Preview
y
COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, SS: SUPERIOR COURT
C.A: NO.: dy - 30
MIIA PROPERTY AND CASUALTY
GROUP, INC. as subrogee of the
wt as bore or fe
TOWN OF WELLESLEY, -CLERK OF C' SOURTS
‘MIDDLESEX
FOR THE COUNTY OF
Plaintiff,
Vv.
MAY 3) 2024
JAMES PETROS, MoE TERK
Go
Defendants.
COMPLAINT AND JURY CLAIM
PARTIES
1 The Plaintiff, MIIA Property and Casualty Group, Inc. (“MIIA”), is a Massachusetts
corporation duly organized under the laws of the Commonwealth of Massachusetts, having a
place of business at 15 Cabot Road, Woburn, Middlesex County, Massachusetts,
2. The Plaintiff, MIIA, is exercising its subrogation rights pursuant to an insurance contract
with the Town of Wellesley, Massachusetts.
3 The Defendant, James Petros (“Defendant”), is an individual residing at 3 Sprague Road,
Wellesley, Massachusetts.
FACTS
5 On or about March 2, 2022, the Town of Wellesley was insured under an insurance
contract administered by the Plaintiff, MIIA.
7. On or about March 2, 2022, Defendant operated a motor vehicle near the Town
Municipal Light Department Building located at 4 Municipal Way in the Town (“Light
Department Building”).
8 At that time, Defendant operated the vehicle negligently so as to strike the Light
Department Building, causing property damage totaling $135,887.16.
=
9 Under the insurance contract, MIIA has paid to or on behalf of the Town of Wellesley
for the above-described damages.
COUNT ONE
Negligence v. James Petros
10. The Plaintiff, MIIA, repeats and re-alleges the allegations set forth in paragraphs 1 - 9 of
its Complaint as if fully set forth herein.
ll. The Defendant had a duty to exercise reasonable care in operating a motor vehicle.
12. The Defendant breached that duty of care owed by driving the vehicle negligently and
carelessly.
13. As a direct and proximate result of Defendant’s negligent operation of a motor vehicle,
the Town sustained damages in excess of $135,887.16.
WHEREFORE, the Plaintiff, MIIA, as subrogee of the Town of Wellesley, demands
judgment for property damage against the Defendant in the amount of $135,887.16, together
with interest thereon, costs and attorney fees, and any other relief that this Honorable Court
deems just and equitable.
THE PLAINTIFF DEMANDS A TRIAL BY JURY ON ALL ISSUES
Dated: SCAB 2Y Respectfully Submitted,
The Plaintiff,
by its attorneys,
PLZZ
Arthur E. ‘lis (564673)
William E-Potter Jr. (709612)
TANG & MARAVELIS, P.C.
50 Mall Road, Suite 111
Burlington, MA 01803
(781) 221-1400
amaravelis@tangmaravelis.com
wpotter@tangmaravelis.com
MIIAI719 Complaint
Preview
y COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, SS: SUPERIOR COURT C.A: NO.: dy - 30 MIIA PROPERTY AND CASUALTY GROUP, INC. as subrogee of the wt as bore or fe TOWN OF WELLESLEY, -CLERK OF C' SOURTS ‘MIDDLESEX FOR THE COUNTY OF Plaintiff, Vv. MAY 3) 2024 JAMES PETROS, MoE TERK Go Defendants. COMPLAINT AND JURY CLAIM PARTIES 1 The Plaintiff, MIIA Property and Casualty Group, Inc. (“MIIA”), is a Massachusetts corporation duly organized under the laws of the Commonwealth of Massachusetts, having a place of business at 15 Cabot Road, Woburn, Middlesex County, Massachusetts, 2. The Plaintiff, MIIA, is exercising its subrogation rights pursuant to an insurance contract with the Town of Wellesley, Massachusetts. 3 The Defendant, James Petros (“Defendant”), is an individual residing at 3 Sprague Road, Wellesley, Massachusetts. FACTS 5 On or about March 2, 2022, the Town of Wellesley was insured under an insurance contract administered by the Plaintiff, MIIA. 7. On or about March 2, 2022, Defendant operated a motor vehicle near the Town Municipal Light Department Building located at 4 Municipal Way in the Town (“Light Department Building”). 8 At that time, Defendant operated the vehicle negligently so as to strike the Light Department Building, causing property damage totaling $135,887.16. = 9 Under the insurance contract, MIIA has paid to or on behalf of the Town of Wellesley for the above-described damages. COUNT ONE Negligence v. James Petros 10. The Plaintiff, MIIA, repeats and re-alleges the allegations set forth in paragraphs 1 - 9 of its Complaint as if fully set forth herein. ll. The Defendant had a duty to exercise reasonable care in operating a motor vehicle. 12. The Defendant breached that duty of care owed by driving the vehicle negligently and carelessly. 13. As a direct and proximate result of Defendant’s negligent operation of a motor vehicle, the Town sustained damages in excess of $135,887.16. WHEREFORE, the Plaintiff, MIIA, as subrogee of the Town of Wellesley, demands judgment for property damage against the Defendant in the amount of $135,887.16, together with interest thereon, costs and attorney fees, and any other relief that this Honorable Court deems just and equitable. THE PLAINTIFF DEMANDS A TRIAL BY JURY ON ALL ISSUES Dated: SCAB 2Y Respectfully Submitted, The Plaintiff, by its attorneys, PLZZ Arthur E. ‘lis (564673) William E-Potter Jr. (709612) TANG & MARAVELIS, P.C. 50 Mall Road, Suite 111 Burlington, MA 01803 (781) 221-1400 amaravelis@tangmaravelis.com wpotter@tangmaravelis.com MIIAI719 Complaint