You are on page 1of 66

St1!

MM~NS -CIVIL
JD~c~-~ aey. 9~a

STATE OF CONNECTICUT

see other side for instructions

SUPERIOR COURT
www.~ud.ccgov

628,62269,P;9,Secs.31~rough35z9se~5a,

Yd~ A~+Y Proper officer, 8Y AUTHORITY OF THE


STATE OF CONNECTICUT, you bra hereby
commanded to make due and legal service of
this Summons and attached Complaint.

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.
"X" If claiming other relief in addition to Orin lieu of money or damages.

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)

146 White St., Danbury,CT p69140


GA

1~t Judicial Dlatrict


a Mouslnp Sesslo~

Return C~t~ (Must be a Tuesday)

~(203 )ZO7-8600
I A~ gown ie wnicn wnt ~s retuineoreJ (c.G.S~ 9 57.346, 50398)

I ~sse type code (see /1st on pays 2)

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

umber, sheet, sown antl z!p code)

Jurls number ~ro ee enten~y py aRamey Dory)

Pepcey JenoBov Roche,53 Eaet Avenue, Nol~Walk, CT 06651


7elephono number (w/tn aroe cone)

Minor; 90

428746

5lpnature of Plalntlrt plsslf{epr~sentedJ

(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

Ema11 aCdrose for delivery p1 pep@r~ under Sect on 10-13{Negroetl to)


~ Yes

Q NO

Number of De(endents: 3

~ Form JD-CV-2 attached for add(tlonal parties

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

Name: The Estate of Npah Poz~er, Leonard Pozner es Administrator


P-02
~a~~;261 S. Mein St.,#332, Newtown, CT 0647'0
Name: THE TOWN OP NEYVTOWN
D.01
Addre9e;TOWN CLERK: Dabble Aurella Halstead, Newtown Municipal Centvr~ 3 Primrose St., Newtown, CT 06470

Addldonal
Defendant

Name: SANDY HOOK BOARD OF EDUCATION


DAz
Addwsa: SUPERIIYTENDANT:JOS6Pii ERADi,JR., Newton Municipal Center,3 Primrose St., Newtown,CY 06470

Addltlonal

Pfaint{ff
Ff~st

Additional

Name: SANDY HOOK ~L~MENTARY SCHOOL

Defendant

Ad~~s~ PRINCIPAL:SANDY COMBOS,375 Fan HIII Hd., Monr

Additional
Defendant

Address:

D-o3

Name:

p.pq

Wit Clerk of Newtown

(~

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

against you In this lawsuit,


2.To be notlfleA of 1uRhe~ prooeetlings, you or your ~norney mustfile a form called an "AppagrallGe"with the Cletk ofthe above-named COUR et the above

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

obtained at the Court address above or at www.fud,c~gov under"Court Fonns."


0.. If you believe that you have Insurenoe-that may cover the claim that is being made against you fn this lawsuit, you should immediately cootect youc
insurance ropresentative. Other action you may have to take Is described in at e Connecticut Practice Book which may be found in a superior court law
library or on-line at www,/ad.ct gov ender ^court Rules:'
S. IPyyu.l~av~gaesNon
~~Etq~~t~lhC9ommews~~d Complaint. you should talk to an attorney gUlCkly. The Clerk of Court Is notailowed to give advice on
l
DONALD A.PAPCSY,ESQ.

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.
d, Tha Clork slgnin9 fhla S~mmone et the request ofthe Pleinti(i(s) fs not responsible in any way far any errors or omissions
in the Summons, any eliegetions eonlaie@d In the Complaint, ar the service ofthe Summons or Complaint
AID

certify 1 have read and


understand the above:

q~Tr~o
r~
~P~irficid tv;n:rry

W.~arlb~ov, Esq.,~63~st Avenue, Norwalk, CT 06851


~rficia akin

gnhce

;7~aro"A
dorl

~~

Do~J(et Number

72.122014

89 /~

s~ztio~zsoz.

:WdLti:z~:5~-so-~o

In'struct'rons
?. Type or print legibly; sign summons.
2. Prepare orphotocopy a summons fvr~ach defendant
3. Attach the ongin~l summons to the original complaint, and attach a copy ofthe summons to each copy of the ~vmplaini. Also,
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.
4. After service has been made by a proper otilcer, file original papers aid officer's rotum with the clerk ofcourt
5. The party recognized to pay costs must appear personally before the authority taking the recognizance.
6. Do nod use this form for fha following actives:
(a)Family matters (for ex8mple divorce, child
support, custody, paternity, and visitetlon
matters).
(b)Summary process actions.
(c)Appllcetions forchange ofname.

(d) Probate apps&lS.


(e) Administrative appeals.
(~ Proceedings pertaining fo arbitration.
(g)Any actions or proceedings!n which an attachment,
garnishment or replevy is sought.

ADA NOTICE
The Judicial Branch of the State of Connecticut complies with the Americans with
Disabilities Act(ADA). If you need a reasonable ~ccommvdation in accordance with the
ADA, contact a court clerk or an ADA contact person fisted at www.jud.ctgo~/ADA.
Case Type Codes
Minor Descrlptlon

Ma)or Description

Md~~

C011t~'aCffi

Coo
C 10
G 20
C 3o
C d0
C 90

Coneuuetion -Ali other


ConsWeUon - State antl Local
fn9uf8nCe Policy
Spec~nC Perprmanoe
CoUecdons
All other

Eminen! Domain

E OD
E 10
E 20
E 3o
E 80

State Miphway Co~eamnauon


Reaevelopment COndemnadon
Ocher State or Municipal ApenGes
PuD11C UtiliGea &Gas Tranam{sslon Componks
All other

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

Defecflve Premises - PrlveM -Snow or ce


D~ctive Premlaea -Private - OU~er
Detective Promlaes - PuGlic- Snow or Ice
Detective Premises -Public- Omer
Proeuets ~Igblury -Other Than Vehicular
Malpradlce - McGl~al
M~Ipmgioe-legal
M~Ipractloe - AID oUer
AssauR aad battery
DefamaVon
Mimels- Dop
Mlmals-Other
Fa{ee Arre9t
Fire oameBe
All other

Vehicular Torts

V 07
V 04
V 05
Y 06
V 00
V 10
V 20
v 3o
V 40
V eu

Moror Vehl~ea- Dnver andlor Passenge~(s)va.


Odvar(s)
MOtOr Vehicles"Pedestrian vs. Driver
Motor Veht~as- Prppeny Dam~pe only
MOfor Veh(cJe"Products L19DIIity Including W6Ra1Or
Motof VehlGe-Alt olhef
Boats
Airplanes
Railroads
Snowmobiles
Atl other
'Motor Venl~es InCfude cars, ttuCkg, mololCyCfes,
and motor 9aooters,

W 10
W 90

ConswcUon owllis and Trusts


Ail other

WIUs, Esfatss
and Ti'u8ta

MIno1'Description

dD-Cv-1 Rev.9.14(BacWPage 2)
~n~.... ~ ..t m

89 /ti #

~~ZtiOLZ~OZ~

~WdLb~Z~~S~-60-LO

~~

~(i

RE'z'tJRN X?ATE; JANUARY 27,2015

SU~'~~tSOR COURT

THE ~STA~ OFJESSE LEWTS,5GARLETT


LEWIS AS ADMiNISTRATRTX AND NELL
HESLIN AS CO-~1DMLNS~.ATOR;THE
ESTATE OF NO,A~ ~'OZNER,LEONARD
POZNER AS ADMINIS'IT.A'z'OR

J.A. OF DANBURY

V.

AT D~NBURY

TT3~ TOWN OF NEWTOWN,ET ,Ax,.

DECEIvII~ER 12,2014
COMPX.AYN'T

FIRST COUNT(THE $STATE OP JESSE LEWIS,SCARLETT ~.~V~XS AS


ADMINISRATRT~ NEIL HESLIN AS CO-ADMINlSTRA'rOR,against THE
NEWTOWN SOAYtD OF EDUGATIOrt}
1. P]aintif~ SGARI,ETT LEW1S is the duly appointcd 1'~dministratrix of the Bst~,tc okes son,
JESSE LEVUY5 and NEII,HESLIN is co-administratoz o tk~~ estate (hereinafter,`JESSE
LEWIS'~

2, Defend~n.c, TFiE N~WTOWN BOATtD OF EDUCATION (Hereinafter rcfetred to as


`BOARD',was,upon infoxmation and belief, an elected Municipal ~3oazd, constituted and
convened foz purposes including, but notlimited to, the implementation and. administration of
~o~Zcxes, procedures, and/ox statutory and legal mandates coz~eernirig the delivery of public
education,supervision aad safety o studemts attendiag public schools in tlae TOWN OF
NE~'OWN,including S.ANDX HOOK ELEMENTARY SCHOOL;and was a vytal
partiapant in dissPm;na~jg ~e safety polices aad proccduxCs fo= SANDY HOOK

89 /9

e~~tioLz~oz~

~WdLti~Z~~~~-60-LO

~~

~X,,~~Vl~NTARY SCHOOL from the TOWN OF NEWTOWN to ~E SA,NDX ~OO~C


FZ,E1vC~N'z'A1~Y SCH04L.
3. Apt all matctial times herein,DAVID FLEISFiMAN was the TOWN OF NEWTOWN'S
$u~cain.tcndeat of Schools, and was responsible for eoordinating,iu~ple~enting, and
communicating THE BOARD'S policies, procedures,xegulsitions, direcrires, anal statutory and
legal mandates,among the TOWN OI'NW~'OWN'S individual schools,including SANDY
HOOK ELEMENTI,RY SCHOOL and was also xespon~ible ox the hiring, traiaiag,
supervision, professional development and getlexa~ guidance ofthe l~ewtown public schools'
teachers, educational assistants and employees as dictated by THE B011RD.
4. At all material times herein,DAVID FLEISY[MAN,as the TOWN OF NEWTOWI~'S
supeaatcndcat was =esponsxble fot the o~e~tion,supervision, control and safety of students
and for managing the entire TOWN OF N'EWT0~1N'S Public School system, overseeing
school administrators' management of day-today operations ofindividual schools,including,
SANDY HOOK EI~MF~TARY SCHOOL,and acting as liaison between the individual
schools and Defenda~tt, THE BOARD,pia their agec~ts, servants, etzaployces, vz xeprese~tatives,
while ATE ~'OW~T OF NEW~'OWN,~E1V~WTOWN'B4A1ZD Off' ~D~U'C~ATZON and
THE SANDY HOOK ELEMENTARY SCHOOL wexe xesponsxb~e ox the cxeauon,
maintenance, supervision, opeae~tion, and/or control, ofthe N~1"fVTOWN PY7BY,IC SG~IOOLS'
safety guidelines, and the implementation ofsame.

89 /9 #

GZtiOLZOZ~

~WdLb~Z~~S~-60-LO

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,

89 /L #

~ZtiOLZ~QZ~

~WdLti~l~~9~-60-LO

.~

9. '~"he Defendant,TfIE IiOAR~,th=ough irs agc,nts and employees,failed to provide a substitute


teacher, oz teacher, in clsLsezoom eight(8) o= ten (10) with a key to lock the door to said
classroom, o= the proper t~ainixig regarding the a~datorp "lock-down" and ev~cuadoa plan the
teaCliers were to Follow shov].d as intruder cntex the school pxetnises, makusg it impossible for
said substitute teacb~et or teachex to follow the.m~nisteriai duty ofauiplementiag the safe~p
protocols est~blish~d by THE TODVN OF NfiW~'OWN,THE BOARD and SANDY NOOK
FT.,E~ENTAR.Y SCHOOL when the inuudec's presence Uecame unmist~.kablp knowxt, and the
dangex to the identifiable class ofvicrims in rooz~s eight(8)end ten (10) became immi~,ent and
readily apparent to the staff oSANDY NOOK ELEMENT.A~RY SCFiQOL.
10. The Defmdan~ THE BOARD as agents and employees ofTiXE TOWN 4F NEWTOWN,
failed to provide the SAN1~X HOOK ~,~MENT~tY SCI~OOL with doors to the even
numbezed classrooms that could be locked from the inside; and instead these doors to the eves
numbex~d classzooms had to be socked from the outside throb the use o~ a key, rlxexeby
ma~ng i~ unpossible fox the teaehrts ofSANDY BOOK ELF.Iv~NTAR~Y SCI300L to follow
tine ministccis~l duty ofIocldn~ dorvx~ the school and evacuating students when,the intruder,
ADANX LANZA'S,presence became uxunistakably known,anti the danger to the identifiable
class of victims in roou~s eight(8) anti teA (10~ became ~**+<+~+~~ exlt and s~dily appazexlt to the
s~t~ of S1iN1~Y HOOTS ~.LEMFN~'ARY SCI~OOL,in violation of C.G.S. 52-557u~
11. ~'he Defendant,THE $OARD,as agents and employees ofTHE TOWN OF NE~W'!'ODUN~,
Failed to provide the SANDY HOOK EL~MENT1~ItY SC~TOOL with a secuxc front entrance,

C~

89 /g ~

~lZtiOLZOZ~

~WdLti~Zl~S~-60-LO

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

MENTEiRY SCHOOL implemented ira case an

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

89 /6 #

~~ZbOLZ~OZ~

~WdLti~Z~~9~-60-LO

EX.EMEN'TAR~C 5CHOOL,by mandate ofTF~E BOARD,'X',H~ TOWN az~d SANDY I~OOI{


~LEMENT,t~tY SCHOOL.
14. The Dcfcndant bad cleated a ministerial duty fos all eszaployees, agents and men~bers to take
whatever precautions necessary and enus~esated in. the sA~ety p=oceduxes set forth by'~'HE
BOARD,TIC$ TOWN OF ~TEWT'OWN,and THE SANDY HOOK ET.,EMENTARY
SCHQOL,to p=otect the Plaintiff ~zom his w=ongfi~l death on Decc~,uber 14,2012 due to the
ezeation of their own internal policies codified iu1 the T3oa~d oEducation's izttemal handbooks,
pokcies, proceduxs, and othex cocli5ed rules aid segu]ations coz~ceming studextt safety
mandated under CGS 233a,and due to their acute knowledge of the imminent and appazent
ham the intrude= ADAM LANZA.preset~ted to the identifiable victims othe SANDY HOOK
~LF:MENT.A,RY SCI~OOL when he fitst shot out the toot windows ofthe school.on
December 14,2012; at which time the fact aa,intruder was present on the school ~zeuiises, and
chc fact that the identifiable victims were in asimminent haran became appaxent to the staff,
agents, employees and memb~cs ofTHE SANDY HOOYC F.~,EMENTARX SCHOOT~.
15. On December 14,2012, at approx'unat~lp 9:30am, the front doors ofSANDY XIpOK
ELEMEN7'~I.Y'SCki00L were locked for the beginning ofthe school day as pazt ofthe
afoPeffi~a.~oned sa~e~ ~a~icy es~,blisl~,etl by the 7'4'~UN,THE BO.A.~tD and TT~~E SCHOOX,.
1G. Located di=ecdy to the right side ofthe locked ~on~ doors ofthe school was anon-safety glass
window with dimensions oapp=oximately ttuee (3)feet in width and ;Four (4) feet zoo hei~hL

89 /0~ #

s~ztioczsoz;

~wdcti~z~:~L-so-Lo

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.

s~ i~~ #

~IZtrOLZOZ;

~WdLti,z~:~~-so-~o

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,

89 /Z~ #

~~ZbQLZEOZ~

~WdLti~~~~9~-60-LO

and THE SANAY HOOK~NTARY SCHOOL,and were therefore not foIIowed in


classxoozns eight(8) and tca (10).
27. Classroom. eight(8) was occu~acd by a substitute teachGt who bad neither a Cep to Lock the doo~c,
nor any knowledge or ~aiaing =egardiug the aforementioned safety and security pzotocols
ze~e~.dq rehearsed at SANDY HOOK ELEIVX~NTARY SCHOOX,is case an intruder or other
daugesous individual gained access to tb.e school.
28. Upon eatetirtg c]assrooms eight(S) and ten (10) the. ADAM I,t1NZA ki]J,ed twenty studcz~t3 and
four adults before taking leis own life outside cLlssroom tea (10).
29. JESSE LEWIS rovas one of the twenty(ZO) studen.ts killed.
30. Q~,December 14,2012 THE BOARD,and its staff anal cm~Zopees negligently deft the st~.ff of
THE SANDX HOOK ETTIv1ENTARY SC~IOOZ,i~r~ a position ahe~te it could not adhere to
the mandatory safety policies and pxoeedures,such as "lock-down" and evacuation, estlb]xshed
by THE TOWN OF NEW~'OWN,'Y'HE BOART~ OF EDUC~.TTON and THE SANDY
HOOK ~.F,~[vZENTARY SCI~OOL in one or moxe ofthe following ways thereby causing the
urron,~a], death ofJESSE LEWIS and other damages setfob herein
a.

Whey failed to pxovide SANDY HOOK ELEMENTARY SCHOOX,rovxth doors that


could be docked from the inside thereby malting the "lock down." ~o=don of the
safety protocols virtually impossible to follow, :u~ violation of C.G.S, 52-5S7u.

b.

The PlaintiFf brings this action puxst~aat to 52-555 of dse Connecd~ut CYene=al
Statutes,

as is~ #

lZtiOLZ~OZ~

~WdLti;z~:~~-60-~0

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

impossible,in vio]ation of C.G.5. ~ 52~557n;


f.

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

10

89 /b~ #

~~ZtiOLZOZ~

~WdLb~Z~~~6-60=10

OX'N~WTOWN'and SANDX H04K ELEMENTARY SGHQOL a useless and


purposeless gestuze irl violation o~ C.G.S. 52-557n;
g.

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

1~

89 /~~ #

LZtiOL~OZ;

~WdLti~Z~~~~-60-LO

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.

12

89 /9L #

~~Zti0LZ~0~~

~WdLti~Z~~56-60-LO

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'~,

13

89 /LL #

E~ZbOLZOZ~

~WdLb~Z~~~~-60-LO

2. Y7efendaa~ THE TOWN OF NEWTOWN (~-Xeseinafte= and previously xefcr~ed to as "THE


'Z'OWN'~,was,upon isrfozmation and belief, a coxporate entity or governrxtent politic chaz~ed
with the safety:md education of the inhabitants of xts town,including the education ofthe
children located thearcin.fxom grade school thzough high school; and tie safety of those children
vcrhile in the schools and at tb.e school functions established by TIDE TOWN under CGS 17a101.
3. At all maxerial times hezein,DAVID FLEISHMI~N vvas the TOWN OF NEWTOWN'S
Superintendent of Schools, and was zesponsible for cootclinati~.g,implementing, and
communicating THE BOARD'S politics, ~rocedu=es, xegulatios~s, directives, and statutory and
legal. mandates,among the Defendant,THE TOWN'S individual schools,including, Defendant,

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-

day operations ofindividual schools,including,SANDY I~OOK ~.~MENTARY SCHOOL,


ax~,d actsng as liaison between the individual schools amd Defendant,THE BOARD as an
extension ofthe Dce~daat, TF-I~ TOWN,via their agenrs, scrvant~, employoe~, or

14

89 /8L #

~~tiOLZOZ~

~WdLti~Z~~96-60-LO

rcprescea~~vcs, wlao wee xgspon~ible fos thg ~seatioaay

to

ce, s~p~xv~saon, op~s~t~on,

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

89 /6L #

~ZtiOLZ~OZ~

~WdLb~Z~~S~-60-LO

8. 7."h~ laefendant, TOTE TOWN,acting thxough an extension ofitself, the Defendan~'~S~


BOARD,failed to provide the staff ofSANl7Y HOOTS ~LENi~NTARY 5CFIOOL with the
z~ccessary infom~uoa,tools, and ua.~iaing to pzoperly implement the safety protocols nx~iously
estab~isk~ed by~~ BOl'f.TLD,T~~ TOWN A,~TD 'Z'~I~ SANDY I~04K ~,S.EMNTARY
SCHOOr,regarding innvdess on the SANDY HOOK ELEMENTARY SCHOOT,grounds,
mal~rtg it so that THE SANDY HOOK EI,~MENTARY SCHOOL staff was unable to
implement said sec~xity pzotocols on Dece~zxbex ~4, 20 2 when the iu~uder entered the
building,in violation o~ GG.S. 52-557u.
9. The Defendant THE TOWN,acting through its agents at the Defendant THE BQARD,failed
to provide a substitute teacher, or teacher,is classroom eight (8) or ten (10) with a key to lock
the doox to the classxoom, o;r the proper tsa,ixaag xegaxding the mandatory `9ock-down" and
evacuation pLnn the teaeJ~ees weze to follow should an intruder eats= the school premises,
ma3~g it impossible fox said teachez to follow the ministerial duty ofimplementing the safety
protocols when the i~b~xder's preseace became knows,is violation of C.G.S.52-557n
10.'The I~ef~at~~ TfIE TOWN,acting through its agenrs at the Y7efeadant,TII~ BO.E~RD,failed
to ~rovidC the S,A,N1aX HOOK ELEMENTARY SCHOOL with doors to the even nw~abe=ed
class=vdtus that could be locked from the inside, and had to be locked from the outside by use
ofa key, thereby making it impossible fos tlae teaches ofSANDY HOOK ELEMEN'i'A~LX
SCHOOL to follow the ministe.~al duty ofIocking dvwa the school and evacuating students
when the intruder,ADAM LANZA's,prCaCIIGC bCC~C ~,OW'LL yIl V~OIAIIOR OF C.G.S. 52-557n.

16

89 /OZ #

~~ZtiOLZ~OZ~

~WdLti~Z~~~~-60-LO

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,

17

89 /~Z #

~~ZtiOLZ~OZ~

~WdLtr~Z6~~6-60-LO

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

rely 9:30am,the f=ont doors ofSANDY HOOK

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

89 /ZZ #

s~ztioczsoz~

~WdLti~Z~~~~-60-LO

18, JESSE L~V~S was located wit]

tie school building at 9:30am on Decembe:14,2012,in

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

89 /Z #

~Zti0LZE0Z~

~WdLb;Z~~S~-60-LO

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

89 /tiZ #

~lZtiOLZOZ~

~WdLti;Z~~S~-60-LO

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

89 /~Z #

~~ZtiOLZ~OZ~

~Wdtti~Z~~S~-60-LO

pxoceduzes as proscribed by the Defendant,THE TOV~N thtougla i~a amts at the


17ef~ndant,'~IE BOARD;in violation of CGS 52-557n
d.

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

89 /9Z #

~~ZtiOL~~OZ~

~WdLti~Z~~~~-60-LO

EI,EMENTI~Y SCHOOL,but wed to provide the same individuals with the


proper equipment acid training to effectuate tie ministerial duty offollowing tlac
safety protocols,in violauo~ of CCyS 52-557n;
i.

'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

es icz #

s~ztioczsoz:

:WdLti:z~:~~-so-~o

place the students,includingJESSE LEWIS,~ immediate danger but the teachers


could notimplement the mandatory security gutdelines because THE TOWN
through its agents at the Defetadant,~Z~ BO,ARn failed to provide adequate
equipment and resources to do so in violation o CGS 52-557n.

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

xxrxtn co~cr~c(~c~~ ~sxAx~ o~r~ssa~ x,~v~s,sc~u.~xx x,~r~zs ~s


ADMINISRATRATRII~L,NEIL HES.LrN AS CO-ADMINSTRATOR against SANTJ'St'
HOO~C E7.~~E~A.RX SCHOOL.)

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'~.

24

89 /8Z #

~lZtiOLZ~OZ~

~WdLb~Zl~96-60-LO

2. Defendant, SAN7~Y I~QOK ELEMENTARY SCHOOL,was, at all w:aes ziaeaaomed herein., a


learning irastitudon existing under the rules,=egularions, aad guidelines ofthe Co~ecdcut
Creneral Statutes, N~W~'OWN BOARD OF EDUCATION,the TOWN OS~ NEWTOWN
a~ntl the State of Connecticut,and subject to tlae same zules and xe~u~riony as aforcmcntionEd.
3. SANDY HOOIC FLEMENTAIZY SCHOOL was, at all times mentioned herein,located in the
town of Newtown,County ofFairfield, and State of Connecticut
4. The deendan.~ SANDY HOOK ELEMENTARY SCHOOL,was to follow safetp procedures
a.~.c~ policies enacted by'I~~ TOWN of NEVPr'OWN,'T'FiE NEWTOWN BOARD of
EDUCATIOi~I acid THE SANDY HOOK~FMI~NTA~ft'Y SC~IOOT,for the safety ofits
students during school hours; most specifically a"lockdown" and evacuation plan ettaeted
should a stranger, or other improper o= dangerous individual enter the school during school
hours, or oehetwise endan,~et the students, and to ensure the safety ofits students.
5. The details of this plan were relayed to school personnel prior to December 14,2012,and had
been rehearsed and practiced by staff aid stadents days/weeks earlier in a "chill" fashion,
G. The details o this plan left zoo discretion to the tcachccs or other employees ofSANDY ~TQOK
F~,~N~N'TrA.R~1'SCS~44Y.as to hovt~ it was to be carfled out, and was to be foIIowed as outlined
~oz the safety of the children at SANDY HppT~ ~MENT11'~Y SCI~OOL,as developed by
THE TOWN OF NEWTOWN,THE BOARD OF EDUCA~TI~N,and THE SANDY
HOOK ELEMENTARY SCHOOL,

25

89 /6Z #

~~ZtiOLZ~OZ~

~WdLb~Z~~~~-60-LO

7. On Decembct 14,2012,at appzo~dmately 9:30am, the froAt doors ofSA~7Y HOOX~

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

as ios #

s~ztiocz~oz:

:WdLti:z~;~~-so-~o

(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

89 /~~ #

~~ZbOL~OZ~

~WdLti~Z6~9~-60-LO

locked 3n accordance wirh the afoiemeudonedlock-down or evacuation p=oceduxes established


by THE TOWN OF NEWT4WN,THE BOAl~ O~ EDUCATrON,and THE SANDY
HOOK F:LEM,CNTARY SC~I40L,and were therefoxe scot foIlowcd iz~, classrooms eight(3)
and.ten.(10)s
19. Classroom eight(S) was occupied by a subscitut~ teacher who had neither a kep to dock the doox,
nor any knotiv~edge o= training regarding the aforementioned safety and security pzotocols
recenfly rehearsed at SANDY HOOK EI.EMENT,A~RY SCHOOL in case an intrudes or other
dangerous inditviduai gained acG~ss to the school
29. Upon euteriug classrooms eight(8) and ten (10) the ADAM z,A,NZA lfllled t~ov~nty students and
Four adults before talflng .his own life outside Classroom tea (10).
20. JESSE LEWTS rovas oue of the twenty (20) studemts killed.
21. Ora Aecember 14,2012 the SANDY HOOK EL~MENTAR~'SCHOOL,ne~lig~utly failed to
adhere co the mandatory safety policies and Qrocedvres, such as "dock-down" anal evacuarion,
established by TIC TOWN OF NEWTOWN,THE BOARD OF EDUCATION and TFiE
SANDY HOOK ELEMEN'~ARY SCE-TOOL is one or moi~ ofthe folloaving ways thcrebp
causing the wxongful dearb ofJESSE I.EDVIS and other damages set forth herein:
a.

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

89 /Z #

E~ZtiQLZ~OZ~

~WdLti~Zl~S~-60-LO

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

89 /~~ #

s~ztiocz~o~:

:WdLti:z~;~~-so-~o

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.

As a student of SANDY HOOK ELEMENTARY SCH04L,~'~SSE LEWIS was


an identifable viGw~a o a~a izauiinent ham that had become trans~axc~nt to the
teache=(s)in his classroom whin the ft~st shots Were fired by the shooter to fain
access to the building;

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]

89 /b~ #

lZtiOLZ~OZ~

~WdLti~Z~~56-60-LO

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

89 /~ #

~~ZbOL~OZ~

~WdLb~Z~~~~-60-~0

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.

FO~CJ~.tTH CQiTNT (T.FIE ESTATE OF NOAH POZl~~,t,~.EONARD POZNER AS

ADMINISYiA'Y'O~t, against THE NEWTOWN BOARD OF EDY7CA'~TO~


1. T'Lzintiff, LEONt1RD POZ1VE~t i~ the duly appointed ~,dminisrratox of the Estate of]us son,
NOAH I'OZNEIt(hereinafter,"NOAH P02NElt'~.
2. Defendant THE NEWTOWN B0~4RD OF EDUCATION (.EIrseinafcex referred to as
`BOARD',was,upon infp~mation and belief, a~ elected Municipal Board,constituted az~d
convoned fos purposes indudiug,but nvt limited to, she implementation asad adr,~uiui~tratioa of
policies, procedures, and/or statumry and aegaZ mandates concerning the delivetp ofpublic
education, supervision az~.d saetp of students attending public schools in the TOWN OF
NEW~'OWN,ia~luding SANn"Y HOOK ELEM~N~'AItY SCT~pOL;and was a viral
participant in disseminating the safety policies az1d ~rocedufes for SANDY HOOK
ELEMENTARY SCHOOL fxom the T0~7N OF NEW~'OVP~T to THE SANDY TOOK
EL~MEN`I',A1ZY"SCHOOL.
3. Ac all material rimes heseiu,DAVID FZ,EIS~~MAN was the TOWN OF NEDUTOWN'S
Su~erin~endeut ofSchools, and vas responsible oz coordinating,implementing,and

32

89 /9 #

~6Zti0LZ~OZ~

~WdLti~Z~~~~-60-LO

cozx~.municating~X~~ BOARD'S policies, procedvses, se~nilatio~.s, directives, and sMtutory and


legal rr~andaces, asn;o~ag the'Y'OWN OF NEDPTOWN'S individwll ~chooLs,including

SANDY

HOOTS ELF.MPNTARY SCFi00Y.and was also responsible or the hiring, u~ais~iag,


supervision, pxofessional development and genczal guidance ofLhe Newtow~a

public schools'

teachexs, educational,assistants and employees as dictated by1~$ B0~1RD.


4. At all material times herein,DAVID kZ.EISHIvI11N, as the TOOT OF NEWrOWN'S
supecincendent zvas responsible foz the operation, supervision, conrsol and safety
ar~d for manag~g t?.ic entire TOWN OF NEV~OWN'S Public School system,

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,

schooL~ and Defendant,TXXE BOf1RD,vii their agents,scents,employee

while THE'Y'OWN'OF NEWTOVPN,THE N~WTO'~WN IiO.f~RD O~ EDUCA,TION and


THE SANDY fI00YC ELEMEN~'AatY SCHOOL were respo~siblc for the creation,
maintenance,svQeavisioa, option,and/oz control, of the NEWTOD~T

PLT$LIC SCHOOLS'

safety guidelines, and the implementation. o~ same.


5. At a.0 material times h~sein the supezintendent was as ag~nnt, secvwt,

esn~loyee, or other

ze~resentadve ofthe Defendant,Tk;E BOARD,and/ox TTY TOWN

OF NEWTON.
al duty

a legal and ministeri


G. At all material times herein the Defendant,THE BOARD,was twd~t
ng variau.S

to create, enforce, and abide by a collection orules and regulations concerni


employee ar1d student conduct, aiiegations,inve~tigazions, pe~oaides, and

to ensure student safety

33

89 /L #

E6ZtOL~~O~~

~WdLb~Zl~96-60-LO

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-

7, At all,mateuat times herein the Defendant, TFiE BOARD,usYdez theregw

discretion by xts
220finstituted school safety policies and proceduzes which let no uea foz

staff

Public School District,

and/oz agents, coaceming the safety ofthe schools in the Newtown

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

itnpJemeat the safety

p=o~eocols ~=~viouslp established by THE TOWI~T OF NEWTOWN,THE

B01~1RD and

SANDY HOOD ~.EMEiZT~'AlZY SCHOOJ.,thereby z~a~king it so that the SANDY


EI,EM~NT~RY SCHQOL staff axx rooms eight(6) and tee (10) were

FIOOK

unable to implement said

,ADAM LANZA entered

obligatory safety protocols on Dec~tnbe=14,2012 when au inuudes


tkze building,

~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

mting the safety

said substituee teacher oar t~achex to follow the mirvstezial duty ofimplem

34

ee ies #

~ZtiOLZ~OZ,

.WdLti.z~;~~-sa-~o

pzotocoL~ established by TI~.E TOWN OF NEV~/TOWN,THE BOA,1tD and SANDX

HOOK

T~L'EM.ENTARY SCHOOL when the intruder's p=eseace became ua:uistalc~bly knows,

and the
nt and

daagex to the idendfaable class ofvicrims in rooms eight(8) and ten (10) beca~o.c ~~+*n~ne
L.

readily ap~aYent to the staff ofSANDY HOOK ~~.F1VIENTARX SCHOO


10. The Defendan~,'~HE BOAR17 as agents and employees ofTHE TOWN

OF NEDilfOW1~T,

failed to provide the SANDY HOO~CELEMENTARY SCFi00L with doors


numbered classrooms that could be locked from the inside; and instead these
numbered classrooms had to be locked fzom the outside through the use

to the even

doors to the eves

ofa key, thezeby

NTARY SCHOOL to follow

ma~~ it im~aossible fox the teachers o~SANDY KOOK ELEME

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.

staff of SAN17Y HOOK ELEMENTARY SCHOOL,in violation of C~G.S. 52-557

O~ NEWTOWN,

1~. The Defendant,THE BOARD,as agents and cmQlopees oTF~E'r'OWN

ailed to provide the SANDY HOOYC ~tEMENTA.RY SCHOOL with a secure front
leaving anon-secutity glass window,witb~ measurements of nearly three(3)

fcGt wide by four(4)

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

school"lock-down" plan established by the TOWN OF NEVPTOWN,THE IiOAR

n.

~'~IE SAY HOOK F~MEN'X'AItY SCHOOZ.,in. ~*iolation of C.G.S. 52-557

35

89 /6~ #

~6Zti0LZOl.

~WdLb~z~;~6-60-LO

12. The defendant,TT~~ BOARD as ageztts and employees ofTHE TOWN


was negligent in that zt ailed to follow or provide its school systems with

OF NEWTO'W~T,

the necessarc tools to

implement the yecw~.ty and safety guidelines wbi~ch THE I30ARD,THE TOWN Off'
atcd in case an

NEWTOWN and'rHE SANDY TOOK I.L~MENTARX SG~IOOL implemec

intruder gained access to the school ~xounds,and thereby made a ministerial duty' tk~at left

no

zoom for discretion by the SANb~'HOOD ~.EMENTARX SCHOOL teachers and/or

staff

to effectuate itx a time of emergency;?~mceforth vitoL~ting the ministeti~l duty cleated by T IE


TOOX/i~T, THE BOARD,and SANDX HOOK EL~.MENTARY SCHOOL to provide a safe
school er.vironmen~, wlsich a~ voluntaslp uadcrtook when the "lock down"and

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

violation of C.G.S. 52-557n.


13. The det~i].s and proscriptions of this plan left ao discretion tv the teachers or other

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

cr 14,2012 due to the

36

89 /Oti #

~Zti0LZE0Z~

;WdLti~Z~;9~-60-LO

~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

89 /~ti #

s~ztioczsoz~

:wd~ti:z~:5i-so-~o

buiXding with a zifle-type gun;and was seen shooting the rile


POZNER'S classroom

down the ha]lway whew NOAH

located,
other staff at this time and killed the

20. AA.AM I.ANZ.A shot down.the hallway at t1~e pzincipal and

principal aad the school psychologist who had exited confere~acc room
hallwap to see what the loud banging (gvn&te) noises were; alI were

9 at the cnd of the

attending a pIanaing and


.

placement meeting with oth~t staff membez~s and a student's pat~ts

~sycholo~st was shot in the leg,but

21..A staff member standing behind the prindpal and school

remained prone on the ground or a moment before crawling back


(9) and made a call to 9-x-1 a]so iaimediatelp turning on the
phone located in room nine (9), which allowed other areas

into confeterxee zoom nine

schoolintercom system through the

of the school to hear what was ~oitng

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

sill stiff membexs were

sad then he entered the

sad these w~.s a lull in the gunfire.

23. After ~D.AM I.AN7A'S second exit from the main of5ce,

the office staffimmediately called 9-

~,-1.
oms eight(8)and rhea teas (10), the

24. ADAM T.ANZA then e~teted the unlocked doors ocL~sro

.RY SCHOOL.

fast grade classrooms ofSANAY HOOIG ~1.EMENT.A

38

89 /zti #

6~ZtrOL~~OZ~

~WdLb~Z~~~6-60-LO

25. At the time ADAM LANZL~ eatezed these rooms,

no doom }aad been locked, none of the

children bad been moved to a safe location, lake rl~e bathroom

located inside both of these

classrooms; bathrooms which could be locked frou~ the inside.


2G. Neither cL~ss=oom eight(8) nor cL~,ssxoom teu (10) had

iutexaal locks to their doors; the only

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

a ~Cey; despite hearing the

the principal and school


r who opened the ir~texcom

psychologist; the gw~s~.ots that wounded the other staff mambe


system ~xom confereace room ~in~ (9); of the lull i~

gunf~e that aspired is the time that it

ofFce before re-estteting the hallway


took the intxuder, ADAM I.ANZA,to ibvcstr~ate the maia
and opening the unlocked doozs to classrooms eight(8)and

ten {10); thereby effectively no


ned lock-down or evacuatiton

clsissroom, dpors were locked iu accordance with the afoseme~.tio


procedures established by TIE TOWN OI^ NEWTOQPN',THE

~4A1t1D OF EAUCATION,

tb.~efose not fo~owed in


aid T.~1E SANDY T-i00K F~S.EMl~;NTARY SCHOOL,and were
classrooms eight(8) anal ten (10),
x who Iaad nrithes a kep to lock the door,

27. Cassroom eight(8) was occupied by a substitute teache

nor any kaowledge or training regarding the a~oremeationed


recentlq xeheazsed at SANDY HOOK EI,EN~ENTARY

safety and seeucitp protocols

SCk~00T,in case stn ~iatcude= or other

dangexous individual gained access to the school..


28. Upon entexvng classrooms e~gb,t(8) and tea(10) the ADAM

LANZA killed tweutp students and

four adults before tai~ng his own life outside classroom ten (10).

39

89 /Eti #

~~ZtiOLZ~OZ~

,WdLb~Z6,96-60-d0

29. NOl~~i P07.NEK was one ofthe twcnty(20) students ]gilled.


the st~.~ of
y
30. On )Jecembes 14,202T~iE BOt~R?J,and its sta:f and employees ~,egligentl left
TAE SANDY HOOK ~L~MENTARY SCHOOL in a position where it could not adhere
the mandatory safety policies az~,d procedures, such as `~oclidown"

to

and evacuation, esG~blished

by THE TOWN OF NEWTOWN,THE BOA.~.D OF EDUCA'z'XON and.THE

SA,Np''Y

HOOK ITT.EMENTARY SC~IOOL in oue oz mo=e of the following ways tlaezeby

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

40

89 /titi #

~ZtiOLZ~OZ~

~WdLb;Z~;~~-60-LO

,~

even attewpt to loc1~ the doozs to the cL~.sstooz~, which could os~lp be ~o~lced from

the outside with a key,iu viol~don of GG.S.52-557n;


e.

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

4I

89 /9ti #

6Zti0LZ~OZ~

~WdLb~Z~~9~-60-LO

to the staff ~t~td perso~el of~'kiE SANDY F~OOK ELEMENTA~X SCHOOL on


how to successfully implement tl~c "lock down" and evacuation security plan,in
violation o~ C.G.S. 52-557n;
h.

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

42

89 /9ti #

~6ZbOLZ~OZ~

~WdLti~Z6~5~-60-LO

n of

Bp11RD f~ti~ed to p=ovxde adequate equipment and resoiuces to do so ~ violatio

C.G.S. 52-557n; and


j.

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,

pzocedute, o~ which the subsritute teacher had no ~owledge, tzsiining ox eicperiez

the

would place ehe students,iucludi~g N.OAF~ POZNER,i~z~ immediate du~g~s,but

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
,

safety and securiry ~n:udeliizes est~Ulished by TTY TOWN OF NEW~`OWN,THE BOAR17


and T~iE SANDY F300If ET,~Mr.NTARX SC~-i00L,tlae shooter was able

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.

43

89 /Lti #

~Zti0LZE0Z~

,WdLb~Z~~S~-60-LO

l expenses at~d burial and funeral

33, TT~E ESTA'1~ OF NOAI-~ POZNER imcuned both medica


expenses, as a result of the events following the shooting;
34. Because of his death, NOAH POZNER'S capaGi.ty

to enjoy li~'s activities and have a fauui~~

weze completely and pexmanentlp extinguished; and


35. NOAH POZNER was a studious and dedicaCed student

wb~o's liFe was cut short before he

could finish his education, begin a cazeer, az~.d he therefore

lost a lifetiuze of potenrial eam~n~s,


ence~ and enjopme~t.

and the opportunity for the participation ifl a lifetime of exp~i

~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~

end pzeviousl~ z~feu


2, Defendant,THE TO~1V O~ ~TLWTOWN (Heseinaftet
'TOWN',was, upon infozmation and belied a corporate

entity or ~ovemxnrnt poliric chazged


ing the education ofthe

with the safety and education of the inhabitants ofits town,includ

chiidrea located rhe=e~u from grade sclsool through high school; as~d

the safety of those children

while in the sc~,00ls and at the school funcrions established bq THE

TOWN und~s CGS 17a

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

Superintend~n.t of Schools, anal was responsible for coordi


communicating THE BO.t1RD'S policies, procedures

regulations, directives, anti statutory and

44

89 /8ti #

~ZtOL~OZ,

~WdLti~Z~~9~-60-LO

schools, includut~g, Defendant,

legal mandates,among the Defendaz3t,7HE TOWN'S individual

ib~e for the hiring, ~aiuing,

SANDY BOOK ELEMENTARY 5CHOOL and was also =e~pons

Newtown public schools'


supctvision, professional develop vent and general guidance ofthe
teacbters, educational assistants anal employees as dictated by THE

BOARD thzottgh the

i ~~

4. At ~.0 material times herein, DAVXD FLEISFiMAN,as

the TOWN'S superintendent was

responsible or the operation,su~esvision, control and safety

of students ar~d for massaging tk~e


trators' management of day-to-

eatire'Z'OWN'S Public Sclsool system, overseeing school adminis

Y HOOK F~,EMLNTAItX SCHOOL,

day operations o~individual schools,including,SAND

THE BOARD as an.


axed acting as lfaison between the i~n.dividual schools and Defendant,
s, employees, or

extension of the Defendant,Z'~iE TODD',via their ag~nrs, servant

supNxwision, operation,
rep=esenretives, who wexc responsible oz the c=eatioz~, maintenance,
rd by the Defendant,THE

snd/or con~ol,of the NBWTOWN PUBLIC SCI~OOIS,as delegat


TOWN,
5. .A.t all material times herein the superintendent was an.

a~cnt,servant, emplo~ce,or other


ant THE TOWN.

repiesent~tive of the Defendant,THE BOf~K~,and/or the Defend

acting th=ough its ag~ts at the


6. At all macerizl times hexein the Defeadswt,THE TOWN,
Defendat~ttt, Tk~ ~QAR17,was under a legal and ministerial
by a collection ofrules and tegulatitons concerning various

duty to create, eaotce, and abide

employee and stude~.t conduct,

45

89 /6ti #

6Zti0Lz~OZ;

~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

10. The Defendant,T1~E TOWN,acting through its ag~n.ts at the Defendan

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

11.'T'he Defendant,THE TOW~T,acting ch=ougka xts agents at t1~e Defendant,THE BOARD,failed


to ptov7ide the SANDY I~OOZt~LEMENTI~RY SCHOOL with a secure front eu~auce,
leaving a aon-security glass window, with measurements of nearly tiuee (3) feet vcride

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

89 /L9 #

~ZbOLZ~OZ~

,WdLti~Zl~9~-60-LO

safetp guidelines wkdch THE BOA,,THE TOWN and SANDY HOOI~

ELEMENTAS~Y

for discx~tion by the

SCFi00X.implemezzted and made a miniseerial duty that left uo room

te in a time of

SANDY F~i00K EI.EMENTAY~Y SCHOOL teachers anal staff to effectua

.'S own mini~tcadal duty

~mexgency, tk~ereby violat~,ug THE BOAZtb'S,T~Wl~'S and SC~IOOX


to Qxovide a sae school en~vizonment,which it vol~tadly undertook

but failed to follo'av after

irD,plemendng a. ministeziat duty to do sv.


at the T~efendan~ THE
13. The debils of the Aefendant,TI~~ TOWN,acting through its agents
classrooms witivx~
BOAR'17, ministe~l Lan were reduced to ~tiag~ and hung oa the inside o
SANDY T,~OOK EI,EIv~NTARY SCI~OOL on Dece~be=14,2012, Uut we=e
follow beea,use the ~cfendant,'Y'HE SOWN,actlag through its agenrs at
BOARD,had violated the conditions ofsame by fat7i~og to ~=ovide

impossible to

the Defendant,THE

adequate training,

superion,aud,equiptacnz to impleu~ent said security procedures, thereby violating

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

SCHOOL,by mandate of the Defendant,TI3E TOWN,acting through its ageit~ at

the

T7efendant,THE B01~RD,.
15. 'Z'he T~efendar~t had a ministezial duty to take whatever ~recautio~ng

necessary to p=otect the

izitc~nal policies
Plaintiff from his wrongful death on December 14,20 2 due to their own.
es, afld other

codified in thhe Boazd ofEducarion's isaxa~l handbooks,politics, procedur

48

89 /Z9 #

~~Zti0LZE0Z~

~WdLb;Z~~~~-60-LO

ed uradcz CGS 233x,and due to

mandat
codifed rules and xeglilations coacerning student safety

r presented to the identi5able victims of

their acute knowledge and the speciSc danger the shoote


the SANDY HOOK ELEMENTARY SCHOOL

w}acn he shot out the front windows and the

fact an izxcrudex was present ou the school Premises becamC


16. O~ necembex 14,2012, at approximately 9:30am, the

a~pazent.

front doors ofSANDY HOOYC

T..~,EMENTATiY SCHOOY.we=e locked for t~e b~ginuing of the

school day to secare the

school as they typicaJ].y were on cv~ty other day.


~7. Located directly to the tight side o~ the locked Mont doozs

o~ the school was ~. non-safety g1a5s

window with dimcaisions ofap~xo~mateiy three (3) feet is width and

four (4) feetin height.

g at 9:30s~m.on Decetraber 14, 2012,in

18. NOAH ~07NER was located within the school buildin

class=oosn {8), his rixst fade classroom for the school hoots of

the dap, as a student ofthe

SANDY ~~OOK ELENLENTARY SGI~.00L,wbuich is a public


19. At app=oxiumately 9:35pm ADAM r.ANZA~.shot ont fihe

school.

window located next to the locked


NT~IRY SCHOOZ..

school doors, and g~szr.ed easy access to S.ANDX kZOOT~ ELEM~

ts at appro~:imately 9:35 am and

Z0. The main office staffzcported heaaiug glass b=eaking and gunsho

saw a white male with a bat and sunglasses,latex identified as ADAM


buitdiug with arifle-type gun.; he was seep shooting t~ze ~afle down

T.ANZA,come into the

the hallway wbese NOAFI

P07NLlZ'S classroom was located.


al azld other staff at this Time and killed the

21. t1D1~MI.AN~A shot down the hallway at the princip

prindpal and the school psycholog~t who had e~eed confr~ence room

9 s~,t the end of the

49

89 /E5 #

6~Zti0LZ~OZ~

,WdL~~zl~~~-60-10

,.

haU.way to see wk~~t the loud baug~g(gunfire) noises were; all were attending

a pLw.ning and

placement meetitng u*ith other sta members at~,d a students pareats.


o~isc was shut ua the leg; but

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

coz~eseace =oom nice


m system through the

(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

school to heaz what vv~s going

on ire Che bu~diag.


23. ADAM LANZA then entered the main office to the school,

were all staff members were

hiding within the office; ADAM I.AN7~.A exited the school office; and

then he entered the

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)

and then ten (10), tk~e

L.

first grade eLlssrooms of SA1vIUY HOOK ELEMENTARY SC~XOO

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

elsissrooms; batluooms ^which could be locked from the inside.


27. Neithez classzoom eight(8) nor classroom ten (10) had internal locks to their ddozs;
way td sock these doors was to lock them from the outside with a key;

the only

despite heating the


l ~d sciool

gunshots that broke the gLnss window,the gunshots that 1~lIed the priuci~a

SO

89 /tip #

~~ltiOLZOl:

~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

89 /~~ #

~ZtiOL~~OZ~

~WdLti~Z~~96-60-LO

a.

They failed to provide S~1~TDY BOOK F~MENTIIRY SC~XOOT.with dooxs that


could be locked com tie iasxde.

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

89 /95 #

~~~tiOLZOZ~

~WdLti~~L~9~-60-LO

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

safety pxotocols,in violation of CGS 5~557n;


i,

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

89 /L9 #

IZbOLZ~OZ~

~WdLti~Z~~~l-6d-LO

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

S4

89 /8~ #

~IZbOLZ~OZ~

~WdLti,Zl~9~-60-1Q

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

THE SIX'I'~T_COITNT(TI-~ ESTATE OF 1~'OAH POZNER,x.~ONARD POZN~~i.,AS


ADMTNISRA'x~tOR against SANA'Y I3p0g EI.~MENTARY SCT30.OL)
1. PLninrif~ LEONI~RA rOLNER,is t}~e duly appointed Administcato= of the ~sC~te of his son,
NOAH PQZNER,(1~exeiaafter,`2~TOAH X'OZNER").
2. T~efendant, S.AN1~Y HOOK ELEMENTARY SCF~OOL,was,at ali tizzies mentioned herein, a
learning instimrion existing wader the rules, regulations, and guidelines of the Connecticut
General Statutes, N'EWTOWN BOARD OF EDUCA,TZON,the TOWN OF I~T~~'O~WN
and the State of Connecticut and subject to the same zules and regulations as aforet~net~tioned.
3. SANDY HOOK ELEMENTA~tY SCI~OOL vv~as, at all times zucntioned herein,located in the
town aF NeRrtowxl, County of Fairfield, aad Seate of ConuecticuG
4. The defendant,SANDY HOOK F~,EMENTA~RY SCT~OOZ,was to Follow safety p=ocedutes
and policies enacted by TI~L~ 'OWN of NEWTOWN,TOTE NEWTOWN BOARD of
EDUCA,TIUI~ and THE SANDY HOOK ~JEME.NTAI.Z~ 5C1~OOL for the safety ofits
students during school ~o~s;most specifically a "1pGkdown" and evacuatio~t plan enacted
should a stxanget, or other unpzoper or dangerous individual enter the school during school
hours, oz otherwise endanger the students, and to ensure rbe safety ofit9 students.

SS

89 /65 #

~ZtiOLZ~QZ~

;WdLti~Z~~~~-60-LO

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

89 /09 #

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

xyt ,grade classrooms oSANDX I~300I~ EL8NI~NTATt'Y SCT~OOL.

57

89 /~9 #

E~ZtiOLZ~OZ~

~WdLb~Z~~S~-60-LO

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

his own life outside dassioo~m ten (10).

58

89 /Z9 #

~ZtrOLZ~OZ~

:WdL~~Z6:~~-60-LO

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;

59

B9 /~9 #

~ZtiOLz~OZ~

~WdLtr~Z6~~6-60-LO

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.

As a studcnz ofSANDY HOOK F.,I.EMENTARY SC~IOOL,NOAH POZNER


was as ide.~tifiable victim of an imminent ha.~ that bad become transparent to the
teack~er(s) in his classroom when the fast sk~ots vv~xe fired by the shooter to gain
access to the building,

.~

B9 /ti9 #

~lZtiOLZOZ~

~WdLti~Zl~9~-60-LO

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

61

89 /~9 #

~~Zti0LZE0Z~

~WdLb~ZL~~6-60-LO

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.

62

89 /99 #

~~Z~bOLZEOZ~

;WdLti~Z~~~~-60LO

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

63

89 /L9 #

E~ZtiOLZ~OZ~

~WdLti;Z~~9~-60-LO

SUPERIOR COURT

RETURN llATE: JANUARY 27,20 5


THE ES~'ATE OF JESSE,LEWIS, SCARZ.E'IT
LEWIS AS ADMYNISTRATRLY ANI~ NEIT.,
HESLYN AS CO-AT,7~IINSTRATOIt;THE
~ST11TE Or ~TQAH POSNE~i,LEONA1tD
POZNER A5 ADMINISTRATUk~

:~'.D. OF DANBUJ~Y

v,

: AT DANBURX
D~CEIV~SER 12, 2014

THE TOWN OF NEWTC7'1~U1~T,ET 11L.

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 _

,~

89 /89 #

~ZbOLZEOZ~

~WdLb~Z~;S~-60-LO