A William & Mary student is suing The Colonial Williamsburg Foundation’s former top executive for crashing into her as she walked across Richmond Road in late 2023.
Rosemary T. Raynal, now a 23-year-old senior at the school, is asking for $25 million in damages. The lawsuit was filed in March 2025 in Richmond Circuit Court.
Raynal contends that Clifford B. “Cliff” Fleet III — who at the time was president and chief executive officer of the CW foundation — was driving his 2023 Audi Q8 SUV “at a speed and in a manner that was not reasonable and prudent” before running into her.
As such, the lawsuit asserts, he was grossly negligent.
Williamsburg’s top prosecutor has said that Fleet was driving 2 miles over the speed limit — 27 mph in a 25 mph zone — at the time. Fleet told Virginia State Police investigators after the crash that the glare from the sun blinded him from seeing Raynal crossing the street.
A four-day jury trial is scheduled to begin in Richmond on July 27, according to court records.
Fleet, 56, a William & Mary alumnus, became the top executive in early 2020 of the nonprofit that maintains and operates Colonial Williamsburg.
He announced this week that he was stepping aside effective immediately for personal reasons.
Clifford Bridges Fleet III, the former president and CEO of The Colonial Williamsburg Foundation. (Courtesy photo)
Carly Fiorina, the chair of the foundation’s board of trustees, will replace Fleet, the foundation said. Fiorina, a former top executive at Hewlett-Packard, ran for the Republican presidential nomination in 2016.
Raynal — then a 21-year-old biology and chemistry student at William & Mary — was on foot in a crosswalk on Richmond Road at 8:12 a.m. on Oct. 26, 2023.
Richmond Road is a two-way street that borders campus.
Raynal was more than halfway across the roadway, near the Armistead Avenue intersection, when she was struck by Fleet’s Audi, which was heading east on Richmond Road.
There are several crosswalks in the area, marked with yellow signs and flashing lights that can be activated by walkers, according to prior reporting from The Virginia Gazette.
Before the accident, the lawsuit said, Fleet “passed a conspicuous sign warning him of the presence of a crosswalk and instructing him to stop for pedestrians.”
Fleet “knew from experience that pedestrians, often college students, crossed the street in that crosswalk,” the complaint said. Though Raynal should have been clearly visible to Fleet, “he failed and neglected to see her.”
“Defendant failed to reduce his speed or take any action to avoid Rosemary and drove through the crosswalk, striking Rosemary with great force, propelling her through the air and onto the pavement.”
After the crash, she was intubated at the scene by medics, then flown to a Sentara hospital in Norfolk, “where she underwent severe traumatic brain injury protocol,” the complaint said.
This is the section of Richmond Road where Colonial Williamsburg’s former top executive struck a student in October 2023. (Virginia State Police)
The lawsuit asserts Raynal suffered permanent physical and emotional injuries, including brain injuries, a skull fracture and breaks to her shoulder and hips, as well as “depression, anxiety, memory loss, and chronic fatigue.”
Raynal was in intensive care for nearly a week, The Gazette reported in 2023. Then she was transferred to a traumatic brain injury unit near her hometown of Raleigh, North Carolina.
The lawsuit said Raynal withdrew from William & Mary’s 2023 fall semester and took medical leave for the spring 2024 semester.
But Raynal returned to school on a reduced schedule in the fall of 2024 and is expected to graduate in May.
Aside from her studies, The Gazette reported, Raynal served as president of William & Mary’s science fiction and fantasy club, worked in a research lab and volunteered weekly at Riverside Doctors’ Hospital.
Though she returned to school, the lawsuit said she suffers from amnesia, short-term memory loss, “worsened verbal fluency,” as well as headaches, and diminished taste and smell.
“She has endured months of painful rehabilitation in an attempt to achieve her pre-collision life,” the complaint said. “Despite her best efforts, however, Rosemary’s life plans have been severely disrupted and permanently altered.”
On the day of the crash, the Virginia State Police said in a news release that neither alcohol nor speed appeared to be factors in the crash.
Fleet was charged with reckless driving at the time, but pleaded guilty in May 2024 to the reduced charge of improper driving.
At that hearing in Williamsburg-James City County General District Court, Green, the commonwealth’s attorney, said there was no sign that Fleet was distracted or impaired driving. Moreover, the prosecutor said witnesses corroborated that sun glare was a factor at the time.
Fleet paid $571 in fines and court costs.
Raynal did not return a phone call Wednesday, and her mother declined to comment. One of Raynal’s attorneys, Jason W. Konvicka with the Richmond law firm of Allen, Allen, Allen & Allen, declined to comment Tuesday.
Fleet’s attorneys, Jon A. Nichols and Danielle Giroux of the Richmond firm of Harman, Claytor, Corrigan and Welllman, did not immediately return phone calls left Wednesday.
Staff writer Kate Seltzer contributed to this report.
Peter Dujardin, 757-897-2062, pdujardin@dailypress.com