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RETURN DATE: MAY 21, 2024 SUPERIOR COURT
ROBYN ABRAMS J.D. OF NEW HAVEN
VS. AT MERIDEN
LAJAJUAN DANCY APRIL 4, 2024
COMPLAINT
1. At all times mentioned herein, Meriden Waterbury Turnpike, running in a generally
easterly and westerly direction, and Meriden Avenue, running in a generally northerly and southerly
direction, were public roads running through Southington, Connecticut, which formed an intersection.
THE DODDLAW FIRM, LLC
2. On or about April 18, 2022, the Plaintiff, Robyn Abrams, was operating her vehicle
eastbound on Meriden Waterbury Turnpike and was proceeding through said intersection in accordance
with a green traffic control light controlling the traffic in her direction when a motor vehicle owned and
being operated by Defendant, Lajajuan Dancy, in a southerly direction on Meriden Avenue, suddenly and
without warning drove through a red traffic control light at said intersection controlling traffic in his
direction, and crashed into Plaintiffs vehicle, causing Plaintiff to sustain severe and permanent personal
injuries and other losses as hereinafter set forth.
3. Said crash was caused by the carelessness and negligence of the Defendant, Lajajuan
Dancy, in one or more of the following respects:
a) IN THAT he operated his vehicle carelessly and negligently,
having regard to the width, traffic, use of the highway, weather
conditions and other conditions then and there existing;
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b) IN THAT he failed to seasonably apply his brakes, when, in the
exercise of due care, he knew or should have known that a crash
was imminent;
c) IN THAT he operated his motor vehicle at a rate of speed greater
than was reasonable, having regard to the width, traffic and use of
the highway, intersection of streets and weather conditions then
and there existing, in violation of C.G.S. Section 14-218a;
d) IN THAT he failed to keep his motor vehicle under proper control;
e) IN THAT he failed to keep a proper lookout for other vehicles on
the road, including Plaintiffs vehicle;
f) IN THAT he was inattentive;
g) IN THAT he failed to stop or otherwise manipulate his motor
vehicle in time and in such a manner as to avoid the crash;
h) IN THAT he failed to give Plaintiffs vehicle a timely signal or
warning of the approach of his motor vehicle;
i) IN THAT he failed to stop his vehicle at a red light controlling
traffic in his direction at said intersection, in violation of C.G.S.
14-299;
j) IN THAT he failed to use the degree of care which a reasonably
careful person would have used under like circumstances.
4. As a result of the crash and the carelessness and negligence of the Defendant, Lajajuan
Dancy, the Plaintiff sustained the following injuries, consequential losses and expenses, all or some of
which may be permanent in nature:
a) An injury to the neck;
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b) An injury to the chest;
c) An injury to the right knee;
d) An injury to the left knee;
e) An injury to the left leg, including but not limited to multiple
contusions;
0 An injury to the right leg, including but not limited to multiple
contusions;
g) An injury to the right foot;
h) An injury to the left shoulder;
THEDODDLAWFIRM, LLC
i) An injury to the right shoulder;
j) An injury to the back;
k) An injury to the teeth;
1) Pain, suffering and discomfort;
m) Emotional distress and mental anguish;
n) Anxiety, fatigue, inconvenience, impairment of mobility and
general debility;
o) The Plaintiff has been obligated in the past, and may be obligated
in the future, to expend sums of money for medical care, hospital
care, nursing care, x-rays, medication and physical therapy;
p) The Plaintiff has been and will be deprived of many of the usual
pleasures, activities and recreations of life; and
q) The Plaintiffs life has been adversely affected by said injuries and
its consequences.
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WHEREFORE, the Plaintiff claims money damages.
Of this Writ, with your doings thereon, make due service and return.
JURIS NO. 402420
Dated at Cheshire, Connecticut this 4t11 day of April, 2024.
THE PLA IFF,
1781HIGHLANDAVENUE, SUITE105 • CHESHIRE, CONNECTICUT 06410• (203) 272-1883
By:
nathan H. Dodd Her Attorney
The Dodd Law Firm, L.L.C.
Ten Corporate Center
1781 Highland Avenue, Suite 105
THE DODD LAW FIRM, LLC
Cheshire, CT 06410
Telephone: 203-272-1883
Facsimile: 203-272-2077
Juris No: 402420
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RETURN DATE: MAY 21, 2024 SUPERIOR COURT
ROBYN ABRAMS J.D. OF NEW HAVEN
VS. AT MERIDEN
LAJAJUAN DANCY APRIL 4, 2024
STATEMENT RE: AMOUNT IN DEMAND
The Plaintiff in the above entitled action hereby sets forth that the amount in demand exceeds
fifteen thousand dollars ($15,000.00), exclusive of interest and costs.
THEDODDLAWFIRM, LLC
THE PLAINTIFF,
By:
n H. Dodd, Her Attorney
e Dodd Law Firm, L.L.C.
Ten Corporate Center
1781 Highland Avenue, Suite 105
Cheshire, CT 06410
Telephone: 203-272-1883
Facsimile: 203-272-2077
Juris No: 402420
5
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RETURN DATE: MAY 21, 2024 SUPERIOR COURT ROBYN ABRAMS J.D. OF NEW HAVEN VS. AT MERIDEN LAJAJUAN DANCY APRIL 4, 2024 COMPLAINT 1. At all times mentioned herein, Meriden Waterbury Turnpike, running in a generally easterly and westerly direction, and Meriden Avenue, running in a generally northerly and southerly direction, were public roads running through Southington, Connecticut, which formed an intersection. THE DODDLAW FIRM, LLC 2. On or about April 18, 2022, the Plaintiff, Robyn Abrams, was operating her vehicle eastbound on Meriden Waterbury Turnpike and was proceeding through said intersection in accordance with a green traffic control light controlling the traffic in her direction when a motor vehicle owned and being operated by Defendant, Lajajuan Dancy, in a southerly direction on Meriden Avenue, suddenly and without warning drove through a red traffic control light at said intersection controlling traffic in his direction, and crashed into Plaintiffs vehicle, causing Plaintiff to sustain severe and permanent personal injuries and other losses as hereinafter set forth. 3. Said crash was caused by the carelessness and negligence of the Defendant, Lajajuan Dancy, in one or more of the following respects: a) IN THAT he operated his vehicle carelessly and negligently, having regard to the width, traffic, use of the highway, weather conditions and other conditions then and there existing; 1 b) IN THAT he failed to seasonably apply his brakes, when, in the exercise of due care, he knew or should have known that a crash was imminent; c) IN THAT he operated his motor vehicle at a rate of speed greater than was reasonable, having regard to the width, traffic and use of the highway, intersection of streets and weather conditions then and there existing, in violation of C.G.S. Section 14-218a; d) IN THAT he failed to keep his motor vehicle under proper control; e) IN THAT he failed to keep a proper lookout for other vehicles on the road, including Plaintiffs vehicle; f) IN THAT he was inattentive; g) IN THAT he failed to stop or otherwise manipulate his motor vehicle in time and in such a manner as to avoid the crash; h) IN THAT he failed to give Plaintiffs vehicle a timely signal or warning of the approach of his motor vehicle; i) IN THAT he failed to stop his vehicle at a red light controlling traffic in his direction at said intersection, in violation of C.G.S. 14-299; j) IN THAT he failed to use the degree of care which a reasonably careful person would have used under like circumstances. 4. As a result of the crash and the carelessness and negligence of the Defendant, Lajajuan Dancy, the Plaintiff sustained the following injuries, consequential losses and expenses, all or some of which may be permanent in nature: a) An injury to the neck; 2 b) An injury to the chest; c) An injury to the right knee; d) An injury to the left knee; e) An injury to the left leg, including but not limited to multiple contusions; 0 An injury to the right leg, including but not limited to multiple contusions; g) An injury to the right foot; h) An injury to the left shoulder; THEDODDLAWFIRM, LLC i) An injury to the right shoulder; j) An injury to the back; k) An injury to the teeth; 1) Pain, suffering and discomfort; m) Emotional distress and mental anguish; n) Anxiety, fatigue, inconvenience, impairment of mobility and general debility; o) The Plaintiff has been obligated in the past, and may be obligated in the future, to expend sums of money for medical care, hospital care, nursing care, x-rays, medication and physical therapy; p) The Plaintiff has been and will be deprived of many of the usual pleasures, activities and recreations of life; and q) The Plaintiffs life has been adversely affected by said injuries and its consequences. 3 WHEREFORE, the Plaintiff claims money damages. Of this Writ, with your doings thereon, make due service and return. JURIS NO. 402420 Dated at Cheshire, Connecticut this 4t11 day of April, 2024. THE PLA IFF, 1781HIGHLANDAVENUE, SUITE105 • CHESHIRE, CONNECTICUT 06410• (203) 272-1883 By: nathan H. Dodd Her Attorney The Dodd Law Firm, L.L.C. Ten Corporate Center 1781 Highland Avenue, Suite 105 THE DODD LAW FIRM, LLC Cheshire, CT 06410 Telephone: 203-272-1883 Facsimile: 203-272-2077 Juris No: 402420 4 RETURN DATE: MAY 21, 2024 SUPERIOR COURT ROBYN ABRAMS J.D. OF NEW HAVEN VS. AT MERIDEN LAJAJUAN DANCY APRIL 4, 2024 STATEMENT RE: AMOUNT IN DEMAND The Plaintiff in the above entitled action hereby sets forth that the amount in demand exceeds fifteen thousand dollars ($15,000.00), exclusive of interest and costs. THEDODDLAWFIRM, LLC THE PLAINTIFF, By: n H. Dodd, Her Attorney e Dodd Law Firm, L.L.C. Ten Corporate Center 1781 Highland Avenue, Suite 105 Cheshire, CT 06410 Telephone: 203-272-1883 Facsimile: 203-272-2077 Juris No: 402420 5