20. Upon reaching this wall of glass, Chloe
asked to be lifted up so that she could bang on the glass of the window, as Chloe frequently did at her older brother’s hockey games. Mr. Anello then lifted Chloe up onto the railing and held Chloe while
she leaned forward to bang on the glass that Mr. Anello
and Chloe thought to be in front of them. As Chloe leaned forward, however, there was no glass in the frame in front of her, and
she slipped from Mr. Anello’s arms, falling through the open pane and down approximately 150 feet below onto the Pier in San Juan, resulting in her death.
https://www.lipcon.com/wp-content/uploads/2019/12/DE-1-Wrongful-Death-Complaint.pdf