Consolidated statement of claim re: Sunrise Propane explosion

38property, and required the plaintiffs and other class members to evacuate theirproperties105, lt was reasonably foreseeable that the plaintitfs and other class members wouldsuffer personal injuries as a result of the explosion or escape of propane and,altematively, the escape of other contaminants from the facility, includingemotional and psychological trauma and mental distress, The plaintiffs whoresided near the Facility and other class members were awoken in the middle ofthe night, felt their homes being shaken, heard and felt a series of largeexplosions, saw several fireballs in the sky near their homes, and wereevacuated from their homes, These events reasonably caused them toexperience personal injury and to be in fear for their lives and the lives of theirfamilies106 lt was atso reasonably foreseeable that the plaintiffs' and other class members'property and contents would sustain property damage, and alternatively could becontaminated by the escape of propane and other contaminants from the facility'It was reasonably foreseeable that, as a re$ult of the explosions and fear offurther explosions, and alternatively as a result of the escape of contaminants,the plaintiffs and other class members would be displaced from their homes andbusinesses for a period of time, causing them to incur a variety of expenses,including expenses for shelter, transportation, meals and other necesslties, andreplacernent of inventory lt was also reasonably foreseeable that, as a result of