https://www.scribd.com/document/831314692/Motion-for-Punitive-Damages-GRANTED​

https://www.scribd.com/document/831314887/Amended-Complaint-W-Request-for-Punitive-Damages

 

 

 

 

Deposition : January 21st 2025

https://www.tiktok.com/@bradley.v.clevelandbrown/video/7478678176638520619​

https://www.tiktok.com/@bradley.v.clevelandbrown/video/7478695362962853166

 

 

 

 

 

Drunk Fan Causes Chaos: Assault at Cleveland Browns Game

 

The Issue:

 

NFL football games are beloved by millions, but an unchecked drinking culture has created a dangerous environment for fans, families, and stadium staff. Alcohol consumption, particularly excessive drinking, has been a major contributor to violence, crime, and unsafe conditions at venues like Huntington Bank Stadium. (Cleveland Browns). Fan reports and safety data show an alarming rise in:

• Physical altercations
• Verbal abuse and harassment
• Public intoxication and related crimes
• Unsafe conditions for families, children, and non-drinking attendees
• Domestic violence incidents correlated to game outcomes

Huntington Bank Stadium is meant to be a safe place for people of all ages to enjoy America’s favorite sport. Yet, the escalation of alcohol-fueled incidents threatens both fan enjoyment and public safety.

Why This Matters:

Safety Risks: Increased drinking contributes to violent incidents that put fans and staff at risk of injury or harm.

Family Unfriendliness: Families and young fans feel unsafe or are deterred from attending games.

Damage to Reputation: Stadium violence and excessive drinking damage the image of NFL teams and the league.

Community Impact: Alcohol-related crime and disorder extend beyond the stadium, negatively affecting the surrounding neighborhoods.

 

Our Call to Action:

We urge the NFL and its leadership, & The Cleveland Browns Owners including Jimmy and Dee Haslam, to enact the following measures:

Enhanced Alcohol Management Policies:

• Limit the number of alcoholic beverages per purchase.
• Reduce alcohol sales after the 2nd quarter to promote responsible drinking.
• Implement stricter ID checks and monitoring to prevent overconsumption.
• Create a job position to recognize and spot potential overly intoxicated patrons. 
  

 

Increased Security Measures:

• Expand training for stadium staff to identify and manage intoxicated individuals.

Fan Education Campaigns:

• Launch league-wide messaging promoting responsible drinking and encouraging fans to “Be a Good Sport” & to "Act like your Mother is there"
• Offer incentives for designated drivers, sober attendees, and fans promoting positive sportsmanship.
• Offer incentives for designated drivers and sober attendees. (reward fans with food coupons for being designated drivers)
• Start a Designated Driver Raffle. Create a station for Everyone who is a designated driver. Stamp their ticket as a designated driver. Give them wrist bands and a raffle ticket for a chance to win the "responsible drinkers raffle". 
• Highlight the harmful link between alcohol, gambling losses, and aggression.

Community Engagement:

• Partner with local law enforcement and community groups to monitor and reduce alcohol-related crime around stadiums.
• Allow responsible drinking groups to hand out free brochures and leaflets to potential fans to help attack alcoholism. 

According to the Harris Poll, about 84% of Americans say they drink alcohol while watching football, which is the highest percentage compared to any other sport. Alcohol and intimate partner violence (IPV) often go hand in hand, with studies showing that 10-15% of American women experience IPV. Alcohol can play a role by impairing judgment, intensifying aggressive tendencies, and creating a sense of control in the abuser, which can escalate violent behaviors. Even though alcohol doesn’t directly cause domestic violence, it’s often used as an excuse and can make abusive tendencies even worse. In fact, alcohol is involved in 40-60% of domestic violence cases , and men with alcohol problems are 2 to 4 times more likely to abuse their partners. Also, women in abusive relationships often struggle with substance use, sometimes because their partners force them into it .

Gambling can also be very addictive, bringing in many people into a cycle that they can’t break, affecting their mental health. Research shows that domestic violence rates can increase by 10% after a football team experiences an unexpected loss, especially in states where sports betting is legal. . A study from the University of Oregon highlighted that this rise in intimate partner violence is even more pronounced in states with mobile sports betting. When fans lose money on a bet, and also after an unexpected loss, their emotions like frustration and anger can escalate, creating a dangerous environment for those around them. The ease of placing bets through mobile apps only adds to the problem, making it easier for fans to gamble from home and increasing both their financial and emotional stress.

ALCOHOL + GAMBLING + LOSING TEAM = Potential Violence 

Therefore you will need a lot of security if the Equation applies 

Conclusion:

NFL games should be a safe, inclusive, and family-friendly experience for all fans. By addressing the drinking culture and implementing these solutions, the NFL can reduce violence, ensure public safety, and set a positive example for professional sports leagues nationwide.

We call on the NFL, Jimmy and Dee Haslam, and all stadium stakeholders to take meaningful action now to create a safer, more welcoming environment for every fan.

 

We call on NFL stakeholders to stop putting "PROFITS OVER PEOPLE"

It's time to start treating the people's health as the main issue. 

The NFL must take responsibility for the dangerous drinking culture it fosters and address the risks it poses to non-drinking fans who are unfairly exposed to its harmful effects.

1. Verbal Harassment: Fans who are intoxicated may shout insults, use foul language, or engage in inappropriate behavior toward others.
2. Physical Altercations: Excessive drinking can escalate to aggressive behavior, increasing the likelihood of fights and physical harm.
3. Safety Risks: Drunk fans may stumble, fall, or cause accidents, endangering those nearby.
4. Property Damage: Intoxicated individuals can damage seats, vehicles, or other property, creating unsafe or uncomfortable environments.
5. Disrupted Game Experience: Excessive noise, spills, and rowdy behavior caused by drunk fans can ruin the enjoyment of the game for others.
6. Health Hazards: Public intoxication can lead to vomiting or other unhygienic situations that pose health concerns to others.
7. Emotional Stress: Constant exposure to loud, aggressive, or disruptive behavior can create anxiety and discomfort for non-drinking fans, especially families or children.
8. Increased Security Concerns: Alcohol-fueled incidents can overwhelm security and make the venue feel unsafe for everyone.

 

Signatures:

 

Joshua David Bradley Sr.   (216) 970-5718

jbradl67@lakers.mercyhurst.edu

 

Recently filed lawsuits alleging Negligent Security at the Huntington Bank Stadium (Cleveland Browns)

Preview attachment APEX_000016-APEX_000025 - First Energy Stadium Incident Report of 10_31_22.pdf

***Update 2/21/2025

 

Lack of Officers at the Northeast Ramp/Electronic Merchant Systems Gateway:

The report confirms that no officers were stationed in that specific area at the time of the incident. However, there were officers placed in other sections of the stadium. The reason for this deployment strategy may have been based on past incidents, crowd control priorities, or an oversight in staffing.

Incident Report Writers vs. Officers Stationed in the Area:
The individuals who wrote the report were not stationed at the Northeast Ramp because no security personnel were assigned to that location. This suggests that the report was written based on secondhand accounts, camera footage, or after-the-fact observations rather than firsthand security presence at the scene.

 
How Proper Staffing Could Have Prevented the Incident:

If APEX Security had assigned guards to the Electronic Merchant Systems Gateway (Sections 120-121), the attack WOULD have been deterred or responded to more quickly. A visible security presence could have discouraged the attackers, allowed for an immediate intervention, and potentially reduced the severity of the incident. The lack of stationed officers in that area created a vulnerability that was exploited during the incident.
 

Preview attachment APEX_000016-APEX_000025 - First Energy Stadium Incident Report of 10_31_22.pdf

   

 

There remain genuine disputes as to whether APEX Security provided adequate security on 10/31/2022. 

The Northeast Ramp only had a bailiff present. (NO APEX EMPLOYEES)
No APEX guards were stationed at the Electronic Merchant Systems Gateway (Sections 120-121). 

Landmark Security guards were observed on their phones, failing to actively monitor or protect the area.

ALSO one of the witness reports states that the location of the attack was 127 . THAT IS NOT TRUE . The attack happened in the 119-121 sections by the electronic merchants systems gateways closer to the BREWSKI Kiosk 
These are not opinions; these are facts.

 Who was actually there to protect the fans and employees?

 

https://www.scribd.com/document/831308179/APEX-000001-APEX-000013-Browns-Contract-Redacted​

https://www.scribd.com/document/831307625/Cleveland-Browns-Answers-and-Objections-to-RFAs-Served-1-20-24​

https://www.scribd.com/document/831308645/Landmark-allied-Contract-Redacted​

https://www.scribd.com/document/831308958/Joshua-Bradley-Sr-v-CLEVELAND-BROWNS-FOOTBALL-COMPANY-LLC​

https://www.scribd.com/document/831309202/Joshua-Bradley-Sr-v-v-CLEVELAND-BROWNS-FOOTBALL-COMPANY-LLC-CLEVELAND-BROWNS-STADIUM-COMPANY-LLC​

https://www.scribd.com/document/831310063/Defendant-APEX-Resp-to-Pltfs-1​

https://www.scribd.com/document/831310444/Bradley-Apex-s-Responses-to-RFPD-1​

https://www.scribd.com/document/831310618/Bradley-Apex-s-Answers-to-Plaintiff-s-Second-Set-of-Interr-1​

https://www.scribd.com/document/831310978/Aramark-Answers-to-1st-Set-of-Interrogatories-32851100-1​

https://www.scribd.com/document/831311117/Aramark-Answers-to-2nd-Set-of-Interrogatories-32850429-1​

https://www.scribd.com/document/831311315/Aramark-Responses-to-RQ-Admissions-32850853-1​

https://www.scribd.com/document/831311741/Aramark-Responses-to-RQ-Production-32850844-1

 

APEX_000016-APEX_000025 - First Energy Stadium Incident Report of 10_31_22.pdf 1.9 MB