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mmonne |S os | SG lranrerm Christina Kain = (coun scons, Sprngield MAOTION HAMPDEN. = _ Se owes 1148 Main Steet, PO Box 20000 Jone 1) 120 Pear Steet, Spingtld, MA 01705, ____ Spring, MA 01108 2.) 36 Court Street, Springfeld, MA 01108 2) 190 Pear Stost, Spingta, MA O1105 eS 45020 TOF RETIN TS VRER DEITY i resonate seen cameo STENT OF DANTGES PORBUANT TOG © EER oun a ted ded teeth hundred sine stearate ey ase, Fo radia sg amage oy. omreusns (oto eae ners ecea (Sete penmy dam a [Rtn ee toto poqoomuesh Ce ee a eee aman mw [oR § swowuwuN ayn iat in cha a an eo tb Rupr ght oar dum and permanent hearing loss in th iat ear romans 5595.00.00) eoummacranis (one SE tna frotss ata cin ces ora Som lala rT TS AST ‘GERTFIGATION PURSUANT TO SG RULE 48 hereby att have carpe wn equrenents oun She Supreme ial ont iam Fs on Dina Reon 10 ese at pe yt wrt Sb. cour-arneted pte ean serous asin wih hen tne) Lee ee sescanages cite veiaamengisatdsporpsclscn. [toni Atrny f Racn X a L>- » owes | 4 a Slanatur of AtenaPro Se Pit: X HAMPDEN COUNTY » RRR gATgORT | JAN 17 2018 | COMMONWEALTH OF MASSACHUSETTS | ‘TRIAL COURT OF THE COMMONWEALTH heey | HAMPDEN, ss. ‘SUPERIOR COURT DEPARTMENT | CIVILACTIONNO: 49. Q2g Plainif, COMPLAINT AND DEMAND *s HORAURY TRIAL RUPERT DANIEL, ‘THE CITY OF SPRINGFIELD, and THE CITY OF SPRINGFIELD POLICE DEPARTMENT, Defendants, ee) PARIIES 1. Thelin, CHRISTINA KALIN, isa natural person of legal age who resides 3 AEB in, Hepes County, Cosmnneslh of Massechsts 2, ‘The Defendant, RUPERT DANIEL, isa natural person of legal age who has a lst known, place of employment et the City of Speingficld Police Department, located at 130 Pearl ‘Street, Springfield, Hampden County, Commonwealth of Massachusetts, 3. The Defendant, THE CITY OF SPRINGFIELD, isa government entity ofthe Commonwealth of Massachusetts, with its principal offices located at 36 Court Stret, Springfield, Hampden County, Commonwealth of Massachusetts. 4, The Defendant, THE CITY OF SPRINGFIELD POLICE DEPARTMENT, is division of the City of Springfield with a police headquarters located at 130 Pearl Steet, ‘Springfield, Hampden County, Commonwealth of Massachusets. LEGA’ 5, The Plsiniff, CHRISTINA KALIN, realleges and "paragraphs one through four of this Complaint. incorporates herein by reference 6. Atall ies relevant in this Complaint, the Plaintiff, CHRISTINA KALIN, was employed ‘and actively working at the Jowish Community Center, located 1160 Dickinson Street in Springfield, Massichusetts (hereinafter ‘facility’, | | | | | | | | | | | } | f | | | 10. nL 14 15, 16. ‘Atall times relevant in this Complaint, the Defendant, RUPERT DANIELS, was en. ‘agent, servant andlor employee of the Defendant, THE CITY OF SPRINGFIELD. Atal times relevant in this Complaiat, the Defendant, RUPERT DANIELS, was an ‘gent, servant and/or employee ofthe Defendant, CITY OF SPRINGFIELD POLICE, DEPARTMENT. n February 28,2016, the Defendant, CITY OF SPRINGFIELD POLICE DEPARTMENT, through thir Tetcal Response Unit was hong sn‘ctve shoot safety dil athe fility. On February 26,2016, the Defendant, RUPERT DANIEL, during the ease and in furtherance of his employment forthe Defendants, THE CITY OF SPRINGFIELD and CITY OF SPRINGFIELD POLICE DEPARTMENT, was impersonating a shooter during the safety dil at that facility. ‘On February 26, 2016, on two separate occasions during the above- identified safety del, the Defendant, RUPERT DANIEL, while impersonating an ative shooter, entered into ‘rooms ofthe facility where the Plaintiff, CHRISTINA KALIN, was and fired a.38 caliber ‘revolver in close proximity to her right ea. (On February 26, 2016, during the above identified safety dil, the Defendant, RUPERT DANIEL, while impersonating an active shooter, entered into the gynanasium ofthe facility whore the Plaintiff, CHRISTINA KALIN, was and fired 2.38 caliber revolver in close proximity to er right ear. (On February 26,2016, during the above-identified safety dil, the Defendant, RUPERT DANIEL, while impersonating an ative shooter, entered into the admission office suite of the facility where the Plaintiff, CHRISTINA KALIN, was and fired 9.38 ealiber revolver in close proximity fo her right ear. ‘On Febmary 26,2016, immediately following the above-identified safety dil, the Plainlff, CHRISTINA KALIN, began to bleed from her right ear. Asa direct and proximate result ofthis incident, the Plaintiff, CHRISTINA KALIN, sustained serious and permanent bodily injuries, including a ruptured eardrum and ‘permanent hearing loss, end required extensive medica treatment. ‘On October 11, 2016, the Plaintiff, CHRISTINA KALIN, by and through her attorney, put the Defendant, THE CITY OF SPRINGFIELD, along with the Commonvveith of “Massachusetts, on notice of her claim for bodily injuries a a result of the incident, ‘pursuant to M.GL. c. 258 §4.