Preview
FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022
SUPREME COURT OF THE STATE OF NEW YORK Date of Purchase:
COUNTY OF NEW YORK Index #
_________________________________________Ç
SENECA INSURANCE COMPANY, INC.,
plaintiff, Bummong
Plaintiff's res. address:
-against- 29th
199 Water Street,
New York, NY 10038
STILLWATER DEVELOPMENT PARTNERS, LLC., The basis for the venue
Designated is
PLAINTIFF'S Residence
defendant.
_____________________________________Ç
To the above named defendant(s):
on Ere mereby Bummoneb: to answer the complaint in this action and
to serve a copy of you answer, or, ifthe complaint is not served with this summons, to
serve a notice of appearance, on the Plaintiff's Attorney(s) within 20 days after the service
of this summons, exclusive of the day of service (or within 30 days after the service is
complete ifthis summons was not personally delivered to you within the State of New
York); and in case of your failure to appear or answpojudgment will be taken against you
for the relief demanded herein
Dated: August 1, 2022
MI FL A. BORG
SOFFER,RECH & BORG, LLP
Attorney for Plaintiff
1565 Franklin Avenue, Suite 200
Mineola, NY 11501
(516) 248-4433
Defendanes Address:
2 Armonk Street
Greenwich, CT 06830
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FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022
SUPREME COURT OF THE STATE OF NEW YORK Index #
COUNTY OF NEW YORK
_______________________________________________________________________Ç
SENECA INSURANCE COMPANY, INC.,
Plaintiff, VERIFIED
COMPLAINT
-against-
STILLWATER DEVELOPMENT PARTNERS, LLC,
Defendant.
_______________________________________________________________________Ç
Plaintiff, by their attorneys, SOFFER, RECH & BORG, L.L.P., complaining of the
defendant, respectfully alleges and sets forth as follows:
1. That the plaintiff is an insurance company, authorized to transact the
business of insurance within the State of New York.
2. That, upon information and belief, the defendant is a domestic corporation.
AS AND FOR A FIRST CAUSE OF ACTION
3. The plaintiff issued to the defendant, at the defendanes special instance and
request, Commercial General Liability Policy #SCC0101982.
4. The policy remained in effect for the period from December 10, 2021 to
January 30, 2022.
5. The policy developed an earned premium of $4,516.00, which remains
unpaid, despite due demand.
AS AND FOR A SECOND CAUSE OF ACTION
6. That an account in the amount of $4,516.00 has been stated to the defendant
and retained without objection.
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FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022
WHEREFORE, theplaintiff demandsjudgmentagainstthe defendantfor$4,516.00,
together with interest from January 30, 2022, along with the costs and disbursements of
this action.
Dated: Mineola, New York fF
August 1, 2022
Mlkl AEL A. BORG, ESQ
SOFFER, RECH & BORG, LLP.
Attorneys for Plaintiff
1565 Franklin Avenue, Suite 200
Mineola, NY 11501
(516) 248-4433
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FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022
Corporate Verification
ROBIN READ, being duly sworn, deposes and says that I am the COLLECTIONS
MANAGER of SENECA INSURANCE COMPANY, INC. the Plaintiff in this action. The
foregoing Complaint is true to my own knowledge, except as to the matters stated therein
to be upon information and belief, and as to them I believe itto be true.
ROBIN READ
Out of State
(NY) Notary as per NYS
Real Prop. Law §309-b
State of ovUC , County of Ó/LL£o ss.:
On the day of U SC in the year ZU 2- before me,
the undersigned, personally ap;feà red ROBIN READ, personally known to me or proved
to me on the basis of satisfactory evidence to be the individual(s) whose name(s) is/are
subscribed to the within instrument and acknowledged to me that he/she/they executed the
same in h her/their capacity and t by his/her/their signature on the instrument the
individu (s) r the per n beh fo ich the 'ndividual acted executed the instrument.
9
Notary Pliblic
CINDY ANN MULQUEEN
Notary Public State of New York
No. 01mu4966335
Qualified in Kings County
Commission Expires May 7,20
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FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022
==================
248-4433(516)
Mineola,
11501NY
Avenue,
200 Suite Franklin1565
Plaintifffor Attorneys
BORG, SOFFER,
LLP & RECH
A.
Borg Michaél
)rivolous. the
not are theind
documentannexed contaÈ
contentions
inquiry, reasona+e
uponand upon that,
information ce State,
that beliefand tiffeà York New
of
thein
courts practice
to undersigned,
the IfU-I.1,
admitted attorney
an R NYC22 to Pursuant
=========_.
===============================
COMPLAINT VERIFIED
AND SUMMONS
==================
LLC., PARTNERS,
DEVELOPMENT STILLWATER
-against-
INC., COMPANY,
INSURANCE SENECA
==================
YORK NEW OF COUNTY
YORK NEW OF STATE THE OF COURT SUPREME
# INDEX
5 of 5
Preview
FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022 SUPREME COURT OF THE STATE OF NEW YORK Date of Purchase: COUNTY OF NEW YORK Index # _________________________________________Ç SENECA INSURANCE COMPANY, INC., plaintiff, Bummong Plaintiff's res. address: -against- 29th 199 Water Street, New York, NY 10038 STILLWATER DEVELOPMENT PARTNERS, LLC., The basis for the venue Designated is PLAINTIFF'S Residence defendant. _____________________________________Ç To the above named defendant(s): on Ere mereby Bummoneb: to answer the complaint in this action and to serve a copy of you answer, or, ifthe complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete ifthis summons was not personally delivered to you within the State of New York); and in case of your failure to appear or answpojudgment will be taken against you for the relief demanded herein Dated: August 1, 2022 MI FL A. BORG SOFFER,RECH & BORG, LLP Attorney for Plaintiff 1565 Franklin Avenue, Suite 200 Mineola, NY 11501 (516) 248-4433 Defendanes Address: 2 Armonk Street Greenwich, CT 06830 1 of 5 FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022 SUPREME COURT OF THE STATE OF NEW YORK Index # COUNTY OF NEW YORK _______________________________________________________________________Ç SENECA INSURANCE COMPANY, INC., Plaintiff, VERIFIED COMPLAINT -against- STILLWATER DEVELOPMENT PARTNERS, LLC, Defendant. _______________________________________________________________________Ç Plaintiff, by their attorneys, SOFFER, RECH & BORG, L.L.P., complaining of the defendant, respectfully alleges and sets forth as follows: 1. That the plaintiff is an insurance company, authorized to transact the business of insurance within the State of New York. 2. That, upon information and belief, the defendant is a domestic corporation. AS AND FOR A FIRST CAUSE OF ACTION 3. The plaintiff issued to the defendant, at the defendanes special instance and request, Commercial General Liability Policy #SCC0101982. 4. The policy remained in effect for the period from December 10, 2021 to January 30, 2022. 5. The policy developed an earned premium of $4,516.00, which remains unpaid, despite due demand. AS AND FOR A SECOND CAUSE OF ACTION 6. That an account in the amount of $4,516.00 has been stated to the defendant and retained without objection. 2 of 5 FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022 WHEREFORE, theplaintiff demandsjudgmentagainstthe defendantfor$4,516.00, together with interest from January 30, 2022, along with the costs and disbursements of this action. Dated: Mineola, New York fF August 1, 2022 Mlkl AEL A. BORG, ESQ SOFFER, RECH & BORG, LLP. Attorneys for Plaintiff 1565 Franklin Avenue, Suite 200 Mineola, NY 11501 (516) 248-4433 3 of 5 FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022 Corporate Verification ROBIN READ, being duly sworn, deposes and says that I am the COLLECTIONS MANAGER of SENECA INSURANCE COMPANY, INC. the Plaintiff in this action. The foregoing Complaint is true to my own knowledge, except as to the matters stated therein to be upon information and belief, and as to them I believe itto be true. ROBIN READ Out of State (NY) Notary as per NYS Real Prop. Law §309-b State of ovUC , County of Ó/LL£o ss.: On the day of U SC in the year ZU 2- before me, the undersigned, personally ap;feà red ROBIN READ, personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in h her/their capacity and t by his/her/their signature on the instrument the individu (s) r the per n beh fo ich the 'ndividual acted executed the instrument. 9 Notary Pliblic CINDY ANN MULQUEEN Notary Public State of New York No. 01mu4966335 Qualified in Kings County Commission Expires May 7,20 4 of 5 FILED: NEW YORK COUNTY CLERK 09/06/2022 01:26 PM INDEX NO. 653229/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/06/2022 ================== 248-4433(516) Mineola, 11501NY Avenue, 200 Suite Franklin1565 Plaintifffor Attorneys BORG, SOFFER, LLP & RECH A. Borg Michaél )rivolous. the not are theind documentannexed contaÈ contentions inquiry, reasona+e uponand upon that, information ce State, that beliefand tiffeà York New of thein courts practice to undersigned, the IfU-I.1, admitted attorney an R NYC22 to Pursuant =========_. =============================== COMPLAINT VERIFIED AND SUMMONS ================== LLC., PARTNERS, DEVELOPMENT STILLWATER -against- INC., COMPANY, INSURANCE SENECA ================== YORK NEW OF COUNTY YORK NEW OF STATE THE OF COURT SUPREME # INDEX 5 of 5