Complaint,Petition: BROCUGLIO, THOMAS v. GANTER, ALLEN LEE

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                                RETURN DATE: APRIL 30, 2024                                                SUPERIOR COURT

THOMAS      BROCUGLIO                                                      J.D. OF HARTFORD

vs.                                                                        AT HARTFORD

ALLEN GANTER                                                               APRIL 3, 2024

                                                 COMPLAINT


Count One: (By the Plaintiff as against the Defendant)

1      At all times relevant to this complaint the Plaintiff, Thomas Brocuglio, was and is a

       resident of Enfield, Connecticut.

       At all times relevant to this complaint the Defendant, Allen            Ganter, was a resident of

       Cromwell, Connecticut and was an officer of the Meriden Police Department.

       On or about December 8, 2023, at approximately 3:45 p.m., the Plaintiff was driving his

       truck on France Street in Rocky           Hill, and was approaching the intersection of France

       Street and Cromwell Avenue.

       At   the   same   time   and     place,   the   Defendant   was   operating   his vehicle   on   the

       aforementioned France Street, and was stopped directly ahead of Plaintiff's vehicle.

       As the two vehicles remained stopped on France Street, the Defendant exited his vehicle,

       displayed his badge to the Plaintiff, and purported to take down Plaintiff's license plate in

       order to arrest or ticket him.

       When the Plaintiff questioned the propriety of Defendant’s conduct and asked for his

       badge number, the Defendant suddenly, and without warning or provocation, lunged into

                                                        1

                                                 Maki Law, tc
              467 Naubue Avenue + Glastonbury CT 06033 + 860.269.5780 + Facsimile: 860.221.3947
                                              Juris No. 437597
the driver’s side window of Plaintiff's vehicle striking Plaintiffin the face with his fist,

       causing the harms and losses more fully set forth below.

7      As a direct and proximate result of said collision, caused by the Defendant's willful and/or

wanton assault ofthe Plaintiff, the Plaintiff suffered physical injuries, some, or all, of which may

be permanent in nature, including the following:

               a.          cervical spine injury;

               b.          facial injuries;

               c.          swelling and contusions.

       As a further direct and proximate result of the Defendant's negligence and/or

       carelessness, the Plaintiff was forced to expend sums for medical care and treatment, and

       will be caused to expend further such sums in the future.

       As a further direct and proximate result of the negligence and/or carelessness of the

       Defendant, the Plaintiff has been and will be impaired in his ability to pursue and enjo

       life’s pleasures.




                                                      2

                                                Maki Law, uc
              467 Naubuc Avenue + Glastonbury Cl’ 06033 + 860.269.5780 + Facsimile: 860.221.3947
                                              Juris No. 437597
WHEREFORE,   the Plaintiff claims and demands:

         Compensatory damages:

         Common law punitive/exemplary damages;

         Costs of suit;

         Such other relief deemed    fair, just and reasonable.




                                            THE PLAINTIFF
                                            THOMAS BROCUGLIO




                                            Bren        Maki,        of
                                            Mak’        LLC
                                            -His Attorneys-




                                                 Be

                                          Maki Law, ic
        467 Naubue Avenue + Glastonbury       N6033 + 860.269.5780    + Facsimile: 860.221.3947
                                          Juris No, 437597
RETURN      DATE: APRIL 30, 2024                                           SUPERIOR COURT

THOMAS      BROCUGLIO                                                      J.D. OF HARTFORD

VS.                                                                        AT HARTFORD

ALLEN GANTER                                                               APRIL 3, 2024
                                       AMOUNT       IN DEMAND

        The amount in demand is in excess of FIFTEEN THOUSAND                  DOLLARS         ($15,000.00)

exclusive of costs and interest.



                                                 THE PLAINTIFF
                                                 THOMAS BROCUGLIO




                                                         Maki Law, LLC
                                                         -His Attorneys




                                                     4

                                              Maki Law, tic
              467 Naubue Avenue + Glastonbury CT 06033 + 860.269.5780   + Facsimile: 860.221.3947
                                              Juris No. 437597