DOCKET NO. HHD-CV-16-6068298-S
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`GLENDALIZ RIVERA
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`V.
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`JAMES TOWNSEND, ET AL
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`SUPERIOR COURT
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`J.D. OF HARTFORD
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`AT HARTFORD
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`JULY 12, 2017
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`REQUEST LEAVE TO AMEND
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`Pursuant to Practice Book § 10-60, the plaintiff, GLENDALIZ RIVERA, hereby requests
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`leave to amend her compliant. This action arises out of a motor vehicle collision where the
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`plaintiff was rear-ended by a snow plow on February 10, 2015. The plaintiff recently returned to
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`treatment in March of 2017 for issues with her left knee. She had previously been diagnosed with a
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`knee contusion after her knee was jammed into the steering wheel of her vehicle. As a result of her
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`new treatment, her orthopedic doctor diagnosed her with chondromalacia patellae, left knee
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`patellofemoral syndrome, left knee pain, and lower left leg joint pain, which he relates to the
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`February 10, 2015 collision. As a result, the plaintiff seeks to amend count five of the operative
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`complaint which sets forth her injuries to include the newly diagnosed conditions. No depositions
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`have been taken yet in the present action. Accordingly, defense counsel will have an opportunity to
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`question the plaintiff regarding this new diagnosis and treatment.
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`PLAINTIFF,
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`BY
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`/s/435320
`Sarah N. Mather, Esq.
`Dressler Strickland
`84 Cedar Street
`Hartford, CT 06106
`(860) 247-1122
`Juris No. 106079
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`GLENDALIZ RIVERA
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`V.
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`JAMES TOWNSEND, ET AL
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`SUPERIOR COURT
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`J.D. OF HARTFORD
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`AT HARTFORD
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`JULY 12, 2017
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`REQUEST LEAVE TO AMEND
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`Pursuant to Practice Book § 10-60, the plaintiff, GLENDALIZ RIVERA, hereby requests
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`leave to amend her compliant. This action arises out of a motor vehicle collision where the
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`plaintiff was rear-ended by a snow plow on February 10, 2015. The plaintiff recently returned to
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`treatment in March of 2017 for issues with her left knee. She had previously been diagnosed with a
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`knee contusion after her knee was jammed into the steering wheel of her vehicle. As a result of her
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`new treatment, her orthopedic doctor diagnosed her with chondromalacia patellae, left knee
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`patellofemoral syndrome, left knee pain, and lower left leg joint pain, which he relates to the
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`February 10, 2015 collision. As a result, the plaintiff seeks to amend count five of the operative
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`complaint which sets forth her injuries to include the newly diagnosed conditions. No depositions
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`have been taken yet in the present action. Accordingly, defense counsel will have an opportunity to
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`question the plaintiff regarding this new diagnosis and treatment.
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`PLAINTIFF,
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`BY
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`/s/435320
`Sarah N. Mather, Esq.
`Dressler Strickland
`84 Cedar Street
`Hartford, CT 06106
`(860) 247-1122
`Juris No. 106079
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`CERTIFICATION
`I certify that a copy of the above was or will immediately be mailed or delivered
`electronically or non-electronically on July 12, 2017 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.
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`Grayson Colt Holmes, Esq.
`Ouellette Deganis Gallagher &
`Grippe, LLC
`143 Main Street
`Cheshire CT 06410
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`Bridget McCormack Ciarlo, Esq.
`Montstream & May, LLP
`P.O. Box 1087
`Glastonbury CT 06033
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`Phone: 203-272-1157
`Fax: 203-250-1835
`*accepts electronic service
`info@odglaw.com
`gholmes@odglaw.com
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`Phone: 860-659-1341
`Fax: 860-657-8519
`*accepts electronic service
`bciarlo@montmaylaw.com
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`for Benjamin Abrahams
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`For James Townsend
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`/s/435320
`Sarah N. Mather, Esq.
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`DOCKET NO.: HHD-CV-16-6068298-S
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`GLENDALIZ RIVERA
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`V.
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`JAMES TOWNSEND, ET AL
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`SUPERIOR COURT
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` J.D. OF HARTFORD
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`AT HARTFORD
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` JULY 12, 2017
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`AMENDED COMPLAINT
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`1.
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`On or about February 10, 2015, at approximately 4:50 p.m., the plaintiff
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`Glendaliz Rivera was operating her motor vehicle in a generally easterly direction on Burnside
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`Avenue, near its intersection with Mary Street, both public highways, in East Hartford,
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`Connecticut.
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`2.
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`On said date, and at said time and place, the defendant James Townsend was
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`operating a motor vehicle with a snow plow attached to the front, owned by the defendant
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`Benjamin Abrahams, as agent, servant, or employee and/or within the meaning of §52-183 of the
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`General Statutes, in a generally easterly direction on said Burnside Avenue and directly to the
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`rear of the motor vehicle being operated by the plaintiff.
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`3.
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`On said date, and at said time and place, as a result of the negligence and
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`carelessness of the defendant James Townsend, as hereinafter set forth, the defendant’s motor
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`vehicle collided with the rear of the motor vehicle operated by the plaintiff, causing the plaintiff
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`to suffer injuries, damages, and losses as more particularly set forth hereinafter.
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`4.
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`The injuries, damages, and losses sustained by the plaintiff were caused by the
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`negligence and carelessness of the defendant, acting as aforesaid, in one or more of the following
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`ways:
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`a.
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`b.
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`c.
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`d.
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`e.
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`f.
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`g.
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`IN THAT he was following the plaintiff’s vehicle more closely than was
`reasonable and prudent, having regard for the speed of such vehicles, the
`amount of traffic, the condition of the highway, and weather conditions, in
`violation of Section 14-240 of the General Statutes;
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`IN THAT he failed to have said motor vehicle under reasonable and
`proper control;
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`IN THAT he was inattentive and/or failed to keep a reasonable and proper
`lookout;
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`IN THAT he failed to apply the brakes in time to avoid the collision;
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`IN THAT he operated said motor vehicle at an excessive rate of speed for
`the circumstances and conditions then and there prevailing;
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`IN THAT he failed to pay attention to the traffic ahead of him; or
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`IN THAT he operated his motor vehicle at a rate of speed greater than was
`reasonable having regard to the width, traffic and use of the highway, the
`intersection of streets and weather conditions, in violation of §14-218a of
`the General Statutes.
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`5.
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`As a result of the negligence and carelessness as aforesaid of the defendant, the
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`plaintiff sustained loss of consciousness, blurred vision and light headedness associated with
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`posttraumatic headaches, cervical, thoracic, and lumbar sprain/strain with associated muscle
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`spasm and segmental joint dysfunction, left knee and elbow contusions, chondromalacia patellae,
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`left knee patellofemoral syndrome, left knee pain, lower left leg joint pain, and such other injuries
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`as are yet unknown.
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`6.
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`From all the injuries or effects thereof, the plaintiff has suffered and will continue
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`to suffer from pain, limitation of motion, and restriction of certain of activities.
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`7.
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`8.
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`The plaintiff’s injuries, or some of them, will be permanent in nature.
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`As a further result of the collision, the plaintiff incurred expenses for medical care
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`and attention, and will require future medical treatment and expenditures.
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`WHEREFORE, THE PLAINTIFF CLAIMS:
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`A.
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`MONETARY DAMAGES
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`Dated at Hartford, Connecticut, on 12th day of July, 2017.
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`PLAINTIFF
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`/s/435320
`Sarah N. Mather, Esq.
`Dressler Strickland, LLC
`84 Cedar Street
`Hartford, CT 06106
`(860) 247-1122
`Juris #: 106079
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`STATEMENT OF AMOUNT IN DEMAND
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`The amount in demand is more than $15,000.00 exclusive of interest and costs.
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`/s/435320
`Sarah N. Mather, Esq.
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