RETURN DATE: May 3, 2016

:

SUPERIOR COURT

HEIDI YERANOSSIAN

:

J. D. OF FAIRFIELD

Vs.

:

AT BRIDGEPORT

VINCENT CHIARAMONTE, ET AL

:

MARCH 30, 2016

COMPLAINT FIRST COUNT: 1.

(HEIDI YERANOSSIAN V. VINCENT CHIARAMONTE)

On June 12, 2014, at approximately 1:59 p.m., the plaintiff, HEIDI

YERANOSSIAN, was the operator of a motor vehicle that was stopped facing in a southerly direction on Danbury Road and had reached a point in the roadway near its intersection with Old Mill Road, both public streets or highways in Wilton, Connecticut. 2.

At

the

same

time

and

place,

the

defendant,

VINCENT

CHIARAMONTE, was the operator of a motor vehicle, owned by the defendant, SERAFINA CHIARAMONTE, that was traveling in a southerly direction on Danbury Road and had reached a point in the roadway directly behind the motor vehicle operated by the plaintiff. 3.

At the same time and place, the motor vehicle operated by the defendant,

VINCENT CHIARAMONTE, suddenly and without warning collided with the motor

Page 1 of 7

vehicle operated by the plaintiff, thereby causing the plaintiff, HEIDI YERANOSSIAN, to suffer the injuries and losses more fully set forth below. 4.

The collision was caused by the negligence of the defendant, VINCENT

CHIARAMONTE, 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 followed too closely behind the vehicle operated by the plaintiff having due regard to the circumstances then and there existing;

c)

He failed to turn or swerve so as to avoid the collision;

d)

He failed to apply the brakes in time to avoid the collision;

e)

He failed to sound the horn or give a timely warning of the impending collision;

f)

He failed to keep the vehicle under proper control;

g)

He was inattentive in the operation of the vehicle;

h)

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 or parking area, the intersection of streets and weather conditions, in violation of § 14-218a of the Connecticut General Statutes; and/or

Page 2 of 7

i)

He followed too closely behind the vehicle operated by the plaintiff having due regard to the circumstances then and there existing and in violation of § 14-240(a) of the Connecticut General Statutes.

5.

As a result

of the negligence of the

defendant,

VINCENT

CHIARAMONTE, the plaintiff, HEIDI YERANOSSIAN, suffered the following injuries, some or all of which may be permanent in nature: a)

Concussion;

b)

Head pain;

c)

Headaches;

d)

Visual impairment;

e)

Traumatic Convergence Insufficiency;

f)

Eye pain;

g)

Neck pain;

h)

Bilateral shoulder pain;

i)

Back pain;

j)

Bilateral hip pain;

k)

Right leg pain;

l)

Pain and suffering, both physical and mental.

Page 3 of 7

6.

As a further result of the negligence of the defendant, VINCENT

CHIARAMONTE, the plaintiff, HEIDI YERANOSSIAN, was forced to expend large sums of money for hospital and medical care, medicines, diagnostic tests and therapy, all necessary to her recovery, and may be forced to expend additional sums in the future. 7.

As a further result of the negligence of the defendant, VINCENT

CHIARAMONTE, the plaintiff, HEIDI YERANOSSIAN, was unable to work, to her financial detriment. 8.

As a further result of the negligence of the defendant, VINCENT

CHIARAMONTE, the plaintiff, HEIDI YERANOSSIAN, was unable, and remains unable, to participate in and enjoy her usual activities.

SECOND COUNT: (HEIDI YERANOSSIAN v. SERAFINA CHIARAMONTE) 1 – 8. Paragraphs 1 through 8 of the First Count are hereby incorporated as corresponding paragraphs 1 through 8 of this Second Count. 9.

At

all

times

material

hereto,

the

defendant,

SERAFINA

CHIARAMONTE, was the owner of the motor vehicle operated by VINCENT CHIARAMONTE. 10.

At all times mentioned herein, VINCENT CHIARAMONTE, was

operating the motor vehicle owned by the defendant, SERAFINA CHIARAMONTE,

Page 4 of 7

with her permission. 11.

At all times mentioned herein, VINCENT CHIARAMONTE, was

operating the motor vehicle owned by the defendant, SERAFINA CHIARAMONTE, as her agent, servant and/or employee. 12.

The defendant, SERAFINA CHIARAMONTE, is liable to the plaintiff,

HEIDI YERANOSSIAN, pursuant to the Connecticut General Statutes §52-182 and/or §52-183.

Page 5 of 7

WHEREFORE, the plaintiff claims money damages. THE PLAINTIFF, HEIDI YERANOSSIAN

By: Garrett M. Moore, Sr. Moore, O'Brien & Foti 891 Straits Turnpike Middlebury, CT 06762 Phone: (203) 272-5881 Juris No.: 408519 Her Attorneys

Page 6 of 7

RETURN DATE: May 3, 2016

:

SUPERIOR COURT

HEIDI YERANOSSIAN

:

J. D. OF FAIRFIELD

Vs.

:

AT BRIDGEPORT

VINCENT CHIARAMONTE, ET AL

:

MARCH 30, 2016

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 PLAINTIFF, HEIDI YERANOSSIAN

By: Garrett M. Moore, Sr. Moore, O'Brien & Foti 891 Straits Turnpike Middlebury, CT 06762 Phone: (203) 272-5881 Juris No.: 408519 Her Attorneys

Page 7 of 7