A bystander at the recent bombing of a concert presented in connection with the Atlanta Olympic Games is suing AT&T (the sponsor of the park), Richard Jewell (the security guard who first noticed the suspicious package), the company contracted to provide security in the concert area, and the organizers of the Games. The complaint cites the lack of warning given to bystanders during the 25 minute period between the report of a suspicious object and the explosion. The complaint also accuses the defendants of failing to properly conduct background checks on new applicants for security positions.

IN THE STATE COURT OF FULTON COUNTY
STATE OF GEORGIA

LORENZO ESPINOSA

Plaintiff

vs.

AT&T CORP., doing business as
ATT Global Information
Systems; ANTHONY DAVIS
ASSOCIATES; and RICHARD
JEWELL and THE ATLANTA
COMMITTEE FOR THE OLYMPIC
GAMES, INC.; ABC CORPORATION
and JOHN DOE

Defendants


CIVIL ACTION FILE NO: 96V50116971 B


COMPLAINT

COMES NOW the Plaintiff, Lorenzo Espinosa, and files this, his
Complaint with this Honorable Court as follows:


COUNT ONE

1.

Defendant, AT&T Corp., d/b/a ATT Global Information Systems
(hereinafter referred to as "AT&T", is doing business in the State of
Georgia and was doing business in the State of Georgia at all times
material to the filing of this Complaint. Said Defendant may be
served by service upon its registered agent, that being: Prentice Hall
Corporation System, 100 Peachtree Street, Atlanta, Georgia, Fulton
County, 30303, and said Defendant is subject to the jurisdiction and
venue of this Honorable Court.

2

Defendant, Anthony Davis Associates, upon information and belief,
is a California Corporation which may or may not be certified and or
licensed to do business within the State of Georgia as a security
agency. Said Defendant may be served by registered or certified mail
directed to its chief executive officer as well as service upon the
Secretary of State. Said Defendant is subject to the jurisdiction and
venue of this Honorable Court.

3.

The Defendant, Richard Jewell is an individual residing in the State
of Georgia who worked as a security guard at Centennial Park on
July 27, 1996. Mr. Jewell may be served at his residence that being:
3649 Buford Highway, Apartment F3, Monico Station Apartments,
Atlanta, Dekalb County, Georgia. Said Defendant is subject to the
jurisdiction of this Honorable Court.

4.

The Defendant, The Atlanta Committee for The Olympic Games,
Inc., is a Georgia Corporation doing business within this State and
was doing business in the State at all times material to the filing of
this Complaint. Said Defendant may be served by serving their
registered agent for service, that being: William Porter Payne at 250
Williams Street, Suite 6000, Atlanta, Georgia 30303, Fulton County,
and said Defendant is subject to the jurisdiction of this Honorable
Court.

5.

Defendant, ABC Corporation whose present identity, name and
information is unknown will be named and served once that
information becomes available to the Plaintiff and said Complaint will
be amended at said time.

6.

Defendant, John Doe, whose present identity, name and information
is presently unknown will be named and served at a later date once
that information is known to the Plaintiff and said Complaint will be
amended at said time.

7.

On Saturday, July 27, 1996, at about 1:00 a.m., the Plaintiff was a
spectator on the premises occupied, managed, and controlled by the
Defendants. As such, the Plaintiff was attending performances and
entertainment sponsored by AT&T at the Global Olympic Village at
Centennial Park, Atlanta, Georgia.

8.

At all times relevant and material hereto, the Defendant, Anthony
Davis Associates, had a contractual duty to provide security for the
premises inuring to the benefit of the spectators and customers at or
near the Olympic Village; said premises being under their direction
and control.

9.

At or about 1:00 a.m., the Defendant, Richard Jewell, a security
guard employed by the Defendant, Anthony Davis Associates,
reportedly spotted a suspicious package that could have contained a
bomb and/or dangerous instrumentality.

10.

At all times material hereto, including July 27, 1996, through and
including 1:30 a.m. the Plaintiff remained as a spectator at Centennial
Park near AT&T's Global Village enjoying the concert.

11.

At no times material hereto, did the Plaintiff, in his capacity as a
spectator, receive safety warnings of any kind that a bomb was
present or may be present nor was the Plaintiff instructed to evacuate
from any zone of danger around or near the suspect package.

12.

Saturday, July 27, 1996, at approximately 1:25 a.m., a bomb
exploded in front of the AT&T Global Olympic Village at the
northeast corner of the sound tower.

13.

At said time and place as the bomb exploded, as outlined herein, and
because the Plaintiff in his capacity as a spectator and other spectators
were not evacuated and warned in a timely manner in the impending
danger, the explosive power of the bomb inflicted injury to the
Plaintiff and other spectators.

14.

Defendants had actual and/or constructive knowledge prior to the
explosion of the danger presented to those persons lawfully upon the
premises.

15.

Specifically, the occurrence made the basis of this Complaint and
Plaintiff's resulting injuries and damages were proximately caused by
the negligent conduct of the Defendants and/or their employees in one
or more of the following particulars:

(a) The Defendants failed to exercise ordinary care by failing to keep
their premises and approaches safe as required by O.C.G.A. Section
51-3-1;

(b) The Defendants failed to take proper steps to provide for safe
warning and evacuation procedures;

(c) The Defendants failed to adhere to safety standards regarding
bomb notice and protection;

(d) The Defendants failed to train and instruct their agents and
employees to properly respond to a bomb threat;

(e) The Defendants failed to properly conduct background checks on
new applicants for security positions;

(f) The Defendants failed to take all their steps applicable to insure the
safety of the Plaintiff and such evidence as will be shown at the trial
of this case.

These acts or omissions as enumerated above, singularly and/or in
combination with others, constitute negligence which proximately
caused the occurrence which forms the basis of this action and
Plaintiff's injuries and damages.

As a direct and proximate result of the explosion and negligence of
the Defendants as outlined herein, the Plaintiff sustained serious,
painful and permanent physical and emotional injuries and damages.
In addition, Plaintiff has incurred hospital and medical expenses, has
and will experience much mental and physical pain and suffering, has
and will lose wages, has a permanent disability, has a diminished
capacity to labor and to earn money, and will incur future medical
expenses.

WHEREFORE, as a result the Plaintiff prays that process issue and
that he have judgment in Count One of this Complaint in an amount
as a jury finds just and equitable for compensatory damages.


COUNT TWO

PUNITIVE DAMAGES

16.

Plaintiff realleges and reincorporates Paragraphs 1 through 15
hereinabove as-if fully set forth and repleads and realleges each
paragraph.

17.

The actions of the Defendants showed willful misconduct, malice,
fraud, wantonness, oppression, and the entire want of care which
raises the presumption of conscious indifference to the consequences
as provided by O.C.G.A. Section 51-12-5.1. Accordingly, the
Plaintiff is entitled to an award of punitive damages to punish,
penalize or deter the Defendant as a jury may find just and equitable.


COUNT THREE

18.

Plaintiff realleges Paragraphs 1 through 17 hereinabove as if fully set
forth and repleads and realleges each paragraph.

19.

The acts of the Defendants were in bad faith, and accordingly
Plaintiff is entitled to recover from Defendants all expenses of
litigation, including attorney's fees as provided by O.C.G.A. Section
13-6-11.

WHEREFORE, the Plaintiff prays for relief against the Defendants
jointly and severely as follow.:

(1) For general damages to compensate Plaintiff in an amount to be
determined by the enlightened conscious of a fair and impartial jury;

(2) For any and all special damages in an amount to be proved at trial;

(3) For punitive damages to deter Defendants from repeating said
conduct injuring the Plaintiff and the public;

(4) For all costs of the foregoing action;

(5) For all costs of litigation including but not limited to attorney's
fees;

(6) For trial by jury; and

(7) For such other relief as thin Honorable Court may deem proper
and necessary.

This 14th day of August, 1996.

Respectfully submitted,

MULLMAN & ALPERT, P.C.

/s/
Roy Mullman
Attorney for Plaintiff

1400 Resurgens Plaza
945 E. Paces Ferry Road
Atlanta, Georgia 30326
(404) 365-8800