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RETURN DATE: JULY 9, 2024 SUPERIOR COURT
RICHARD HOLLOWAY J.D, OF HARTFORD
Vv. AT HARTFORD
NEISON LUIS HOMAR JUNE 4, 2024
COMPLAINT
COUNT ONE - Negligence
1. Atall times mentioned herein, plaintiff, RICHARD HOLLOWAY was a resident of the
City of Hartford, State of Connecticut.
2. Atall times mentioned herein, the defendant, NEISON LUIS HOMAR was a resident of
the City of Bristol, State of Connecticut.
3. Atall relevant times hereinafter referenced, the plaintiff, RICHARD HOLLOWAY
(hereinafter referred to as “Plaintiff) was the driver of a 2010 green Honda Accord Crosstour
motor vehicle bearing CT license piate.
4. Atall relevant times herein after defendant NEISON LUIS HOMAR (hereinafter referred
to as “Defendant”) was the driver of a 2015 428xi Blue BMW motor vehicle bearing CT license
plate.
5. On or about June 30, 2023, Plaintiff was traveling northbound on Stone Street in the
City of Hartford, State of Connecticut.
Law Office of Michael Chambers Jr. - ATTORNEYS AT LAW
2 Congress Street* Hartford, CT 06114 + (860) 231-9335 + FAX: (888) 859-9496 » JURIS NO. 423287
6. At approximately the same time, Defendant traveling westbound from Broadview
Terrace in the City of Hartford, State of Connecticut.
7. Atall relevant times herein after, the defendant was operating his motor vehicle when
suddenly and without warning stopped and made a left turn directly into the path of Plaintiff's
vehicle.
8. Plaintiff was unable to stop his car in time and violently collided with Defendant's
vehicle.
9. The collision, and resulting injuries, losses and damages sustained by the Plaintiff were
caused by the carelessness and negligence of Defendant in one or more of the following ways
a. Violated Section 14-301 of motor vehicle laws of the State of Connecticut by
failing to obey stop sign;
Defendant failed to Maintain Proper Lane in violation of Section 14-236 of the
State of Connecticut motor vehicle laws;
Violated Section 14-240 of motor vehicle laws of the State of Connecticut by
failing to drive a reasonable distance apart.
Defendant illegally passed on the Right in violation of Section 14-233of the State
of Connecticut motor vehicle law;
Violated section 14-21 8a(a) of the motor vehicle laws of the State of Connecticut
in traveling too fast for the condition;
Law Office of Michael Chambers Jr.» ATTORNEYS AT LAW
2 Congress Strects Hartford, CT 061 14 + (860) 231-9535 » FAX: (888) 859-9496 + JURIS NO. 423287
Violated Section 14-224(b)(1) of the motor vehicle taws of the State of
Connecticut in causing serious physical injury to any other person;
Violated section 14-224(b)(3) of the motor vehicle laws of ihe State of
Connecticut in causing injury or damage to property;
Operated said automobile with defective or inadequate brakes, or failed to apply
brakes in time to avoids aid collision in violation of section 14-218(a)of the State
of Connecticut motor vehicle laws;
ViolatedSection14-218(a)of the motor vehicle laws of the State of Connecticut
operating said motor vehicle at a rate of speed greater than is reasonable having
no regard to the width, traffic, and use of the highway, and the weather
conditions;
The defendant was inattentive and failed to keep a reasonable and proper look
out for other vehicles;
Defendant failed to keep the vehicle under reasonable control;
Defendant failed to maneuver his vehicle to the right or to the left to avoid striking
our client's vehicle; although by proper and reasonable exercise of his faculties
he could have done so; and
Defendant failed to stop said motor vehicle in time to avoid the collision, although
by a proper and reasonable exercise of his faculties he could have done so.
Law Office of Michael Chambers Jr. - ATTORNEYS AT LAW
2 Congress Street+ Hartford, CT 06114 + (860) 231-9535 + FAX: (888) 859-9496 = JURES NO, 423287
plaintiff received
40. As a result of the negligence and carelessness of the defendant, the
and suffered from the injuries listed below. Plaintiff also received a severe shock to his
nervous system. From all the injuries listed below or the effects thereof, Plaintiff has suffered
injuries, or the
and will suffer great pain, mental anguish and nervousness, some of which
effects thereof, are, or are likely to be, permanent. Plaintiff's injuries, inter alia, are as follows
a Cervical spine sprain and strain;
b Lumbar spine sprain and strain;
Cc Thoracic spine sprain and strain;
Right lower extremity radiating pain;
Headaches;
Blurry vision inb left eye;
Right hand numbness and tingling;
Other injuries that have yet to be ascertained.
and will incur
11. As a further result of the conduct of the Defendant, the Plaintiff has incurred
physical therapy and
in the future, inter alia, considerable expenses, pharmaceutical supplies,
necessary hospital and medical treatment.
42. Asa further result of the conduct of the Defendant, Plaintiff suffers from the fear and
.
anxiety that future medical complications may occur arising out of this accident
and will
13.As a further result of the conduct of the Defendant, the Plaintiff has suffered
continue to suffer from the loss of ability to enjoy life's pleasures and activities.
Law Office of Michael Chambers Jr. + ATTORNEYS AT LAW
+ SURIS NO. 423287
2 Congress Streets Hartford, CT 06114 + (860) 231-9535 * FAX: (888) 859-9496
14, As a further result of the conduct of the Defendant, the Plaintiff has suffered economic
damages both past and future including lost wages.
THE PLAINTIFF,
RICHARD HOLLOWAY
BY. 181423287
Michael L. Chambers Jr., Esq.
The Law Office of Michael L. Chambers Jr.
2 Congress Street
Hartford, CT 06114
Telephone: (860) 231-9535
Facsimile: (888) 859-9496
Juris No.: 423287
His Attorney
Michael@mchamberslaw.com
Law Office of Michael Chambers Jr. + ATTORNEYS AT LAW
2 Congress Street» Hartford, CT 06114 + (860) 231-9535 * FAX: (888) 859-9496 + JURIS NO. 423287
RETURN DATE: JULY 9, 2024 SUPERIOR COURT
RICHARD HOLLOWAY J.D. OF HARTFORD
Vv. AT HARTFORD
NEISON LUIS HOMAR JUNE 4, 2024
PRAYER FOR RELIEF
WHEREFORE, the plaintiff claims:
1 Money damages;
2 Double or treble damages;
2 Costs of this action;
Allowable costs; and,
Such other relief as the Court deems just and proper.
THE PLAINTIFF,
RICHARD HOLLOWAY
BY. /s/423287
Michael L. Chambers Jr., Esq.
The Law Office of Michael L. Chambers Jr.
2 Congress Street
Hartford, CT 06114
Telephone: (860) 231-9535
Facsimile: (888) 859-9496
Juris No.: 423287
His Attorney
Michael@mchamberslaw.com
Law Office of Michael Chambers Jr. » ATTORNEYS AT LAW
2 Congress Street? Hartford, CT 06114 + (860) 231-9535 « FAX: (888) 859-9496 * JURIS NO. 423287
RETURN DATE: JULY 9, 2024 SUPERIOR COURT
RICHARD HOLLOWAY J.D. OF HARTFORD
Vv AT HARTFORD
NEISON LUIS HOMAR JUNE 4, 2024
STATEMENT OF AMOUNT IN DEMAND
The amount in demand is $15,000.00 or more, exclusive of costs and interest.
THE PLAINTIFF,
RICHARD HOLLOWAY
BY. [s/423287
Michael L. Chambers Jr., Esq.
The Law Office of Michael L. Chambers Jr.
2 Congress Sireet
Hartford, CT 06114
Telephone: (860) 231-9535
Facsimile: (888) 859-9496
Juris No.: 423287
His Attorney
Michael@mchambersiaw.com
Law Office of Michael Chambers Jr. « ATTORNEYS AT LAW
2 Congress Street» Hartford, CT 061 14 + (860) 231-9535 * FAX: (888) 859-9496 » JURIS NO, 423287
Preview
RETURN DATE: JULY 9, 2024 SUPERIOR COURT RICHARD HOLLOWAY J.D, OF HARTFORD Vv. AT HARTFORD NEISON LUIS HOMAR JUNE 4, 2024 COMPLAINT COUNT ONE - Negligence 1. Atall times mentioned herein, plaintiff, RICHARD HOLLOWAY was a resident of the City of Hartford, State of Connecticut. 2. Atall times mentioned herein, the defendant, NEISON LUIS HOMAR was a resident of the City of Bristol, State of Connecticut. 3. Atall relevant times hereinafter referenced, the plaintiff, RICHARD HOLLOWAY (hereinafter referred to as “Plaintiff) was the driver of a 2010 green Honda Accord Crosstour motor vehicle bearing CT license piate. 4. Atall relevant times herein after defendant NEISON LUIS HOMAR (hereinafter referred to as “Defendant”) was the driver of a 2015 428xi Blue BMW motor vehicle bearing CT license plate. 5. On or about June 30, 2023, Plaintiff was traveling northbound on Stone Street in the City of Hartford, State of Connecticut. Law Office of Michael Chambers Jr. - ATTORNEYS AT LAW 2 Congress Street* Hartford, CT 06114 + (860) 231-9335 + FAX: (888) 859-9496 » JURIS NO. 423287 6. At approximately the same time, Defendant traveling westbound from Broadview Terrace in the City of Hartford, State of Connecticut. 7. Atall relevant times herein after, the defendant was operating his motor vehicle when suddenly and without warning stopped and made a left turn directly into the path of Plaintiff's vehicle. 8. Plaintiff was unable to stop his car in time and violently collided with Defendant's vehicle. 9. The collision, and resulting injuries, losses and damages sustained by the Plaintiff were caused by the carelessness and negligence of Defendant in one or more of the following ways a. Violated Section 14-301 of motor vehicle laws of the State of Connecticut by failing to obey stop sign; Defendant failed to Maintain Proper Lane in violation of Section 14-236 of the State of Connecticut motor vehicle laws; Violated Section 14-240 of motor vehicle laws of the State of Connecticut by failing to drive a reasonable distance apart. Defendant illegally passed on the Right in violation of Section 14-233of the State of Connecticut motor vehicle law; Violated section 14-21 8a(a) of the motor vehicle laws of the State of Connecticut in traveling too fast for the condition; Law Office of Michael Chambers Jr.» ATTORNEYS AT LAW 2 Congress Strects Hartford, CT 061 14 + (860) 231-9535 » FAX: (888) 859-9496 + JURIS NO. 423287 Violated Section 14-224(b)(1) of the motor vehicle taws of the State of Connecticut in causing serious physical injury to any other person; Violated section 14-224(b)(3) of the motor vehicle laws of ihe State of Connecticut in causing injury or damage to property; Operated said automobile with defective or inadequate brakes, or failed to apply brakes in time to avoids aid collision in violation of section 14-218(a)of the State of Connecticut motor vehicle laws; ViolatedSection14-218(a)of the motor vehicle laws of the State of Connecticut operating said motor vehicle at a rate of speed greater than is reasonable having no regard to the width, traffic, and use of the highway, and the weather conditions; The defendant was inattentive and failed to keep a reasonable and proper look out for other vehicles; Defendant failed to keep the vehicle under reasonable control; Defendant failed to maneuver his vehicle to the right or to the left to avoid striking our client's vehicle; although by proper and reasonable exercise of his faculties he could have done so; and Defendant failed to stop said motor vehicle in time to avoid the collision, although by a proper and reasonable exercise of his faculties he could have done so. Law Office of Michael Chambers Jr. - ATTORNEYS AT LAW 2 Congress Street+ Hartford, CT 06114 + (860) 231-9535 + FAX: (888) 859-9496 = JURES NO, 423287 plaintiff received 40. As a result of the negligence and carelessness of the defendant, the and suffered from the injuries listed below. Plaintiff also received a severe shock to his nervous system. From all the injuries listed below or the effects thereof, Plaintiff has suffered injuries, or the and will suffer great pain, mental anguish and nervousness, some of which effects thereof, are, or are likely to be, permanent. Plaintiff's injuries, inter alia, are as follows a Cervical spine sprain and strain; b Lumbar spine sprain and strain; Cc Thoracic spine sprain and strain; Right lower extremity radiating pain; Headaches; Blurry vision inb left eye; Right hand numbness and tingling; Other injuries that have yet to be ascertained. and will incur 11. As a further result of the conduct of the Defendant, the Plaintiff has incurred physical therapy and in the future, inter alia, considerable expenses, pharmaceutical supplies, necessary hospital and medical treatment. 42. Asa further result of the conduct of the Defendant, Plaintiff suffers from the fear and . anxiety that future medical complications may occur arising out of this accident and will 13.As a further result of the conduct of the Defendant, the Plaintiff has suffered continue to suffer from the loss of ability to enjoy life's pleasures and activities. Law Office of Michael Chambers Jr. + ATTORNEYS AT LAW + SURIS NO. 423287 2 Congress Streets Hartford, CT 06114 + (860) 231-9535 * FAX: (888) 859-9496 14, As a further result of the conduct of the Defendant, the Plaintiff has suffered economic damages both past and future including lost wages. THE PLAINTIFF, RICHARD HOLLOWAY BY. 181423287 Michael L. Chambers Jr., Esq. The Law Office of Michael L. Chambers Jr. 2 Congress Street Hartford, CT 06114 Telephone: (860) 231-9535 Facsimile: (888) 859-9496 Juris No.: 423287 His Attorney Michael@mchamberslaw.com Law Office of Michael Chambers Jr. + ATTORNEYS AT LAW 2 Congress Street» Hartford, CT 06114 + (860) 231-9535 * FAX: (888) 859-9496 + JURIS NO. 423287 RETURN DATE: JULY 9, 2024 SUPERIOR COURT RICHARD HOLLOWAY J.D. OF HARTFORD Vv. AT HARTFORD NEISON LUIS HOMAR JUNE 4, 2024 PRAYER FOR RELIEF WHEREFORE, the plaintiff claims: 1 Money damages; 2 Double or treble damages; 2 Costs of this action; Allowable costs; and, Such other relief as the Court deems just and proper. THE PLAINTIFF, RICHARD HOLLOWAY BY. /s/423287 Michael L. Chambers Jr., Esq. The Law Office of Michael L. Chambers Jr. 2 Congress Street Hartford, CT 06114 Telephone: (860) 231-9535 Facsimile: (888) 859-9496 Juris No.: 423287 His Attorney Michael@mchamberslaw.com Law Office of Michael Chambers Jr. » ATTORNEYS AT LAW 2 Congress Street? Hartford, CT 06114 + (860) 231-9535 « FAX: (888) 859-9496 * JURIS NO. 423287 RETURN DATE: JULY 9, 2024 SUPERIOR COURT RICHARD HOLLOWAY J.D. OF HARTFORD Vv AT HARTFORD NEISON LUIS HOMAR JUNE 4, 2024 STATEMENT OF AMOUNT IN DEMAND The amount in demand is $15,000.00 or more, exclusive of costs and interest. THE PLAINTIFF, RICHARD HOLLOWAY BY. [s/423287 Michael L. Chambers Jr., Esq. The Law Office of Michael L. Chambers Jr. 2 Congress Sireet Hartford, CT 06114 Telephone: (860) 231-9535 Facsimile: (888) 859-9496 Juris No.: 423287 His Attorney Michael@mchambersiaw.com Law Office of Michael Chambers Jr. « ATTORNEYS AT LAW 2 Congress Street» Hartford, CT 061 14 + (860) 231-9535 * FAX: (888) 859-9496 » JURIS NO, 423287