IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

IN RE ETHIOPIAN AIRLINES FLIGHT 

ET 302 CRASH 

JAMES ANDERSON WANSBROUGH 

VICK and REBECCA LOUISE VICK, 

Individually and as Co-Executors of the Estate 

of OLIVER CHARLES ANDERSON VICK, 

Deceased, on behalf of all Surviving 

Beneficiaries, 

Plaintiffs, 

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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PLAINTIFFS JAMES ANDERSON WANSBROUGH VICK, and REBECCA LOUISE 

VICK, Individually and as Co-Executors of the Estate of OLIVER CHARLES ANDERSON 

VICK, Deceased, on behalf of all Surviving Beneficiaries, complain of the defendants, and each 

of them as follows: 

1. Plaintiffs refer to and incorporate herein by reference the Master Complaint, and any and 

all later amendments thereto, filed in IN RE ETHIOPIANAIRLINES FLIGHT ET 302 CRASH, 

as though fully set forth herein. Plainfiffs hereby adopt the Master Complaint and agree to be 

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

2. Plaintiffs adopt 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. Plaintiffs bring those Counts, as applicable, against each of the Defendants in the 

Master Complaint checked below: 

E/ 

THE BOEING COMPANY 

ROSEMOUNT AEROSPACE, INC. 

ROCKWELL COLLINS, INC. 

4. Plaintiffs incorporate by reference each of the Counts in the Master Complaint checked 

below: 

As against THE BOEING COMPANY.• 

® Count One fox 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 

1~ Count Seven for Breach of Warranty 

As against ROCKWELL COLLINS, INC.: 

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® Count Eight for Negligence 

® Count Nine for Strict Liability 

® Count Ten for Breach of Warranty 

PLAINTIFF'S INFORMATION: 

4. Decedent, Oliver Chazles Anderson Vick, 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, beneficiazies, 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: 

JAMES ANDERSON WANSBROUGH VICK, father of the Decedent and CoExecutor of Decedent's Estate entitled to bring wrongful death claims on behalf of all 

surviving beneficiaries; 

REBECCA LOUISE VICK, sister of the Decedent and Co-Executor of Decedent's 

Estate entitled to bring wrongful death claims on behalf of all surviving beneficiaries; 

6. Plaintiffs are residents of England. Plaintiffs' Decedent was a resident of England and 

France who worked for the United Nations and was stationed in Somalia. 

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

® JAMES ANDERSON WANSBROUGH VICK and REBECCA LOUISE VICK are CoExecutors of Decedent's Estate and are authorized to bring an action on behalf of the 

Decedent's Estate. Plaintiffs were appointed as Co-Executors by the High Court of 

Justice England and Wales, on December 6, 2019 

❑ Other (please describe): 

PLAINTIFFS) DAMAGES: 

8. Plaintiffs) requests the relief checked below: 

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

at trial, including the following: 

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f.1 

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 

anamount according to proof at trial. 

❑x 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; 

❑x 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): 

ADDITIONAL ALLEGATIONS, IF ANY 

9. Oliver "011y" Charles Anderson Vick was born on September 20, 1973, and died in the 

crash of ET302 on March 10, 2019 at the age of 45. He is survived by his two daughters, S.V., 

age 8, and I.V., age 11. He is also survived by his father, James Anderson Wansborough Vick, 

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his mother, Cheryl Anne Vick, his sister, Rebecca Louise Vick, and his former partner, Ilaria 

Gandossi, who is also the mother and natural guardian of 011y's children. Ilazia resides in Italy 

with her and 011y's daughters, S.V. and I.V. 

011y was a humanitazian worker with the United Nations assistance mission in Somalia. 

At the time of the crash, 011y was returning to work with UNSOM in Mogadishu, after two 

weeks' annual leave in France and Italy with his children. In his storied career in humanitazian 

aid, 011y left an indelible mazk throughout the world. He helped bring forth pazliamentary 

elections in Afghanistan, where he spent a decade working to establish democracy in the waztorn country. 011y was a dedicated and loving father, son, brother and provider who supported 

his children and their mother Ilaria. 011y was well known for his warmth and energy and will 

be missed deazly by his two young daughters and their mother, his loving parents and sister, as

well as many co-workers and friends. 

The manner in which 011y died is pazticulazly distressing for surviving family due to the 

tenifying 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, 011y experienced 

violent oscillations of the aircraft which resulted in his fear of impending death as well as physical 

and mental pre-death pain and suffering. Ultimately, 011y was exposed to extreme forces as the 

aircraft dove down towards the ground at speeds approaching 600 miles per hour during which 

time 011y surely knew he was about to die. 

DEMAND FOR JURY TRIAL 

PLAINTIFFS hereby demand a trial by jury as to all claims in this action. 

Dated: Chicago, Illinois 

2020 

/s/Todd A. Smith 

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One of the Attorneys for the Plaintiff 

Todd A. Smith 

Brian LaCien 

Smith LaCien, LLP 

70 West Madison, Suite 5770 

Chicago, IL 60602 

T:312-509-8900 

F:312-210-9358 

Email: tsmith~u,smithlacien.com 

Email: blacien@smithlacien.com

KREINDLER & KREINDLER LLP 

Justin T. Green, 

Anthony Tarricone 

Brian J. Alexander 

Daniel O. Rose 

Megan W. Benett 

Andrew J. Maloney, III 

Vincent C. Lesch 

Kevin J. Mahoney 

Erin R. Applebaum 

750 Third Avenue 

New York, NY 10017 

Tel: 212-687-8181 

Email: jgreen@kreindler.com 

Email: atarricone@kreindler.com 

Email: balexander@kreindler.com 

Email: drose@kreindler.com 

Email• mbenett@kreindler.com 

Email: amaloney@kreindler.com 

Email: vlesch@kreindler.com 

Email: kmahoney@kreindler.com 

Email: applebaum@kreindler.com 

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