RETURN DATE: APRIL 11, 2023
`SUSAN BRAUN
`V.
`CSAA AFFINITY INSURANCE COMPANY
`SUPERIOR COURT
`J. D. OF HARTFORD
`AT HARTFORD
`MARCH 10, 2023
`FOMPLAINT
`COUNT nw- IINOERI^HRKn MOTH^T mVERAGF fS^san Brmm v. C<!AA Affinity
`Jnaurance Company)
`1. At all times pertinent hereto, the Plaintiff, Susan Braun, is a resident of the
`Town ofEnfield, Connecticut.
`2.
`The Defendant, CSAA Affinity Insurance Company, [hereinafter referred to
`as "Defendant"), is, and at all times relevant hereto was, an entity domiciled in the State
`of Arizona and authorized to do business in the State of Connecticut, including, but not
`limited to issuing policies of automobile insurance.
`3. On or about July 29, 2020, at approximately 9:52 p. m., the Plaintiff. Susan
`Braun. was the operator of a 2019 Nissan Rogue S motor vehicle driving eastbound on
`South Road in the Town of Enfield, Connecticut.
`4. On said date and at said time, Raymond Sanbria-Fontanez ("Sanbria-
`Fontanez"), was operating a 2006 Victory VX motorcycle traveling westbound on South
`Road in the Town ofEnfield, Connecticut.
`5. On said date at said time, Sanbria-Fontanez was operating the Victory VX
`motorcycle with the full permission and/or authority of the vehicle's owner, Lilian
`Deleon, under Connecticut General Statute § 52-182.
`6. On said date and at said time, as the Plaintiff was traveling on South Road
`96 OAK STREET . HARTFORD
`LAW OFFICES OF
`FAZZANO & TOMASIEWICZ
`CT
`06'1
`^'.
`"8'6^r3
`'1
`-7766'-FAX
`(860)
`560-7359 .
`JURIS
`No.
`4
`1
`4049
`
`SUSAN BRAUN
`V.
`CSAA AFFINITY INSURANCE COMPANY
`SUPERIOR COURT
`J. D. OF HARTFORD
`AT HARTFORD
`MARCH 10, 2023
`FOMPLAINT
`COUNT nw- IINOERI^HRKn MOTH^T mVERAGF fS^san Brmm v. C<!AA Affinity
`Jnaurance Company)
`1. At all times pertinent hereto, the Plaintiff, Susan Braun, is a resident of the
`Town ofEnfield, Connecticut.
`2.
`The Defendant, CSAA Affinity Insurance Company, [hereinafter referred to
`as "Defendant"), is, and at all times relevant hereto was, an entity domiciled in the State
`of Arizona and authorized to do business in the State of Connecticut, including, but not
`limited to issuing policies of automobile insurance.
`3. On or about July 29, 2020, at approximately 9:52 p. m., the Plaintiff. Susan
`Braun. was the operator of a 2019 Nissan Rogue S motor vehicle driving eastbound on
`South Road in the Town of Enfield, Connecticut.
`4. On said date and at said time, Raymond Sanbria-Fontanez ("Sanbria-
`Fontanez"), was operating a 2006 Victory VX motorcycle traveling westbound on South
`Road in the Town ofEnfield, Connecticut.
`5. On said date at said time, Sanbria-Fontanez was operating the Victory VX
`motorcycle with the full permission and/or authority of the vehicle's owner, Lilian
`Deleon, under Connecticut General Statute § 52-182.
`6. On said date and at said time, as the Plaintiff was traveling on South Road
`96 OAK STREET . HARTFORD
`LAW OFFICES OF
`FAZZANO & TOMASIEWICZ
`CT
`06'1
`^'.
`"8'6^r3
`'1
`-7766'-FAX
`(860)
`560-7359 .
`JURIS
`No.
`4
`1
`4049
`
`
`when Sanabria-Fontanez lost control of his motorcycle, failed to negotiate the curve in
`the roadway and crossed into the Plaintiffs lane of travel striking her vehicle resulting
`in the injuries and losses as set forth hereafter.
`7.
`The collision identified above, and the resultant injuries and losses to the
`Plaintiff were caused by the negligence ofSanbria-Fontanez in one or more of the
`following ways:
`a. In that he failed to have the motorcycle which he was operating under
`reasonable and proper control;
`b. In that he failed to keep a proper look out for other vehicles on a public
`highway or roadway;
`c. In that he was operating the motorcycle without regard for the traffic
`conditions then and there existing;
`d. In that he failed to turn the motorcycle in a sufficient manner so as to
`avoid the collision with the Plaintiffs motor vehicle;
`e. In that he was operating his motorcycle in a manner that was too fast for
`the conditions existing then and there;
`f. In that he failed to apply his brakes in time or with sufficient force so as to
`avoid the collision identified above; and/or
`g. In that he negligently operated amc)torvehicle in violation ofc-G-s- §14'
`236 by failing to stay in his established lane.
`8. As a result ofSanbria-Fontanez's negligence and breaches of their duties
`herein, the Plaintiff suffered and sustained the following injuries: cervical spine strain;
`strain to the left shoulder including tenderness to the left trapezius; abrasion to the
`anterolateral base of the cervical spine; exacerbated injury to the cervical spine;
`contusion of the right hip; pain and suffering, and a shock to her entire nervous system.
`Some of these injuries and the effects therefrom may be of a permanent nature.
`96 OAK STREET . HARTFORD
`LAW OFFICES OF
`CT
`06F^ZA8N°)a3
`TOMS'm"6°) 56»735C.. .
`UK,
`S
`No.
`4,
`<04S
`
`
`9. As a result of Sanbria-Fontanez's negligence and breaches of their duties
`herein, the Plaintiff was caused to seek medical treatment, therapy, hospital care and the
`like, and is likely to continue to need same in the future, all to her further loss and
`detriment.
`10. As a result ofSanbria-Fontanez's negligence and breaches of their duties
`herein, the Plaintiff was caused to lose the enjoyment of life's activities, and is likely to
`continue to suffer such loss, to her further loss and detriment.
`11. At the time of the motor vehicle accident on July 29, 2020, owner Lilian
`Deleon carried liability coverage of $25, 000/$50, 000 per person/per incident through
`GEICO.
`12. At the time of the motor vehicle accident on July 29, 2020, Plaintiff Susan
`Braun was named as an additional insured on an automobile insurance policy with
`underinsured motorist coverage limits of $250, 000/$500, 000 through Defendant
`[hereinafter "UIM policy").
`13. Said UIM policy was in full force and effect at the time that the Plaintiff
`sustained the personal injuries in the aforementioned accident, and Plaintiff Susan Braun
`had complied with all requirements and consideration for the enforcement of said policy.
`14. On or about September 3, 2020, the Plaintiff, through her counsel, gave
`written notice that the Plaintiff could be asserting an uninsured/underinsured motonst
`claim against CSAA Affinity Insurance Company. Said notice was delivered on September
`8, 2020.
`96 OAK STREET . HARTFORD
`LAW OFFICES OF
`FAZZANO & TOMASIEWICZ
`CT 06'1^":^'^3"1^"7"6i«-FAX^860) 560-7359 . JURIS No. 414049
`
`
`15. On September 22, 2022, Plaintiff executed a settlement agreement with
`Lilian Deleon and Sanbria-Fontanez in the amount of $25, 000. 00, thereby exhausting the
`underlying liability coverage available through GEICO.
`16. The Defendant, CSAA Affinity Insurance Company, therefore, is legally
`responsible to pay for additional damages, injuries, and losses suffered by the Plaintiff
`Susan Braun in accordance with Conn. Gen. Stat. § 38a-336 and the parties' UIM policy.
`THE PLAINTIFF,
`SUS^TBRAUN
`BY
`Patnck Tomasiewicz, Esq.
`Fazzano &Tomasiewicz, LLC
`Her Attorneys
`96 OAK STREET . HARTFORD,
`LAW OFFICES OF
`FAZZANO & TOMASIEWICZ
`CT 06'1 ^'^(86CT23'1 -7766 . FAX (860) 560-7359 . JURIS No. 414049
`
`
`RETURN DATE: APRIL 11, 2023
`SUSAN BRAUN
`V.
`CSAA AFFINITY INSURANCE COMPANY
`PRAYER FOR RELIEF
`WHEREFORE, the Plaintiff claims:
`1. Monetary relief; and
`2. Such other relief as this Court deems fair and equitable
`THE PLAINTIFF,
`SUSAI^BRAUN
`BY
`SUPERIOR COURT
`J. D. OF HARTFORD
`AT HARTFORD
`MARCH 10, 2023
`Patrick Tomaq^eWicz, Esq.
`Fazzano & Tomasiewicz, LLC
`Her Attorneys
`96 OAK STREET . HARTFORD
`LAW OFFICES OF
`CT 06F^N°)&3r°M?sT°S°) 5607359 . ^s No, 4, 4049
`
`
`RETURN DATE: APRIL 11, 2023
`SUSAN BRAUN
`V.
`CSAA AFFINITY INSURANCE COMPANY
`SUPERIOR COURT
`J. D. OF HARTFORD
`AT HARTFORD
`MARCH 10, 2023
`STATPMRNT OF AMOUNT IN DEMAND
`The Plaintiff claims damages in excess of FIFTEEN THOUSAND DOLLARS
`[$15, 000. 00), exclusive of interest and costs.
`THE PLAINTIFF,
`SUSAT^HRAUN
`BY
`Patrick Tomagff^wicz, Esq.
`Fazzano &Tomasiewicz, LLC
`Her Attorneys
`6
`LAW OFFICES OF
`^O.
`S^.
`H.
`^O»,
`C.
`O^"SNOa3
`T°MM.
`m"eO,
`^0.
`3^.^
`
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