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RETURN DATE: FEBRUARY 20, 2024
SUPERIOR COURT
KARLA VANEGAS J.D. OF NORWALK/STAMFORD
AT STAMFORD
HANNAH SESSLER and
MARC C. SESSLER JANUARY 16, 2024
COMPLAINT
FIRST COUNT: Negligence -
Hannah Sessler
1. On February 18, 2022, at 6:38 a.m., the plaintiff, KARLA VANEGAS, was
operating a 2017 Toyota Camry motor vehicle traveling north on Elm Street in Stamford,
Connecticut. Karla Vanegas was pregnant at the time.
2. At said time and place, the defendant-driver, HANNAH SESSLER, was
operating a 2014 Honda Pilot motor vehicle traveling east on Tresser Boulevard in Stamford
c czz Connecticut.
3. At said time and place, the defendant, HANNAH SESSLER proceeded into the
intersection of Elm Street and Tresser Boulevard, failed to stop and drives through a red light.
4. At that time and place, the defendant-driver, HANNAH SESSLER, suddenly and
without warning struck the driver side front bumper of the plaintiffs vehicle causing the airbags
to deploy.
5. As a direct result of the negligence and/or carelessness of the defendant-operator,
HANNAH SESSLER, the plaintiff sustained injuries and damages.
6. The aforesaid collision and resulting injuries were caused by the negligence
and/or carelessness of the defendant-driver, HANNAH SESSLER, in one or more of the
following respects:
a. In that she failed to obey traffic control signal in violation of Connecticut
General Statutes Section 14-299
b. In that she failed to operate the motor vehicle at a reasonable speed in light of
the intersection of streets, weather conditions and highway traffic in violation
of Connecticut General Statutes Section 14-218a;
c. In that she failed to operate said motor vehicle in a safe and reasonable
manner;
d. In that she failed to apply the brakes in time to avoid a collision, although by a
proper and reasonable exercise of her faculties, she could and should have
done
so;
e. In that she failed to exercise that degree of care required of a reasonably
prudent person, under the circumstances then and there existing;
f. In that shefailed to turn the motor vehicle to the left or right so as to avoid a
collision,although by a proper and reasonable exercise of her faculties, she
could and should have done so;
In that she failed maintain
g. to a proper lookout;
h. In that she failed to maintain control of the motor vehicle;
i. In that she failed to timely brake the motor vehicle; and
j. In that she failed to sound the horn or give a timely warning of the impending
collision.
7. As a direct result of the negligence and/or carelessness of the defendant-driver,
HANNAH SESSLER, the plaintiff, KARLA VANEGAS, sustained the following painful, severe
and/or permanent injuries:
a. Cervical pain/strain/sprain;
b. Lumbar pain/strain/sprain;
c. Right leg pain;
d. Bilateral hip sprain/strain/pain;
e. Facial abrasions, bruising, swelling;
f. Fetal monitoring and observation of unborn baby
8. As a further result of the negligence and/or carelessness of the defendant-driver,
HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment
to her cervical spine.
9. As a further result of the negligence and/or carelessness of the defendant-driver,
HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment
to her right leg/lower extremity.
10. As a further result of the negligence and/or carelessness of the defendant-driver,
HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment
to her lumbar spine.
c
11. As a further result of the negligence and/or carelessness of the defendant-driver,
L.L4 HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has been required to expend and/or
may be required to expend money for medical treatment, hospitalization, physical therapy, pain
management, durable medical supplies and equipment, prescriptions, radiological studies, and
other diagnostic tests, medical care and treatment, and medication all to her financial loss.
12. As a further result of the negligence and/or carelessness of the defendant-driver,
HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has and will continue to suffer great
physical, mental, and emotional pain and anguish and pain and suffering, and she has been
and/or will be sick, sore and/or disabled for a long period of time.
13. As a further result of the negligence and/or carelessness of the defendant-driver
HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment
of her ability to engage in and/or enjoy life's activities.
SECOND COUNT: Statutory Recklessness —
Hannah Sessler
1-4. Paragraphs 1 through 4 of the First Count are hereby fully incorporated herein and
made Paragraphs 1 through 4 of this the Second Count.
5. The aforesaid collision and the resulting injuries and damages to the plaintiff, KARLA
VANEGAS, were caused by the deliberate and/or reckless disregard of the defendant, HANNAH
SESSLER, in one or more of the following respects:
(a) In that she was traveling at a rate of speed greater than is reasonable, having regard
to the width, traffic and use of highway and weather conditions, in violation of Section 14-218a of
the Connecticut General Statutes and with reckless disregard of the safety of the plaintiff and
consequence of her actions and failed to take reasonable precautions to avoid the known risk of
injury to him;
(b) In that she deliberately and/or willfully operated the motor vehicle recklessly in
violation of Connecticut General Statutes Section 14-222 and with reckless disregard of the safety
of the plaintiff and consequence of her actions and failed to take reasonable precautions to avoid
the known risk of injury to her;
(c) In that she deliberately and/or willfully chose not to obey a traffic control signal
while operating a motor vehicle in violation of Connecticut General Statutes Section 14-299.
6. The aforementioned violations set forth in Paragraphs 5(a) through (c) were a
substantial factor in causing the injuries to the plaintiff as set forth herein.
7. As a direct result of the result of the deliberate and/or reckless disregard of the
defendant, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, sustained the following
painful severe and/or permanent injuries:
a. Cervical pain/strain/sprain;
b. Lumbar pain/strain/sprain;
c. Right leg pain;
d. Bilateral hip sprain/strain/pain;
e. Facial abrasions, bruising, swelling;
f. Fetal monitoring and observation of unborn baby
9-4
8. As a further result of the deliberate and/or reckless disregard of the defendant-
driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent
impairment to her cervical spine.
9. As a further result of the deliberate and/or reckless disregard of the defendant-
driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent
c
impairment to her right leg/lower extremity.
10. As a further result of the deliberate and/or reckless disregard of the defendant-
driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent
impairment to her lumbar spine.
11. As a result of the deliberate and/or reckless disregard of the defendant-
driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has been required to expend
and/or may be required to expend money for medical treatment, hospitalization, physical
therapy, injections, pain management, surgery and/or anesthesia, durable medical supplies and
equipment, prescriptions, x-rays and other diagnostic tests, medical care and treatment, and
medication all to her financial loss.
12. As a further result of the deliberate and/or reckless disregard of the defendant-
driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has and will continue to suffer
physical, mental and emotional pain and suffering.
13. As a further result of the deliberate and/or reckless disregard of the defendant-
driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has and will continue to suffer
great physical, mental and emotional pain and anguish and has been and will be sick, sore and
disabled for a long period of time.
14. As a further result of the deliberate and/or reckless disregard of the defendant-
driver,
HANNAH SESSLER, the ability of the plaintiff, KARLA VANEGAS, to carry on life's
activities has been and will be permanently and severely curtailed.
THIRD COUNT: Common Law Recklessness- Hannah Sessler
c
1-4. Paragraphs 1-4 of the Second Count are hereby fully incorporated herein and made
Paragraphs 1 through 4 of this the Third Count.
5. The aforesaid collision, and the resulting injuries and damages to the plaintiff, KARLA
VANEGAS, were caused by the deliberate and/or reckless disregard of the defendant, HANNAH
SESSLER, in the operation of the motor vehicle in the following ways:
(a) In that she was traveling at a rate of speed greater than is reasonable, having regard
to the width, traffic and use of highway and weather conditions and with reckless disregard of
the safety of the plaintiff and consequence of her actions and failed to take reasonable precautions
to avoid the known risk of injury to her;
(b) In that she deliberately operated the motor vehicle recklessly and with reckless
disregard of the safety of the plaintiff and consequence of her actions and failed to take reasonable
precautions to avoid the known risk of injury to her;
(c) In that she was aware of the presence of the plaintiff, yet failed to safely control
the motor vehicle by slowing down even though he knew or should have known that a collision
and consequence of
was likely to occur and with reckless disregard of the safety of the plaintiff
her actions and failed to take reasonable precautions to avoid the known risk of injury to her;
and
(d) In that she willfully and/or deliberately chose to disobey traffic control signal then
and there existing by operating the motor vehicle against the traffic control signal.
6. The aforementioned violations set forth in Paragraphs 5(a) through (d) were a
substantial factor in causing the injuries to the plaintiff as set forth herein.
7-14. Paragraphs 7 through 14 ofthe Second Count are hereby repeated, realleged and
incorporated herein by reference as Paragraph 7 through 14 of this the Third Count.
FOURTH COUNT Negligence -Marc C. Sessler
1-13. Counts One through Thirteen of the First Count are hereby re-alleged and re-
incorporated as Counts One through Thirteen of the Second Count as if set forth fully herein.
14. At all relevant times, the vehicle being driven by defendant-driver HANNAH
SESSLER, was owned by defendant-owner, MARC C. SESSLER.
15. Defendant-owner, MARC C. SESSLER, is liable for the damages caused by the
negligence and carelessness of the defendant-driver, HANNAH SESSLER, because the
defendant-driver was operating said motor vehicle with the express and/or implied permission of
the defendant-owner, MARC C. SESSLER, and within the general scope of his agency and
authority to operate defendant-owner's vehicle, and is presumed to be the agent and servant of
the defendant-owner, MARC C. SESSLER, under Connecticut General Statutes Section 52-183.
16. Defendant-owner, MARC C. SESSLER, is liable for the damages caused by the
negligence and carelessness of the defendant-driver, HANNAH SESSLER, because he was
operating the vehicle as a member of the family or household of defendant-owner, MARC C.
SESSLER under Connecticut General Statutes Section 52-182.
T PLAINT4kF,
BY ocr
Christina Hanna, Esq.
Berkowitz and Hanna LLC
2 Corporate Drive, Third Fl. Suite 340
Shelton, CT 06484 T: (203) 324-7909;
F: (203)
324-5067; Juris #412801
channa@theberkowitzlawfirm.com
RETURN DATE: FEBRUARY 20, 2024
SUPERIOR COURT
KARLA VANEGAS J.D. OF
NORWALK/STAMFORD
AT STAMFORD
HANNAH SESSLER and
MARC C. SESSLER JANUARY 16, 2024
CLAIM FOR RELIEF
WHEREFORE, the plaintiff claims:
1. Money damages;
2. Costs;
3. Such other and further relief as this Court may deem proper;
4. Double and treble damages pursuant to Section 14-295 of the
Connecticut General Statutes.
THE PLAINTIFF,
BY
Christina Hanna, Esq.
Berkowitz and Hanna LLC
2 Corporate Drive, Third Fl. Suite 340
Shelton, CT 06484 T: (203) 324-7909;
F: (203)
324-5067; Juris #412801
channa@theberkowitzlawfirm.com
RETURN DATE: FEBRUARY 20, 2024 SUPERIOR COURT
KARLA VANEGAS J.D. OF
NORWALK/STAMFORD
AT STAMFORD
HANNAH SESSLER and
MARC C. SESSLER JANUARY 16, 2024
STATEMENT OF AMOUNT IN DEMAND
The amount of demand, exclusive of interest and costs, is in excess of Fifteen
Thousand ($ 15,000.00) Dollars.
c
THE PLAINTIFF,
BY
Christina Hanna, Esq.
Berkowitz and Hanna LLC
2 Corporate Drive, Third Fl. Suite 340
Shelton, CT 06484 T: (203) 324-7909;
F: (203) 324-5067; Juris #412801
channa@theberkowitzlawfirm.com
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RETURN DATE: FEBRUARY 20, 2024 SUPERIOR COURT KARLA VANEGAS J.D. OF NORWALK/STAMFORD AT STAMFORD HANNAH SESSLER and MARC C. SESSLER JANUARY 16, 2024 COMPLAINT FIRST COUNT: Negligence - Hannah Sessler 1. On February 18, 2022, at 6:38 a.m., the plaintiff, KARLA VANEGAS, was operating a 2017 Toyota Camry motor vehicle traveling north on Elm Street in Stamford, Connecticut. Karla Vanegas was pregnant at the time. 2. At said time and place, the defendant-driver, HANNAH SESSLER, was operating a 2014 Honda Pilot motor vehicle traveling east on Tresser Boulevard in Stamford c czz Connecticut. 3. At said time and place, the defendant, HANNAH SESSLER proceeded into the intersection of Elm Street and Tresser Boulevard, failed to stop and drives through a red light. 4. At that time and place, the defendant-driver, HANNAH SESSLER, suddenly and without warning struck the driver side front bumper of the plaintiffs vehicle causing the airbags to deploy. 5. As a direct result of the negligence and/or carelessness of the defendant-operator, HANNAH SESSLER, the plaintiff sustained injuries and damages. 6. The aforesaid collision and resulting injuries were caused by the negligence and/or carelessness of the defendant-driver, HANNAH SESSLER, in one or more of the following respects: a. In that she failed to obey traffic control signal in violation of Connecticut General Statutes Section 14-299 b. In that she failed to operate the motor vehicle at a reasonable speed in light of the intersection of streets, weather conditions and highway traffic in violation of Connecticut General Statutes Section 14-218a; c. In that she failed to operate said motor vehicle in a safe and reasonable manner; d. In that she failed to apply the brakes in time to avoid a collision, although by a proper and reasonable exercise of her faculties, she could and should have done so; e. In that she failed to exercise that degree of care required of a reasonably prudent person, under the circumstances then and there existing; f. In that shefailed to turn the motor vehicle to the left or right so as to avoid a collision,although by a proper and reasonable exercise of her faculties, she could and should have done so; In that she failed maintain g. to a proper lookout; h. In that she failed to maintain control of the motor vehicle; i. In that she failed to timely brake the motor vehicle; and j. In that she failed to sound the horn or give a timely warning of the impending collision. 7. As a direct result of the negligence and/or carelessness of the defendant-driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, sustained the following painful, severe and/or permanent injuries: a. Cervical pain/strain/sprain; b. Lumbar pain/strain/sprain; c. Right leg pain; d. Bilateral hip sprain/strain/pain; e. Facial abrasions, bruising, swelling; f. Fetal monitoring and observation of unborn baby 8. As a further result of the negligence and/or carelessness of the defendant-driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment to her cervical spine. 9. As a further result of the negligence and/or carelessness of the defendant-driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment to her right leg/lower extremity. 10. As a further result of the negligence and/or carelessness of the defendant-driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment to her lumbar spine. c 11. As a further result of the negligence and/or carelessness of the defendant-driver, L.L4 HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has been required to expend and/or may be required to expend money for medical treatment, hospitalization, physical therapy, pain management, durable medical supplies and equipment, prescriptions, radiological studies, and other diagnostic tests, medical care and treatment, and medication all to her financial loss. 12. As a further result of the negligence and/or carelessness of the defendant-driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has and will continue to suffer great physical, mental, and emotional pain and anguish and pain and suffering, and she has been and/or will be sick, sore and/or disabled for a long period of time. 13. As a further result of the negligence and/or carelessness of the defendant-driver HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment of her ability to engage in and/or enjoy life's activities. SECOND COUNT: Statutory Recklessness — Hannah Sessler 1-4. Paragraphs 1 through 4 of the First Count are hereby fully incorporated herein and made Paragraphs 1 through 4 of this the Second Count. 5. The aforesaid collision and the resulting injuries and damages to the plaintiff, KARLA VANEGAS, were caused by the deliberate and/or reckless disregard of the defendant, HANNAH SESSLER, in one or more of the following respects: (a) In that she was traveling at a rate of speed greater than is reasonable, having regard to the width, traffic and use of highway and weather conditions, in violation of Section 14-218a of the Connecticut General Statutes and with reckless disregard of the safety of the plaintiff and consequence of her actions and failed to take reasonable precautions to avoid the known risk of injury to him; (b) In that she deliberately and/or willfully operated the motor vehicle recklessly in violation of Connecticut General Statutes Section 14-222 and with reckless disregard of the safety of the plaintiff and consequence of her actions and failed to take reasonable precautions to avoid the known risk of injury to her; (c) In that she deliberately and/or willfully chose not to obey a traffic control signal while operating a motor vehicle in violation of Connecticut General Statutes Section 14-299. 6. The aforementioned violations set forth in Paragraphs 5(a) through (c) were a substantial factor in causing the injuries to the plaintiff as set forth herein. 7. As a direct result of the result of the deliberate and/or reckless disregard of the defendant, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, sustained the following painful severe and/or permanent injuries: a. Cervical pain/strain/sprain; b. Lumbar pain/strain/sprain; c. Right leg pain; d. Bilateral hip sprain/strain/pain; e. Facial abrasions, bruising, swelling; f. Fetal monitoring and observation of unborn baby 9-4 8. As a further result of the deliberate and/or reckless disregard of the defendant- driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment to her cervical spine. 9. As a further result of the deliberate and/or reckless disregard of the defendant- driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent c impairment to her right leg/lower extremity. 10. As a further result of the deliberate and/or reckless disregard of the defendant- driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has sustained a permanent impairment to her lumbar spine. 11. As a result of the deliberate and/or reckless disregard of the defendant- driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has been required to expend and/or may be required to expend money for medical treatment, hospitalization, physical therapy, injections, pain management, surgery and/or anesthesia, durable medical supplies and equipment, prescriptions, x-rays and other diagnostic tests, medical care and treatment, and medication all to her financial loss. 12. As a further result of the deliberate and/or reckless disregard of the defendant- driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has and will continue to suffer physical, mental and emotional pain and suffering. 13. As a further result of the deliberate and/or reckless disregard of the defendant- driver, HANNAH SESSLER, the plaintiff, KARLA VANEGAS, has and will continue to suffer great physical, mental and emotional pain and anguish and has been and will be sick, sore and disabled for a long period of time. 14. As a further result of the deliberate and/or reckless disregard of the defendant- driver, HANNAH SESSLER, the ability of the plaintiff, KARLA VANEGAS, to carry on life's activities has been and will be permanently and severely curtailed. THIRD COUNT: Common Law Recklessness- Hannah Sessler c 1-4. Paragraphs 1-4 of the Second Count are hereby fully incorporated herein and made Paragraphs 1 through 4 of this the Third Count. 5. The aforesaid collision, and the resulting injuries and damages to the plaintiff, KARLA VANEGAS, were caused by the deliberate and/or reckless disregard of the defendant, HANNAH SESSLER, in the operation of the motor vehicle in the following ways: (a) In that she was traveling at a rate of speed greater than is reasonable, having regard to the width, traffic and use of highway and weather conditions and with reckless disregard of the safety of the plaintiff and consequence of her actions and failed to take reasonable precautions to avoid the known risk of injury to her; (b) In that she deliberately operated the motor vehicle recklessly and with reckless disregard of the safety of the plaintiff and consequence of her actions and failed to take reasonable precautions to avoid the known risk of injury to her; (c) In that she was aware of the presence of the plaintiff, yet failed to safely control the motor vehicle by slowing down even though he knew or should have known that a collision and consequence of was likely to occur and with reckless disregard of the safety of the plaintiff her actions and failed to take reasonable precautions to avoid the known risk of injury to her; and (d) In that she willfully and/or deliberately chose to disobey traffic control signal then and there existing by operating the motor vehicle against the traffic control signal. 6. The aforementioned violations set forth in Paragraphs 5(a) through (d) were a substantial factor in causing the injuries to the plaintiff as set forth herein. 7-14. Paragraphs 7 through 14 ofthe Second Count are hereby repeated, realleged and incorporated herein by reference as Paragraph 7 through 14 of this the Third Count. FOURTH COUNT Negligence -Marc C. Sessler 1-13. Counts One through Thirteen of the First Count are hereby re-alleged and re- incorporated as Counts One through Thirteen of the Second Count as if set forth fully herein. 14. At all relevant times, the vehicle being driven by defendant-driver HANNAH SESSLER, was owned by defendant-owner, MARC C. SESSLER. 15. Defendant-owner, MARC C. SESSLER, is liable for the damages caused by the negligence and carelessness of the defendant-driver, HANNAH SESSLER, because the defendant-driver was operating said motor vehicle with the express and/or implied permission of the defendant-owner, MARC C. SESSLER, and within the general scope of his agency and authority to operate defendant-owner's vehicle, and is presumed to be the agent and servant of the defendant-owner, MARC C. SESSLER, under Connecticut General Statutes Section 52-183. 16. Defendant-owner, MARC C. SESSLER, is liable for the damages caused by the negligence and carelessness of the defendant-driver, HANNAH SESSLER, because he was operating the vehicle as a member of the family or household of defendant-owner, MARC C. SESSLER under Connecticut General Statutes Section 52-182. T PLAINT4kF, BY ocr Christina Hanna, Esq. Berkowitz and Hanna LLC 2 Corporate Drive, Third Fl. Suite 340 Shelton, CT 06484 T: (203) 324-7909; F: (203) 324-5067; Juris #412801 channa@theberkowitzlawfirm.com RETURN DATE: FEBRUARY 20, 2024 SUPERIOR COURT KARLA VANEGAS J.D. OF NORWALK/STAMFORD AT STAMFORD HANNAH SESSLER and MARC C. SESSLER JANUARY 16, 2024 CLAIM FOR RELIEF WHEREFORE, the plaintiff claims: 1. Money damages; 2. Costs; 3. Such other and further relief as this Court may deem proper; 4. Double and treble damages pursuant to Section 14-295 of the Connecticut General Statutes. THE PLAINTIFF, BY Christina Hanna, Esq. Berkowitz and Hanna LLC 2 Corporate Drive, Third Fl. Suite 340 Shelton, CT 06484 T: (203) 324-7909; F: (203) 324-5067; Juris #412801 channa@theberkowitzlawfirm.com RETURN DATE: FEBRUARY 20, 2024 SUPERIOR COURT KARLA VANEGAS J.D. OF NORWALK/STAMFORD AT STAMFORD HANNAH SESSLER and MARC C. SESSLER JANUARY 16, 2024 STATEMENT OF AMOUNT IN DEMAND The amount of demand, exclusive of interest and costs, is in excess of Fifteen Thousand ($ 15,000.00) Dollars. c THE PLAINTIFF, BY Christina Hanna, Esq. Berkowitz and Hanna LLC 2 Corporate Drive, Third Fl. Suite 340 Shelton, CT 06484 T: (203) 324-7909; F: (203) 324-5067; Juris #412801 channa@theberkowitzlawfirm.com