BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD, CONNECTICUT
`
`C6460
`
`JURS NUMBER
`22801
`
`(203) 783-1200
`
`DOCKET NO. FST CV 25 6077732S SUPERIOR COURT
`
`BERKLEYNET : J.D. STAMFORD/NORWALK
`VS. : AT STAMFORD
`TOWN OF WESTPORT ; JANUARY 13, 2026
`
`MOTION TO STRIKE
`
`Pursuant to Section 10-39, et seq., of the Connecticut Practice Book, the
`Defendant Town of Westport hereby moves to strike the Plaintiff Berkleynet's Complaint
`dated November 13, 2025 (“Complaint”).
`
`As more fully set out in the Defendant's Memorandum of Law in Support of this
`Motion to Strike, which is filed herewith, the Complaint sounding in negligence should
`be stricken because General Statutes §13a-149, the highway defect statute, is the
`Plaintiff's exclusive remedy against the Town of Westport and precludes an action
`against a municipality for damages resulting from a highway defect through General
`Statutes §52-557n.
`
`Furthermore, even if the Court does not find that §13a-149 is the Plaintiff's
`exclusive remedy, the Complaint should still be stricken because of the protection
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`afforded by governmental immunity, pursuant to §52-557n.
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`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BRCAL STREET
`MILFORD, CONNECTICLT
`06460
`
`JURIS NUMBER
`
`22801
`
`(203) 783-1200
`
`WHEREFORE, it is respectfully requested that the Court strike the Plaintiff's
`
`Complaint.
`
`THE DEFENDANT,
`TOWN OF WESTPORT
`
`BY \. .
`Jonathan D{-Berchem
`Berchem Moses PC
`75 Broad Street
`Milford, CT 06460
`Tel. (203) 783-1200
`Juris # 022801
`
`CERTIFICATION
`
`This is to certify that a copy of the foregoing was, or will immediately be mailed or
`delivered electronically, or non-electronically, on the date hereon to all counsel and self-
`represented parties of record and that written consent for electronic delivery was
`received from all counsel and self-represented parties of record who were or will
`
`immediately be electronically served as follows:
`
`Gary J. Greene, Esquire
`
`Greene Law
`
`1055 Farmington Avenue - Suite C
`Farmington, CT 06032
`service@greenelawpc.com
`
`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSEL QRS AT LAW
`75 BROAD STREET
`MILFORD, CONNFCTICUT
`06460
`JURIS NUMBER
`22801
`
`(703} 783-12C0
`
`DOCKET NO. FST CV 256077732 S SUPERIOR COURT
`
`BERKLEYNET : J.D. STAMFORD/NORWALK
`VS. : AT STAMFORD
`TOWN OF WESTPORT : JANUARY 13, 2026
`
`MOTION TO STRIKE
`
`Pursuant to Section 10-39, et seq., and § 10-42 of the Connecticut Practice
`Book, the Defendant Town of Westport hereby submits this Memorandum of Law in
`Support of its Motion to Strike the Plaintiff Complaint dated November 13, 2025.
`
`. FACTS AND PROCEDURAL BACKGROUND
`
`The Plaintiff instituted the present action against the Defendant by way of writ,
`summons and complaint bearing a return date of December 23, 2025.
`
`The Plaintiff alleges that on or about December 5, 2023, Bertha Matis ("Ms.
`Matis”), an employee of the Westport Public Library, allegedly slipped and fell on
`exterior stairs located outside of the library property. Complaint, | 2. The Plaintiff claims
`that Ms. Matis sustained a knee injury as a result of this fall. /d. {] 3. Following the
`incident, Ms. Matis made a claim for workers’ compensation benefits under the policy
`issued by BerkleyNet to the Westport Public Library, and BerkleyNet alleges it paid
`
`benefits totaling $83,029.61. /d. §] 8.
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`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD, CONNECTICJT
`06460
`
`JURIS NUNMBER
`22801
`
`(203) /831200
`
`The Plaintiff alleges, upon information and belief, that the exterior stairs where the
`incident occurred are owned and maintained by the Town of Westport. /d. {1 5. Based on
`that alleged ownership and control, BerkleyNet claims that the Town owed a duty to the
`library and its employees to maintain the exterior stairs in a safe condition and in
`compliance with applicable building codes. /d. [ 6.
`
`The complaint asserts a common-law negligence claim against the Town, alleging
`generally that the Town failed to keep the exterior stairs in good repair and working
`order, failed to ensure the stairs conformed to building code, failed to keep the stairs
`free of tripping hazards, and failed to ensure the stairs were safe for public use. /d. { 7.
`The complaint does not identify a specific defect, code violation, or hazardous condition,
`nor does it allege how long any purported condition existed prior to the fall. Similarly, the
`Complaint does not point to any statutory reliance for bringing claims against the
`municipal Defendant.
`
`BerkleyNet brings this action as a subrogation claim, seeking reimbursement of the
`workers’ compensation benefits it allegedly paid as a result of the incident described
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`above.
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`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD, CONNECTICUT
`06460
`
`JURIS NUMBER
`22801
`
`(203) 783-1200
`
`Il. LEGAL STANDARD
`
`The purpose of a motion to strike is to contest the legal sufficiency of the
`allegations of a complaint to state a claim upon which relief may be granted. Practice
`Book §10-39; Ameriquest Morg. Co. v. Lax., 113 Conn. App. 646, 650 (2009). In ruling
`on a motion to strike, the court is limited to the facts alleged in the complaint, which it
`must construe in the manner most favorable to the plaintiff. See, e.g., Fort Trumbull
`Conservancy, LLC v. Alves, 262 Conn. 480, 498 (2003). While a motion to strike admits
`all facts well-pleaded, it does not admit legal conclusions or the truth or accuracy of
`opinions stated in the complaint. Minachos v. CBS, Inc., 196 Conn. 901, 108 (1985),
`O&G Industries, Inc. v. Travelers Prop. Cas. Corp., 2001 WL 11787089, at *3 (Conn.
`Super. Ct. Sept. 7, 2001).
`
`Conclusory statements absent supportive facts are insufficient to survive a
`motion to strike. Heinrichs v. Danbury Ins. Co., 2008 WL 4210587, at *3 (Conn. Super.
`Ct. Aug. 25, 2008): Melfi v. Danbury, 70 Conn. App. 679, 686, cert. denied, 261 Conn.
`922 (2002). A motion to strike is properly granted when a complaint fails to plead all of
`the facts essential to proving a cause of action. See Robert S. Weiss Assoc. v.
`Wiederlight, 208 Conn. 525, 536-37 (1988). Brown v. Branford, 12 Conn.App. 1086, 111
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`n. 3, 529 A.2d 743 (1987). Where it is apparent from the face of the complaint that the
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`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD, CONNECTICUT
`06460
`
`JURIS NUMBER
`22801
`
`(203) 783-1200
`
`municipality was engaging in a governmental function while performing the acts and
`omission complained of by the plaintiff, the defendant...may attack the legal sufficiency
`of the complaint through a motion to strike.” Internal quotation marks omitted. Coe v.
`Board of Education, 301 Conn. 112, 116 at n. 4 (2011).
`
`. ARGUMENT
`
`A. The Plaintiff’s Claims Must Be Stricken Because General Statutes §
`13a-149 Is the Exclusive Remedy and the Complaint Fails to Plead
`the Required Statutory Elements.
`
`It is well settled that General Statutes §13a-149, commonly referred to as the
`highway defect statute, is the exclusive remedy for a claim based upon a highway
`defect. Ferreira v. Pringle, 255 Conn. 330, 341, 766 A.2d 400,408(2001).
`
`Section 13a-149 provides:
`
`Any person injured in person or property by means of a defective road or bridge
`may recover damages from the party bound to keep it in repair. No action for any
`such injury sustained on or after October 1, 1982, shall be brought except within
`two years from the date of such injury. No action for any such injury shall be
`maintained against any town, city, corporation or borough, unless written notice
`of such injury and a general description of the same, and of the cause thereof
`and of the time and place of its occurrence, shall, within ninety days thereafter be
`given to a selectman or the clerk of such town, or the clerk of such city or
`borough, or to the secretary or treasurer of such corporation. If the injury has
`been caused by a structure legally placed on such road by a railroad company, it, ‘
`and not the party bound to keep the road in repair, shall be liable therefore. No
`notice given under the provisions of this section shall be held invalid or
`insufficient by reason of an inaccuracy in describing the injury or in stating the
`time, place or cause of its occurrence, if it appears that there was no intention to
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`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD, CONNECTICLT
`06460
`
`JURS NUMBER
`22801
`
`(20%) 783-1200
`
`mislead or that such town, city, corporation or borough was not in fact misled
`thereby.
`
`To prove a breach of statutory duty under the Highway Defect Statute, the
`Plaintiff must prove: (1) that the highway was defective; (2) that the Town actually knew
`of the particular defect or that, in the exercise of its supervision of highways in the
`Town, it should have known of that defect; (3) that the Town, having actual or
`constructive knowledge of this defect, failed to remedy it having had a reasonable time
`under all the circumstances to do so; and (4) that the defect must have been the sole
`proximate cause of the injuries and damages claimed. Ormsby v. Frankel, 255 Conn.
`670, 675-76 (2001).
`
`A highway defect can be any object or condition affecting a roadway that would
`obstruct or hinder the use of the road for the purpose of traveling thereon. Sanzone v.
`Bd. of Police Comm’rs of City of Bridgeport, 219 Conn. 179, 201, 592 A.2d 912, 924
`1991). “Furthermore, a highway is defective within the meaning of §13a-149 when it is
`not reasonably safe for public travel, and the term public travel refers to the normal or
`reasonably anticipated uses that the public makes of a highway in the ordinary course
`of travel." Burton v. City of New Britain, Docket No. CV186048265, 2019 LX 13125, at
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`*3 (Super. Dec. 11, 2019).
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`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD, CCNNECTICLT
`06460
`
`JURIS NUMRER
`22801
`
`(203) 783-1200
`
`Connecticut's courts have interpreted the definition of “road or bridge” in §13a-
`149 to include sidewalks and public walkways. ‘The word road or highway as used in
`the highway defect statute has usually been construed to include sidewalks,. The term
`sidewalk is meant to apply to those areas that the public uses for travel... Furthermore
`the highway is defective within the meaning of § 13a-149 when it is not reasonably safe
`for public travel, and the term public travel refers to the normal and anticipated uses that
`the public makes of a highway in the ordinary course of travel. “Novicki, 47 Conn. App.
`at 740, 709 A.2d at 5. In fact, in Novicki v. New Haven, our Appellate Court found that a
`public walkway leading from a city street to a public school to be a “road or bridge for
`purposes of the highway defect statute.” /d. In making that finding, the court reasoned:
`“Since the walkway on which the plaintiff was injured was on public property and led
`from a city street to a public school, it was reasonably anticipated that the public would
`make use of it.” (emphasis added) /d.
`
`Similarly, in Kelly v. City of New Britain, Docket No. CV020518091, 2004 Conn.
`Super. LEXIS 3590 (Super. Dec. 10, 2004), the court found a plaintiff alleging he
`slipped and fell on an exterior stairway of the city dump's office building onto a walkway
`constituted a claim under § 13a-149. The court stated: “[W]alkways and sidewalks that
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`lead to public buildings do come within the ambit of § 13a-149." /d. at *3. '
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`4925-9308-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`M LFORDE, CONNECTICU™
`
`06460
`
`JURIS NUMBER
`2280
`
`(2033 783-1200
`
`Likewise, in Escoriza v. Town of Rocky Hill, Docket No. : HHD CV-25-6201804-
`S, 2025 Conn. Super. LEXIS 3540, at *7-8 (Super. Dec. 22, 2025), the plaintiff
`“sustained injuries on a publicly owned and maintained sidewalk adjacent to the
`Community Center, a public building, while attending an activity that was open to the
`public. It was reasonable to expect members of the public, like the plaintiff, to use the
`sidewalk to access the Community Center via the sidewalk connected to the parking lot.
`Therefore; the sidewalk at issue is a road within the meaning of § 13a-149."
`
`Any party who is injured while on a roadway or sidewalk negligently maintained
`by a municipality is afforded the right to bring a cause of action against that municipality
`pursuant to §13a-149. Although plaintiff has not specifically referred to § 13a-149 in her
`Complaint, the underlying facts are similar to those in the above-mentioned cases in
`that the Plaintiff fell down a set of stairs on the exterior of the public library, an area
`which the public would be reasonably anticipated to travel on and make use of.
`Therefore, this factual scenario comes directly within the purview of the highway defect
`statute.
`
`Accordingly, § 13a-149 is the proper and exclusive remedy for the Plaintiff's
`claims, and because the Plaintiff has neither pleaded liability under the highway defect
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`statute nor alleged any of the statute’s mandatory elements, the Complaint should be
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`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD. CONMMECTICUT
`06460
`
`JURIS NUMBER
`
`228071
`
`(203) 783-1200
`
`stricken. The Complaint does not reference § 13a-149 at all and fails to allege, inter alia,
`that the Town had actual or constructive notice of the alleged defect, that the Plaintiff
`complied with the statutory requirement to provide timely written notice of the claim to
`the Stratford Town Clerk, or that the alleged defect was the sole proximate cause of the
`Plaintiff's injuries. In the absence of these essential allegations, the Plaintiff has failed to
`state a legally cognizable claim, and the Complaint is legally insufficient as a matter of
`law.
`B. To the Extent the Complaint Is Construed Under General Statutes §
`52-557n, the Claims Must Be Stricken Because the Defendant Is
`Entitled to Governmental Immunity.
`Assuming, arguendo, that the Court determines that the exclusivity provisions of
`§13a-149 do not bar plaintiffs claim, the Complaint should still be stricken as plaintiffs
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`claim is barred by governmental immunity.
`
`i. The allegations of the Plaintiff's Complaint implicate
`discretionary governmental functions.
`
`As the facts have been pleaded, they allege discretionary functions entitling the
`Town and its employees to government immunity. “Section 52-557n (a) (1) provides that
`'[e]xcept as otherwise provided by law, a political subdivision of the state shall be liable i
`for damages to person or property caused by: (A) The negligent acts or omissions of
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`such political subdivision or any employee, officer or agent thereof acting within the
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`BERCHEM MOSES PC
`COUNSELORS A™ _AW
`75 BROAD STREET
`MILFORD, CONNECTICUT
`06460
`
`JURIS NUMBER
`22801
`
`(203) 783-1200
`
`scope of his employment or official duties . . . . Section 52-557n (a) (2) (B) extends,
`however, the same discretionary act immunity that applies to municipal officials to the
`municipalities themselves by providing that they will not be liable for damages caused
`by 'negligent acts or omissions which require the exercise of judgment or discretion as
`an official function of the authority expressly or impliedly granted by law." Hohorst v.
`Town of Easton, Docket No. FBT CV19 6088107 S, 2024 LX 16033, at *9 (Super. May
`9, 2024).
`"Municipal officials are immunized from liability for negligence arising out of their
`discretionary acts in part because of the danger that a more expansive exposure
`to liability would cramp the exercise of official discretion beyond the limits
`desirable in our society. . . . Discretionary act immunity reflects a value judgment
`that—despite injury to a member of the public—the broader interest in having
`government officers and employees free to exercise judgment and discretion in
`their official functions, unhampered by fear of second-guessing and retaliatory
`lawsuits, outweighs the benefits to be had from imposing liability for that injury.
`Hohorst v. Town of Easton, Docket No. FBT CV19 6088107 S, 2024 LX 16033,
`at *9 (Super. May 9, 2024) citing Northrup v. Witkowski, 332 Conn. 158, 167-
`168, 210 A.3d 29, 36, 2019 Conn. LEXIS 183, *15-17, 2019 WL 2720605.
`Borelli observed that for purposes of determining whether a duty is discretionary
`or ministerial, there is a difference between laws that impose general duties on officials
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`and those that mandate a particular response to specific conditions. “A ministerial act is
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`one which a person performs in a given state of facts, in a prescribed manner, in
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD, CONNECTICJT
`Q6460
`
`JURIS NUMBER
`
`22800
`
`(203) 783-12C00
`
`obedience to the mandate of legal authority, without regard to or the exercise of his own
`judgment [or discretion] upon the propriety of the act being done.’ ... In contrast, when
`an official has a general duty to perform a certain act, but there is no ‘city charter
`provision, ordinance, regulation, rule, policy, or any other directive [requiring the
`government official to act in a] prescribed manner,’ the duty is deemed discretionary.”
`Citations omitted. Borelli v. Renaldi, 336 Conn. 1, 20-12 (2020) citing Northrup v.
`Witkowski, 332 Conn. 158, 169-70, 210 A.3d 29 (2019). Borelli further recognized that
`“our courts consistently have held that to demonstrate the existence of a ministerial duty
`on the part of a municipality and its agents, a plaintiff ordinarily must point to some
`statute, city charter provision, ordinance, regulation, rule, policy, or other directive that,
`by its clear language, compels a municipal employee to act in a prescribed manner,
`without the exercise of judgment or discretion...” Emphasis added. Id.
`
`In the Plaintiffs Complaint, it alleges that the Town was negligent in that the
`Town failed to keep the exterior stairs in good repair and working order, failed to ensure
`the stairs conformed to building code, failed to keep the stairs free of tripping hazards,
`and failed to ensure the stairs were safe for public use. The complaint does not identify
`a specific defect, code violation, or hazardous condition, nor does it allege how long any
`
`purported condition existed prior to the fall, nor does it identify any charter or cited
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 3ROAD STREET
`MIl FORD, CONNZCTICUT
`
`06460
`
`JURIS NUMBER
`22801
`
`(203) 783-:200
`
`provision delegating a ministerial duty to the Town to maintain the stairs where the
`Plaintiff fell in a particular manner. Accordingly, there is no question that the acts or
`omissions complained of by the Plaintiff involve discretionary governmental functions
`thus availing the Town to government immunity.
`
`Maintenance of municipal property in a reasonably safe condition amounts to a
`governmental function. Kramer-Gidley v. MAB Rink Mgmt., LLC, 2018 WL 4054339, at
`*3 (Conn. Super.); Johnson v. City of New Haven, 2003 WL 21297348, at *3 (Conn.,
`Super.). "In general, the exercise of duties involving inspection, maintenance and repair
`of hazards are considered discretionary acts entitled to governmental immunity.”
`Grignano v. Milford, 106 Conn.App. 648, 656, 943 A.2d 507 (2008); see also Evon v.
`Andrews, 211 Conn. 501, 506-507 (1989).
`
`Based on these well-established legal principles, and the Plaintiff's failure to
`identify a ministerial duty, the Town was clearly engaged in discretionary acts and is
`thus entitled to government immunity.
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`ii. No exception to governmental immunity applies.
`
`The Plaintiff did not assert liability pertaining to General Statutes § 52-557n, and
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`likewise the Plaintiff did not assert that Ms. Matis, was an identifiable victim subject to
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`imminent harm. As such, the Town is entitled to government immunity should the Court
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`BERCH=M MOSES PC
`COLNSELORS AT LAW
`75 BROAD STRE=T
`MILFOR™, CONNECTICUT
`
`06460
`
`JURIS NUMBER
`22801
`
`(203) 783-1200
`
`find that the claim should have been plead pursuant to §52-557n. As pleaded, no
`exception to government immunity applies.
`
`The three exceptions to government immunity have been well-established: (1) where
`the circumstances make it apparent to the public officer or employee that his failure to
`act would be likely to subject an identifiable person to imminent harm (the so-called
`“identifiable person / imminent harm exception); (2) where a statute specifically provides
`for a cause of action against a municipality or municipal official for failure to enforce
`certain laws; and (3) where the alleged acts involve malice, wantonness or intent to
`injure, rather than negligence. Elliott v. City of Waterbury, 245 Conn. 385, 422, 715 A.2d
`27 (1998): Purzycki v. Town of Fairfield, 244 Conn. 101,108, 708 A.2d 937 (1998); Evon
`v. Andrews, 211 Conn. 501, 505, 559 A.2d 1131 (1989).
`
`The identifiable person subject to imminent harm exceptions has three requirements,
`all of which have not been pleaded by the Plaintiff, the requirements include: : (1) an
`imminent harm; (2) an identifiable victim; and (3) a public official to whom it is apparent
`that his or her conduct is likely to subject that victim to that harm.” Haynes v. City of
`Middletown, 314 Conn. 303, 312, 101 A.3d 249 (2014). “If the plaintiffs fail to establish
`any one of the three prongs, this failure will be fatal to their claim that they come within
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`the imminent harm exception.” Farrell v. West Hartford Public Schools Board of
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`4925-9306-2021, v. 2
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BRCAD STREET
`V¥ _FORD, CONNECTICUT
`06460
`
`JURIS NUMBER
`
`22801
`
`(2€3) 783-1200
`
`Education, Docket No. HHDCV176083415S, 2019 LX 65028, at *13 (Super. May 30,
`2019). Here the Plaintiff has failed to plead and prove any of the elements above.
`
`The Complaint does not allege the existence of an open and obvious defect or
`any condition that created an imminent risk of harm. Indeed, the Plaintiff does not
`identify the nature of the alleged defect at all. Without such allegations, the Complaint
`fails to plead an imminent harm or that it was apparent to any municipal official that the
`Plaintiff was likely to be subjected to such harm. Additionally, the Plaintiff does not
`allege facts demonstrating that she was a member of a narrowly defined, identifiable
`class of victims, as opposed to a member of the general public.
`
`Because the Plaintiff has failed to plead any of the required elements of an
`exception to governmental immunity, the Town is entitled to governmental immunity as
`a matter of law, and the claims must be stricken.
`
`IV. CONCLUSION
`For the foregoing reasons, the Defendant Town of Westport respectfully requests
`
`that the Court grant its Motion and Strike the Plaintiff's Complaint.
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`BERCHEM MOSES PC
`COUNSELORS AT LAW
`75 BROAD STREET
`MILFORD, CONNECTICUT
`06460
`
`JURIS NUMBER
`22801
`
`(203) 78317200
`
`THE DEFENDANT,
`TOWN OF WESTPORT
`
`BY ¢ )
`Jonath&n-D. Berchem
`Berchem Moses PC
`75 Broad Street
`Milford, CT 06460
`Tel. (203) 783-1200
`Juris # 022801
`
`CERTIFICATION
`
`This is to certify that a copy of the foregoing was, or will immediately be mailed or
`delivered electronically, or non-electronically, on the date hereon to all counsel and self-
`represented parties of record and that written consent for electronic delivery was
`received from all counsel and self-represented parties of record who were or will
`
`immediately be electronically served as follows:
`
`Gary J. Greene, Esquire
`Greene Law
`
`1055 Farmington Avenue - Suite C .
`Farmington, CT 06032 /\ "
`
`service@agreenelawpc.com
`
`Jonathan D. Berchem
`
`16
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