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JACOBS & JACOBS * ATTORNEYS ATLAW
700 STATE STREET * THIRD FLOOR
* NEW HAVEN, CT 06511
JURIS NO. 432571
(203) 777-2300 *
RETURN DATE: 05/14/19 : SUPERIOR COURT
JAMES BEDDINGTON : J.D. OF STAMFORD/NORWALK
vs. : ATSTAMFORD
JENNIFER L. MARGNELLI; and :
JASON T. MARGNELLI : April 3, 2019
COMPLAINT
FIRST COUNT: (STRICT LIABILITY)
1. On or about August 18, 2017, the defendants, Jennifer L. Margnelli and Jason T|
Margnelli, owned and resided at 257 Fillow Street, Norwalk, Connecticut.
2. On and before August 18, 2017, the defendants were the owners and/or keepers of a
Labradoodle dog named “Bumpus’.
3. On or about August 18, 2017 at approximately 6:22 p.m., the plaintiff, James Beddington,
a mail carrier for the United States Postal Service, was delivering mail to 257 Fillow Street, Norwalk,
Connecticut.
4. At that time and place, Bumpus ran from the home at 257 Fillow Street, Norwalk,
Connecticut toward Mr. Beddington as Mr. Beddington was approaching the property, chasing Mr|
Beddington back to his service vehicle.
5. In the course of being chased by Bumpus back to his vehicle, Mr. Beddington struck his)
knees and hip against the vehicle.* ATTORNEYS AT LAW
700 STATE STREET * THIRD FLOOR © NEWHAVEN, CT 06511
JACOBS & JACOBS
(203) 777-2300 * JURIS NO. 432574
6. At that time and place the plaintiff, James Beddington was not committing a trespass o!
tort or teasing, tormenting or abusing said dog.
7. As a result of that event, the plaintiff, James Beddington sustained severe, painful and
permanent injuries consisting of a shock to his nervous system, left knee contusion, chondromalacial
patella — left knee, left lumbar strain/sprain, left lumbar radiculopathy, annular tear at L3-4, left lateral
disc protrusion at L4-5, and left paramidline disc protrusion at L5-S1. Those injuries have caused him
and will cause him pain and suffering, mental distress and anxiety, and have caused him and will cause
him to limit his activities.
8. As a further result of said injuries, the plaintiff, James Beddington has incurred and wil
incur expenses for medical examination and treatment, diagnostic imaging and testing, medication,
orthopedic appliances, surgery, epidural steroidal injections, and transportation.
9. As a further result of those injuries, the plaintiff, James Beddington has lost time from
work, will lose time from work, and his earning capacity has been impaired, all to his financial loss.
10. The defendants are strictly liable for the event described herein and the injuries and)
losses resulting therefrom in accordance with the provisions of §22-357 of the Connecticut Genera
Statutes.
SECOND COUNT: (NEGLIGENCE)
1-9. Paragraphs 1-9 of the First Count are hereby incorporated as paragraphs 1-9 of the
Second Count.
-2-YS AT LAW
FLOOR * NEWHAVEN, CT 06511
* JURIS NO. 432871
JACOBS & JACOBS * ATTORNE'
700 STATE STREET © THIRD
(203) 777-2300
12. The plaintiff James Beddington’s injuries and losses, as described herein, were
proximately caused by the negligence of the defendants in one or more of the following ways, in that:
A. They failed to keep their dog under proper and reasonable control;
B. They allowed the dog run out of the house when it was not reasonably safe for the
dog to do so;
Cc. They failed to warn Mr. Beddington of the presence of the dog and the likelihood
that the dog would cause some harm of a general nature.THIRD FLOOR © NEW HAVEN, CT 06511
(203) 777-2300 ° JURIS NO. 432574
JACOBS & JACOBS * ATTORNEYS ATLAW
700 STATE STREET ©
DEMAND FOR RELIEF
AS TO FIRST COUNT:
THE PLAINTIFF, JAMES BEDDINGTON, CLAIMS MONEY DAMAGES,
THE AMOUNT IN DEMAND IS MORE THAN FIFTEEN THOUSAND ($15,000.00) DOLLARS,
EXCLUSIVE OF COSTS AND INTEREST.
AS TO SECOND COUNT:
THE PLAINTIFF, JAMES BEDDINGTON, CLAIMS MONEY DAMAGES.
THE AMOUNT IN DEMAND IS MORE THAN FIFTEEN THOUSAND ($15,000.00) DOLLARS,
EXCLUSIVE OF COSTS AND INTEREST.IN, CT 06511
* ATTORNEYS ATLAW
* THIRD FLOOR * NEW HAVE!
(203) 777-2300 * JURIS NO. 432571
JACOBS & JACOBS
700 STATE STREET
Of this writ, with your doings hereon, make due service and return.
Dated at New Haven, Connecticut this __ 34 day of April, 2019.
A
STEVEN D. JACOBS, ESQ.
COMMISSIONER OF THE SUPERIOR COURT
APPEARANCE FOR THE PLAINTIFF
IS HEREBY ENTERED BY
JACOBS & JACOBS, LLC
700 STATE STREET
NEW HAVEN, CT 06511
PHONE: (203) 777-2300
FAX: (203) 773-8075
JURIS NO. 432571
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JACOBS & JACOBS * ATTORNEYS ATLAW 700 STATE STREET * THIRD FLOOR * NEW HAVEN, CT 06511 JURIS NO. 432571 (203) 777-2300 * RETURN DATE: 05/14/19 : SUPERIOR COURT JAMES BEDDINGTON : J.D. OF STAMFORD/NORWALK vs. : ATSTAMFORD JENNIFER L. MARGNELLI; and : JASON T. MARGNELLI : April 3, 2019 COMPLAINT FIRST COUNT: (STRICT LIABILITY) 1. On or about August 18, 2017, the defendants, Jennifer L. Margnelli and Jason T| Margnelli, owned and resided at 257 Fillow Street, Norwalk, Connecticut. 2. On and before August 18, 2017, the defendants were the owners and/or keepers of a Labradoodle dog named “Bumpus’. 3. On or about August 18, 2017 at approximately 6:22 p.m., the plaintiff, James Beddington, a mail carrier for the United States Postal Service, was delivering mail to 257 Fillow Street, Norwalk, Connecticut. 4. At that time and place, Bumpus ran from the home at 257 Fillow Street, Norwalk, Connecticut toward Mr. Beddington as Mr. Beddington was approaching the property, chasing Mr| Beddington back to his service vehicle. 5. In the course of being chased by Bumpus back to his vehicle, Mr. Beddington struck his) knees and hip against the vehicle.* ATTORNEYS AT LAW 700 STATE STREET * THIRD FLOOR © NEWHAVEN, CT 06511 JACOBS & JACOBS (203) 777-2300 * JURIS NO. 432574 6. At that time and place the plaintiff, James Beddington was not committing a trespass o! tort or teasing, tormenting or abusing said dog. 7. As a result of that event, the plaintiff, James Beddington sustained severe, painful and permanent injuries consisting of a shock to his nervous system, left knee contusion, chondromalacial patella — left knee, left lumbar strain/sprain, left lumbar radiculopathy, annular tear at L3-4, left lateral disc protrusion at L4-5, and left paramidline disc protrusion at L5-S1. Those injuries have caused him and will cause him pain and suffering, mental distress and anxiety, and have caused him and will cause him to limit his activities. 8. As a further result of said injuries, the plaintiff, James Beddington has incurred and wil incur expenses for medical examination and treatment, diagnostic imaging and testing, medication, orthopedic appliances, surgery, epidural steroidal injections, and transportation. 9. As a further result of those injuries, the plaintiff, James Beddington has lost time from work, will lose time from work, and his earning capacity has been impaired, all to his financial loss. 10. The defendants are strictly liable for the event described herein and the injuries and) losses resulting therefrom in accordance with the provisions of §22-357 of the Connecticut Genera Statutes. SECOND COUNT: (NEGLIGENCE) 1-9. Paragraphs 1-9 of the First Count are hereby incorporated as paragraphs 1-9 of the Second Count. -2-YS AT LAW FLOOR * NEWHAVEN, CT 06511 * JURIS NO. 432871 JACOBS & JACOBS * ATTORNE' 700 STATE STREET © THIRD (203) 777-2300 12. The plaintiff James Beddington’s injuries and losses, as described herein, were proximately caused by the negligence of the defendants in one or more of the following ways, in that: A. They failed to keep their dog under proper and reasonable control; B. They allowed the dog run out of the house when it was not reasonably safe for the dog to do so; Cc. They failed to warn Mr. Beddington of the presence of the dog and the likelihood that the dog would cause some harm of a general nature.THIRD FLOOR © NEW HAVEN, CT 06511 (203) 777-2300 ° JURIS NO. 432574 JACOBS & JACOBS * ATTORNEYS ATLAW 700 STATE STREET © DEMAND FOR RELIEF AS TO FIRST COUNT: THE PLAINTIFF, JAMES BEDDINGTON, CLAIMS MONEY DAMAGES, THE AMOUNT IN DEMAND IS MORE THAN FIFTEEN THOUSAND ($15,000.00) DOLLARS, EXCLUSIVE OF COSTS AND INTEREST. AS TO SECOND COUNT: THE PLAINTIFF, JAMES BEDDINGTON, CLAIMS MONEY DAMAGES. THE AMOUNT IN DEMAND IS MORE THAN FIFTEEN THOUSAND ($15,000.00) DOLLARS, EXCLUSIVE OF COSTS AND INTEREST.IN, CT 06511 * ATTORNEYS ATLAW * THIRD FLOOR * NEW HAVE! (203) 777-2300 * JURIS NO. 432571 JACOBS & JACOBS 700 STATE STREET Of this writ, with your doings hereon, make due service and return. Dated at New Haven, Connecticut this __ 34 day of April, 2019. A STEVEN D. JACOBS, ESQ. COMMISSIONER OF THE SUPERIOR COURT APPEARANCE FOR THE PLAINTIFF IS HEREBY ENTERED BY JACOBS & JACOBS, LLC 700 STATE STREET NEW HAVEN, CT 06511 PHONE: (203) 777-2300 FAX: (203) 773-8075 JURIS NO. 432571