On September 02, 2021 a
Miscellaneous
was filed
involving a dispute between
D'Ambra,
D'Ambra, Lisa,
D'Ambra, Sr., Vincent,
and
Dp23 Bulldogs, Llc.,
Dp23 Bulldogs Llc.,,
Plourde, Daniel,
for Torts
in the District Court of Worcester County.
Preview
DOCKET NUMBER Trial Court of Massachusetts
CIVIL ACTION COVER SHEET The Superior Court
COUNTY WORCESTER
Vincent D'Ambra, Lisa D'Ambra Individually and as
Plaintiff Defendant: DP23 Bulldogs, LLC., & Daniel Plourde
ADDRESS: next friend of Morgan, Charlotte, Lucy, & Vincent Jr. ADDRESS: 5 Quoaboag Street, Brookfield, MA
15 Robin Way, Meredith,NH
Kelsey Raycroft Rose
Plaintiff Attorney: Defendant Attorney:
ADDRESS: Morgan & Morgan P.A. ADDRESS:
One State Street, 7th Floor
Boston, MA 02109
BBO: 692102 BBO:
TYPE OF ACTION AND TRACK DESIGNATION (see instructions section below)
CODE NO. TYPE OF ACTION (specify) TRACK HAS A JURY CLAIM BEEN MADE?
B04 Other Negligence - Personal Injury F-Fast Track X YES NO
*If "Other" please describe:
Is there a claim under G.L. c. 93A? Is there a class action under Mass. R. Civ. P. 23?
YES X NO YES X NO
STATEMENT OF DAMAGES PURSUANT TO G.L. c. 212, § 3A
The following is a full, itemized and detailed statement of the facts on which the undersigned plaintiff or plaintiff's counsel relies to determine money damages.
For this form, disregard double or treble damage claims; indicate single damages only.
TORT CLAIMS
A. Documented medical expenses to date
1. Total hospital expenses $1,500,000.00 (ongoing)
2. Total doctor expenses
3. Total chiropractic expenses
4. Total physical therapy expenses
5. Total other expenses (describe below)
Subtotal (1-5): $1,500,000.00
B. Documented lost wages and compensation to date $225,000.00 (ongoing)
C. Documented property damages to date
D. Reasonably anticipated future medical and hospital expenses $5,000,000.00
E. Reasonably anticipated lost wages $750,000.00
F. Other documented items of damages (describe below) $10,000.00
Pain & Suffering, Loss of function, Loss of enjoyment, Loss of consortium x5
TOTAL (A-F): $17,475,000.00
G. Briefly describe plaintiff's injury, including the nature and extent of injury:
Permanent paralysis due to hyperextension and fractures of the cervical spine, head injury.
CONTRACT CLAIMS
This action includes a claim involving collection of a debt incurred pursuant to a revolving credit agreement. Mass. R. Civ. P. 8.1(a).
Item # Detailed Description of Each Claim Amount
1.
Total
Signature of Attorney/Unrepresented Plaintiff: X Date: 08/31/21
RELATED ACTIONS: Please provide the case number, case name, and county of any related actions pending in the Superior Court.
CERTIFICATION PURSUANT TO SJC RULE 1:18
I hereby certify that I have complied with requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SJC Rule 1:18) requiring that I provide my
clients with information about court-connected dispute resolution services and discuss with them the advantages and disadvantages of the various methods of dispute resolution.
Signature of Attorney/Unrepresented Plaintiff: X Date: 08/31/21
SC0001: 1/22/2021 www.mass.gov/courts Date/Time Printed:07-08-2021 15:39:55
Document Filed Date
September 02, 2021
Case Filing Date
September 02, 2021
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