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RETURN DATE: JULY 16, 2024 SUPERIOR COURT
NATALY RAMIREZ JUDICIAL DISTRICT
vs. OF HARTFORD
ANDREA MANINGAS JUNE 10, 2024
COMPLAINT
1 At all times mentioned herein, the Plaintiff, Nataly Ramirez, was a resident of the
City of Hartford, State of Connecticut.
2 At all times mentioned herein, the Defendant, Andrea Maningas, was a resident of
the Town of Ellington, State of Connecticut.
3 At all times mentioned herein, Plaintiff was the seat-belted passenger of a 2013
Dodge Caravan motor vehicle bearing Connecticut registration plate number L.4340L and driven by
Marleni Garcia-Urena.
4 At all times mentioned herein, Defendant was the operator of a 2017 Honda Pilot
motor vehicle bearing Connecticut registration plate number AAAA10.
5 On or about March 13, 2023, the Plaintiff was traveling southbound on Spring Street
in Hartford, Connecticut approaching the Interstate 84 Exit 48 exit ramp, and the Defendant was
traveling immediately behind the Plaintiff motor vehicle.
6 At the same time and place, the Plaintiff came to a controlled stop at the stop sign at
the intersection of Spring Street and the Interstate 84 Exit 48 off ramp, when suddenly and without
warning, the Defendant collided with the rear of the Plaintiff motor vehicle, causing the losses and
injuries to the Plaintiff set out more fully below.
7 The collision and resulting injuries and losses to Plaintiff were caused by the
carelessness and negligence of Defendant in one or more of the following ways, in that she:
a. failed to keep her vehicle under a proper and reasonable control;
failed to sound her horn or give the Plaintiff a timely warning, or any warning
whatsoever, of the impending collision;
was inattentive and failed to keep a reasonable and proper lookout for other vehicles
using the roadway;
operated her vehicle with defective or inadequate brakes, or failed to apply said
brakes in time to avoid the impending collision, though in the exercise of due care,
he could and should have done so;
Failed to obey one or more traffic control devices;
Operated her motor vehicle at an unreasonable rate of speed;
violated section 14-240(b) of the motor vehicle laws of the State of Connecticut by
following the Plaintiff motor vehicle more closely than is reasonable and prudent,
having regard for the speed of such vehicles, the traffic upon and the condition of the
highway.
8 As a result of the foregoing careless and negligent conduct, Plaintiff received and
suffered from the injuries listed below, some of which injuries, or the effects thereof, are, or are
likely to be, permanent. Plaintiff's injuries, inter alia, are as follows:
Neck pain;
Strain of muscle, tendon, and fascia of the neck;
Cervical facet mediated pain;
Back pain;
Strain of muscle, tendon, and fascia of the lower back;
Lumbar facet mediated pain;
Left shoulder pain;
Left knee pain;
Subchondral degeneration within the medial femoral trochlea: .>
Left patellofemoral chondromalacia;
Left knee joint effusion;
5% Permanent Partial Impairment of the left knee;
m. Other injuries the nature, extent, and permanence of which are not yet determined,
9. Asa result of the carelessness and negligence of Defendant, the Plaintiff
has incurred
and will incur in the future, inter alia, considerable expenses, pharmaceutical supplies, physical
therapy, and necessary hospital and medical treatment.
10. As a result of the carelessness and negligence of Defendant, the Plaintiff
has suffered
and will continue to suffer in the future emotional pain and suffering.
ll. As a result of the carelessness and negligence of Defendant, the Plaintiff further
suffers from the fear and anxiety that future medical treatment and/or complications may occur
arising out of this accident.
12. As a further result of the carelessness and negligence of Defendant, the Plaintiff has
suffered and will continue to suffer from the loss of ability to enjoy life’s pleasures and activities.
13. As a further result of the carelessness and negligence of the Defendant, the Plaintiff
was caused to suffer and will further suffer lost wages and a loss in earning capacity.
THE PLAINTIFF
NATALY RAMIREZ
By
Emanuel Cicchiello, Esq.
Cicchiello & Cicchiello, LLP
364 Franklin Avenue
Hartford, CT 06114
Phone: 860-296-3457
Fax: 860-296-0676
Email: manny@cicchielloesq.com
RETURN DATE: JULY 16, 2024 SUPERIOR COURT
NATALY RAMIREZ JUDICIAL DISTRICT
VS. OF HARTFORD
ANDREA MANINGAS JUNE 10, 2024
PRAYER FOR RELIEF
WHEREFORE, Plaintiff claims:
1. Money damages;
2. Costs of this action;
3. Allowable costs; and,
4. Such other relief as the Court deems just and proper.
THE PLAINTIFF
NATALY RAMIREZ
By:
Emanuele R. Cicchiello, Esq.
Cicchiello & Cicchiello, LLP
364 Franklin Avenue
Hartford, CT 06114
Phone: 860-296-3457
Fax: 860-296-0676
Email: manny@cicchielloesq.com
RETURN DATE: JULY 16, 2024 SUPERIOR COURT
NATALY RAMIREZ JUDICIAL DISTRICT
VS. OF HARTFORD
ANDREA MANINGAS JUNE 10, 2024
STATEMENT OF AMOUNT IN DEMAND
The amount in demand exceeds $15,000.00, excluding costs and interests
THE PLAINTIFF
NATALY RAMIREZ
By:
Emanuele R. Cicchiello, Esq.
Cicchiello & Cicchiello, LLP
364 Franklin Avenue
Hartford, CT 06114
Phone: 860-296-3457
Fax: 860-296-0676
Email: manny @cicchielloesq.com
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RETURN DATE: JULY 16, 2024 SUPERIOR COURT NATALY RAMIREZ JUDICIAL DISTRICT vs. OF HARTFORD ANDREA MANINGAS JUNE 10, 2024 COMPLAINT 1 At all times mentioned herein, the Plaintiff, Nataly Ramirez, was a resident of the City of Hartford, State of Connecticut. 2 At all times mentioned herein, the Defendant, Andrea Maningas, was a resident of the Town of Ellington, State of Connecticut. 3 At all times mentioned herein, Plaintiff was the seat-belted passenger of a 2013 Dodge Caravan motor vehicle bearing Connecticut registration plate number L.4340L and driven by Marleni Garcia-Urena. 4 At all times mentioned herein, Defendant was the operator of a 2017 Honda Pilot motor vehicle bearing Connecticut registration plate number AAAA10. 5 On or about March 13, 2023, the Plaintiff was traveling southbound on Spring Street in Hartford, Connecticut approaching the Interstate 84 Exit 48 exit ramp, and the Defendant was traveling immediately behind the Plaintiff motor vehicle. 6 At the same time and place, the Plaintiff came to a controlled stop at the stop sign at the intersection of Spring Street and the Interstate 84 Exit 48 off ramp, when suddenly and without warning, the Defendant collided with the rear of the Plaintiff motor vehicle, causing the losses and injuries to the Plaintiff set out more fully below. 7 The collision and resulting injuries and losses to Plaintiff were caused by the carelessness and negligence of Defendant in one or more of the following ways, in that she: a. failed to keep her vehicle under a proper and reasonable control; failed to sound her horn or give the Plaintiff a timely warning, or any warning whatsoever, of the impending collision; was inattentive and failed to keep a reasonable and proper lookout for other vehicles using the roadway; operated her vehicle with defective or inadequate brakes, or failed to apply said brakes in time to avoid the impending collision, though in the exercise of due care, he could and should have done so; Failed to obey one or more traffic control devices; Operated her motor vehicle at an unreasonable rate of speed; violated section 14-240(b) of the motor vehicle laws of the State of Connecticut by following the Plaintiff motor vehicle more closely than is reasonable and prudent, having regard for the speed of such vehicles, the traffic upon and the condition of the highway. 8 As a result of the foregoing careless and negligent conduct, Plaintiff received and suffered from the injuries listed below, some of which injuries, or the effects thereof, are, or are likely to be, permanent. Plaintiff's injuries, inter alia, are as follows: Neck pain; Strain of muscle, tendon, and fascia of the neck; Cervical facet mediated pain; Back pain; Strain of muscle, tendon, and fascia of the lower back; Lumbar facet mediated pain; Left shoulder pain; Left knee pain; Subchondral degeneration within the medial femoral trochlea: .> Left patellofemoral chondromalacia; Left knee joint effusion; 5% Permanent Partial Impairment of the left knee; m. Other injuries the nature, extent, and permanence of which are not yet determined, 9. Asa result of the carelessness and negligence of Defendant, the Plaintiff has incurred and will incur in the future, inter alia, considerable expenses, pharmaceutical supplies, physical therapy, and necessary hospital and medical treatment. 10. As a result of the carelessness and negligence of Defendant, the Plaintiff has suffered and will continue to suffer in the future emotional pain and suffering. ll. As a result of the carelessness and negligence of Defendant, the Plaintiff further suffers from the fear and anxiety that future medical treatment and/or complications may occur arising out of this accident. 12. As a further result of the carelessness and negligence of Defendant, the Plaintiff has suffered and will continue to suffer from the loss of ability to enjoy life’s pleasures and activities. 13. As a further result of the carelessness and negligence of the Defendant, the Plaintiff was caused to suffer and will further suffer lost wages and a loss in earning capacity. THE PLAINTIFF NATALY RAMIREZ By Emanuel Cicchiello, Esq. Cicchiello & Cicchiello, LLP 364 Franklin Avenue Hartford, CT 06114 Phone: 860-296-3457 Fax: 860-296-0676 Email: manny@cicchielloesq.com RETURN DATE: JULY 16, 2024 SUPERIOR COURT NATALY RAMIREZ JUDICIAL DISTRICT VS. OF HARTFORD ANDREA MANINGAS JUNE 10, 2024 PRAYER FOR RELIEF WHEREFORE, Plaintiff claims: 1. Money damages; 2. Costs of this action; 3. Allowable costs; and, 4. Such other relief as the Court deems just and proper. THE PLAINTIFF NATALY RAMIREZ By: Emanuele R. Cicchiello, Esq. Cicchiello & Cicchiello, LLP 364 Franklin Avenue Hartford, CT 06114 Phone: 860-296-3457 Fax: 860-296-0676 Email: manny@cicchielloesq.com RETURN DATE: JULY 16, 2024 SUPERIOR COURT NATALY RAMIREZ JUDICIAL DISTRICT VS. OF HARTFORD ANDREA MANINGAS JUNE 10, 2024 STATEMENT OF AMOUNT IN DEMAND The amount in demand exceeds $15,000.00, excluding costs and interests THE PLAINTIFF NATALY RAMIREZ By: Emanuele R. Cicchiello, Esq. Cicchiello & Cicchiello, LLP 364 Franklin Avenue Hartford, CT 06114 Phone: 860-296-3457 Fax: 860-296-0676 Email: manny @cicchielloesq.com