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RETURN DATE: FEBRUARY 20, 2024 SUPERIOR COURT
SABRINA TOLPPI and JUDICIAL DISTRICT OF
ROBERT TOLPPI, DANBURY
Plaintiffs
AT DANBURY
VS.
MARCUS DELGADO, PV HOLDING CORP.
and ALLSTATE INSURANCE COMPANY,
Defendants January 15, 2024
COMPLAINT
The plaintiffs for their complaint allege on information and belief:
Count One: SABRINA TOLPPI v. MARCUS DELGADO - Negligence
1 At all times herein alleged the plaintiff SABRINA TOLPPI was a resident of
Waterford, Connecticut.
2 At all times herein alleged the plaintiff ROBERT TOLPPI was a resident of
Waterford, Connecticut.
3 At all times herein alleged the defendant MARCUS DELGADO was a resident of
Brookfield, Connecticut.
4 At all times herein alleged the defendant PV HOLDING CORP. was a Delaware
corporation with a principal place of business in Parsippany, New Jersey.
5. At all times herein alleged the defendant PV HOLDING CORP. was licensed to
transact business in Connecticut and did in fact transact business in Connecticut.
6 On or about September 8, 2023, at about 7:15 p.m. Robin Slane was operating a
2010 Dodge Grand Caravan motor vehicle in a westerly direction on Route 34 in Derby,
Connecticut near its intersection with Cullens Hill Rd.
7 At that time and place the defendant MARCUS DELGADO was driving a Jeep
Grand Cherokee motor vehicle in an easterly direction on Route 34 in Derby,
Connecticut near its intersection with Cullens Hill Rd.
8 At that time and place the plaintiffs SABRINA TOLPPI and ROBERT TOLPPI
were passengers in the motor vehicle operated by their mother Robin Slane.
9 At all relevant times, the Jeep Grand Cherokee motor vehicle being operated by
defendant MARCUS DELGADO, was owned by the defendant PV HOLDING CORP.
10. On or about September 8, 2023, at about 7:15 p.m., the vehicle operated by
MARCUS DELGADO and owned by the defendant PV HOLDING CORP. violently
crashed into the vehicle being operated by Robin Slane, causing serious, permanent,
and life-altering injuries to the plaintiff, SABRINA TOLPPI including:
a Traumatic injury to her head, neck, brain, back, abdomen, and torso;
b. Multiple spinal fractures;
c Abdominal injuries including perforation of her intestines;
Spinal fusion surgery;
Surgery to repair the injuries to her abdomen and intestines.
Damage to her muscles, ligaments, and anatomical structures;
Economic damages including expenses for past and future medical,
rehabilitative and surgical care; lost earnings; and impaired earning capacity;
Noneconomic damages including mental and emotional anguish, pain,
suffering, and inability to engage and/or enjoy life’s activities; and
Bystander emotional distress resulting from her contemporaneous sensory
perception of the death of her mother.
11. The motor vehicle collision and SABRINA TOLPP'’s injuries were caused by the
negligence of the defendant MARCUS DELGADO in all or some of the following
respects:
a. In that he failed to maintain his proper lane of travel although by a proper and
reasonable exercise of his faculties he could have and should have done so;
b. In that he failed to turn or swerve so as to avoid collision;
c In that he failed to apply the brakes in time to avoid the collision;
In that he failed to keep a reasonable and proper lookout for other vehicles on
the road;
In that he failed to drive at a reasonable rate of speed, having due regard to
the width, traffic, and use of the highway, road or parking area, the
intersection of streets and weather conditions;
In that he failed to keep the vehicle under proper control;
In that he failed to sound the horn or give a timely warning of the impeding
collision;
In that he was inattentive in the operation of the vehicle; and
In that he failed to exercise reasonable care and safety in exercising his
faculties when driving and making turns.
Count Two: SABRINA TOLPPI v. MARCUS DELGADO - Statutory Recklessness
1-10. The plaintiff, SABRINA TOLPPI, hereby re-alleges and incorporates paragraphs
One through Ten of the First Count as paragraphs One through Ten of this the Second
Count as if fully set forth and alleged herein.
11. The motor vehicle collision and SABRINA TOLPP''s injuries were caused by the
defendant MARCUS DELGADO’s deliberate and reckless disregard for the
consequences of his actions in that he:
a. Drove his vehicle at an unreasonable rate of speed with regard to the width,
traffic and use of highway, the intersection of streets and weather conditions
then and there in place in violation of Connecticut General Statutes Section
14-218(a) when he knew or should have known that traveling at such a
dangerously high rate of speed was likely to cause serious injury or death;
Made a conscious choice to speed by operating his vehicle at such a high
rate of speed as to endanger human life in violation of Connecticut General
Statutes § 14-219 when he knew or should have known that traveling at such
a dangerously high rate of speed was likely to cause serious injury or death;
Operated his motor vehicle recklessly in violation of Connecticut General
Statutes §14-222 by driving on the opposite side of a double yellow line,
knowing that his actions created an extraordinarily high risk of serious injury
or death to the driving public, including the plaintiff;
d. Drove his vehicle in the left lane of travel in violation of Connecticut General
Statutes § 14-230 when he knew or should have known that traveling in the
left lane of travel was likely to cause serious injury or death; and
Failed to drive his vehicle on the right-hand side of a divided highway in
violation of Connecticut General Statutes § 14-237 when he knew or should
have known that failing to drive on the right-hand side was likely to cause
serious injury or death.
Count Three: SABRINA TOLPPI v. MARCUS DELGADO - Common Law
Recklessness
1-10. The plaintiff, SABRINA TOLPPI, hereby re-alleges and incorporates paragraphs
One through Ten of the Second Count as paragraphs One through Ten of this the Third
Count as if fully set forth and alleged herein.
11. The motor vehicle collision and SABRINA TOLPPI’s injuries were caused by the
defendant MARCUS DELGADO'’s deliberate and reckless disregard for the
consequences of his actions in that he:
a Drove his vehicle at an unreasonable rate of speed with regard to the width,
traffic and use of highway, the intersection of streets and weather conditions
then and there in place when he knew or should have known that traveling at
such a dangerously high rate of speed was likely to cause serious injury or
death;
Made a conscious choice to speed by operating his vehicle at such a high
rate of speed as to endanger human life when he knew or should have known
that traveling at such a dangerously high rate of speed was likely to cause
serious injury or death;
Operated his motor vehicle recklessly by driving on the opposite side of a
double yellow line, knowing that his actions created an extraordinarily high
risk of serious injury or death to the driving public, including the plaintiff;
Drove his vehicle in the left lane of travel when he knew or should have
known that traveling in the left lane of travel was likely to cause serious injury
or death; and
Failed to drive his vehicle on the right-hand side of a divided highway when
he knew or should have known that failing to drive on the right-hand side was
likely to cause serious injury or death.
Count Four: SABRINA TOLPPI v. PV HOLDING CORP. — Negligence
1-10. Paragraphs One through Ten of the First Count are hereby re-alleged and
reincorporated as paragraphs One through Ten of this the Fourth count as if set forth
fully herein.
11. At all times herein alleged, defendant PV Holding Corp. including its agents,
servants, and employees was in the business of renting, leasing, and loaning motor
vehicles to the general public.
12. As a lessor of motor vehicles to the general public, defendant PV Holding Corp.
including its agents, servants, and employees had a duty to exercise reasonable care in
determining whether a prospective lessee was proper and suitable to operate a motor
vehicle before renting one out.
13. Defendant PV Holding Corp. including its agents, servants, and employees had a
duty to ascertain whether a prospective lessee possessed an active and valid driver's
license before renting out a vehicle.
14. At all relevant times, defendant PV Holding Corp. including its agents, servants,
and employees rented, leased, and/or loaned the Jeep Grand Cherokee motor vehicle
to the defendant-driver MARCUS DELGADO.
15. At all relevant times, defendant-driver MARCUS DELGADO was operating the
Jeep Grand Cherokee motor vehicle owned by defendant PV Holding Corp. with the
permission of defendant PV Holding Corp.
16. At the time he rented the Jeep Grand Cherokee motor vehicle from the defendant
PV Holding Corp., its agents, servants, and employees, the defendant-driver MARCUS
DELGADO was not proper and suitable to operate the motor vehicle rented to him and
did not a valid driver's license with the State of Connecticut or in any state.
17. Prior to renting, leasing, or loaning the Jeep Grand Cherokee motor vehicle to
the defendant-driver MARCUS DELGADO, defendant PV HOLDING CORP., its agents,
servants, and employees failed to conduct a background check to determine whether he
was proper and suitable to rent a vehicle including whether the defendant-driver
possessed a valid and active driver's license.
18. The motor vehicle collision and injuries sustained by the plaintiff, SABRINA
TOLPPI, as hereinbefore alleged were caused by the negligence of defendant PV
HOLDING CORP.. and its agents, servants, and employees in some or all of the
following respects:
a In that it failed to properly create, promulgate, or enforce policies and
procedures to ensure that prospective lessors, including the defendant-driver
MARCUS DELGADO, had valid driver's licenses;
In that it failed to properly supervise its employees in determining whether
prospective lessors, including the defendant-driver MARCUS DELGADO,
were proper and suitable to rent a vehicle including whether the defendant-
driver possessed a valid and active driver's license;
In that it failed to properly train its employees to determine whether
prospective lessors, including the defendant-driver MARCUS DELGADO,
were proper and suitable to rent a vehicle including whether the defendant-
driver possessed a valid and active driver's license;
In that it failed to implement procedures to properly screen for unlicensed and
unsafe drivers, including the defendant-driver, Marcus Delgado;
In that it failed to properly hire competent employees who were capable of
determining whether prospective lessors, including the defendant-driver
Marcus Delgado, were proper and suitable to rent a vehicle including whether
the defendant-driver possessed a valid and active driver's license; and
In that it failed to properly implement safety measures to ensure that
unlicensed and unsafe drivers were not given a motor vehicle.
Count Five: SABRINA TOLPPI v. PV HOLDING CORP. — Negligent Entrustment
1-17. Paragraphs One through Seventeen of the Fourth Count are hereby re-alleged
and reincorporated as paragraphs One through Seventeen of this the Fifth count as if
set forth fully herein.
18. The motor vehicle collision and resulting injuries sustained by the plaintiff,
SABRINA TOLPPI, were caused by the negligent entrustment of defendant PV Holding
Corp. and its agents, servants, and employees in some or all of the following respects:
a. In that it knew or should have known that the defendant-driver, MARCUS
DELGADO, was not competent to operate the Jeep Grand Cherokee motor
vehicle, and yet entrusted said motor vehicle to him despite the unreasonable
risk of injury created to the public, including the plaintiff SABRINA TOLPPI;
In that that it knew or should have known that the defendant-driver, MARCUS
DELGADO, was an unsafe driver, and yet entrusted said motor vehicle to him
despite the risk of injury to the public, including the plaintiff SABRINA
TOLPPI; and
In that that it knew or should have known that the defendant-driver, MARCUS
DELGADO, did not possess an active and valid driver's license, and yet
entrusted said motor vehicle to him anyways despite the unreasonable risk of
injury to the public, including the plaintiff SABRINA TOLPPI.
Count Six: SABRINA TOLPPI v. Allstate Insurance Company — Underinsured
Motorist Benefits
1-11. Paragraphs One through Eleven of the First Count are hereby re-alleged and
reincorporated as paragraphs One through Eighteen of this the Sixth count as if set
forth fully herein.
12. On or about September 8, 2023 and for sometime prior thereto, defendant
ALLSTATE entered into a contract and insurance policy (policy number 984540619,
“the Allstate Policy” by the terms of which agreed to provide automobile insurance in
exchange for the payment of premiums.
13. The 2010 Dodge Grand Caravan involved in the September 8, 2023 accident
was a covered vehicle under the Allstate Policy.
14. Under the Allstate Policy, ALLSTATE agreed to pay for uninsured/underinsured
motorist benefits in the amount of $250,000 per person and $500,000 per occurrence to
SABRINA TOLPPI for injuries sustained due to a collision with an underinsured motor
vehicle.
15. The Allstate Policy was in full force and effect at the time of the September 8,
2023 accident.
16. The injuries and damages of the plaintiff SABRINA TOLPPI are in excess of the
liability limits of the tortfeasor-defendant MARCUS DELGADO’s insurance policy. Said
policy is inadequate to fully compensate the plaintiff for the injuries and losses herein
alleged, and is less than the plaintiff's fair, just and reasonable damages.
17. The tortfeasor-defendant, MARCUS DELGADO, constitutes an underinsured
motorist under the Allstate Policy and under the definition of an underinsured motor
vehicle as defined in Connecticut General Statutes § 38a-336(e), thereby triggering the
policy’s underinsured motorist benefits coverage.
18. The plaintiff, SABRINA TOLPPI is entitled to underinsured motorist benefits
under the Allstate Policy.
19. The plaintiff SABRINA TOLPP''s injuries and losses as alleged are therefore the
legal responsibility of the defendant ALLSTATE pursuant to the terms of the Allstate
Policy and in accordance with the Connecticut General Statutes.
20. The defendant ALLSTATE Insurance Company is now required to pay SABRINA
TOLPPI underinsured benefits under the Allstate Policy.
Count Seven: ROBERT TOLPPI v. MARCUS DELGADO - Negligence
1-9. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs
One through Nine of the First Count as paragraphs One through Nine of this the
Seventh Count as if fully set forth and alleged herein.
10. On or about September 8, 2023, at about 7:15 p.m., the vehicle operated by
MARCUS DELGADO and owned by the defendant PV HOLDING CORP. violently
crashed into the vehicle being operated by Robin Slane, causing serious, permanent,
and life-altering injuries to the plaintiff, ROBERT TOLPPI including:
a. Traumatic injury to his head, neck, and back;
b Cervical sprain/strain/pain;
C. Thoracic sprain/strain/pain; and
Lumbar sprain/strain/pain.
Damage to his muscles, ligaments, and anatomical structures;
Economic damages including expenses for past and future medical,
rehabilitative and surgical care; and
Noneconomic damages including mental and emotional anguish, pain,
suffering, and inability to engage and/or enjoy life’s activities.
Bystander emotional distress resulting from her contemporaneous sensory
perception of the death of his mother.
Count Eight: ROBERT TOLPPI v. MARCUS DELGADO - Statutory Recklessness
1-11. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs
One through Eleven of the Second Count as paragraphs One through Eleven of this the
Eighth Count as if fully set forth and alleged herein.
12. The motor vehicle collision and SABRINA TOLPP''s injuries were caused by the
defendant MARCUS DELGADO’s deliberate and reckless disregard for the
consequences of his actions in that he:
a. Drove his vehicle at an unreasonable rate of speed with regard to the width,
traffic and use of highway, the intersection of streets and weather conditions
then and there in place in violation of Connecticut General Statutes Section
14-218(a) when he knew or should have known that traveling at such a
dangerously high rate of speed was likely to cause serious injury or death;
Made a conscious choice to speed by operating his vehicle at such a high
rate of speed as to endanger human life in violation of Connecticut General
Statutes § 14-219 when he knew or should have known that traveling at such
a dangerously high rate of speed was likely to cause serious injury or death;
Operated his motor vehicle recklessly in violation of Connecticut General
Statutes §14-222 by driving on the opposite side of a double yellow line,
knowing that his actions created an extraordinarily high risk of serious injury
or death to the driving public, including the plaintiff;
Drove his vehicle in the left lane of travel in violation of Connecticut General
Statutes § 14-230 when he knew or should have known that traveling in the
left lane of travel was likely to cause serious injury or death; and
Failed to drive his vehicle on the right-hand side of a divided highway in
violation of Connecticut General Statutes § 14-237 when he knew or should
have known that failing to drive on the right-hand side was likely to cause
serious injury or death.
Count Nine: ROBERT TOLPPI v. MARCUS DELGADO - Common Law
Recklessness
1-10. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs
One through Ten of the Third Count as paragraphs One through Ten of this the Ninth
Count as if fully set forth and alleged herein.
11. The motor vehicle collision and ROBERT TOLPP''s injuries were caused by the
defendant MARCUS DELGADO's deliberate and reckless disregard for the
consequences of his actions in that he:
a. Drove his vehicle at an unreasonable rate of speed with regard to the width,
traffic and use of highway, the intersection of streets and weather conditions
then and there in place when he knew or should have known that traveling at
such a dangerously high rate of speed was likely to cause serious injury or
death;
Made a conscious choice to speed by operating his vehicle at such a high
rate of speed as to endanger human life when he knew or should have known
that traveling at such a dangerously high rate of speed was likely to cause
serious injury or death;
Operated his motor vehicle recklessly by driving on the opposite side of a
double yellow line, knowing that his actions created an extraordinarily high
10
risk of serious injury or death to the driving public, including the plaintiff;
Drove his vehicle in the left lane of travel when he knew or should have
known that traveling in the left lane of travel was likely to cause serious injury
or death; and
Failed to drive his vehicle on the right-hand side of a divided highway when
he knew or should have known that failing to drive on the right-hand side was
likely to cause serious injury or death.
Count Ten: ROBERT TOLPPI v. PV HOLDING CORP. —- Negligence
1-17. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs
One through Seventeen of the Fourth Count as paragraphs One through Seventeen of
this the Tenth Count as if fully set forth and alleged herein.
18. The motor vehicle collision and resulting injuries sustained by the plaintiff,
ROBERT TOLPPI, as hereinbefore alleged were caused by the negligence of defendant
PV Holding Corp. and its agents, servants, and employees in some or all of the
following respects:
a. In that it failed to properly create, promulgate, or enforce policies and
procedures to ensure that prospective lessors, including the defendant-driver
MARCUS DELGADO, had valid driver's licenses;
In that it failed to properly supervise its employees in determining whether
prospective lessors, including the defendant-driver MARCUS DELGADO,
were proper and suitable to rent a vehicle including whether the defendant-
driver possessed a valid and active driver's license;
In that it failed to properly train its employees to determine whether
prospective lessors, including the defendant-driver MARCUS DELGADO,
were proper and suitable to rent a vehicle including whether the defendant-
driver possessed a valid and active driver's license;
In that it failed to implement procedures to properly screen for unlicensed and
unsafe drivers, including the defendant-driver, MARCUS DELGADO;
In that it failed to properly hire competent employees who were capable of
determining whether prospective lessors, including the defendant-driver
MARCUS DELGADO, were proper and suitable to rent a vehicle including
whether the defendant-driver possessed a valid and active driver's license;
and
11
f. In that it failed to properly implement safety measures to ensure that
unlicensed and unsafe drivers were not given a motor vehicle.
Count Eleven: ROBERT TOLPPI v. PV HOLDING CORP. — Negligent Entrustment
1-17. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs
One through Seventeen of the Tenth Count as paragraphs One through Seventeen of
this the Eleventh Count as if fully set forth and alleged herein.
18. The motor vehicle collision and resulting injuries sustained by the plaintiff,
ROBERT TOLPPI, were caused by the negligent entrustment of defendant PV Holding
Corp. and its agents, servants, and employees in some or all of the following respects:
a In that it knew or should have known that the defendant-driver, Marcus
Delagdo, was not competent to operate the Jeep Grand Cherokee motor
vehicle, and yet entrusted said motor vehicle to him despite the unreasonable
risk of injury created to the public, including the plaintiff SABRINA TOLPPI;
In that that it knew or should have known that the defendant-driver, Marcus
Delagdo, was an unsafe driver, and yet entrusted said motor vehicle to him
despite the risk of injury to the public, including the plaintiff SABRINA
TOLPPI; and
In that that it knew or should have known that the defendant-driver, Marcus
Delagdo, did not possess an active and valid driver's license, and yet
entrusted said motor vehicle to him anyways despite the unreasonable risk of
injury to the public, including the plaintiff SABRINA TOLPPI.
Count Twelve: ROBERT TOLPPI v. Allstate Insurance Company — Underinsured
Motorist Benefits
1-10. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs
One through Ten of the Seventh Count as paragraphs One through Ten of this the
Twelfth Count as if fully set forth and alleged herein.
11. On or about September 8, 2023 and for sometime prior thereto, defendant
ALLSTATE entered into a contract and insurance policy (policy number 984540619,
12
“the Allstate Policy” by the terms of which agreed to provide automobile insurance in
exchange for the payment of premiums.
12. The 2010 Dodge Grand Caravan involved in the September 8, 2023 accident
was a covered vehicle under the Allstate Policy.
13. Under the Allstate Policy, ALLSTATE agreed to pay for uninsured/underinsured
motorist benefits in the amount of $250,000 per person and $500,000 per occurrence to
SABRINA TOLPPI for injuries sustained due to a collision with an underinsured motor
vehicle.
14. The Allstate Policy was in full force and effect at the time of the September 8,
2023 accident.
15. The injuries and damages of the plaintiff SABRINA TOLPPI are in excess of the
liability limits of the tortfeasor-defendant MARCUS DELGADO’s insurance policy. Said
policy is inadequate to fully compensate the plaintiff for the injuries and losses herein
alleged, and is less than the plaintiff's fair, just and reasonable damages.
16. The tortfeasor-defendant, MARCUS DELGADO, constitutes an underinsured
motorist under the Allstate Policy and under the definition of an underinsured motor
vehicle as defined in Connecticut General Statutes § 38a-336(e), thereby triggering the
policy’s underinsured motorist benefits coverage.
17. The plaintiff, SABRINA TOLPPI is entitled to underinsured motorist benefits
under the Allstate Policy.
18. The plaintiff SABRINA TOLPP’s injuries and losses as alleged are therefore the
legal responsibility of the defendant ALLSTATE pursuant to the terms of the Allstate
Policy and in accordance with the Connecticut General Statutes.
13
19. The defendant ALLSTATE Insurance Company is now required to pay SABRINA
TOLPPI underinsured benefits under the Allstate Policy.
14
WHEREFORE, the plaintiffs claim:
Money damages;
Double and treble damages as to Counts Two and Eight
Punitive damages as to Counts Three and Nine;
Interests and costs;
Such other and further relief as this Court may deem just and equitable
THE PLAINTIFFS
CHRISTOPHER EAGRER
Meagher & Meagher, PC
111 Church Street
White Plains, NY 10601
Tel: (914) 328-8844
Juris No.: 409563
cmeagher @meagherandmeagherpc.com
15
RETURN DATE: FEBRUARY 20, 2024 SUPERIOR COURT
SABRINA TOLPPI and JUDICIAL DISTRICT OF
ROBERT TOLPPI, DANBURY
Plaintiffs
AT DANBURY
VS.
MARCUS DELGADO, PV HOLDING CORP.
and ALLSTATE INSURANCE COMPANY,
Defendants January 15, 2024
AMOUNT IN DEMAND
This is to certify that plaintiffs seek to recover damages in excess of Fifteen
Thousand dollars ($15,000.00), exclusive of any interest or costs.
THE PLAINTIFFS
awn Ie
CHRISTOPHER B MEAGHER
Meagher & Meagher, PC
111 Church Street
White Plains, NY 10601
Tel: (914) 328-8844
Juris No.: 409563
cmeagher @meagherandmeagherpc.com
16
STATE OF CONNECTICUT : January 19, 2024
: SS: WEST HARTFORD
COUNTY OF HARTF ORD
THEN and by virtue hereof and by direction of the plaintiffs
to locate the wit! hin named
Attorney, I made diligent search throughout my precincts
defendant:
DELGADO, MARCUS
the office of the Motor Vehicles
but could not find said defendant at the address on file at
Commissioner of the State of Connecticut.
AFTERWARDS on January 19, 2024 in the town of
nt to provisions of
ge
Wethersfield, County of Hartford and State of Connecticut, pursua
SE upon the within named defendant
Qf C.GS. Sec. 52-63 (B) (C), I made due and legal service
SUMMONS and
by leaving a verified true and attested copy of the original WRIT,
§ ae at least 12 days
re COMPLAINT at the office of the Commissioner of Motor Vehicles,
ble with the required fee, and
Mees
‘Se before the session of the court to which this Writ is returna
ae of the
Bo affidavit of my due and diligent effort to obtain service at the address
sioner of Motor
owner/operator on file in the motor vehicle department. Said Commis
Vehicles is the duly authorized agent for the within named defendant:
THEREAFTER on January 19, 2024, I deposited in
of the original
the Post Office in the Town of West Hartford a true and attested copy
requested addressed
WRIT, SUMMONS and COMPLAINT, certified mail, return receipt
Commission of
to the within named defendant at the last known address on file with the
Motor Vehicles.
DELGADO, MARCUS
26 HILLANDALE ROAD
APT, 2
BROOKFIELD, CT 06804
Scott M. KraIMER
Connecticut STATE MARSHAL
P.O. Box 271621 * West Hartford, CT 06127-1621 + 860-521-1223
service of
ALSO on January 19, 2024, I made due and legal
leaving a true and attested copy
he within original Writ, Summons and Complaint by
lat the office of CORPORATION SERVICE COMPANY whom is the duly authorized
dant:
lagent to accept service on behalf of the within named defen
PV HOLDING CORP.
At 225 Asylum Street, 20" floor, Hartford, CT.
e of the within
ALSO on January 19, 2024, I made due and legal servic
and attested copies at the
original Writ, Summons and Complaint by leaving two true
wh om is the duly authorized agent to
office of Andrew N. Mais, Insurance Commissioner
accept service on behalf of the within named defendant:
e3
ge ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY
At 153 Market Street, Hartford, CT.
ie.
AND
THE WITHIN IS THE ORIGINAL WRIT, SU MMONS
wes
2 COMPLAINT WITH MY DOINGS HEREON ENDORSED.
aw E
#5
BS
FEES: ATTEST: |
af
SERVICE $150.00 Zig /A
$ 68.50 MKRAL
b.
TRAVEL
$ 7.50 A RSHAI
ENDORSEMENTS
$ 85.00 RTFO! RD COUNTY
PAGES
PD.D.M.V. $ 50.00
POSTAGE $ 9.00
PD. INS. COMM. $ 50.00
TOTAL $420.00
Scott M. KRAIMER
Connecticut STATE MARSHAL
P.O. Box 271621 * West Hartford, CT 06127-1621 + 860-521-1223
Preview
RETURN DATE: FEBRUARY 20, 2024 SUPERIOR COURT SABRINA TOLPPI and JUDICIAL DISTRICT OF ROBERT TOLPPI, DANBURY Plaintiffs AT DANBURY VS. MARCUS DELGADO, PV HOLDING CORP. and ALLSTATE INSURANCE COMPANY, Defendants January 15, 2024 COMPLAINT The plaintiffs for their complaint allege on information and belief: Count One: SABRINA TOLPPI v. MARCUS DELGADO - Negligence 1 At all times herein alleged the plaintiff SABRINA TOLPPI was a resident of Waterford, Connecticut. 2 At all times herein alleged the plaintiff ROBERT TOLPPI was a resident of Waterford, Connecticut. 3 At all times herein alleged the defendant MARCUS DELGADO was a resident of Brookfield, Connecticut. 4 At all times herein alleged the defendant PV HOLDING CORP. was a Delaware corporation with a principal place of business in Parsippany, New Jersey. 5. At all times herein alleged the defendant PV HOLDING CORP. was licensed to transact business in Connecticut and did in fact transact business in Connecticut. 6 On or about September 8, 2023, at about 7:15 p.m. Robin Slane was operating a 2010 Dodge Grand Caravan motor vehicle in a westerly direction on Route 34 in Derby, Connecticut near its intersection with Cullens Hill Rd. 7 At that time and place the defendant MARCUS DELGADO was driving a Jeep Grand Cherokee motor vehicle in an easterly direction on Route 34 in Derby, Connecticut near its intersection with Cullens Hill Rd. 8 At that time and place the plaintiffs SABRINA TOLPPI and ROBERT TOLPPI were passengers in the motor vehicle operated by their mother Robin Slane. 9 At all relevant times, the Jeep Grand Cherokee motor vehicle being operated by defendant MARCUS DELGADO, was owned by the defendant PV HOLDING CORP. 10. On or about September 8, 2023, at about 7:15 p.m., the vehicle operated by MARCUS DELGADO and owned by the defendant PV HOLDING CORP. violently crashed into the vehicle being operated by Robin Slane, causing serious, permanent, and life-altering injuries to the plaintiff, SABRINA TOLPPI including: a Traumatic injury to her head, neck, brain, back, abdomen, and torso; b. Multiple spinal fractures; c Abdominal injuries including perforation of her intestines; Spinal fusion surgery; Surgery to repair the injuries to her abdomen and intestines. Damage to her muscles, ligaments, and anatomical structures; Economic damages including expenses for past and future medical, rehabilitative and surgical care; lost earnings; and impaired earning capacity; Noneconomic damages including mental and emotional anguish, pain, suffering, and inability to engage and/or enjoy life’s activities; and Bystander emotional distress resulting from her contemporaneous sensory perception of the death of her mother. 11. The motor vehicle collision and SABRINA TOLPP'’s injuries were caused by the negligence of the defendant MARCUS DELGADO in all or some of the following respects: a. In that he failed to maintain his proper lane of travel although by a proper and reasonable exercise of his faculties he could have and should have done so; b. In that he failed to turn or swerve so as to avoid collision; c In that he failed to apply the brakes in time to avoid the collision; In that he failed to keep a reasonable and proper lookout for other vehicles on the road; In that he failed to drive at a reasonable rate of speed, having due regard to the width, traffic, and use of the highway, road or parking area, the intersection of streets and weather conditions; In that he failed to keep the vehicle under proper control; In that he failed to sound the horn or give a timely warning of the impeding collision; In that he was inattentive in the operation of the vehicle; and In that he failed to exercise reasonable care and safety in exercising his faculties when driving and making turns. Count Two: SABRINA TOLPPI v. MARCUS DELGADO - Statutory Recklessness 1-10. The plaintiff, SABRINA TOLPPI, hereby re-alleges and incorporates paragraphs One through Ten of the First Count as paragraphs One through Ten of this the Second Count as if fully set forth and alleged herein. 11. The motor vehicle collision and SABRINA TOLPP''s injuries were caused by the defendant MARCUS DELGADO’s deliberate and reckless disregard for the consequences of his actions in that he: a. Drove his vehicle at an unreasonable rate of speed with regard to the width, traffic and use of highway, the intersection of streets and weather conditions then and there in place in violation of Connecticut General Statutes Section 14-218(a) when he knew or should have known that traveling at such a dangerously high rate of speed was likely to cause serious injury or death; Made a conscious choice to speed by operating his vehicle at such a high rate of speed as to endanger human life in violation of Connecticut General Statutes § 14-219 when he knew or should have known that traveling at such a dangerously high rate of speed was likely to cause serious injury or death; Operated his motor vehicle recklessly in violation of Connecticut General Statutes §14-222 by driving on the opposite side of a double yellow line, knowing that his actions created an extraordinarily high risk of serious injury or death to the driving public, including the plaintiff; d. Drove his vehicle in the left lane of travel in violation of Connecticut General Statutes § 14-230 when he knew or should have known that traveling in the left lane of travel was likely to cause serious injury or death; and Failed to drive his vehicle on the right-hand side of a divided highway in violation of Connecticut General Statutes § 14-237 when he knew or should have known that failing to drive on the right-hand side was likely to cause serious injury or death. Count Three: SABRINA TOLPPI v. MARCUS DELGADO - Common Law Recklessness 1-10. The plaintiff, SABRINA TOLPPI, hereby re-alleges and incorporates paragraphs One through Ten of the Second Count as paragraphs One through Ten of this the Third Count as if fully set forth and alleged herein. 11. The motor vehicle collision and SABRINA TOLPPI’s injuries were caused by the defendant MARCUS DELGADO'’s deliberate and reckless disregard for the consequences of his actions in that he: a Drove his vehicle at an unreasonable rate of speed with regard to the width, traffic and use of highway, the intersection of streets and weather conditions then and there in place when he knew or should have known that traveling at such a dangerously high rate of speed was likely to cause serious injury or death; Made a conscious choice to speed by operating his vehicle at such a high rate of speed as to endanger human life when he knew or should have known that traveling at such a dangerously high rate of speed was likely to cause serious injury or death; Operated his motor vehicle recklessly by driving on the opposite side of a double yellow line, knowing that his actions created an extraordinarily high risk of serious injury or death to the driving public, including the plaintiff; Drove his vehicle in the left lane of travel when he knew or should have known that traveling in the left lane of travel was likely to cause serious injury or death; and Failed to drive his vehicle on the right-hand side of a divided highway when he knew or should have known that failing to drive on the right-hand side was likely to cause serious injury or death. Count Four: SABRINA TOLPPI v. PV HOLDING CORP. — Negligence 1-10. Paragraphs One through Ten of the First Count are hereby re-alleged and reincorporated as paragraphs One through Ten of this the Fourth count as if set forth fully herein. 11. At all times herein alleged, defendant PV Holding Corp. including its agents, servants, and employees was in the business of renting, leasing, and loaning motor vehicles to the general public. 12. As a lessor of motor vehicles to the general public, defendant PV Holding Corp. including its agents, servants, and employees had a duty to exercise reasonable care in determining whether a prospective lessee was proper and suitable to operate a motor vehicle before renting one out. 13. Defendant PV Holding Corp. including its agents, servants, and employees had a duty to ascertain whether a prospective lessee possessed an active and valid driver's license before renting out a vehicle. 14. At all relevant times, defendant PV Holding Corp. including its agents, servants, and employees rented, leased, and/or loaned the Jeep Grand Cherokee motor vehicle to the defendant-driver MARCUS DELGADO. 15. At all relevant times, defendant-driver MARCUS DELGADO was operating the Jeep Grand Cherokee motor vehicle owned by defendant PV Holding Corp. with the permission of defendant PV Holding Corp. 16. At the time he rented the Jeep Grand Cherokee motor vehicle from the defendant PV Holding Corp., its agents, servants, and employees, the defendant-driver MARCUS DELGADO was not proper and suitable to operate the motor vehicle rented to him and did not a valid driver's license with the State of Connecticut or in any state. 17. Prior to renting, leasing, or loaning the Jeep Grand Cherokee motor vehicle to the defendant-driver MARCUS DELGADO, defendant PV HOLDING CORP., its agents, servants, and employees failed to conduct a background check to determine whether he was proper and suitable to rent a vehicle including whether the defendant-driver possessed a valid and active driver's license. 18. The motor vehicle collision and injuries sustained by the plaintiff, SABRINA TOLPPI, as hereinbefore alleged were caused by the negligence of defendant PV HOLDING CORP.. and its agents, servants, and employees in some or all of the following respects: a In that it failed to properly create, promulgate, or enforce policies and procedures to ensure that prospective lessors, including the defendant-driver MARCUS DELGADO, had valid driver's licenses; In that it failed to properly supervise its employees in determining whether prospective lessors, including the defendant-driver MARCUS DELGADO, were proper and suitable to rent a vehicle including whether the defendant- driver possessed a valid and active driver's license; In that it failed to properly train its employees to determine whether prospective lessors, including the defendant-driver MARCUS DELGADO, were proper and suitable to rent a vehicle including whether the defendant- driver possessed a valid and active driver's license; In that it failed to implement procedures to properly screen for unlicensed and unsafe drivers, including the defendant-driver, Marcus Delgado; In that it failed to properly hire competent employees who were capable of determining whether prospective lessors, including the defendant-driver Marcus Delgado, were proper and suitable to rent a vehicle including whether the defendant-driver possessed a valid and active driver's license; and In that it failed to properly implement safety measures to ensure that unlicensed and unsafe drivers were not given a motor vehicle. Count Five: SABRINA TOLPPI v. PV HOLDING CORP. — Negligent Entrustment 1-17. Paragraphs One through Seventeen of the Fourth Count are hereby re-alleged and reincorporated as paragraphs One through Seventeen of this the Fifth count as if set forth fully herein. 18. The motor vehicle collision and resulting injuries sustained by the plaintiff, SABRINA TOLPPI, were caused by the negligent entrustment of defendant PV Holding Corp. and its agents, servants, and employees in some or all of the following respects: a. In that it knew or should have known that the defendant-driver, MARCUS DELGADO, was not competent to operate the Jeep Grand Cherokee motor vehicle, and yet entrusted said motor vehicle to him despite the unreasonable risk of injury created to the public, including the plaintiff SABRINA TOLPPI; In that that it knew or should have known that the defendant-driver, MARCUS DELGADO, was an unsafe driver, and yet entrusted said motor vehicle to him despite the risk of injury to the public, including the plaintiff SABRINA TOLPPI; and In that that it knew or should have known that the defendant-driver, MARCUS DELGADO, did not possess an active and valid driver's license, and yet entrusted said motor vehicle to him anyways despite the unreasonable risk of injury to the public, including the plaintiff SABRINA TOLPPI. Count Six: SABRINA TOLPPI v. Allstate Insurance Company — Underinsured Motorist Benefits 1-11. Paragraphs One through Eleven of the First Count are hereby re-alleged and reincorporated as paragraphs One through Eighteen of this the Sixth count as if set forth fully herein. 12. On or about September 8, 2023 and for sometime prior thereto, defendant ALLSTATE entered into a contract and insurance policy (policy number 984540619, “the Allstate Policy” by the terms of which agreed to provide automobile insurance in exchange for the payment of premiums. 13. The 2010 Dodge Grand Caravan involved in the September 8, 2023 accident was a covered vehicle under the Allstate Policy. 14. Under the Allstate Policy, ALLSTATE agreed to pay for uninsured/underinsured motorist benefits in the amount of $250,000 per person and $500,000 per occurrence to SABRINA TOLPPI for injuries sustained due to a collision with an underinsured motor vehicle. 15. The Allstate Policy was in full force and effect at the time of the September 8, 2023 accident. 16. The injuries and damages of the plaintiff SABRINA TOLPPI are in excess of the liability limits of the tortfeasor-defendant MARCUS DELGADO’s insurance policy. Said policy is inadequate to fully compensate the plaintiff for the injuries and losses herein alleged, and is less than the plaintiff's fair, just and reasonable damages. 17. The tortfeasor-defendant, MARCUS DELGADO, constitutes an underinsured motorist under the Allstate Policy and under the definition of an underinsured motor vehicle as defined in Connecticut General Statutes § 38a-336(e), thereby triggering the policy’s underinsured motorist benefits coverage. 18. The plaintiff, SABRINA TOLPPI is entitled to underinsured motorist benefits under the Allstate Policy. 19. The plaintiff SABRINA TOLPP''s injuries and losses as alleged are therefore the legal responsibility of the defendant ALLSTATE pursuant to the terms of the Allstate Policy and in accordance with the Connecticut General Statutes. 20. The defendant ALLSTATE Insurance Company is now required to pay SABRINA TOLPPI underinsured benefits under the Allstate Policy. Count Seven: ROBERT TOLPPI v. MARCUS DELGADO - Negligence 1-9. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs One through Nine of the First Count as paragraphs One through Nine of this the Seventh Count as if fully set forth and alleged herein. 10. On or about September 8, 2023, at about 7:15 p.m., the vehicle operated by MARCUS DELGADO and owned by the defendant PV HOLDING CORP. violently crashed into the vehicle being operated by Robin Slane, causing serious, permanent, and life-altering injuries to the plaintiff, ROBERT TOLPPI including: a. Traumatic injury to his head, neck, and back; b Cervical sprain/strain/pain; C. Thoracic sprain/strain/pain; and Lumbar sprain/strain/pain. Damage to his muscles, ligaments, and anatomical structures; Economic damages including expenses for past and future medical, rehabilitative and surgical care; and Noneconomic damages including mental and emotional anguish, pain, suffering, and inability to engage and/or enjoy life’s activities. Bystander emotional distress resulting from her contemporaneous sensory perception of the death of his mother. Count Eight: ROBERT TOLPPI v. MARCUS DELGADO - Statutory Recklessness 1-11. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs One through Eleven of the Second Count as paragraphs One through Eleven of this the Eighth Count as if fully set forth and alleged herein. 12. The motor vehicle collision and SABRINA TOLPP''s injuries were caused by the defendant MARCUS DELGADO’s deliberate and reckless disregard for the consequences of his actions in that he: a. Drove his vehicle at an unreasonable rate of speed with regard to the width, traffic and use of highway, the intersection of streets and weather conditions then and there in place in violation of Connecticut General Statutes Section 14-218(a) when he knew or should have known that traveling at such a dangerously high rate of speed was likely to cause serious injury or death; Made a conscious choice to speed by operating his vehicle at such a high rate of speed as to endanger human life in violation of Connecticut General Statutes § 14-219 when he knew or should have known that traveling at such a dangerously high rate of speed was likely to cause serious injury or death; Operated his motor vehicle recklessly in violation of Connecticut General Statutes §14-222 by driving on the opposite side of a double yellow line, knowing that his actions created an extraordinarily high risk of serious injury or death to the driving public, including the plaintiff; Drove his vehicle in the left lane of travel in violation of Connecticut General Statutes § 14-230 when he knew or should have known that traveling in the left lane of travel was likely to cause serious injury or death; and Failed to drive his vehicle on the right-hand side of a divided highway in violation of Connecticut General Statutes § 14-237 when he knew or should have known that failing to drive on the right-hand side was likely to cause serious injury or death. Count Nine: ROBERT TOLPPI v. MARCUS DELGADO - Common Law Recklessness 1-10. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs One through Ten of the Third Count as paragraphs One through Ten of this the Ninth Count as if fully set forth and alleged herein. 11. The motor vehicle collision and ROBERT TOLPP''s injuries were caused by the defendant MARCUS DELGADO's deliberate and reckless disregard for the consequences of his actions in that he: a. Drove his vehicle at an unreasonable rate of speed with regard to the width, traffic and use of highway, the intersection of streets and weather conditions then and there in place when he knew or should have known that traveling at such a dangerously high rate of speed was likely to cause serious injury or death; Made a conscious choice to speed by operating his vehicle at such a high rate of speed as to endanger human life when he knew or should have known that traveling at such a dangerously high rate of speed was likely to cause serious injury or death; Operated his motor vehicle recklessly by driving on the opposite side of a double yellow line, knowing that his actions created an extraordinarily high 10 risk of serious injury or death to the driving public, including the plaintiff; Drove his vehicle in the left lane of travel when he knew or should have known that traveling in the left lane of travel was likely to cause serious injury or death; and Failed to drive his vehicle on the right-hand side of a divided highway when he knew or should have known that failing to drive on the right-hand side was likely to cause serious injury or death. Count Ten: ROBERT TOLPPI v. PV HOLDING CORP. —- Negligence 1-17. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs One through Seventeen of the Fourth Count as paragraphs One through Seventeen of this the Tenth Count as if fully set forth and alleged herein. 18. The motor vehicle collision and resulting injuries sustained by the plaintiff, ROBERT TOLPPI, as hereinbefore alleged were caused by the negligence of defendant PV Holding Corp. and its agents, servants, and employees in some or all of the following respects: a. In that it failed to properly create, promulgate, or enforce policies and procedures to ensure that prospective lessors, including the defendant-driver MARCUS DELGADO, had valid driver's licenses; In that it failed to properly supervise its employees in determining whether prospective lessors, including the defendant-driver MARCUS DELGADO, were proper and suitable to rent a vehicle including whether the defendant- driver possessed a valid and active driver's license; In that it failed to properly train its employees to determine whether prospective lessors, including the defendant-driver MARCUS DELGADO, were proper and suitable to rent a vehicle including whether the defendant- driver possessed a valid and active driver's license; In that it failed to implement procedures to properly screen for unlicensed and unsafe drivers, including the defendant-driver, MARCUS DELGADO; In that it failed to properly hire competent employees who were capable of determining whether prospective lessors, including the defendant-driver MARCUS DELGADO, were proper and suitable to rent a vehicle including whether the defendant-driver possessed a valid and active driver's license; and 11 f. In that it failed to properly implement safety measures to ensure that unlicensed and unsafe drivers were not given a motor vehicle. Count Eleven: ROBERT TOLPPI v. PV HOLDING CORP. — Negligent Entrustment 1-17. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs One through Seventeen of the Tenth Count as paragraphs One through Seventeen of this the Eleventh Count as if fully set forth and alleged herein. 18. The motor vehicle collision and resulting injuries sustained by the plaintiff, ROBERT TOLPPI, were caused by the negligent entrustment of defendant PV Holding Corp. and its agents, servants, and employees in some or all of the following respects: a In that it knew or should have known that the defendant-driver, Marcus Delagdo, was not competent to operate the Jeep Grand Cherokee motor vehicle, and yet entrusted said motor vehicle to him despite the unreasonable risk of injury created to the public, including the plaintiff SABRINA TOLPPI; In that that it knew or should have known that the defendant-driver, Marcus Delagdo, was an unsafe driver, and yet entrusted said motor vehicle to him despite the risk of injury to the public, including the plaintiff SABRINA TOLPPI; and In that that it knew or should have known that the defendant-driver, Marcus Delagdo, did not possess an active and valid driver's license, and yet entrusted said motor vehicle to him anyways despite the unreasonable risk of injury to the public, including the plaintiff SABRINA TOLPPI. Count Twelve: ROBERT TOLPPI v. Allstate Insurance Company — Underinsured Motorist Benefits 1-10. The plaintiff, ROBERT TOLPPI, hereby re-alleges and incorporates paragraphs One through Ten of the Seventh Count as paragraphs One through Ten of this the Twelfth Count as if fully set forth and alleged herein. 11. On or about September 8, 2023 and for sometime prior thereto, defendant ALLSTATE entered into a contract and insurance policy (policy number 984540619, 12 “the Allstate Policy” by the terms of which agreed to provide automobile insurance in exchange for the payment of premiums. 12. The 2010 Dodge Grand Caravan involved in the September 8, 2023 accident was a covered vehicle under the Allstate Policy. 13. Under the Allstate Policy, ALLSTATE agreed to pay for uninsured/underinsured motorist benefits in the amount of $250,000 per person and $500,000 per occurrence to SABRINA TOLPPI for injuries sustained due to a collision with an underinsured motor vehicle. 14. The Allstate Policy was in full force and effect at the time of the September 8, 2023 accident. 15. The injuries and damages of the plaintiff SABRINA TOLPPI are in excess of the liability limits of the tortfeasor-defendant MARCUS DELGADO’s insurance policy. Said policy is inadequate to fully compensate the plaintiff for the injuries and losses herein alleged, and is less than the plaintiff's fair, just and reasonable damages. 16. The tortfeasor-defendant, MARCUS DELGADO, constitutes an underinsured motorist under the Allstate Policy and under the definition of an underinsured motor vehicle as defined in Connecticut General Statutes § 38a-336(e), thereby triggering the policy’s underinsured motorist benefits coverage. 17. The plaintiff, SABRINA TOLPPI is entitled to underinsured motorist benefits under the Allstate Policy. 18. The plaintiff SABRINA TOLPP’s injuries and losses as alleged are therefore the legal responsibility of the defendant ALLSTATE pursuant to the terms of the Allstate Policy and in accordance with the Connecticut General Statutes. 13 19. The defendant ALLSTATE Insurance Company is now required to pay SABRINA TOLPPI underinsured benefits under the Allstate Policy. 14 WHEREFORE, the plaintiffs claim: Money damages; Double and treble damages as to Counts Two and Eight Punitive damages as to Counts Three and Nine; Interests and costs; Such other and further relief as this Court may deem just and equitable THE PLAINTIFFS CHRISTOPHER EAGRER Meagher & Meagher, PC 111 Church Street White Plains, NY 10601 Tel: (914) 328-8844 Juris No.: 409563 cmeagher @meagherandmeagherpc.com 15 RETURN DATE: FEBRUARY 20, 2024 SUPERIOR COURT SABRINA TOLPPI and JUDICIAL DISTRICT OF ROBERT TOLPPI, DANBURY Plaintiffs AT DANBURY VS. MARCUS DELGADO, PV HOLDING CORP. and ALLSTATE INSURANCE COMPANY, Defendants January 15, 2024 AMOUNT IN DEMAND This is to certify that plaintiffs seek to recover damages in excess of Fifteen Thousand dollars ($15,000.00), exclusive of any interest or costs. THE PLAINTIFFS awn Ie CHRISTOPHER B MEAGHER Meagher & Meagher, PC 111 Church Street White Plains, NY 10601 Tel: (914) 328-8844 Juris No.: 409563 cmeagher @meagherandmeagherpc.com 16 STATE OF CONNECTICUT : January 19, 2024 : SS: WEST HARTFORD COUNTY OF HARTF ORD THEN and by virtue hereof and by direction of the plaintiffs to locate the wit! hin named Attorney, I made diligent search throughout my precincts defendant: DELGADO, MARCUS the office of the Motor Vehicles but could not find said defendant at the address on file at Commissioner of the State of Connecticut. AFTERWARDS on January 19, 2024 in the town of nt to provisions of ge Wethersfield, County of Hartford and State of Connecticut, pursua SE upon the within named defendant Qf C.GS. Sec. 52-63 (B) (C), I made due and legal service SUMMONS and by leaving a verified true and attested copy of the original WRIT, § ae at least 12 days re COMPLAINT at the office of the Commissioner of Motor Vehicles, ble with the required fee, and Mees ‘Se before the session of the court to which this Writ is returna ae of the Bo affidavit of my due and diligent effort to obtain service at the address sioner of Motor owner/operator on file in the motor vehicle department. Said Commis Vehicles is the duly authorized agent for the within named defendant: THEREAFTER on January 19, 2024, I deposited in of the original the Post Office in the Town of West Hartford a true and attested copy requested addressed WRIT, SUMMONS and COMPLAINT, certified mail, return receipt Commission of to the within named defendant at the last known address on file with the Motor Vehicles. DELGADO, MARCUS 26 HILLANDALE ROAD APT, 2 BROOKFIELD, CT 06804 Scott M. KraIMER Connecticut STATE MARSHAL P.O. Box 271621 * West Hartford, CT 06127-1621 + 860-521-1223 service of ALSO on January 19, 2024, I made due and legal leaving a true and attested copy he within original Writ, Summons and Complaint by lat the office of CORPORATION SERVICE COMPANY whom is the duly authorized dant: lagent to accept service on behalf of the within named defen PV HOLDING CORP. At 225 Asylum Street, 20" floor, Hartford, CT. e of the within ALSO on January 19, 2024, I made due and legal servic and attested copies at the original Writ, Summons and Complaint by leaving two true wh om is the duly authorized agent to office of Andrew N. Mais, Insurance Commissioner accept service on behalf of the within named defendant: e3 ge ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY At 153 Market Street, Hartford, CT. ie. AND THE WITHIN IS THE ORIGINAL WRIT, SU MMONS wes 2 COMPLAINT WITH MY DOINGS HEREON ENDORSED. aw E #5 BS FEES: ATTEST: | af SERVICE $150.00 Zig /A $ 68.50 MKRAL b. TRAVEL $ 7.50 A RSHAI ENDORSEMENTS $ 85.00 RTFO! RD COUNTY PAGES PD.D.M.V. $ 50.00 POSTAGE $ 9.00 PD. INS. COMM. $ 50.00 TOTAL $420.00 Scott M. KRAIMER Connecticut STATE MARSHAL P.O. Box 271621 * West Hartford, CT 06127-1621 + 860-521-1223