Preview
SUSNONS - CIVIL STATE OF CONNECTICUT s a torinetrct
gatas, . UPERIOR COURT ee page 2 for instructions
Seis 82.250, P's Sees 5 tough 92181 www jud.ct gov
4 "X" if amount, legal interest or property in demand, not including interest and
TO: Any proper officer, BY AUTHORITY OF THE
costs is less than $2,500. STATE OF CONNECTICUT, you are hereby
oO "X" if amount, legal interest or property in demand, not including interest and commanded to make due and legal service of
costs is $2,500 or more. this Summons and attached Complaint.
Oo “X" if claiming other relief in addition to or in lieu of money or damages.
‘Address of court clerk where writ and olher papers shall be filed (Number, street, town and zip code) | Telephone number of clerk (with | Retum Date (Must be a Tuesday)
(C.G.8, §§ 51-346, 51-360) area code}
14 West River Street, Milford, CT 06460 ( 203 )877-4293 Januar 27, 2 015
on “Day Year
[Ex] Judicial District ‘At (Town in which writs retumable) (C.G.S. §§ 61-346, 51-349) Case type code (See list on page 2)
GA 1 5
[__] Housing Session [1 Number: Milford Major: © Minor: 90
For the Plaintiff(s) please enter the appearance of:
Name and address of attorney, law firm or plaintiff self-rapresented (Number, street, town and zip code) ‘Juris number (o be entered by attorney only)
Gregory J. Stamos - P.O. Box 166, Ansonia, CT 06401 101020
Telephone number (with area code) ‘Signature of Plaintiff (if seltrepresented)
(203) 735-9293
Number of Plaintiffs: 1 Number of Defendants: 3 | [] Form JD-CV-2 attached for additional parties
Parties Name (Last, First, Middle Initial) and Address of Each party (Number; Street; P.O. Box; Town; State; Zip; Country, if not USA)
First Name: . POT
Plaintiff Address: Gregory J. Stamos, Fiduciary & Guardian of the Estate of James T. Brown, Minor
200 Main Street, Ansonia, CT_06401
Additional | Name: P-02
Plaintif | Address
First Name: The Prudential Insurance Company of America D-01
Defendant | A44ress: Agent for Service - Connecti Insurance Department - 153 Market Street, 7th Floor, Hartford, CT 06103
iti Name: Pruco Life Insurance Company - Agent for Service - Connecticut Insurance Department D-02
Adcitional | pagress: 188 Market Street, 7th Flour, Hartford, CT 08103 °
iti Name: D-03|
Additional Address: Prudential Annuities Life Insurance Corporation
Agent for Service - Connecticut Corporation System, 1 Corporate Center, Hartford, CT 06103
Additional | Name: D-04
Defendant | Address:
Notice to Each Defendant
4. YOU ARE BEING SUED. This paper is a Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making
against you in this lawsuit.
2. To be notified of further proceedings, you or your attormey must file a form called an “Appearance” with the clerk of the above-named Court at the above
Court address on or before the second day after the above Return Date. The Return Date is not a hearing date. You do not have to come to court on the
Return Date uniess you receive a separate notice telling you to come to court.
3. IF you or your attorney do not file a written "Appearance" form on time, a judgment may be entered against you by default. The "Appearance" form may be
obtained at the Court address above or at www.jud.ct.gov under “Court Forms.”
4. If you believe that you have insurance that may cover the claim that is being made against you in this lawsuit, you should immediately contact your
insurance representative. Other action you may have to take is described in the Connecticut Practice Book which may be found in a superior court law
library or on-line at www.jud.ct.gov under "Court Rules.”
§, If you have questions about the Summons and C; mpfaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on
legal questions.
Signed (Sign and "X" pro ] Commissioner of the | Name of Person Signing at Left ma aud
Ey Super Geert | Gregory J. Stamos Toho
For Court Use Only
If this Summons ig’ sig}
a. The signing has been done so tat the Plaintiffs) will not be denied access to the courts. File Date
b. It is the responsibility of the Plaintiff(s) to see that service is made in the manner provided by law.
c, The Clerk is not permitted to give any legal advice in connection with any lawsuit.
d. The Clerk signing this Summons at the request of the Plaintifi(s) is not responsible in any way for any errors or omissions
in the Summons, any allegations contained in the Complaint, or the service of the Summons or Complaint.
I certify |have read and | Signed (SeitRepresented Plainti) Date
understand the above:
Name and address of person recognized to prosecute in the amount of $250
Cart . Ajello - 200 Main Street, Ansonia CT 06401--~~ 7
‘Signed (Official taking recognizanfe; 7 fof wy are os ssaennse
superior Court
Assistant Clerk 12/23/2014
(Page 1 of 2)RETURN DATE: JANUARY 27, 2015 : SUPERIOR COURT
GREGORY J. STAMOS, FIDUCIARY and : J.D. OF ANSONIA/MILFORD
GUARDIAN OF THE ESTATE OF JAMES T.
BROWN, MINOR
vs. : AT MILFORD
THE PRUDENTIAL INSURANCE COMPANY : DECEMBER 23, 2014
OF AMERICA, PRUCO LIFE INSURANCE
COMPANY, PRUDENTIAL ANNUITIES
LIFE INSURANCE CORPORATION
D/B/A PRUDENTIAL
COMPLAINT
FIRST COUNT - BREACH OF CONTRACT
1. The Plaintiff, GREGORY J. STAMOS, FIDUCIARY and GUARDIAN
OF THE ESTATE OF JAMES T. BROWN, MINOR, is the Successor
Fiduciary and Guardian of the Estate of James T. Brown, duly
appointed as such by the Probate Court, District of Derby, #042
(hereinafter referred to as the “Probate Court”), on May 14,
2014, with a law office at 200 Main Street, Ansonia, Connecticut
(hereinafter referred to as the “Plaintiff”);
2. The Defendants, THE PRUDENTIAL INSURANCE COMPANY OF
AMERICA, PRUCO LIFE INSURANCE COMPANY , and PRUDENTIAL ANNUITIES
LIFE INSURANCE CORPORATION D/B/A PRUDENTIAL are in the business
of selling life insurance and investment products, including
annuities (hereinafter collectively referred to as either
“Prudential” or “Defendants”);
GREGORY J. STAMOS ¢ ATTORNEY AT LAW
200 MAIN STREET « P.O, BOX 166 ¢ ANSONIA, CT 06401-0166 « JURIS NUMBER 101020 + (203) 735-9293 * FAX (203) 734-50653. The Defendants on February 7, 2000 sold a Prudential
Variable Annuity (hereinafter referred to as the “Annuity”) to
Priscilla Wedler, the then Fiduciary and Guardian of the Estate
of the then minor, James T. Brown, pursuant to a Variable Annuity
Application dated February 1, 2000;
4, Said Variable Annuity Application was processed by
Prudential Agent Jim McMahon (now deceased), and had as
attachments: a) a Probate Court Order issued by the Probate
Court, District of Derby (#037) (Clifford D. Hoyle, J.), dated
April 29, 1999 that approved placing of certain funds with
Prudential in the joint names of Priscilla Wedler, the then
Guardian/Fiduciary of the Estate of James T. Brown, minor, and of
the Derby Probate Court #037; and b) correspondence from Attorney
Dina L. Weismann to Prudential Agent Jim McMahon, dated January
11, 2000, indicating that said funds needed to be placed in a
“restricted” account. (Copies of said Application and the two
(2) attachments referenced herein are attached hereto and
incorporated herein as Exhibit A, and are hereinafter referred to
as the “Application”);
5, Pursuant to said Application, an Annuity Contract
E0183524 (the “Annuity”) was issued by the Defendant on February
7, 2000, in the initial amount of $63,006.47;
6. Subsequent thereto, there were a limited number of
withdrawals from said Annuity issued pursuant to Probate Court
authorization and pursuant to Probate Court Decree;
7. Said Annuity has been completely depleted by
withdrawals made and allowed by the Defendants without the
requisite Probate Court authorization and pursuant to Probate
Court decree;
8. Defendants’ actions allowing withdrawals from the
Annuity without Probate Court authorization or pursuant to
GREGORY J. STAMOS e ATTORNEY AT LAW
200 MAIN STREET ¢ P.O. BOX 166 » ANSONIA, CT 06401-0166 ¢ JURIS NUMBER 101020 © (203) 735-9293 « FAX (203) 734-5065Probate Court decree are a breach of the terms of the underlying
contract;
9. The Plaintiff has suffered money damages as a result of
Defendants’ breach of contract, and the Defendants neglect and/or
refuse to pay same; and
10. Probate Court District #042 (Clifford D. Hoyle, J.)
(Successor to Probate Court #037, District of Derby) has
authorized and directed the Plaintiff to pursue recovery from the
Defendants for any and all withdrawals from said Annuity made and
allowed by the Defendants without Probate Court authorization or
pursuant to Probate Court decree.
SECOND COUNT — NEGLIGENCE
1-7. Paragraphs 1-7 of the First Count are set forth as
Paragraphs 1-7 of this Second Count as if fully set forth herein;
8. The Defendants failed and/or neglected to perform in
accordance with the established terms of the Annuity, in that
they allowed withdrawals from said Annuity to be made without
Probate Court approval or pursuant to Probate Court decree;
9. The Defendants neglected and/or failed to safeguard the
funds in said Annuity by failing to ensure that the unauthorized
withdrawals were allowable and approved;
10. The Defendants’ negligence was the proximate cause of
Plaintiff's damages;
1l. The Plaintiff has suffered monetary damages as a result
of the Defendant’s negligence, and the Defendants neglect and/or
refuse to pay same; and
12. Paragraph 10 of the First Count is set forth as
Paragraph 12 of this Second Count as if fully set forth herein.
GREGORY J. STAMOS ¢ ATTORNEY AT LAW
200 MAIN STREET ¢ P.O. BOX 166 ¢ ANSONIA, CT 06401-0166 * JURIS NUMBER 101020 ¢ (203) 735-9293 s FAX (203) 734-5065THIRD COUNT - CUTPA
1-9. Paragraphs 1-9 of the First Count are set forth as
Paragraphs 1-9 of this Third Count as if fully set forth herein;
10. The Defendants’ conduct as aforesaid constitutes unfair
methods of competition and unfair and deceptive acts or practices
of any trade or commerce in violation of Connecticut General
Statutes, Section 42-110b (known as the Connecticut Unfair Trade
Practices Act (“CUTPA”));
il. Defendants’ unfair and deceptive fair trade practices
have caused substantial injury and monetary damages to the
Plaintiff, a consumer within the meaning of Connecticut General
Statutes, Section 46-110b;
12. The Plaintiff seeks monetary damages, including
punitive damages, as a result of Defendants’ willful or wanton
and unlawful conduct as set forth hereinabove; and
13. Paragraph 10 of the First Count is set forth as
Paragraph 13 of this Third Count as if fully set forth herein.
“" GREGORY J. STAMOS ¢ ATTORNEY AT LAW
200 MAIN STREET ¢ P.O, BOX 166 « ANSONIA, CT 06401-0166 # JURIS NUMBER 101020 ¢ (203) 735-9293 « FAX (203) 734-5065
4
|WHEREFORE, the Plaintiff claims:
. Money Damages;
. Costs;
. Statutory Interest;
. Attorney’s Fees;
. Punitive Damages;
On Fe WN
. Double and Triple Damages pursuant to Connecticut General
Statutes, Section 42-110b; and
7. Such other and further relief that the Plaintiff may be
entitled to at the time of judgment.
THE PLAINTIFF,
GREGORY J. STAMOS, FIDUCIARY and
GUARDIAN OF THE ESTATE OF
JAMES T. BROWN, MINOR
BY:
Gr y if gyamos, His Attorney
P.0./BoxU/L6
Ansfnia, CT 06401
Tel. No.: 203-735-9293
Juris No.: 101020
“ GREGORY J. STAMOS « ATTORNEY AT LAW
200 MAIN STREET P.O. BOX 166 « ANSONIA, CT 06401-0166 * JURIS NUMBER 101020 + (203) 735-9293 » FAX (203) 734-5065
i
1
:
i
|RETURN DATE: JANUARY 27, 2015
GREGORY J. STAMOS, FIDUCIARY and
SUPERIOR COURT
J.D. OF ANSONIA/MILFORD
GUARDIAN OF THE ESTATE OF JAMES T.
BROWN
vs.
THE PRUDENTIAL INSURANCE COMPANY
OF AMERICA, PRUCO LIFE INSURANCE
COMPANY, PRUDENTIAL ANNUITIES
LIFE INSURANCE CORPORATION
D/B/A PRUDENTIAL
AT MILFORD
DECEMBER 23, 2014
STATEMENT OF AMOUNT IN DEMAND
The amount of money damages, exclusive of costs and
interest, being sought in the above-entitled action is more than
TWO THOUSAND FIVE HUNDRED ($2,500.00) DOLLARS.
BY:
THE PLAINTIFF
GREGORY J. STAMOS,
FIDUCIARY & GUARDIAN OF THE
ESTATE OF JAMES T. BROWN, MINOR
{ Stfamos, His Attorney
P.GY/Box/166
Ansoniay CT 06401
Tel. No.: (203) 735-9293
Juris No.: 101020
GREGORY J. STAMOS * ATTORNEY AT LAW
200 MAIN STREET ¢ P.O. BOX 166 « ANSONIA, CT 06401-0166 * JURIS NUMBER 101020 « (203) 735-9293 « FAX (203) 734-5065
Preview
SUSNONS - CIVIL STATE OF CONNECTICUT s a torinetrct gatas, . UPERIOR COURT ee page 2 for instructions Seis 82.250, P's Sees 5 tough 92181 www jud.ct gov 4 "X" if amount, legal interest or property in demand, not including interest and TO: Any proper officer, BY AUTHORITY OF THE costs is less than $2,500. STATE OF CONNECTICUT, you are hereby oO "X" if amount, legal interest or property in demand, not including interest and commanded to make due and legal service of costs is $2,500 or more. this Summons and attached Complaint. Oo “X" if claiming other relief in addition to or in lieu of money or damages. ‘Address of court clerk where writ and olher papers shall be filed (Number, street, town and zip code) | Telephone number of clerk (with | Retum Date (Must be a Tuesday) (C.G.8, §§ 51-346, 51-360) area code} 14 West River Street, Milford, CT 06460 ( 203 )877-4293 Januar 27, 2 015 on “Day Year [Ex] Judicial District ‘At (Town in which writs retumable) (C.G.S. §§ 61-346, 51-349) Case type code (See list on page 2) GA 1 5 [__] Housing Session [1 Number: Milford Major: © Minor: 90 For the Plaintiff(s) please enter the appearance of: Name and address of attorney, law firm or plaintiff self-rapresented (Number, street, town and zip code) ‘Juris number (o be entered by attorney only) Gregory J. Stamos - P.O. Box 166, Ansonia, CT 06401 101020 Telephone number (with area code) ‘Signature of Plaintiff (if seltrepresented) (203) 735-9293 Number of Plaintiffs: 1 Number of Defendants: 3 | [] Form JD-CV-2 attached for additional parties Parties Name (Last, First, Middle Initial) and Address of Each party (Number; Street; P.O. Box; Town; State; Zip; Country, if not USA) First Name: . POT Plaintiff Address: Gregory J. Stamos, Fiduciary & Guardian of the Estate of James T. Brown, Minor 200 Main Street, Ansonia, CT_06401 Additional | Name: P-02 Plaintif | Address First Name: The Prudential Insurance Company of America D-01 Defendant | A44ress: Agent for Service - Connecti Insurance Department - 153 Market Street, 7th Floor, Hartford, CT 06103 iti Name: Pruco Life Insurance Company - Agent for Service - Connecticut Insurance Department D-02 Adcitional | pagress: 188 Market Street, 7th Flour, Hartford, CT 08103 ° iti Name: D-03| Additional Address: Prudential Annuities Life Insurance Corporation Agent for Service - Connecticut Corporation System, 1 Corporate Center, Hartford, CT 06103 Additional | Name: D-04 Defendant | Address: Notice to Each Defendant 4. YOU ARE BEING SUED. This paper is a Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making against you in this lawsuit. 2. To be notified of further proceedings, you or your attormey must file a form called an “Appearance” with the clerk of the above-named Court at the above Court address on or before the second day after the above Return Date. The Return Date is not a hearing date. You do not have to come to court on the Return Date uniess you receive a separate notice telling you to come to court. 3. IF you or your attorney do not file a written "Appearance" form on time, a judgment may be entered against you by default. The "Appearance" form may be obtained at the Court address above or at www.jud.ct.gov under “Court Forms.” 4. If you believe that you have insurance that may cover the claim that is being made against you in this lawsuit, you should immediately contact your insurance representative. Other action you may have to take is described in the Connecticut Practice Book which may be found in a superior court law library or on-line at www.jud.ct.gov under "Court Rules.” §, If you have questions about the Summons and C; mpfaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on legal questions. Signed (Sign and "X" pro ] Commissioner of the | Name of Person Signing at Left ma aud Ey Super Geert | Gregory J. Stamos Toho For Court Use Only If this Summons ig’ sig} a. The signing has been done so tat the Plaintiffs) will not be denied access to the courts. File Date b. It is the responsibility of the Plaintiff(s) to see that service is made in the manner provided by law. c, The Clerk is not permitted to give any legal advice in connection with any lawsuit. d. The Clerk signing this Summons at the request of the Plaintifi(s) is not responsible in any way for any errors or omissions in the Summons, any allegations contained in the Complaint, or the service of the Summons or Complaint. I certify |have read and | Signed (SeitRepresented Plainti) Date understand the above: Name and address of person recognized to prosecute in the amount of $250 Cart . Ajello - 200 Main Street, Ansonia CT 06401--~~ 7 ‘Signed (Official taking recognizanfe; 7 fof wy are os ssaennse superior Court Assistant Clerk 12/23/2014 (Page 1 of 2)RETURN DATE: JANUARY 27, 2015 : SUPERIOR COURT GREGORY J. STAMOS, FIDUCIARY and : J.D. OF ANSONIA/MILFORD GUARDIAN OF THE ESTATE OF JAMES T. BROWN, MINOR vs. : AT MILFORD THE PRUDENTIAL INSURANCE COMPANY : DECEMBER 23, 2014 OF AMERICA, PRUCO LIFE INSURANCE COMPANY, PRUDENTIAL ANNUITIES LIFE INSURANCE CORPORATION D/B/A PRUDENTIAL COMPLAINT FIRST COUNT - BREACH OF CONTRACT 1. The Plaintiff, GREGORY J. STAMOS, FIDUCIARY and GUARDIAN OF THE ESTATE OF JAMES T. BROWN, MINOR, is the Successor Fiduciary and Guardian of the Estate of James T. Brown, duly appointed as such by the Probate Court, District of Derby, #042 (hereinafter referred to as the “Probate Court”), on May 14, 2014, with a law office at 200 Main Street, Ansonia, Connecticut (hereinafter referred to as the “Plaintiff”); 2. The Defendants, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PRUCO LIFE INSURANCE COMPANY , and PRUDENTIAL ANNUITIES LIFE INSURANCE CORPORATION D/B/A PRUDENTIAL are in the business of selling life insurance and investment products, including annuities (hereinafter collectively referred to as either “Prudential” or “Defendants”); GREGORY J. STAMOS ¢ ATTORNEY AT LAW 200 MAIN STREET « P.O, BOX 166 ¢ ANSONIA, CT 06401-0166 « JURIS NUMBER 101020 + (203) 735-9293 * FAX (203) 734-50653. The Defendants on February 7, 2000 sold a Prudential Variable Annuity (hereinafter referred to as the “Annuity”) to Priscilla Wedler, the then Fiduciary and Guardian of the Estate of the then minor, James T. Brown, pursuant to a Variable Annuity Application dated February 1, 2000; 4, Said Variable Annuity Application was processed by Prudential Agent Jim McMahon (now deceased), and had as attachments: a) a Probate Court Order issued by the Probate Court, District of Derby (#037) (Clifford D. Hoyle, J.), dated April 29, 1999 that approved placing of certain funds with Prudential in the joint names of Priscilla Wedler, the then Guardian/Fiduciary of the Estate of James T. Brown, minor, and of the Derby Probate Court #037; and b) correspondence from Attorney Dina L. Weismann to Prudential Agent Jim McMahon, dated January 11, 2000, indicating that said funds needed to be placed in a “restricted” account. (Copies of said Application and the two (2) attachments referenced herein are attached hereto and incorporated herein as Exhibit A, and are hereinafter referred to as the “Application”); 5, Pursuant to said Application, an Annuity Contract E0183524 (the “Annuity”) was issued by the Defendant on February 7, 2000, in the initial amount of $63,006.47; 6. Subsequent thereto, there were a limited number of withdrawals from said Annuity issued pursuant to Probate Court authorization and pursuant to Probate Court Decree; 7. Said Annuity has been completely depleted by withdrawals made and allowed by the Defendants without the requisite Probate Court authorization and pursuant to Probate Court decree; 8. Defendants’ actions allowing withdrawals from the Annuity without Probate Court authorization or pursuant to GREGORY J. STAMOS e ATTORNEY AT LAW 200 MAIN STREET ¢ P.O. BOX 166 » ANSONIA, CT 06401-0166 ¢ JURIS NUMBER 101020 © (203) 735-9293 « FAX (203) 734-5065Probate Court decree are a breach of the terms of the underlying contract; 9. The Plaintiff has suffered money damages as a result of Defendants’ breach of contract, and the Defendants neglect and/or refuse to pay same; and 10. Probate Court District #042 (Clifford D. Hoyle, J.) (Successor to Probate Court #037, District of Derby) has authorized and directed the Plaintiff to pursue recovery from the Defendants for any and all withdrawals from said Annuity made and allowed by the Defendants without Probate Court authorization or pursuant to Probate Court decree. SECOND COUNT — NEGLIGENCE 1-7. Paragraphs 1-7 of the First Count are set forth as Paragraphs 1-7 of this Second Count as if fully set forth herein; 8. The Defendants failed and/or neglected to perform in accordance with the established terms of the Annuity, in that they allowed withdrawals from said Annuity to be made without Probate Court approval or pursuant to Probate Court decree; 9. The Defendants neglected and/or failed to safeguard the funds in said Annuity by failing to ensure that the unauthorized withdrawals were allowable and approved; 10. The Defendants’ negligence was the proximate cause of Plaintiff's damages; 1l. The Plaintiff has suffered monetary damages as a result of the Defendant’s negligence, and the Defendants neglect and/or refuse to pay same; and 12. Paragraph 10 of the First Count is set forth as Paragraph 12 of this Second Count as if fully set forth herein. GREGORY J. STAMOS ¢ ATTORNEY AT LAW 200 MAIN STREET ¢ P.O. BOX 166 ¢ ANSONIA, CT 06401-0166 * JURIS NUMBER 101020 ¢ (203) 735-9293 s FAX (203) 734-5065THIRD COUNT - CUTPA 1-9. Paragraphs 1-9 of the First Count are set forth as Paragraphs 1-9 of this Third Count as if fully set forth herein; 10. The Defendants’ conduct as aforesaid constitutes unfair methods of competition and unfair and deceptive acts or practices of any trade or commerce in violation of Connecticut General Statutes, Section 42-110b (known as the Connecticut Unfair Trade Practices Act (“CUTPA”)); il. Defendants’ unfair and deceptive fair trade practices have caused substantial injury and monetary damages to the Plaintiff, a consumer within the meaning of Connecticut General Statutes, Section 46-110b; 12. The Plaintiff seeks monetary damages, including punitive damages, as a result of Defendants’ willful or wanton and unlawful conduct as set forth hereinabove; and 13. Paragraph 10 of the First Count is set forth as Paragraph 13 of this Third Count as if fully set forth herein. “" GREGORY J. STAMOS ¢ ATTORNEY AT LAW 200 MAIN STREET ¢ P.O, BOX 166 « ANSONIA, CT 06401-0166 # JURIS NUMBER 101020 ¢ (203) 735-9293 « FAX (203) 734-5065 4 |WHEREFORE, the Plaintiff claims: . Money Damages; . Costs; . Statutory Interest; . Attorney’s Fees; . Punitive Damages; On Fe WN . Double and Triple Damages pursuant to Connecticut General Statutes, Section 42-110b; and 7. Such other and further relief that the Plaintiff may be entitled to at the time of judgment. THE PLAINTIFF, GREGORY J. STAMOS, FIDUCIARY and GUARDIAN OF THE ESTATE OF JAMES T. BROWN, MINOR BY: Gr y if gyamos, His Attorney P.0./BoxU/L6 Ansfnia, CT 06401 Tel. No.: 203-735-9293 Juris No.: 101020 “ GREGORY J. STAMOS « ATTORNEY AT LAW 200 MAIN STREET P.O. BOX 166 « ANSONIA, CT 06401-0166 * JURIS NUMBER 101020 + (203) 735-9293 » FAX (203) 734-5065 i 1 : i |RETURN DATE: JANUARY 27, 2015 GREGORY J. STAMOS, FIDUCIARY and SUPERIOR COURT J.D. OF ANSONIA/MILFORD GUARDIAN OF THE ESTATE OF JAMES T. BROWN vs. THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PRUCO LIFE INSURANCE COMPANY, PRUDENTIAL ANNUITIES LIFE INSURANCE CORPORATION D/B/A PRUDENTIAL AT MILFORD DECEMBER 23, 2014 STATEMENT OF AMOUNT IN DEMAND The amount of money damages, exclusive of costs and interest, being sought in the above-entitled action is more than TWO THOUSAND FIVE HUNDRED ($2,500.00) DOLLARS. BY: THE PLAINTIFF GREGORY J. STAMOS, FIDUCIARY & GUARDIAN OF THE ESTATE OF JAMES T. BROWN, MINOR { Stfamos, His Attorney P.GY/Box/166 Ansoniay CT 06401 Tel. No.: (203) 735-9293 Juris No.: 101020 GREGORY J. STAMOS * ATTORNEY AT LAW 200 MAIN STREET ¢ P.O. BOX 166 « ANSONIA, CT 06401-0166 * JURIS NUMBER 101020 « (203) 735-9293 « FAX (203) 734-5065