SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

ERICKA JINETH HERCULES RAMIREZ,
ROSALI AMAYA BENITEZ,
ABEBA HEYI,
ENCARNACION DUBON ORTIZ,
DONALDO MONDRAGON,
YAMILETH REYES VALLADAREZ and
SOLOMON M. WELDEMARIAM, on behalf
of themselves and all of those similarly
situated,

Case No. _________________

JURY TRIAL DEMANDED
Plaintiffs,
v.
WASHINGTON GAS LIGHT COMPANY
101 Constitution Ave. NW
Washington, DC 20001,
WGL HOLDINGS, INC.
101 Constitution Ave. NW
Washington, DC 20001,
KAY MANAGEMENT COMPANY, INC.
8720 Georgia Ave., Suite 410,
Silver Spring, Maryland 20910,
and
JOHN DOES,
Manufacturers of residential gas delivery
equipment to Flower Branch Apartments,
Address Unknown at this Time,
Defendants.

CLASS ACTION COMPLAINT
Introduction
1.

Close to midnight on Wednesday, August 10, 2016, a massive explosion ripped

through the 362-unit Flower Branch Apartments complex, creating a gas-fed inferno that nearly

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levelled a four-story building, killed seven residents, injured more than 30, and left dozens of
families homeless.
2.

Compounding the tragedy of this horrific event is the fact that it was entirely

preventable. Less than three weeks before the explosion and fire, residents had reported the smell
of natural gas, but the Defendants – Washington Gas Light Company, which supplied natural gas
to the complex, and Kay Management Company, which managed the complex – failed to take
any action to address the complaints. They did not repair the gas leak, did not make an
appropriate inspection that would have identified a leak, and did not warn or evacuate residents.
Defendants also failed to perform routine inspections that would have uncovered the potential for
catastrophe and saved the lives and property of the residents.
3.

The effects of these failures reach far beyond the residents of Flower Branch

Apartments. Washington Gas, which is headquartered in the District, makes corporate-wide
safety and maintenance decisions here, operates hundreds of miles of natural gas pipeline here,
and is the sole distributor of natural gas to D.C. residents and businesses. Kay Management
markets and rents its apartments extensively to D.C. residents. The District of Columbia
therefore has compelling interests – specifically, its interests in protecting the life, safety, and
property of its 675,000 citizens – that justify both the exercise of jurisdiction over the Defendants
in the District, and the application of the District’s law to this legal dispute.
4.

Plaintiffs therefore bring this action in this Court on behalf of a class of persons

affected by the explosion at Building 8701 at the Flower Branch Apartments. Plaintiffs seek
justice in pursuit of two principle aims: first, to obtain compensation for themselves and other
residents who lost personal property and sustained damages; and second, to secure injunctive

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relief and structural reforms at Washington Gas and Kay Management to ensure that tragedies
like that at Flower Branch never happen again.
Parties
5.

Plaintiff Ericka Jineth Hercules Ramirez, a resident of Silver Spring, Maryland,

currently lives in Building 8650 at the Flower Branch Apartments.
6.

Plaintiff Rosali Amaya Benitez, a resident of Silver Spring, Maryland, currently

lives in Building 8640 at the Flower Branch Apartments.
7.

Plaintiff Abeba Heyi, a resident of Silver Spring, Maryland, lived in Building

8703 at the Flower Branch Apartments. Ms. Heyi continues to reside in Silver Spring, MD.
8.

Plaintiff Encarnacion Dubon Ortiz, a resident of Silver Spring, Maryland,

currently lives in Building 8644 at the Flower Branch Apartments.
9.

Plaintiff Donaldo Mondragon, a resident of Silver Spring, Maryland, currently

lives in Building 8670 at the Flower Branch Apartments.
10.

Plaintiff Yamileth Reyes Valladarez, a resident of Silver Spring, Maryland, lived

in Building 8701 at the Flower Branch Apartments. Ms. Valladarez continues to reside in Silver
Spring, MD.
11.

Plaintiff Solomon M. Weldemariam, a resident of Silver Spring, Maryland, lived

in Building 8701 at the Flower Branch Apartments. Mr. Weldemariam continues to reside in
Silver Spring, MD.
12.

The Plaintiffs named in paragraphs 5 through 11 are herein after collectively

referenced as “Class Representatives” or “Plaintiffs.”
13.

Defendant Washington Gas Light Company is incorporated in, and has its

principal place of business in, Washington, D.C.

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14.

Defendant WGL Holdings, Inc. (“WGL”), is incorporated in, and has its principal

place of business in, Washington, D.C. It is a publicly traded company (NYSE: WGL) formed in
2000, and operates and owns Washington Gas.
15.

WGL Holdings, Inc. and Washington Gas are collectively referred to herein as

“Washington Gas.”
16.

Defendant Kay Management Co., Inc. (“Kay Management”) is incorporated in

Maryland, where it also has its principal place of business.
17.

John Does are the manufacturers of the various parts that comprise the residential

gas service that serviced Building 8701 in the Flower Branch Apartments.
Jurisdiction and Venue
18.

The Court has subject matter jurisdiction under D.C. Code § 11-921(a).

19.

The Court has personal jurisdiction over Washington Gas and WGL because

Washington Gas is domiciled in, organized under the laws of, and maintains its principal place of
business in Washington, D.C. In addition, Washington Gas keeps its records and performs
significant corporate functions in the District – including the planning and implementation of
safety, inspection, and maintenance programs – and many of the acts and omission complained
of herein occurred within the geographic boundaries of the District of Columbia. D.C. Code
Ann. § 13-422.
20.

The Court has personal jurisdiction over Kay Management because it transacts

business in the District of Columbia by, among other means that will be revealed through
discovery: (a) systematically and continuously advertising their properties to District residents;
(b) renting their properties to former District residents; (c) conducting regular business with
Washington Gas; and (d) requiring every resident at the Flower Branch Apartments to enter into

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a contract with Washington Gas in order to have cooking gas and hot water. Because of this
conduct, it is reasonable for Kay Management to anticipate that it would find itself in court in the
District. D.C. Code § 13-423(a)(1) and (b).
21.

Venue is proper and convenient in this forum.

22.

Venue is proper here in because a substantial part of the events or omissions

giving rise to Plaintiffs’ claims occurred in the District, and a substantial part of the wrongful
conduct of Washington Gas emanated from the District.
23.

Moreover, both Defendants regularly and systematically conduct business in

Washington, D.C.
24.

A central liability issue in this case arises from Washington Gas’s decisions and

failures to act, many of which took place at Washington Gas headquarters and its operations
located in the District.
25.

The District and its citizens have an interest in regulating and holding accountable

businesses located in the District that engage in the wrongful conduct alleged here.
26.

The District is convenient for all parties to this litigation and both Washington

Gas and Kay Management have bona fide connections to this forum.
27.

Additionally, all physical evidence related to the cause of the explosion is no

longer located at the Flower Branch Apartments, but is instead in the possession of Washington
Gas and various federal agencies, including the Bureau of Alcohol, Tobacco, and Firearms, and
the National Transportation Safety Board, both of which have assumed jurisdiction over and
have performed investigations into the cause of the explosion.

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Factual Allegations
28.

Late in the evening on August 10, 2016, a resident of Building 8701 at the Flower

Branch Apartments was taking his trash out. As he passed by the gas meter room on the first
floor of his building, he heard a strange hissing noise and could smell natural gas. Before he
could return to his apartment to call for help, an explosion described as a “sonic boom” rocked
the surrounding area.
29.

The fire, caused by the explosion and fed by leaking natural gas, spread with such

force and speed that the residents, most of whom had been asleep, had just seconds to escape.
They were forced to use any possible means of getting out as the stairs and floors and walls
collapsed around them. With the hallways full of smoke and flames, many jumped from their
balconies to the ground below.
30.

Other residents, including those with children too small to jump, shouted

desperately from their upper floor windows, pleading for help. Some were forced to drop their
babies from the windows to terrified neighbors below.
31.

Despite the residents’ efforts to save their families and one another, seven

residents died in the fire, including two young children. Scores more suffered physical injuries.
32.

Those lucky enough to survive nonetheless endured great losses. Due to fire,

smoke, and water damage, residents lost their homes, family photos, life savings, identification
documents, furniture, and the contents of every room, closet, cabinet and shelf. Some were left
with nothing but what they grabbed when they fled their apartments.
33.

Those residents who were eventually able to return home had no gas service, and

could not cook or run hot water. Many were displaced for several days, and were unable to get to
work. The heavy smell of smoke and gas remains, and the remnants of the collapsed and burned

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out buildings stand just feet from their doors as a daily reminder of that horrific evening and the
suffering that followed.
34.

Before the explosion on August 10, residents of the Flower Branch Apartments

had informed Kay Management and authorities on many occasions that they could smell natural
gas.
35.

Just weeks before the explosion, on July 25, 2016, a Building 8701 resident called

911 reporting a gas smell.
36.

Despite this report and others, neither Kay Management nor Washington Gas

undertook appropriate inspections or repairs.
37.

Washington Gas is the sole distributor of natural gas to Washington D.C.

residents through its residential gas service. Washington Gas serves over 1.1 million customers
in the Washington, D.C. region.
38.

Washington Gas operates roughly 200 miles of Department of Transportation-

regulated transmission pipelines and thousands of miles of distribution pipelines.
39.

The underground pipe, service lines, and equipment that distribute natural gas to

Building 8701 of the Flower Branch Apartments were installed by Washington Gas and should
have been monitored, inspected, serviced, and maintained by Washington Gas.
40.

The Flower Branch Apartments, including Building 8701, are owned, managed

and maintained by Kay Management.
41.

Kay Management should have monitored, inspected, serviced, and maintained the

meter room of Building 8701.

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42.

John Does manufactured and sold to Washington Gas the underground pipes,

service lines, and equipment that distribute natural gas to Building 8701 of the Flower Branch
Apartments.
43.

Despite the 911 call from the resident of Building 8701 and numerous complaints

of natural gas odors by other residents, the Defendants did not properly inspect or remedy the
problem resulting in the tragedy of August 10, 2016.
Facts Related to Class Representatives
44.

Plaintiff Ericka Jineth Hercules Ramirez lives in Building 8650 and witnessed the

events of August 10, 2016. Following the explosion, she and her family were displaced from
their home for a night. When they returned they did not have hot water or gas to cook. She still
does not feel safe in her apartment.
45.

Plaintiff Rosali Amaya Benitez lives in Building 8640 and witnessed the events of

August 10, 2016. Following the explosion, he and his family were unable to return to their
apartment for several days and Mr. Benitez was unable to return to work until he could get back
into his apartment.
46.

Plaintiff Abeba Heyi lived in Building 8703 and witnessed the events of August

10, 2016. As a result of the explosion and fire, her home was entirely destroyed. She lost
everything she owned. She was unable to return to her apartment and was permanently displaced.
47.

Plaintiff Encarnacion Dubon Ortiz lives in Building 8644 and witnessed the

events of August 10, 2016. Following the explosion, he and his wife were unable to work until
they could return to their home several days later. They had extensive smoke damage to their
home and possessions.

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48.

Donaldo Mondragon lives in Building 8670 and witnessed the events of August

10, 2016. Following the explosion, he and his family were temporarily displaced from their
home.
49.

Yamileth Reyes Valladarez lived in Building 8701 and witnessed the events of

August 10, 2016. As a result of the explosion, her home was entirely destroyed. She lost
everything she owned. She and her family were unable to return to her apartment and were
permanently displaced.
50.

Plaintiff Solomon M. Weldemariam lived in Building 8701. His home was

entirely destroyed. He lost everything he owned. He was unable to return to his apartment and
was permanently displaced.
Class Definition and Class Action Allegations
51.

Class Plaintiffs bring this action on behalf of themselves and others under Rule 23

of the District of Columbia Superior Court Rules of Civil Procedure.
52.

Subject to revision as the case progresses through pretrial rulings and discovery,

the proposed class consists of all residents and residents’ guests of the Flower Branch
Apartments who sustained damages as a result of the August 10, 2016 explosion, excluding those
who sustained damages for personal injury or wrongful death.
53.

Specifically excluded from the Class are Defendants, any entities in which

Defendants have a controlling interest, and Defendants’ agents and employees.
54.

Numerosity: The Class is composed of approximately 75 households, and it is

impractical to individually join each household in a single action.
55.

Commonality: Defendants have engaged in a standardized course of conduct that

affects all Class Members. A critical question of law and fact common to the Class will

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materially advance the litigation: whether the gas explosion was the result of Defendants’
wrongful conduct. Other questions of law and fact common to the Class exist as to all members
and predominate over any questions affecting only individual members, including the following:
a.

Whether Washington Gas owed a duty to Plaintiffs and Class Members to

exercise due care in the installation, monitoring, inspection, servicing, and maintenance of the
underground pipe, service lines, and other equipment that distributes natural gas to Building 8701
of the Flower Branch Apartments;
b.

Whether Washington Gas had a duty to exercise the degree of care

commensurate with the danger inherent in providing residential natural gas service;
c.

Whether Washington Gas had notice of the natural gas leak prior to the

explosion and had a duty to take immediate and proper corrective action;
d.

Whether Washington Gas is responsible for the gas meters and related

equipment at the Flower Branch Apartments;
e.

Whether a defect in one or more of the products within the natural gas

delivery system was the proximate cause of the explosion;
f.

Whether Kay Management owed a duty to maintain the Flower Branch

Apartments, including the gas meter room of Building 8701, in a reasonably safe condition;
g.

Whether the natural gas leak in the meter room that caused the explosion

was the result of an unreasonably unsafe condition created by Kay Management’s failure to
inspect, maintain, and make necessary repairs;
h.

Whether Kay Management knew or should have known that the failure to

take corrective action after repeatedly being made aware of natural gas odors would constitute an
unreasonable risk of harm to Plaintiffs;

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i.

Whether Kay Management failed to care for, maintain, and otherwise

operate so as to give Plaintiffs free and quiet enjoyment of said premises thereby breaching the
lease;
j.

Whether Plaintiffs and Class Members were deprived of possession and

leasehold interest in part or all of the leased property; and
k.

Whether Defendants owed a duty of care (prior to the explosion) to provide

truthful information regarding the existence of the natural gas leak and the risk associated
therewith.

56.

Typicality: Plaintiffs’ claims are typical of the claims of the Class Members, as all

such claims arise out of the Defendants’ wrongful conduct, which is the proximate cause of the
damages sustained by Plaintiffs and Class Members. Further, the wrongful conduct of
Defendants renders each Class Member’s claims, legal theory, and injury common and typical.
57.

Adequate Representation: Plaintiffs are adequate representatives of the Class

because their interests do not conflict with the interests of the Class, they will fairly and
adequately protect the interests of the Class, and the Plaintiffs are represented by counsel skilled
and experienced in class actions.
58.

Predominance and Superiority: Class certification is appropriate because common

questions of law and fact predominate over questions affecting only individual Class Members
and a class action is the superior method of fair and efficient adjudication of this controversy.
The common liability issues in this class action may be resolved efficiently on a class-wide basis.
Should individual Class Members be required to bring separate actions, this Court and/or other
courts would be confronted with a multiplicity of lawsuits burdening the court system while also
creating the risk of inconsistent rulings and contradictory judgments. In contrast to proceeding on

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a case-by-case basis, in which inconsistent results will magnify the delay and expense to all
parties and the court system, this class action presents far fewer management difficulties while
providing unitary adjudication, economies of scale and comprehensive supervision by a single
court. The likelihood that individual members of the Classes will prosecute separate actions is
remote due to the time and expense necessary to conduct such litigation.
COUNT ONE
(Negligence – Washington Gas)
59.

Washington Gas owed a duty to Plaintiffs to exercise due care in the installation,

monitoring, inspection, servicing, and maintenance of the underground pipe, service lines, and
other equipment that distributes natural gas to Building 8701 of the Flower Branch Apartments.
60.

Washington Gas had a duty to exercise the degree of care commensurate with the

danger inherent in providing residential natural gas service.
61.

Washington Gas had notice of the natural gas leak prior to the explosion and had

a duty to take immediate and proper corrective action to inspect, service, and repair the gas leak.
62.

Washington Gas breached its duties to Plaintiffs by failing to use due care when

installing, monitoring, inspecting, servicing, and maintaining the underground pipe, service lines,
and other equipment that distributes natural gas to Building 8701 of the Flower Branch
Apartments. Further, Washington Gas breached its duty to Plaintiffs by failing to take corrective
action to properly inspect, service, and repair the gas leak.
63.

Washington Gas’s failure to exercise the degree of caution commensurate with

the danger in providing gas services was the proximate cause of Plaintiffs’ injuries.
64.

The damages sustained by Plaintiffs were a direct or a reasonably probable

consequence of the gas leak at Building 8701 of the Flower Branch Apartments.

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65.

Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Washington Gas for all compensatory damages for themselves and each member of
the Class.
COUNT TWO
(Product Liability – Washington Gas)
66.

Washington Gas delivered gas to the Flower Branch Apartments through their

system of transmission, distribution, and service lines. Washington Gas is responsible for the gas
meters and related equipment at the Flower Branch Apartments. All of the products within this
system used to deliver natural gas to the Flower Branch Apartments are products owned and
controlled by Washington Gas.
67.

A defect in one or more of the products within the natural gas delivery system

was the proximate cause of the explosion.
68.

Washington Gas possessed actual knowledge of the product defects and

consciously and deliberately disregarded the foreseeable harm that might result from the defects.
69.

The actual knowledge of Washington Gas includes, but is not limited to: (a) its

belief that there was likely a problem, accompanied by a failure to make a reasonable inquiry,
and (b) its willful refusal to know of the defects.
70.

The defects within the gas delivery system were the proximate cause of injury to

Plaintiffs.
71.

Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Washington Gas for all compensatory damages for themselves and each member of
the Class.

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COUNT THREE
(Negligent Failure to Inspect and Maintain – Kay Management)

72.

Kay Management owed a duty to Plaintiffs to maintain the Flower Branch

Apartments, including the gas meter room of Building 8701, in a reasonably safe but failed to do
so.
73.

Kay Management knew or should have known that the failure to maintain the

Flower Branch Apartments, including, the gas meter room of Building 8701, would create an
unreasonable risk of harm to Plaintiffs.
74.

The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition created by Kay Management’s failure to inspect, maintain, and
make necessary repairs.
75.

The natural gas leak in the meter room was the result of an unreasonably unsafe

condition of which Kay Management had notice. By failing to properly inspect, maintain, repair,
or notify Washington Gas of the known unsafe condition, Kay Management breached its duty to
Plaintiffs. For all conduct described herein, all of the employees or agents of Kay Management
acted within their scope of employment.
76.

Kay Management’s breach of its duty was the proximate cause of Plaintiffs’

injuries.
77.

Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of
the Class.

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COUNT FOUR
(Negligent Failure to Act - Kay Management)
78.

Kay Management knew or should have known that the failure to take corrective

action after repeatedly being made aware of natural gas odors would constitute an unreasonable
risk of harm to Plaintiffs.
79.

The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition created by Kay Management’s failure to take the appropriate
corrective action after being made aware of natural gas odors.
80.

The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition of which Kay Management had notice. By failing to properly
inspect, maintain, repair, or notify Washington Gas of the known unsafe condition, Kay
Management breached its duty to Plaintiffs.
81.

Kay Management’s breach of its duty was the proximate cause of Plaintiffs’

injuries.
82.

Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of
the Class.
COUNT FIVE
(Breach of Contract – Kay Management)
83.

Before August 10, 2016, Plaintiffs entered into or were the beneficiaries of a lease

agreement with Defendant Kay Management wherein it warranted and agreed that Plaintiffs
would be permitted to occupy a portion of the subject premises, and that the said premises would
be cared for, maintained, and otherwise operated so as to give Plaintiffs free and quiet enjoyment
of said premises.

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84.

On multiple occasions prior to the explosion, Kay Management was informed that

residents of Flower Branch Apartments could smell natural gas.
85.

As a result of its acts or omissions, Kay Management failed to care for, maintain,

and otherwise operate the Flower Branch Apartments so as to give Plaintiffs free and quiet
enjoyment of said premises thereby breaching the lease.
86.

Kay Management’s breach of the lease was the proximate cause of Plaintiffs’

injuries.
87.

Plaintiffs suffered damages as a result of Kay Management’s breach.

88.

Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of
the Class.
COUNT SIX
(Constructive Eviction – Kay Management)

89.

Before August 10, 2016, Plaintiffs entered into or were the beneficiaries of a lease

agreement with Defendant Kay Management wherein it warranted and agreed that Plaintiffs
would be permitted to occupy a portion of the subject premises, and that the said premises would
be cared for, maintained, and otherwise operated so as to give Plaintiffs free and quiet enjoyment
of said premises.
90.

On multiple occasions prior to the explosion, Kay Management was informed that

residents of the Flower Branch Apartments could smell natural gas.
91.

As a proximate result of Kay Management’s acts or omissions, Plaintiffs were

deprived of possession and leasehold interest in part or all of the leased property.

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92.

Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of
the Class.
COUNT SEVEN
(Breach of Implied Warranty of Habitability – Kay Management)

93.

Kay Management had a duty to maintain the leased premises in habitable

condition.
94.

On multiple occasions prior to the explosion, Kay Management was informed that

residents of the Flower Branch Apartments could smell the odor of natural gas.
95.

As a proximate result of Kay Management’s acts or omissions, Plaintiffs’

premises were left in an uninhabitable condition.
96.

Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of
the Class.
COUNT EIGHT
(Product Liability – John Does)
97.

John Does are manufacturers of the various parts that comprise the Washington

Gas system of transmission, distribution, and service lines for residential gas service to the
Flower Branch Apartments.
98.

A defect in one or more of the products within the natural gas delivery system

was the proximate cause of the explosion.
99.

John Does possessed actual knowledge of the product defects and consciously and

deliberately disregarded the foreseeable harm that might result from the defects.

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100.

The actual knowledge of John Does includes, but is not limited to: (a) their belief

that it was probable that there was a defect accompanied by a purposeful failure to make a
reasonable inquiry, and (b) their willful refusal to know of the defects.
101.

Plaintiffs, individually, and on behalf of the Class, demand judgment against the

John Doe Defendants for all compensatory damages for themselves and each member of the
Class.
Relief Sought
102.

Plaintiffs seek the following relief for themselves and the class:
a.

An Order certifying the proposed class, naming Plaintiffs as the Class

representatives for the Class, and appointing their counsel as Class Counsel;
b.

Judgment in favor of Plaintiffs and the Class for all damages, including

damages for being rendered homeless and displaced, harm to personal property, loss of use of
personal property, loss of use of household goods or wearing apparel, loss of the benefit of
leasehold interests, lost wages, additional expenses, nuisance, interference with enjoyment of
property, annoyance and inconvenience, the total of which does not exceed $5 million.
c.

A declaration that Defendants are financially responsible for providing

notice to the Class;
d.

Injunctive and equitable relief designed to prevent similar tragedies in the

future, both at Flower Branch Apartments and at other locations serviced by Washington Gas or
Kay Management.
e.

Attorneys’ fees and costs,

f.

Pre-judgment and post-judgment interest; and

g.

All other relief as the Court deems just and proper.

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Jury demand
Plaintiffs demand a trial by jury on all counts.

November 2, 2016

Respectfully submitted,

________________________
Brian A. Glasser (DC 1024003)
Cary Joshi (DC 1028594)
Bailey Glasser LLP
1054 31st Street NW, Suite 230
Washington, DC 20007
T: (202) 463-2101
F: (202) 463-2103
bglasser@baileyglasser.com
cjoshi@baileyglasser.com
John W. Barrett (pro hac to be filed)
Bailey Glasser LLP
209 Capitol Street
Charleston, WV 25301
T: (304) 345-6555
F: (304) 342-1110
jbarrett@baileyglasser.com
Nicholas Katz (pro hac to be filed)
CASA
8151 15th Ave.
Hyattsville, MD 20793
T: (240) 491-5743
nkatz@wearecasa.org
Deepak Gupta (DC 495451)
Matthew W.H. Wessler (DC 985241)
Gupta Wessler PLLC
1735 20th Street NW
Washington, DC 20009
T: (202) 888-1741
deepak@guptawessler.com
matt@guptawessler.com
Counsel for Plaintiffs and the Putative Class

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