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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE ETHIOPIAN AIRLINES FLIGHT 

ET 302 CRASH

DONNA MARGARET VECERE, 

Individually, and as Personal Representative of 

the Estate of MATTHEW THOMAS 

VECERE, deceased, and on behalf of all 

Surviving Beneficiaries,

Plaintiff,

v.

THE BOEING COMPANY, a Delaware 

corporation;

ROSEMOUNT AREOSPACE, INC., a 

Delaware corporation;

ROCKWELL COLLINS, INC., a Delaware 

corporation,

Defendants.

Lead Case No.: 19-cv-02170

SHORT FORM COMPLAINT AND 

NOTICE OF ADOPTION OF MASTER 

COMPLAINT

DEMAND FOR JURY TRIAL

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PLAINTIFF, DONNA MARGARET VECERE, Individually, and as the Personal 

Representative of the Estate of MATTHEW THOMAS VECERE, deceased, COMPLAINS OF 

THE DEFENDANTS AND EACH OF THEM AS FOLLOWS: 

1. Plaintiff refers to and incorporates herein by reference the Master Complaint, and any 

and all later amendments thereto, filed in IN RE ETHIOPIAN AIRLINES FLIGHT ET 302 

CRASH, as though fully set forth herein. Plaintiff hereby adopts the Master Complaint and 

agrees to be bound by any rulings with respect to the pleadings of the Master Complaint.

2. Plaintiff adopts each of the general allegations of the Master Complaint except for those 

paragraph numbers set forth here, if any: N/A

CLAIMS AGAINST DEFENDANTS

3. Plaintiff brings those Counts, as applicable, against each of the Defendants in the 

Master Complaint checked below:

☒ THE BOEING COMPANY

☒ ROSEMOUNT AEROSPACE, INC.

☒ ROCKWELL COLLINS, INC.

4. Plaintiff incorporates by reference each of the Counts in the Master Complaint checked 

below:

As against THE BOEING COMPANY:

☒ Count One for Negligence 

☒ Count Two for Breach of Warranty

☒ Count Three for Strict Liability

☒ Count Four for Failure to Warn

As against ROSEMOUNT AEROSPACE, INC.:

☒ Count Five for Negligence

☒ Count Six for Strict Liability

☒ Count Seven for Breach of Warranty

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As against ROCKWELL COLLINS, INC.:

☒ Count Eight for Negligence

☒ Count Nine for Strict Liability

☒ Count Ten for Breach of Warranty

PLAINTIFFS’ INFORMATION:

4. Decedent, MATTHEW THOMAS VECERE, was an individual who was killed in the 

crash of Ethiopian Airlines Flight ET 302 on March 10, 2019. 

5. The following Plaintiffs are heirs, beneficiaries, and/or next of kin of Decedent, or 

other persons entitled to bring an action for the wrongful death of Decedent, and bring 

the causes of action alleged herein: 

DONNA MARGARET VECERE is the Personal Representative of the Estate of the 

Decedent entitled to bring claims on behalf of all surviving heirs, beneficiaries, and/or 

next of kin under applicable law(s)

6. Plaintiff is a resident of Mays Landing, New Jersey. Plaintiff’s decedent was a resident 

of Long Beach, California. 

7. Decedent’s Estate is represented in the following capacity:

☒ DONNA MARGARET VECERE is the Personal Representative of the Estate of 

Decedent and is authorized to bring an action on behalf of the Decedent. The Superior 

Court of California, County of Los Angeles, has appointed plaintiffs as the Personal 

Representative on February 4, 2020: 

☐ Other (please describe): 

________________________________________________________________.

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PLAINTIFFS’ DAMAGES:

8. Plaintiffs request the relief checked below:

All past and future general and compensatory damages in an amount according to proof 

at trial, including the following:

☒ For Decedent’s conscious and physical pain and suffering, fright and terror, fear of 

impending and imminent death, mental anguish, and emotional distress, in an amount 

according to proof at trial.

☒ For past and future loss of support and services in money or in kind, in an amount 

according to proof at trial.

☒ For past and future loss of consortium, love, companionship, comfort, care, assistance, 

protection, affection, society, moral support, training, advice, tutelage, and guidance, in 

an amount according to proof at trial.

☒ For past and future grief, emotional distress, and sorrow, in an amount according to 

proof at trial.

☒ For funeral expenses, burial expenses, estate administration expenses, and other related 

expenses in an amount according to proof at trial.

☒ For expenses for the identification and/or transportation of Decedent’s remains, 

according to proof at trial.

☒ For all property losses, in an amount according to proof at trial.

☒ For attorneys’ fees, costs and other damages as permitted under applicable laws.

☒ For punitive and exemplary damages in an amount according to proof at trial;

☒ For pre- and post-judgment interest on all damages as allowed by the law.

☒ For all costs of suit incurred herein. 

☒ For such other and further relief as the Court shall deem just and proper.

☐ Other (specify): 

____________________________________________________________________________

____________________________________________________________________________

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ADDITIONAL ALLEGATIONS, IF ANY

9. MATTHEW THOMAS VECERE is survived by his mother, DONNA MARAGERET 

VECERE, and his sister Tomra Vecere. He was 43 years old when he died. Matt was a 

marketing writer and content provider for IQAir, a company specializing in air filtration 

systems and air quality monitoring products. He was traveling to Nairobi aboard Flight 302 to 

represent his company at a weeklong environmental summit sponsored by the United Nations

Environmental Assembly (“UNEA”). Tragically, Matt was never able to address the members 

of the UNEA and share with them the cutting edge technologies that were available to help 

monitor and improve the air quality for people in countries like Nigeria, which suffers from 

serious air pollution issues. 

Ever since Matt was a young man, he was passionate about the environment, civil 

rights, social and environmental justice, and advocating for those less fortunate. Simply put he 

was a humanitarian. His mother, Donna, says that helping others is what drove her son. For 

example, Matt dropped everything to travel to Haiti after the 7.0 magnitude earthquake struck 

in 2010. He would return many times to Haiti to help overcome the devastation and improve 

living conditions for countless victims. Matt gave his time, resources, boundless energy and 

passion to help the children of Haiti through the Sustainable Orphanages for Haiti organization. 

Matt was so dedicated to his work in Haiti that many children thought of him like a father, and 

were heartbroken by his loss. Just weeks before his death, Matt returned to Haiti to deliver 

some air cleaning systems. This led to IQAir recognizing his passion and skill for helping 

others and selecting him to present at the UN event in Nairobi. 

Donna has been devastated by the sudden and senseless loss of her only son Matthew. 

Matt was a devoted son and they had a very close and loving relationship. Donna's grief, 

sorrow, pain and suffering are overwhelming and she will never be the same. Donna’s 

suffering is compounded by the circumstances of the crash and how easily the defendants 

could have prevented it from occurring. Matt’s death and the manner in which he died has 

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caused her severe grief and mental harm, in addition the loss of companionship, services and 

support from her son.

The manner in which Matt died is particularly distressing due to the terrifying nature of 

his final moments. Shortly after take-off, the aircraft began making noticeably unusual, alarming 

and uncomfortable movements in response to the erroneous AOA sensor and MCAS activations. 

During the last several minutes before ET-302 crashed, Matt experienced violent oscillations of 

the aircraft, which resulted in his fear of impending death, as well as physical and mental predeath pain and suffering. Ultimately, Matt was exposed to extreme forces as the aircraft dove 

down towards the ground at speeds approaching 600 miles per hour during which time Matt

surely knew he was about to die. 

DEMAND FOR JURY TRIAL

PLAINTIFF hereby demands a trial by jury as to all claims in this action.

DATED: June 9, 2020

/s/ Todd A. Smith

Todd A. Smith

Brian LaCien

SMITH LACIEN LLP

70 West Madison Street, Suite 5770

Chicago, IL 60602 

Tel: 312-509-8900

Email: tsmith@smithlacien.com 

Email: blacien@smithlacien.com 

KREINDLER & KREINDLER LLP

Brian J. Alexander

Justin T. Green,

Anthony Tarricone

Daniel O. Rose

Megan W. Benett

Vincent C. Lesch

750 Third Avenue 

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New York, NY 10017 

Tel: 212-687-8181 

Email: balexander@kreindler.com

Email: jgreen@kreindler.com 

Email: atarricone@kreindler.com

Email: drose@kreindler.com

Email: mbenett@kreindler.com

Email: vlesch@kreindler.com

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