On June 05, 2014 a
Complaint,Petition
was filed
involving a dispute between
David Confeiteiro,
and
Gelco Corporation,
Tatiana Mezarina-Rojas,
The Nielsen Company,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of Fairfield County.
Preview
RETURN DATE: JUNE 24, 2014 SUPERIOR COURT
DAVID CONFEITEIRO J. D. OF FAIRFIELD
V AT BRIDGEPORT
TATIANA MEZARINA-ROJAS ET AL MAY 30, 2014
COMPLAINT
I
On June 4, 2012, the plaintiff, DAVID CONFEITEIRO was operating his vehicle in a northerly
direction on Interstate 95 a public highway in the town of Bridgeport, Connecticut, slowing for
traffic.
II
On said date at approximately 6:30p.m., the defendant TATIANA MEZARINA ROJAS was
operating a vehicle owned by the defendant GELCO CORPORATION and leased/rented by
the defendant THE NIELSEN COMPANY(US), LLC also in a northerly direction on said
Interstate 95 and to the rear of the plaintiff vehicle when suddenly and without warning, she
collided into the rear of the plaintiff vehicle causing him to sustain the serious and painful
injuries and losses hereinafter set forth.
III
At all times relevant to this complaint, the defendant TATIANA MEZARINA ROJAS was
operating the vehicle rented/leased by the defendant THE NIELSEN COMPANY(US), LLC
and owned by the defendant GELCO CORPORATION, as their agent, servant and/or
employee, or she was operating said vehicle as a family vehicle with a general authority to
operate same.
IV
Said collision and resultant injuries and losses were caused by the carelessness and negligence of
the defendants in any one or more of the following respects:
1. In that said defendant TATIANA MEZARINA ROJAS was inattentive and failed to
keep and operate said vehicle under reasonable and proper control;
2. In that said defendant TATIANA MEZARINA ROJAS she was inattentive and failed to
keep a proper lookout for other vehicles lawfully upon said highway;
3. In that said defendant TATIANA MEZARINA ROJAS, operated said vehicle at a
greater rate of speed than was warranted for the conditions then and there existing;
4. In that said defendant TATIANA MEZARINA ROJAS violated Connecticut General
Statute 14-240 in following the plaintiff’s vehicle more closely than was reasonable;
5. In that said defendant TATIANA MEZARINA ROJAS failed to give the plaintiff a
timely warning or any warning whatsoever of her approach;
6. In that said defendant TATIANA MEZARINA ROJAS failed to apply the brakes in
time to avoid said collision and/or said defendants THE NIELSEN COMPANY(US),
LLC and/or GELCO CORPORATION allowed and permitted said vehicle to be
operated with defective or inadequate brakes;
7. In that said defendant TATIANA MEZARINA ROJAS failed to steer her vehicle to the
right or left so as to avoid said collision;
8. In that said defendants THE NIELSEN COMPANY(US), LLC and/or GELCO
CORPORATION failed to properly instruct said defendant TATIANA MEZARINA
ROJAS as to the proper use and operation of said vehicle.
V
As a consequence of said carelessness and negligence of the defendants, the plaintiff received
and suffered from:
1. Acceleration/deceleration trauma to the cervical spine;
2. Acute Musculoligamentous strain/sprain of the thoracic spine; which has now progressed
to the sub-acute phase
3. Acute Musculoligamentous strain/sprain of the Lumbosacral spine; which has now
progressed to the sub-acute phase
4. Post traumatic TMJ type symptoms;
5. Headaches post concussive, cervicogenic or post traumatic muscle tension type;
6. Soft tissue injury is evidenced by posterior joint capsule tenderness during motion
palpation as well as myofascial spasm trigger points and hypertonicity present throughout
the paravertebral musculature;
7. Acute Musculoligamentous strain of the cervical spine;
8. Acute lateral-epicondylitis, left elbow
9. Pain and obvious limp left hip with tenderness over the trochanteric bursa with pain on
active abduction
10. Dizziness
11. Right Sided occipital neuralgia
12. Jaw displacement with internal derangement of the temporomandibular joint. He has
slipped disc of the temporomandibular joint system;
13. Contusion to the trigeminal nerve;
14. Contusion to the facial nerve;
From all of which injuries or the effects therefrom were severe and painful, causing the plaintiff
to undergo injections as well as a cervical disc laminectomy and some of which injuries are
permanent in nature.
VI
As a further consequence of said carelessness and negligence of the defendants, and resultant
injuries of the plaintiff, he has been obliged to expend a large sum of money for medical care and
attention and may be so obliged to do so in the future.
VII
As a further consequence of said carelessness and negligence of the defendants, and resultant
injuries, the plaintiff has been unable to attend to the duties of his employment for a
considerable period of time and lost the income therefrom and will be so disabled in the future.
VIII
As a further consequence of said carelessness and negligence of the defendants and resultant
injuries, the plaintiff’s normal activities and enjoyments of life have been impaired for a
considerable period of time and will be so impaired in the future.
______________________________/015768/
Joseph S. Dobrowolski
Commissioner of the Superior Court
RETURN DATE: JUNE 24, 2014 SUPERIOR COURT
DAVID CONFEITEIRO J. D. OF FAIRFIELD
V AT BRIDGEPORT
TATIANA MEZARINA-ROJAS ET AL MAY 30, 2014
DEMAND FOR RELIEF
WHEREFORE, the plaintiff claims compensatory damages within the jurisdiction of this court.
The amount, legal interest or property in demand is in excess of FIFTEEN THOUSAND
($15,000.00) DOLLARS, exclusive of interest and costs.
THE PLAINTIFF
BY____________________________/015768/_
Joseph S. Dobrowolski, his attorney
51 Elm St., New Haven, CT 06510
(203)787-1293
Fax # 203-782-2116
Document Filed Date
June 05, 2014
Case Filing Date
June 05, 2014
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
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RETURN DATE: JUNE 24, 2014 SUPERIOR COURT DAVID CONFEITEIRO J. D. OF FAIRFIELD V AT BRIDGEPORT TATIANA MEZARINA-ROJAS ET AL MAY 30, 2014 COMPLAINT I On June 4, 2012, the plaintiff, DAVID CONFEITEIRO was operating his vehicle in a northerly direction on Interstate 95 a public highway in the town of Bridgeport, Connecticut, slowing for traffic. II On said date at approximately 6:30p.m., the defendant TATIANA MEZARINA ROJAS was operating a vehicle owned by the defendant GELCO CORPORATION and leased/rented by the defendant THE NIELSEN COMPANY(US), LLC also in a northerly direction on said Interstate 95 and to the rear of the plaintiff vehicle when suddenly and without warning, she collided into the rear of the plaintiff vehicle causing him to sustain the serious and painful injuries and losses hereinafter set forth. III At all times relevant to this complaint, the defendant TATIANA MEZARINA ROJAS was operating the vehicle rented/leased by the defendant THE NIELSEN COMPANY(US), LLC and owned by the defendant GELCO CORPORATION, as their agent, servant and/or employee, or she was operating said vehicle as a family vehicle with a general authority to operate same. IV Said collision and resultant injuries and losses were caused by the carelessness and negligence of the defendants in any one or more of the following respects: 1. In that said defendant TATIANA MEZARINA ROJAS was inattentive and failed to keep and operate said vehicle under reasonable and proper control; 2. In that said defendant TATIANA MEZARINA ROJAS she was inattentive and failed to keep a proper lookout for other vehicles lawfully upon said highway; 3. In that said defendant TATIANA MEZARINA ROJAS, operated said vehicle at a greater rate of speed than was warranted for the conditions then and there existing; 4. In that said defendant TATIANA MEZARINA ROJAS violated Connecticut General Statute 14-240 in following the plaintiff’s vehicle more closely than was reasonable; 5. In that said defendant TATIANA MEZARINA ROJAS failed to give the plaintiff a timely warning or any warning whatsoever of her approach; 6. In that said defendant TATIANA MEZARINA ROJAS failed to apply the brakes in time to avoid said collision and/or said defendants THE NIELSEN COMPANY(US), LLC and/or GELCO CORPORATION allowed and permitted said vehicle to be operated with defective or inadequate brakes; 7. In that said defendant TATIANA MEZARINA ROJAS failed to steer her vehicle to the right or left so as to avoid said collision; 8. In that said defendants THE NIELSEN COMPANY(US), LLC and/or GELCO CORPORATION failed to properly instruct said defendant TATIANA MEZARINA ROJAS as to the proper use and operation of said vehicle. V As a consequence of said carelessness and negligence of the defendants, the plaintiff received and suffered from: 1. Acceleration/deceleration trauma to the cervical spine; 2. Acute Musculoligamentous strain/sprain of the thoracic spine; which has now progressed to the sub-acute phase 3. Acute Musculoligamentous strain/sprain of the Lumbosacral spine; which has now progressed to the sub-acute phase 4. Post traumatic TMJ type symptoms; 5. Headaches post concussive, cervicogenic or post traumatic muscle tension type; 6. Soft tissue injury is evidenced by posterior joint capsule tenderness during motion palpation as well as myofascial spasm trigger points and hypertonicity present throughout the paravertebral musculature; 7. Acute Musculoligamentous strain of the cervical spine; 8. Acute lateral-epicondylitis, left elbow 9. Pain and obvious limp left hip with tenderness over the trochanteric bursa with pain on active abduction 10. Dizziness 11. Right Sided occipital neuralgia 12. Jaw displacement with internal derangement of the temporomandibular joint. He has slipped disc of the temporomandibular joint system; 13. Contusion to the trigeminal nerve; 14. Contusion to the facial nerve; From all of which injuries or the effects therefrom were severe and painful, causing the plaintiff to undergo injections as well as a cervical disc laminectomy and some of which injuries are permanent in nature. VI As a further consequence of said carelessness and negligence of the defendants, and resultant injuries of the plaintiff, he has been obliged to expend a large sum of money for medical care and attention and may be so obliged to do so in the future. VII As a further consequence of said carelessness and negligence of the defendants, and resultant injuries, the plaintiff has been unable to attend to the duties of his employment for a considerable period of time and lost the income therefrom and will be so disabled in the future. VIII As a further consequence of said carelessness and negligence of the defendants and resultant injuries, the plaintiff’s normal activities and enjoyments of life have been impaired for a considerable period of time and will be so impaired in the future. ______________________________/015768/ Joseph S. Dobrowolski Commissioner of the Superior Court RETURN DATE: JUNE 24, 2014 SUPERIOR COURT DAVID CONFEITEIRO J. D. OF FAIRFIELD V AT BRIDGEPORT TATIANA MEZARINA-ROJAS ET AL MAY 30, 2014 DEMAND FOR RELIEF WHEREFORE, the plaintiff claims compensatory damages within the jurisdiction of this court. The amount, legal interest or property in demand is in excess of FIFTEEN THOUSAND ($15,000.00) DOLLARS, exclusive of interest and costs. THE PLAINTIFF BY____________________________/015768/_ Joseph S. Dobrowolski, his attorney 51 Elm St., New Haven, CT 06510 (203)787-1293 Fax # 203-782-2116