On January 24, 2023 a
Answer
was filed
involving a dispute between
Rahsean Heard,
Rodney Heard,
Schmara Mckiver,
and
Diane Chambery,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of New Haven County.
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NO. NNH-CV23-6129675-S : SUPERIOR COURT
RAHSEAN HEARD & : J.D. OF NEW HAVEN
RODNEY HEARD &
SCHMARA MCKIVER : AT NEW HAVEN
V. :
May 01, 2023
DIANE CHAMBERY
ANSWER TO PLAINTIFFS’ COMPLAINT
DATED DECEMBER 27, 2022
COUNT ONE
1. As to the allegations in Paragraphs 1 through 4, the undersigned defendant has
insufficient knowledge upon which to form a belief and therefore leaves the plaintiff to his
proof.
2. Paragraph number 5 is denied.
3. As to the allegations in Paragraphs 6 through 10, the undersigned defendant
has insufficient knowledge upon which to form a belief and therefore leaves the plaintiff to
his proof. Any allegations or inferences of negligence against the undersigned defendant are
hereby denied.
COUNT TWO
1. The answers to Paragraphs 1 through 10 of Count One, are hereby incorporated
and made the answers to Paragraphs 1 through 10 of Count Two.
COUNT THREE
1. The answers to Paragraphs 1 through 10 of Count One, are hereby incorporated
and made the answers to Paragraphs 1 through 10 of Count Three.
1
THE DEFENDANT
DIANE CHAMBERY
By: /s/439221
Evan Tegtmeier
Law Offices of Dennis J. Rinaldi
55 Capital Boulevard, Suite 202
Rocky Hill, CT 06067
Telephone: (203) 281-8508
E-Service Only:
LOMSG.Hamden@allstate.com
Juris No. 423048
2
CERTIFICATION
I hereby certify that a copy of the above was mailed or electronically delivered on May 01,
2023, 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 electronically served:
R.J. Weber, III, Esq.
WEBER & RUBANO, LLC
401 Center Street
Wallingford, CT 06492
rjweber@rjwlawyer.com
/s/439221
Evan Tegtmeier
Attorney at Law
3
Document Filed Date
May 01, 2023
Case Filing Date
January 24, 2023
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
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NO. NNH-CV23-6129675-S : SUPERIOR COURT RAHSEAN HEARD & : J.D. OF NEW HAVEN RODNEY HEARD & SCHMARA MCKIVER : AT NEW HAVEN V. : May 01, 2023 DIANE CHAMBERY ANSWER TO PLAINTIFFS’ COMPLAINT DATED DECEMBER 27, 2022 COUNT ONE 1. As to the allegations in Paragraphs 1 through 4, the undersigned defendant has insufficient knowledge upon which to form a belief and therefore leaves the plaintiff to his proof. 2. Paragraph number 5 is denied. 3. As to the allegations in Paragraphs 6 through 10, the undersigned defendant has insufficient knowledge upon which to form a belief and therefore leaves the plaintiff to his proof. Any allegations or inferences of negligence against the undersigned defendant are hereby denied. COUNT TWO 1. The answers to Paragraphs 1 through 10 of Count One, are hereby incorporated and made the answers to Paragraphs 1 through 10 of Count Two. COUNT THREE 1. The answers to Paragraphs 1 through 10 of Count One, are hereby incorporated and made the answers to Paragraphs 1 through 10 of Count Three. 1 THE DEFENDANT DIANE CHAMBERY By: /s/439221 Evan Tegtmeier Law Offices of Dennis J. Rinaldi 55 Capital Boulevard, Suite 202 Rocky Hill, CT 06067 Telephone: (203) 281-8508 E-Service Only: LOMSG.Hamden@allstate.com Juris No. 423048 2 CERTIFICATION I hereby certify that a copy of the above was mailed or electronically delivered on May 01, 2023, 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 electronically served: R.J. Weber, III, Esq. WEBER & RUBANO, LLC 401 Center Street Wallingford, CT 06492 rjweber@rjwlawyer.com /s/439221 Evan Tegtmeier Attorney at Law 3