The shooting took place Oct. 21 on the set of the film on Bonanza Creek Ranch in Santa Fe County, N.M., as Mr. Baldwin prepared to film a close-up of him drawing a .45 revolver from a shoulder holster. According to Ms. Mitchell’s lawsuit, Mr. Baldwin failed to check the gun himself to see if it was loaded before handling it.
They were preparing for three tight camera shots, according to the lawsuit: one of Mr. Baldwin’s eyes, one of a blood stain on his shoulder, and one of his “torso as he reached his hand down to his holster and removed the gun.”
According to court papers filed by the Santa Fe County Sheriff’s Department, the movie’s first assistant director, Dave Halls, had called out “cold gun” before handing the revolver to Mr. Baldwin, using a term indicating that the gun did not contain live ammunition. A lawyer for the movie’s armorer, Hannah Gutierrez-Reed, said that Ms. Gutierrez-Reed had loaded the revolver with what she believed to have been dummy rounds, which do not contain gunpowder and cannot be fired.
The lawsuit charges that Mr. Baldwin knew that it was typical protocol for an armorer or prop master to hand a gun to the actor after demonstrating that it is empty — not for the first assistant director to do so — and that Mr. Baldwin failed to follow those rules. It also charges that Ms. Gutierrez-Reed allowed guns and ammunition to be left unattended on the set that day. The lawsuit accuses the production of hiring Ms. Gutierrez-Reed, 24, who had just started out her career as a lead armorer in the film industry, as part of a series of “cost-cutting measures.”
Ms. Gutierrez-Reed’s lawyer, Jason Bowles, has said that his client noticed that day the gun was left unattended for several minutes after she had asked other crew members to watch the firearms and ammunition. Mr. Bowles has defended Ms. Gutierrez’s qualifications for the job, saying that she was dedicated to ensuring safety on set. Previously lawyers for Ms. Gutierrez-Reed said that she had been hired to two positions on the film, “which made it extremely difficult to focus on her job as an armorer.”
Mr. Halls, Ms. Gutierrez-Reed and Sarah Zachry, the movie’s prop master, are all named as defendants in Ms. Mitchell’s lawsuit. Ms. Zachry and a lawyer for Mr. Halls did not immediately respond to requests for comment. Mr. Bowles said he had not yet reviewed the lawsuit.
Last week, Serge Svetnoy, the film’s gaffer, or chief lighting technician, filed a lawsuit accusing the movie’s producers, Mr. Baldwin and several other crew members of failing to follow appropriate firearm safety protocols that would have prevented the fatal shooting. Mr. Svetnoy said he was standing just six or seven feet away from Mr. Baldwin and said that he was injured by discharge materials from the gun and traumatized by seeing his friend die, trauma that had left him unable to work.