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Connecticut Superior Court Holds That Negligence Count Does Not Relate Back to Strict Liability Count

In the recent Connecticut Superior Court case of Falconi v. Spicer, Judge Emmet Cosgrove held that an amended complaint adding a claim of negligence to an original complaint asserting only a claim of strict liability under the Dog Bite Statute, CGS Sec. 22-357, does not relate back to the filing of the original complaint for purposes of determining whether the statute of limitations for the negligence claim has expired.

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