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RETURN DATE: May 19, 2020 SUPERIOR COURT
JOSEPH T. RONDINONE, ET AL J.D. OF MIDDLESEX
Vv. AT MIDDLETOWN
CHARLES F. MONZEGLIO, JR., ET AL APRIL 2, 2020
COMPLAINT
FIRST COUNT: (Joseph T. Rondinone v. Charles F. Monzeglio, Jr.)
1 On October 24, 2018, at approximately 5:29 a.m., the plaintiff, Joseph
T. Rondinone, was the operator of a motor vehicle traveling west on East High
Street, and was approaching its intersection with Lake Drive, both public streets or
highways in East Hampton, Connecticut.
2. At the same time and place, the defendant, Charles F. Monzeglio, Jr.
was the operator of a motor vehicle traveling south on Lake Drive, and had reached
its intersection with East High Street.
3 Atall times mentioned herein, southbound traffic on Lake Drive faced
a stop sign at its intersection with East High Street.
4 At the same time and place, the motor vehicle operated by the
defendant, Charles F. Monzeglio, Jr., suddenly and without warning, entered the
intersection and collided with the motor vehicle operated by the plaintiff, Joseph T.
Rondinone, thereby causing the plaintiff to suffer the injuries and losses set forth
below.
5 The collision was caused by the negligence of the defendant, Charles
F. Monzeglio, Jr., in one or more of the following ways:
a) he failed to keep a reasonable and proper lookout
for other vehicles on the road;
b) he failed to turn or swerve so as to avoid the
collision;
c) he failed to apply the brakes in time to avoid the
collision;
d) he failed to sound the horn or give a timely
warning of the impending collision;
—— _ _
°) he failed to “keep the vehicle under proper
control;
he was inattentive in the operation of the vehicle;
8) he operated the vehicle at a rate of speed greater
than was reasonable, having due regard to the
width, traffic, and use of the highway, road, the
intersection of streets and/or weather conditions,
in violation of § 14-218a of the Connecticut
General Statutes;
h) he moved the vehicle from a stopped position
when it was not reasonably safe to do so, in
violation of § 14-243(a) of the Connecticut
General Statutes;
i) he turned the vehicle left upon the roadway when
it was unsafe to do so, in violation of § 14-242(a)
of the Connecticut General Statutes;
jd he failed to yield the right of way to vehicles on
East High Street when attempting to turn left
onto East High Street, in violation of § 14-242(e)
of the Connecticut General Statutes;
k) he failed to stop at a stop sign and/or failed to
yield the right of way to traffic on East High
Street while facing a stop sign, in violation of §
14-301 of the Connecticut General Statutes;
and/or
_ a _ —- ° he operated a vehicle so as to obstruct or impede
_._.traffie,_in_ violation. of .§ 14-240(b) ofthe...
Connecticut General Statutes.
6 As a result of the collision, the plaintiff, Joseph T. Rondinone,
suffered the following injuries, some or all of which may be permanent in nature:
a) contusion and laceration to his forehead;
b) scarring and disfigurement;
c) facial bruising and swelling;
d) neck pain;
e) back pain; and
) pain and suffering, both mental and physical.
7
As a further result of the collision, the plaintiff, Joseph T. Rondinone,
was forced to incur expenses for medical care and treatment, and will likely incur
additional expenses in the future.
8 As a further result of the collision, the plaintiff, Joseph T. Rondinone,
was unable and remains unable to participate in and enjoy his usual activities.
SECOND COUNT: (Joseph T. Rondinone v. CMF Construction Corporation)
1-8. Paragraphs 1 through 8 of the First Count are hereby incorporated and
made corresponding paragraphs of this Second Count as if fully set forth herein.
9. At all times mentioned herein, the defendant, CMF Construction
_ a - — a _
Corporation, was and is aConnecticut corporation located at 150 Sycamore Street in
Glastonbury, Connecticut.
10. At all times mentioned herein, the defendant, CMF Construction
Corporation, owned the motor vehicle operated by Charles F. Monzeglio, Jr.
ll. At all times mentioned herein, Charles F, Monzeglio, Jr. was operating
the motor vehicle with the permission of the defendant, CMF Construction
Corporation.
12, At all times mentioned herein, Charles F. Monzeglio, Jr. was operating
the motor vehicle as the agent, servant and/or employee of the defendant, CMF
Construction Corporation.
13. At all times mentioned herein, Charles F. Monzeglio, Jr. was operating
the motor vehicle as the agent of the defendant, CMF Construction Corporation,
pursuant to Connecticut General Statute §52-183.
THIRD COUNT: (Joseph M. Rondinone PPA Nicole Brean v. Charles F.
Monzeglio, Jr.)
1 The minor plaintiff, Joseph M. Rondinone, brings this action by and
through his mother and next friend, Nicole Brean.
ao 2. _ On October
24, 2018, at approximately
5:29 a.m., the minor plaintiff,
Joseph M. Rondinone, was a passenger in a motor vehicle traveling west on East
High Street, and was approaching its intersection with Lake Drive, both public
streets or highways in East Hampton, Connecticut.
3 At the same time and place, the defendant, Charles F. Monzeglio, Jr.,
was the operator of a motor vehicle traveling south on Lake Drive, and had reached
its intersection with East High Street.
4 At all times mentioned herein, southbound traffic on Lake Drive faced
a stop sign at its intersection with East High Street.
5 At the same time and place, the motor vehicle operated by the
defendant, Charles F. Monzeglio, Jr., suddenly and without warning
, entered the
intersection and collided with the motor vehicle occupied by the minor
plaintiff,
Joseph M. Rondinone, thereby causing him to suffer the injuries and losses
set forth
below.
6 The collision was caused by the negligence of the defendant, Charles
F. Monzeglio, Jr., in one or more of the following ways:
a) he failed to keep a reasonable and proper lookout
- for other vehicles on the road; _ ae
b) he failed to turn or swerve so as to avoid the
collision;
°) he failed to apply the brakes in time to avoid the
collision;
@) he failed to sound the horn or give a timely
warning of the impending collision;
e) he failed to keep the vehicle under proper
control;
he was inattentive in the operation of the vehicle;
8) he operated the vehicle at a rate of speed greater
than was reasonable, having due regard to the
width, traffic, and use of the highway, road, the
intersection of streets and/or weather conditions,
in violation of § 14-218a of the Connecticut
General Statutes;
h) he moved the vehicle from a stopped position
when it was not reasonably safe to do so, in
violation of § 14-243(a) of the Connecticut
General Statutes;
i) he turned the vehicle left upon the roadway when
it was unsafe to do so, in violation of § 14-242(a)
of the Connecticut General Statutes;
jd he failed to yield the right of way to vehicles on
East High Street when attempting to turn left
onto East High Street, in violation of § 14-242(e)
—— _of the Connecticut General Statutes; an
k) he failed to stop at a stop sign and/or failed to
yield the right of way to traffic on East High
Street while facing a stop sign, in violation of §
14-301 of the Connecticut General Statutes;
and/or
D he operated a vehicle so as to obstruct or impede
traffic, in violation of § 14-240(b) of the
Connecticut General Statutes.
7 As a result of the collision, the minor plaintiff, Joseph M. Rondinone,
suffered the following injuries, some or all of which may be permanent in nature:
a) contusions and bruising throughout his head, body, and
extremities;
b) neck pain;
°) shoulder pain; head pain;
d) back pain;
e) post-traumatic stress and anxiety; and
pain and suffering, both mental and physical.
8 As a further result of the collision, the plaintiff, Nicole Brean, was
forced to incur expenses for medical care and treatment for her son, and will likely
incur additional expenses in the future on his behalf.
— a a oe
9 As a further result of the collision, the minor plaintite Joseph M.
Rondinone, was unable and remains unable to participate in and enjoy his usual
activities.
FOURTH COUNT: (Joseph M. Rondinone v. CMF Construction Corporation)
1-9. Paragraphs | through 9 of the Third Count are hereby incorporated and
made corresponding paragraphs of this Fourth Count as if fully set forth herein.
10. At all times mentioned herein, the defendant, CMF Construction
Corporation, was and is a Connecticut corporation located at 150 Sycamore Street in
Glastonbury, Connecticut
11. At all times mentioned herein, the defendant, CMF Construction
Corporation, owned the motor vehicle operated by Charles F, Monzeglio, Jr.
12. At all times mentioned herein, Charles F. Monzeglio, Jr. was operating
the motor vehicle with the permission of the defendant, CMF Construction
Corporation.
13, At all times mentioned herein, Charles F. Monzeglio, Jr. was operating
the motor vehicle as the agent, servant and/or employee of the defendant, CMF
— a - _— ee So a _
~~-—~~Construction Corporation.
14. At all times mentioned herein, Charles F. Monzeglio, Jr. was operating
the motor vehicle as the agent of the defendant, CMF Construction Corporation,
pursuant to Connecticut General Statute §52-183.
WHEREFORE, the plaintiffs claim:
1 Monetary damages.
THE PLAINTIFFS,
JOSEPH T.
M. RONDINONE PPA
NICOLE BREAN
Brian M. Flood
The Flood Law Firm, LLC
190 Washington Street
Middletown, CT 06457
860 346-2695
Juris #433718
ne i ae a we _— a ea
RETURN DATE: May 19, 2020 SUPERIOR COURT
JOSEPH T. RONDINONE, ET AL J.D, OF MIDDLESEX
Vv. AT MIDDLETOWN
CHARLES F. MONZEGLIO, JR., ET AL APRIL 2, 2020
STATEMENT OF AMOUNT IN DEMAND
The amount of money damages claimed is greater than Fifteen Thousand
Dollars ($15,000.00), exclusive of interest and costs.
THE PLAINTIF)
JOSE ONDIN!
PH M. RO IONE PPA
NICOLE BREAN
oe a oo Sf Sy oe SL. o
rian M. Flood
The Flood Law Firm, LLC
190 Washington Street
Middletown, CT 06457
860 346-2695
Juris #433718
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RETURN DATE: May 19, 2020 SUPERIOR COURT JOSEPH T. RONDINONE, ET AL J.D. OF MIDDLESEX Vv. AT MIDDLETOWN CHARLES F. MONZEGLIO, JR., ET AL APRIL 2, 2020 COMPLAINT FIRST COUNT: (Joseph T. Rondinone v. Charles F. Monzeglio, Jr.) 1 On October 24, 2018, at approximately 5:29 a.m., the plaintiff, Joseph T. Rondinone, was the operator of a motor vehicle traveling west on East High Street, and was approaching its intersection with Lake Drive, both public streets or highways in East Hampton, Connecticut. 2. At the same time and place, the defendant, Charles F. Monzeglio, Jr. was the operator of a motor vehicle traveling south on Lake Drive, and had reached its intersection with East High Street. 3 Atall times mentioned herein, southbound traffic on Lake Drive faced a stop sign at its intersection with East High Street. 4 At the same time and place, the motor vehicle operated by the defendant, Charles F. Monzeglio, Jr., suddenly and without warning, entered the intersection and collided with the motor vehicle operated by the plaintiff, Joseph T. Rondinone, thereby causing the plaintiff to suffer the injuries and losses set forth below. 5 The collision was caused by the negligence of the defendant, Charles F. Monzeglio, Jr., in one or more of the following ways: a) he failed to keep a reasonable and proper lookout for other vehicles on the road; b) he failed to turn or swerve so as to avoid the collision; c) he failed to apply the brakes in time to avoid the collision; d) he failed to sound the horn or give a timely warning of the impending collision; —— _ _ °) he failed to “keep the vehicle under proper control; he was inattentive in the operation of the vehicle; 8) he operated the vehicle at a rate of speed greater than was reasonable, having due regard to the width, traffic, and use of the highway, road, the intersection of streets and/or weather conditions, in violation of § 14-218a of the Connecticut General Statutes; h) he moved the vehicle from a stopped position when it was not reasonably safe to do so, in violation of § 14-243(a) of the Connecticut General Statutes; i) he turned the vehicle left upon the roadway when it was unsafe to do so, in violation of § 14-242(a) of the Connecticut General Statutes; jd he failed to yield the right of way to vehicles on East High Street when attempting to turn left onto East High Street, in violation of § 14-242(e) of the Connecticut General Statutes; k) he failed to stop at a stop sign and/or failed to yield the right of way to traffic on East High Street while facing a stop sign, in violation of § 14-301 of the Connecticut General Statutes; and/or _ a _ —- ° he operated a vehicle so as to obstruct or impede _._.traffie,_in_ violation. of .§ 14-240(b) ofthe... Connecticut General Statutes. 6 As a result of the collision, the plaintiff, Joseph T. Rondinone, suffered the following injuries, some or all of which may be permanent in nature: a) contusion and laceration to his forehead; b) scarring and disfigurement; c) facial bruising and swelling; d) neck pain; e) back pain; and ) pain and suffering, both mental and physical. 7 As a further result of the collision, the plaintiff, Joseph T. Rondinone, was forced to incur expenses for medical care and treatment, and will likely incur additional expenses in the future. 8 As a further result of the collision, the plaintiff, Joseph T. Rondinone, was unable and remains unable to participate in and enjoy his usual activities. SECOND COUNT: (Joseph T. Rondinone v. CMF Construction Corporation) 1-8. Paragraphs 1 through 8 of the First Count are hereby incorporated and made corresponding paragraphs of this Second Count as if fully set forth herein. 9. At all times mentioned herein, the defendant, CMF Construction _ a - — a _ Corporation, was and is aConnecticut corporation located at 150 Sycamore Street in Glastonbury, Connecticut. 10. At all times mentioned herein, the defendant, CMF Construction Corporation, owned the motor vehicle operated by Charles F. Monzeglio, Jr. ll. At all times mentioned herein, Charles F, Monzeglio, Jr. was operating the motor vehicle with the permission of the defendant, CMF Construction Corporation. 12, At all times mentioned herein, Charles F. Monzeglio, Jr. was operating the motor vehicle as the agent, servant and/or employee of the defendant, CMF Construction Corporation. 13. At all times mentioned herein, Charles F. Monzeglio, Jr. was operating the motor vehicle as the agent of the defendant, CMF Construction Corporation, pursuant to Connecticut General Statute §52-183. THIRD COUNT: (Joseph M. Rondinone PPA Nicole Brean v. Charles F. Monzeglio, Jr.) 1 The minor plaintiff, Joseph M. Rondinone, brings this action by and through his mother and next friend, Nicole Brean. ao 2. _ On October 24, 2018, at approximately 5:29 a.m., the minor plaintiff, Joseph M. Rondinone, was a passenger in a motor vehicle traveling west on East High Street, and was approaching its intersection with Lake Drive, both public streets or highways in East Hampton, Connecticut. 3 At the same time and place, the defendant, Charles F. Monzeglio, Jr., was the operator of a motor vehicle traveling south on Lake Drive, and had reached its intersection with East High Street. 4 At all times mentioned herein, southbound traffic on Lake Drive faced a stop sign at its intersection with East High Street. 5 At the same time and place, the motor vehicle operated by the defendant, Charles F. Monzeglio, Jr., suddenly and without warning , entered the intersection and collided with the motor vehicle occupied by the minor plaintiff, Joseph M. Rondinone, thereby causing him to suffer the injuries and losses set forth below. 6 The collision was caused by the negligence of the defendant, Charles F. Monzeglio, Jr., in one or more of the following ways: a) he failed to keep a reasonable and proper lookout - for other vehicles on the road; _ ae b) he failed to turn or swerve so as to avoid the collision; °) he failed to apply the brakes in time to avoid the collision; @) he failed to sound the horn or give a timely warning of the impending collision; e) he failed to keep the vehicle under proper control; he was inattentive in the operation of the vehicle; 8) he operated the vehicle at a rate of speed greater than was reasonable, having due regard to the width, traffic, and use of the highway, road, the intersection of streets and/or weather conditions, in violation of § 14-218a of the Connecticut General Statutes; h) he moved the vehicle from a stopped position when it was not reasonably safe to do so, in violation of § 14-243(a) of the Connecticut General Statutes; i) he turned the vehicle left upon the roadway when it was unsafe to do so, in violation of § 14-242(a) of the Connecticut General Statutes; jd he failed to yield the right of way to vehicles on East High Street when attempting to turn left onto East High Street, in violation of § 14-242(e) —— _of the Connecticut General Statutes; an k) he failed to stop at a stop sign and/or failed to yield the right of way to traffic on East High Street while facing a stop sign, in violation of § 14-301 of the Connecticut General Statutes; and/or D he operated a vehicle so as to obstruct or impede traffic, in violation of § 14-240(b) of the Connecticut General Statutes. 7 As a result of the collision, the minor plaintiff, Joseph M. Rondinone, suffered the following injuries, some or all of which may be permanent in nature: a) contusions and bruising throughout his head, body, and extremities; b) neck pain; °) shoulder pain; head pain; d) back pain; e) post-traumatic stress and anxiety; and pain and suffering, both mental and physical. 8 As a further result of the collision, the plaintiff, Nicole Brean, was forced to incur expenses for medical care and treatment for her son, and will likely incur additional expenses in the future on his behalf. — a a oe 9 As a further result of the collision, the minor plaintite Joseph M. Rondinone, was unable and remains unable to participate in and enjoy his usual activities. FOURTH COUNT: (Joseph M. Rondinone v. CMF Construction Corporation) 1-9. Paragraphs | through 9 of the Third Count are hereby incorporated and made corresponding paragraphs of this Fourth Count as if fully set forth herein. 10. At all times mentioned herein, the defendant, CMF Construction Corporation, was and is a Connecticut corporation located at 150 Sycamore Street in Glastonbury, Connecticut 11. At all times mentioned herein, the defendant, CMF Construction Corporation, owned the motor vehicle operated by Charles F, Monzeglio, Jr. 12. At all times mentioned herein, Charles F. Monzeglio, Jr. was operating the motor vehicle with the permission of the defendant, CMF Construction Corporation. 13, At all times mentioned herein, Charles F. Monzeglio, Jr. was operating the motor vehicle as the agent, servant and/or employee of the defendant, CMF — a - _— ee So a _ ~~-—~~Construction Corporation. 14. At all times mentioned herein, Charles F. Monzeglio, Jr. was operating the motor vehicle as the agent of the defendant, CMF Construction Corporation, pursuant to Connecticut General Statute §52-183. WHEREFORE, the plaintiffs claim: 1 Monetary damages. THE PLAINTIFFS, JOSEPH T. M. RONDINONE PPA NICOLE BREAN Brian M. Flood The Flood Law Firm, LLC 190 Washington Street Middletown, CT 06457 860 346-2695 Juris #433718 ne i ae a we _— a ea RETURN DATE: May 19, 2020 SUPERIOR COURT JOSEPH T. RONDINONE, ET AL J.D, OF MIDDLESEX Vv. AT MIDDLETOWN CHARLES F. MONZEGLIO, JR., ET AL APRIL 2, 2020 STATEMENT OF AMOUNT IN DEMAND The amount of money damages claimed is greater than Fifteen Thousand Dollars ($15,000.00), exclusive of interest and costs. THE PLAINTIF) JOSE ONDIN! PH M. RO IONE PPA NICOLE BREAN oe a oo Sf Sy oe SL. o rian M. Flood The Flood Law Firm, LLC 190 Washington Street Middletown, CT 06457 860 346-2695 Juris #433718