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Transcript of Santos Complaint
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RETURN DATE: APRIL 8, 2014 : SUPERIOR COURT
SANDRA SANTOS, ET AL : J.D. OF NEW HAVEN
V. : AT NEW HAVEN
UNITED ILLUMINATING
COMPANY THE, ET AL : FEBRUARY 28, 2014
COMPLAINT
COUNT ONE: SANDRA SANTOS v. UNITED ILLUMINATING COMPANY THE (negligence)
1. At all times herein mentioned the defendant, UNITED ILLUMINATING COMPANY
THE (hereafter United Illuminating), was a Connecticut corporation with a place of business at 180
Marsh Hill Road, Orange, CT 06477.
2. At all times herein mentioned the defendant, United Illuminating, acting through its
servants, agents and/or employees was involved in the development, design, erection, fabrication,
installation, maintenance, operation and/or supervision of activities surrounding the construction and
maintenance of the power lines and conductivity located at or near the area of 301 and 305 Howard
Avenue in New Haven, Connecticut.
3. On or about March 3, 2012, at about 7:41 am, the plaintiff, SANDRA SANTOS, was
inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
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4. On or about March 3, 2012, at about 7:41 am, the plaintiff, FELISBERTO SANTOS,
was inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
5. On or about March 3, 2012, at about 7:41 am, the plaintiff, JONATHAN SANTOS ppa
SANDRA SANTOS (hereafter Jonathan Santos), was inside a residence located at 305 Howard
Avenue in New Haven, Connecticut.
6. On or about March 3, 2012, at about 7:41 am, the plaintiff, JOCELYN SANTOS ppa
SANDRA SANTOS (hereafter Jocelyn Santos), was inside a residence located at 305 Howard
Avenue in New Haven, Connecticut.
7. On or about that date, there was a gas-related explosion which caused the plaintiff, to
sustain and suffer the personal injuries and losses hereinafter set forth.
8. The gas explosion and resulting personal injuries and losses of the plaintiff were caused
by the carelessness and negligence of the defendant, United Illuminating, acting through its servants,
agents and/or employees in one or more of the following ways:
a. IN THAT it failed to adequately and properly maintain a high voltage power line
in the area of 301 and 305 Howard Avenue in New Haven, Connecticut;
b. IN THAT it failed to adequately and properly inspect in a timely manner the
down power line in the area of 301 and 305 Howard Avenue in New Haven,
Connecticut;
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c. IN THAT it failed to adequately and properly secure the area where the downed
line was located at or near 301 and 305 Howard Avenue in New Haven,
Connecticut;
d. IN THAT it failed to adequately and properly conduct a damage assessment upon
becoming aware that there was a downed line in the area of 301 and 305 Howard
Avenue in New Haven, Connecticut;
e. IN THAT it failed to adequately and properly coordinate with others, including
Southern Connecticut Gas Company and the local homeowners, to be certain
there were no gas leaks caused by the downed line;
f. IN THAT it failed to adequately and properly inspect and test for any gas leaks in
the area before activating, reactivating and/or turning the power back on in the
area, particularly including the electricity for 301 and 305 Howard Avenue;
g. IN THAT it failed to warn the residents of 301 and 305 Howard Avenue that it
was going to turn the power back on before doing so even though it knew or
should have known that it had not yet adequately inspected and/or tested for gas
leaks and/or had others conduct such tests; and
h. IN THAT it reactivated and turned the electrical power back on at a time when it
knew or should have known that it was not safe to do so;
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9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to SANDRA SANTOS, in that:
a. She suffered from smoke inhalation;
b. She suffered from respiratory distress and all of its accompanying symptoms;
c. She suffered cuts, bruises, abrasions, and/or burns;
d. She suffered physical trauma to her left second toe;
e. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
f. She suffered and/or continues to suffer from Asthma and all of its accompanying
symptoms;
g. She suffered and/or continues to suffer from Panic Disorder and its accompanying
chronic attacks;
h. She suffered and/or continues to suffer from sleep apnea/insomnia;
i. She suffered and/or continues to suffer from depression;
j. She suffered and/or continues to suffer from severe anxiety;
k. She experienced concussive force from the blast;
l. She experienced severe mental trauma;
m. She has endured great pain of body, mind, and humiliation;
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10. As a result of her injuries, SANDRA SANTOS incurred expenses for ambulance
transportation, hospitalization, X-Rays, medical treatment and care, psychiatric treatment, and for
matters incidental thereto, and will be required to incur similar expenses in the future.
11. At the time of this explosion and fire, SANDRA SANTOS was employed, and as a result
of her injuries she was not able to perform such work, and she may not be able to do so from time to
time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may
be permanently impaired.
12. As a further result thereof, the plaintiff, SANDRA SANTOS, has been forced to incur
financial obligations for hospital and medical care and treatment, diagnostic studies, x-rays, medicines
and the like.
13. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a loss of
wages and/or earning capacity, and her future earning capacity is diminished, all to her further loss and
detriment.
14. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a reduction in
her ability to pursue his usual activities to the same extent as prior to the accident, all to her further loss
and detriment.
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COUNT TWO: SANDRA SANTOS v. SOUTHERN CONNECTICUT GAS COMPANY THE(negligence)
1. At all times herein mentioned the defendant, SOUTHERN CONNECTICUT GAS
COMPANY THE (hereafter SCGC), was a Connecticut corporation with a principal place of
business at 60 Marsh Hill Road, Orange, CT 06477 in Orange, Connecticut.
2. At all times herein mentioned the defendant, SCGC, acting through its servants, agents
and/or employees was involved in the development, design, erection, fabrication, installation,
maintenance, operation and/or supervision of activities surrounding the construction and maintenance
of the natural gas lines located at or near the area of 301 and 305 Howard Avenue in New Haven,
Connecticut.
3. On or about March 3, 2012, at about 7:41 am, the plaintiff, SANDRA SANTOS, was
inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
4. On or about March 3, 2012, at about 7:41 am, the plaintiff, FELISBERTO SANTOS,
was inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
5. On or about March 3, 2012, at about 7:41 am, the plaintiff, JONATHAN SANTOS ppa
SANDRA SANTOS (hereafter Jonathan Santos, was inside a residence located at 305 Howard
Avenue in New Haven, Connecticut.
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6. On or about March 3, 2012, at about 7:41 am, the plaintiff, JOCELYN SANTOS ppa
SANDRA SANTOS (hereafter Jocelyn Santos), was inside a residence located at 305 Howard
Avenue in New Haven, Connecticut.
7. On or about that date, there was a gas-related explosion which caused the plaintiff, to
sustain and suffer the personal injuries and losses hereinafter set forth.
8. The gas explosion and resulting personal injuries and losses of the plaintiff were caused
by the carelessness and negligence of the defendant, SCGC, acting through its servants, agents and/or
employees in one or more of the following ways:
a. IN THAT it failed to exercise reasonable care in installing the instrumentalities
to supply natural gas for the area of 301 and 305 Howard Avenue.
b. IN THAT it failed to properly maintain the instrumentalities supplying natural
gas to the area of 301 and 305 Howard Avenue.
c. IN THAT it failed to properly maintain the instrumentalities supplying gas to the
area of 301 and 305 Howard Avenue.
d. IN THAT it failed to prevent the ignition of natural gas in the area 301 and 305
Howard Avenue.
e. IN THAT it failed to implement safeguards for the conductivity of its
instrumentality;
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f. IN THAT it failed to contain the natural gas in the area of 301 and 305 Howard
Avenue;
g. IN THAT it did not adequately pre-odorize the natural gas;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to SANDRA SANTOS, in that:
a. She suffered from smoke inhalation;
b. She suffered from respiratory distress and all of its accompanying symptoms;
c. She suffered cuts, bruises, abrasions, and/or burns;
d. She suffered physical trauma to her left second toe;
e. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
f. She suffered and/or continues to suffer from Asthma and all of its accompanying
symptoms;
g. She suffered and/or continues to suffer from Panic Disorder and its accompanying
chronic attacks;
h. She suffered and/or continues to suffer from sleep apnea/insomnia;
i. She suffered and/or continues to suffer from depression;
j. She suffered and/or continues to suffer from severe anxiety;
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k. She experienced concussive force from the blast;
l. She experienced severe mental trauma;
m. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, SANDRA SANTOS incurred expenses for ambulance
transportation, hospitalization, X-Rays, medical treatment and care, psychiatric treatment, and for
matters incidental thereto, and will be required to incur similar expenses in the future.
11. At the time of this explosion and fire, SANDRA SANTOS was employed, and as a result
of her injuries she was not able to perform such work, and she may not be able to do so from time to
time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may
be permanently impaired.
12. As a further result thereof, the plaintiff, SANDRA SANTOS, has been forced to incur
financial obligations for hospital and medical care and treatment, diagnostic studies, x-rays, medicines
and the like.
13. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a loss of
wages and/or earning capacity, and her future earning capacity is diminished, all to her further loss and
detriment.
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14. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a reduction in
her ability to pursue his usual activities to the same extent as prior to the accident, all to her further loss
and detriment.
COUNT THREE: SANDRA SANTOS v. UIL HOLDINGS CORPORATION (negligence)
1. At all times herein mentioned the defendant, UIL HOLDINGS CORPORATION
(hereafter UIL), was a Connecticut corporation with a principal place of business at 157 Church
Street, New Haven, Connecticut.
2. At all times herein mentioned the defendant, UIL, acting through its servants, agents
and/or employees was involved in the development, design, erection, fabrication, installation,
maintenance, operation and/or supervision of activities surrounding the construction and maintenance
of the power lines and conductivity located at or near the area of 301 and 305 Howard Avenue in New
Haven, Connecticut.
3. On or about March 3, 2012, at about 7:41 am, the plaintiff, SANDRA SANTOS, was
inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
4. On or about March 3, 2012, at about 7:41 am, the plaintiff, FELISBERTO SANTOS,
was inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
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5. On or about March 3, 2012, at about 7:41 am, the plaintiff, JONATHAN SANTOS ppa
SANDRA SANTOS (hereafter Jonathan Santos), was inside a residence located at 305 Howard
Avenue in New Haven, Connecticut.
6. On or about March 3, 2012, at about 7:41 am, the plaintiff, JOCELYN SANTOS ppa
SANDRA SANTOS (hereafter Jocelyn Santos), was inside a residence located at 305 Howard
Avenue in New Haven, Connecticut.
7. On or about that date, there was a gas-related explosion which caused the plaintiff, to
sustain and suffer the personal injuries and losses hereinafter set forth.
8. The gas explosion and resulting personal injuries and losses of the plaintiff were caused
by the carelessness and negligence of the defendant, United Illuminating, acting through its servants,
agents and/or employees in one or more of the following ways:
a. IN THAT it failed to adequately and properly maintain a high voltage power line in
the area of 301 and 305 Howard Avenue in New Haven, Connecticut;
b. IN THAT it failed to adequately and properly inspect in a timely manner the down
power line in the area of 301 and 305 Howard Avenue in New Haven, Connecticut;
c. IN THAT it failed to adequately and properly secure the area where the downed line
was located at or near 301 and 305 Howard Avenue in New Haven, Connecticut;
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d. IN THAT it failed to adequately and properly conduct a damage assessment upon
becoming aware that there was a downed line in the area of 301 and 305 Howard
Avenue in New Haven, Connecticut;
e. IN THAT it failed to adequately and properly coordinate with others, including
Southern Connecticut Gas Company and the local homeowners, to be certain there
were no gas leaks caused by the downed line;
f. IN THAT it failed to adequately and properly inspect and test for any gas leaks in the
area before activating, reactivating and/or turning the power back on in the area,
particularly including the electricity for 301 and 305 Howard Avenue;
g. IN THAT it failed to warn the residents of 301 and 305 Howard Avenue that it was
going to turn the power back on before doing so even though it knew or should have
known that it had not yet adequately inspected and/or tested for gas leaks and/or had
others conduct such tests; and
h. IN THAT it reactivated and turned the electrical power back on at a time when it
knew or should have known that it was not safe to do so;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to SANDRA SANTOS, in that:
a. She suffered from smoke inhalation;
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b. She suffered from respiratory distress and all of its accompanying symptoms;
c. She suffered cuts, bruises, abrasions, and/or burns;
d. She suffered physical trauma to her left second toe;
e. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
f. She suffered and/or continues to suffer from Asthma and all of its accompanying
symptoms;
g. She suffered and/or continues to suffer from Panic Disorder and its accompanying
chronic attacks;
h. She suffered and/or continues to suffer from sleep apnea/insomnia;
i. She suffered and/or continues to suffer from depression;
j. She suffered and/or continues to suffer from severe anxiety;
k. She experienced concussive force from the blast;
l. She experienced severe mental trauma;
m. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, SANDRA SANTOS incurred expenses for ambulance
transportation, hospitalization, X-Rays, medical treatment and care, psychiatric treatment, and for
matters incidental thereto, and will be required to incur similar expenses in the future.
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11. At the time of this explosion and fire, SANDRA SANTOS was employed, and as a result
of her injuries she was not able to perform such work, and she may not be able to do so from time to
time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may
be permanently impaired.
12. As a further result thereof, the plaintiff, SANDRA SANTOS, has been forced to incur
financial obligations for hospital and medical care and treatment, diagnostic studies, x-rays, medicines
and the like.
13. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a loss of
wages and/or earning capacity, and her future earning capacity is diminished, all to her further loss and
detriment.
14. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a reduction in
her ability to pursue his usual activities to the same extent as prior to the accident, all to her further loss
and detriment.
COUNT FOUR: FELISBERTO SANTOS v. UNITED ILLUMINATING COMPANY THE
(negligence)
1-8. Paragraphs 1 through 8 of the FIRST COUNT are hereby incorporated and made
Paragraphs 1 through 8 of this the SECOND COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to FELISBERTO SANTOS, in that:
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a. He suffered cuts, bruises, abrasions, and/or burns;
b. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
c. He suffered and/or continues to suffer from an altered mental status;
d. He suffered and/or continues to suffer from sleep apnea/insomnia;
e. He suffered and/or continues to suffer from depression;
f. He suffered and/or continues to suffer from severe anxiety;
g. He experienced concussive force from the blast;
h. He experienced severe mental trauma;
i. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, FELISBERTO SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
11. At the time of this explosion and fire, FELISBERTO SANTOS was employed, and as a
result of his injuries he was not able to perform such work, and he may not be able to do so from time
to time in the future, with a resulting financial loss of earnings and his earning capacity was, is and may
be permanently impaired.
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COUNT FIVE: FELISBERTO SANTOS v. SOUTHERN CONNECTICUT GAS COMPANYTHE (negligence)
1-8. Paragraphs 1 through 8 of the SECOND COUNT are hereby incorporated and made
Paragraphs 1 through 8 of this the FIFTH COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to FELISBERTO SANTOS, in that:
a. He suffered cuts, bruises, abrasions, and/or burns;
b. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
c. He suffered and/or continues to suffer from an altered mental status;
d. He suffered and/or continues to suffer from sleep apnea/insomnia;
e. He suffered and/or continues to suffer from depression;
f. He suffered and/or continues to suffer from severe anxiety;
g. He experienced concussive force from the blast;
h. He experienced severe mental trauma;
i. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, FELISBERTO SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
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11. At the time of this explosion and fire, FELISBERTO SANTOS was employed, and as a
result of his injuries he was not able to perform such work, and he may not be able to do so from time
to time in the future, with a resulting financial loss of earnings and his earning capacity was, is and may
be permanently impaired.
COUNT SIX: FELISBERTO SANTOS v. UIL HOLDINGS CORPORATION (negligence)
1-8. Paragraphs 1 through 8 of the THIRD COUNT are hereby incorporated and made
Paragraphs 1 through 8 of this the SIXTH COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to FELISBERTO SANTOS, in that:
a. He suffered cuts, bruises, abrasions, and/or burns;
b. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
c. He suffered and/or continues to suffer from an altered mental status;
d. He suffered and/or continues to suffer from sleep apnea/insomnia;
e. He suffered and/or continues to suffer from depression;
f. He suffered and/or continues to suffer from severe anxiety;
g.
He experienced concussive force from the blast;
h. He experienced severe mental trauma;
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i. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, FELISBERTO SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
11. At the time of this explosion and fire, FELISBERTO SANTOS was employed, and as a
result of his injuries he was not able to perform such work, and he may not be able to do so from time
to time in the future, with a resulting financial loss of earnings and his earning capacity was, is and may
be permanently impaired.
COUNT SEVEN: JONATHAN SANTOS ppa SANDRA SANTOS v. UNITED ILLUMINATING
COMPANY THE (negligence)
1-8. Paragraphs 1 through 8 of the FIRST COUNT are hereby incorporated and made
Paragraphs 1 through 8 of this the SEVENTH COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to JONATHAN SANTOS, in that:
a. He suffered from smoke inhalation;
b. He suffered from respiratory distress and all of its accompanying symptoms;
c. He suffered cuts, bruises, abrasions, and/or burns;
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d. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
e. He suffered and/or continues to suffer from sleep apnea/insomnia;
f. He suffered and/or continues to suffer from depression;
g. He suffered and/or continues to suffer from severe anxiety;
h. He experienced concussive force from the blast;
i. He experienced severe mental trauma;
j. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, JONATHAN SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
COUNT EIGHT: JONATHAN SANTOS ppa SANDRA SANTOS v. SOUTHERN
CONNECTICUT GAS COMPANY THE (negligence)
1-8. Paragraphs 1 through 8 of the SECOND COUNT are hereby incorporated and made
Paragraphs 1 through 8 of this the EIGHTH COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to JONATHAN SANTOS, in that:
a. He suffered from smoke inhalation;
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b. He suffered from respiratory distress and all of its accompanying symptoms;
c. He suffered cuts, bruises, abrasions, and/or burns;
d. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
e. He suffered and/or continues to suffer from sleep apnea/insomnia;
f. He suffered and/or continues to suffer from depression;
g. He suffered and/or continues to suffer from severe anxiety;
h. He experienced concussive force from the blast;
i. He experienced severe mental trauma;
j. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, JONATHAN SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
COUNT NINE: JONATHAN SANTOS ppa SANDRA SANTOS v. UIL HOLDINGS
CORPORATION (negligence)1-8. Paragraphs 1 through 8 of the THIRD COUNT are hereby incorporated and made
Paragraphs 1 through 8 of this the NINTH COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
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serious, painful and permanent nature to JONATHAN SANTOS, in that:
a. He suffered from smoke inhalation;
b. He suffered from respiratory distress and all of its accompanying symptoms;
c. He suffered cuts, bruises, abrasions, and/or burns;
d. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
e. He suffered and/or continues to suffer from sleep apnea/insomnia;
f. He suffered and/or continues to suffer from depression;
g. He suffered and/or continues to suffer from severe anxiety;
h. He experienced concussive force from the blast;
i. He experienced severe mental trauma;
j. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, JONATHAN SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
COUNT TEN: JOCELYN SANTOS ppa SANDRA SANTOS v. UNITED ILLUMINATING
COMPANY THE (negligence)
1-8. Paragraphs 1 through 8 of the FIRST COUNT are hereby incorporated and made
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Paragraphs 1 through 8 of this the TENTH COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to JOCELYN SANTOS, in that:
a. She suffered from smoke inhalation;
b. She suffered from Hypoxemia;
c. She suffered from respiratory distress and all of its accompanying symptoms;
d. She suffered cuts, bruises, abrasions, and/or burns;
e. She suffered from chest pain;
f. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
g. She suffered and/or continues to suffer from shortness of breath and all of its
accompanying symptoms;
h. She suffered and/or continues to suffer from Panic Disorder and its accompanying
chronic attacks;
i. She suffered and/or continues to suffer from sleep apnea/insomnia;
j. She suffered and/or continues to suffer from depression;
k. She suffered and/or continues to suffer from severe anxiety;
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l. She experienced and/or continues to experience a decreased ability to concentrate or
focus;
m. She experienced concussive force from the blast;
n. She experienced severe mental trauma;
o. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, JOCELYN SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
COUNT ELEVEN: JOCELYN SANTOS ppa SANDRA SANTOS v. SOUTHERN
CONNECTICUT GAS COMPANY THE (negligence)
1-8. Paragraphs 1 through 8 of the SECOND COUNT are hereby incorporated and made
Paragraphs 1 through 8 of this the ELEVENTH COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to JOCELYN SANTOS, in that:
a. She suffered from smoke inhalation;
b. She suffered from Hypoxemia;
c. She suffered from respiratory distress and all of its accompanying symptoms;
d. She suffered cuts, bruises, abrasions, and/or burns;
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e. She suffered from chest pain;
f. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
g. She suffered and/or continues to suffer from shortness of breath and all of its
accompanying symptoms;
h. She suffered and/or continues to suffer from Panic Disorder and its accompanying
chronic attacks;
i. She suffered and/or continues to suffer from sleep apnea/insomnia;
j. She suffered and/or continues to suffer from depression;
k. She suffered and/or continues to suffer from severe anxiety;
l. She experienced and/or continues to experience a decreased ability to concentrate or
focus;
m. She experienced concussive force from the blast;
n. She experienced severe mental trauma;
o. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, JOCELYN SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
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COUNT TWELVE: JOCELYN SANTOS ppa SANDRA SANTOS v. UIL HOLDINGS
CORPORATION (negligence)
1-8. Paragraphs 1 through 8 of the THIRD COUNT are hereby incorporated and made
Paragraphs 1 through 8 of this the TWELFTH COUNT, as if fully set forth herein;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to JOCELYN SANTOS, in that:
a. She suffered from smoke inhalation;
b. She suffered from Hypoxemia;
c. She suffered from respiratory distress and all of its accompanying symptoms;
d. She suffered cuts, bruises, abrasions, and/or burns;
e. She suffered from chest pain;
f. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
g. She suffered and/or continues to suffer from shortness of breath and all of its
accompanying symptoms;
h. She suffered and/or continues to suffer from Panic Disorder and its accompanying
chronic attacks;
i. She suffered and/or continues to suffer from sleep apnea/insomnia;
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j. She suffered and/or continues to suffer from depression;
k. She suffered and/or continues to suffer from severe anxiety;
l. She experienced and/or continues to experience a decreased ability to concentrate or
focus;
m. She experienced concussive force from the blast;
n. She experienced severe mental trauma;
o. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, JOCELYN SANTOS incurred expenses for ambulance
transportation, hospitalization, medical treatment and care, psychiatric treatment, and for matters
incidental thereto, and will be required to incur similar expenses in the future.
COUNT THIRTEEN: SANDRA SANTOS v. UNITED ILLUMINATING COMPANY THE
(expenses)
1-10. Paragraphs 1 through 10 of the SEVENTH COUNT are hereby incorporated and made
Paragraphs 1 through 10 of this THIRTEENTH COUNT.
11. SANDRA SANTOS suffered damages on behalf of JONATHAN SANTOS, a minor, in the
form of expenses for medical attention, matters incidental to, and may incur similar expenses in
the future.
COUNT FOURTEEN: SANDRA SANTOS v. SOUTHERN CONNECTICUT GAS COMPANY
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THE (expenses)
1-10. Paragraphs 1 through 10 of the EIGHTH COUNT are hereby incorporated and made Paragraphs
1 through 10 of this FOURNTEETH COUNT.
11. SANDRA SANTOS suffered damages on behalf of JONATHAN SANTOS, a minor, in the
form of expenses for medical attention, matters incidental to, and may incur similar expenses in
the future.
COUNT FIFTEEN: SANDRA SANTOS v. UIL HOLDINGS CORPORATION (expenses)
1-10. Paragraphs 1 through 10 of COUNT NINE are hereby incorporated and made Paragraphs 1
through 10 of this FIFTIENTH COUNT.
11. SANDRA SANTOS suffered damages on behalf of JONATHAN SANTOS, a minor, in the
form of expenses for medical attention, matters incidental to, and may incur similar expenses in
the future.
COUNT SIXTEEN: SANDRA SANTOS v. UNITED ILLUMINATING COMPANY THE
(expenses)
1-10. Paragraphs 1 through 10 of the TENTH COUNT are hereby incorporated and made Paragraphs
1 through 10 of this SIXTEENTH COUNT.
11. SANDRA SANTOS suffered damages on behalf of JOCELYN SANTOS, a minor, in the form
of expenses for medical attention, matters incidental to, and may incur similar expenses in the
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future.
COUNT SEVENTEEN: SANDRA SANTOS v. SOUTHERN CONNECTICUT GAS COMPANY
THE (expenses)
1-10. Paragraphs 1 through 10 of the ELEVENTH COUNT are hereby incorporated and made
Paragraphs 1 through 10 of this SEVENTEENTH COUNT.
11. SANDRA SANTOS suffered damages on behalf of JOCELYN SANTOS, a minor, in the form
of expenses for medical attention, matters incidental to, and may incur similar expenses in the
future.
COUNT EIGHTEEN: SANDRA SANTOS v. UIL HOLDINGS CORPORATION (expenses)
1-10. Paragraphs 1 through 10 of the TWELFTH COUNT are hereby incorporated and made
Paragraphs 1 through 10 of this EIGHTEENTH COUNT.
11. SANDRA SANTOS suffered damages on behalf of JOCELYN SANTOS, a minor, in the form
of expenses for medical attention, matters incidental to, and may incur similar expenses in the
future.
COUNT NINETEEN: SANDRA SANTOS v. UNITED ILLUMINATING COMPANY THE
1-11. Paragraphs 1 through 11 of the FOURTH COUNT are hereby incorporated and made
Paragraphs 1 through 11 of this NINETEENH COUNT.
12. SANDRA SANTOS is the spouse of the plaintiff FELISBERTO SANTOS.
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13. The plaintiff SANDRA SANTOS has suffered and will continue to suffer a loss of
consortium, affection, and services from her husband as a result of the defendants negligence.
COUNT TWENTY: SANDRA SANTOS v. SOUTHERN CONNECTICUT GAS COMPANY
THE (Loss of Consortium)
1-11. Paragraphs 1 through 11 of the FIFTH COUNT are hereby incorporated and made
Paragraphs 1 through 11 of this TWENTIETH COUNT.
12. SANDRA SANTOS is the spouse of the plaintiff FELISBERTO SANTOS.
13. The plaintiff SANDRA SANTOS has suffered and will continue to suffer a loss of
consortium, affection, and services from her husband as a result of the defendants negligence.
COUNT TWENTY ONE: SANDRA SANTOS v. UIL HOLDINGS CORPORATION (Loss of
Consortium)
1-11. Paragraphs 1 through 11 of the SIXTH COUNT are hereby incorporated and made
Paragraphs 1 through 11 of this TWENTY-FIRST COUNT.
12. SANDRA SANTOS is the spouse of the plaintiff FELISBERTO SANTOS.
13. The plaintiff SANDRA SANTOS has suffered and will continue to suffer a loss of
consortium, affection, and services from her husband as a result of the defendants negligence.
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COUNT TWENTY TWO: FELISBERTO SANTOS v. UNITED ILLUMINATING COMPANYTHE (Loss of Consortium)
1-11. Paragraphs 1 through 11 of the FOURTH COUNT are hereby incorporated and made
Paragraphs 1 through 11 of this TWENTY-SECOND COUNT.
12. FELISBERTO SANTOS is the spouse of the plaintiff SANDRA SANTOS.
13. The plaintiff FELISBERTO SANTOS has suffered and will continue to suffer a loss of
consortium, affection, and services from his wife as a result of the defendants negligence.
COUNT TWENTY THREE: FELISBERTO SANTOS v. SOUTHERN CONNECTICUT GAS
COMPANY THE (Loss of Consortium)
1-11. Paragraphs 1 through 11 of the FIFTH COUNT are hereby incorporated and made
Paragraphs 1 through 11 of this TWENTY-THIRD COUNT.
12. FELISBERTO SANTOS is the spouse of the plaintiff SANDRA SANTOS.
13. The plaintiff FELISBERTO SANTOS has suffered and will continue to suffer a loss of
consortium, affection, and services from his wife as a result of the defendants negligence.
COUNT TWENTY FOUR: FELISBERTO SANTOS v. UIL HOLDINGS CORPORATION
(Loss of Consortium)
1-11. Paragraphs 1 through 11 of the SIXTH COUNT are hereby incorporated and made
Paragraphs 1 through 11 of this TWENTY-FOURTH COUNT.
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5. On or about March 3, 2012, at about 7:41 am, the plaintiff, CHRISTIAN ORTIZ ppa
NOEL ORTIZ (hereafter Christian Ortiz), was inside a residence located at 301 Howard Avenue in
New Haven, Connecticut.
6. On or about March 3, 2012, at about 7:41 am, the plaintiff, BRIDGETTE ORTIZ ppa
NOEL ORTIZ (hereafter Bridgette Ortiz), was inside a residence located at 301 Howard Avenue in
New Haven, Connecticut.
7. On or about that date, there was a gas-related explosion which caused the plaintiff, to
sustain and suffer the personal injuries and losses hereinafter set forth.
8. The gas explosion and resulting personal injuries and losses of the plaintiff were caused
by the carelessness and negligence of the defendant, United Illuminating, acting through its servants,
agents and/or employees in one or more of the following ways:
a. IN THAT it failed to adequately and properly maintain a high voltage power line in
the area of 301 and 305 Howard Avenue in New Haven, Connecticut;
b. IN THAT it failed to adequately and properly inspect in a timely manner the down
power line in the area of 301 and 305 Howard Avenue in New Haven, Connecticut;
c. IN THAT it failed to adequately and properly secure the area where the downed line
was located at or near 301 and 305 Howard Avenue in New Haven, Connecticut;
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d. IN THAT it failed to adequately and properly conduct a damage assessment upon
becoming aware that there was a downed line in the area of 301 and 305 Howard
Avenue in New Haven, Connecticut;
e. IN THAT it failed to adequately and properly coordinate with others, including
Southern Connecticut Gas Company and the local homeowners, to be certain there
were no gas leaks caused by the downed line;
f. IN THAT it failed to adequately and properly inspect and test for any gas leaks in the
area before activating, reactivating and/or turning the power back on in the area,
particularly including the electricity for 301 and 305 Howard Avenue;
g. IN THAT it failed to warn the residents of 301 and 305 Howard Avenue that it was
going to turn the power back on before doing so even though it knew or should have
known that it had not yet adequately inspected and/or tested for gas leaks and/or had
others conduct such tests; and
h. IN THAT it reactivated and turned the electrical power back on at a time when it
knew or should have known that it was not safe to do so;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to NOEL ORTIZ, in that:
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a. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
b. He suffered and/or continues to suffer from sleep apnea/insomnia;
c. He suffered and/or continues to suffer from depression;
d. He suffered and/or continues to suffer from severe anxiety;
e. He experienced severe mental trauma;
f. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, NOEL ORTIZ incurred expenses for medical treatment and
care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
11. At the time of this explosion, NOEL ORTIZ was employed, and as a result of his
injuries he was not able to perform such work, and he may not be able to do so from time to time in the
future, with a resulting financial loss of earnings and his earning capacity was, is and may be
permanently impaired.
COUNT TWENTY SIX: NOEL ORTIZ v. SOUTHERN CONNECTICUT GAS COMPANY
THE (negligence)
1. At all times herein mentioned the defendant, SOUTHERN CONNECTICUT GAS
COMPANY THE (hereafter SCGC), was a Connecticut corporation with a principal place of
business at 60 Marsh Hill Road, Orange, CT 06477 in Orange, Connecticut.
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2. At all times herein mentioned the defendant, SCGC, acting through its servants, agents
and/or employees was involved in the development, design, erection, fabrication, installation,
maintenance, operation and/or supervision of activities surrounding the construction and maintenance
of the natural gas lines located at or near the area of 301 and 305 Howard Avenue in New Haven,
Connecticut.
3. On or about March 3, 2012, at about 7:41 am, the plaintiff, NOEL ORTIZ, was inside a
residence located at 301 Howard Avenue in New Haven, Connecticut.
4. On or about March 3, 2012, at about 7:41 am, the plaintiff, DIANA ORTIZ, was inside a
residence located at 301 Howard Avenue in New Haven, Connecticut.
5. On or about March 3, 2012, at about 7:41 am, the plaintiff, CHRISTIAN ORTIZ ppa
NOEL ORTIZ (hereafter Christian Ortiz), was inside a residence located at 301 Howard Avenue in
New Haven, Connecticut.
6. On or about March 3, 2012, at about 7:41 am, the plaintiff, BRIDGETTE ORTIZ ppa
NOEL ORTIZ (hereafter Bridgette Ortiz), was inside a residence located at 301 Howard Avenue in
New Haven, Connecticut.
7. On or about that date, there was a gas-related explosion which caused the plaintiff, to
sustain and suffer the personal injuries and losses hereinafter set forth.
8. The gas explosion and resulting personal injuries and losses of the plaintiff were caused
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by the carelessness and negligence of the defendant, SCGC, acting through its servants, agents and/or
employees in one or more of the following ways:
a. IN THAT it failed to exercise reasonable care in installing the instrumentalities
to supply natural gas for the area of 301 and 305 Howard Avenue.
b. IN THAT it failed to properly maintain the instrumentalities supplying natural
gas to the area of 301 and 305 Howard Avenue.
c. IN THAT it failed to properly maintain the instrumentalities supplying gas to the
area of 301 and 305 Howard Avenue.
d. IN THAT it failed to prevent the ignition of natural gas in the area 301 and 305
Howard Avenue.
e. IN THAT it failed to implement safeguards for the conductivity of its
instrumentality;
f. IN THAT it failed to contain the natural gas in the area of 301 and 305 Howard
Avenue;
g. IN THAT it did not adequately pre-odorize the natural gas;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to NOEL ORTIZ, in that:
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a. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
b. He suffered and/or continues to suffer from sleep apnea/insomnia;
c. He suffered and/or continues to suffer from depression;
d. He suffered and/or continues to suffer from severe anxiety;
e. He experienced severe mental trauma;
f. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, NOEL ORTIZ incurred expenses for medical treatment and
care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
11. At the time of this explosion, NOEL ORTIZ was employed, and as a result of his
injuries he was not able to perform such work, and he may not be able to do so from time to time in the
future, with a resulting financial loss of earnings and his earning capacity was, is and may be
permanently impaired.
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COUNT TWENTY SEVEN: NOEL ORTIZ v. UIL HOLDINGS CORPORATION (negligence)
1. At all times herein mentioned the defendant, UIL HOLDINGS CORPORATION
(hereafter UIL), was a Connecticut corporation with a principal place of business at 157 Church
Street, New Haven, Connecticut.
2. At all times herein mentioned the defendant, UIL, acting through its servants, agents
and/or employees was involved in the development, design, erection, fabrication, installation,
maintenance, operation and/or supervision of activities surrounding the construction and maintenance
of the power lines and conductivity located at or near the area of 301 and 305 Howard Avenue in New
Haven, Connecticut.
3. On or about March 3, 2012, at about 7:41 am, the plaintiff, NOEL ORTIZ, was inside a
residence located at 301 Howard Avenue in New Haven, Connecticut.
4. On or about March 3, 2012, at about 7:41 am, the plaintiff, DIANA ORTIZ, was inside a
residence located at 301 Howard Avenue in New Haven, Connecticut.
5. On or about March 3, 2012, at about 7:41 am, the plaintiff, CHRISTIAN ORTIZ ppa
NOEL ORTIZ (hereafter Christian Ortiz), was inside a residence located at 301 Howard Avenue in
New Haven, Connecticut.
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6. On or about March 3, 2012, at about 7:41 am, the plaintiff, BRIDGETTE ORTIZ ppa
NOEL ORTIZ (hereafter Bridgette Ortiz), was inside a residence located at 301 Howard Avenue in
New Haven, Connecticut.
7. On or about that date, there was a gas-related explosion which caused the plaintiff, to
sustain and suffer the personal injuries and losses hereinafter set forth.
8. The gas explosion and resulting personal injuries and losses of the plaintiff were caused
by the carelessness and negligence of the defendant, United Illuminating, acting through its servants,
agents and/or employees in one or more of the following ways:
a. IN THAT it failed to adequately and properly maintain a high voltage power line in
the area of 301 and 305 Howard Avenue in New Haven, Connecticut;
b. IN THAT it failed to adequately and properly inspect in a timely manner the down
power line in the area of 301 and 305 Howard Avenue in New Haven, Connecticut;
c. IN THAT it failed to adequately and properly secure the area where the downed line
was located at or near 301 and 305 Howard Avenue in New Haven, Connecticut;
d. IN THAT it failed to adequately and properly conduct a damage assessment upon
becoming aware that there was a downed line in the area of 301 and 305 Howard
Avenue in New Haven, Connecticut;
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e. IN THAT it failed to adequately and properly coordinate with others, including
Southern Connecticut Gas Company and the local homeowners, to be certain there
were no gas leaks caused by the downed line;
f. IN THAT it failed to adequately and properly inspect and test for any gas leaks in the
area before activating, reactivating and/or turning the power back on in the area,
particularly including the electricity for 301 and 305 Howard Avenue;
g. IN THAT it failed to warn the residents of 301 and 305 Howard Avenue that it was
going to turn the power back on before doing so even though it knew or should have
known that it had not yet adequately inspected and/or tested for gas leaks and/or had
others conduct such tests; and
h. IN THAT it reactivated and turned the electrical power back on at a time when it
knew or should have known that it was not safe to do so;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to NOEL ORTIZ, in that:
a. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
b. He suffered and/or continues to suffer from sleep apnea/insomnia;
c. He suffered and/or continues to suffer from depression;
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d. He suffered and/or continues to suffer from severe anxiety;
e. He experienced severe mental trauma;
f. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, NOEL ORTIZ incurred expenses for medical treatment and
care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
11. At the time of this explosion, NOEL ORTIZ was employed, and as a result of his
injuries he was not able to perform such work, and he may not be able to do so from time to time in the
future, with a resulting financial loss of earnings and his earning capacity was, is and may be
permanently impaired.
COUNT TWENTY EIGHT: DIANA ORTIZ v. UNITED ILLUMINATING COMPANY THE
(negligence)
1-8. Paragraphs 1 through 8 of the TWENTY-FIFTH COUNT are hereby incorporated and
made Paragraphs 1 through 8 of this TWENTY-EIGHTH COUNT.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to DIANA ORTIZ, in that:
a. She suffered from smoke inhalation;
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b. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
c. She suffered and/or continues to suffer from Asthma and all of its accompanying
symptoms;
d. She suffered from acute bronchitis;
e. She suffered from and/or continues to suffer from severe headaches;
f. She suffered and/or continues to suffer from sleep apnea/insomnia;
g. She suffered and/or continues to suffer from depression;
h. She suffered and/or continues to suffer from severe anxiety;
i. She experienced severe mental trauma;
j. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, DIANA ORTIZ incurred expenses for medical treatment and
care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
11. At the time of this explosion and fire, DIANA ORTIZ was employed, and as a result of
her injuries she was not able to perform such work, and she may not be able to do so from time to time
in the future, with a resulting financial loss of earnings and her earning capacity was, is and may be
permanently impaired.
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COUNT TWENTY NINE: DIANA ORTIZ v. SOUTHERN CONNECTICUT GAS COMPANY
THE (negligence)
1-8. Paragraphs 1 through 8 of the TWENTY-SIXTH COUNT are hereby incorporated and
made Paragraphs 1 through 8 of this TWENTY-NINTH COUNT.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to DIANA ORTIZ, in that:
a. She suffered from smoke inhalation;
b. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
c. She suffered and/or continues to suffer from Asthma and all of its accompanying
symptoms;
d. She suffered from acute bronchitis;
e. She suffered from and/or continues to suffer from severe headaches;
f. She suffered and/or continues to suffer from sleep apnea/insomnia;
g. She suffered and/or continues to suffer from depression;
h. She suffered and/or continues to suffer from severe anxiety;
i. She experienced severe mental trauma;
j. She has endured great pain of body, mind, and humiliation;
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10. As a result of her injuries, DIANA ORTIZ incurred expenses for medical treatment and
care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
11. At the time of this explosion and fire, DIANA ORTIZ was employed, and as a result of
her injuries she was not able to perform such work, and she may not be able to do so from time to time
in the future, with a resulting financial loss of earnings and her earning capacity was, is and may be
permanently impaired.
COUNT THRITY: DIANA ORTIZ v. UIL HOLDINGS CORPORATION (negligence)
1-8. Paragraphs 1 through 8 of the TWENTY-SEVENTH COUNT are hereby incorporated
and made Paragraphs 1 through 8 of this THIRTIETH COUNT.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to DIANA ORTIZ, in that:
a. She suffered from smoke inhalation;
b. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
c. She suffered and/or continues to suffer from Asthma and all of its accompanying
symptoms;
d. She suffered from acute bronchitis;
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e. She suffered from and/or continues to suffer from severe headaches;
f. She suffered and/or continues to suffer from sleep apnea/insomnia;
g. She suffered and/or continues to suffer from depression;
h. She suffered and/or continues to suffer from severe anxiety;
i. She experienced severe mental trauma;
j. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, DIANA ORTIZ incurred expenses for medical treatment and
care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
11. At the time of this explosion and fire, DIANA ORTIZ was employed, and as a result of
her injuries she was not able to perform such work, and she may not be able to do so from time to time
in the future, with a resulting financial loss of earnings and her earning capacity was, is and may be
permanently impaired.
COUNT THIRTY ONE: CHRISTIAN ORTIZ ppa NOEL ORTIZ v. UNITED
ILLUMINATING COMPANY THE (negligence)
1-8. Paragraphs 1 through 8 of the TWENTY-FIFTH COUNT are hereby incorporated and
made Paragraphs 1 through 8 of this THIRTY-FIRST COUNT.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to CHRISTIAN ORTIZ, in that:
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a. He suffered and/or continues to suffer from severe Adjustment Disorder and all of
its accompanying symptoms;
b. He suffered and/or continues to suffer from severe panic attacks;
c. He suffered and/or continues to suffer from sleep apnea/insomnia;
d. He suffered and/or continues to suffer from depression;
e. He suffered and/or continues to suffer from severe anxiety;
f. He experienced severe mental trauma;
g. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, CHRISTIAN ORTIZ incurred expenses for psychiatric
treatment, and for matters incidental thereto, and will be required to incur similar expenses in the future.
COUNT THIRTY TWO: CHRISTIAN ORTIZ ppa NOEL ORTIZ v. SOUTHERN
CONNECTICUT GAS COMPANY THE (negligence)
1-8. Paragraphs 1 through 8 of the TWENTY-SIXTH COUNT are hereby incorporated and
made Paragraphs 1 through 8 of this THIRTY-SECOND COUNT.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to CHRISTIAN ORTIZ, in that:
a. He suffered and/or continues to suffer from severe Adjustment Disorder and all of
its accompanying symptoms;
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b. He suffered and/or continues to suffer from severe panic attacks;
c. He suffered and/or continues to suffer from sleep apnea/insomnia;
d. He suffered and/or continues to suffer from depression;
e. He suffered and/or continues to suffer from severe anxiety;
f. He experienced severe mental trauma;
g. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, CHRISTIAN ORTIZ incurred expenses for psychiatric
treatment, and for matters incidental thereto, and will be required to incur similar expenses in the future.
COUNT THRITY THREE: CHRISTIAN ORTIZ ppa NOEL ORTIZ v. UIL HOLDINGS
CORPORATION (negligence)
1-8. Paragraphs 1 through 8 of the TWENTY-SEVENTH COUNT are hereby incorporated
and made Paragraphs 1 through 8 of this THIRTY-THIRD COUNT.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to CHRISTIAN ORTIZ, in that:
a. He suffered and/or continues to suffer from severe Adjustment Disorder and all of
its accompanying symptoms;
b. He suffered and/or continues to suffer from severe panic attacks;
c. He suffered and/or continues to suffer from sleep apnea/insomnia;
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f. She experienced severe mental trauma;
g. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, BRIDGETTE ORTIZ incurred expenses for medical treatment
and care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
COUNT THIRTY FIVE: BRIDGETTE ORTIZ ppa NOEL ORTIZ v. SOUTHERNCONNECTICUT GAS COMPANY THE (negligence)
1-8. Paragraphs 1 through 8 of the TWENTY-SIXTH COUNT are hereby incorporated and
made Paragraphs 1 through 8 of this THIRTY-FIFTH COUNT.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to BRIDGETTE ORTIZ, in that:
a. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
b. She suffered and/or continues to suffer from severe panic attacks;
c. She suffered and/or continues to suffer from sleep apnea/insomnia;
d. She suffered and/or continues to suffer from depression;
e.
She suffered and/or continues to suffer from severe anxiety;
f. She experienced severe mental trauma;
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g. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, BRIDGETTE ORTIZ incurred expenses for medical treatment
and care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
COUNT THIRTY SIX: BRIDGETTE ORTIZ ppa NOEL ORTIZ v. UIL HOLDINGS
CORPORATION
1-8. Paragraphs 1 through 8 of the TWENTY-SEVENTH COUNT are hereby incorporated
and made Paragraphs 1 through 8 of this THIRTY-SIXTH COUNT.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to BRIDGETTE ORTIZ, in that:
a. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
b. She suffered and/or continues to suffer from severe panic attacks;
c. She suffered and/or continues to suffer from sleep apnea/insomnia;
d. She suffered and/or continues to suffer from depression;
e. She suffered and/or continues to suffer from severe anxiety;
f. She experienced severe mental trauma;
g. She has endured great pain of body, mind, and humiliation;
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10. As a result of her injuries, BRIDGETTE ORTIZ incurred expenses for medical treatment
and care, psychiatric treatment, and for matters incidental thereto, and will be required to incur similar
expenses in the future.
COUNT THIRTY SEVEN: NOEL ORTIZ v. UNITED ILLUMINATING COMPANY THE
(expenses)
1-10. Paragraphs 1 through 10 of the THIRTY-FIRST COUNT are hereby incorporated and made
Paragraphs 1through 10 of this THIRTY-SEVENTH COUNT.
11. NOEL ORTIZ suffered damages on behalf of CHRISTIAN ORTIZ, a minor, in the form of
expenses for medical attention, matters incidental to, and may incur similar expenses in the
future.
COUNT THIRTY EIGHT: NOEL ORTIZ v. SOUTHERN CONNECTICUT GAS COMPANY
THE (expenses)
1-10. Paragraphs 1 through 10 of the THIRTY-SECOND COUNT are hereby incorporated and made
Paragraphs 1 through 10 of this THIRTY-EIGHTH COUNT.
11. NOEL ORTIZ suffered damages on behalf of CHRISTIAN ORTIZ, a minor, in the form of
expenses for medical attention, matters incidental to, and may incur similar expenses in the
future.
COUNT THRITY NINE: NOEL ORTIZ v. UIL HOLDINGS CORPORATION (expenses)
1-10. Paragraphs 1 through 10 of the THIRTY-THIRD COUNT are hereby incorporated and made
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Paragraphs 1 through 10 of this THIRTY-NINTH COUNT.
11. NOEL ORTIZ suffered damages on behalf of CHRISTIAN ORTIZ, a minor, in the form of
expenses for medical attention, matters incidental to, and may incur similar expenses in the
future.
COUNT FOURTY: NOEL ORTIZ v. UNITED ILLUMINATING COMPANY THE (expenses)
1-10. Paragraphs 1 through 10 of the THIRTY-FOURTH COUNT are hereby incorporated and made
Paragraphs 1 through 10 of this FORTIETH COUNT.
11. NOEL ORTIZ suffered damages on behalf of BRIDGETTE ORTIZ, a minor, in the form of
expenses for medical attention, matters incidental to, and may incur similar expenses in the
future.
COUNT FOURTY ONE: NOEL ORTIZ v. SOUTHERN CONNECTICUT GAS COMPANY
THE (expenses)
1-10. Paragraphs 1 through 10 of the THIRTY-FIFTH COUNT are hereby incorporated and made
Paragraphs 1 through 10 of this FORTY-FIRST COUNT.
11. NOEL ORTIZ suffered damages on behalf of BRIDGETTE ORTIZ, as minor, in the form of
expenses for medical attention, matters incidental to, and may incur similar expenses in the
future.
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COUNT FOURTY TWO: NOEL ORTIZ v. UIL HOLDINGS CORPORATION (expenses)
1-10. Paragraphs 1 through 10 of the THIRTY-SIXTH COUNT are hereby incorporated and made
Paragraphs 1 through 10 of this FORTY-SECOND COUNT.
11. NOEL ORTIZ suffered damages on behalf of BRIDGETTE ORTIZ, a minor, in the form of
expenses for medical attention, matters incidental to, and may incur similar expenses in the
future.
COUNT FORTY THREE: SANDRA SANTOS v. UNITED ILLUMINATING COMPANY THE
(Recklessness)
1. At all times herein mentioned the defendant, UNITED ILLUMINATING COMPANY
THE (hereafter United Illuminating), was a Connecticut corporation with a principal place of
business at 180 Marsh Hill Road, Orange, CT 06477 in Orange, Connecticut.
2. At all times herein mentioned the defendant, United Illuminating, acting through its
servants, agents and/or employees was involved in the development, design, erection, fabrication,
installation, maintenance, operation and/or supervision of activities surrounding the construction and
maintenance of the power lines and conductivity located at or near the area of 301 and 305 Howard
Avenue in New Haven, Connecticut.
3. On or about March 3, 2012, at about 7:41 am, the plaintiff, SANDRA SANTOS, was
inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
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4. On or about March 3, 2012, at about 7:41 am, the plaintiff, FELISBERTO SANTOS,
was inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
5. On or about March 3, 2012, at about 7:41 am, the plaintiff, JONATHAN SANTOS PPA
SANDRA SANTOS (hereafter JONATHAN SANTOS), was inside a residence located at 305
Howard Avenue in New Haven, Connecticut.
6. On or about March 3, 2012, at about 7:41 am, the plaintiff, JOCELYN SANTOS PPA
SANDRA SANTOS (hereafter JOCELYN SANTOS), was inside a residence located at 305 Howard
Avenue in New Haven, Connecticut.
7. On or about that date, there was a gas-related explosion which caused the plaintiff, to
sustain and suffer the personal injuries and losses hereinafter set forth.
8. The gas explosion and resulting personal injuries and losses of the plaintiff were caused
by the recklessness of the defendant, United Illuminating, acting through its servants, agents and/or
employees in one or more of the following ways:
a. IN THAT they intentionally and recklessly failed to maintain a high voltage
power line in the area of 301 and 305 Howard Avenue in New Haven,
Connecticut;
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b. IN THAT they intentionally and recklessly failed to inspect the down power line,
and surrounding residences, in the area of 301 and 305 Howard Avenue in New
Haven, Connecticut;
c. IN THAT they intentionally and recklessly failed to secure the area where the
downed line was located at or near 301 and 305 Howard Avenue in New Haven,
Connecticut;
d. IN THAT they intentionally and recklessly failed to conduct a damage
assessment upon becoming aware that there was a downed line in the area of 301
and 305 Howard Avenue in New Haven, Connecticut;
e. IN THAT they intentionally and recklessly failed to coordinate with others,
including Southern Connecticut Gas Company and the local homeowners, to be
certain there were no gas leaks or other damage caused by the downed line;
f. IN THAT they intentionally and recklessly failed to inspect and test for any gas
leaks in the area before activating, reactivating and/or turning the power back on
in the area, particularly including the electricity for 301 and 305 Howard
Avenue;
g. IN THAT they intentionally and recklessly failed to warn the residents of 301
and 305 Howard Avenue that it was going to turn the power back on before
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doing so even though it knew or should have known that it had not yet
adequately inspected and/or tested for gas leaks and/or had others conduct such
tests; and
h. IN THAT they intentionally and recklessly reactivated and turned the electrical
power back on at a time when it knew or should have known that it was not safe
to do so;
i. IN THAT they intentionally and recklessly turned the electrical power back on
without performing any type of inspection of the surrounding residences;
j. IN THAT they intentionally and recklessly disregarded the safety of others by
allowing electrical current to flow into a residence for an unreasonable amount of
time;
k. IN THAT they intentionally and recklessly failed to cut power to the affected
area within a reasonable amount of time;
l. IN THAT they intentionally and recklessly failed to test for gas leaks;
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to SANDRA SANTOS, in that:
a. She suffered from smoke inhalation;
b. She suffered from respiratory distress and all of its accompanying symptoms;
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c. She suffered cuts, bruises, abrasions, and/or burns;
d. She suffered physical trauma to her left second toe;
e. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
f. She suffered and/or continues to suffer from Asthma and all of its accompanying
symptoms;
g. She suffered and/or continues to suffer from Panic Disorder and its accompanying
chronic attacks;
h. She suffered and/or continues to suffer from sleep apnea/insomnia;
i. She suffered and/or continues to suffer from depression;
j. She suffered and/or continues to suffer from severe anxiety;
k. She experienced concussive force from the blast;
l. She experienced severe mental trauma;
m. She has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, SANDRA SANTOS incurred expenses for ambulance
transportation, hospitalization, X-Rays, medical treatment and care, psychiatric treatment, and for
matters incidental thereto, and will be required to incur similar expenses in the future.
11. At the time of this explosion and fire, SANDRA SANTOS was employed, and as a result
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of her injuries she was not able to perform such work, and she may not be able to do so from time to
time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may
be permanently impaired.
12. As a further result thereof, the plaintiff, SANDRA SANTOS, has been forced to incur
financial obligations for hospital and medical care and treatment, diagnostic studies, x-rays, medicines
and the like.
13. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a loss of
wages and/or earning capacity, and her future earning capacity is diminished, all to her further loss and
detriment.
14. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a reduction in
her ability to pursue his usual activities to the same extent as prior to the accident, all to her further loss
and detriment.
COUNT FORTY FOUR: SANDRA SANTOS v. UIL HOLDINGS CORPORATION
(Recklessness)
1. At all times herein mentioned the defendant, UIL HOLDINGS CORPORATION
(hereafter UIL), was a Connecticut corporation with a principal place of business at 157 Church
Street in New Haven, Connecticut.
2.
At all times herein mentioned the defendant, UIL, acting through its servants, agents
and/or employees was involved in the development, design, erection, fabrication, installation,
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maintenance, operation and/or supervision of activities surrounding the construction and maintenance
of the power lines and conductivity located at or near the area of 301 and 305 Howard Avenue in New
Haven, Connecticut.
3. On or about March 3, 2012, at about 7:41 am, the plaintiff, SANDRA SANTOS, was
inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
4. On or about March 3, 2012, at about 7:41 am, the plaintiff, FELISBERTO SANTOS,
was inside a residence located at 305 Howard Avenue in New Haven, Connecticut.
5. On or about March 3, 2012, at about 7:41 am, the plaintiff, JONATHAN SANTOS PPA
SANDRA SANTOS (hereafter JONATHAN SANTOS), was inside a residence located at 305
Howard Avenue in New Haven, Connecticut.
6. On or about March 3, 2012, at about 7:41 am, the plaintiff, JOCELYN SANTOS PPA
SANDRA SANTOS (hereafter JOCELYN SANTOS), was inside a residence located at 305 Howard
Avenue in New Haven, Connecticut.
7. On or about that date, there was a gas-related explosion which caused the plaintiff, to
sustain and suffer the personal injuries and losses hereinafter set forth.
8. The gas explosion and resulting personal injuries and losses of the plaintiff were caused
by the recklessness of the defendant, UIL, acting through its servants, agents and/or employees in one
or more of the following ways:
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a. IN THAT they intentionally and recklessly failed to maintain a high voltage
power line in the area of 301 and 305 Howard Avenue in New Haven,
Connecticut;
b. IN THAT they intentionally and recklessly failed to inspect the down power line,
and surrounding residences, in the area of 301 and 305 Howard Avenue in New
Haven, Connecticut;
b. IN THAT they intentionally and recklessly failed to secure the area where the
downed line was located at or near 301 and 305 Howard Avenue in New Haven,
Connecticut;
c. IN THAT they intentionally and recklessly failed to conduct a damage
assessment upon becoming aware that there was a downed line in the area of 301
and 305 Howard Avenue in New Haven, Connecticut;
d. IN THAT they intentionally and recklessly failed to coordinate with others,
including Southern Connecticut Gas Company and the local homeowners, to be
certain there were no gas leaks or other damage caused by the downed line;
e. IN THAT they intentionally and recklessly failed to inspect and test for any gas
leaks in the area before activating, reactivating and/or turning the power back on
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in the area, particularly including the electricity for 301 and 305 Howard
Avenue;
f. IN THAT they intentionally and recklessly failed to warn the residents of 301
and 305 Howard Avenue that it was going to turn the power back on before
doing so even though it knew or should have known that it had not yet
adequately inspected and/or tested for gas leaks and/or had others conduct such
tests; and
g. IN THAT they intentionally and recklessly reactivated and turned the electrical
power back on at a time when it knew or should have known that it was not safe
to do so;
h. IN THAT they intentionally and recklessly turned the electrical power back on
without performing any type of inspection of the surrounding residences;
i. IN THAT they intentionally and recklessly disregarded the safety of others by
allowing electrical current to flow into a residence for an unreasonable amount of
time;
j. IN THAT they intentionally and recklessly failed to cut power to the affected
area within a reasonable amount of time;
k. IN THAT they intentionally and recklessly failed to test for gas leaks;
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9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to SANDRA SANTOS, in that:
a. She suffered from smoke inhalation;
b. She suffered from respiratory distress and all of its accompanying symptoms;
c. She suffered cuts, bruises, abrasions, and/or burns;
d. She suffered physical trauma to her left second toe;
e. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
f. She suffered and/or continues to suffer from Asthma and all of its accompanying
symptoms;
g. She suffered and/or continues to suffer from Panic Disorder and its accompanying
chronic attacks;
h. She suffered and/or continues to suffer from sleep apnea/insomnia;
i. She suffered and/or continues to suffer from depression;
j. She suffered and/or continues to suffer from severe anxiety;
k. She experienced concussive force from the blast;
l. She experienced severe mental trauma;
m. She has endured great pain of body, mind, and humiliation;
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10. As a result of her injuries, SANDRA SANTOS incurred expenses for ambulance
transportation, hospitalization, X-Rays, medical treatment and care, psychiatric treatment, and for
matters incidental thereto, and will be required to incur similar expenses in the future.
11. At the time of this explosion and fire, SANDRA SANTOS was employed, and as a result
of her injuries she was not able to perform such work, and she may not be able to do so from time to
time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may
be permanently impaired.
12. As a further result thereof, the plaintiff, SANDRA SANTOS, has been forced to incur
financial obligations for hospital and medical care and treatment, diagnostic studies, x-rays, medicines
and the like.
13. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a loss of
wages and/or earning capacity, and her future earning capacity is diminished, all to her further loss and
detriment.
14. As a further result thereof, the plaintiff, SANDRA SANTOS, has suffered a reduction in
her ability to pursue his usual activities to the same extent as prior to the accident, all to her further loss
and detriment.
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COUNT FORTY FIVE: FELISBERTO SANTOS v. UNITED ILLUMINATING COMPANYTHE (Recklessness)
1-8. Paragraphs One through Eight of Count Forty Three are hereby incorporated and made
Paragraphs One through Eight of this Forty Fifth Count.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a serious,
painful and permanent nature to FELISBERTO SANTOS, in that:
a. He suffered cuts, bruises, abrasions, and/or burns;
b. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
c. He suffered and/or continues to suffer from an altered mental status;
d. He suffered and/or continues to suffer from sleep apnea/insomnia;
e. He suffered and/or continues to suffer from depression;
f. He suffered and/or continues to suffer from severe anxiety;
g. He experienced concussive force from the blast;
h. He experienced severe mental trauma;
i. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, FELISBERTO SANTOS incurred expenses for ambulance
transportation, hospitalization, X-Rays, medical treatment and care, psychiatric treatment, and for
matters incidental thereto, and will be required to incur similar expenses in the future.
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11. At the time of this explosion and fire, FELISBERTO SANTOS was employed, and as a
result of his injuries he was not able to perform such work, and he may not be able to do so from time
to time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may
be permanently impaired.
12. As a further result thereof, the plaintiff, FELISBERTO SANTOS, has been forced to
incur financial obligations for hospital and medical care and treatment, diagnostic studies, x-rays,
medicines and the like.
13. As a further result thereof, the plaintiff, FELISBERTO SANTOS, has suffered a loss of
wages and/or earning capacity, and his future earning capacity is diminished, all to his further loss and
detriment.
14. As a further result thereof, the plaintiff, FELISBERTO SANTOS, has suffered a
reduction in his ability to pursue his usual activities to the same extent as prior to the accident, all to his
further loss and detriment.
COUNT FORTY SIX: FELISBERTO SANTOS v. UIL HOLDINGS CORPORATION
(Recklessness)
1-8. Paragraphs One through Eight of Count Forty Four are hereby incorporated and made
Paragraphs One through Eight of this Forty Sixth Count.
9.
The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to FELISBERTO SANTOS, in that:
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a. He suffered cuts, bruises, abrasions, and/or burns;
b. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
c. He suffered and/or continues to suffer from an altered mental status;
d. He suffered and/or continues to suffer from sleep apnea/insomnia;
e. He suffered and/or continues to suffer from depression;
f. He suffered and/or continues to suffer from severe anxiety;
g. He experienced concussive force from the blast;
h. He experienced severe mental trauma;
i. He has endured great pain of body, mind, and humiliation;
10. As a result of his injuries, FELISBERTO SANTOS incurred expenses for ambulance
transportation, hospitalization, X-Rays, medical treatment and care, psychiatric treatment, and for
matters incidental thereto, and will be required to incur similar expenses in the future.
11. At the time of this explosion and fire, FELISBERTO SANTOS was employed, and as a
result of his injuries he was not able to perform such work, and he may not be able to do so from time
to time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may
be permanently impaired.
12. As a further result thereof, the plaintiff, FELISBERTO SANTOS, has been forced to
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incur financial obligations for hospital and medical care and treatment, diagnostic studies, x-rays,
medicines and the like.
13. As a further result thereof, the plaintiff, FELISBERTO SANTOS, has suffered a loss of
wages and/or earning capacity, and his future earning capacity is diminished, all to his further loss and
detriment.
14. As a further result thereof, the plaintiff, FELISBERTO SANTOS, has suffered a
reduction in his ability to pursue his usual activities to the same extent as prior to the accident, all to his
further loss and detriment.
COUNT FORTY SEVEN: JONATHAN SANTOS ppa SANDRA SANTOS v. UNITED
ILLUMINATING COMPANY THE (Recklessness)
1-8. Paragraphs One through Eight of Count Forty Three are hereby incorporated and made
Paragraphs One through Eight of this Forty Seventh Count.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to JONATHAN SANTOS, in that:
a. He suffered from smoke inhalation;
b. He suffered from respiratory distress and all of its accompanying symptoms;
c. He suffered cuts, bruises, abrasions, and/or burns;
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d. He suffered and/or continues to suffer from severe Post Traumatic Stress Disorder
and all of its accompanying symptoms;
e. He suffered and/or continues to suffer from sleep apnea/insomnia;
f. He suffered and/or continues to suffer from depression;
g. He suffered and/or continues to suffer from severe anxiety;
h. He experienced concussive force from the blast;
i. He experienced severe mental trauma;
j. He has endured great pain of body, mind, and humiliation;
10. As a result of her injuries, JONATHAN SANTOS incurred expenses for ambulance
transportation, hospitalization, X-Rays, medical treatment and care, psychiatric treatment, and for
matters incidental thereto, and will be required to incur similar expenses in the future.
11. At the time of this explosion and fire, JONATHAN SANTOS was employed, and as a
result of his injuries he was not able to perform such work, and he may not be able to do so from time
to time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may
be permanently impaired.
12. As a further result thereof, the plaintiff, JONATHAN SANTOS, has been forced to incur
financial obligations for hospital and medical care and treatment, diagnostic studies, x-rays, medicines
and the like.
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13. As a further result thereof, the plaintiff, JONATHAN SANTOS, has suffered a loss of
wages and/or earning capacity, and his future earning capacity is diminished, all to his further loss and
detriment.
14. As a further result thereof, the plaintiff, JONATHAN SANTOS, has suffered a reduction
in his ability to pursue his usual activities to the same extent as prior to the accident, all to his further
loss and detriment.
COUNT FORTY EIGHT: JONATHAN SANTOS ppa SANDRA SANTOS v. UIL HOLDINGS
CORPORATION (Recklessness)
1-8. Paragraphs One through Eight of Count Forty Four are hereby incorporated and made
Paragraphs One through Eight of this Forty Eighth Count.
9. The force of the violent explosion and fire caused and/or exacerbated injuries of a
serious, painful and permanent nature to JONATHAN SANTOS, in that:
a. She suffered from smoke inhalation;
b. He suffere