The notice claims negligence on the parts of Broward County Public Schools, Marjory Stoneman Douglas’ principal and its school resource officer.

“The failure of Broward County Public Schools, and of the principal and school resource officer to adequately protect students, and in particular our client, from life-threatening harm were unreasonable, callous and negligent,” Arreaza wrote. “Such action or inaction led to the personal injuries sustained by my client.”

Borges is currently unable to walk, has undergone several surgeries and remains hospitalized at Broward Health Medical Center. His medical bills are sure to top $1 million, Arreaza said.