COMMONWEALTH OF MASSACHUSETTS
Suffolk, ss. Superior Court Department
of the Trial Court
___________________________________________ Civil Action No.
*
THE CITY OF BOSTON, THE BOSTON *
PUBLIC HEALTH COMMISSION *
Plaintiffs *
*
v. *
*
SMITH & WESSON Corp., F.I.E Corp., *
BERETTA U.S.A. Corp., COLT'S MFG. Corp., *
BROWNING ARMS Corp., GLOCK Corp., *
CHARTER ARMS Corp., SAVAGE ARMS Corp., *
DAVIS INDUSTRIES Corp., INTERARMS Corp., *
HARRINGTON & RICHARDSON Corp., *
HI-POINT FIREARMS Corp., SIGARMS Corp., *
NAVEGAR INC. d/b/a INTRATEC USA Corp., *
B.L. JENNINGS Corp., BRYCO ARMS Corp., *
KEL-TEC CNC, Corp., PHOENIX ARMS Corp., *
HERITAGE MANUFACTURING, INC. *
IMPORT SPORT Corp., *
LORCIN ENGINEERING Corp., *
MARLIN FIREARMS Corp., *
STURM, RUGER & CO Corp., *
SUNDANCE INDUSTRIES Corp., *
TAURUS FIREARMS Corp., *
U.S. REPEATING ARMS Corp. *
MOSSBERG & SONS, O.F. Corp., *
REMINGTON ARMS Corp., *
AMERICAN SHOOTING SPORTS COUNCIL, *
INC., NATIONAL SHOOTING SPORTS *
FOUNDATION, INC., SPORTING ARMS *
AND AMMUNITION MANUFACTURERS *
INSTITUTE, INC., AND DOES 1-250. *
Defendants *
___________________________________________*
COMPLAINT AND JURY DEMAND
Now come the plaintiffs, the City of Boston and the Boston Public Health Commission, by and
through their attorneys and hereby bring the present action against the above named defendants. The
facts alleged in this Complaint are made on information and belief.
A. NATURE OF THE ACTION
The City of Boston ("Boston") and the Boston Public Health Commission ("Commission") bring
SNIPPETS:
CHARTER ARMS Corp., SAVAGE ARMS Corp., * DAVIS INDUSTRIES Corp., INTERARMS Corp., *
Now come the plaintiffs, the City of Boston and the Boston Public Health Commission, by and
The City of Boston and the Boston Public Health Commission bring the present action to obtain
Through this calculated strategy of willful blindness, defendants exploit, rely upon, and
The resulting flood of guns for criminal use has created a public nuisance within the City of
Defendants affirmatively rely upon the laxness of dealers and the ingenuity of criminals to
Others conveniently look the other way while sales are made to straw purchasers or under
Even a disposable lighter has certain safety devices and contains warnings regarding the risk
The defects in the design of firearms not only pose a danger to the user of the products, but
As a result of the defendants' actions, the plaintiffs have had to expend significant money
Commonwealth of Massachusetts and is located in Suffolk County,
Defendant CHARTER ARMS Corp. is a corporation organized and existing under the laws of the
Defendant DAVIS INDUSTRIES Corp. is a corporation organized and existing under the laws of
ASSC is an industry trade association composed of firearms manufacturers and sellers,
Of these, more than 14,300 were homicides and about 18,100 were suicides, with more than
Tracing of crime guns by the Federal Bureau of Alcohol, Tobacco and Firearms confirms that
The flow of defendants' firearms into the unlawful market and into the hands of unauthorized
Year after year, a number of children in Boston are grievously injured and/or killed because
Furthermore, as a direct result of the defendants' manufacture, sale and distribution of
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