The Waterbury Democrat., 1941-08-23

LegdENotices
NOTICE

NOTICE
 TO THE SHERIFF or THE COUNTY or NEW HAVEN, HIS DEPUTY OR EITHER CON- STABLE or THE TOWN OF WATERBURY, WITHIN SAID COUNTY, GREETING: BY AUTHORITY OF THE STATE or CONNECTICUT, You are hereby commanded to attach to the value of TWENTY FIVE THOUSAND ($25, ,OO0) DOLLARS, the goods or estate of FREDERICK IMBELBO, of the City of Water bury, County of New Haven, State of Connecticut, and him summon to appear before the SUPERIOR COURT, to be held at Waterbury, within and for the County of New Haven, on the first Tuesday of Oc- tober, 1941, then and there to answer unto ANTHONY MEIdLLO, of Waterbury aforesaid, in a civil action, wherein the plaintiff corn- plains and says:
 l. On August 18th, 194O, Oak Street, in said Waterbury, was and still is public street running in 8 general northwesterly and south easterly direction, and the travelled portion of said highway was and still is approximately thirty eight (38) feet wide at a point where it Is tntersected by Ash Street on the easterly side.
 2. On said day, at about the hour of 9:30 F. M, Eastern Daylight Saving Time, the plaintiff was pro- ceeding across said Oak Street from its westerly side at a point at or near the intersection of Oak and Ash Streets, and when he had reached point on said highway a few feet west of its easterly edge, a 194O Chevrolet Delivery Truck, own- ed by the defendant and then being driven by one Carl Rosa, of said Waterbury, in northwesterly di- rection on said Oak Street, struck the plaintiff and as result there of, he was knocked, thrown down upon and dragged along the pave ment of Oak Street, causing him tc sustain the following injuries:
 a. Cuts, contusions and abrasionS
 about his face, limbs and body; b. A severe physical and nervous
 shock to his system;
 c. A large abrasion involving the
 subcutaneous tissue of the
 right thigh and left elbow; d. A sizeable swelling of the right
 cheek bone:
 e. He was bleeding from the nose
 and mouth;
 f. He was unconscious for sev-
 eral days;
 g. A concussion of the brain;
 h. A laceration~ of the brain;
 i. A fractured skull;
 j. He has suffered and will con-
 tinue to suffer great pain of
 body and mind;
 k. He has partial paralysis of
 his right side;
 l. He suffers constant headaches
 and dizziness, and has lost the
 senses of smell and taste;
 m. He has developed a definite
 impeachment of speech; and all of said injuries have generally and permanently disabled and in- capacitated the plaintiff.
 3. AS further result of his in- juries, the plaintiff developed a respiratory infection, had to be fed intravenouSly; he was incontinent; he has had dificulty in sleeping; his speech is incoherent, and with reasonable probability he may de- velop post-traumatic epilepsy.
 4. As a further result of all the injuries and diseases as aforesaid, the plaintiff has incurred and will continue to incur large expenses for medical and surgical attention, hos pital and nursing care, X-rays, medicines, serums, intravenous blood injections, services of donors of blood, and medical and surgical supplies.
 5. As further result of said in- juries, the plaintiff, who was em- ployed at a gainful occupation, has been and will continue to be ir1- capacitated from engaging in his former employment of doing any other kind of work for a long period of time, and he has lost and will continue to lose the income which he did and would derive from work ing.
 6. Said injuries and the result ing consequences were caused by the carelessness and negligence of the said Carl Rosa:
 8. In that he was driving the said
 automobile truck at a rate of
 speed that was high, reckless,
 dangerous, unreasonable and
 unlawful, having regard to the
 width, traff1c, weather condi-
 tions and use of said highway
 at said time and place;
 b. In that he did not have said
 automobile truck under such
 reasonable control as to enable
 him to stop it or to otherwise
 manipulate it in time to avoid
 striking the plaintiff;
 c. In failing to give the plaintiff
 a timely signal of the approach
 of said automobile truck;
 d. In failing to keep 8 proper
 lookout so as to avoid striking
 the plaintiff who was lawfully
 using said highway at said
 time and place, when reason
 able care required him to do
 all of these things under the
 prevailing circumstances and
 conditions.
 THE PLAINTIFF CLAIMS $25,- 900 DAMAGES.
 I hereby certify that I have per- sonal knowledge as to the financial