In the complaint, the plaintiff's attorneys,Max B. Stern and Lynn Weissberg, argue thatHarvard neglected to install an alarm system inthe apartment occupied by the professor and hisfamily.

The complaint notes that alarm systems wereinstalled in the Faculty Row apartments occupiedby Jewett and North House Master J. WoodlandHastings '66, Magelsdorf professor of naturalsciences.

The University conducted an inspection ofHasting's and Jewett's apartments to determinewhether they should install alarms, according tothe suit. But no such inspection was ordered forthe family's apartment.

The security inspection of Jewett's housefollowed a break-in in 1987. As a result of theinspection, the University installed an alarmsystem in Jewett's apartment. Hastings' alarm wasinstalled in 1981.

Harvard, in its opposition to the amendedcomplaint, contended that it was merely a stalltactic by the plaintiff to shift the focus of thecase before the close of the discovery process.

Lawyers for the professor's daughter had arguedthat the University failed to secure theapartment's glass sliding door and that theplaintiff was not properly instructed how to lockand secure the door. But attorney Richard J.Riley, who is representing the University,contends that the shift was prompted because earlyevidence discounted these two key claims of theplaintiff.

In his response to the plaintiff's amendedcomplaint, Riley says that Jewett should not be adefendant in the case.

"The occurrence of a break-in in a differentresidence occupied by a high-profile target fouryears prior to the incident at issue affords nobasis for asserting a claim of negligence againstDean Jewett individually," Riley says.

Riley argues further that previous breakins and theinstallation of alarms are irrelevant because pastincidents were not 'sufficiently similar innature, location, or recency of occurrence."

In addition to the break-in at Jewett's, therewere two break-ins at Hastings'--in 1981 and 1982after his alarm had been installed.

In his deposition, Hastings testified thatduring the second break-in, "a man gained entry byphysically breaking the [sliding door] lock andphysically moving the door so that he could liftthe door up and over the slide bolt and opened thedoor and came into the house."

Hastings said he wasn't at home when thebreak-in occurred.

Attorneys for the plaintiff are arguing thatHastings' testimony shows the sliding doors werevulnerable to break-in.

"These units had sliding glass doors mounted insuch a way as to make them particularly prone tobreak-ins," says a recent filing of the plaintiffin the case.

The plaintiff's attorneys argue that theUniversity installed Hastings' and Jewett's alarmsbecause they are important figures on campus.