Preview
DOCKET NO: NNI-CV-23-6028465-S SUPERIOR COURT
SILVIA VAZQUEZ J.D. OF NEW HAVEN
vs. AT MERIDEN
VANESSA BUCK, ET AL FEBRUARY 1, 2024
MOTION TO CONSOLIDATE
Pursuant to Section 9-5 of the Connecticut Practice Book, as amended, the
undersigned defendants, Vanessa Buck, Amazon Logistics, Inc., and MAD Logistics,
LLC, hereby respectfully move this Court to consolidate the following cases: Silvia
Vazquez v. Vanessa Buck, et al. (Docket No. NNI-CV23-6028465-S) and Isaiah Bryant
v. Vanessa Buck, et al. (Docket No. NNI-CV23-6029918-S). A corresponding Motion to
Consolidate is also being filed in the related case. The undersigned defendants certify
that the instant motion was served on all parties to both of these actions in accordance
with Sections 10-12 through 10-17 of the Connecticut Practice Book.
In support of this Motion, the undersigned states that these two cases arise from
the same motor vehicle accident that occurred at the intersection of East Main Street and
Parkway Place in Meriden, Connecticut. (Gee Complaints from each action, attached
hereto as Exhibit A). In the matter
of Silvia Vazquez v. Vanessa Buck, etal., Ms. Vazquez
alleges that Ms. Buck negligently caused the subject motor vehicle accident, and that Ms.
Vazquez was injured as a result. In the matter of Isaiah Bryant v. Vanessa Buck, et al.,
Mr. Bryant similarly alleges that Ms. Buck negligently caused the subject motor vehicle
accident, and that Mr. Bryant was injured as a result.
The question of liability in each action stems from the same accident and involves
the same witnesses and parties. Consequently, each action involves the same or similar
Ln HALLORAN
Halloran & Sage LLP Phone 860.522.6103
225 Asylum Street Fax 860.548.0006
Hartford, CT 06103 SAGE Juris No. 026105
IMANAGE\29647\0002\9009676.v1-2/1/24
issues concerning liability and would involve only differing issues when it came to
determining damages, if any, for each party. Accordingly, it would be in the interest of
judicial economy to consolidate these cases for the purposes of discovery and trial.
Practice Book Section 9-5 provides that “[w]henever there are two or more
separate actions which should be tried together, the judicial authority may, upon motion
of any party or upon its own motion, order that the actions be consolidated for trial." Case
law in Connecticut is clear that consolidation in matters such as those before the Court is
appropriate. “Independent of statutory authority, courts of general jurisdiction have
inherent power to consolidate different causes, or order them tried together, when the
circumstances authorize such course; and unless otherwise provided by statute,
questions respecting such procedure are addressed to the discretion of the trial court,
and its action will not be revised unless an abuse of discretion clearly appears." Rode v.
Adley Express Co., 130 Conn. 274, 277 (1943). “[T]he public has an interest in the
prevention of unnecessary litigation, both because of the burden it places on the State
and the resulting crowding of the dockets of the courts. This procedure of trying cases
together, which has long been the established practice in this state, assists in expediting
business without doing anyone an injustice." Groth v. Redmond, 24 Conn. Supp. 467,
469 (Conn. App. Ct. 1962).
The cases which the undersigned defendants seek to consolidate arise from the
exact same accident, involve the same parties, involve the same witnesses, and involve
the same questions of liability. If consolidated, one jury will be able to make a
determination as to liability and damages as opposed to having the same action tried by
-2-
Ln HALLORAN
Halloran & Sage LLP Phone 860.522.6103
225 Asylum Street Fax 860.548.0006
Hartford, CT 06103 SAGE Juris No. 026105
IMANAGE\29647\0002\9012227.v1-2/1/24
two separate juries. Trying these cases together will prevent the Court from wasting
limited resources and will prevent any potential incongruent factual determinations based
on the same set of facts. In sum, consolidating these actions will expedite the Court’s
business, avoid two trials over the same factual questions, and will not unduly burden the
parties in any way.
WHEREFORE, for all of the foregoing reasons, the undersigned defendants
respectfully request that this Motion to Consolidate be granted.
THE DEFENDANTS,
VANESSA BUCK,
AMAZON LOGISTICS, INC., AND
MAD LOGISTICS LLC
By:445126
Kevin M. Roche
Christopher B. Wiezbicki
HALLORAN & SAGE LLP
225 Asylum Street
Hartford, Connecticut 06103
J uris No.026105
Their attorneys
-3-
Ln HALLORAN
Halloran & Sage LLP Phone 860.522.6103
225 Asylum Street Fax 860.548.0006
Hartford, CT 06103 SAGE Juris No. 026105
IMANAGE\29647\0002\9012227.v1-2/1/24
CERTIFICATION
This is to certify that on this 1st day of February 2024, a copy of the foregoing
was either mailed, postage prepaid, sent via electronic mail, or hand-delivered to:
Brian M. Flood, Esq.
The Flood Law Firm, LLC
190 Washington Street
Middletown, CT 06457
legaldocs@ thefloodlawfirm.com
For the Plaintiff
Sean Carew, Esq.
Law Offices of Meehan, Di Palma, Roberts & Turret
108 Leigus Road, 1st Floor
Wallingford, CT 06492
LMLAWCT@libertymutual.com
For the Defendant, Isaiah Bryant
445126
Christopher B. Wiezbicki
wiezbicki@ halloransage.com
-4-
Ln HALLORAN
Halloran & Sage LLP Phone 860.522.6103
225 Asylum Street Fax 860.548.0006
Hartford, CT 06103 SAGE Juris No. 026105
IMANAGE\29647\0002\9012227.v1-2/1/24
EXHIBIT A
-5-
Ln HALLORAN
Halloran & Sage LLP Phone 860.522.6103
treet Fax 860.548.0006
06103 SAGE Juris No. 026105
IMANAGE\29647\0002\9012227.v1-2/1/24
SUMMONS - CIVIL For information on STATE OF CONNECTICUT ke
JD-CV-1 Rev. 2-22 ADA accommodations, SUPERIOR COURT
C.G.S. §§ 51-346, 51-347, 51-349, 51-350, 52-45a, 52-48, 52-259;
P.B. §§ 3-1 through 3-21, 8-1, 10-13
contact a court clerk or www jud.ct, gov es
go to: www.jud.ct.gov/ADA.
Instructions are on page 2.
oO Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,500.
[x] Select if amount, legal interest, or property in demand, not including interest and costs, is $2,500 or MORE.
oO Select if claiming other relief in addition to, or in place of, money or damages.
TO: Any proper officer
By authority of the State of Connecticut, you are hereby commanded to make due and legal service of this summons and attached complaint.
‘Address of court clerk (Number, sireef, fown and zip code) Telephone number of clerk Return Date (Mustbe a Tuesday)
54 West Main Street, Meriden, CT 06051 (203 ) 238 - 6666 11/7/2023
Judicial District GA.
Bt (Ciiy/Town) Case type cade (See list on page 2)
(1 Housing Session 1 Number: Meriden Major: V Minor: 01
For the plaintiff(s) enter the appearance of:
Name and address of atiomey, law firm or plaintiff sell-represented (Number, street, town and zip code) Turis number (Fatfomey
or law frm)
The Flood Law Firm, LLC, 190 Washington Street, Middletown, CT 06457 433718
Telephone number Signature of plainiif (i selFrepresenited)
(860 )346 - 2695
The attorney or law firm appearing for the plaintiff, or the plaintiff if E-mail address for delivery of papers under Section 10-13 of the
self-represented, agrees to accept papers (service) electronically
Connecticut Practice Book (if agreed)
in this case under Section 10-13 of the Connecticut Practice Book. [x] Yes [J No legaldocs@thefloodlawfirm.com
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: Vazquez, Silvia P-01
plaintiff Address: 133 Belvedere Drive, Meriden, CT 06450
Additional Name: P-02
plaintiff Address:
First Name: Bryant, Isaiah D-01
defendant Address: : 234 Spring Street, Meriden, CT 06451
Additional Name: D-02
defendant Address:
Additional Name: D-03
defendant Address:
Additional Name: D-04
defendant Address:
Total number of plaintiffs: 4 Total number of defendants: 1 (1 Form JD-CV-2 attached for additional parties
Notice to each defendant
4 You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you.
2. To receive further notices, you or your attorney must file an Appearance (form JD-CL-12) with the clerk at the address above. Generally,
it must be filed on or before the second day after the Return Date. The Return Date is not a hearing date. You do not have to come to
court on the Return Date unless you receive a separate notice telling you to appear.
If you or your attorney do not file an Appearance on time, a default judgment may be entered against you. You can get an Appearance
form at the court address above, or on-line at https://jud.ct.gov/webforms/.
If you believe that you have insurance that may cover the claim being made against you in this lawsuit, you should immediately contact
your insurance representative. Other actions you may take are described in the Connecticut Practice Book, which may be found in a
superior court law library or on-line at https://www.jud.ct.gov/pb.htm.
5; If you have questions about the summons and complaint, you should talk to an attorney.
The court staff is not allowed to give advice on legal matters.
Dale Signed (Sign and select proper box) eZ [x] Commissioner of Superior Court | Name of person signing
10/6/2023 oO Clerk Brian M. Flood, Esq.
If this summons is signed by a Clerk: For Court Use Only
File Dale
a The signing has been done so that the plaintiff(s) will not be denied access to the courts.
b, It is the responsibility of the plaintiff(s) to ensure that service is made in the manner provided by law.
c. The court staff is not permitted to give any legal advice in connection with any lawsuit.
d. The Clerk signing this summons at the request of the plaintiff(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.
Signed (Self-represented plaintif) Dale Docket Number
| certify | have read and
understand the above: NNI-CV-23-6028465-S
Print Form Page 1 of2 Reset Form
DOCKET NO.: NNI-CV-23-6028465-S SUPERIOR COURT
SILVIA VAZQUEZ J.D. OF NEW HAVEN
Vv AT MERIDEN
VANESSA BUCK, ET AL. OCTOBER 6, 2023
NOTICE OF AMENDED COMPLAINT PURSUANT
TO § 52-102b(d) OF THE CONNECTICUT GENERAL STATUTES
Pursuant to Connecticut General Statutes §52-102b(d), the plaintiff in the above-
captioned matter asserts a claim against defendant, Isaiah Bryant, for the reason that he is
or may be liable for all or part of the plaintiff’s injuries, losses and damages. The interests
of Isaiah Bryant are set forth in the Amended Complaint attached hereto.
THE PLAINTIFF,
SILVIA VAZQUEZ
Brian M. Flood
The Flood Law Firm, LLC
190 Washington Street
Middletown, CT 06457
Phone: (860) 346-2695
Juris # 433718
DOCKET NO.: NNI-CV-23-6028465-S SUPERIOR COURT
SILVIA VAZQUEZ J.D. OF NEW HAVEN
Vv. AT MERIDEN
VANESSA BUCK, ET AL. OCTOBER 6, 2023
AMENDED COMPLAINT
FIRST COUNT: (Silvia Vazquez v. Vanessa Buck — Negligence)
1 On February 2, 2022, at approximately 4:00 p.m., the plaintiff, Silvia
Vazquez, was the operator of a motor vehicle that was stopped facing south on Parkway
Place at its intersection with East Main Street, both public streets or highways in Meriden,
Connecticut.
2 At the same time and place, Isaiah Bryant was the operator of a motor vehicle
that was traveling west on East Main Street and had reached its intersection with Parkway
Place and 893 East Main Street.
3. At the same time and place, the defendant, Vanessa Buck, was the owner and
operator of a motor vehicle that was traveling north in the parking lot located at 893 East
Main Street and reached its intersection with East Main Street.
4 At all times mentioned herein, the northbound exit located at the 893 East
Main Street faced a stop sign at its intersection with East Main Street.
5 At the same time and place, the motor vehicle operated by the defendant,
Vanessa Buck, suddenly and without warning entered East Main Street collided with the
motor vehicle operated by Isaiah Bryant, and then collided with the motor vehicle operated
by the plaintiff, Silvia Vazquez, all of which caused the plaintiff, Silvia Vazquez, to suffer
the injuries and losses set forth below.
6 The collisions were caused by the negligence of the defendant, Vanessa
Buck, in one or more of the following ways:
a) she failed to keep a reasonable and proper lookout for
other vehicles on the road;
b) she failed to turn or swerve so as to avoid the collision;
°) she failed to apply the brakes in time to avoid the
collision;
d) she failed to sound the horn or give a timely warning of
the impending collision;
e) she failed to keep the vehicle under proper control;
f) she was inattentive in the operation of the vehicle;
8) she operated the vehicle at a rate of speed greater than
is reasonable, having due regard to the width, traffic,
and use of the highway, road or parking area, the
intersection of streets and weather conditions, in
violation of § 14-218a of the Connecticut General
Statutes;
h) she operated a vehicle so as to obstruct or impede traffic,
in violation of § 14-240(b) of the Connecticut General
Statutes;
i) she failed to stop for the stop sign posted at the
intersection and/or entered the intersection without
yielding the right of way to the vehicle operated by
Isaiah Bryant, in violation of § 14-301(c) of the
Connecticut General Statues;
D she moved the vehicle from a stopped position when it
was unsafe to do so, in violation of§ 14-243(a) of the
Connecticut General Statues;
k) she failed to yield the right-of-way to vehicles on the
public road when entering the roadway from a private
driveway, in violation of § 14-247a of the Connecticut
General Statutes; and/or
) she failed to stop the vehicle before entering a public
street from a private driveway in violation of § 14-247a
of the Connecticut General Statutes.
7 As a result of the collisions, the plaintiff, Silvia Vazquez, suffered the
following injuries, some or all of which may be permanent in nature:
a) headache;
b) cervical sprain/strain;
c) cervical joint restriction and dysfunction;
d) neck pain;
e) cervical radiculopathy;
f) trapezius muscle strain;
8) shoulder pain;
h) lumbar joint restriction and dysfunction;
i) lumbar sprain/strain;
d back pain;
k) aggravation of the injuries suffered in the July 15, 2021
accident; and
) pain and suffering, both mental and physical.
8 As a further result of the collisions, the plaintiff, Silvia Vazquez, was forced
to incur expenses for medical care and treatment, and will likely incur additional expenses
for medical care and treatment in the future.
9 As a further result of the collisions, the plaintiff, Silvia Vazquez, was unable
and remains unable to participate in and enjoy her usual activities.
10. As a further result of the collisions, the motor vehicle owned by the plaintiff,
Silvia Vazquez, was damaged to her financial detriment.
SECOND COUNT: (Silvia Vazquez v. Amazon Logistics, Inc. — Vicarious Liability)
1-10. Paragraphs | through 10 of the First Count are hereby incorporated and made
corresponding paragraphs of this Second Count as if fully set forth herein.
ll. At all times mentioned herein, the defendant, Amazon Logistics, Inc., was
and is a Delaware corporation with its business address located at 410 Terry Avenue North
in Seattle, Washington.
12. At all times mentioned herein, the defendant, Amazon Logistics, Inc., owned
the motor vehicle operated by Vanessa Buck.
13. At all times mentioned herein, Vanessa Buck was operating the motor vehicle
with the permission of the defendant, Amazon Logistics, Inc.
14. At all times mentioned herein, Vanessa Buck was operating the motor vehicle
as the agent, servant and/or employee of the defendant, Amazon Logistics, Inc.
15. Atall timed mentioned herein, Vanessa Buck was operating the motor vehicle
as the agent of the defendant, Amazon Logistics, Inc., pursuant to Connecticut General
Statutes § 52-183.
THIRD COUNT: (Silvia Vazquez v. MAD Logistics LLC — Vicarious Liability)
1-10. Paragraphs | through 10 of the First Count are hereby incorporated and made
corresponding paragraphs of this Third Count as if fully set forth herein.
lL. At all times mentioned herein, the defendant, MAD Logistics LLC, was and
is a Connecticut limited liability company with its business address located at 974 Old
Durham Road in Wallingford, Connecticut.
12. At all times mentioned herein, the defendant, MAD Logistics LLC, owned
the motor vehicle operated by Vanessa Buck.
13. At all times mentioned herein, Vanessa Buck was operating the motor vehicle
with the permission of the defendant, MAD Logistics LLC.
14. Atall times mentioned herein, Vanessa Buck was operating the motor vehicle
as the agent, servant and/or employee of the defendant, MAD Logistics LLC.
15. Atall timed mentioned herein, Vanessa Buck was operating the motor vehicle
as the agent of the defendant, MAD Logistics LLC, pursuant to Connecticut General
Statutes § 52-183.
FOURTH COUNT: (Silvia Vazquez v. Isaiah Bryant)
1 On July 17, 2023, the defendants Vanessa Buck and MAD Logistics LLC,
filed an apportionment complaint against Isaiah Bryant claiming that Isaiah Bryant is
liable for the plaintiff’s injuries.
2. In the event the jury finds against the apportionment defendant Isaiah
Bryant in accordance with the claims of negligence asserted in the apportionment
complaint, and in order to protect her rights, the plaintiff, Silvia Vazquez, hereby
asserts a claim against the apportionment defendant, Isaiah Bryant, pursuant to §52-
102b of the Connecticut General Statutes.
3 On February 2, 2022, at approximately 4:00 p.m., the plaintiff, Silvia
Vazquez, was the operator of a motor vehicle that was stopped facing south on Parkway
Place at its intersection with East Main Street, both public streets or highways in Meriden,
Connecticut.
4 At the same time and place, Isaiah Bryant was the operator of a motor vehicle
that was traveling west on East Main Street and had reached its intersection with Parkway
Place and 893 East Main Street.
5 At the same time and place, the defendant, Vanessa Buck, was the operator
of a motor vehicle that was traveling north in the parking lot located at 893 East Main
Street and reached its intersection with East Main Street.
6 At all times mentioned herein, the northbound exit located at the 893 East
Main Street faced a stop sign at its intersection with East Main Street.
7
At the same time and place, the motor vehicle operated by the defendant,
Vanessa Buck, entered East Main Street and collided with the motor vehicle operated by
Isaiah Bryant which then caused the motor vehicle operated by Vanessa Buck to collide
with the motor vehicle operated by the plaintiff, Silvia Vazquez, all of which her to suffer
the injuries and losses set forth below.
8 The collisions were caused by the negligence of the defendant, Isaiah Bryant,
in one or more of the following ways:
a) he failed to keep a reasonable and proper lookout for
other vehicles on the road;
b) he failed to turn or swerve so as to avoid the collision;
c) he failed to apply the brakes in time to avoid the
collision;
d) he failed to sound the horn or give a timely warning of
the impending collision;
e) he failed to keep the vehicle under proper control;
he was inattentive in the operation of the vehicle; and/or
g) he operated the vehicle at a rate of speed greater than is
reasonable, having due regard to the width, traffic, and
use of the highway, road or parking area, the
intersection of streets and weather conditions, in
violation of § 14-218a of the Connecticut General
Statutes.
9 As a result of the collisions, the plaintiff, Silvia Vazquez, suffered the
following injuries, some or all of which may be permanent in nature:
a) headache;
b) cervical sprain/strain;
°) cervical joint restriction and dysfunction;
qd) neck pain;
g) cervical radiculopathy;
f) trapezius muscle strain;
8) shoulder pain;
h) lumbar joint restriction and dysfunction;
i) lumbar sprain/strain;
D back pain;
k) aggravation of the injuries suffered in the July 15, 2021
accident; and
) pain and suffering, both mental and physical.
10. As a further result of the collisions, the plaintiff, Silvia Vazquez, was forced
to incur expenses for medical care and treatment, and will likely incur additional expenses
for medical care and treatment in the future.
11. As a further result of the collisions, the plaintiff, Silvia Vazquez, was unable
and remains unable to participate in and enjoy her usual activities.
12. Asa further result of the collisions, the motor vehicle owned by the plaintiff,
Silvia Vazquez, was damaged to her financial detriment.
WHEREFORE, the plaintiff claims:
1 Monetary damages.
THE PLAINTIFF,
SILVIA VAZQUEZ
Te
Brian M. Flood
The Flood Law Firm, LLC
190 Washington Street
Middletown, CT 06457
Phone: (860) 346-2695
Juris #433718
DOCKET NO.: NNI-CV-23-6028465-S SUPERIOR COURT
SILVIA VAZQUEZ J.D. OF NEW HAVEN
V. AT MERIDEN
VANESSA BUCK, ET AL. OCTOBER 6, 2023
STATEMENT OF AMOUNT IN DEMAND
The amount of money damages claimed is greater than Fifteen Thousand Dollars
($15,000.00), exclusive of interest and costs.
THE PLAINTIFF,
SILVIA VAZQUEZ
Te
Brian M. Flood
The Flood Law Firm, LLC
190 Washington Street
Middletown, CT 06457
Phone: (860) 346-2695
Juris #433718
|
STATE MARSHAL RETURN
STATE OF CONNECTICUT )
) ss: Meriden Octaber 10, 2023
COUNTY OF NEW HAVEN )
Then and there by virtue hereof and at the special direction of the plaintiff ‘sAttorney on October 10,
2023, I made due and legal service by leaving a true and attested copy of the within Summons, Notice
of
Amended Complaint Pursuant to §52-102b(d) of the Connecticut General Statutes, Amer ided and Statement
of
Amount in Demand with my doings endorsed thereon at the usual Place of abode of ISAIAH BRYANT at
234
Spring Street, Meriden, CT.
(Note: I confirmed the defendant’s address with the USPS) |
The within and foregoing is the original Summons, Notice of; Amended Complaint Pursuant to §52-
102b(d) of the Connecticut General Statutes, Amended and Statement of Amount in Demand with my doings
endorsed hereon.
ATTEST:
A itMW i
QUA
THOMAS G, STATE ARSHAL
Fees:
Basic: 50.00
Travel: 26.00
Copies: 12.00
End 1.00
Total: 89.00
SUMMONS - CIVIL For information on
JD-CV-1_ Rev, 2-22 STATE OF CONNECTICUT
ADA accommodations,
C.GS. §§ 51-346, 51-347, 51-349, 51-350, 52-45a, 52-48, 52-259; contact a court clerk or
SUPERIOR COURT
P.B. §§ 341 through 3-21, 8-1, 10-13 www jud.ct.gov <
go to: www.jud.ct.gov/ADA.
Instructions are on page 2.
CO Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,501 RECEIVE
[x] Select if amount, legal interest, or property in demand, not including interest and costs, is $2,500 or MORE.
C1 Select if claiming other relief in addition to, or in place of, money or damages.
AUG 3 RECD
TO: Any proper officer OFFICE OF STATE MARSHAL
By authority of the State of Connecticut, you are hereby commanded to make due and legal service of this
cummane Bee ahs ARINAN int
‘Address of court clerk (Number, street, town and zip code) Telephone number of clerk Return Date (Must be a Tuesday)
54 WEST MAIN STREET, MERIDEN, CT 06451 (203 ) 238 —6667 09/12/2023
[xX] Judicial District GA. ‘At (City/Town) Case type code (See list on page 2)
(2 Housing Session C1 Number: MERIDEN Major: Minor:
For the plaintiff(s) enter the appearance of:
Name and address of attomey, law firm or plaintiff if self-representod (Number, street, town and zip code) ‘Juris number (if attorney or law firm)
EDWARD W. CASE, ESQ., 21 OAK STREET, SUITE 60, HARTFOD, CT 06106 102274
Telephone number ‘Signature of piainliff (iseiF-represented)
(860 )525 - 4461
The attorney or law firm appearing for the plaintiff, or the plaintiff if E-mail address for deli of f papers under Section 10-13 of the
self-represented, agrees to accept papers (service) electronically Connecticut Practice Book (if agreed)
in this case under Section 10-13 oft he Connecticut Practice Book. [L_] Yes [] No geracelegal@gmail.com
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: BRYANT, ISAIAH NOAH
plaintiff Address: 234 SPRING STREET, MERIDEN, CT 06451 Pot
Additional Name:
plaintiff Address: P-02
First Name: BUCK, VANESSA
defendant Address: : 522 POMEROY AVENUE, MERIDEN, CT 06450 D-01
Additional Name: AMAZON LOGISTICS LLC, 974 OLD DURHAM ROAD, WALLINGFORD, CT 06492
defendant Address: : Agent: Corporation Service Company, Goodwin Sq., 225 Asylum St., 20th Fir, Hartford, CT 06103 D02
Additional Na MAD LOGISTICS LLC, 974 OLD DURHAM ROAD, WALLINGFORD, CT 06492
defendant Address: : Agent: Matthew Oneto, 974 Old Durham Road, Wallingford, CT 06492 D-03
Additional Name:
defendant Address: D-04
Total number of plaintiffs: 4 Total number of defendants: 3 (J Form JD-CV-2 attached for additional parties
Notice to each defendant
1 You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you.
2. To receive further notices, you or your attorney must file an A, \ppearance (form JD-CL-12) with the clerk at the address above. Generally,
it must be filed on or before the second day >">" th= Peters Nate The Paturn Nate ic nota hearing date You do not have to come to
court on the Return Date you receivi
rps do on b Appos BS le) Sele) er a on go) lea ay Le) Rel Voalg
RSH Sen I) aU ® Complete items 1, 2, and 3. A. Signature
ott PN en 1d =i | oo ™ Print your name and address on the reverse SZ —T
TUE A EUR rent
so that we can return the card to you.
1 Addressee
SO 1 orAtach this card to the back of the maipiece, B, Received
by (Printed Name)
(
Caitied Wal Fee
r
~ -
-1¢
t y
4
oT
on the front if space permits.
Brtinia Arleressed to: D. Is delivery address different from item 1? 11 Yes
is
If YES, enter delivery address below: [] No
|Exira Services & Fees (chock box, add feo as appropriate) Vanessa Buck
Retumn Receipt haricopy)
[C)retun Receipt electronic) 522 Pomeroy Ave
‘|
8
i centied Mail Restricted Oetivary Meriden, Ct 06450
DAdut signature Required
Ci Adut Signature Restricted Delivery
Postage
ll VAN A
> Som Vanessa Buck 3. Service Type
[Total Pe O Priority Mail Express®
p ceraas toa
522 Pomeroy Ave D Adult Signature istered Mail™
istered Mall Restrictes
‘Sent To Meriden, Ct 06450 9590 9402 8195 3030 1752 82 ‘O Certified
Mail Restricted very
D Signature Confirmation™
OG [siete O Collect
on Del Di Signature Confirmation
2, Article Number (Transfer from service label) 1 Collect
on Delivery Restricted Delivery Restricted Delivary
Ci Sti ?Oe2 2410 OO02 9587 140k Mail Restricted Delivery
PELs i m eect PS Form 3811, July 2020 Psn 7530-02-000-9053
Domestic Return Receipt
|| SUPERIOR COURT
RETURN DATE: SEPTEMBER 12, 2023
ISAIAH NOAH BRYANT J.D. OF MERIDEN
v AT MERIDEN
VANESSA ALEXIS BUCK JULY 25, 2023
AMAZON LOGISTICS INC.
MAD LOGISTICS, LLC
COMPLAINT
FIRST COUNT: (Isaiah Bryant v. Vanessa Buck —Negligence)
1 On or about February 2, 2022, at approximately 4:00 p.m., the plaintiff, Isaiah Noah
Bryant, was operating his motor vehicle westerly on East Main Street, in front of the intersection of
Parkway Place and 893 East Main Street, having the right-of-way and proceeding through the
intersection in Meriden, Connecticut.
2 On said date and at said time and place, the defendant, Vanessa Alexis Buck, was
|
| operating a motor vehicle owned by defendant Amazon Logistics Inc. and/or MAD Logistics Inc.,
|
|| stopped at the stop sign northbound on Parkway Place and East Main when, without warning or
notice, she drove out directly into the right —of way of the plaintiff .
3 On said date and at said time and place, the motor vehicle operated by the defendant
GERACE & ASSOCIATES
ATTORNEYS AT LAW
21 OAK STREET - SUITE 604 + HARTFORD, CONNECTICUT 06106 - (860) 525-4461 + FAX (860) 527-2439 » JURIS NO. 102274
| violently collided with the driver’s side front end of the motor vehicle operated by the plaintiff, and
| then head- on into a third vehicle operated by Silvia Vazquez, stopped southbound in the parking
| lot at 893 East Main Street at the stop sign located there.
4 Said collision caused the plaintiff to suffer the injuries and losses as more
|
| particularly set forth hereinafter.
5 The injuries and losses suffered by the plaintiffs were caused by the negligence and
|
|
carelessness of the defendant in one or more of the following ways:
| |
|
a. IN THAT she operated said motor vehicle at a rate of speed greater than was
reasonable having regard for the width, traffic and use of the highway and the weather conditions,
| in violation of General Statute §14-218a;
|
b, IN THAT she operated said motor vehicle at a greater rate of speed than was
||
|
| reasonable under the circumstances then and there existing;
| Cc. IN THAT she did not have said motor vehicle under proper and reasonable control;
|
d IN THAT she failed to pay attention to the traffic ahead or to keep a reasonable and
| proper lookout;
e IN THAT she failed to apply her brakes and stop, when she knew or should have
known that a collision with the vehicle in front was imminent;
| f. IN THAT she was failed to grant the right of way, in violation of General Statutes
| §14-247 et seq.;
g IN THAT she failed to stop the vehicle before entering a public s
Preview
DOCKET NO: NNI-CV-23-6028465-S SUPERIOR COURT SILVIA VAZQUEZ J.D. OF NEW HAVEN vs. AT MERIDEN VANESSA BUCK, ET AL FEBRUARY 1, 2024 MOTION TO CONSOLIDATE Pursuant to Section 9-5 of the Connecticut Practice Book, as amended, the undersigned defendants, Vanessa Buck, Amazon Logistics, Inc., and MAD Logistics, LLC, hereby respectfully move this Court to consolidate the following cases: Silvia Vazquez v. Vanessa Buck, et al. (Docket No. NNI-CV23-6028465-S) and Isaiah Bryant v. Vanessa Buck, et al. (Docket No. NNI-CV23-6029918-S). A corresponding Motion to Consolidate is also being filed in the related case. The undersigned defendants certify that the instant motion was served on all parties to both of these actions in accordance with Sections 10-12 through 10-17 of the Connecticut Practice Book. In support of this Motion, the undersigned states that these two cases arise from the same motor vehicle accident that occurred at the intersection of East Main Street and Parkway Place in Meriden, Connecticut. (Gee Complaints from each action, attached hereto as Exhibit A). In the matter of Silvia Vazquez v. Vanessa Buck, etal., Ms. Vazquez alleges that Ms. Buck negligently caused the subject motor vehicle accident, and that Ms. Vazquez was injured as a result. In the matter of Isaiah Bryant v. Vanessa Buck, et al., Mr. Bryant similarly alleges that Ms. Buck negligently caused the subject motor vehicle accident, and that Mr. Bryant was injured as a result. The question of liability in each action stems from the same accident and involves the same witnesses and parties. Consequently, each action involves the same or similar Ln HALLORAN Halloran & Sage LLP Phone 860.522.6103 225 Asylum Street Fax 860.548.0006 Hartford, CT 06103 SAGE Juris No. 026105 IMANAGE\29647\0002\9009676.v1-2/1/24 issues concerning liability and would involve only differing issues when it came to determining damages, if any, for each party. Accordingly, it would be in the interest of judicial economy to consolidate these cases for the purposes of discovery and trial. Practice Book Section 9-5 provides that “[w]henever there are two or more separate actions which should be tried together, the judicial authority may, upon motion of any party or upon its own motion, order that the actions be consolidated for trial." Case law in Connecticut is clear that consolidation in matters such as those before the Court is appropriate. “Independent of statutory authority, courts of general jurisdiction have inherent power to consolidate different causes, or order them tried together, when the circumstances authorize such course; and unless otherwise provided by statute, questions respecting such procedure are addressed to the discretion of the trial court, and its action will not be revised unless an abuse of discretion clearly appears." Rode v. Adley Express Co., 130 Conn. 274, 277 (1943). “[T]he public has an interest in the prevention of unnecessary litigation, both because of the burden it places on the State and the resulting crowding of the dockets of the courts. This procedure of trying cases together, which has long been the established practice in this state, assists in expediting business without doing anyone an injustice." Groth v. Redmond, 24 Conn. Supp. 467, 469 (Conn. App. Ct. 1962). The cases which the undersigned defendants seek to consolidate arise from the exact same accident, involve the same parties, involve the same witnesses, and involve the same questions of liability. If consolidated, one jury will be able to make a determination as to liability and damages as opposed to having the same action tried by -2- Ln HALLORAN Halloran & Sage LLP Phone 860.522.6103 225 Asylum Street Fax 860.548.0006 Hartford, CT 06103 SAGE Juris No. 026105 IMANAGE\29647\0002\9012227.v1-2/1/24 two separate juries. Trying these cases together will prevent the Court from wasting limited resources and will prevent any potential incongruent factual determinations based on the same set of facts. In sum, consolidating these actions will expedite the Court’s business, avoid two trials over the same factual questions, and will not unduly burden the parties in any way. WHEREFORE, for all of the foregoing reasons, the undersigned defendants respectfully request that this Motion to Consolidate be granted. THE DEFENDANTS, VANESSA BUCK, AMAZON LOGISTICS, INC., AND MAD LOGISTICS LLC By:445126 Kevin M. Roche Christopher B. Wiezbicki HALLORAN & SAGE LLP 225 Asylum Street Hartford, Connecticut 06103 J uris No.026105 Their attorneys -3- Ln HALLORAN Halloran & Sage LLP Phone 860.522.6103 225 Asylum Street Fax 860.548.0006 Hartford, CT 06103 SAGE Juris No. 026105 IMANAGE\29647\0002\9012227.v1-2/1/24 CERTIFICATION This is to certify that on this 1st day of February 2024, a copy of the foregoing was either mailed, postage prepaid, sent via electronic mail, or hand-delivered to: Brian M. Flood, Esq. The Flood Law Firm, LLC 190 Washington Street Middletown, CT 06457 legaldocs@ thefloodlawfirm.com For the Plaintiff Sean Carew, Esq. Law Offices of Meehan, Di Palma, Roberts & Turret 108 Leigus Road, 1st Floor Wallingford, CT 06492 LMLAWCT@libertymutual.com For the Defendant, Isaiah Bryant 445126 Christopher B. Wiezbicki wiezbicki@ halloransage.com -4- Ln HALLORAN Halloran & Sage LLP Phone 860.522.6103 225 Asylum Street Fax 860.548.0006 Hartford, CT 06103 SAGE Juris No. 026105 IMANAGE\29647\0002\9012227.v1-2/1/24 EXHIBIT A -5- Ln HALLORAN Halloran & Sage LLP Phone 860.522.6103 treet Fax 860.548.0006 06103 SAGE Juris No. 026105 IMANAGE\29647\0002\9012227.v1-2/1/24 SUMMONS - CIVIL For information on STATE OF CONNECTICUT ke JD-CV-1 Rev. 2-22 ADA accommodations, SUPERIOR COURT C.G.S. §§ 51-346, 51-347, 51-349, 51-350, 52-45a, 52-48, 52-259; P.B. §§ 3-1 through 3-21, 8-1, 10-13 contact a court clerk or www jud.ct, gov es go to: www.jud.ct.gov/ADA. Instructions are on page 2. oO Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,500. [x] Select if amount, legal interest, or property in demand, not including interest and costs, is $2,500 or MORE. oO Select if claiming other relief in addition to, or in place of, money or damages. TO: Any proper officer By authority of the State of Connecticut, you are hereby commanded to make due and legal service of this summons and attached complaint. ‘Address of court clerk (Number, sireef, fown and zip code) Telephone number of clerk Return Date (Mustbe a Tuesday) 54 West Main Street, Meriden, CT 06051 (203 ) 238 - 6666 11/7/2023 Judicial District GA. Bt (Ciiy/Town) Case type cade (See list on page 2) (1 Housing Session 1 Number: Meriden Major: V Minor: 01 For the plaintiff(s) enter the appearance of: Name and address of atiomey, law firm or plaintiff sell-represented (Number, street, town and zip code) Turis number (Fatfomey or law frm) The Flood Law Firm, LLC, 190 Washington Street, Middletown, CT 06457 433718 Telephone number Signature of plainiif (i selFrepresenited) (860 )346 - 2695 The attorney or law firm appearing for the plaintiff, or the plaintiff if E-mail address for delivery of papers under Section 10-13 of the self-represented, agrees to accept papers (service) electronically Connecticut Practice Book (if agreed) in this case under Section 10-13 of the Connecticut Practice Book. [x] Yes [J No legaldocs@thefloodlawfirm.com 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: Vazquez, Silvia P-01 plaintiff Address: 133 Belvedere Drive, Meriden, CT 06450 Additional Name: P-02 plaintiff Address: First Name: Bryant, Isaiah D-01 defendant Address: : 234 Spring Street, Meriden, CT 06451 Additional Name: D-02 defendant Address: Additional Name: D-03 defendant Address: Additional Name: D-04 defendant Address: Total number of plaintiffs: 4 Total number of defendants: 1 (1 Form JD-CV-2 attached for additional parties Notice to each defendant 4 You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you. 2. To receive further notices, you or your attorney must file an Appearance (form JD-CL-12) with the clerk at the address above. Generally, it must be filed on or before the second day after the Return Date. The Return Date is not a hearing date. You do not have to come to court on the Return Date unless you receive a separate notice telling you to appear. If you or your attorney do not file an Appearance on time, a default judgment may be entered against you. You can get an Appearance form at the court address above, or on-line at https://jud.ct.gov/webforms/. If you believe that you have insurance that may cover the claim being made against you in this lawsuit, you should immediately contact your insurance representative. Other actions you may take are described in the Connecticut Practice Book, which may be found in a superior court law library or on-line at https://www.jud.ct.gov/pb.htm. 5; If you have questions about the summons and complaint, you should talk to an attorney. The court staff is not allowed to give advice on legal matters. Dale Signed (Sign and select proper box) eZ [x] Commissioner of Superior Court | Name of person signing 10/6/2023 oO Clerk Brian M. Flood, Esq. If this summons is signed by a Clerk: For Court Use Only File Dale a The signing has been done so that the plaintiff(s) will not be denied access to the courts. b, It is the responsibility of the plaintiff(s) to ensure that service is made in the manner provided by law. c. The court staff is not permitted to give any legal advice in connection with any lawsuit. d. The Clerk signing this summons at the request of the plaintiff(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. Signed (Self-represented plaintif) Dale Docket Number | certify | have read and understand the above: NNI-CV-23-6028465-S Print Form Page 1 of2 Reset Form DOCKET NO.: NNI-CV-23-6028465-S SUPERIOR COURT SILVIA VAZQUEZ J.D. OF NEW HAVEN Vv AT MERIDEN VANESSA BUCK, ET AL. OCTOBER 6, 2023 NOTICE OF AMENDED COMPLAINT PURSUANT TO § 52-102b(d) OF THE CONNECTICUT GENERAL STATUTES Pursuant to Connecticut General Statutes §52-102b(d), the plaintiff in the above- captioned matter asserts a claim against defendant, Isaiah Bryant, for the reason that he is or may be liable for all or part of the plaintiff’s injuries, losses and damages. The interests of Isaiah Bryant are set forth in the Amended Complaint attached hereto. THE PLAINTIFF, SILVIA VAZQUEZ Brian M. Flood The Flood Law Firm, LLC 190 Washington Street Middletown, CT 06457 Phone: (860) 346-2695 Juris # 433718 DOCKET NO.: NNI-CV-23-6028465-S SUPERIOR COURT SILVIA VAZQUEZ J.D. OF NEW HAVEN Vv. AT MERIDEN VANESSA BUCK, ET AL. OCTOBER 6, 2023 AMENDED COMPLAINT FIRST COUNT: (Silvia Vazquez v. Vanessa Buck — Negligence) 1 On February 2, 2022, at approximately 4:00 p.m., the plaintiff, Silvia Vazquez, was the operator of a motor vehicle that was stopped facing south on Parkway Place at its intersection with East Main Street, both public streets or highways in Meriden, Connecticut. 2 At the same time and place, Isaiah Bryant was the operator of a motor vehicle that was traveling west on East Main Street and had reached its intersection with Parkway Place and 893 East Main Street. 3. At the same time and place, the defendant, Vanessa Buck, was the owner and operator of a motor vehicle that was traveling north in the parking lot located at 893 East Main Street and reached its intersection with East Main Street. 4 At all times mentioned herein, the northbound exit located at the 893 East Main Street faced a stop sign at its intersection with East Main Street. 5 At the same time and place, the motor vehicle operated by the defendant, Vanessa Buck, suddenly and without warning entered East Main Street collided with the motor vehicle operated by Isaiah Bryant, and then collided with the motor vehicle operated by the plaintiff, Silvia Vazquez, all of which caused the plaintiff, Silvia Vazquez, to suffer the injuries and losses set forth below. 6 The collisions were caused by the negligence of the defendant, Vanessa Buck, in one or more of the following ways: a) she failed to keep a reasonable and proper lookout for other vehicles on the road; b) she failed to turn or swerve so as to avoid the collision; °) she failed to apply the brakes in time to avoid the collision; d) she failed to sound the horn or give a timely warning of the impending collision; e) she failed to keep the vehicle under proper control; f) she was inattentive in the operation of the vehicle; 8) she operated the vehicle at a rate of speed greater than is reasonable, having due regard to the width, traffic, and use of the highway, road or parking area, the intersection of streets and weather conditions, in violation of § 14-218a of the Connecticut General Statutes; h) she operated a vehicle so as to obstruct or impede traffic, in violation of § 14-240(b) of the Connecticut General Statutes; i) she failed to stop for the stop sign posted at the intersection and/or entered the intersection without yielding the right of way to the vehicle operated by Isaiah Bryant, in violation of § 14-301(c) of the Connecticut General Statues; D she moved the vehicle from a stopped position when it was unsafe to do so, in violation of§ 14-243(a) of the Connecticut General Statues; k) she failed to yield the right-of-way to vehicles on the public road when entering the roadway from a private driveway, in violation of § 14-247a of the Connecticut General Statutes; and/or ) she failed to stop the vehicle before entering a public street from a private driveway in violation of § 14-247a of the Connecticut General Statutes. 7 As a result of the collisions, the plaintiff, Silvia Vazquez, suffered the following injuries, some or all of which may be permanent in nature: a) headache; b) cervical sprain/strain; c) cervical joint restriction and dysfunction; d) neck pain; e) cervical radiculopathy; f) trapezius muscle strain; 8) shoulder pain; h) lumbar joint restriction and dysfunction; i) lumbar sprain/strain; d back pain; k) aggravation of the injuries suffered in the July 15, 2021 accident; and ) pain and suffering, both mental and physical. 8 As a further result of the collisions, the plaintiff, Silvia Vazquez, was forced to incur expenses for medical care and treatment, and will likely incur additional expenses for medical care and treatment in the future. 9 As a further result of the collisions, the plaintiff, Silvia Vazquez, was unable and remains unable to participate in and enjoy her usual activities. 10. As a further result of the collisions, the motor vehicle owned by the plaintiff, Silvia Vazquez, was damaged to her financial detriment. SECOND COUNT: (Silvia Vazquez v. Amazon Logistics, Inc. — Vicarious Liability) 1-10. Paragraphs | through 10 of the First Count are hereby incorporated and made corresponding paragraphs of this Second Count as if fully set forth herein. ll. At all times mentioned herein, the defendant, Amazon Logistics, Inc., was and is a Delaware corporation with its business address located at 410 Terry Avenue North in Seattle, Washington. 12. At all times mentioned herein, the defendant, Amazon Logistics, Inc., owned the motor vehicle operated by Vanessa Buck. 13. At all times mentioned herein, Vanessa Buck was operating the motor vehicle with the permission of the defendant, Amazon Logistics, Inc. 14. At all times mentioned herein, Vanessa Buck was operating the motor vehicle as the agent, servant and/or employee of the defendant, Amazon Logistics, Inc. 15. Atall timed mentioned herein, Vanessa Buck was operating the motor vehicle as the agent of the defendant, Amazon Logistics, Inc., pursuant to Connecticut General Statutes § 52-183. THIRD COUNT: (Silvia Vazquez v. MAD Logistics LLC — Vicarious Liability) 1-10. Paragraphs | through 10 of the First Count are hereby incorporated and made corresponding paragraphs of this Third Count as if fully set forth herein. lL. At all times mentioned herein, the defendant, MAD Logistics LLC, was and is a Connecticut limited liability company with its business address located at 974 Old Durham Road in Wallingford, Connecticut. 12. At all times mentioned herein, the defendant, MAD Logistics LLC, owned the motor vehicle operated by Vanessa Buck. 13. At all times mentioned herein, Vanessa Buck was operating the motor vehicle with the permission of the defendant, MAD Logistics LLC. 14. Atall times mentioned herein, Vanessa Buck was operating the motor vehicle as the agent, servant and/or employee of the defendant, MAD Logistics LLC. 15. Atall timed mentioned herein, Vanessa Buck was operating the motor vehicle as the agent of the defendant, MAD Logistics LLC, pursuant to Connecticut General Statutes § 52-183. FOURTH COUNT: (Silvia Vazquez v. Isaiah Bryant) 1 On July 17, 2023, the defendants Vanessa Buck and MAD Logistics LLC, filed an apportionment complaint against Isaiah Bryant claiming that Isaiah Bryant is liable for the plaintiff’s injuries. 2. In the event the jury finds against the apportionment defendant Isaiah Bryant in accordance with the claims of negligence asserted in the apportionment complaint, and in order to protect her rights, the plaintiff, Silvia Vazquez, hereby asserts a claim against the apportionment defendant, Isaiah Bryant, pursuant to §52- 102b of the Connecticut General Statutes. 3 On February 2, 2022, at approximately 4:00 p.m., the plaintiff, Silvia Vazquez, was the operator of a motor vehicle that was stopped facing south on Parkway Place at its intersection with East Main Street, both public streets or highways in Meriden, Connecticut. 4 At the same time and place, Isaiah Bryant was the operator of a motor vehicle that was traveling west on East Main Street and had reached its intersection with Parkway Place and 893 East Main Street. 5 At the same time and place, the defendant, Vanessa Buck, was the operator of a motor vehicle that was traveling north in the parking lot located at 893 East Main Street and reached its intersection with East Main Street. 6 At all times mentioned herein, the northbound exit located at the 893 East Main Street faced a stop sign at its intersection with East Main Street. 7 At the same time and place, the motor vehicle operated by the defendant, Vanessa Buck, entered East Main Street and collided with the motor vehicle operated by Isaiah Bryant which then caused the motor vehicle operated by Vanessa Buck to collide with the motor vehicle operated by the plaintiff, Silvia Vazquez, all of which her to suffer the injuries and losses set forth below. 8 The collisions were caused by the negligence of the defendant, Isaiah Bryant, in one or more of the following ways: a) he failed to keep a reasonable and proper lookout for other vehicles on the road; b) he failed to turn or swerve so as to avoid the collision; c) he failed to apply the brakes in time to avoid the collision; d) he failed to sound the horn or give a timely warning of the impending collision; e) he failed to keep the vehicle under proper control; he was inattentive in the operation of the vehicle; and/or g) he operated the vehicle at a rate of speed greater than is reasonable, having due regard to the width, traffic, and use of the highway, road or parking area, the intersection of streets and weather conditions, in violation of § 14-218a of the Connecticut General Statutes. 9 As a result of the collisions, the plaintiff, Silvia Vazquez, suffered the following injuries, some or all of which may be permanent in nature: a) headache; b) cervical sprain/strain; °) cervical joint restriction and dysfunction; qd) neck pain; g) cervical radiculopathy; f) trapezius muscle strain; 8) shoulder pain; h) lumbar joint restriction and dysfunction; i) lumbar sprain/strain; D back pain; k) aggravation of the injuries suffered in the July 15, 2021 accident; and ) pain and suffering, both mental and physical. 10. As a further result of the collisions, the plaintiff, Silvia Vazquez, was forced to incur expenses for medical care and treatment, and will likely incur additional expenses for medical care and treatment in the future. 11. As a further result of the collisions, the plaintiff, Silvia Vazquez, was unable and remains unable to participate in and enjoy her usual activities. 12. Asa further result of the collisions, the motor vehicle owned by the plaintiff, Silvia Vazquez, was damaged to her financial detriment. WHEREFORE, the plaintiff claims: 1 Monetary damages. THE PLAINTIFF, SILVIA VAZQUEZ Te Brian M. Flood The Flood Law Firm, LLC 190 Washington Street Middletown, CT 06457 Phone: (860) 346-2695 Juris #433718 DOCKET NO.: NNI-CV-23-6028465-S SUPERIOR COURT SILVIA VAZQUEZ J.D. OF NEW HAVEN V. AT MERIDEN VANESSA BUCK, ET AL. OCTOBER 6, 2023 STATEMENT OF AMOUNT IN DEMAND The amount of money damages claimed is greater than Fifteen Thousand Dollars ($15,000.00), exclusive of interest and costs. THE PLAINTIFF, SILVIA VAZQUEZ Te Brian M. Flood The Flood Law Firm, LLC 190 Washington Street Middletown, CT 06457 Phone: (860) 346-2695 Juris #433718 | STATE MARSHAL RETURN STATE OF CONNECTICUT ) ) ss: Meriden Octaber 10, 2023 COUNTY OF NEW HAVEN ) Then and there by virtue hereof and at the special direction of the plaintiff ‘sAttorney on October 10, 2023, I made due and legal service by leaving a true and attested copy of the within Summons, Notice of Amended Complaint Pursuant to §52-102b(d) of the Connecticut General Statutes, Amer ided and Statement of Amount in Demand with my doings endorsed thereon at the usual Place of abode of ISAIAH BRYANT at 234 Spring Street, Meriden, CT. (Note: I confirmed the defendant’s address with the USPS) | The within and foregoing is the original Summons, Notice of; Amended Complaint Pursuant to §52- 102b(d) of the Connecticut General Statutes, Amended and Statement of Amount in Demand with my doings endorsed hereon. ATTEST: A itMW i QUA THOMAS G, STATE ARSHAL Fees: Basic: 50.00 Travel: 26.00 Copies: 12.00 End 1.00 Total: 89.00 SUMMONS - CIVIL For information on JD-CV-1_ Rev, 2-22 STATE OF CONNECTICUT ADA accommodations, C.GS. §§ 51-346, 51-347, 51-349, 51-350, 52-45a, 52-48, 52-259; contact a court clerk or SUPERIOR COURT P.B. §§ 341 through 3-21, 8-1, 10-13 www jud.ct.gov < go to: www.jud.ct.gov/ADA. Instructions are on page 2. CO Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,501 RECEIVE [x] Select if amount, legal interest, or property in demand, not including interest and costs, is $2,500 or MORE. C1 Select if claiming other relief in addition to, or in place of, money or damages. AUG 3 RECD TO: Any proper officer OFFICE OF STATE MARSHAL By authority of the State of Connecticut, you are hereby commanded to make due and legal service of this cummane Bee ahs ARINAN int ‘Address of court clerk (Number, street, town and zip code) Telephone number of clerk Return Date (Must be a Tuesday) 54 WEST MAIN STREET, MERIDEN, CT 06451 (203 ) 238 —6667 09/12/2023 [xX] Judicial District GA. ‘At (City/Town) Case type code (See list on page 2) (2 Housing Session C1 Number: MERIDEN Major: Minor: For the plaintiff(s) enter the appearance of: Name and address of attomey, law firm or plaintiff if self-representod (Number, street, town and zip code) ‘Juris number (if attorney or law firm) EDWARD W. CASE, ESQ., 21 OAK STREET, SUITE 60, HARTFOD, CT 06106 102274 Telephone number ‘Signature of piainliff (iseiF-represented) (860 )525 - 4461 The attorney or law firm appearing for the plaintiff, or the plaintiff if E-mail address for deli of f papers under Section 10-13 of the self-represented, agrees to accept papers (service) electronically Connecticut Practice Book (if agreed) in this case under Section 10-13 oft he Connecticut Practice Book. [L_] Yes [] No geracelegal@gmail.com 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: BRYANT, ISAIAH NOAH plaintiff Address: 234 SPRING STREET, MERIDEN, CT 06451 Pot Additional Name: plaintiff Address: P-02 First Name: BUCK, VANESSA defendant Address: : 522 POMEROY AVENUE, MERIDEN, CT 06450 D-01 Additional Name: AMAZON LOGISTICS LLC, 974 OLD DURHAM ROAD, WALLINGFORD, CT 06492 defendant Address: : Agent: Corporation Service Company, Goodwin Sq., 225 Asylum St., 20th Fir, Hartford, CT 06103 D02 Additional Na MAD LOGISTICS LLC, 974 OLD DURHAM ROAD, WALLINGFORD, CT 06492 defendant Address: : Agent: Matthew Oneto, 974 Old Durham Road, Wallingford, CT 06492 D-03 Additional Name: defendant Address: D-04 Total number of plaintiffs: 4 Total number of defendants: 3 (J Form JD-CV-2 attached for additional parties Notice to each defendant 1 You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you. 2. To receive further notices, you or your attorney must file an A, \ppearance (form JD-CL-12) with the clerk at the address above. Generally, it must be filed on or before the second day >">" th= Peters Nate The Paturn Nate ic nota hearing date You do not have to come to court on the Return Date you receivi rps do on b Appos BS le) Sele) er a on go) lea ay Le) Rel Voalg RSH Sen I) aU ® Complete items 1, 2, and 3. A. Signature ott PN en 1d =i | oo ™ Print your name and address on the reverse SZ —T TUE A EUR rent so that we can return the card to you. 1 Addressee SO 1 orAtach this card to the back of the maipiece, B, Received by (Printed Name) ( Caitied Wal Fee r ~ - -1¢ t y 4 oT on the front if space permits. Brtinia Arleressed to: D. Is delivery address different from item 1? 11 Yes is If YES, enter delivery address below: [] No |Exira Services & Fees (chock box, add feo as appropriate) Vanessa Buck Retumn Receipt haricopy) [C)retun Receipt electronic) 522 Pomeroy Ave ‘| 8 i centied Mail Restricted Oetivary Meriden, Ct 06450 DAdut signature Required Ci Adut Signature Restricted Delivery Postage ll VAN A > Som Vanessa Buck 3. Service Type [Total Pe O Priority Mail Express® p ceraas toa 522 Pomeroy Ave D Adult Signature istered Mail™ istered Mall Restrictes ‘Sent To Meriden, Ct 06450 9590 9402 8195 3030 1752 82 ‘O Certified Mail Restricted very D Signature Confirmation™ OG [siete O Collect on Del Di Signature Confirmation 2, Article Number (Transfer from service label) 1 Collect on Delivery Restricted Delivery Restricted Delivary Ci Sti ?Oe2 2410 OO02 9587 140k Mail Restricted Delivery PELs i m eect PS Form 3811, July 2020 Psn 7530-02-000-9053 Domestic Return Receipt || SUPERIOR COURT RETURN DATE: SEPTEMBER 12, 2023 ISAIAH NOAH BRYANT J.D. OF MERIDEN v AT MERIDEN VANESSA ALEXIS BUCK JULY 25, 2023 AMAZON LOGISTICS INC. MAD LOGISTICS, LLC COMPLAINT FIRST COUNT: (Isaiah Bryant v. Vanessa Buck —Negligence) 1 On or about February 2, 2022, at approximately 4:00 p.m., the plaintiff, Isaiah Noah Bryant, was operating his motor vehicle westerly on East Main Street, in front of the intersection of Parkway Place and 893 East Main Street, having the right-of-way and proceeding through the intersection in Meriden, Connecticut. 2 On said date and at said time and place, the defendant, Vanessa Alexis Buck, was | | operating a motor vehicle owned by defendant Amazon Logistics Inc. and/or MAD Logistics Inc., | || stopped at the stop sign northbound on Parkway Place and East Main when, without warning or notice, she drove out directly into the right —of way of the plaintiff . 3 On said date and at said time and place, the motor vehicle operated by the defendant GERACE & ASSOCIATES ATTORNEYS AT LAW 21 OAK STREET - SUITE 604 + HARTFORD, CONNECTICUT 06106 - (860) 525-4461 + FAX (860) 527-2439 » JURIS NO. 102274 | violently collided with the driver’s side front end of the motor vehicle operated by the plaintiff, and | then head- on into a third vehicle operated by Silvia Vazquez, stopped southbound in the parking | lot at 893 East Main Street at the stop sign located there. 4 Said collision caused the plaintiff to suffer the injuries and losses as more | | particularly set forth hereinafter. 5 The injuries and losses suffered by the plaintiffs were caused by the negligence and | | carelessness of the defendant in one or more of the following ways: | | | a. IN THAT she operated said motor vehicle at a rate of speed greater than was reasonable having regard for the width, traffic and use of the highway and the weather conditions, | in violation of General Statute §14-218a; | b, IN THAT she operated said motor vehicle at a greater rate of speed than was || | | reasonable under the circumstances then and there existing; | Cc. IN THAT she did not have said motor vehicle under proper and reasonable control; | d IN THAT she failed to pay attention to the traffic ahead or to keep a reasonable and | proper lookout; e IN THAT she failed to apply her brakes and stop, when she knew or should have known that a collision with the vehicle in front was imminent; | f. IN THAT she was failed to grant the right of way, in violation of General Statutes | §14-247 et seq.; g IN THAT she failed to stop the vehicle before entering a public s