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DOCKET NO. KNL-CV19-6042579-S : SUPERIOR COURT
MORGAN MARCAURELE : J.D. OF NEW LONDON
VS. : AT NEW LONDON
JOSE ZAPORTA ET AL : APRIL 8, 2020
ANSWER TO AMENDED COMPLAINT
COUNT ONE
This Count is not directed to this defendant; therefore, this defendant does not plead to
same.
COUNT TWO
1. As to the allegations contained in paragraph 1, this defendant has no knowledge
and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff
to her proof thereof.
2. As to the allegations contained in paragraph 2, this defendant has no knowledge
and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff
to her proof thereof.
3. Paragraph 3 is admitted.
{00962933.DOC}
GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067
TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029
4. As to the allegations contained in paragraph 4, this defendant has no knowledge
and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff
to her proof thereof.
5. So much of paragraph 5 as alleges, “On said date and at said time and pleace, the
Defendant, JOSE ZAPORTA, traveled directly into the path of the motor vehicle operated by the
Defendant SAMUEL LUEBKE, which was traveling eastbound through the intersection, causing
a T-bone collision between the vehicles,” is admitted. As to the remaining allegations contained
in paragraph 5, this defendant has no knowledge and/or information sufficient to form a belief
and therefore denies same and leaves the plaintiff to her proof thereof.
6. Paragraph 6 is admitted.
7. Paragraph 7 is denied.
8. So much of paragraph 8 as alleges, “As a result of the negligence of the Defendant
SAMUEL LUEBKE as aforesaid, is denied. As to the remaining allegations contained in
paragraph 8, this defendant has no knowledge and/or information sufficient to form a belief and
therefore denies same and leaves the plaintiff to her proof thereof.
8*1. So much of the second paragraph 8 as alleges, “As a further consequence of the
negligence of the Defendant SAMUEL LUEBKE as aforesaid,” is denied. As to the remaining
allegations contained in the second paragraph 8, this defendant has no knowledge and/or
1
*Count Two of the plaintiff’s Amended Complaint contains two paragraphs numbered 8.
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GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067
TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029
information sufficient to form a belief and therefore denies same and leaves the plaintiff to her
proof thereof.
9. So much of paragraph 9 as alleges, “As a further consequence of the negligence of
the Defendant SAMUEL LUEBKE as aforesaid,” is denied. As to the remaining allegations
contained in paragraph 9, this defendant has no knowledge and/or information sufficient to form
a belief and therefore denies same and leaves the plaintiff to her proof thereof.
10. So much of paragraph 10 as alleges, “As a further consequence of the negligence of
the Defendant SAMUEL LUEBKE, as aforesaid,” is denied. As to the remaining allegations
contained in paragraph 10, this defendant has no knowledge and/or information sufficient to
form a belief and therefore denies same and leaves the plaintiff to her proof thereof.
COUNT THREE
This Count is not directed to this defendant; therefore, this defendant does not plead to
same.
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GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067
TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029
COUNT FOUR
This Count is not directed to this defendant; therefore, this defendant does not plead to
same.
DEFENDANT: Samuel Luebke
BY__ 413278 Janis K. Malec___
JANIS K. MALEC
Gordon, Muir and Foley, LLP
1344 Silas Deane Highway, Ste. 501
Rocky Hill, CT 06067
860-525-5361 ext. 102
jmalec@gmflaw.com
{00962933.DOC}
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GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067
TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029
CERTIFICATION
I certify that a copy of this document was or will immediately be mailed or delivered
electronically or non-electronically on April 8, 2020 to all attorneys and self-represented parties
of record and that written consent for electronic delivery was received from all attorneys and
self-represented parties of record who received or will immediately be receiving electronic
delivery.
Donald E. Leone, Jr.
Chinigo Leone & Maruzo LLP
PO Box 510
Norwich, CT 06360
Email: dleone@norwichlaw.com
Vincent Di Palma, Esq.
Meehan Roberts Turret & Rosenbaum
108 Leigus Road, 1st Floor
Wallingford, CT 06492
Email: lmlawct@libertymutual.com
Joseph A. Marotti, Esq.
Monstream Law Group LLP
PO Box 1087
Glastonbury, CT 06033
Email: JMarotti@mlgwc.com
BY___/s/ Janis K. Malec ______
JANIS K. MALEC
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GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067
TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029
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DOCKET NO. KNL-CV19-6042579-S : SUPERIOR COURT MORGAN MARCAURELE : J.D. OF NEW LONDON VS. : AT NEW LONDON JOSE ZAPORTA ET AL : APRIL 8, 2020 ANSWER TO AMENDED COMPLAINT COUNT ONE This Count is not directed to this defendant; therefore, this defendant does not plead to same. COUNT TWO 1. As to the allegations contained in paragraph 1, this defendant has no knowledge and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff to her proof thereof. 2. As to the allegations contained in paragraph 2, this defendant has no knowledge and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff to her proof thereof. 3. Paragraph 3 is admitted. {00962933.DOC} GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067 TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029 4. As to the allegations contained in paragraph 4, this defendant has no knowledge and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff to her proof thereof. 5. So much of paragraph 5 as alleges, “On said date and at said time and pleace, the Defendant, JOSE ZAPORTA, traveled directly into the path of the motor vehicle operated by the Defendant SAMUEL LUEBKE, which was traveling eastbound through the intersection, causing a T-bone collision between the vehicles,” is admitted. As to the remaining allegations contained in paragraph 5, this defendant has no knowledge and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff to her proof thereof. 6. Paragraph 6 is admitted. 7. Paragraph 7 is denied. 8. So much of paragraph 8 as alleges, “As a result of the negligence of the Defendant SAMUEL LUEBKE as aforesaid, is denied. As to the remaining allegations contained in paragraph 8, this defendant has no knowledge and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff to her proof thereof. 8*1. So much of the second paragraph 8 as alleges, “As a further consequence of the negligence of the Defendant SAMUEL LUEBKE as aforesaid,” is denied. As to the remaining allegations contained in the second paragraph 8, this defendant has no knowledge and/or 1 *Count Two of the plaintiff’s Amended Complaint contains two paragraphs numbered 8. {00962933.DOC} 2 GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067 TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029 information sufficient to form a belief and therefore denies same and leaves the plaintiff to her proof thereof. 9. So much of paragraph 9 as alleges, “As a further consequence of the negligence of the Defendant SAMUEL LUEBKE as aforesaid,” is denied. As to the remaining allegations contained in paragraph 9, this defendant has no knowledge and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff to her proof thereof. 10. So much of paragraph 10 as alleges, “As a further consequence of the negligence of the Defendant SAMUEL LUEBKE, as aforesaid,” is denied. As to the remaining allegations contained in paragraph 10, this defendant has no knowledge and/or information sufficient to form a belief and therefore denies same and leaves the plaintiff to her proof thereof. COUNT THREE This Count is not directed to this defendant; therefore, this defendant does not plead to same. {00962933.DOC} 3 GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067 TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029 COUNT FOUR This Count is not directed to this defendant; therefore, this defendant does not plead to same. DEFENDANT: Samuel Luebke BY__ 413278 Janis K. Malec___ JANIS K. MALEC Gordon, Muir and Foley, LLP 1344 Silas Deane Highway, Ste. 501 Rocky Hill, CT 06067 860-525-5361 ext. 102 jmalec@gmflaw.com {00962933.DOC} 4 GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067 TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029 CERTIFICATION I certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on April 8, 2020 to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys and self-represented parties of record who received or will immediately be receiving electronic delivery. Donald E. Leone, Jr. Chinigo Leone & Maruzo LLP PO Box 510 Norwich, CT 06360 Email: dleone@norwichlaw.com Vincent Di Palma, Esq. Meehan Roberts Turret & Rosenbaum 108 Leigus Road, 1st Floor Wallingford, CT 06492 Email: lmlawct@libertymutual.com Joseph A. Marotti, Esq. Monstream Law Group LLP PO Box 1087 Glastonbury, CT 06033 Email: JMarotti@mlgwc.com BY___/s/ Janis K. Malec ______ JANIS K. MALEC {00962933.DOC} 5 GORDON, MUIR AND FOLEY, LLP, ATTORNEYS AT LAW, 1344 SILAS DEANE HIGHWAY, SUITE 501, ROCKY HILL, CT 06067 TELEPHONE (860)525-5361 FAX (860)525-4849 JURIS NO. 24029