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  • D'Ambra, Sr., Vincent et al vs. DP23 Bulldogs LLC., et al Other Negligence - Personal Injury / Property Damage document preview
  • D'Ambra, Sr., Vincent et al vs. DP23 Bulldogs LLC., et al Other Negligence - Personal Injury / Property Damage document preview
						
                                

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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