ORDER 443517
`DOCKET NO: FBTCV256142373S SUPERIOR COURT
`DESOUZA, SERGIO ALVES JUDICIAL DISTRICT OF BRIDGEPORT
`V. AT BRIDGEPORT
`VALLEJO, BONILLA EtAl
`5/5/2025
`ORDER
`ORDER REGARDING:
`04/17/2025 108.00 MOTION TO CITE ADDITIONAL PARTY
`The foregoing, having been considered by the Court, is hereby:
`ORDER: GRANTED
`It is ordered that on or before 6/5/2025 the complaint be amended to state facts showing the interests of
`CN1 COMMUNICATIONS LLC and SECOND STREET LEASING LLC in this action and summon
`CN1 COMMUNICATIONS LLC and SECOND STREET LEASING LLC to appear as defendants in
`this action on or before the second day following 6/17/2025, by causing some proper officer to serve on
`the defendants in the manner prescribed by lawa true and attested copy of this order, a true and attested
`or certified copy of the complaint in this action as amended, and a Summons Civil Form JD-CV-1 and
`due return make.
`Judicial Notice (JDNO) was sent regarding this order.
`443517
`Judge: CHARLES P REED
`Processed by: Andrew Laroche
`This document may be signed or verified electronically and has the same validity and status as a document with a physical
`(pen-to-paper) signature. For more information, see Section LE. of the State ofConnecticut Superior Court E-Services
`Procedures andTechnical Standards (https://jud.ct. gov/external/super/E-Services/e-standards.pdf), section 51-193c of the
`Connecticut General Statutes and Connecticut Practice Book Section 4-4.
`FBTCV2561423738 5/5/2025 Page 1of 1
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`SUMMONS- CIVIL For information on STATE OF CONNECTICUT
`JD-CV-1 Rev. 1-20 ADA accommodations f
`C.G.S. §§ 51-346, 51-347, 51-349, 51-350, 52-45a, 52-48, 52-259: contact a court clerk or SUPERIOR COURT \
`P.B. §§ 3-1 through 3-21, 8-1, 10-13 www.jud.ct.govgo to: www.jud.ct.gov/ADA.
`Instructions are on page 2.
`L_] Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,500.
`Select if amount, legal interest, or property in demand, not including interest and costs, is $2,500 or MORE.
`CJ Select if claiming other relief in addition to, or in place of, money or damages.
`TO: Any proper officer
`By authority of the State of Connecticut, you are hereby commanded to make due.and legal service of this summons and attached complaint.
`Address of court clerk (Number, street, town and zip code) Telephone number ofclerk Return Date (Must be a Tuesday)
`1061 Main Street, Bridgeport, CT 06604 (203 ) 579 —6527 6/17/2025
`Judicial District GA. At (City/Town) : Case type code (See list on page 2)
`(_] Housing Session [_] Number: Bridgeport . Major: V Minor: 01
`For the plaintiff(s) enter the appearance of:
`Name and address of attorney, law firm or plaintiff if self-represented (Number, street, town and zip code) Juris number (if attorney or law firm)
`The Flood Law Firm, LLC, 190 Washington Street, Middletown, CT 06457 433718
`Telephone number Signature of plaintiff (if self-represented)
`(860 ) 346 —2695
`The attorney or law firm appearing for the plaintiff, or the plaintiff if E-mail address for delivery of papers under Section 10-13 of the
`Connecticut Practice Book (if agreed)
`legaldocs@thefloodlawfirm.com
`self-represented, agrees to accept papers (service) electronically
`in this case under Section 10-13 of the Connecticut Practice Book. Yes L] No
`Parties Name (Last, First, Middle Initial) and address of each party (Number; street; P.O. Box; town; state; zip; country, ifnot USA)
`First Name: DeSouza, Sergio Alves P01
`plaintiff | Address: 27 Dogwood Lane, Monroe, CT 06468
`Additional | Name: P-02plaintiff Address:
`First Name: CN1 Communications LLC, 315 Riggs Street, Building B, Suite 6, Oxford, CT 06478 D-01
`defendant | Address: Agent: Brian Rodgers, 315 Riggs Street, Building B, Suite 6, Oxford, CT 06478
`Additional | Name: Second Street Leasing, LLC, 315 Riggs Street, Building B, Suite 7, Oxford, CT 06478 p-02
`defendant | Address:_ Agent: Matthew Zaloumis, 315 Riggs Street, Building A, Suite 6, Oxford, CT 06478
`Additional | Name: D-03defendant | Address:
`Additional | Name: D-04
`defendant | Address: .
`Total number of plaintiffs: 1 Total number of defendants:2 [_] Form JD-CV-2 attached for additional parties
`Notice to each defendant
`1. You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you.
`2. To receive further notices, you or your attorney must file an Appearance (form JD-CL-12) with the clerk atthe address above. Generally,
`it must be filed on or before the second dayafter the Return Date. The Return Date is not a hearing date. You do not have to come to
`court on the Return Date unless you receive a separate notice telling you to appear.
`3. Ifyou or your attorney do not file an Appearance on time, a default judgment may be entered against you. You can get an Appearance
`form at the court address above, or on-line at https://jud.ct.aov/webforms/.
`4. If you believe that you have insurance that may cover the claim being made against you in this lawsuit, you should immediately contact
`your insurance representative. Other actions you may take are described in the Connecticut Practice Book, which may be found ina
`superior court law library or on-line at httpe:/Avww.jue-tt.gov/pb.htm
`5. If you have questions about the summ nt, you should talk to an attorney.
`The court staff is not allowed to giy vice on legal matters.
`Date Signed (Sign and select pr enBox) Commissioner of Superior Court | Name of person signing
`5/7/2025 CT] Clerk | Brian M. Flood, Esquire
`If this summons is signed by a Clerk: ' For Court Use Only
`a. The signing has been done so that the plajatiff(s) will not be denied access to the courts. File Date
`b. It is the responsibility of the plaintiff(s) to-énsure that service is made in the manner provided by law.
`c. The court staff is not permitted to give any legal advice in connection with any lawsuit.
`d. The Clerk signing this summons at the request of the plaintiff(s) is not responsible in any way for any
`errors or omissions in the summons, any allegations contained in the complaint, or the service ofthe
`summons or complaint.
`I certify | have read and_| Signed (Self-represented plaintiff) Date Docket Number
`understand the above: FBT-CV-25-6142373-S
`intForm 1 Page 1of 2 ASAEEAE
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`DOCKET NO.: FBT-CV-25-6142373-S — : SUPERIOR COURT
`SERGIO ALVES DESOUZA : J.D. OF BRIDGEPORT
`V. : AT BRIDGEPORT
`BONILLA VALLEJO, ET AL : MAY 7, 2025
`AMENDED COMPLAINT
`FIRST COUNT: (Sergio Alves DeSouza v. Bonilla Vallejo —Negligence)
`l. On February 6, 2024, at approximately 8:14 a.m., the plaintiff, Sergio
`Alves DeSouza, was the operator of a motor vehicle that was traveling north on
`Wallace Street, a public street or highway in Bridgeport, Connecticut.
`2. At the same time and place, the defendant, Bonilla Vallejo, was the
`operator ofa motor vehicle that was traveling south on Wallace Street.
`3. At the same time and place, the motor vehicle operated by the
`defendant, Bonilla Vallejo, suddenly and without warning entered the northbound
`lane oftravel on Wallace Street and collided with the motor vehicle operated by the
`plaintiff, Sergio Alves DeSouza, thereby causing him to suffer the injuries and
`losses set forth below.
`4. The collision was caused by the negligence ofthe defendant, Bonilla
`Vallejo, in one or more ofthe following ways:
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`g)
`h)
`j)
`he failed to keep a reasonable and proper lookout
`for other vehicles on the road;
`he failed to turn or swerve so as to avoid the
`collision;
`he failed to apply the brakes in time to avoid the
`collision;
`he failed to sound the horn or give a timely
`warning of the impending collision;
`he failed to keep the vehicle under proper
`control;
`he was inattentive in the operation of the vehicle;
`he operated the vehicle at a rate of speed greater
`than was reasonable, having due regard to the
`width, traffic, and use of the highway, road, the
`intersection of streets and/or weather conditions,
`in violation of § 14-218a of the Connecticut
`General Statutes;
`he operated a vehicle so as to obstruct or impede
`traffic, in violation of § 14-240(c) of the
`Connecticut General Statutes;
`he failed to drive the vehicle to the right side of
`the roadway, in violation of § 14-230 of the
`Connecticut General Statutes;
`he failed to give the motor vehicle operated by
`the plaintiff at least one-half of the main traveled
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`portion of the road, in violation of § 14-231 of
`the Connecticut General Statutes;
`k) he drove the vehicle on the left side of the
`roadway when it was not safe to do so, in
`violation of § 14-235 ofthe Connecticut General
`Statutes; and/or
`l) he turned the vehicle left upon the roadway when
`it was unsafe to do so, in violation of § 14-242(a)
`of the Connecticut General Statutes.
`5. As a result of the collision, the plaintiff, Sergio Alves DeSouza,
`suffered the following injuries, some or all of which may be permanent in nature:
`a) headaches;
`b) cervical segmental dysfunction;
`c) cervical strain/sprain;
`d) neck pain;
`e) bilateral shoulder pain;
`f) bilateral arm pain;
`g) left flank pain;
`h) thoracic segmental dysfunction;
`i) thoracic strain/sprain;
`j) lumbar segmental dysfunction;
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`k) lumbar sprain/strain;
`1) back pain; and
`m) pain and suffering, both mental and physical.
`6. As a further result of the collision, the plaintiff, Sergio Alves
`DeSouza, was forced to incur expenses for medical care and treatment and will
`likely be forced to incur additional expenses for medical care and treatment in the
`future.
`7. As a further result of the collision, the plaintiff, Sergio Alves
`DeSouza, was unable and remains unable to participate in and enjoy his usual
`activities.
`SECOND COUNT: (Sergio Alves DeSouza v. Zaloumis Contracting Service
`Inc.— Vicarious Liability)
`1-7. Paragraphs 1through 7 of the First Count are hereby incorporated and
`made corresponding paragraphs of this Second Count as if fully set forth herein.
`8. At all times mentioned herein, the defendant, Zaloumis Contracting
`Service Inc., was and is a Connecticut corporation with its business address located
`at 315 Riggs Street, Building A-Suite 6 in Oxford, Connecticut.
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`9. At all times mentioned herein, the defendant, Zaloumis Contracting
`Service Inc., owned the motor vehicle operated by Bonilla Vallejo.
`10. At all times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle with the permission of the defendant, Zaloumis Contracting Service Inc.
`11. Atall times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle as the agent, servant and/or employee of the defendant, Zaloumis Contracting
`Service Inc.
`12. Atall times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle within the course and scope of his employment with the defendant, Zaloumis
`Contracting Service Inc.
`13. At all times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle as the agent of the defendant, Zaloumis Contracting Service Inc., pursuant to
`Connecticut General Statutes § 52-183.
`THIRD COUNT: (Sergio Alves DeSouza v. CN1 Communications LLC —
`Vicarious Liability)
`1-7. Paragraphs 1through 7 of the First Count are hereby incorporated and
`made corresponding paragraphs of this Third Count as iffully set forth herein.
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`8. At all times mentioned herein, the defendant, CN1 Communications
`LLC, was and is a Connecticut limited liability company with its business address
`located at 315 Riggs Street, Building B-Suite 6 in Oxford, Connecticut.
`9. At all times mentioned herein, the defendant, CN1 Communications
`LLC, owned the motor vehicle operated byBonilla Vallejo.
`10. At all times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle with the permission of the defendant, CN1 Communications LLC
`11. Atall times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle as the agent, servant and/or employee of the defendant, CN1 Communications
`LLC
`12. At all times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle within the course and scope of his employment with the defendant, CN1
`Communications LLC
`13. At all times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle as the agent of the defendant, CN] Communications LLC, pursuant to
`Connecticut General Statutes § 52-183.
`FOURTH COUNT: (Sergio Alves DeSouza v. Second Street Leasing, LLC —
`Vicarious Liability)
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`1-7. Paragraphs | through 7 of the First Count are hereby incorporated and
`made corresponding paragraphs of this Fourth Count as if fully set forth herein.
`8. At all times mentioned herein, the defendant, Second Street Leasing,
`LLC, was and is a Connecticut limited liability company with its business address
`located at 315 Riggs Street, Building B-Suite 7, in Oxford, Connecticut.
`9. At all times mentioned herein, the defendant, Second Street Leasing,
`LLC, owned the motor vehicle operated by Bonilla Vallejo.
`10. At all times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle with the permission ofthe defendant, Second Street Leasing, LLC.
`11. Atall times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle as the agent, servant and/or employee ofthe defendant, Second Street Leasing,
`LLC.
`12. Atal times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle within the course and scope of his employment with the defendant, Second
`Street Leasing, LLC.
`13. Atall times mentioned herein, Bonilla Vallejo was operating the motor
`vehicle as the agent of the defendant, Second Street Leasing, LLC, pursuant to
`Connecticut General Statutes § 52-183.
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`WHEREFORE, the plaintiff claims:
`1. Monetary damages.
`THE PLAINTIFF,
`SERGIO ALVES DESOUZA
`Brian ML.Flo6d
`The Flood Law Firm, LLC
`190 Washington Street
`Middletown, CT 06457
`Phone: (860) 346-2695
`Juris # 433718
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`DOCKET NO.: FBT-CV-25-6142373-S —: SUPERIOR COURT
`SERGIO ALVES DESOUZA : J.D. OF BRIDGEPORT
`V. : AT BRIDGEPORT
`BONILLA VALLEJO, ET AL : MAY 7, 2025
`STATEMENT OF AMOUNT IN DEMAND
`The amount of money damages claimed is greater than Fifteen Thousand
`Dollars ($15,000.00), exclusive of interest and costs.
`THE PLAINTIFF,
`SERGIO ALVES DESOUZA
`Bridn M. Flgod
`The Flood/Law Firm, LLC
`Middletown, CT 06457
`Phone: (860) 346-2695
`Juris #433718
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`STATE MARSHAL RETURN
`STATE OF CONNECTICUT
`) ss: Oxford
`COUNTY OF NEW HAVEN
`May 16, 2025
`Then and there by virtue hereof and at the special direction of the plaintiff 's Attorney on
`May 16, 2025, I made due and legal service by leaving a true and attested copy of the within Order
`Regarding Motion to Cite Additional Party, Amended Writ, Summons, Complaint and Statement of
`Amount in Demand with my doings endorsed thereon at the usual place of abode of BRIAN RODGERS,
`AGENT FOR SERVICE for the within named defendant, CN1 COMMUNICATIONS LLC., who is duly
`authorized to accept service at 315 Riggs Street, Building B, Suite 6, Oxford, СT 06478.
`And afterwards on May 16, 2025, I made due and legal service by leaving a true and attested copy of the
`within Order Regarding Motion to Cite Additional Party, Amended Writ, Summons, Complaint and Statement
`of Amount in Demand with my doings endorsed thereon at the usual place of abode of MATTHEW
`ZALOUMIS, AGENT FOR SERVICE for the within named defendant, SECOND STREET LEASING, LLC..
`who is duly authorized to accept service at 6 Bonnie Lane, Oxford, CСТ.
`The within and foregoing is the original, Order Regarding Motion to Cite Additional Party, Amended
`Writ, Summons, Complaint and Statement of Amount in Demand with my doings endorsed hereon.
`ATTEST:
`Phoma
`THOMAS GAHAN STATE MARSHAL
`Fees:
`Basic: $ 100.00
`Travel: 32.00
`Copies: 22.00
`End 1.50
`Total: $ 155.50
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