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COMMONWEALTH OF MASSACHUSETTS
HAMPDEN, ss. SUPERIOR COURT DEPARTMENT
CIVIL DOCKET NO. HAMPDEN COUNTY
‘SUPERIOR COURT
24 267 FILED
ALENA GALLAGHER ppa MAY 15-2024
CASSANDRA TRUDEAU,
Plaintiff )
CLERK
OF COURTS
VS. PLAINTIFF’S COMPLAINT AND
DEMAND FOR JURY TRIAL
KATHLEEN WILLIAMS and
KEVIN WILLIAMS,
Defendants
PARTIES
The Plaintiff, Alena Gallagher ppa Cassandra Trudeau, is an individual who resides at 46
Day Avenue, Westfield, Hampden County, Massachusetts.
The Defendant, Kathleen Williams, is an individual who resides at 302 Twin Lakes Drive,
Summerville, Dorchester County, South Carolina.
The Defendant, Kevin Williams, is an individual who resides at 302 Twin Lakes Drive,
Summerville, Dorchester County, South Carolina.
FACTS
The Plaintiff repeats, realleges, and incorporates herein by reference the allegations
contained in paragraphs | through 3 of this Complaint.
On or about September 14, 2022, the minor Plaintiff, Alena Gallagher, was a pedestrian on
Pleasant Street in Westfield, Hampden County, Massachusetts.
At the same time and place, the Defendant, Kathleen Williams, was the operator of a
motor vehicle traveling on Pleasant Street in Westfield, Hampden County,
Massachusetts.
At the same time and place, the Defendant, Kevin Williams, was the owner of the motor
vehicle operated by the Defendant, Kathleen Williams.
The Defendant, Kathleen Williams, negligently caused her motor vehicle to strike the
minor Plaintiff.
COUNT I: NEGLIGENCE
(ALENA GALLAGHER ppa CASSANDRA TRUDEAU vs. KATHLEEN WILLIAMS)
The Plaintiff repeats, realleges, and incorporates herein by reference the allegations
contained in paragraphs | through 8 of this Complaint.
10 The Defendant, Kathleen Williams, owed the minor Plaintiff a duty to operate her motor
vehicle in a safe and reasonable manner.
" On or about September 14, 2022, the Defendant, Kathleen Williams, breached her duty to
operate her motor vehicle in a safe and reasonable manner when she operated her motor
vehicle carelessly and negligently so as to cause her motor vehicle to strike the minor
Plaintiff.
12. Asa direct and proximate result of the Defendant, Kathleen Williams’, negligent operation
of her motor vehicle, the Plaintiff sustained severe personal injuries, disability, medical
expenses, and other financial losses as well as continuing pain and suffering.
13 The minor Plaintiff was at all times pertinent to this Complaint, in the exercise of due care.
WHEREFORE, the Plaintiff demands judgment against the Defendant, Kathleen Williams,
in an amount to be determined at trial, plus interest and costs of suit as well as such other relief to
which the Plaintiff may be entitled.
The Plaintiff demands a trial by jury on all issues.
COUNT Il: NEGLIGENCE
(ALENA GALLAGHER ppa CASSANDRA TRUDEAU vs. KEVIN WILLIAMS)
14, The Plaintiff repeats, realleges, and incorporates herein by reference the allegations
contained in paragraphs 1 through 13 of this Complaint.
45 Pursuant to M.G.L. c. 231 §85A and 85B, the Defendant, Kevin Williams, as owner of the
motor vehicle involved in said collision, is legally responsible for the negligent conduct of
the Defendant, Kathleen Williams.
16. The Defendant, Kevin Williams, had a duty to ensure that his motor vehicle was being
operated in a reasonable and safe manner.
17. The Defendant, Kevin Williams, breached his duty to ensure that his motor vehicle was
being operated in a reasonable and safe manner through the negligent operation of his
motor vehicle by its driver, Defendant, Kathleen Williams, who negligently caused the
motor vehicle owned by the Defendant, Kevin Williams, to strike the minor Plaintiff.
18 Asa direct and proximate result of the negligence of the Defendant, Kevin Williams, for
whom the negligence of the Defendant, Kathleen Williams, was responsible, the minor
Plaintiff was caused to sustain severe personal injuries, disability, medical expenses, and
other financial losses as well as continuing pain and suffering,
WHEREFORE, the Plaintiff demands judgment against the Defendant, Kevin Williams,
in an amount to be determined by this Court, plus interest and costs of suit as well as such other
relief to which the Plaintiff may be entitled
The Plaintiff demands a trial by jury on all issues.
The Plaintiff,
By counsel,
a Lt
“Michael B. Doherty, Esquire
BBO No. 651214
Law Offices of Mark E. Salomone
175 State Street, Suite 200
Springfield, MA 01103
Telephone No. (413) 737-7783
mdoherty@marksalomone.com
DATED Mey iB, 201-4
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COMMONWEALTH OF MASSACHUSETTS HAMPDEN, ss. SUPERIOR COURT DEPARTMENT CIVIL DOCKET NO. HAMPDEN COUNTY ‘SUPERIOR COURT 24 267 FILED ALENA GALLAGHER ppa MAY 15-2024 CASSANDRA TRUDEAU, Plaintiff ) CLERK OF COURTS VS. PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL KATHLEEN WILLIAMS and KEVIN WILLIAMS, Defendants PARTIES The Plaintiff, Alena Gallagher ppa Cassandra Trudeau, is an individual who resides at 46 Day Avenue, Westfield, Hampden County, Massachusetts. The Defendant, Kathleen Williams, is an individual who resides at 302 Twin Lakes Drive, Summerville, Dorchester County, South Carolina. The Defendant, Kevin Williams, is an individual who resides at 302 Twin Lakes Drive, Summerville, Dorchester County, South Carolina. FACTS The Plaintiff repeats, realleges, and incorporates herein by reference the allegations contained in paragraphs | through 3 of this Complaint. On or about September 14, 2022, the minor Plaintiff, Alena Gallagher, was a pedestrian on Pleasant Street in Westfield, Hampden County, Massachusetts. At the same time and place, the Defendant, Kathleen Williams, was the operator of a motor vehicle traveling on Pleasant Street in Westfield, Hampden County, Massachusetts. At the same time and place, the Defendant, Kevin Williams, was the owner of the motor vehicle operated by the Defendant, Kathleen Williams. The Defendant, Kathleen Williams, negligently caused her motor vehicle to strike the minor Plaintiff. COUNT I: NEGLIGENCE (ALENA GALLAGHER ppa CASSANDRA TRUDEAU vs. KATHLEEN WILLIAMS) The Plaintiff repeats, realleges, and incorporates herein by reference the allegations contained in paragraphs | through 8 of this Complaint. 10 The Defendant, Kathleen Williams, owed the minor Plaintiff a duty to operate her motor vehicle in a safe and reasonable manner. " On or about September 14, 2022, the Defendant, Kathleen Williams, breached her duty to operate her motor vehicle in a safe and reasonable manner when she operated her motor vehicle carelessly and negligently so as to cause her motor vehicle to strike the minor Plaintiff. 12. Asa direct and proximate result of the Defendant, Kathleen Williams’, negligent operation of her motor vehicle, the Plaintiff sustained severe personal injuries, disability, medical expenses, and other financial losses as well as continuing pain and suffering. 13 The minor Plaintiff was at all times pertinent to this Complaint, in the exercise of due care. WHEREFORE, the Plaintiff demands judgment against the Defendant, Kathleen Williams, in an amount to be determined at trial, plus interest and costs of suit as well as such other relief to which the Plaintiff may be entitled. The Plaintiff demands a trial by jury on all issues. COUNT Il: NEGLIGENCE (ALENA GALLAGHER ppa CASSANDRA TRUDEAU vs. KEVIN WILLIAMS) 14, The Plaintiff repeats, realleges, and incorporates herein by reference the allegations contained in paragraphs 1 through 13 of this Complaint. 45 Pursuant to M.G.L. c. 231 §85A and 85B, the Defendant, Kevin Williams, as owner of the motor vehicle involved in said collision, is legally responsible for the negligent conduct of the Defendant, Kathleen Williams. 16. The Defendant, Kevin Williams, had a duty to ensure that his motor vehicle was being operated in a reasonable and safe manner. 17. The Defendant, Kevin Williams, breached his duty to ensure that his motor vehicle was being operated in a reasonable and safe manner through the negligent operation of his motor vehicle by its driver, Defendant, Kathleen Williams, who negligently caused the motor vehicle owned by the Defendant, Kevin Williams, to strike the minor Plaintiff. 18 Asa direct and proximate result of the negligence of the Defendant, Kevin Williams, for whom the negligence of the Defendant, Kathleen Williams, was responsible, the minor Plaintiff was caused to sustain severe personal injuries, disability, medical expenses, and other financial losses as well as continuing pain and suffering, WHEREFORE, the Plaintiff demands judgment against the Defendant, Kevin Williams, in an amount to be determined by this Court, plus interest and costs of suit as well as such other relief to which the Plaintiff may be entitled The Plaintiff demands a trial by jury on all issues. The Plaintiff, By counsel, a Lt “Michael B. Doherty, Esquire BBO No. 651214 Law Offices of Mark E. Salomone 175 State Street, Suite 200 Springfield, MA 01103 Telephone No. (413) 737-7783 mdoherty@marksalomone.com DATED Mey iB, 201-4