Santos Complaint

7/27/2019 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


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


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.






SANDRA SANTOS (hereafter Jonathan Santos, was inside a residence located at 305 Howard



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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;


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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;










symptoms;


chronic attacks;





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and the like.



detriment.


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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



of the power lines and conductivity located at or near the area of 301 and 305 Howard Avenue in New

Haven, Connecticut.






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SANDRA SANTOS (hereafter Jonathan Santos), was inside a residence located at 305 Howard










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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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







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symptoms;


chronic attacks;











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and the like.



detriment.



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;


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


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



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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;

















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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;










g.

He experienced concussive force from the blast;



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COUNT SEVEN: JONATHAN SANTOS ppa SANDRA SANTOS v. UNITED ILLUMINATING

COMPANY THE (negligence)


Paragraphs 1 through 8 of this the SEVENTH COUNT, as if fully set forth herein;


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


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



COUNT EIGHT: JONATHAN SANTOS ppa SANDRA SANTOS v. SOUTHERN

CONNECTICUT GAS COMPANY THE (negligence)


Paragraphs 1 through 8 of this the EIGHTH COUNT, as if fully set forth herein;





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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;



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COUNT TEN: JOCELYN SANTOS ppa SANDRA SANTOS v. UNITED ILLUMINATING

COMPANY THE (negligence)



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Paragraphs 1 through 8 of this the TENTH COUNT, as if fully set forth herein;


serious, painful and permanent nature to JOCELYN SANTOS, in that:


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


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



COUNT ELEVEN: JOCELYN SANTOS ppa SANDRA SANTOS v. SOUTHERN



Paragraphs 1 through 8 of this the ELEVENTH COUNT, as if fully set forth herein;








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chronic attacks;





focus;








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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;













chronic attacks;



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focus;







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.



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.



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.



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.



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.




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.





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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














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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


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



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2. At all times herein mentioned the defendant, SCGC, acting through its servants, agents



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












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by the carelessness and negligence of the defendant, SCGC, acting through its servants, agents and/or


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;




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COUNT TWENTY SEVEN: NOEL ORTIZ v. UIL HOLDINGS CORPORATION (negligence)



Street, New Haven, Connecticut.

2. At all times herein mentioned the defendant, UIL, acting through its servants, agents




Haven, Connecticut.

3. On or about March 3, 2012, at about 7:41 am, the plaintiff, NOEL ORTIZ, was inside a


4. On or about March 3, 2012, at about 7:41 am, the plaintiff, DIANA ORTIZ, was inside a






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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.


serious, painful and permanent nature to DIANA ORTIZ, in that:



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b. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder


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



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



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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.







symptoms;









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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.







symptoms;



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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.


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



made Paragraphs 1 through 8 of this THIRTY-SECOND COUNT.






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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)


and made Paragraphs 1 through 8 of this THIRTY-THIRD COUNT.








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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


COUNT THIRTY FIVE: BRIDGETTE ORTIZ ppa NOEL ORTIZ v. SOUTHERNCONNECTICUT GAS COMPANY THE (negligence)


made Paragraphs 1 through 8 of this THIRTY-FIFTH COUNT.


serious, painful and permanent nature to BRIDGETTE ORTIZ, in that:

a. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder


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;



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COUNT THIRTY SIX: BRIDGETTE ORTIZ ppa NOEL ORTIZ v. UIL HOLDINGS

CORPORATION


and made Paragraphs 1 through 8 of this THIRTY-SIXTH COUNT.


serious, painful and permanent nature to BRIDGETTE ORTIZ, in that:

a. She suffered and/or continues to suffer from severe Post Traumatic Stress Disorder


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;




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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.



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.



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


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


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


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


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





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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





by the recklessness of the defendant, United Illuminating, acting through its servants, agents and/or


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;






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symptoms;


chronic attacks;












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and the like.



detriment.



and detriment.

COUNT FORTY FOUR: SANDRA SANTOS v. UIL HOLDINGS CORPORATION

(Recklessness)



Street in New Haven, Connecticut.

2.

At all times herein mentioned the defendant, UIL, acting through its servants, agents



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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





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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symptoms;


chronic attacks;








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and the like.



detriment.



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:















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to time in the future, with a resulting financial loss of earnings and her earning capacity was, is and may


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



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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


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.







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10. As a result of her injuries, JONATHAN SANTOS incurred expenses for ambulance



11. At the time of this explosion and fire, JONATHAN SANTOS was employed, and as a




12. As a further result thereof, the plaintiff, JONATHAN SANTOS, has been forced to incur


and the like.


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13. As a further result thereof, the plaintiff, JONATHAN SANTOS, has suffered a loss of


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.




b. He suffere

Documents

Santos Complaint