Soto et al v. Bushmaster Firearms International, LLC et al

Filing 1

NOTICE OF REMOVAL by Remington Outdoor Company, Inc., Remington Arms Company, LLC from Connecticut Superior Court, Judicial District of Fairfield, at Bridgeport Filing fee $ 400 receipt number 0205-3478818, filed by Remington Outdoor Company, Inc., Remington Arms Company, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Whitcomb, Jonathan) (Additional attachment(s) added on 1/15/2015: # 5 REPLACEMENT PDF) (Lynch, K.).

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 1 of 54

EXHIBIT A

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 2 of 54

Service of Process
Transmittal

CT Corporation

12/15/2014
CT Log Number 526238625
TO:

Legal Department
Remington Arms Company, Inc.
PO Box 700
Madison, NC 27025-0700

RE:

Process Served in Connecticut

FOR:

Remington Outdoor Company, Inc. (Domestic State: DE)

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:

TITLE OF ACTION:

Donna L. Soto, Administratrix of the Estate of Victor ia L. Soto, et al.,
Pills. vs. Bushmaster Firearms International, LLC, etc., et al. including Remington
Outdoor Company, Inc., Dfts.

DOCUMENT(S) SERVED:

Summons, Introduction, Instructions, Exhibit(s)

COURT/AGENCY:

Fairfield at Bridgeport Superior Court Judicial District, CT
Case # None

NATURE OF ACTION:

Wrongful Death - Bushmaster AR-15 rifle, model XM15-E2S

ON WHOM PROCESS WAS SERVED:

C T Corporation System, Hartford, CT

DATE AND HOUR OF SERVICE:

By Process Server on 12/15/2014 at 15:30

JURISDICTION SERVED:

Connecticut

APPEARANCE OR ANSWER DUE:

02/03/15

ATTORNEY(S) SENDER(S):

Joshua D. Koskoff
Koskoff, Koskoff Et Bieder, P.C.
350 Fairfield Avenue
Bridgeport, CT 06604
203-336-4421

REMARKS:

The documents received have been modified to reflect the name of the entity being
served.

ACTION ITEMS:

SOP Papers with Transmittal, via Fed Ex 2 Day, 772241424171
Email Notification, Legal Department [e-mail]

SIGNED:
ADDRESS:

C T Corporation System
One Corporate Center
Hartford, CT 06103-3220
860-724-9044

TELEPHONE:

Page 1 of 1 / MEF
Information displayed on this transmittal is for CT Corporations
record keeping purposes only and Is provided to the recipient for
quick reference. This information does not constitute a legal
opinion as to the nature of action, the amount of damages, the
answer date, or any information contained in the documents
themselves. Recipient is responsible for interpreting said
documents and for taking appropriate action. Signatures on
certified mail receipts confirm receipt of package only, not
contents.

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 3 of 54

SUMMONS CIVIL

STATE OF CONNECTICUT

JD-CV-1 Rev. 9-14
C.G.S. §§ 51-346, 51-347, 51-349, 51-350, 52-45a,
52-48, 52-259, P,B. Secs. 3-1 through 3-21, 8-1

See other side for instructions

SUPERIOR COURT
www.jud.ct.gov

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

"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 and
costs is $2,500 or more.
0 "X" if claiming other relief in addition to or in lieu of money or damages.
Address of court clerk where writ and other papers shall be filed (Number, street, town and zip code)
(C. G. S. §§ 51-346, 51-350)

area code)

1061 Main Street, Bridgeport, CT 06604

(

[1] Judicial District

p
D Housing Session

[]

(A .
.
umber

At (Town in which writ is returnable)
Bridge ort

Telephone number of clerk

th

203 )579-6527

(C.G S. §§ 51-346, 51-349)

Return Date (Must be a Tuesday)

3 , 2 015

February
Month

—MT Year

Case type code (See list on page 2)

Major: T

Minor: 90

For the Plaintiff(s) please enter the appearance of:
(Number, street, town and zip code)

Name and address of attorney, law firm or plaintiff if self-represented

-ItinS number (lobe entered by attorney only)

Joshua D. Koskoff, Koskoff, Koskoff & Bieder, 350 Fairfield Avenue, Bridgeport, CT 06604
Telephone number (with area code)

032250

Signature of Plaintiff (If self-represented)

( 203 ) 336-4421
Email address for delivery of papers under Section 10- 13 (i1 agreed to)

The attorney or law firm appearing for the plaintiff, or the plaintiff if
self-represented, agrees to accept papers (service) electronically in
this case under Section 10-13 of the Connecticut Practice Book.

11

Number of Plaintiffs:

Parties
First
Plaintiff
Additional

Plaintiff

No

Yes

[e-mail]

Number of Defendants: 11

Form JD-CV-2 attached for additional parties

Address of Each party (Number; Street; P.O. Box; Town; State; Zip; Country, if not USA)
Name:
P-co
Soto, Donna L., AdmInistratrix of the Estate of Victoria L. Soto, Deceased
Address: 158 Knowlton Street, Stratford, CT 06615
Name (Last, First Middle Initial) and

Name:

Hockley, Ian and Nicole, Co-Administrators of the Estate of Dylan C. Hockley
Charter Ridge Drive, Sandy Hook, CT 06482

Address: 61

!we
?

P-02

P

Address;

Bushmaster Firearms International, LLC aka Freedom Group, Inc. aI Remington e tdoor Company, In
Corp Trust Ctr, 1209 Orange Street, Wilmington, DE1870 Remington D11vtf, Madiso , NC 27025-8331--

0-01

Defendant

Additional
Defendant

Name:
Address:

Freedom Group, Inc aka Freedom Group aka Freedom Group, LLC aka Remington Outdoor Company
Secretary, 870 Remington Drive, Madison, NC 27026/CT Corp System, 1 Corporate Center, Hartford, CT

0-02

Additional

Name:
Address:

Bushmaster Firearms aka Freedom Group, Inc. aka Remington Outdoor Company, Inc.
Secretary, 999 Roosevelt Trail, Windham, ME 04062; CT Corp System, 1 Corporate Center, Hartford, CT

0-03

Defendant

Additional
Defendant

Name:

Bushmaster Firearms, Inc. aka Freedom Group, Inc. aka Remington Outdoor Company, Inc,
Secretary, 999 Roosevelt Trail, Windham, ME 04062; CT Corp System, 1 Corporate Center, Hartford, CT

0-04

First

Name:

Address:

Notice to Each Defendant
I.

yOU ARE BEING SUED. This paper is a Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making

against you in this lawsuit.
2. To be notified of further proceedings, you or your attorney must file a form called an "Appearance" with the clerk of the above-named Court at the above
Court address on or before the second day after the above Return Date. The Return Date is not a hearing date. You do not have to come to court on the
Return Date unless you receive a separate notice telling you to come to court.
3. If you or your attorney do not tile a written "Appearance form on time, a judgment may be entered against you by default. The "Appearance" form may be
obtained at the Court address above or at www.jud.ct.gov under "Court Forms."
4. If you believe that you have insurance that may cover the claim that is being made against you in this lawsuit, you should immediately contact your
insurance representative. Other action you may have to take is described in the Connecticut Practice Book which may be found in a superior court law
library or on-line at www. jud. ct. gov under "Court Rules,"
6. If you have questions about the Summons and Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on

legal uestions.
Sig n

çj Commissioner of the
Superior Court

(S n and 'X" pro

Lj

Assistant Clerk

Name of Person Signing at Left

12/13/2014

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

Signed (Self-Represented Plaintiff)

understand the above:

fa /

4.

File Date

afr
040'
)' I)
,ANA*.6,140C
C, tir tg°
f,14\

Diana Orozco, 350 Fairfield Av ue, Bridgeport,CT 06604
ro er box)

For Court Use Only

Date

Name and address of person recognized to prosecute in the amount of $250

Si•hra, !ffioal taking recogn

Date signed

Joshua D. Koskoff

Commissioner of the
Superior Court
Assistant Clark

(Page 1 of 2)

Date

12/13/2014

ocket Number

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 4 of 54

Instructions
1. Type or print legibly; sign summons.
2. Prepare or photocopy a summons for each defendant.
3. Attach the original summons to the original complaint, and attach a copy of the summons to each copy of the complaint. Also,
if there are more than 2 plaintiffs or more than 4 defendants prepare form JD-CV-2 and attach it to the original and all copies
of the complaint.
4. After service has been made by a proper officer, file original papers and officer's return with the clerk of court.
5. The party recognized to pay costs must appear personally before the authority taking the recognizance.
6. Do not use this form for the following actions:
(a) Family matters (for example divorce, child
support, custody, paternity, and visitation
matters).
(b) Summary process actions.
(c) Applications for change of name.

(d) Probate appeals.
(e) Administrative appeals.
(t) Proceedings pertaining to arbitration.
(g) Any actions or proceedings in 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 accommodation in accordance with the
ADA, contact a court clerk or an ADA contact person listed at wwwjud.ct.gov/ADA.

Case Type Codes
Codes

Major Description

Codes

Minor Description

l'2,1,0
ig

Major Description

tow n

Minor Description

Torts (Other than
Vehicular)

T 02

Defective Premises - Private - Snow or Ice

103

Defective Premises - Private - Other

Minor

Construction - All other
Construction • State and Local

C 20

Insurance Policy

7 11

Defective Premises - Public - Snow or Ice

C 30

Specific Performance

T 12

Defective Premises - Public - Other

C 40

Collections

120

Products Liability - Other than Vehicular

C 90

All other

T 28

Malpractice - Medical

E 00

State Highway Condemnation

7 29

Malpractice - Legal

E 10

Eminent Domain

C 00
C 10

Contracts

Redevelopment Condemnation

E 20

Public Utilities & Gas Transmission Companies

Malpractice - All other

7 40

Other State or Municipal Agencies

E 30

130

Assault and Battery

7 50

Defamation

181

Animals - Dog

E 90

7 89

Animals - Other

M 00

Injunction

T 70

False Arrest

M 10

Receivership

7 71

Fire Damage

M 20

Mandamus

7 90

All other

M 30

Habeas Corpus (extradition, release from Penal
Institution)

V 01

Motor Vehicles' - Driver and/or Passenger(s) vs.
Driver(s)

M 40

Arbitration

V 04

Motor Vehicles' - Pedestrian vs. Driver

NI 50

Declaratory Judgment

V 05

Motor Vehicles' - Property Damage only

M 63

Bar Discipline

V 06

Motor Vehicle' - Products Liability Including Warranty

M 66

Miscellaneous

All other

Department of Labor Unemployment Compensation
Enforcement

V 09

Motor Vehicle' - All other

Vehicular Torts

M 70

Municipal Ordinance and Regulation Enforcement

M 80

Foreign Civil Judgments - C.G.S. 52-604 6 C.G.S.
500-30

M 82

All other

P 00

All other

Foreign Protective Order

M 90

Property

Snowmobiles

V90

Small Claims Transfer to Regular Docket

P/I 84

Railroads

V 40

Housing Civil Matters

NI 83

Airplanes

V 30

Bar Discipline - Inactive Status

Boats

V20

M 68

V 10

Foreclosure

P 10

Partition

P20

Quiet Title/Discharge of Mortgage or Lien

P 30

Asset Forfeiture

P 90

'Motor Vehicles include cars, trucks, motorcycles,
and motor scooters.

All other

Wills, Estates
and Trusts

JD-CV-1 Rev. 9-14 (Back/Page 2)

(Page 2 of 2)

W10

Construction of Wills and Trusts

W 90

All other

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 5 of 54

CIVIL SUMMONS

STATE OF CONNECTICUT
SUPERIOR COURT

CONTINUATION OF PARTIES
JD-CV-2 Rev. 4-97
FIRST NAMED PLAINTIFF (Last, First, Middle Initial)

Soto, Donna L., Administrator of the Estate of Victoria L. Soto, Deceased
FIRST NAMED DEFENDANT (Last First, Middle Initial)

Bushmaster Firearms International, LLC

*;

' Teti

,

ADDITION

ItAINittFFS

NAME (Last, First, Middle Initial, if Individual)
ADDRESS (No., Street, Town and ZIP Code)
Sherlach, William, Executor of the Estate of Mary J. Sheriach
33 Vintage Road, Trumbull, CT 06611
Sherlach, William
33 Vintage Road, Trumbull, CT 06611
Pozner, Leonard, Administrator of the Estate of Noah S. Pozner
,
2615 Main Street, #322, Newtown, CT 06470
Rousseau, Gilles J., Administrator of the Estate of Lauren G. Rousseau
67 Horse Fence Hill Road, Southbury, CT 06488

CODE

03
04
05
06

Wheeler, David C., Administrator of the Estate of Benjamin A. Wheeler
10 Lakeview Terrace, Sandy Hook, CT 06482
Heslin, Neil and Lewis, Scarlett, Co-Administrators of the Estate of Jesse McCord Lewis
6 Great Ring Road, Sandy Hook, CT 06482
Barden, Mark and Jacqueline, Co-Administrators of the Estate of Daniel G. Barden
35 Paugussett Road, Sandy Hook, CT 06482
D'AvIno, Mary, Administratrix of the Estate of Rachel IVI. D'Avino
48 Deerwood Drive, Bethlehem, CT 06751
Hammond, Natalie
108 Munn Road, Southbury, CT 06488

07

08
09

10
11

12
13

4Akft6040410444400#3100WIRMMVAbINTIONAVOtKENESANZSVINVIO

'''OPIt'e, , .;..,

:

4

ADDRESS (No., Street, Town and ZIP Code)
Bushmaster Holdings, LLC aka Freedom Group, Inc. aka Remington Outdoor Company Inc.
Corporation Trust Center, 1209 Orange St. Wilmington, DE/CT Corp. System, One Corporate Center, 11th Fl., Hartford, CT
Remington Arms Co, LLC aka Bushmaster Firearms Int, Inc. aka Freedom Group, Inc aka Remington Outdoor Co.
Ciiiv. Trust Center, 1209,0range'Street Wilmington, DE/CT Corp System, One Corporate Center, 11th Fl., Hartford, CT
Remington Outdoor Company, Inc. aka Freedom Group, Inc.
CT Corp. System, 1 Corporate Ctr, 11th Fl, Hartford, CT 06103-3220/ Secretary, 870 Remington Drive, Madison, NC 27025-8331
Camfour, Inc.
Secretary, 65 Westfield Industrial Park Road, Westfield, MA 01086-1693/Bryan R. Stefano, 1776 Main St., Springfield, MA 01102
Camfour Holding, LLP a/k/a Camfour Holding, Inc.
Secretary, 55 Westfield Industrial Park Road, Westfield, MA 01085-1693/Bryan R. Stefano, 1776 Main St., Springfield, MA 01102
NAME (Last, First, Middle Initial, if individual)

Riverview Sales, Inc.
Agent for Service: Varunes & Associates, 5 Grand Street, Hartford, CT 06106
David LaGuercia
1100 River Road, Agawam, MA 01001/119 Walnut Street, Agawam, MA 01001

CODE

54

55
56
57
58
59

60
FOR COURT USE ONLY FILE DATE
-

61

62

63 D OCKET NO,

CIVIL SUMMONS-Continuation

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 6 of 54

RETURN DATE: FEBRUARY 3, 2015

SUPERIOR COURT

DONNA L. SOTO, ADMINISTRATRIX OF
THE ESTATE OF VICTORIA L. SOTO;
IAN AND NICOLE HOCKLEY,
CO-ADMINISTRATORS OF THE
ESTATE OF DYLAN C. HOCKLEY;
WILLIAM D. SHERLACH, EXECUTOR
OF THE ESTATE OF MARY JOY SHERLACH;
WILLIAM D. SHERLACH, INDIVIDUALLY; :
LEONARD POZNER, ADMINISTRATOR OF :
THE ESTATE OF NOAH S. POZNER;
GILLES J. ROUSSEAU, ADMINISTRATOR :
OF THE ESTATE OF LAUREN G.
ROUSSEAU; DAVID C. WHEELER,
ADMINISTRATOR OF THE ESTATE OF
BENJAMIN A. WHEELER;
NEIL HESLIN AND SCARLETT LEWIS,
:
CO-ADMINISTRATORS OF THE ESTATE OF:
JESSE MCCORD LEWIS;
MARK AND JACQUELINE BARDEN,
CO-ADMINISTRATORS OF THE ESTATE OF:
DANIEL G. BARDEN; MARY D'AVINO,
ADMINISTRATRIX OF THE ESTATE
OF RACHEL M. D'AVINO; and
NATALIE HAMMOND
VS.
BUSHMASTER FIREARMS
INTERNATIONAL, LLC a/k/a FREEDOM :
GROUP, INC. afk/a REMINGTON OUTDOOR:
GROUP, INC; FREEDOM GROUP, INC. a/k/a :
FREEDOM GROUP a/k/a FREEDOM GROUP,:
LLC a/k/a REMINGTON OUTDOOR
COMPANY; BUSHMASTER FIREARMS a/k/a :
FREEDOM GROUP a/k/a REMINGTON
OUTDOOR COMPANY, INC.; BUSHMASTER:
FIREARMS, INC. a/Ida FREEDOM GROUP, :
INC. a/k/a REMINGTON OUTDOOR
COMPANY, INC.; BUSHMASTER
HOLDINGS, LLC a/k/a FREEDOM GROUP,
INC. a/k/a REMINGTON OUTDOOR
•
COMPANY, INC.; REMINGTON ARMS CO., :
LLC, a/k/a BUSHMASTER FIREARMS INT.,
INC., a/k/a FREEDOM GROUP, INC. a/k/a

1

JUDICIAL DISTRICT OF
FAIRFIELD
AT BRIDGEPORT

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 7 of 54

REMINGTON OUTDOOR CO.; REMINGTON :
OUTDOOR COMPANY, INC. a/k/a
FREEDOM GROUP, INC.; CAMFOUR, INC.; :
CAMFOUR HOLDING, LLP a/k/a CAMFOUR :
HOLDING, INC.; RIVERVIEW SALES, INC.; :
DAVID LA GUERCIA DECEMBER 13, 2014
INTRODUCTION
1.
This is a civil action for damages and injunctive relief stemming from the
shooting at Sandy Hook Elementary School on December 14, 2012.
2.
In less than five minutes, 20 first-grade children and 6 adults were killed. Two
others were wounded.
3.
The number of lives lost in those 264 seconds was made possible by the shooter's
weapon of choice: a Bushmaster AR-15 rifle, model XM15-E2S.
4.
The AR-15 was designed as a military weapon, and it has always excelled on the
battlefield. Born out of the exigencies of modern combat, the AR-15 was engineered to deliver
maximum carnage with extreme efficiency.
5.
The AR-15 proved to be very good at its job. It has endured as the United States
Army's standard-issue rifle and has more recently become a valuable law enforcement weapon.
In both contexts, the AR-15 is subject to strict safety measures, including advanced training and
regimented storage.
6.
The AR-15, however, has little utility for legitimate civilian purposes. The rifle's
size and overwhelming firepower, so well adapted to the battlefield, are in fact liabilities in home
defense.
7.
But there is one tragically predictable civilian activity in which the AR-15 reigns
supreme: mass shootings. Time and again, mentally unstable individuals and criminals have
acquired an AR-15 with ease, and they have unleashed the rifle's lethal power into our streets,
our malls, our places of' worship, and our schools.

8.
Defendants makers and sellers of the XM15 E2S rifle have, like all
Americans, watched mass shootings become a harrowing yet predictable part of modern life.
—

-

—

9.
Defendants know that, as a result of selling AR-15s to the civilian market,
individuals unfit to operate these weapons gain access to them.
And defendants know that the AR-15's military firepower, unsuited to home
10.
defense or recreation, enables an individual in possession of the weapon to inflict unparalleled
civilian carnage.

2

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 8 of 54

11.
Despite that knowledge, defendants continued to sell the XM15-E2S rifle to the
civilian market.
12.
In order to continue profiting from the sale of AR-15s, defendants chose to
disregard the unreasonable risks the rifle posed outside of specialized, highly regulated
institutions like the armed forces and law enforcement.
13.
Plaintiffs seek nothing more and nothing less than accountability for the
consequences of that choice,
PARTIES
14.
Defendant Bushmaster Firearms, also known as B.F.I. and B.F.I., Inc., was a
Maine corporation created in 1973 and located in Windham, Maine. Bushmaster Firearms
manufactured and sold AR-15s. Bushmaster Firearms is now part of Freedom Group, Inc.
15.
Defendant Bushmaster Firearms, Inc. was another Maine corporation that
manufactured and sold AR-15s. Upon information and belief, Bushmaster Firearms, Inc.
manufactured and sold AR-15s. Bushmaster Firearms, Inc. is now part of Freedom Group, Inc.
16.
Defendant Bushmaster Firearms International, LLC was a Delaware corporation
that was formed in 2006. (When originally created, it was named Rambo Acquisition, LLC.)
According to corporate filings, Bushmaster Firearms International, LLC was merged into
Remington Arms Company, LLC in 2011.
17.
At all relevant times, Bushmaster Firearms International, LLC manufactured and
sold AR-15s.
18.
Upon information and belief, Bushmaster Firearms International, LLC
manufactured the XM15-E2S that was used in the shooting at Sandy Hook Elementary School on
December 14, 2012.
Defendant Remington Arms Company, LLC is a Delaware limited liability
19.
corporation, Defendant Bushmaster Firearms International, LLC was merged into Defendant
Remington Arms Company, LLC in 2011. At all relevant times, Remington Arms Company,
LLC manufactured and sold AR-15s.
20.
Defendant Bushmaster Holdings, LLC was incorporated in 2006 and operated as a
holding company for Bushmaster Firearms International, Inc. Bushmaster Holdings, LLC
merged into Freedom Group, Inc. in 2009.
21.
Defendant Freedom Group, Inc., which is also sometimes called Freedom Group
and Freedom Group, LLC is a Delaware corporation originally formed under another name in
2007, Freedom Group, Inc, is one of the world's largest manufacturers and dealers in firearms,
ammunition, and related accessories.

3

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 9 of 54

22.
Upon information and belief, from 2006 on, Freedom Group, Inc. controlled,
marketed and sold the Bushmaster brand. Upon information and belief, during this time period
Freedom Group, Inc. sold Bushmaster brand products directly to retail stores.
23.
Defendant Remington Outdoor Company, Inc. is a corporation formed in 2009
that is engaged in the business of manufacturing and selling AR-15s. Freedom Group, Inc.,
which upon information and belief at all relevant times controlled the Bushmaster brand, was
renamed Remington Outdoor Company, Inc.
24.
Upon information and belief, Defendants Bushmaster Firearms; Bushmaster
Firearms, Inc.; Bushmaster Firearms International, LLC; Remington Arms Company, LLC;
Bushmaster Holdings, LLC; Freedom Group, Inc.; and Remington Outdoor Company, Inc. are
functionally one entity and are hereinafter referred to as the "Bushmaster Defendants."
25.
The Bushmaster Defendants manufacture and sell firearms and ammunition under
the Bushmaster brand name.
26.
The Bushmaster Defendants, one or more of them, manufactured and sold the
Bushmaster XM15-E2S rifle that was used in the shooting at Sandy Hook Elementary School on
December 14, 2012,
27.
Defendant Camfour, Inc. is a Massachusetts corporation. Camfour, Inc. was at all
relevant times a distributor of firearms and was federally licensed to deal in firearms.
28.
Defendant Camfour Holding, Inc. aka Camfour Holding, LLF is a Massachusetts
corporation. Upon information belief, Camfour Holding, Inc. aka Camfour Holding, LLP is
functionally the same entity as Camfour, Inc. These entities are hereinafter referred to as the
"Camfour Defendants."
Upon information and belief, the Camfour Defendants purchased the Bushmaster
29.
XM15-E2S rifle that was used in the shooting at Sandy Hook Elementary School from the
Bushmaster Defendants.
30.
The Carnfour Defendants are qualified product sellers within the meaning of 15
U.S.C. § 7903(6).
Upon information and belief, the Camfour Defendants sold the Bushmaster
31.
XM15-E2S rifle that was used in the shooting at Sandy Hook Elementary School to the
Riverview Defendants, as described below.
32.
Defendant Riverview Gun Sales, Inc. aka Riverview Gun Sales is a retail gun
store located in East Windsor, Connecticut. The Bushmaster XM15-E2S rifle that was used in
the shooting at Sandy Hook Elementary School on December 14, 2012 was purchased from
Riverview Gun Sales.

4

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 10 of 54

33.
Defendant David LaGuercia is or was the federally licensed firearms dealer who
through Riverview Gun Sales, Inc. sold the Bushmaster XM15-E2S rifle that was used in the
shooting at Sandy Hook Elementary School.
34.
Riverview Gun Sales, Inc. and David LaGuercia are hereafter referred to as the
"Riverview Defendants." The Riverview Defendants are qualified product sellers within the
meaning of 15 U.S.C. § 7903(6).
35.
On February 7, 2013, Plaintiff Donna L. Soto was appointed Administratrix of the
Estate of Victoria Leigh Soto. A copy of the fiduciary certificate is attached hereto as Plaintiffs'
Exhibit A.
36.
On December 3, 2014, Plaintiffs Ian and Nicole Hockley were appointed CoAdministrators of the Estate of Dylan Christopher Jack Hocldey, A copy of the fiduciary
certificate is attached hereto as Plaintiffs' Exhibit B.
37.
On December 4, 2014, Plaintiff David C. Wheeler was appointed Administrator
of the Estate of Benjamin A. Wheeler. A copy of the fiduciary certificate is attached hereto as
Plaintiffs' Exhibit C.
38.
On January 22, 2013, Plaintiff Mary A. D'Avino was appointed Administratrix of
the Estate of Rachel Marie D'Avino a/k/a Rachel M. D'Avino. A copy of the fiduciary
certificate is attached hereto as Plaintiffs' Exhibit D.
39.
On December 8, 2014, Plaintiffs Mark and Jacqueline Barden were appointed CoAdministrators of the Estate of Daniel G. Barden. A copy of the fiduciary certificate is attached
hereto as Plaintiffs' Exhibit E.
40.
On March 7, 2013, Plaintiff William D. Sherlach was appointed Executor of the
Estate of Mary Joy Sherlach. A copy of the fiduciary certificate is attached hereto as Plaintiffs'
Exhibit F. Mr. Sherlach also brings this action in his individual capacity for loss of consortium.
41.
On December 9, 2014, Plaintiffs Neil Heslin and Scarlett Lewis were appointed
Co-Administrators of the Estate of Jesse McCord Lewis. A copy of the fiduciary certificate is
attached hereto as Plaintiffs' Exhibit G.

On December 10, 2014, Plaintiff Leonard Pozner was appointed Administrator of
42.
the Estate of Noah Samuel Pozner. A copy of the fiduciary certificate is attached hereto as
Plaintiffs' Exhibit H.
43.
On January 3, 2013, Plaintiff Gilles J. Rousseau was appointed Administrator of
the Estate of Lauren G. Rousseau. A copy of the fiduciary certificate is attached hereto as
Plaintiffs' Exhibit I.
44.
Plaintiff Natalie Hammond brings this action in her individual capacity for
injuries suffered on December 14, 2012.

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THE GUN
A.

The Bushmaster XM15 E2S is a Military Weapon
-

, 45.
Bushmaster's XM15-E2S is an AR-15 rifle, a weapon adopted by the United
States military and other armed forces around the world because of its efficiency as a military
assault rifle.
46.
After World War II, the U.S. Army's Operations Research Office analyzed over
three million casualty reports from World War I and World War II. In its final report, the group
observed that modern combat occurred at short range and was highly mobile. More importantly,
they determined that the number one predictor of casualties was the total number of shots fired.
47.
These findings led the U.S. Army to develop specifications for a new combat
weapon: a lightweight firearm that would hold a large detachable magazine and rapidly expel
ammunition with enough velocity to penetrate body armor and steel helmets.
48.
A company called 'Annalite designed the AR-15 in response. Lightweight, aircooled, gas-operated, and magazine-fed, the AR-15's capacity for rapid fire with limited recoil
meant its lethality was not dependent on good aim or ideal combat conditions.
49.
After extensive testing, the military concluded that a five-man squad armed with
AR-15s had equal or superior "hit-and-kill" potential in combat situations when compared with
an 11-man squad armed with M14 rifles, the AR-15's predecessor. Troops field-testing the AR15 reported instantaneous deaths, as well as routine amputations, decapitations, and massive
body wounds. The military ultimately adopted the AR-15 as its standard-issue service rifle,
renaming it the M16.
50.
After Annalite sold its licensing rights, Colt took over its military contracts and
began manufacturing the M16.
Today, Colt remains the largest supplier of combat rifles to the military.

51.

Bushmaster, meanwhile, holds the distinction of being the largest supplier of
52.
combat rifles to civilians.
The XM15-E2S is one such rifle.

53.
B.

A "Civilian" Weapon Designed for Combat

As an AR-15 rifle, the Bushmaster XM15-E2S is essentially indistinguishable
54.
from its military sibling, the M16. Both weapons are designed for mass casualty assaults. Both
share design features of exceptional muzzle velocity, the ability to accommodate large-capacity
magazines, and effective rapid fire.

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Muzzle Velocity
55.
The term "muzzle velocity" refers to the speed a bullet possesses at the moment it
leaves the muzzle of a firearm.
56.
capacity.

The velocity of a bullet on impact is the main determinant of its destructive

57.
Typical handgun muzzle velocities range from approximately 750 feet per second
to approximately 1,300 feet per second.
58.
Because longer barrels give the ammunition's propellant more time to work, long
guns eject projectiles at significantly higher velocities than short-barreled firearms.
59.
AR-15 rifles like the XM15-E2S are capable of propelling ammunition at 4,000
feet per second, which multiplies the lethality of each hit.
60.
According to a study by physicians who performed autopsies on soldiers killed by
gunfire in Iraq, the greater the speed of the bullet on impact, the greater the extent of tissue
deterioration. The study found that rounds with a velocity exceeding 2,500 feet per second cause
a shockwave to pass through the body upon impact that results in catastrophic injuries even in
areas remote to the direct wound.

Large-Capacity Magazines
61.
In addition to exceptional muzzle velocity, AR-15 rifles are also designed to
accept large-capacity magazines.
62.
Such magazines were first designed and produced for the military in order to
increase the firepower of U.S. infantry by minimizing time spent reloading.
63.
"Civilian" AR-15 rifles, including the XM15-E2S, are manufactured to be
compatible with large capacity magazines.

Effective Rapid Fire
All AR-15 rifles, including the XM15-E2S, can empty their magazines with
64.
exceptional speed.
65.
The rifles carried by U.S. forces are capable of both full automatic and
semiautomatic fire. Full automatic fire can empty a 30-round magazine in two seconds.
Semiautomatic fire can empty the same 30-round magazine in approximately ten seconds.
66.
The United States Army considers semiautomatic fire more effective than
automatic fire in most combat situations.

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67.
"Civilian" semiautomatic rifles like the XM15-E2S, therefore, are capable of the
same rapid fire that the U.S. Army deems optimal for the military theater.
68.
Structurally and mechanically, therefore, AR-15 rifles remain the progeny — and
instruments — of war.
69.
Semiautomatic fire unleashes a torrent of bullets in a matter of seconds; largecapacity magazines allow for prolonged assaults; and powerful velocity makes each hit
catastrophic,
70.

The net effect is more wounds, of greater severity, in more victims, in less time.

71.
This superior capacity for lethality — above and beyond other semiautomatic
weapons — is why the AR-15 style rifle has endured as the U.S. military's weapon of choice for
50 years.
C.

A "Civilian" Weapon Marketed for Combat

The uniquely military characteristics of the AR-15 type rifle are not lost on the
72,
Bushmaster Defendants. In fact, they are the weapon's primary selling point.
73.
The Bushmaster Defendants tout Bushmaster rifle barrels as "the finest AR15Type / M16-Type barrels made," promising that they "provide the same matte black, nonreflective finish found on quality military-type arms."
74.
When the Bushmaster Defendants rolled out a new AR-15 rifle model,
defendants' advertising lauded the gun as "the uncompromising choice when you demand a rifle
as mission-adaptable as you are."
75.
The Bushmaster Defendant's 2012 Bushmaster Product Catalogue shows soldiers
moving on patrol through jungles, armed with Bushmaster rifles. Superimposed over the
silhouette of a soldier holding his helmet against the backdrop of an American flag is text that
reads: "When you need to perform under pressure, Bushmaster delivers."
76.
In the Bushmaster Defendant's 2011 Bushmaster Product Catalogue, firearms like
the XM15-E2S are advertised with the slogan, "military-proven performance."
77.
In 2010, the Bushmaster Defendants promoted one of their "civilian" rifles as "the
ultimate combat weapons system."
78.
Invoking the unparalleled destructive power of the weapon, the Bushmaster
Defendants' advertising copy read: "Forces of opposition, bow down. You are single-handedly
outnumbered."

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79.
The Bushmaster Defendants' militaristic marketing reinforces the image of the
AR-15 as a combat weapon used for the purpose of waging war and killing human beings.
80.
This marketing tactic dovetails with the widespread popularity of realistic and
addictive first-person shooter games — most notably "Call of Duty" — that prominently feature
AR-15s and rewards players for "head shots" and "kill streaks" among other assaultive and
violent "achievements."
81.
It is widely known that "Call of Duty" exposes players to intensely realistic
tactical scenarios and teaches assaultive weapon techniques such as "taped reloads," which allow
high capacity magazines to be taped together to reduce reloading time.

D.

A "Civilian" Weapon with no Legitimate Civilian Purpose

82.
As set forth above, the AR-15's combination of exceptional muzzle velocity,
ability to accept large-capacity magazines, and effective rapid fire has significant utility in the
military context. These same features make the weapon ill-suited for legitimate civilian
purposes.

Self-Defense
83.
There is no evidence that semiautomatic rifles are commonly used for, or
necessary for, legitimate self-defense by law-abiding citizens.
84.
of a home.

Semiautomatic rifles' length makes them inferior to smaller guns in the confines

It is handguns, and not long guns, that are widely considered to be the optimal
85.
weapon for home defense,
In D.C. v. Helier, 554 U.S. 570,629 (2008), the Supreme Court of the United
86.
States extolled the handgun as the "quintessential self-defense weapon." The Court cited several
reasons for this: "It is easier to store in a location that is readily accessible in an emergency; it
cannot easily be redirected or wrestled away by an attacker; it is easier to use for those without
the upper-body strength to lift and aim a long gun; it can be pointed at a burglar with one hand
while the other hand dials the police." These virtues are absent from the AR-15.
Semiautomatic rifles are not only ill-suited to home defense, they are dangerous
87.
when used in that capacity.
88.
The velocity and rate of semiautomatic fire in the home creates a significant risk
of what is referred to as "over-penetration," where bullets breach walls and doors, putting family
members, neighbors, and even passers-by at risk.
89.
The military has concluded that use of the M16 in close quarters greatly increases
the risk of noncombatant casualties, and trains soldiers accordingly.

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90.
When a Bushmaster AR-15 was reviewed by Guns & Ammo Magazine in 1983,
the reviewer commented: "As a home defense weapon, it certainly possesses ample firepower
with a 30-round magazine, but the .223 cartridge is a mite too powerful and penetrating for this
use." It concluded that the rifle would instead be of value to "a police S.W.A.T. team in closequarter encounters with evil-doers."
91.
Moreover, the ability to accept large-capacity magazines, vital for modern
combat, is unnecessary for home defense.
92.
The National Rifle Association Institute for Legislative Action ("NRA-ILA")
maintains a database of "armed citizen" stories describing private citizens who have successfully
defended themselves or others using a firearm. According to a study of all incidents in that
database from 1997 to 2001, an average of 2.2 shots were fired by defenders. In 28% of
incidents, no shots were fired at all.
A similar analysis was performed for the period of 2011-2013 and revealed that
93.
defenders fired an average of 2.1 shots.
94.
The likelihood of an AR-15 causing accidental harm when used for home defense
substantially exceeds the likelihood that large quantities of semiautomatic fire will be necessary
for protection.

Hunting and Sporting
The Gun Control Act of 1968 generally prohibits the importation of firearms into
95.
the United States, but makes an exception for weapons that are particularly suitable for or readily
adaptable to sporting purposes.
Congress stated that one of the purposes for the law was to stop the influx of
96.
military-grade weapons, which was turning the United States into "the dumping ground of the
castoff surplus military weapons of other nations."
The Bureau of Alcohol, Tobacco and Firearms (ATF) is responsible for
97.
interpreting the statute and thereby determining the suitability of various firearms for sporting or
hunting purposes.
In 1989, ATF issued a broad suspension of the importation of "assault-type rifles"
98.
until an analysis of their sporting utility could be undertaken. ATF defined this category to
include rifles with three characteristics: a military appearance, a detachable magazine, and the
ability to fire semi-automatically. It referred to this group of weapons as "semiautomatic assault
rifles."
As part of its analysis, ATF studied advertising and marketing literature, reviewed
99.
evaluations of the firearms by technical writers, solicited information from the firearm importers,

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and sent questionnaires to licensed hunting guides, state game and fish commissions, local
hunting associations, competitive shooting groups, and hunting/shooting magazine editors.
100. In its final report, ATF concluded that semiautomatic assault rifles were designed
and intended for combat and not suited to either sporting or hunting. it prohibited the
importation of rifles with military features other than detachable magazines.
101. Foreign gun manufacturers quickly adapted to the restriction. They began
exporting semiautomatic rifles that had been stripped of all military features except for the ability
to accept a detachable magazine. Significantly, these modified rifles had the ability to accept
large-capacity magazines.
102. In 1998, ATF was called upon to evaluate the sporting utility of semiautomatic
assault rifles that accepted large-capacity magazines but lacked other military features.
103. After an equally exhaustive analysis, ATF found it "clear and compelling" that
semiautomatic assault rifles that accept large-capacity magazines are not suitable for sporting or
hunting.
104. ATF concluded that the ability to expel large amounts of ammunition quickly
"serves a function in combat and crime, but serves no sporting purpose."
ENTRUSTMENT OF MILITARY WEAPONS TO THE MILITARY
105. When assault rifles are sold to the military, the seller entrusts them to a highly
regulated institution with expertise in minimizing the risk of physical harm — whether criminal or
accidental — to soldiers or others.
106. Standardized medical fitness standards prohibit induction, enlistment,
appointment, or retention in the Armed Forces if the individual suffers from major depression,
bipolar disorder, affective psychoses, or a history of symptoms consistent with mental instability
that impairs school, social, or work efficiency.
107. When the U.S. Government purchases assault rifles for use by armed forces, it
retains ownership of those weapons.
108.

Military assault rifles are issued to soldiers for instruction, training, exercises, and

109.

Soldiers are held strictly accountable for their assault rifle at all times.

110.

Assault rifles must be kept in safety mode when not in use.

combat.

111. Soldiers are instructed not to leave their assault rifle unattended under any
circumstances.

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112. If an assault rifle cannot be accounted for, the Army will place an entire base or
installation on lockdown until the weapon is located.
113. After the assault rifle is located, an investigation will be conducted and a
recommendation made as to the appropriate punishment.
114. In general, the most lenient punishment for the transgression of misplacing an
assault rifle is to lose rank and pay and to be assigned extra duty.
115.
sanctions.

If an assault rifle is misplaced in a combat zone, the soldier may face severe

116. Assault rifles are stored in secure weapons rooms on military bases. Soldiers
must sign out their rifle anytime they remove it so a chain of custody is established.
117. The military requires soldiers to undergo extensive training on the proper use of
an assault rifle, including techniques to minimize the weapon's potential for inflicting collateral
damage.
118. The Department of the Army produces a 400-page manual for commanders,
leaders, and instructors devoted exclusively to weapon pedagogy and related safety issues.
119. According to the manual, soldiers are first instructed on the weapon's capabilities,
mechanical training, and the fundamentals and principles of rifle marksmanship. Live-fire
applications are scheduled only after the soldier has demonstrated preliminary skills.
120. To ensure safety during live-fire applications, ammunition is issued to firing units
immediately before scheduled training exercises and released to troops only when they are on the
firing line.
121. Commanders are charged with identifying any "hazards" to safety by using a
complex "risk assessment matrix" to estimate the probability and severity of an adverse impact.
The manual notes that hazards may arise from health or behavioral concerns.
122. Military leadership is empowered to prevent access to combat weapons if
circumstances warrant it.
ENTRUSTMENT OF MILITARY WEAPONS TO LAW ENFORCEMENT
123. When military-grade weapons are sold to law enforcement, the seller entrusts
them to organizations and departments that regulate and oversee officers' access to firearms and
possess expertise in minimizing the risk of physical iarm to civilians.
124. Prior to being entrusted with assault rifles, law enforcement officers undergo
extensive training.

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125.

Officers are trained on when it is and is not appropriate to use an assault rifle.

126. For the vast majority of engagements in which it is necessary to draw or use a
firearm, law enforcement considers an officer's sidearm — and not an assault rifle — to be the
most appropriate weapon
127. Police leadership is empowered to remove any weapon from an officer if
circumstances warrant it.
ENTRUSTMENT OF MILITARY WEAPONS TO THE PUBLIC
128. The military and law enforcement have a legitimate need for a weapon as lethal as
the AR-15, but they also recognize that strict safety measures are necessary to protect soldiers,
police officers, and innocent civilians from physical harm. Consequently, entrusting assault
rifles to these specialized institutions is reasonable.
129.

The same is not true for the entrustment of AR-15 rifles to civilians.

130. In addition to the lack of utility set forth above, when AR-15s are entrusted to the
public there is no institutional structure in place to oversee the safe and intelligent use of those
weapons.
131.

AR-15s are sold to wholesalers and/or dealers who sell directly to civilians.

132. Large capacity magazines that are compatible with AR-15s are sold to
wholesalers and/or dealers who sell directly to civilians.
133. In the overwhelming majority of states, young people can legally purchase an
AR-15 before they are legally permitted to drink alcohol.
134. In at least a dozen states, the minimum age for possession of an AR-15 is 14 or
16, or there is no minimum age at all.
135. In the overwhelming majority of states, a license or permit is not required to
purchase or own an AR-15,
136. In the overwhelming majority of states, no safety training is required for the
purchase of an AR-15.
137. There is not a single state that requires a mental health examination of a potential
purchaser of an AR-15.
138. There is not a single state that requires a potential purchaser of an AR-15 to
answer questions about other individuals with whom they intend to share access.
139.

More than half of American households with firearms do not store them securely.

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140. Civilians are entrusted with AR-15s even though they are not suited for legitimate
civilian purposes.
141. Civilians are entrusted with AR-15s whether or not they have a mechanism to
safely secure the weapons and ammunition in their home.
142. Civilians are entrusted with AR-15s even if they have children in the home who
can gain access to their weapons and ammunition.
143. Civilians are entrusted with AR-15s even if they intend to make the weapon
available to other persons, including those who may be mentally unstable.
144. Several highly-publicized mass shootings have demonstrated that perpetrators of
mass shootings are able to purchase or otherwise acquire AR-15s.
THE ROAD TO SANDY HOOK
145. The most chilling legacy of the entrustment of AR-15s to the general population
may be that Americans are no longer shocked when combat weapons are used to kill people as
they work, shop, commute, attend school, and otherwise go about their lives. We may be
horrified, saddened, even sickened, but we can no longer be shocked.
146. Prior to December 14, 2012, assault rifles like the XM15-E2S had been used to
kill in department stores and fast food chains, at offices and homecoming parties, on courthouse
steps, and in schools.
147. Prior to December 14, 2012, assault rifles like the XM15-E2S had torn apart
communities in California and Massachusetts and Nevada and Washington and Nebraska and
Wisconsin and Oregon and Texas and Florida and Washington D.C. and Missouri and Alabama.
148. Prior to December 14, 2012, assault rifles like the XM15-E2S had been used to
kill elementary school children, high school children, and college students.
149. Yet Bushmaster Defendants continued to entrust the XM15-E2S to the civilian
population through wholesalers and dealers.
150. Bushmaster Defendants continued making the XM15-E2S compatible with large
capacity magazines.
151. Bushmaster Defendants continued marketing the XM15-E2S and similar rifles as
combat weapons that would make others "bow down."
152. Sometime prior to March of 2010, the Bushmaster Defendants entrusted the
X1\415-E2S Bushmaster rifle to the Camfour Defendants.

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153. Sometime prior to March of 2010, the Camfour Defendants entrusted the XM15E2S Bushmaster rifle to the Riverview Defendants; the Riverview Defendants then entrusted the
rifle to Nancy Lanza in March of 2010.
154. On the morning of December 14, 2012, Lanza retrieved the Bushmaster rifle and
ten 30-round magazines — several of which he taped together to allow for faster reload — from an
unlocked gun closet in the house he shared with his mother and drove to Sandy Hook Elementary
School.
155. Upon information and belief, Adam Lanza chose the XM15-E2S to use in his
attack on Sandy Hook Elementary School for its military and assaultive qualities, and in
particular its efficiency in inflicting mass casualties.
156. Meanwhile, on the morning of December 14, 2012, Victoria Leigh Soto was a 27year-old first-grade teacher in classroom 10 at Sandy Hook Elementary School.. In fewer than
five years of teaching, Vicki had earned the reputation of being a fun, and sometimes zany,
teacher. Vicki loved snow and had something of an obsession with pink flamingos. Vicki began
her morning, as she usually did, with a long car ride from Stratford to Sandy Hook. On this
particular morning, she had with her all the ingredients and materials for her class to make
gingerbread houses for the holidays.
157. On the morning of December 14, 2012, Dylan Hockley was a six-year-old boy in
classroom 10. Dylan had a beaming smile that lit up a room and an infectious laugh. Dylan was
a child with autism, but was learning to read and would come home every day from school
proudly bearing a new book. He loved the moon, garlic bread, the color purple, cuddling, and
bouncing on the trampoline. Dylan idolized his older brother, and best friend, Jake.
158, On the morning of December 14, 2012, Benjamin Wheeler, 6, wasn't sure if he
wanted to be an architect, a paleontologist, a lighthouse keeper — or all three at once. Benjamin
was a bright, spirited, inquisitive, caring boy who brought joyful energy to his parents and big
brother. He was an avid reader and was becoming a very strong swimmer. Each morning he
could hardly wait to get to classroom 8.
159. On the morning of December 14, 2012, Rachel D'Avino was a 29-year-old
behavioral therapist with a passion for helping children and adults with autism. She was working
toward a doctorate, and aspired to help shape the field of applied behavioral therapy. Rachel
possessed seemingly limitless patience and empathy for the children with whom she worked;
they, in turned, adored her. In eleven days, Rachel's boyfriend planned to propose.
160. On the morning of December 14, 2012, Daniel Barden was — at age 7 — one of the
older children in classroom 8. Daniel understood things about life in a way that prompted many
who knew him to call him an "old soul." Daniel was not only bright and loving; he understood
what it meant to live life with compassion. Daniel always made an effort to make other children
around him feel accepted. He would take notice of children who sat alone and would ask to go
sit with them or invite them to join an activity. He gave hugs often, and with abandon.

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161. On the morning of December 14, 2012, Mary Sherlach was a 56-year-old school
psychologist at Sandy Hook Elementary School. After 18 years at the school, Mary was
planning to retire the following June. On her calendar for retirement was spending more time
with her husband, Bill, to whom she had been married for 31 years, and patiently waiting for one
of her two daughters to provide her with a grandchild. Although retirement would allow more
time for gardening and reading, Mary still planned on remaining professionally active for the
pure joy that she took from helping a child through a difficult time.
162. On the morning of December 14, 2012, Jesse Lewis, 6, was a first-grader in
classroom 10. The only child of Neil Heslin and Scarlett Lewis, Jesse loved to ride horses, play
memory card games for which he was known to be unbeatable, and have books read to him by
his mother. He also loved going out for special breakfasts before school with his dad. On the
morning of December 14, father and son found time to enjoy a sausage and egg sandwich,
polished off by hot chocolate.
163. On the morning of December 14, 2012, Noah Pozner was the youngest first
grader in classroom 10, having just turned six only three weeks before. Noah loved costumes,
video games, and superheroes — especially Spiderman. He was also a budding philosopher,
known to stump his parents with spontaneous questions about Creation and the nature of free
will. He was, truly, a force of nature.
164. On the morning of December 14, 2012, Lauren Rousseau, 30, headed to Sandy
Hook Elementary School, where she had recently landed a permanent substitute teaching job.
That day, she was scheduled to teach in classroom 8. Lauren's warmth, enthusiasm, and
creativity made her a natural first-grade teacher. That evening, Lauren planned to see the movie
"The Hobbit" with her boyfriend and then attend a party with friends. Lauren had already made
cupcakes for the party, each one featuring a different character from The Hobbit.
165. On the morning of December 14, 2012, Natalie Hammond, 40, began her day as
Lead Teacher of Sandy Hook Elementary School. It was special day for Natalie; her daughter
was turning 12.
166. Just before 9:30 am, Lanza shot his way into the locked school with the
Bushmaster rifle. It was the weapon he would use to take every life in the school aside from his
own.
167. Mary Sherlach and the school's principal were in a meeting when they heard
shots. When they went to investigate, both were killed with the Bushmaster rifle. Natalie
Hammond and another staff member were shot with the Bushmaster rifle and wounded.
168.

Lanza then approached two first-grade classrooms, Classroom 8 and Classroom

10.
169. In Classroom 8, Lanza used the Bushmaster rifle to kill 15 children and 2 adults,
including Daniel Barden, Benjamin Wheeler, Noah Pozner, Rachel D'Avino, and Lauren
Rousseau.

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170. In Classroom 10, Lanza used the Bushmaster rifle to kill 5 children and 2 adults,
including Dylan Hockley, Jesse Lewis, and Victoria Soto.
171. Nine children from Classroom 10 were able to escape when Lanza paused to
reload the Bushmaster with another 30-round magazine.
172. The first call to 911 from Sandy Hook Elementary School was made at 9:35am.
By 9:40am, Lanza's massacre was complete.
173. Police collected 154 spent .223 casings that had been expelled from the
Bushmaster rifle.
COUNT ONE: § 52-555 Wrongful Death
(Estate of Victoria L. Soto v. Bushmaster Defendants)
1.-173. Plaintiffs hereby incorporate and reallege as if fully set forth herein Paragraphs
1-173 of the foregoing opening section.
174. The Bushmaster Defendants knew, or should have known, of all of the foregoing
information alleged at Paragraphs 1-10, 45-173. Based on this and similar information, the
Bushmaster Defendants knew, or should have known, that the sale of assault rifles, including the
XM15-E2S, in the civilian market posed an unreasonable and egregious risk of physical injury to
others.
175. The Bushmaster Defendants knew, or should have known, of the civilian
population's poor track record of safely securing weapons.
176. A mass casualty event, such as the shooting at Sandy Hook Elementary School,
was within the scope of the risk created by the Bushmaster Defendants' manufacture and sale of
the XM15-E2S for the civilian market.
177. The Bushmaster Defendants knew, or should have known, of the unreasonably
high risk that the XM15-E2S would be used in a mass shooting to inflict maximum casualties
before law enforcement was able to intervene.
178. The Bushmaster Defendants knew, or should have known, that schools are
particularly vulnerable to — and frequently targets of — mass shootings.
179. The Bushmaster Defendants knew, or should have known, that the utility of the
XM15-E2S for hunting, sporting or self-defense was negligible in comparison to the risk that the
weapon would be used in its assaultive capacity.
180. The Bushmaster Defendants knew, or should have known, that the XM15-E2S,
when used in its assaultive capacity, would be likely to inflict multiple casualties and serious
injury.

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181. The Bushmaster Defendants, as those who deal in firearms, are required to
exercise the closest attention and the most careful precautions in the conduct of their business.
182. The Bushmaster Defendants have for years sold AR-15s in a manner that
foreseeably leads to the use of those weapons by unauthorized and unsafe users.
183. The Bushmaster Defendants have had the ability for years to design and
manufacture AR-15s for the civilian population with safety mechanisms that prevent the weapon
from being fired by someone other than the purchaser.
184. The Bushmaster Defendants have had the ability for years to design and
manufacture AR-15s for the civilian market that do not accept large capacity magazines.
185. The Bushmaster Defendants' conduct had a continuing inherent or natural
tendency to create danger and inflict injury, was offensive to public policy, and posed a serious
risk to public health.
186. The Bushmaster Defendants' conduct interfered with the right of the public to be
safe in their communities, and, more particularly, of children to be safe in their schools.
187. In this case, on information and belief, the Bushmaster Defendants supplied the
XN115-E2S to the Camfour Defendants for resale to the civilian population.
188. The Bushmaster Defendants knew, or should have known, that the Camfour
Defendants' use of the product — the supply to the civilian market — involved an unreasonable
risk of physical injury to others.
189.
nuisance.

The Bushmaster Defendants' conduct as previously alleged constituted a public

190. Upon information and belief, the Bushmaster Defendants' conduct as previously
alleged constituted a knowing violation of the Connecticut Unfair Trade Practices Act,
Connecticut General Statutes Section 42-110a et seq.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Victoria Soto, as further described in the
following two paragraphs.
192. On December 14, 2012, plaintiff's decedent, Victoria Soto, suffered the following
injuries and losses:
a.
b.
c.
d.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and

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e. death.
193. As a result of the injuries and death of Victoria Soto, the Estate of Victoria Soto
incurred funeral expenses to its financial loss.
COUNT TWO: § 52-555 Wrongful Death
(Estate of Victoria L. Soto v. Camfour Defendants)
1.-173. Plaintiffs hereby incorporate and realiege as if fully set forth herein Paragraphs
1-173 of Count One.

174. The Camfour Defendants knew, or should have known, of all of the foregoing
information alleged at Paragraphs 1-10, 45-173 of Count One. Based on this and similar
information, the Camfour Defendants knew or should have known that the sale of assault rifles,
including the XM15-E2S, in the civilian market posed an unreasonable and egregious risk of
physical injury to others.
175. The Camfour Defendants knew, or should have known, of the civilian
population's poor track record of safely securing weapons.
176. A mass casualty event, such as the shooting at Sandy Hook Elementary School,
was within the scope of the risk created by the Camfour Defendants' sale of the XM15-E2S to
the civilian market.
177. The Camfour Defendants knew, or should have known, of the unreasonably high
risk that the XM15-E2S would be used in a mass shooting to inflict maximum casualties before
law enforcement was able to intervene.
178. The Camfour Defendants knew or should have known that schools are
particularly vulnerable to — and frequently targets of— mass shootings.
179. The Carnfour Defendants knew, or should have known, that the utility of the
XM15-E2S for hunting, sporting or self-defense was negligible in comparison to the risk that the
weapon would be used in its assaultive capacity.
180. The Camfour Defendants knew, or should have known, that the XM15-E2S, when
used in its assaultive capacity, would be likely to inflict multiple casualties and serious injury.
181. The Camfour Defendants, as those who deal in firearms, are required to exercise
the closest attention and the most careful precautions in the conduct of their business.
182. The Candour Defendants have for years sold AR-15s in a manner that foreseeably
leads to the use of those weapons by unauthorized and unsafe users.

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183. The Camfour Defendants' conduct had a continuing inherent or natural tendency
to create danger and inflict injury, was offensive to public policy, and posed a serious risk to
public health.
184. The Camfour Defendants' conduct interfered with the right of the public to be
safe in their communities, and, more particularly, of children to be safe in their schools.
185. The Camfour Defendants are a qualified product seller within the meaning of 18
U.S.C. § 7903(6).
186. In this case, on information and belief, the Camfour Defendants supplied the
XM15-E2S to the Riverview Defendants for resale to the civilian market.
187. The Camfour defendants knew, or should have known, that the Riverview
Defendants' use of the product — supplying it to the civilian population — involved an extreme
and unreasonable risk of physical injury to others.
188. The Camfour Defendants' conduct as previously alleged constituted a public
nuisance.
189. Upon information and belief, the Camfour Defendants' conduct as previously
alleged constituted a knowing violation of the Connecticut Unfair Trade Practices Act,
Connecticut General Statutes Section 42-110a et seq.
190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Victoria Soto, as further described in the
following two paragraphs.
191. On December 14, 2012, plaintiff's decedent, Victoria Soto, suffered the following
injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

192. As a result of the injuries and death of Victoria Soto, the Estate of Victoria Soto
incurred funeral expenses to its financial loss.
COUNT THREE: § 52-555 Wrongful Death
(Estate of Victoria L. Soto v. Riverview Defendants)
I. - 173. Plaintiffs hereby incorporate and reallege as if fully set forth herein Paragraphs
1-173 of Count One.

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174. The Riverview Defendants knew, or should have known, of all of the foregoing
information alleged at Paragraphs 1-10, 45-173 of Count One. Based on this and similar
information, the Riverview Defendants knew or should have known that the sale of assault rifles,
including the XM15-E2S, in the civilian market posed an unreasonable and egregious risk of
physical injury to others.
175. The Riverview Defendants knew, or should have known, of the civilian
population's poor track record of safely securing weapons.
176. A mass casualty event, such as the shooting at Sandy Hook Elementary School,
was within the scope of the risk created by the Riverview Defendants' sale of the XM15-E2S to
Nancy Lanza.
177. The Riverview Defendants knew, or should have known, of the unreasonably high
risk that the XM15-E2S would be used in a mass shooting to inflict maximum casualties before
law enforcement was able to intervene.
178. The Riverview Defendants knew, or should have known, that schools are
particularly vulnerable to — and frequently targets of— mass shootings.
179. The Riverview Defendants knew, or should have known, that the utility of the
XM15-E2S for hunting, sporting or self-defense was negligible in comparison to the risk that the
weapon would be used in its assaultive capacity.
180. The Riverview Defendants knew, or should have known, that the XM15-E2S,
when used in its assaultive capacity, would be likely to inflict multiple casualties and serious
injury.
181. The Riverview Defendants, as those who deal in firearms, are required to exercise
the closest attention and the most careful precautions in the conduct of their business.
182. The Riverview Defendants for years sold AR-15s in a manner that foreseeably led
to the use of those weapons by unauthorized and unsafe users.
183. The Riverview Defendants' conduct had a continuing inherent or natural tendency
to create danger and inflict injury, was offensive to public policy, and posed a serious risk to
public health.
184. The Riverview Defendants' conduct interfered with the right of the public to be
safe in their communities, and, more particularly, of children to be safe in their schools.
185. The Riverview Defendants are a qualified product seller within the meaning of 18
U.S.C. § 7903(6).
186. The Riverview Defendants began the process of selling the XM15-E2S rifle to
Nancy Lanza on March 15, 2010.

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187. The Riverview Defendants transferred the XM15-E2S rifle to Nancy Lanza on
March 29, 2010.
188. The Riverview defendants knew, or should have known, that Nancy Lanza's
receipt and possession of the XM15-E2S involved an unreasonable risk of physical injury to
others.
189. The Riverview Defendants' sale of the XM15-E2S involved an unreasonable risk
of physical injury to others.
190. The Riverview Defendants' conduct as previously alleged constituted a public
nuisance.
191. Upon information and belief, the Riverview Defendants' conduct as previously
alleged constituted a knowing violation of the Connecticut Unfair Trade Practices Act,
Connecticut General Statutes Section 42-110a et seq.
192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Victoria Soto, as further described in the
following two paragraphs.
On December 14, 2012, plaintiff's decedent, Victoria Soto, suffered the
193.
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

194. As a result of the injuries and death of Victoria Soto, the Estate of Victoria Soto
incurred funeral expenses to its financial loss.
COUNT FOUR: § 52-555 Wrongful Death
(Estate of Dylan C. Hockley v. Bushmaster Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-190. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Dylan Hockley, as further described in the
following two paragraphs.

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192. On December 14, 2012, plaintiffs' decedent, Dylan Hockley, suffered the
following injuries and losses:
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

193. As a result of the injuries and death of Dylan Hockley, the Estate of Dylan C.
Hockley incurred funeral expenses to its financial loss.
COUNT FIVE: § 52-555 Wrongful Death
(Estate of Dylan C. Hocldey v. Camfour Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174. - 189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two.
190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Dylan Hockley, as further described in the
following two paragraphs.

191. On December 14, 2012, plaintiffs' decedent, Dylan Hockley, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

192. As a result of the injuries and death of Dylan Hockley, the Estate of Dylan C.
Hockley incurred funeral expenses to its financial loss.
COUNT SIX: § 52-555 Wrongful Death
(Estate of Dylan C. Hockley v, Riverview Defendants)
1. - 173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.

174.-191. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three.

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192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Dylan Hockley, as further described in the
following two paragraphs.
193. On December 14, 2012, plaintiffs' decedent, Dylan Hockley, suffered the
following injuries and losses:
a. Terror;
b, ante-mortem pain and suffering;
c. destruction of the ability to enjoy life's activities;
d. destruction of earning capacity; and
e. death.
194. As a result of the injuries and death of Dylan Hockley, the Estate of Dylan C.
Hockley incurred funeral expenses to its financial loss.
COUNT SEVEN: §52-555 Wrongful Death
(Estate of Mary Joy Sherlach v. Bushmaster Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-190. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Mary Joy Sherlach, as further described in
the following two paragraphs.
192. On December 14, 2012, plaintiff's decedent, Mary Joy Sherlach, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

193. As a result of the injuries and death of Mary Joy Sherlach, the Estate of Mary Joy
Sherlach incurred funeral expenses to its financial loss.

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COUNT EIGHT: §52-555 Wrongful Death
(Estate of Mary Joy Sherlach v. Camfour Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two.
190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Mary Joy Sherlach, as further described in the
following two paragraphs.
191. On December 14, 2012, plaintiff's decedent, Mary Joy Sherlach, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

192. As a result of the injuries and death of Mary Joy Sherlach, the Estate of Mary Joy
Sherlach incurred funeral expenses to its financial loss.
COUNT NINE: §52-555 Wrongful Death
(Estate of Mary Joy Sherlach v. Riverview Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-191. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three.
192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Mary Joy Sherlach, as further described in the
following two paragraphs.
193. On December 14, 2012, plaintiff's decedent, Mary Joy Sherlach, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

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194. As a result of the injuries and death of Mary Joy Sherlach, the Estate of Mary Joy
Sherlach incurred funeral expenses to its financial loss.
COUNT TEN: Loss of Consortium
(William D. Sherlach v. Bushmaster Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-190. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Mary Joy Sherlach.
192. At all times mentioned herein, the plaintiff William D. Sherlach was the husband
of Mary Joy Sherlach.
193. As a result of the aforesaid occurrences to Mary Joy Sherlach, the plaintiff
William Sherlach has been deprived of the companionship and society of his wife, all to his
damage.
COUNT ELEVEN: Loss of Consortium
(William D. Sherlach v. Camfour Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two.
190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Mary Joy Sherlach.
191. At all times mentioned herein, the plaintiff William D. Sherlach was the husband
of Mary Joy Sherlach.
192. As a result of the aforesaid occurrences to Mary Joy Sherlach, the plaintiff
William Sherlach has been deprived of the companionship and society of his wife, all to his
damage.

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COUNT TWELVE: Loss of Consortium
(William D. Sherlach v. Riverview Defendants)
1.-173. Plaintiff hereby incorporates and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-191. Plaintiff hereby incorporates and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three.
192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Mary Joy Sherlach.
193. At all times mentioned herein, the plaintiff William D. Sherlach was the husband
of Mary Joy Sherlach.
194. As a result of the aforesaid occurrences to Mary Joy Sherlach, the plaintiff
William Sherlach has been deprived of the companionship and society of his wife, all to his
damage.
COUNT THIRTEEN: § 52-555 Wrongful Death
(Estate of Noah S. Pozner v. Bushmaster Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.

174.-190. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Noah Pozner, as further described in the
following two paragraphs.
192. On December 14, 2012, plaintiff's decedent, Noah Pozner, suffered the following
injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

193. As a result of the injuries and death of Noah Pozner, the Estate of Noah S. Pozner
incurred funeral expenses to its financial loss.

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COUNT FOURTEEN: § 52-555 Wrongful Death
(Estate of Noah S. Pozner v. Camfour Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two.
190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Noah Pozner, as further described in the
following two paragraphs.
191, On December 14, 2012, plaintiff's decedent, Noah Pozner, suffered the following
injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

192. As a result of the injuries and death of Noah Pozner, the Estate of Noah S. Pozner
incurred funeral expenses to its financial loss.
COUNT FIFTEEN: § 52-555 Wrongful Death
(Estate of Noah S. Pozner v. Riverview Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-191. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three.
192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Noah Pozner, as further described in the
following two paragraphs.
193. On December 14, 2012, plaintiff's decedent, Noah Pozner, suffered the following
injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

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194. As a result of the injuries and death of Noah Pozner, the Estate of Noah S. Pozner
incurred funeral expenses to its financial loss.
COUNT SIXTEEN: § 52-555 Wrongful Death
(Estate of Lauren G. Rousseau v. Bushmaster Defendants)
1,-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-190. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Lauren Rousseau, as further described in
the following two paragraphs.
192. On December 14, 2012, plaintiff's decedent, Lauren Rousseau, suffered the
following injuries and losses:

a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

193. As a result of the injuries and death of Lauren Rousseau, the Estate of Lauren G.
Rousseau incurred funeral expenses to its financial loss.
COUNT SEVENTEEN: § 52-555 Wrongful Death
(Estate of Lauren G. Rousseau v. Cainfour Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two.
190, The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Lauren Rousseau, as further described in the
following two paragraphs.
191. On December 14, 2012, plaintiff's decedent, Lauren Rousseau, suffered the
following injuries and losses:
a. Terror;

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b.
c.
d.
e.

ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

192. As a result of the injuries and death of Lauren Rousseau, the Estate of Lauren G.
Rousseau incurred funeral expenses to its financial loss.
COUNT EIGHTEEN: § 52-555 Wrongful Death
(Estate of Lauren G. Rousseau v. Riverview Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-191. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three,
192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Lauren Rousseau, as further described in the
following two paragraphs.
193. On December 14, 2012, plaintiff's decedent, Lauren Rousseau, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

194. As a result of the injuries and death of Lauren Rousseau, the Estate of Lauren G.
Rousseau incurred funeral expenses to its financial loss.
COUNT NINETEEN: § 52-555 Wrongful Death
(Estate of Benjamin A. Wheeler v. Bushmaster Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-190. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Benjamin Wheeler, as further described in
the following two paragraphs.

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192. On December 14, 2012, plaintiffs decedent, Benjamin Wheeler, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

193. As a result of the injuries and death of Benjamin Wheeler, the Estate of Benjamin
A. Wheeler incurred funeral expenses to its financial loss.
COUNT TWENTY: § 52-555 Wrongful Death
(Estate of Benjamin A. Wheeler v. Camfour Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two.
190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Benjamin Wheeler, as further described in the
following two paragraphs.
191. On December 14, 2012, plaintiff's decedent, Benjamin Wheeler, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

192. As a result of the injuries and death of Benjamin Wheeler, the Estate of Benjamin
A. Wheeler incurred funeral expenses to its financial loss,
COUNT TWENTY-ONE: § 52-555 Wrongful Death
(Estate of Benjamin A. Wheeler v. Riverview Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-191. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three.

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192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Benjamin Wheeler, as further described in the
following two paragraphs.
193. On December 14, 2012, plaintiff's decedent, Benjamin Wheeler, suffered the
following injuries and losses:

a. Terror;
b. ante-mortem pain and suffering;
c. destruction of the ability to enjoy life's activities;
cl, destruction of earning capacity; and
e. death.
194. As a result of the injuries and death of Benjamin Wheeler, the Estate of Benjamin
A. Wheeler incurred funeral expenses to its financial loss.
COUNT TWENTY-TWO: § 52-555 Wrongful Death
(Estate of Jesse McCord Lewis v. Bushmaster Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-190, Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Jesse McCord Lewis, as further described
in the following two paragraphs.
192. On December 14, 2012, plaintiffs' decedent, Jesse McCord Lewis, suffered the
following injuries and losses:
a. Terror;
b. ante-mortem pain and suffering;
c. destruction of the ability to enjoy life's activities;
d. destruction of earning capacity; and
c. death.
193. As a result of the injuries and death of Jesse McCord Lewis, the Estate of
Benjamin A. Wheeler incurred funeral expenses to its financial loss,
COUNT TWENTY-THREE: § 52-555 Wrongful Death
(Estate of Jesse McCord Lewis v. Cam four Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.

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174.-189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two.
190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Jesse McCord Lewis, as further described in the
following two paragraphs.
191. On December 14, 2012, plaintiffs' decedent, Jesse McCord Lewis, suffered the
following injuries and losses:
a. Terror;
b. ante-mortem pain and suffering;
c, destruction of the ability to enjoy life's activities;
d. destruction of earning capacity; and
e. death.
192. As a result of the injuries and death of Jesse McCord Lewis, the Estate of Jesse
McCord Lewis incurred funeral expenses to its financial loss.
COUNT TWENTY-POUR: § 52-555 Wrongful Death
(Estate of Jesse McCord Lewis v. Riverview Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-191. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three.
192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Jesse McCord Lewis, as further described in the
following two paragraphs.
193. On December 14, 2012, plaintiffs' decedent, Jesse McCord Lewis, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

194. As a result of the injuries and death of Jesse McCord Lewis, the Estate of Jesse
McCord Lewis incurred funeral expenses to its financial loss.

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COUNT TWENTY-FIVE: § 52-555 Wrongful Death
(Estate of Daniel G. Barden v. Bushmaster Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-190. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting in the injuries, suffering, and death of Daniel Barden, as further described in the
following two paragraphs.
192. On December 14, 2012, plaintiffs' decedent, Daniel Barden, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

193. As a result of the injuries and death of Daniel Barden, the Estate of Daniel G.
Barden incurred funeral expenses to its financial loss.
COUNT TWENTY-SIX: § 52-555 Wrongful Death
(Estate of Daniel G. Barden v. Camfour Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two.
190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Daniel Barden, as further described in the
following two paragraphs.
191. On December 14, 2012, plaintiffs' decedent, Daniel Barden, suffered the
following injuries and losses;
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

34

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 40 of 54

192. As a result of the injuries and death of Daniel Barden, the Estate of Daniel G.
Barden incurred funeral expenses to its financial loss,
COUNT TWENTY-SEVEN § 52-555 Wrongful Death
(Estate of Daniel G. Barden v. Riverview Defendants)
1,-173, Plaintiffs hereby incorporate and re-allegea.s if fully set forth herein
1-173 of Count One.

=graphs

114,.,191. Plaintiffs hereby incOrnorate and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three.
192. The Riverview Defendants' conduct as previously allugettwas,a substantial factor
resulting in the injuries, suffering, and death of Daniel Barden, : as further described in the
following two paragraphs.
193. On December 14, 2012, plaintiffs' decedent, Daniel Barden, suffered ,the
following injuries and l.SsSI.
a.
b.
c.
d.
e.

Terror;
ante-mortern pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

194. As a result of the injuries and death of Daniel Barden, the Estate of Daniel G.
arden incurred funeral expenses to its financial loss.
COUNT TWENTY-EIGHT 52-555 Wrongful Death
(Estate of Rachel M. D'Avino v. Bushmaster Defendants)
1,473. Plaintiffs hereby incorporate and re-allege as if fully set forth heroin Paragraphs
1-173 of Count One.
174.-190. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial,
factor resulting in the injuries, suffering, and death of Rachel D'Avino, as further described in
the following two paragraphs.
192. On December 14, 2012, plaintiff's decedent, Rachel D'Avino, suffered the
following injuries and losses:
a. Terror;

35

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 41 of 54

b.
c.
d.
e.

ante-mortem pain and suffering;
destruction of the ability to enjoy• life's activities;
destruction of earning capacity; and
death.

193. As a result of the injuries and death of Rachel D'Avino, the Estate of Rachel.M.
D'Avino incurred funeral expenses to its financial loss.
COUNT TWENTY-NINE: 52-555 Wrongful Death
(Estate of Rachel M. D'Avino v. Camfour Defendants)
1,173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-1710f Count One,
174;7489. Plaintiffsberebyincorporate and re-allege as if fully set forth herein
Patosts* 174-189 of Count Two.
190; The Carnfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Rachel D'Avino, as further described in the
following two paragraphs.
101 On December 14, 2012, plaintiff's decedent, Rachel D'Avino,„ suffered the
following injuries and losseat
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death.

192. As a result of the injuries and death of Rachel D'Avino, the Estate of Rachel M.
D'AVitto incurred funeral expenses to its financial loss.
COUNT THIRTY; § 52-555 Wrongful Dtath
(Estate of Rachel M. D'Avino v. Riverview Defendants)
173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One,
174.-191. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-191 of Count Three.
192. The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries, suffering, and death of Rachel D'Avino, as further described in the
following two paragraphs.

36

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 42 of 54

193. On December 14, 2012, plaintiff's decedent, Rachel D'Avino, suffered the
following injuries and losses:
a.
b.
c.
d.
e.

Terror;
ante-mortem pain and suffering;
destruction of the ability to enjoy life's activities;
destruction of earning capacity; and
death,

194. As a result Of the injuries and death Of RachellrAvine t the Estate of Rachel M.
D'Avino incurred funeral expenses to its financial loss.
COUNT THIRTY-ONE: § 52-555 Wrongful Death
(Natalie Haingwav, Bushmaster Defendants)
1.-171. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-190, Plaintiffs hereby incOrpora and re-allege as if fully set forth herein
Paragraphs 174-190 of Count One.
191. The Bushmaster Defendants' conduct as previously alleged was a substantial
factor resulting the injuries and suffering of Natalie Hammond, as further described in the
following two paragraphs,
192. On December 14, 2012, plaintiff, Natalie Hammond, suffered the following
injuries and losses:
a. Terror;
b. pain and suffering;
c. severe, permanent and painful injuries to her left calf, left foot, left thigh and
left hand;
d. destruction of the ability to enjoy life's activities; and
e. destruction of earning capacity.
193. As a result of such injurie.s, Ms. Hammond incurred medical expenses to her
financial loss.
COUNT THIRTY-TWO: § 52-555 Wrongful Death
(Natalie Hammond v. Camfour Defendants)
1.-173. Plaintiffs hereby incorporate and re-allege as if fully set forth herein Paragraphs
1-173 of Count One.
174.-189. Plaintiffs hereby incorporate and re-allege as if fully set forth herein
Paragraphs 174-189 of Count Two,

37

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 43 of 54

190. The Camfour Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries and suffering of Natalie Hammond, as further described in the following
two paragraphs.
191. On December 14, 2012, plaintiff, Natalie Hammond, suffered the following
injuries and losses:
a. Terror;
b. pain and suffering;
c. severe, permanent and painful injuries to her left calf, left foot, left thigh and
left hank
d. destruction of the ability to enjoy life's activities; and
e. destruction of earning capacity,
192. As a result of such injuries, Ms. Hammond incurred medical expenses to her
financial loss.
COUNT THIRTY-THREE: § 52=555 Wrongful Death
(Natalie Hammond v. Riverview Defendants)
1.-173. Plaintiffs hereby incolporateandrerallege as if fully set forth herein Paragraphs
1473 of Count One
174,491. Plaintiffs hereby incorporate and re-allege .as if fully set forthlerein
Paragraphs 174-191 of Count Three,
19Z The Riverview Defendants' conduct as previously alleged was a substantial factor
resulting in the injuries and suffering of Natalie Hammond, as further described in the following
two paragraphs.
193. On December 14, 2012, plaintiff, Natalie Hammond, suffered the following
injuries and losses:
a. Terror;
b. pain and suffering;
c. severe, permanent and painful injuries to her left calf, left foot, left thigh and
left hand;
d. destruction of the ability to enjoy life's activitiet,and
e. destruction of earning capacity.
194. As a result of such injuries, Ms. Hammond incurred medical expenses to her

financial loss.

38

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 44 of 54

WHEREFORE, THE PLAINTIFFS CLAIM DAMAGES IN EXCESS OF FIFTEEN
THOUSAND DOLLARS AND THE FOLLOWING gEtrEF AS FURTHER SET FORTH
BELOW:
Plaintiffs seek relief as follows:
A. Monetary damages;
B. Punitive damage•;,
C. Attorneys'

fees;

R., Costs;
E. Injunctive relief-

This matter

the jurisdiction of this

COWL

39

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 45 of 54

Of this writ, with your doings thereon, make due terviCe and return.
3 rif of December, 2014.
Dated at Bridgeport Connecticut this

1

THE PLAINTIFFS

By
Josh a D. oskoff
Alin r Sterling
Katie Mesner-Hage
Koskoff, Koskoff & Bieder,
350 Fairfield Avenue
Bridgeport, CT 06604
Juris No. 032250
Tel: 203:336 - 4421
Fax: [phone]
-

PLEASE ENTER THE APPEARANCE OF:
Koskoff, Koskoff Biedgr
350 Fairfield Avenue
Bridgeport, CT 06604
for the Plaintiffs

40

-

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 46 of 54

FIDUCIARY'S PROBATE
CERTIFICATE
PC 450 REV, 8/02

STATE OP' CONNECTICUT
COURT OF PROBATE

COURT OF PROBATE, Stratford Probate District

DISTRICT NO. PO47

ESTATE OF/1N THE MATTER. OF

DATE OF CERTIFICATE
February 7, 2013
Valid for:

Victoria Leigh Soto (I-3-00070)

year from this date

FIDUCIARY'S MOTION OF TRUST

F1DUCIARN4S'NAME AND ADDRESS
Donna Louise Snip, 1411 Knowlton fte.,0t, Stratford, CT

0661 5 .

„

-

7:

1,

Adrninistratrik

DATE OF APPOINTMENT
February 7, 2013

The undersigned hereby certifies that the flduCtetry,ofthe above-named estate has accepted appointment, has executed bond according to
law Orkar.40*cusettfroth executing bond by will or by statute, and Is legally authorized and qualified to act zr such fiduciary on said
estate because said appointment is unrevolied and in fullforce as of the above dote of certificate.
Limitation,

it any; on the above certificate:

IN TESTIMONY WFIEREOF, I have hereunto set tny hancl and affixed the seal this Coun Oil tbe above date of certificate.

11444(<.14e. PY1111,ftv
1
(

„
Lorraine Magi lone, Assistant Clerk

Court
Seal
NOT VALID WITHOUT COURT OF PROBATE SEAL IMPRESSED

EXHIBIT A

FIDUCIARY'S PROBATE CERTIFICATE
PC-450

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 47 of 54

FIDUCIARY'S PROBATE
CERTIFICATE
PC-450 REV. 7/13

STATE.OF CONNECTICUT
COURT OF PRORATE

COURT OF PROBATE, Northern F'alrfield County

DISTRICT NO PD45

ESTATE OF/IN THE MATTER OF

DATE OF CERTIFICATE
December 3, 2014

Dylan Christopher Jack Hockley, (14.0564)

FIDUCIARY'S NAME AND ADDRESS
lan-Hockley, 61 Charter RidgelDrive. SandyHook, CT
06482
Nicole Hocicley, 61 - harter Ridge Drive3 Sandy Wick,
C
CT O648
•

FIDUCLARY'SPOSITIONOF TRUST

DATE OF APPOINTMENT

Co-Administrator

December 3, 2014

Co-Administrator

December 3,2014

aufhorizetiond qyalffied
eiindiistineitherelvoertifies.thatthefidimiary ip• the Ox•i**ngpsiNikiiiriggi• has; *septet/ qppoinanerg. i.r
•.
= •••
•
to ci ti-ak4fichitiai;;Ncauseihit..
—appoailment is liarevaiod lard itefulliaraE h afthe aboolf data of ciitVicaik •

This certificateJs valid for oneygarfronk Ott date erth*eertineate ,
Other limitation, f ru. oribe above cettificate:

IN TESTIMONY WHEREOF, rhava hbretiAtti set my hand antriffdett the seal of this Court; on

above date of Certificate.

AtinssIVI. Lucchesi, Clerk
Court
Seal

•

NOT VALID WITHOUT COURT OF PROBATE SEAL IMPRESSED

EXHIBIT B
FIDUCIARY'S PROBATE CERTIFICATE

PC-450

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 48 of 54

FIDUCIARY'S PROBATE
CERTIFICATE

PC-450 REV. 7/13

STATE OF CONNECTICUT

COURT OF PROBATE

COURT OF PROBATE, Northern Fairfield County

DISTRICT NO. PO45

ESTATE OF/IN THE MATTER OF

DATE OF CERTIFICATE
December 10, 2014

Benjamin Andrew Wheeler, (14-0567)

FIDUCIARY'S NAME AND ADDRESS
David Cole Wheeler, 10 Lakeview Terrace, -Sandy Hook,
CT 064E2

FIDUCIARY'S POSITION Or TRUST
ActroMistrator

DATE OF APPOINTMENT
Deceinberk2014

The undersigned hereby certifies that the fiduciary in the above - named matter has accepted appointment, is legally authorized and qualified
to act, oSsUchfichtelary because the appointment is unrevoked and in fulljbrce as olthe above date of certificate.

This certificate is valid for one year from the date of the certificate.
Other limitation, V any, on the above car qflcuie:

IN TESTIMONY 'HEREOF, I have hereunto set *land and affixed the seal of this Court on the above date of certificate.
-

Inc Buckle, Clue erk
Court

NOT VALID WITHOUT COURT OF PROBATE SEAL IMPRESSED

EXHIBIT C
FIDUCIARY'S PROBATE CERTIFICATE

PC-450

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 49 of 54

FIDUCIARY'S PROBATE
CERTIFICATE
PC 450 REV. 7113

STATE OF CONNECTICUT
COURT OF PROBATE

COURT OF PROBATE, Region #22 Probate District

DISTRICT NO. PD22

ESTATE OF/IN THE MATTER OF

DATE OF CERTIFICATE
December 10, 2014

RACHEL MARIE D'AVINO, , AKA RACHEL M. D'AVINO (13-0036)

FAMCIARY'S NAMWAND ADDFASS
Mary A. DtAvinoc48 Dierwoocittivei Bethlehem., ,OF
06751

FIDUCIARY'S POSITION OF TRUST
Administratrix

DATE OF APPOINTMENT
January 22, 20IS

The undersigned hereby ceri0ezOtaiditirfiduciaty In ileabove-named matter has accepted appointment, blegdij authorized and qualitW,
„
to act as such fiduclaty becatdiethketftp,ohttmentis.era ul Mild! fbrce as oldie above date of certificate.

This certificate is valid or o

•

vat from the date of the certificate.

Other !imitation, ifanyn?I.bVQ.ccIfijtig
. •

DITBSTimp, i O-ypp,ToF, I lu.tWhereunto set my hand and affixed the seal of this Court on the above date of certificate.
I-, . \
1 \ ...* :"..'..
.
0.':.:. .. f' Y.-) IV' Ji....,) ''. ....Al.,-" •
'`..*, • Ci, V,!.
T,-;J.: •:-.• .
-', ..".": .\;•. 1.4
‘ • '," :0 "4 '
'( u
Pamela L. Osborne, Assistant Clerk
..'.... r.

'..„:'

;

W101 11. 0.

NOT Ymf

Tho1T COT OF PROBATE SEAL IMPRESSED

EXHIBIT D
FIDUCIARY'S PROBATE CERTIFICATE

PC-450

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 50 of 54

FIDUCIARY'S PROBATE
CERTIFICATE
PC-450 REV. 7/13

STATE OF CONNECTICUT
COURT OF PROBATE

COURT OF PROBATE, Northern Fairfield County

DISTRICT NO. PD45

ESTATE OF/IN THE MATTER OF

PATE OF CERTIFICATE
December 10A 2014,

Daniel Gerard Barden, (14-0577)

DuaAWS NAME AND ADDRESS
Mark Barden, 35 Paugnssett Road, Sandy Hook, CT
06482
Jacqueline Barden, 35 FaugussettRoad, Sandy Hook, CT
06482

FIDUCIARY'S POSITION OF TRUST

" DATE:OP Mic*ri+ONT

Co-Administrator

December 8, 2014

C6Admin.istrator

December .8, 2014

The undersigned hereto! , certifies that the fiduciaty in the above-named matter has accepted appointment, is legally authorized and qualffied
tc. act as such fiduciwy because the appointment is nnrevolred#nd infitil force as of the above date of certificate

This certificate is valid far one'yearitoni the date Otthecertiflcate.
Other limitation, trany, on the above certificate:

TESTIMONYNMERECiPi

aye beiein osetmyhandand affix

the seal of th Court on the above date of certificate:

/OA
4

1

o

e e4 Buckle, Chief Clerk

Court
Seal

NOT VALID WITHOUT COURT-OP PROBATE SEAL IMPRESSED,

.,.

EXHIBIT E

FIDUCIARY'S PROBATE CERTIFICATE

PC-450

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 51 of 54
1j001/001

12/09/2014 22:11 FAX

FIDUCIARY'S PROBATE
CERTIFICATE
PC-450 REV. 7/1;

STATE OF CONNECTICUT
COURT OF PROBATE

COURT OF PROBATE, Tram bull Probate District

DISTRICT NO. PO46

ESTATE OF/IN THE MATTER OF

AkTEOF CERTWICATE
December 19.20)4

Mary Joy Sherlock, la% of Trumbull, AKA MARY J. SliERLACII (I -00062)

FIDUCIARY'SNAME AND ADDRESS

William - a Sherlock, 33 viotogeWii,'Tturribliii, CT
060

FIDUCIARY'S POSITION OF TRUST

DATE OF APPONTIVIDIT

Executor

March 7,2013

The undersigna hereby cerien Otirthe fichicicry in ourabove-natned matter has actePted appeihhnint, is legally auaortzed anciquoleicist
10 gig os,suchlkhicitoy her.vo.nr iho upiwirtornmt unrevoktd andin/id/f orte at ofthe above dam Qfisr 1 lflcwe,

Thisseertiticate Is valid tor one year frentthedate , of the affiliate.
Oilier Ilitliailtak if any, as the above certificate:

IN TESTIMONY- WHEREOF, I llinlbereuntoset aft hand and affixed the seal of this Court on the above dim of certitle

Q

9)".91CLir ks 9.
. 119)

e ikj o •ery
ve 449.4.

i

s

1.47. *.

-

..

Susan M, Pubs, A55111ttirit Clerk
Court
sat.

NOT VALID WITIIOUT COURT OF PROBATE SEAL IMPRESSED

EXHIBIT F
FIDUCIARY'S PROBATE CERTIFICATE

PC-450

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 52 of 54

FIDUCIARY'S PROBATE
CERTiFiCATE
PC-450 REV. 7/13

STATE OF CONNECTICUT
COURT OF PROBATE

COURT OF PROBATE, Northern Fairfield County

DISTRICT NO. PD45

ESTATE um TEE MAI TER OF
Jessie McCord Lewis„ AKA Jessie]

DATE OF CERTIFICATE
December BY, 2014

Lewis (13-0048)

FIDUCIARY'S NAN'S AND ADDRESS
Stirlen Lewis, 6 Great Ring Road, Sandy Hook, CT
06482
Neil Heslin, 90 Polar Drive, Shelton, CT 06484

FIDUCIARY'S POSITION OF TRUST

DATE OF APPOINTMENT

Co-Admiaistrator,

December 9, 2014

Co-Administrator, diiit

December 9, 2014

The Undersigned hereby detail that the fiduciary in the above-named matter has accepted appolnantag Is legally authorized and qualified
to act as such fiduciary because the appointment kunrevolted and in fid,1 force as of the above date oftertfficate.

This certilleatels valid for one year frOg the dat.e of the certificate.
Othier limitation, trot% on the above certificate:

,T.P.Mgew WHEREOF, I have herewith s

certificate.

COO
Seal

NOT vAxo WITHOUT COURT OF PROBATE SEAL IMPRESSED

EXHIBIT G
FIDUCIARY'S PROBATE CERTIFICATE

PC -450

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 53 of 54

FIDUCIARY'S PROBATE
CERTIFICATE
PC-450 REV. 7/13

STATE OF CONNECTICUT
COURT OF PROBATE

COURT OF PROBATE, Northern Fairfield County

DISTRICT NO. P1)45

ESTATE OF/IN ME MATTER OF

DA1E OF CERTIFICATE

December 10.2

Noah Samuel Poxner, (14-0589)

FIDUCIARY'S NAME AND ADDRESS

Leonard Pomer, 261 South Main Street, 11332, Newtown,
CT 06470

FIDUCIARY'S POSITION OP 'MOST
Atiminis.tratot

. DATE OP APPOINTMENT
Domber itia014

The undersigned hereby cortege that the Nuctcry in the above-named matter has accepted appointment, Is egally authorized and
because the appointment aormked and infay farce as of the above date of certificate.

to act

This certificate is valid for one year from the date of the certificate.
•ptherlimitation, if any, on the above certificate:

IN TESTIMONY WHEREOF, I haw hereunto. set my hand and affixed the

trt.. theabove date of certificate.
en

tee, Clerk

Can't
Seak

NOT VALID WITHOUT COURT OF PROBATE SEAL tveRESSED

EXHIBIT H

FIDUCIARY'S PROBATE CERTIFICATE

PC-450

Case 3:15-cv-00068-RNC Document 1-1 Filed 01/14/15 Page 54 of 54
•

FIDUCIARY'S PROBATE
CERTIFICATE
K450, REV. 7/13

••

•`•• •

.• •

STATE OF CONNECTICUT

COURT OF PROBATE

COUItT OF PROBATE, Danbury Probate District

DISTRICT NO. P1)43

DATE OF CERTIFICATE

ESTATE OF/IN THE MATIER OF

December'll, 201Z

Lauren G. Rousseau, (13-0007)

FIDUCIARY'S NAME AND ADDRESS
Gilles J. ROUSS8414 67-IrOrSe Felitle Hill Road, Southbury,
T6488

FIDUCIARY'S POSITION TRUtt

ONTMENT

,

Mint:list:00r

lanuaryt 2013

The undersigned hereby certifies that the fiduciary in the above..named matter has accepted appointment, is legally authorized and qualified
to act as such fiduciary because the appointment is unrevoked and in full force as of the above date of certificate.

This certificate is valid for one year from the date of the certificate.
Other limitation, if any, on the abovecertificate:

IN TESTIMONY AltifEREOP, I have hereunto set my hand and affixed the seal of tills Co
.
.

acT• of certificate.
:oy iite

.......

Jessica
.

Assistant Clerk

Court
Seal

NOT VALID.../UROUT COURT OF PROBATE SEAL UYIPRESSED

EXHIBIT I

FIDUCIARY'S PROBATE CERIII.ICATE

PC-450