firearms and ammunition possessed by those accessing and entering Building 197 at the Washington Naval Yard. 186. The USA (d/b/a Department of the Navy) owed a duty to properly hire, supervise and train security staff to protect the Plaintiff Mary Frances Delorenzo Knight and military and civilian employees in Building 197 at the Washington Naval Yard by mitigating the risk of injury and/or death from a known active inside shooter. 187. The USA (d/b/a Department of the Navy) breached its duty to properly hire, supervise and train security staff to protect the Plaintiff Mary Frances Delorenzo Knight by failing to mitigate for the risk of injury and/or death from a known active inside shooter by screening and searching for prohibited items including firearms and ammunition possessed by those accessing and entering Building 197 at the Washington Naval Yard. 188. The decedent Mary Frances Delorenzo Knight suffered and experienced severe pain, mental anguish and emotional distress prior to her wrongful death. 189. 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) Page 70 of 96
Delorenzo v. United States of America, et al Complaint for Damages and Demand for Jury Trial