Free Complaint - District Court of Delaware - Delaware

Case 1:05-cv-00345-SLR Document 1-4 Filed 05/27/2005 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Civil Action No. Q xm
Claim # 2 Reckless Endangerment
_ Gross Negligence
The alleged acts, in this suit, concem:
Other acts, which violated my civil rights (specified below)
l. Reckless Endangerment/Gross Negligence l
lt
A. While deployed outside my division, as a member of a Hazardous il
Materials Response Team, myself and other members of the FBI that i
were operating at the same location were needlessly exposed to an
extremely hazardous substance as a direct result of orders given by the ‘
Director of the Federal Bureau of Investigation, Robert S. Mueller III. L
During the briefing for the procedures to be completed by the team, E
the briefing officer specifically stated that the team would be staging
inside the building because the Director did not want to see FBI ,
personnel “suiting up" on the news. We were then told that the CDC (
and other members of the FBI had determined that the area that would I
be used for staging was safe. This was not tme. At the point were one it
member manifested symptoms that were similar to those which would
occur with the substance being tested for, panic set in.
B. The order to deviate from FBI guidelines for processing this type of
substance as well as the standard used in the Hazardous Materials
Response community placed all members of the team at risk for no
other reason but to avoid the perceived bad media coverage on the
part of Director Mueller.
C. Additionally, the medical expenses incurred for the prophylaxis
medical treatment was not initially paid for by the FBI. Since a
Workman’s Compensation (WC) Claim had to be filed by those
treated and we were exposed but need not contract anything, WC
refused to pay the bills. Several bills were sent and Johns Hopkins
threatened to refer them to a collection agency, thereby potentially
damaging the individual’s credit rating, before the FBI finally paid the
medical charges.