Complaint,Petition: SANSONE, DOMINIC v. LENNON, RALSTON G Et Al

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                                30 Lucy Street Woodbridge, CT 06525 (203) 397-1283

PERKINS & ASSOCIATES - Attorneys at Law

 

 

RETURN DATE: JUNE 2, 2020 : SUPERIOR COURT
DOMINIC SANSONE : J.D. OF HARTFORD
VS. : AT HARTFORD

RALSTON G, LENNON AND J.B. HUNT : APRIL 23, 2020
TRANSPORT, INC.

COMPLAINT
1. On or about October 10, 2018 at about 2:39 a.m., the plaintiff, Dominic Sansone, was
operating his motor vehicle on Route 20 Eastbound near its merge with I-91 S, in Windsor
Connecticut.
2. Shortly before the plaintiff was operating his vehicle on Route 20 Eastbound near the
merge with I-91S, the defendant, Ralston G. Lennon, an employee, servant and/or
agent of the defendant, J.B. Hunt Transport, Inc. , was operating a vehicle owned by the
defendant, J.B. Hunt Transport, Inc. when the driveshaft fell off the vehicle causing the
defendant, Ralston G. Lennon, to stop his vehicle further ahead on the roadway.
3. The plaintiff drove over the driveshaft (“the collision”) left in the roadway by the
defendant, Ralston G. Lennon.
4. This collision, and the resulting injuries and losses suffered by the plaintiff were due
to the negligence of the defendant, Ralston G. Lennon , operating a vehicle owned by

the defendant , J.B. Hunt Transport, Inc. in one or more of the following ways:30 Lucy Street Woodbridge, CT 06525 (203) 397-1283

PERKINS & ASSOCIATES - Attorneys at Law

 

 

a. He failed to keep his vehicle under proper and reasonable control;
b. He failed to exercise due care in operating his vehicle.
c. He failed to inspect his vehicle for proper working conditions before engaging
same;
d. He failed to remove said driveshaft from the roadway in a timely manner; and
e. He failed to alert other drivers of the driveshaft in the roadway by way of
cones, flares, or lights.
5. As a result of the collision described above, the plaintiff, suffered the following
injuries, some or all which may be permanent in nature: :

a. Exacerbated his posttraumatic stress disorder;

b. Exacerbated a prior back injury;

c. Headaches; and

d. Emotional Distress.
6. As a result of these injuries, the plaintiff has experienced, and will experience in
the future, painand suffering.
7. Asa further result of these injuries, the plaintiff has incurred, and may

continue to incur, medical expenses.PERKINS & ASSOCIATES - Attorneys at Law

30 Lucy Street Woodbridge, CT 06525 (203) 397-1283

 

 

8. Asa further result of these injuries, the ability of the plaintiff to pursue and

enjoy life's leisure activities has been reduced.

THE PLAINTIFF

  

By:

 
  
 
 

py Dé Lynch
rS & Associates

y Street
Woodbridge, CT 06525
Tel. No.: (203) 397-1283
Juris No.: 42115430 Lucy Street Woodbridge, CT 06525 (203) 397-1283

PERKINS & ASSOCIATES - Attorneys at Law

 

 

RETURN DATE: JUNE 2, 2020

DOMINIC SANSONE

SUPERIOR COURT

J.D. OF HARTFORD

VS. AT HARTFORD
RALSTON G. LENNON AND J.B. HUNT : APRIL 23, 2020
TRANSPORT, INC.

PRAYER FOR RELIEF

The plaintiffs claim:

1.

2.

Monetary relief; and

Such other and further relief as the Court deems appropriate.

  
  

PLAINTIFFS

By:

 
  

. Lynch
& Associates

30 Jducy Street
oodbridge, CT 06525
Tel. No.: (203) 397-1283
Juris No.: 42115430 Lucy Street Woodbridge, CT 06525 (203) 397-1283

PERKINS & ASSOCIATES - Attorneys at Law

 

 

RETURN DATE: JUNE 2, 2020
DOMINIC SANSONE

VS.

RALSTON G. LENNON AND J.B. HUNT

TRANSPORT, INC.

SUPERIOR COURT
J.D. OF HARTFORD
AT HARTFORD

APRIL 23, 2020

STATEMENT OF AMOUNT IN DEMAND

 

The amount in demand is greater than $15,000.00, exclusive of interest and costs.

THE PLAINTIFFS

 
 

By:

   

L\
¢ D.|Lynch