225. The wrongful death of Mary Frances DeLorenzo Knight on September 16, 2013 occurred within the limits of the District of Columbia. 226. The wrongful death of Mary Frances DeLorenzo Knight was proximately caused by the negligence of the USA (d/b/a Department of Veterans Affairs). 227. Plaintiff, as lawfully appointed personal representative, is authorized to bring this action in the name of the personal representative of the estate of deceased Mary Frances Delorenzo Knight pursuant to DC code ยง16-2702 (2013). 228. Plaintiff, as personal representative, brings this cause of action for damages caused to the Estate of Mary Frances Delorenzo Knight and for damages to the next of kin pursuant to DC Code ยง12-101 et seq. (2013) 229. The decedent Mary Frances Delorenzo Knight suffered and experienced severe pain, mental anguish and emotional distress prior to her wrongful death. 230. The estate of Mary Frances Delorenzo Knight lost probable future earnings, ability to earn in the future, economic and noneconomic damages in all other damages provided by DC code ยง16-2701 et seq. (2013) 231. As a Direct and foreseeable result of the negligence of the USA, proximately causing her wrongful death, the next of kin of Mary Frances Delorenzo Knight have suffered damages including severe pain, mental anguish Page 84 of 96
Delorenzo v. United States of America, et al Complaint for Damages and Demand for Jury Trial