Civil Action No. 1:21-CV-400-APM
IX. Plaintiffs
Were Injured by Defendants’ Conduct
a. The Honorable Bennie Thompson
During this entire time, Plaintiff Thompson reasonably feared
for his physical safety. While trapped in the building, during the siege by the
rioters that Defendants unleashed on the Capitol, Plaintiff Thompson feared for
his life and worried that he might never see his family again.
b. The Honorable Karen Bass
The riot has shaken Rep. Bass’s faith in the security of the
Capitol. For days after the riot, she was troubled by the realization that she
could have been seriously harmed or killed by the rioters at the Capitol.
c. The Honorable Stephen Cohen
Following the incidents described above, Rep. Cohen developed
difficulties falling and staying asleep that he had not previously suffered and
difficulties with his digestion that he had not suffered before. He became
jumpy whenever he heard a loud or unfamiliar noise in his home. He also had
recurring fears that he was not as safe as he had previously believed, renewing
his thoughts about the choice of places where he would be buried.
d. The Honorable Veronica Escobar
Rep. Escobar struggled to fall asleep that night and has had
difficulty, as never before, sleeping in the weeks following January 6, 2021.
She suffered from violent nightmares and has since talked with mental health
professionals as a direct result of these events.
e. The Honorable Pramila Jayapal
In addition to the pain and suffering caused Rep. Jayapal by the
events alleged above, she also suffered grave fear for her personal safety
while she was confined in the House Chamber. In the days following the events
of January 6, Rep. Jayapal spoke with mental health professionals in both group
and individual settings about fears for her safety that she had never
encountered before. Her need for counseling was a direct result of the attack
on the Capitol.
f. The Honorable Henry C. Johnson, Jr.
Eventually, Rep. Johnson was directed to shelter in Longworth,
where he remained for several hours. Immediately upon arriving at the Longworth
room and throughout his time sheltering there, he was forced to stand with
other members who, because of their number, could not be socially distant from
each other, as the CDC prescribed to minimize transmission of the COVID-19
virus. And many members declined to wear masks, as the CDC prescribed. As Rep.
Johnson was 66 years old at the time, he feared during the time he sheltered in
Longworth that he would contract the virus and jeopardize his health after having
fled conditions that jeopardized his safety. After he sheltered in Longworth
for several hours, he returned to the Capitol where he completed his
responsibility to oversee and approve the results of the Electoral College
balloting.
g. The Honorable Marcy Kaptur
After she exited the Gallery, Rep. Kaptur traveled a long
distance through hallways and stairwells down to the sub-basement, where she
finally arrived at a very crowded room where other members and their staffs
sheltered. After leaving threats to her physical safety, Rep. Kaptur grew
concerned for her health, as she was directed to shelter in a room in which
members could not remain socially distant and many refused to wear masks, as
the CDC prescribed as the means to minimize the risk of contracting COVID-19.
Rep. Kaptur was 74 years old at the time and therefore within the age group for
which the virus posed the greatest risk to her health. Rep. Kaptur was required
to remain in this room for several hours until she was informed that it was
safe to return to her office. She returned to her office and joined her staff
at approximately 9:00 PM, at which point she left the Capitol complex and
returned home.
h. The Honorable Barbara Lee
The events on January 6 described above left Rep. Lee feeling that
she had narrowly escaped serious injury or death on that date, prompting her to
finalize her plans for her estate.
i. The Honorable Jerrold Nadler
Rep. Nadler sheltered in place in the Judiciary Committee office
for hours awaiting confirmation that the riot had been quelled. Throughout this
time, Rep. Nadler genuinely feared for his safety. Anticipating that he might
need to evacuate Rayburn on short notice, he prepared a “go bag” with materials
he might need in the immediate future. Having watched reports of the menacing
and aggressive behavior of the rioters who entered the Capitol, Rep. Nadler had
serious concerns that his personal safety and even his life would be
jeopardized in the event the intruders came to Rayburn.
j. The Honorable Maxine Waters
Since the riot, Rep. Waters has had increased worries about her
safety, and has felt compelled to increase the amount of security personnel
with whom she travels to and from her home.
k. The Honorable Bonnie Watson Coleman
After learning from the attending physician that persons with
her in Longworth were testing positive for COVID-19, on Monday, January 9,
2021, Rep. Watson Coleman submitted to a test that day. Following the test,
Rep. Watson Coleman learned that her results were
positive. Her age and medical condition permitted her access to the Monoclonal
Antibody Treatment for COVID-19, which she began receiving the same day as she
received the test results. Her physician informed her that, absent her partial
vaccination and special antibody treatment, her life would have been in
jeopardy. Notwithstanding the prompt medical treatment she received, Rep.
Watson Coleman still suffered from congestion, coughing, and fatigue.
PRAYER FOR RELIEF
Wherefore, Plaintiffs respectfully request an award of the following relief:
A.
Compensatory damages
C. An award of reasonable attorney’s fees
D. Such other relief as the Court deems necessary and just.
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Dated: April 7,
2021 |
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about "We the People" John Doe American and Jane Doe American 1 through….
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