RE|URN DATE: JTINE 29,201A SUPERIOR COURT

RONALD SABATINI J.D. OF ANSOMA-MII FORD

VS. AT MILFORD

STAFFIHzu &, I{UGHES, LLC DlBIA

CONNIE'S FAMILY RESTAURANT
ard JEFFREY R. HUGHES,
PERMITTEE JLNE 3,20]O

COMPLAINT

COUNT ONE

t. The Ptaintiff, RONALD SABATINI, all relevant times mentioned herein.

was an individual residing atilEl in Derby, Connecticut.

2. The Defendant, S'I'AFFIFRI & HLIGHES" LLC is a limited liability company

organized under the laws of the State of Connecticut with a principalplace of business

located at 87 Elizabeth Street in Derby, Connecticut.

3, Tbe Defendant, STA-FFIi-RI & HUGHES, LLC, all reievant times menrioned

lrerein, was doing business as Connie's Family Restaurant located at 8'1 E\zabeth Street in

Derby, Connecticut.

4. The Defendant. S IAFFIERI & !ruGFIES, LLC, at all relevant rimes

mentioned herein. w-as the backer of the liciuor permit permitting them to serve liquor at 87

Elizabeth Strect in Derby, Connecticut.

 5. The Defendant, JEFFREY R. FruGF{ES, at all relevant times mentioned

herein. was the Permittee of a liquor permit permined them to serve liquor at 87 Elizabeth

Street in Derby. Con-necticut.

6. On the evening of March 5, 2010 and early morning of March 6. 2010, John

Doe and Jim Doe were patrons at Connie's Famiiy Restaurant located at 87 Etizabeth Street

in Derby, Connecticut.

7 . On the evening of March 5, 2010 and early morning of March 6, 2010, John

Doe and Jim Doe. while intoxicated, were sold a-nd/or served alcoholic beverages by the

employee's agents and/or servants of the Defendants.

8. On the eariy moming of March 6, 2010 at approximately 1:45 a.m." the

Plaintiff, RONALD SABATINI, was a patron at Connie's Family Restaurant, and as he

afiempted to exit the estabiishment, he was brutally assaulted, battered and beaten by John

Doe and Jim Doe, who punched and kicked tlre PlaintitT in the head and about his body

leaving him unconscious and in a coma.

9. As a result of the beating inflicted by John Doe and Jim Doe, the Plaintif{

RONALD SABATINI, suffered signilicant internal injuuies, closed head injuries and

damages as set forth below:

a. traumatic brain injury;

b, internal injuries;

c. intemal bleedi.ng;
 d. contusions and abrasions about the body;

e. Ioss of teeth and dental injuries;

f. cervical injuries;

g. spine injuriesl

h. loss of memory and cognitive skills;

i. headaches;

j fractured ribs;

k- fi'actured facial bones:

l. pain and suffering.

10. As a further result of the beating, the Plaintiff, RONALD SABATINI, was

transported via EMS to the emcrgency room and rcceived medical treatment. physical care

and reatnrent, received prescription medication, plrysical therapy, and medical testing for

which he incurred substantial financial liability for the cost of the same and will incur'

additional medical costs in the future.

II . As a further result of the beating. the Plaintiff. RONALD SABATINI, was

hospitalized and in a coma for a number of days.

12. As a fur'ther result of the beating. the PLaintifl RONALD SABATINI,

suffered extreme physical pain, mental pain, suffering, depression, and anxiety, and is likely

to suffer the same in the future.

 13, As a fuither result of the beating, the Plaintjff, RONALD SABATIlrrl, has

been Ieft with a traumatic brain injury, cognitive impai.rment, memory loss and has physical

disabilities.

14. As a result of the beating, the Plaintifi, RONALD SABATINI, has iosl

income and r.vill lose income in the future

15. .\s a further result of the beating, the Plaintiff, RONATD SABATINI,

suffered a loss of life's enjoyments.

16. The beating and the Plaintiff s injuries and losses were the consequence of

the intoxication of John Doe and Jim Doe as set tbrth above, and the Plaintiff seeks to

recover damages for such injuries and losses pursuant to Conn. Stat. $30-102 (The Dram

Shop Act) from the Defendants.

17. Written notice as required by' the Dram Shop Act has been given to the

Defendant-backer and the Defendant-Permittee within one hundred and twenty (120) days of

the occurrence ofthe PtaintifPs injuries and losses. A copy ofsuch notice is annexed hereto

as Exhibit A.

18. 'l'he Defendant is responsible for the Plaintifl RONALD SABATIM'S,

injuries and damages pursuant to Conn. Gen. Stat. $ 30-102, The Dram Shop Act.
COUNT TWO

1. The Plaintiff, RONALD SABATINI, at all relevant times mentioned herein,

was an individLrai residing at 7 Fifth Street in Derby, Connecticut,

2. The Defendant, STAFFIIRI & HUGHES, LLC, is a limited tiability

company organized under the laws of the State of Connecticut wilh a principal place of

br-rsiness located at 87 Elizabeth Street in Derby, Connecticut.

3. The Defendant, STAFFIERI & I{UGI{ES, LLC, all relevant times mentioned

herein, r.vas doing business as Connie's Family Restaurant located at 87 Ltizabeth Sfteet in

Derby, Connecticut.

4. "l-he
Defendaxt, STAFFIERI & HUGHFS, LLC dlblaConnie's Family

Restaurant, at all relevant ti-rnes mentioned herein was in the business of providing food and

entertainment to its patrons at 87 Elizabeth Street, Derby, Comecticut, and often remained

open until the early morning hou's.

5. On the ovening of March 5, 2010 and eariy moming of March 6, 2010, the

Det'endant had a group of patrons and/or employees at the establishment who were unruly

and disorderly.

6. The unruly and disorderly patrons and/or employees were allowcd to

congregatc at the exit of thc Defendant's establishment.

7. In the early morning of Malch 6,2010, the Plaintiff, RONALD SABATINI,

was a patron at the Defendant's establishment

 8. On March 6, 2010 at approximately 1:45 a.m., the Plaintiff, RONAL D

SABATINI, attempted to leave the Defendant's establishment and as he attempted to exit,

he was brutally assaulted, baltered and beaten by the unruly group of patrons andlor

employees of the Defendant's establishment wiro punched and kicked the Plaintiff in the

head and about the body leaving him unconscious and suffering from multiple injuries.

9- As a result of the beating inflicted by Jobn Doe and Jim Doe, the Ptaintiff,

RONALD SABATINI, suffered significant internal injuries, closed head injuries and

damages as set forth below:

a. traumatic brain injury;

b. internal injuries;

c. intemalb)eeding:

d. contusions and abrasions about the body;

e. loss of teeth and dental injuries;

f. cervical injuries;

g. spine injuries;

h. loss of memory and cognitive skills;

i. headaches;

j fracrured ribs;

k. fraclwed facial bones;

l. pain and suffenng.

 a. in that they failed to provide adequate security for the protection of its

invitees and patrons;

b. in that they falled to warn the Plaintiff. RON,\LD SABA'I'INI. of the hazard

which existed on the properfy;

c. in that they failed to request assistance to control the crowd drey invited onto

tbeir premises;

d. in that they faited to train or provide adequate staff to propcrly deal with

violent siruations;

e. in tJrat they failed to provide assistance to the Plairrtiff, RONALD

SABATTNI;

f. in that they failed to disburse a group of patrons from their property who

posed a significmt risk to the Plaintiff, RONALD SABAIIM, and others;

g. in that they failed to break up an attack or call for assistance;

h. in that they faited to provide security in the front of the restaurant and/or in

the parking lot;

i. in that no one was supervising the tiont exit or parking lot areas;

j in that they failed to have adequate security personnel on the propefiy during

business hows;

k, in that they faited to keep the premises reasonably safe;

l. in tJ:at they failed to enact and/or enforce adequate safety measues;

 m. in that they faiJed to wam invitees that they may be assaulted. that the lionl

exit and parking lots were not secure, or to provide adequate securiry; and

n. in that they lailed to adequateiy illuminate or provide security or surveillance

as a deterrent.

NOTICE lS I{EREBY GIVFN that the Plaintiff, RONALD SABATINI, intends to seek

satisfaction of any jr-rdgment rendered in his favor in this action out of any debt accruing to

the Defendants, STAFFIERI & HUGHES. LLC D/B/A CONNIE'S FAMILY

RES IAURANT and JEFFREY R. HUGHES, PERMIT1L,E. by reason of the personal

services of the Defendants.

 WHEREFORE, the Piairrtiff claims:

1. Monetary Damages;

2. Costs;

3. Interest;

4. Any olher relief at law and in ecluity that the Court may debm just and proper.

Dated at Seymour, Connecticut this 3'd day of June, 2010.

HEREOF. FAIL NOl BUT OF THIS WRIT. WITH YOUR DOINGS THEREON,

MAK-E DUE SERVICE AND RETURN N ACCORDANI'E WITI{ TH.L, LAWS OF TFIE

S'IATE OF CONNBCTICUI"

THE PLAJNTIFF
RONALD SABATINI

LAW OF'FICE OF ANDREW J. PIANKA, LLC

100 Bani( Street. Suite 206.4
Seymour, C'l'06483
Juris No.: 412614
Telephone No.: (203) 463-4414
Facsimile No.: (203) 463-4416
RETURN DATE: Ji NF 29,2410 SUPERIOR COI R.T

RONAI,D SASATINi J.D OF ANSONIA-MILFORD

VS. AT MILFORD

STAFFIERI & HUGHES. LLC DIB/A

CONNIE'S FAMILY RFSTAURANT
and JEFFREY R. FruGHES,
PERMITTEE JLTNE 3.2010

STATEMENT RE: AMOIINT IN DEMAND

The amount in demand is greater than FIFTEEN THOLISAND ($15,000.00)

DOI.LARS, exclusive of .interest and costs.

IHE PLA$TTIFF
RON.AID SABATINI

LAW OFFICE OF ANDREW J. PIANKA, LLC

100 Bank Street, Suite 206A
Seymour, CT 06483
Juris No.: 412614
Teleplrone No.: (203) 463-4414
Facsimile No. : (203) 463-4416
EXHIBIT A
 Dram Shop Notice Pursuant to
Connecticut Gen. Stat. $ 30-102

To: Jeffrey R. Hughes, Permittee Jeffrey R. Hughes, Permittec

Connie's Fami ly Resteurant Connie's Fami 11' Restaurant
87 Elizabeth Slreet 15 Pleasant View Road
Derby, CT 06418 Derby, ('T 06418

Staffieri & Hughes, LLC. Baci<er Staffieri & Hughes, LLC, Backer
c/o Anthony E. Staffieri c/o Anthony E. Staffreri
87 Elizabeth Street l7 O'Sullivan Road
Derby, CT 0641 I Derby, CT 0641I

Notice is herein given, pursllanl to Connecticut Gen. Stilt. Section 30-102, that RonaLd

Sabati:l of 7 Fiftb Slreet, Derby, Connecticut, intends to bring an action under the Drlm Shop

Act to rcover for injuries and damages he sr;stained on ol about Sarurday, March 6, 201 0 at

approximately 1:45 a.m. The injurics and damages were sustaincd as result of the beatiug

inflicted by a group of the establishment's pafrons as Mr. Sabati"ni exited the establishment. The

names and addresses of the assailants ar* unkno'"r,n at this timc,

Notice is further given that any and ali surveillance tapes and all records concernilg

liquor sales, names and addresses of all employees, aeents or servants and patrons who were

present at said date time and place shall be preserved,

1HE PLAI}'i'IIF}'
RONAID SABATINI

^-
- ",.-:-
-'--::-\
/ u,*...-.2

Andrew J, Piurka, Esq.

LA1V OFFICE OF ANDRE1V J. PIANKA, LLC
100 Bank Street, Suite 206A
Scymour, CT 06483
Juiis No.: 412614
Telephone No.: (203) 463-44i1
Facsinrile No.: 1203) 461-4416
 OFFICER/S RETURN
STAIE OF CONN'C?ICUT
ss: Derby, Apri - 25, 2010

COUNTY OF NEW HAVEN

Then and there by virtue hereof, 1 served the within

named STAI'FIERI & HUGHES, LLC (BACKER) c/o AI{THoNY E.
SIAS'FIERI, by leaving at. the usuai place of abode o:L Anthony
E. St.af f ieri , its Registered Agent, who .is duly authorized
to accept serv:ce, dt 11 Elizabeth St-reet, Apt. O, Derby,
CT., with and in the hands of his brother, who is duly
auihorized to accept service and who accepted service, two
(2) true and attested copies (one for each) of the original
Notlce in Dram Shop Action pursuant to Section 30-102 of the
C. G. S, , with my endorsement thereon.

And afterwards, on April 26, 2010, in the Town of New

Haven, I served the within named I served the within named
Jqffreir R.- Huqhes, (Permj-ttee), CONNIE'IS F4Pi[ILY RESTA9RANT,
by leaving at the usual place of abode of Jeffrey R, Hughes,
at 422 Cent:al Avenue, Apt. 3, New Haven, CT., two (2) true
and attested copies (or-e for eacn) of the original Notice in
Dram Shop Action pursuani. to Sectior: 30-102 of the C.G.S.,
with my endorsement thereon.
The within and foregoing is the original Notice in Dram
Shop Action pursuant to Section 3o-102 of the c.G. s., with
ny deings herec'n endorsed.
ATTEST:

EtrEr:'
Service
Copies
l-ee

Endorsements
$ 80.00
4.00
2 .00
-T>-]tv
Travel 25 .04 DANIN, P.
'vALL
STATE MARSHAL
$11:..00
NEW HAVEN COUNTY