Preview
FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ALBANY
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TRAVIS ALDRIDGE, Index No.:
Plaintiff,
-against- SUMMONS
The basis of the venue is:
Place of Occurrence
JANE DOUGHERTY,
Defendant.
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To the above-named defendants,
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
appearance, on the Plaintiff’s attorney within 30 days after the service of this summons,
exclusive of the day of service; and in case of your failure to appear or answer judgment will be
taken against you by default for the relief demanded in the complaint.
Place of Occurrence: Wolf Road and Ulenski Drive, Colonie, New York, County of Albany.
Dated: New York, New York
November 3, 2022
Daniel J. Watts
___________________
DANIEL WATTS, ESQ.
MORGAN & MORGAN NY PLLC
203 Jay Street, 6th Floor
Brooklyn, NY 11201
(917) 344-7043
TO: JANE DOUGHERTY
41 Hi Tor East
Freeland, PA 18224
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FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ALBANY
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TRAVIS ALDRIDGE, Index No.:
Plaintiff,
-against- VERIFIED COMPLAINT
JANE DOUGHERTY,
Defendant.
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Plaintiff, by and through his attorneys, Morgan and Morgan New York PLLC,
complaining of the defendants herein, respectfully shows to the Court, and alleges as follows
upon information and belief:
AS AND FOR A FIRST CAUSE OF ACTION
1. That at all times hereinafter mentioned, plaintiff, TRAVIS ALDRIDGE, was, and still is,
a resident of the State of Florida, County of Lee.
2. That at all times hereinafter mentioned, defendant, JANE DOUGHERTY, was, and still
is, a resident of the State of Pennsylvania, County of Luzerne.
3. That at all times hereinafter mentioned and on July 10, 2022, defendant, JANE
DOUGHERTY, was an owner, as defined in the Vehicle and Traffic Law Sec.128, of a
2020 Subaru Sedan motor vehicle bearing Pennsylvania State plate number 14743PD.
4. That at all times hereinafter mentioned, and on July 10, 2022, the defendant, JANE
DOUGHERTY, operated and controlled the motor vehicle bearing Pennsylvania State
plate number 14743PD.
5. That at all times hereinafter mentioned and on July 10, 2022, the plaintiff, TRAVIS
ALDRIDGE, was the owner of a 2019 Harley Davidson motor vehicle bearing Vermont
State license plate number KD414.
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FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022
6. That on July 10, 2022, the plaintiff, TRAVIS ALDRIDGE, was the operator of said
motor vehicle bearing New York State license plate number Vermont State license plate
number KD414 upon Wolf Road and Ulenski Drive, Colonie, New York, County of
Albany.
7. That on July 10, 2022, at said location upon Wolf Road and Ulenski Drive, Colonie, New
York, County of Albany, the defendant’s aforesaid motor vehicle came in contact with
the plaintiff’s vehicle while in violation of the New York Vehicle and Traffic Law.
8. That the aforesaid collision and injuries resulting therefrom, were due solely and wholly
to the careless and negligent manner in which the defendant, JANE DOUGHERTY,
operated and controlled their said motor vehicle without the plaintiff in any way
contributing thereto.
9. That by the reason of the foregoing and the negligence of the said defendant, plaintiff
TRAVIS ALDRIDGE was informed and verily believes that his aforesaid injuries are
permanent and that he will permanently suffer from the effects of his aforesaid injuries
and that he will be caused to suffer continuous pain and inconvenience.
10. That by reason of the foregoing, the plaintiff, TRAVIS ALDRIDGE, were compelled and
did necessarily require medical aid and attention and did necessarily pay and become
liable therefore, for medicines and other related medical expenses and upon information
and belief, the plaintiff will necessarily incur similar expenses.
WHEREFORE plaintiff, TRAVIS ALDRIDGE, demands judgment against defendant, JANE
DOUGHERTY in an amount to be determined at the time of trial, together with the costs and
disbursements of this action which exceeds the jurisdiction of the lower courts.
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FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022
Dated: New York, New York
November 3, 2022
Respectfully Submitted,
Daniel J. Watts
_________________________
HANDLING ATTORNEY, ESQ.
MORGAN & MORGAN NY PLLC
203 Jay Street, 6th Floor
Brooklyn, NY 11201
(917) 344-7043
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FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022
ATTORNEY VERIFICATION
DANIEL WATTS, an attorney duly licensed to practice in the courts of the State of New York,
hereby affirms the following under penalties of perjury:
That I am associated with the law firm of MORGAN & MORGAN NY, PLLC attorneys for the
plaintiff in the within action; that I have read the foregoing SUMMONS AND VERIFIED
COMPLAINT and know the contents thereof; and that the same is true to my own knowledge, except as
to the matters therein alleged to be on information and belief, and as to those matters, I believe them to be
true. The reason this Verification is made by me and not by the plaintiff is that said claimants resides
outside of the County in which the Affirmant’s office is located.
The grounds of my belief as to all matters stated upon my own knowledge are as follows: the
records, reports, contracts, and/or documents contained in the plaintiff’s file.
Daniel J. Watts
______________________
HANDLING ATTORNEY, ESQ.
MORGAN & MORGAN NY PLLC
203 Jay Street, 6th Floor
Brooklyn, NY 11201
(917) 344-7043
Affirmed: November 3, 2022
New York, NY
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Preview
FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ALBANY ----------------------------------------------------------------x TRAVIS ALDRIDGE, Index No.: Plaintiff, -against- SUMMONS The basis of the venue is: Place of Occurrence JANE DOUGHERTY, Defendant. ----------------------------------------------------------------x To the above-named defendants, YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff’s attorney within 30 days after the service of this summons, exclusive of the day of service; and in case of your failure to appear or answer judgment will be taken against you by default for the relief demanded in the complaint. Place of Occurrence: Wolf Road and Ulenski Drive, Colonie, New York, County of Albany. Dated: New York, New York November 3, 2022 Daniel J. Watts ___________________ DANIEL WATTS, ESQ. MORGAN & MORGAN NY PLLC 203 Jay Street, 6th Floor Brooklyn, NY 11201 (917) 344-7043 TO: JANE DOUGHERTY 41 Hi Tor East Freeland, PA 18224 1 of 5 FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ALBANY ----------------------------------------------------------------x TRAVIS ALDRIDGE, Index No.: Plaintiff, -against- VERIFIED COMPLAINT JANE DOUGHERTY, Defendant. ----------------------------------------------------------------x Plaintiff, by and through his attorneys, Morgan and Morgan New York PLLC, complaining of the defendants herein, respectfully shows to the Court, and alleges as follows upon information and belief: AS AND FOR A FIRST CAUSE OF ACTION 1. That at all times hereinafter mentioned, plaintiff, TRAVIS ALDRIDGE, was, and still is, a resident of the State of Florida, County of Lee. 2. That at all times hereinafter mentioned, defendant, JANE DOUGHERTY, was, and still is, a resident of the State of Pennsylvania, County of Luzerne. 3. That at all times hereinafter mentioned and on July 10, 2022, defendant, JANE DOUGHERTY, was an owner, as defined in the Vehicle and Traffic Law Sec.128, of a 2020 Subaru Sedan motor vehicle bearing Pennsylvania State plate number 14743PD. 4. That at all times hereinafter mentioned, and on July 10, 2022, the defendant, JANE DOUGHERTY, operated and controlled the motor vehicle bearing Pennsylvania State plate number 14743PD. 5. That at all times hereinafter mentioned and on July 10, 2022, the plaintiff, TRAVIS ALDRIDGE, was the owner of a 2019 Harley Davidson motor vehicle bearing Vermont State license plate number KD414. 2 of 5 FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022 6. That on July 10, 2022, the plaintiff, TRAVIS ALDRIDGE, was the operator of said motor vehicle bearing New York State license plate number Vermont State license plate number KD414 upon Wolf Road and Ulenski Drive, Colonie, New York, County of Albany. 7. That on July 10, 2022, at said location upon Wolf Road and Ulenski Drive, Colonie, New York, County of Albany, the defendant’s aforesaid motor vehicle came in contact with the plaintiff’s vehicle while in violation of the New York Vehicle and Traffic Law. 8. That the aforesaid collision and injuries resulting therefrom, were due solely and wholly to the careless and negligent manner in which the defendant, JANE DOUGHERTY, operated and controlled their said motor vehicle without the plaintiff in any way contributing thereto. 9. That by the reason of the foregoing and the negligence of the said defendant, plaintiff TRAVIS ALDRIDGE was informed and verily believes that his aforesaid injuries are permanent and that he will permanently suffer from the effects of his aforesaid injuries and that he will be caused to suffer continuous pain and inconvenience. 10. That by reason of the foregoing, the plaintiff, TRAVIS ALDRIDGE, were compelled and did necessarily require medical aid and attention and did necessarily pay and become liable therefore, for medicines and other related medical expenses and upon information and belief, the plaintiff will necessarily incur similar expenses. WHEREFORE plaintiff, TRAVIS ALDRIDGE, demands judgment against defendant, JANE DOUGHERTY in an amount to be determined at the time of trial, together with the costs and disbursements of this action which exceeds the jurisdiction of the lower courts. 3 of 5 FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022 Dated: New York, New York November 3, 2022 Respectfully Submitted, Daniel J. Watts _________________________ HANDLING ATTORNEY, ESQ. MORGAN & MORGAN NY PLLC 203 Jay Street, 6th Floor Brooklyn, NY 11201 (917) 344-7043 4 of 5 FILED: ALBANY COUNTY CLERK 11/03/2022 08:37 AM INDEX NO. 908331-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2022 ATTORNEY VERIFICATION DANIEL WATTS, an attorney duly licensed to practice in the courts of the State of New York, hereby affirms the following under penalties of perjury: That I am associated with the law firm of MORGAN & MORGAN NY, PLLC attorneys for the plaintiff in the within action; that I have read the foregoing SUMMONS AND VERIFIED COMPLAINT and know the contents thereof; and that the same is true to my own knowledge, except as to the matters therein alleged to be on information and belief, and as to those matters, I believe them to be true. The reason this Verification is made by me and not by the plaintiff is that said claimants resides outside of the County in which the Affirmant’s office is located. The grounds of my belief as to all matters stated upon my own knowledge are as follows: the records, reports, contracts, and/or documents contained in the plaintiff’s file. Daniel J. Watts ______________________ HANDLING ATTORNEY, ESQ. MORGAN & MORGAN NY PLLC 203 Jay Street, 6th Floor Brooklyn, NY 11201 (917) 344-7043 Affirmed: November 3, 2022 New York, NY 5 of 5