D was the 'tour manager' of 'Great White,' a band that performed at The Station, a nightclub located in Warwick, Rhode Island. D allegedly ignited pyrotechnic devices ('D.O.T. Class C' Fireworks - Classification 1.4) inside the Station as part of the band's performance. The ignition of such pyrotechnics would constitute a misdemeanor if D was not licensed to possess, control, or use the pyrotechnics under § 11-13-1. P alleges that the pyrotechnics started a fire inside The Station that proximately caused the deaths of one hundred people. In the capacity as tour manager, D planned, procured, and executed pyrotechnic special effects accompanying some of Great White's musical performances.

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