DOCKETNO. NNH-CV-23-6130601-S
`
`SUPERIOR COURT
`
`ANTHONY DELMAURO
`
`VS.
`
`:
`
`:
`
`PROPRIETORS OF THE COMMONSAT :
`MILL RIVER, INC,, ET AL
`
`J.D. OF NEW HAVEN
`
`AT NEW HAVEN
`
`AUGUST31, 2023
`
`MOTION TO CITE IN PARTY DEFENDANT
`
`Pursuant to Connecticut Practice Book §§ 9-18, 9-19, 9-22, and 10-60, the plaintiff,
`
`Anthony DelMauro,respectfully moves this Court to permit himto cite Visel Tree Service,
`
`Inc., LLC., as party defendant. The plaintiff further moves this Court to permit himto file
`
`an Amended Complaint, a copy of which has been annexed hereto, to include allegations
`
`directed towards the proposed party defendant. In support ofthis motion the plaintiff avers
`
`the following:
`
`1.
`
`This action was commenced by way ofservice of a writ of Summons and
`
`Complaint dated February 15, 2023, against defendants Proprietors of The Commonsat
`
`Mill River, Inc., Imagincers, LLC and Imagineers Property Management, LLC.
`
`2.
`
`The plaintiff now seeks to add Visel Tree Service, Inc.., to the existing action
`
`on the groundsthat this action arises out of a premises liability incident that occurred on
`
`February 7, 2022, from whichthe plaintiff, Anthony DelMauro,sustained personal injuries.
`
`© ATTORNEYS AT LAW
`Kennedy, Johuson, Schwab & Roberge LL.C.
`LONG WIIARF MARITIME CENTER © 555 LONG WHARF DRIVE, [3th Floor
`® NEW HAVEN, CE 06511
`FAX (203) 865-5345 ©
`(203) 865-8450 * JURIS NO. 106077
`
`
`
`SUPERIOR COURT
`
`ANTHONY DELMAURO
`
`VS.
`
`:
`
`:
`
`PROPRIETORS OF THE COMMONSAT :
`MILL RIVER, INC,, ET AL
`
`J.D. OF NEW HAVEN
`
`AT NEW HAVEN
`
`AUGUST31, 2023
`
`MOTION TO CITE IN PARTY DEFENDANT
`
`Pursuant to Connecticut Practice Book §§ 9-18, 9-19, 9-22, and 10-60, the plaintiff,
`
`Anthony DelMauro,respectfully moves this Court to permit himto cite Visel Tree Service,
`
`Inc., LLC., as party defendant. The plaintiff further moves this Court to permit himto file
`
`an Amended Complaint, a copy of which has been annexed hereto, to include allegations
`
`directed towards the proposed party defendant. In support ofthis motion the plaintiff avers
`
`the following:
`
`1.
`
`This action was commenced by way ofservice of a writ of Summons and
`
`Complaint dated February 15, 2023, against defendants Proprietors of The Commonsat
`
`Mill River, Inc., Imagincers, LLC and Imagineers Property Management, LLC.
`
`2.
`
`The plaintiff now seeks to add Visel Tree Service, Inc.., to the existing action
`
`on the groundsthat this action arises out of a premises liability incident that occurred on
`
`February 7, 2022, from whichthe plaintiff, Anthony DelMauro,sustained personal injuries.
`
`© ATTORNEYS AT LAW
`Kennedy, Johuson, Schwab & Roberge LL.C.
`LONG WIIARF MARITIME CENTER © 555 LONG WHARF DRIVE, [3th Floor
`® NEW HAVEN, CE 06511
`FAX (203) 865-5345 ©
`(203) 865-8450 * JURIS NO. 106077
`
`
`
`oy
`
`Upon information obtained,
`
`the proposed party defendant, Visel Tree
`
`Service, Inc., was responsible for the snow andice removalofthe premisesat the time and
`
`place wherethe plaintiff claims to have beeninjured.
`
`4,
`
`The proposed party defendant, Visel Tree Service, Inc., is necessary for a
`
`complete determination ofthe issues in dispute among real parties in interest, as they are
`
`or maybe liable forall or part ofthe plaintiff's injuries, losses and damages occasioned by
`
`the subject collision.
`
`WHEREFORE,theplaintiff respectfully request that this Court permit himto cite
`
`in the proposed party defendant, Visel Tree Service,Inc., by way ofthe proposed writ of
`
`Summons and Complaint.
`
`THE PLAINTIFF
`
`MM.
`
`Robert L. Schwab, Esq.
`Kennedy, Johnson, Schwab & Roberge
`555 Long WharfDrive — 13" Floor
`NewHaven, CT 06511
`Tel: (203) 865-8430
`Juris No. 106077
`
`© arrorNeys Ar Law
`Kennedy, Johnson, Schwab e& Roberge LLC.
`LONG WHARF MARITIME CENTER © 555 LONG WHARE DRIVE, 13th Floor
`® NeW LLAVEN, CT 06511
`PAX (203) 865-5345 ©
`(203) 865-8430 # JURIS NO. 106077
`
`
`
`CERTIFICATION
`
`I certify that a copy ofthis document wasorwill immediately be mailed or
`delivered electronically or non-electronically on August 31, 2023, to all attorneys and
`self-represented parties of record and that written consent for electronic delivery was
`received fromall attorneys and self-represented parties of record whoreceived orwill
`immediately be receiving electronic delivery.
`
`John C, Mayano, Esq.
`Milano & Wanat LLC
`471 East MainStreet
`Brantford, CT 06405
`Via E-mail: jmayano@mwlle.us
`
`ets
`
`
`
`Robert L. Schwab
`
`© ATTORNEYS AT LAW
`Kennedy, Johnson, Schwab e& Roberge L.L.C.
`LONG WHARF MARITIME CENTER © 555 LONG WHARF DRIVE, 13th Floor
`®& NEW TIAVEN, CT 06511
`PAX (203) 865-5345 ©
`(203) 865-8430 © JURIS NO. 106077
`
`
`
`DOCKET NO. NNH-CV-23-6130601-S
`
`ANTHONY DELMAURO
`
`VS,
`
`:
`
`:
`
`PROPRIETORS OF THE COMMONSAT :
`MILL RIVER, INC., ET AL
`
`SUPERIOR COURT
`
`J.D. OF NEW HAVEN
`
`AT NEW HAVEN
`
`AUGUST31, 2023
`
`ORDER
`
`A Motionto Cite in Visel Tree Service, Inc. as defendant in the above-captioned
`
`matter having been presented, and is appearing that it should be granted, it is hereby:
`
`ORDERED,thatthe plaintiff shall be permitted to cite in Visel Tree Service, Inc.
`
`by causing some properofficer to serve upon its agent a true and attested copy of the
`
`attached Writ, Summons and Complaint (Amended Complaint) and this Order at least
`
`twelve (12) days before the return date
`
`Dated at New Haven, Connecticutthis
`
`day of
`
`, 2023,
`
`
`
`© atrornevs ar Law
`Kennedy, fohnson, Schwab or Roberge LL.C.
`LONG WHARF MARITIME CENTER ® 555 LONG WIEARF DRIVE, 131 Foor
`* NEW Laven, CT 06511
`FAX (203) 865-5345 «
`(209) 865-8430 JURIS NO) 106077
`
`
`
`DOCKET NO. NNH-CV-23-6130601-S
`
`ANTHONY DELMAURO
`
`VS.
`
`:
`
`:
`
`:
`
`PROPRIETORS OF THE COMMONSAT :
`MILL RIVER, INC., ET AL
`
`SUPERIOR COURT
`
`J.D, OF NEW HAVEN
`
`AT NEW HAVEN
`
`AUGUST31, 2023
`
`SUMMONS
`
`TO ANY PROPER OFFICER:
`
`BY AUTHORITY OF THE STATE OF CONNECTICUT,youare hereby commanded to
`
`summon:
`
`Visel Tree Service, Inc, Through its Agent for Service:
`Hamden, CT 06514
`
`John M. Visel, 40 Nolan Rd,
`
`to appearbefore the Superior Court, Judicial District of New Haven at New Haven, 235
`Church Street, New Haven, Connecticut on
`, Said appearance to be
`
`made by Visel Tree Service, Inc. by filling a written statement of appearance with the
`
`Clerk of the court, then and there to answer unto the Amended Complaint in the above
`entitled action, by serving on it in the manner prescribed by law a true and attested copy of
`said Complaint and a true and attested copy ofthe foregoing Order. Hereof, fail not, but
`
`due service and return make.
`
`Dated at New Haven, Connecticutthis
`
`day of
`
`, 2023,
`
`© ArrORNEYS AT LAW
`Kennedy, Johnson, Schwab o& Raberge LAL.C.
`LONG WIIARF MARIUIME CENTER ¢ 555 LONG WIARF DRIVE. [3th Moor
`* New HAVEN, CV 06511
`FAX (203) 865-5345 *
`(203) 865-8430)
`© JURIS NO. 106077
`
`
`
`THE PLAINTIFF
`ANTHONY DELMAURO
`
`wv£YtIAL
`
`
`Robert L. Schwab, Esq.
`Kennedy, Johnson, Schwab & Roberge, LLC
`555 Long WharfDrive, 13" Floor
`New Haven, CT 06511
`Telephone: 203-865-8430
`Fax: 203-865-5345
`Juris No.: 106077
`
`© atTorNEYS AT LAW
`Kennedy,Johnson, Schwab e& Roberge LL.C.
`LONG WHARF MARITIME CENTER ® 555 LONG WHARF DRIVE, [3th Floor
`®& NEW TIAVEN, CT 06511
`FAX (203) 865-5345 ©
`(203) 865-8430 » JURIS NO, 106077
`
`
`
`c
`
`é
`
`DOCKET NO. NNH-CV-23-6130601-S
`
`ANTHONY DELMAURO
`
`VS.
`
`PROPRIETORS OF THE COMMONS
`AT MILL RIVER, INC., ET AL
`
`:
`
`:
`
`:
`
`:
`
`SUPERIOR COURT
`
`J.D. OF NEW HAVEN
`
`AT NEW HAVEN
`
`AUGUST31, 2023
`
`AMENDED COMPLAINT
`
`
`FIRST COUNT:
`
`As to Proprietors of The Commonsat Mill River, Inc,
`
`l.
`
`Atall times mentioned herein, the defendant, Proprietors of The Commons
`
`at Mill River, Inc, was a corporation organized and existing under the lawsofthe state of
`
`Connecticut.
`
`2.
`
`Atall times mentioned herein, the defendant, Proprietors of The Commons
`
`at Mill River,
`Inc., owned, possessed, controlled, maintained, and/or managed a
`condominium complex known as The Commonsat Mill River located at 75 Washington
`
`Avenue in Hamden, Connecticut.
`
`3,
`
`On February 7, 2022, and tor sometime prior thereto, there existed on the
`
`property a dangerous, defective, and unsafe condition, namely snow and ice on the surface
`
`of the walkwaysin the complex.
`
`© arrorners av ta
`Kennedy, Johnson, Schwab & Roberge LAL.C.
`LONG WUARF MARITIME CENTER © 555 LONG WHARE DRIVE, 13th Floor
`® New LLAVEN. CP 06511
`FAX (203) 865-5545 ©
`(208) 865-8430 © JURIS NO. 106077
`
`
`
`4,
`
`On February 7, 2022, as the plaintiff was walking on the walkway by the
`
`gazebo to building 2, he was causedto slip andfall on snow and ice which had
`
`accumulated, thereby causing him serious injuries hereinafter set forth.
`
`5.
`
`The plaintiff's injuries and damages were caused by the negligence and
`
`carelessness of the defendant, Proprietors of The Commonat Milf River, Inc., its agents,
`
`servants, and/or employees, in one or more ofthe following ways:
`
`a.
`
`b.
`
`c.
`
`d.
`
`€.
`
`f.
`
`In that they knew,or had it exercised due care, should have known
`about the dangerous, defective, and unsafe condition.
`
`In thai they allowed snow and ice to accumulate on the walkways,
`creating a dangerous, defective, and unsafe condition:
`
`In that they failed to adequately remove the snow andice from
`the walkways;
`
`In that they failed to apply salt, sand, or any other non-slip
`substance to the surface ofthe walkways;
`
`they failed to make a reasonable inspection of the
`In that
`property, in order to determine the existence ofthe dangerous,
`defective, and unsafe condition;
`
`they failed to warn the plaintiff of the dangerous,
`in that
`defective, and unsafe condition.
`
`6.
`
`As a result of the negligence of the defendant, its agents, servants, and/or
`
`employees, the plaintiff sustained the following personalinjuries:
`
`Kennedy, Johnson, Schwab & Roberge LLC. © ArroRNEYS AT LAW
`LONG WILARF MARIVIME GENTER © 555 LONG WHARF DRIVE,
`[31h Floor
`® New TRAWEN, CE 0651]
`FAX (203) 865-5345 ©
`(203) 865-8450 © JURIS NO. 106077
`
`
`
`a,
`
`b,
`
`c,
`
`d.
`
`e,
`
`f.
`
`g,
`
`h,
`
`Neck pain that radiates to the right shoulderand right side ofchest;
`
`Upperback pain;
`
`Right shoulderpain;
`
`Right arm pain;
`
`Numbnessandtingling in the right arm andright hand;
`
`Weaknessinthe right arm and right hand;
`
`Right hip pain;
`
`Right foot pain.
`
`From all of which injuries or the effects thereof, said plaintiff suffered considerable pain
`
`and suffering and someorall of said injuries imay be permanentin nature.
`
`7.
`
`As a further result ofthe negligence and carelessness ofthe defendant,its
`
`agents, servants and/or employees, the plaintiff has incurred considerable expenses for
`
`urgent care, medical care and treatment, surgery, physical therapy, occupational therapy,
`diagnostic imaging, and medications and inay be obliged to incur additional expenses for
`
`same in the future.
`
`8.
`
`Asstill a further result of the negligence and carelessness ofthe defendant,
`
`its agents, servants, and/or employees, the plaintiff missed time from work, her earning
`
`capacity was impaired and may be so impairedin the future,
`
`© arronneys ar Law
`Kennedy, Johnson, Schwab & Roberge LLC.
`[31h Floar
`® New PLAWEN. CP 06511
`LONG WHARF MARITIME CENTER © 555 LONG WHARE DRIVE,
`FAX (203) 865-5345 ©
`(203) 865-8130 * JURIS NO. 106077
`
`
`
`9,
`
`As a further result of the negligence and carelessness of the defendant, its
`
`agents, servants, and/or employees, the plaintiff's normal daily activities and enjoyments of
`life have been impaired and maybe so impairedinthe future.
`
`SECOND COUNT:Asto Imagineers, LLC
`
`I.
`
`At all times mentioned herein, the detendant, Imagineers, LLC., was a
`
`corporation organized andexisting underthe laws ofthe state of Connecticut.
`
`At all times mentioned herein, the defendant, Imagineers, LLC.. possessed,
`2,
`controlled, maintained, and/or managed a condominium complex known as The Commons
`
`at Mill River located at 75 Washington Avenue in Hamden, Connecticut.
`
`3.
`
`On February 7, 2022, and for some time prior thereto, there existed on the
`
`property a dangerous, defective, and unsate condition, namely snowandice on the surface
`
`of the walkways in the complex.
`
`On February 7, 2022,as the plaintiff was walking on the walkway by the
`4,
`gazebo to building 2, he was caused to slip and fall on snow and ice which had
`
`accumulated, thereby causing himserious injuries hereinafterset forth.
`
`Kennedy, fohnsan, Schwab o Roberge LLC. © arrornrys AP LAW
`LONG WHLARF MARITIME CENTER © 555 LONG WHARF DRIVE, 18th Floor
`© NEW TIAVEN. CT 06511
`FAX (203) 865-5345 ©
`(203) 865-8430 © JURIS NO. 106077
`
`
`
`5,
`
`The plaintiff's injuries and damages were caused by the negligence and
`
`carelessness ofthe defendant, Imagineers, LLC., its agents, servants, and/or employees, in
`
`one or more ofthe following ways:
`
`In that they knew, orhad it exercised due care, should have known
`about the dangerous, defective, and unsafe condition.
`
`In that they allowed snow and ice to accumulate onthe walkways,
`creating a dangerous, defective, and unsafe condition;
`
`In that they failed to adequately remove the snow and ice from
`the walkways:
`
`In that they failed to apply salt, sand, or any other non-slip
`substanceto the surface of the walkways;
`
`they failed to make a reasonable inspection of the
`In that
`property, in order to determine the existence of the dangerous,
`defective, and unsafe condition;
`
`they failed to warn the plaintiff of the dangerous,
`In that
`defective, and unsafe condition.
`
`a.
`
`b.
`
`o d
`
`.
`
`e.
`
`f.
`
`6.
`
`As a result ofthe negligence ofthe defendant, its agents, servants, and/or
`
`employees,the plaintiff sustained the following personal injuries:
`
`a.
`
`b,
`
`c,
`
`Neck painthat radiates to the right shoulder and right side of chest;
`
`Upperback pain:
`
`Right shoulder pain;
`
`« ArroRneys ar Law
`Kennedy, Johnson, Schwab & Roberwe LLC.
`LONG WHARF MARITIME CENTER © 555 LONG WILARKF DRIVE. 13th Floor
`* New flaven, CYT OGSLE
`FAN (203) 865-5345 ©
`(203) 865-8130 © JURIS NO, 106077
`
`
`
`d.
`
`e.
`
`f.
`
`g.
`
`h.
`
`Right armpain;
`
`Numbnessand tingling in the right arm and right hand;
`
`Weaknessin the right arm and right hand;
`
`Right hip pain;
`
`Right foot pain.
`
`Fromall of which injuries or the effects thereof, said plaintiff suffered considerable pain
`
`and suffering and someorall of said injuries may be permanentin nature.
`
`7.
`
`As a furtherresult of the negligence and carelessness ofthe defendant,its
`
`agents, servants and/or employees, the plaintiff has incurred considerable expenses for
`
`urgent care, medical care and treatment, surgery, physical therapy, occupational therapy,
`
`diagnostic imaging, and medications and may be obliged to incur additional expenses for
`
`same in the future.
`
`8.
`
`Asstill a furtherresult ofthe negligence and carelessness of the defendant,
`
`its agents, servants, and/or employees, the plaintiff missed time from work, her earning
`
`capacity was impaired and may be so impairedin the future.
`
`9,
`
`As a further result of the negligence and carelessness of the defendant, its
`
`agents, servants, and/or employees, the plaintiff's normal daily activities and enjoyments of
`
`life have been impaired and may be so impaired in the future,
`
`© ATTORNEYS AT Law
`Kennedy, Johnson, Schwab er Roberge LLC.
`LONG WITARF MARIVIME CENTER # 555 LONG WILARF DRIVE, [3th Floor
`© NeW [laAven, Cl 06511
`FAN (203) 865-5345 ©
`(203) 865-8430 © JURIS NO.
`(06077
`
`
`
`
`THIRD COUNT: Asto Imagineers Property Management, LLC
`
`1.
`
`At all
`
`times mentioned herein,
`
`the defendant,
`
`Imagineers Property
`
`Management, LLC., was a corporation organized and existing under the laws ofthe state
`
`of Connecticut.
`
`2.
`
`At all
`
`times mentioned herein,
`
`the defendant,
`
`Imagineers Property
`
`Management, LLC., possessed, controlled, maintained, and/or managed a condominium
`
`complex known as The Commonsat Mill River located at 75 Washington Avenue in
`
`Hamden, Connecticut.
`
`3,
`
`OnFebruary 7, 2022, and for sometime prior thereto, there existed on the
`
`property a dangerous, defective, and unsafe condition, namely snow and ice onthe surface
`
`of the walkways in the complex.
`
`4,
`
`On February 7, 2022, as the plaintiff was walking on the walkway by the
`
`gazebo to building 2, he was causedto slip and fall on snow and ice which had
`
`accumulated, thereby causing him serious injuries hereinafterset forth.
`
`5.
`
`The plaintiff's injuries and damages were caused by the negligence and
`
`carelessness of the defendant,
`
`Imagineers Property Management, LLC.,
`
`its agents,
`
`servants, and/or employees,in one or more of the following ways:
`
`© arrorneys Av Law
`Kennedy, Johnson, Schwab & Roberge LLC.
`LONG WUARF MARTUIME CENTER © 555 LONG WHARE DRIVE, 13th Floor
`© NEW ELaveN, Cl 06517]
`FAX (203) 865-5315 «©
`(203) BG5-8430 «© JURIS NO. 106077
`
`
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`In that they knew, or had it exercised due care, should have known
`about the dangerous, defective, and unsafe condition.
`
`In that they allowed snow andice to accumulate on the walkways,
`creating a dangerous, defective, and unsafe condition:
`
`In that they failed to adequately remove the snow and ice from
`the walkways;
`
`In that they failed to apply salt, sand, or any other non-slip
`substance to the surface ofthe walkways;
`
`they failed to make a reasonable inspection of the
`In that
`property, in order to determine the existence of the dangerous,
`defective, and unsafe condition;
`
`they failed to warn the plaintiff of the dangerous,
`In that
`defective, and unsafe condition.
`
`6,
`
`As a result ofthe negligence of the defendant, its agents, servants, and/or
`
`employees, the plaintiff sustained the following personal injuries:
`
`a.
`
`b.
`
`Neck painthat radiates to the right shoulder and right side ofchest;
`
`Upperback pain;
`
`Right shoulderpain;
`
`Right arm pain;
`
`Numbnessandtingling in the right arm and right hand:
`
`Weakness inthe right arm and right hand;
`
`© ArrORNEYS AT LAY
`Kennedy, Johnson, Schweh cv Roberge LLC.
`LONG WHARE MARTUIME CENTER © 555 LONG WEARF DRIVE, 13th Floor
`© NEW ELAVEN, CT OG511
`FAX (203) 865-5345 ©
`(203) 865-8420 ¢ JURIS NO, (06077
`
`
`
`g.
`
`h.
`
`Right hip pain;
`
`Right foot pain.
`
`Fromall of which injuries orthe effects thereof, said plaintiff suffered considerable pain
`
`and suffering and someorail ofsaid injuries may be permanent in nature.
`
`7.
`
`Asa furtherresult of the negligence and carelessness of the defendant,its
`
`agents, servants and/or employees, the plaintiff has incurred considerable expenses for
`
`urgent care, medical care and treatment, surgery, physical therapy, occupational therapy,
`
`diagnostic imaging, and medications and may be obliged to incur additional expenses for
`
`samein the future.
`
`8.
`
`As still a further result of the negligence and carelessness of the defendant,
`
`its agents, servants, and/or employees, the plaintiff missed time from work, her earning
`
`capacity was impaired and maybeso impaired in the future.
`
`9,
`
`As a further result of the negligence and carelessness ofthe defendant, its
`
`agents, servants, and/or employees, the plaintiffs normaldaily activities and enjoyments of
`
`life have been impaired and may be so impaired in the future.
`
`Kennedy, Johnson, Schwab ce Roberge LC. © ATTORNEYS AT LAW
`LONG WHARF MARITIME CENTER * 555 LONG WHARE DRIVE, 14th Floor
`© NeW DIavEN, Cl 065] 1
`FAX (203) 865-5915 @
`(203) 865-8490 « JURIS NO, 106077
`
`
`
`FOURTH COUNT: Asto Vise! Tree Service, Ine.
`
`l.
`
`At all times mentioned herein, the defendant, Visel Tree Service, Inc., was
`
`a corporation organized and existing underthe laws of the state of Connecticut.
`
`2.
`
`At all times mentioned herein, the defendant, Visel Tree Service, Inc., was
`
`a contractor hired to remove snow and ice at a condominium complex known as The
`
`Commonsat Mill River located at 75 Washington Avenue in Hamden, Connecticut.
`
`3.
`
`On February 7, 2022, and for sometime prior thereto, there existed on the
`
`property a dangerous, defective, and unsafe condition, namely snow and ice onthe surface
`
`ofthe walkways in the complex.
`
`4,
`
`OnFebruary 7, 2022, as the plaintiff was walking on the walkway by the
`
`gazebo to building 2, he was caused to slip and fall on snow and ice which had
`
`accumulated, thereby causing him serious injuries hereinafter set forth.
`
`5.
`
`The plaintiffs injuries and damages were caused by the negligence and
`
`carelessness of the defendant, Visel Tree Service,
`
`Inc.,
`
`its agents, servants, and/or
`
`employees, in one or more ofthe following ways:
`
`a.
`
`b.
`
`In that they knew, or had it exercised due care, should have known
`about the dangerous, defective, and unsafe condition.
`
`In that they allowed snow and ice to accumulate on the walkways,
`creating a dangerous, defective, and unsafe condition:
`
`Kennedy,Johnson, Schwab & Roberge LLC. © ATroRNEYS AT LAW
`LONG WOARF MARITIME CENTER * 555 LONG WELARE DRIVE. [3th Floor
`© New TLAVEN, CT OG5TI
`FAN (203) 865-5315 ©
`(203) 865-4430 © JURIS NO. LO6077
`
`
`
`c.
`
`d.
`
`e.
`
`f.
`
`In that they failed to adequately remove the snow andice from
`the walkways;
`
`In that they failed to apply salt, sand, or any other non-slip
`substance to the surface of the walkways;
`
`they tailed to make a reasonable inspection of the
`In that
`property, in order to determine the existence of the dangerous,
`defective, and unsafe condition;
`
`they failed to warn the plaintiff of the dangerous,
`In that
`defective, and unsafe condition.
`
`6.
`
`As a result of the negligence of the defendant, its agents, servants. and/or
`
`employees, the plaintiff sustained the following personal injuries:
`
`a.
`
`b.
`
`C.
`
`d.
`
`€.
`
`f.
`
`g.
`
`h.
`
`Neck pain that radiates to the right shoulder and right side ofchest:
`
`Upperback pain;
`
`Right shoulderpain;
`
`Right arm pain:
`
`Numbness andtingling in the right arm and right hand;
`
`Weaknessin the right arm and right hand;
`
`Right hip pain;
`
`Right foot pain.
`
`© arrORNEYS AT LAW
`Kennedy, folaison, Schinah e Roberge LLC.
`LONG WUARF MARITIME CENTER * 555 LONG WILARF DRIVE, 13th Floor
`® New [TAven, CO) 065th
`VAX (203) 865-5345 ©
`(203) 865-8430 © JURIS NO. 106077
`
`
`
`Fromall of which injuries or the effects thereof, said plaintiff suffered considerable pain
`
`and suffering and someorall of said injuries may be permanentin nature.
`
`7,
`
`As a further result of the negligence and carelessness of the defendant, its
`
`agents, servants and/or employees, the plaintiff has incurred considerable expenses for
`
`urgent care, medical care and treatment, surgery, physical therapy, occupational therapy,
`
`diagnostic imaging, and medications and may be obliged to incur additional expenses for
`
`same in the future.
`
`8.
`
`Asstill a further result of the negligence and carelessness ofthe defendant,
`
`its agents, servants, and/or employees,the plaintiff missed time from work, her earning
`
`capacity was impaired and may be so impaired in the future.
`
`9,
`
`As a further result of the negligence and carelessness of the defendant, its
`
`agents, servants, and/or employees,the plaintiff's normal daily activities and enjoyments of
`
`life have been impaired and may be so impaired in the future.
`
`Wherefore, the plaintiff herein claims money damages.
`
`Dated at New Haven, this 31“ day of August, 2023.
`
`Kennedy, Johnson, Schwab e& Roberge LLC. © AtTORNEYS AT LAW
`LONG WHARF MARITIME CENTER © 555 LONG WILARE DRIVE, 13th Floor
`© NeW Phwen, CV 06511
`PAN (203) 865-5345 ©
`(203) 865-8130 © JURIS NO. 106077
`
`
`
`THE PLAINTIFF
`
`5
`
`BY
`
`Robert L. Schwab, Esq.
`Kennedy, Johnson, Schwab & Roberge, LLC
`555 Long WharfDrive, 13'" Floor
`NewHaven, CT 06511
`Juris No. 106077
`Tel: 203-865-8430
`
`© ArrORNEYS AT LAW
`Kennedy, Johnson, Schwab & Roberge LLC.
`LONG WILARF MARITIME CENTER © 555 LONG WHARF DRIVE, 13th Floor
`® NEW TLAVEN, CT 06511
`FAX (203) 865-5315 *
`(203) 865-8430 © JURIS NO. 106077
`
`
`
`DOCKET NO. NNH-CV-23-6130601-S
`
`MARYANN VENDETTO
`
`VS.
`
`POND HOLLOW OWNERS’
`ASSOCIATION, INC., ET AL
`
`:
`
`:
`
`SUPERIOR COURT
`
`J.D, OF NEW HAVEN
`
`AT NEW HAVEN
`
`AUGUST31, 2023
`
`STATEMENT OF AMOUNT IN DEMAND
`
`The plaintiff claims money damages in excess of Fifteen Thousand Dollars
`
`($15,000.00), exclusive ofinterest and costs.
`
`THE PLAINTIFF
`
` ~ Ban
`
`Robert L. Schwab, Esq.
`Kennedy, Johnson, Schwab & Roberge, LLC
`555 Long WharfDrive, 13" Floor
`New Haven, CT 06511
`Juris No. 106077
`Tel: 203-865-8430
`
`Kennedy, Johnson, Schwab e Roberge LL.C.
`© ATTORNEYS AT LAW
`LONG WHARF MARITIME CENTER § 555 LONG WILARF DRIVE, 13th Floor
`® NEW TLWEN, GT 06511
`FAX (203) 865-5345 ©
`(203) 865-8430 * JURIS NO. 106077
`
`
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