a. Failing to provide adequate crowd control on the premises when it knew or should have known that Plaintiffs were exposed to a risk of harm;
b. Failing to prevent the reasonably foreseeable injuries from occurring to Plaintiffs;
c. Failing to recognize the high likelihood of injuries by third persons which might endanger the safety of Plaintiffs;
d. Failing to properly patrol the premises;
e. Allowing guns to be brought into the club;
f. Failing to screen for guns and to prevent guns from being brought into the club;
g. Failing to hire and/or utilize properly trained security guards and other employees;
h. Failing to properly train, instruct and supervise their employees in fulfilling their duties and obligations to invitees, such as Plaintiffs;
i. Negligently retaining incompetent security guards and other employees;
j. Failing to provide appropriate security measures to ensure the safety of Plaintiffs;
k. Failing to have sufficient increased security when it is foreseeable that there will be criminal acts at the concert of said rapper;
l. Failure to secure all outside entrances to Power;
m. Failing to provide an environment that is reasonably safe from security threats;
n. Failing to evaluate the potential security risks posed by the physical and operational environment at Power;
o. Failing to take all violent and threatening incidents seriously, investigate and take appropriate corrective action;
p. Failing to provide necessary authority and resources for staff to carry out violence prevention measures;
q. Inadequate physical qualifications, testing, training, supervision, communications and instruction of security personnel;
r. Failure to warn their business invitees of the magnitude of criminal activities that occurred around the premises of Power;
s. Failing to secure and monitor the area leading from the outside of Power to the inside;
t. Failing to properly observe, monitor, and report in order to avoid the shooting;
u. Failing to intervene in order to avoid the shooting;
v. Failing to identify, investigate, report and maintain records of significant security incidents and suspicious activities in and around the premises of Power, including but not limited to the parking areas;
w. Failing to exercise reasonable care to detect, forestall or prevent or deter the danger;
x. Failing to recognize and act promptly in response to previous incidents of dangers;
y. Failing to adhere to city code and state laws designed to enhance citizen safety, including laws regulating capacity;
z. Failing to provide and maintain sufficient entry and exit locations;
aa. Failing to otherwise protect Plaintiffs from such danger on Power premises; and
bb. Other such other negligent acts and/or omissions as discovery or the evidence may show.
"The victims of the Power Ultra Lounge shooting deserve better," [plaintiff Tasheara] Slocum said Wednesday at a news conference in Little Rock. "I refuse to be a lifelong victim." ...
"While I was not prepared for such a shooting to occur, Power Ultra Lounge and its owners and employees should have been," [plaintiff Tyrone] Jackson said. "It seemed like the club and its employees were not prepared for any type of crime to occur, let alone a mass shooting."
Attorneys for Jackson and Slocum said the 19 plaintiffs include people who were shot or trampled, as well as people who suffered psychological trauma.
"It's no secret that our city has a crime problem," plaintiff's attorney Joshua Gillispie said. "Much of that is difficult to prevent. This particular crime was not."