors to classrooms eight(8) and ten (10); thcxeby effectively nd elasszoom doozs were
1ockCd in accordanec Frith the aforemcatioaed loci:down or evacuation pxocedures established
by'Z'~E TOWN OF N~'WTOWN,TS~~ BOARD OP EDUCATION,and THE St1NDY
X~QOK ELF:MEN`t'ARY SCHOOL.,end were th~re~ore not followed in. classrooms eight(S)
and tee (10).
?~9. Classroom ei~hc(8) was occupied by a subsritute teaches who bad neither a key to lock the door,
nor anp knowledge or txaaning =e~arding the aforementioned safety and security protocols
xecently rehearsed at SANDY HOOD F~.EMENTARY SC~YOOL in case an.antcuder or ocher
dangeaous iwdividual gained access to the school.
19. Upon eneeriug ra.~sszooms eight (8) ar~.d tea (10) the ADAM I..tiNZA lolled tac:nry students and
four adults befo=e
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20. NOAH POZNER was o~ae of the twenty (20) sCudencs lolled,
21. On Dcceznliec 14,2012 the S,A,I~T~Y HOOK ELEMENTARY SCHOOL,aegligently failed to
adhexe to the mandatory safety policies and pzocedutes, such as "dock-down" and evacuation,
est~b~ished Uy THE TOWN Off'1~TEWTOWN,THE B~1~RD OF EDUCATYON and THE
St1NDY k~,00YC ~T.EMENTARX SCT~OOL in one or xnoxe of the following ways t}~ieraby
causing the wrongful death ofNOAH P07NER and othex damages set forth hercit~c
a.
Thep failed to lock the doo=s to the ~L~sszooms eight(8) aad teta (10} to prevent the
ADl1M LANZA~ access to those rooms xa. vio]ation of Co~ecti~ut Gen.~acal Statutes
52-5~7n.
b.
'The T~]aintiff brings this action pursuant to X52-555 of the Connecticut Cyenesal
Statutes;
c,
'Whey failed eo take the studeats to a safer location vc~trhin. the cLzssroom, such as the
bathroom; which bad au antcmal locking mecha=tiszr~ to the door;in violation of
C.G.S. 52-557n;
d.
'T'hep dxd mot or could not take the necessary effox~; to follow the max~datocy "loekddwu" or evacuation pzo~ocol~,in. vio]ation of C.Gr.S, 52-557n;
e.
They had rua duets days ear~ez to prepare for such a contingency and did not follow
the protocols and pxocedures outlined in the ma.~cldatory safety procedures, oz
practiced in the chills, despixe having no discx~tion in. enacting these ~xoscribed
safety measures,in v;vls~rion of C.G.S. ~52-557n;
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f.
'Z'laey did not, or were usxable, to take steps to protect, secure, o=otherwise prevent
the filling of the decedent, despite hacin~ adequate notice that an intn~deL was on
pzemises and inflicting t~ox~il.wo~xrds to staff a.~d pexsonnel ofSANDY HOOK
ELEI'~IENTAR'Y SCHOOL;despzte haYing a lull in the shooting wat]x~ which the
"loch-down" procedure could b~awe been effectuated as desz~a~nd~d by the protocol,
and despite having a plan in place fox just such a conriagency,in vio~aCion o C.G.S.
52-557n.;
g.
By failsng to provide the staff a~ad other agents ofSANDY HOOXC ~.T,EMEN7ARY
SCHOOL with the uccessazy too]s and gaining to implement the safety p=otocols,
such as keys to the dooxs in oide= to lock satxae, the `~.Qck-down" and evacuation
pL-w. itself, a secure building without access for trespassers once the dooxs w~xe
locked, and vaaous otklez tools and information which would have allowed the
tearhexs and staff ofSANDYHOOK EI~MENTARY SCHOOL a~n =oozas eight(8)
and ten (10) to ~o~lovv the proscubed safety and Iock-down procedures,in violation
of C.G.S. 52-557n
b.
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7'he teache=s had no disctction in enacting the policctc;s anal pzoceduzes for the safe
"lock down" and evacuation of the school i~ a tt~spasscr or other dangerous and
impzopes individual enteaed school. property by the mandates ofthe safety polip,e~
a.~d pxocedu=es set forth by THE TOV~ OF NEWTOWN,'i'HE BOt1RD OF
EDUCATION and THE SANDX NOOK ELEMENTARY SCHOOL;
j.
The harm to which NOAH POZNER way exposed was ~+7+*+~ineat in that it was
isolated in time to tlxe collecrion of minutes from when AA.AM T,ANZA fizst shot
out the front window until he uitimatelp tools his owe life; and wsis restricted to the
area in which NOA.T~ ~'QLNER and his classzz~ates ~x~xe located in their classrooms;
.ip rhat the teachers and otl~e= staffin his classroom were well-aware of this imminent
ham as gnu shots had been firing down the hallway outssdc the doox td ~TO.~X
POZNER'S classzoom killing both the school p~cipal at thG end of the halfway, the
school psychologist at the ertd of tle hallway,and injuring at Ieast one sraff member
at the end d~ the hallway; thezefo=e the teache=(s)~ NOAI~ ~'C7ZN~~'5 classzoom
wexe on notice that an imminent harsh Was ~rescat co she idenri5able victims in their
CL`iSSY00in~ d11G~
k,
'Z'he danger was ap~a=ent to NOAH P07NT~t'5 teachex(s) and othex stiffin, his
classroom in chat it was easily observed and understood that gunfre down the
hallway outside the classroom doo=would expose the childxea inside same classzoom
td an imrncdiatc anal uneirniable danger,anti the srafPs ailuse oz iziabi~ity to act, to
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lock tb.e door or o~heswise Eollow the loc3adovvn ~rocedute would undeniably place
the students,including NOSH POZNER,in imnacdiate dames.
21. As a result of the shooting and failure by the TOWN OF NEWTOWN,NEWTOWN L'OA1tI~
OF ~IaUCA.TION and SANDX NOOK ELEMENTARY to fouow the proscribed ~sotocols,
NOAH P07NER sufex~d massive injuries aad wrtimely death.
22. NOAH P07.NE~ suffezed both physically and mentsllp prior to his untimely death,
23. TT-~ ESTATE OF NOAH POZ~TER incurred both medical expesases and burial and fun.etal
e~.-~enses, as a result ofthe c~eaxts o314wing the shooriug.
24. Btcau:;e of his death, NOAH POZNER'S ca~iacity to enjoy life's activities aad have a family
were completely and pemoanendp extinguished; and
25. NOAH POZNER was a studious and dedicated student whose iie vas cut short befoze he
could 5uish his eduction, and/or be$1n a career; and be therefoze lost a lifctizne o potential
eamin~,s, and the opportunity fos the pazticipatioa in a lifetime of experiences and enJoyment.
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WHE~FORE,Plair~;tif claims:
1~
Monetary damages;
2.
Such other and fuxt~er re]ief as thi,~ Honorable Count map deem just and equitable.
7C
I3Y
Donald A.l~a~csy, Esq.
Papcsy Jaxaosov Roche,LLC
53 fast Avenue
Norwa]I~, CT 06581
P:(203) G42.3888
Juris No. X28746
~~ ~ ~+'~ Tr e op
.4.
At~:~-;J ~:: hr;'~~~Ci
CVT~~. JI~+;ti ~~~i~+r'SI1c1I
F~ir(icici County
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SUPERIOR COURT
:~'.D. OF DANBUJ~Y
v,
: AT DANBURX
D~CEIV~SER 12, 2014
AMOYJN'T IN DE
The amount,legal.interests, ox propectp is~ demand is FIFI~EN ~'II~US~ND AND
N'O/100 DOLX.A~tS ($15,000,00) ox mote,exclusivc o~interests and costs.
BY
a cry, sc~.
Donal
Papcsy~aaosov Roche,I.LC
53 East Av~ntzc
NorwaUt, CT 06582
P:(203) 642,3888
Jw~s No.428746
uo~qpy n n
~J--~,x~
N. ~. Nikola
Corn, Sl,alr. P4arshal
Faini~ltl County
Attcs _
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