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FILED: ALBANY COUNTY CLERK 11/09/2022 11:27 AM INDEX NO. 908442-22
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ALBANY
Index No.:
TAQUELL M. PLOWDEN, Date Purchased:
Plaintiff,
- against - SUMMONS
Plaintiff designates Albany County as
GEORGE J. MASTRANGELO, and TATIANA the place of Trial.
S. ST. LAURENT
The basis of venue is: Party Residence and
Defendants.
Place of Occurrence – Albany, NY
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(s) within 20 days after the service of this
summons, exclusive of the date of service (or within 30 days after the service is complete if
this summons is not personally delivered to you within the State of New York); 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.
Dated: New York, New York
November 7, 2022 BRANDON J. BRODERICK, LLC
By:____________________________
JASON A. RICHMAN, ESQ.
Attorneys for Plaintiff
11 BROADWAY STE 615
NEW YORK, NY 10004
Telephone: (201) 746-4528
TO:
GEORGE J. MASTRANGELO
299 ½ LARK STREET
ALBANY, NY 12210
TATIANA S. ST. LAURENT
228 CLINTON AVENUE
ALBANY, NY 12210
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ALBANY
Index No.:
TAQUELL M. PLOWDEN,
Plaintiff, VERIFIED COMPLAINT
- against -
GEORGE J. MASTRANGELO, and TATIANA
S. ST. LAURENT
Defendants.
Plaintiff, TAQUELL M. PLOWDEN, by his attorneys, BRANDON J. BRODERICK,
ESQ., LLC, complaining of the defendants herein, respectfully sets forth and alleges the following
upon information and belief:
1. That at all times hereinafter mentioned, Plaintiff, TAQUELL M. PLOWDEN, has
been a resident of Albany County, State of New York.
2. Upon information and belief, and at all times hereinafter mentioned, the defendant,
GEORGE J. MASTRANGELO, has been a resident of Albany County, State of New York.
3. Upon information and belief, and at all times hereinafter mentioned, the
defendant, GEORGE J. MASTRANGELO, was the owner and operator of a motor vehicle bearing
New York State plate number GSH6876 for the year 2007.
4. Upon information and belief, and at all times hereinafter mentioned, the defendant,
TATIANA S. ST. LAURENT has been a resident of Albany County, State of New York.
5. Upon information and belief, and at all times hereinafter mentioned, the defendant,
TATIANA S. ST. LAURENT was the owner and operator of a motor vehicle bearing New York
State plate number KSK7961 for the year 2006.
6. That on or about January 24, 2022, the plaintiff, TAQUELL M. PLOWDEN, was
a passenger of the defendant’s TATIANA S. ST. LAURENT vehicle who, was struck by
Defendant GEORGE J. MASTRANGELO’S vehicle.
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7. That at all times hereinafter mentioned the accident occurred at the intersection of
Quail Street and Elberon Place, Albany County, State of New York, which intersection was and
still is a public roadway located within New York State.
8. Upon information and belief and at all times and places hereinafter mentioned, the
defendants were fully responsible for the proper and prudent operation, management, maintenance,
entrustment, and control of their aforesaid motor vehicles.
9. That on the aforesaid date and at the aforesaid location, the motor vehicle owned
and operated by the defendant GEORGE J. MASTRANGELO’s was traveling on Elberton Place
failed to stop at the stop sign located at the intersection colliding with the defendant TATIANA
S. ST. LAURENT’s vehicle.
10. That the said accident occurred solely and wholly by reason of the carelessness,
recklessness and negligence of the defendants in the ownership, operation, maintenance,
management and control of their aforementioned motor vehicles and without any negligence on
the part of the innocent passenger plaintiff TAQUELL M. PLOWDEN in any manner contributing
hereto.
11. That the negligence of the defendant, GEORGE J. MASTRANGELO and
TATIANA S. ST. LAURENT consisted of their negligent operation, ownership, maintenance and
control of their motor vehicle; in operating their motor vehicle at an excessive rate of speed under
the circumstances then and there prevailing; in failing to stop; in failing to slow down; in operating
their motor vehicle in a state of disrepair; in failing to keep their motor vehicle under proper
control; in operating their motor vehicle in a dangerous and reckless manner; in failing to keep a
proper lookout; in failing to give warning of their approach; in failing to observe the traffic controls
and rules of the road; in failing to make proper, timely and adequate use of the signal devices,
brakes and other safety equipment; in disregarding and disobeying the applicable laws, statutes,
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ordinances, rules and regulations governing the movement of motor vehicle traffic at the time and
place of the occurrence; and in being in all ways generally careless, reckless and negligent.
12. That as a result of the negligence of the defendant, as hereinbefore alleged, the
plaintiff, was caused to be rendered sick, sore, lame and disabled, and to sustain severe and
grievous injuries to the head, body and limbs, both internal and external, and to sustain and still
sustain severe pain, mental anguish and physical and emotional disability.
13. Upon information and belief, that this action falls within one or more of the
exceptions of §1602 of the Civil Practice Law and Rules.
14. That be reason thereof, the plaintiff TAQUELL M. PLOWDEN, is entitled to
recover non-economic loss and for such economic losses as set forth in Section 5102(j) of the
Insurance Law of the State of New York.
15. That the plaintiff, TAQUELL M. PLOWDEN, is a “covered person” as defined by
section 5102(j) of the Insurance Law of the State of New York.
16. That the plaintiff. TAQUELL M. PLOWDEN has sustained serious injuries as
defined in Sections 5102 and 5104 of the Insurance Law of the State of New York.
17. That as a result, plaintiff TAQUELL M. PLOWDEN was caused to sustain serious
and severe personal injuries.
18. That as a result of said injuries, plaintiff TAQUELL M. PLOWDEN has been
caused to incur, and will, upon information and belief, continue to incur expenses for medical care,
surgeries and rehabilitation; as a result of said injuries, Plaintiff was and has been unable to
perform his usual occupations and activities, and as a further result, Plaintiff was and will continue
to be rendered unable to perform his normal daily activities and duties as he could prior to the
complained of accident.
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022
19. That by reason of the foregoing negligent hiring and retention, Plaintiff TAQUELL
M. PLOWDEN has sustained damages, both general and special, in an amount which exceeds the
jurisdictional limits of all lower courts which would otherwise have jurisdiction.
20. That as a result of the negligence and/or recklessness of defendants GEORGE J.
MASTRANGELO and TATIANA S. ST. LAURENT as alleged above, plaintiff TAQUELL M.
PLOWDEN was injured and has suffered damages in an amount which exceeds the monetary
jurisdictional limits of all lower New York State Courts.
WHEREFORE, plaintiff TAQUELL M. PLOWDEN demands monetary damages and
judgment against the defendants GEORGE J. MASTRANGELO and TATIANA S. ST.
LAURENT, jointly and severally, as set forth above, for compensatory damages in a sum which
exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction,
together with interest thereon from the date of judgment where applicable herein; and plaintiff
demands the costs and disbursements of this action as well as such other and further relief as to
this Court may seem just, proper and equitable.
Dated: New York, New York
November 7, 2022 BRANDON J. BRODERICK, ESQ., LLC
By:____________________________
JASON A. RICHMAN, ESQ.
Attorneys for Plaintiff
11 Broadway Suite 615
New York, New York 10004
Telephone: (201) 746-4528
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022
ATTORNEY VERIFICATION
Jason A. Richman, Esq., an attorney duly admitted to practice law before the Courts of
the State of New York, affirms the truth of the following matters under penalty of perjury:
I am an associate of the law firm of BRANDON J. BRODERICK LLC attorneys for the
plaintiff in the within action, and as such am fully familiar with facts and circumstances
constituting the within action.
I have read the foregoing Verified Complaint and know the contents thereof to be true to
my own knowledge, except as to those matters alleged therein upon information and belief, and as
to those matters, I believe them to be true.
The sources of my belief as those matters alleged upon information and belief are as
follows: conversations with my client, investigation, research, and review of the file in this matter.
The reason that this verification is being made by me and not the plaintiff personally is that
plaintiff is presently not within the county where I maintain my office for the practice of law.
Dated: New York, New York
November 7, 2022 BRANDON J. BRODERICK, LLC
By:____________________________
JASON A. RICHMAN, ESQ.
Attorneys for Plaintiff
11 Broadway Suite 615
New York, New York 10004
Telephone: (201) 746-4528
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Preview
FILED: ALBANY COUNTY CLERK 11/09/2022 11:27 AM INDEX NO. 908442-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ALBANY Index No.: TAQUELL M. PLOWDEN, Date Purchased: Plaintiff, - against - SUMMONS Plaintiff designates Albany County as GEORGE J. MASTRANGELO, and TATIANA the place of Trial. S. ST. LAURENT The basis of venue is: Party Residence and Defendants. Place of Occurrence – Albany, NY 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(s) within 20 days after the service of this summons, exclusive of the date of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); 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. Dated: New York, New York November 7, 2022 BRANDON J. BRODERICK, LLC By:____________________________ JASON A. RICHMAN, ESQ. Attorneys for Plaintiff 11 BROADWAY STE 615 NEW YORK, NY 10004 Telephone: (201) 746-4528 TO: GEORGE J. MASTRANGELO 299 ½ LARK STREET ALBANY, NY 12210 TATIANA S. ST. LAURENT 228 CLINTON AVENUE ALBANY, NY 12210 1 1 of 6 FILED: ALBANY COUNTY CLERK 11/09/2022 11:27 AM INDEX NO. 908442-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ALBANY Index No.: TAQUELL M. PLOWDEN, Plaintiff, VERIFIED COMPLAINT - against - GEORGE J. MASTRANGELO, and TATIANA S. ST. LAURENT Defendants. Plaintiff, TAQUELL M. PLOWDEN, by his attorneys, BRANDON J. BRODERICK, ESQ., LLC, complaining of the defendants herein, respectfully sets forth and alleges the following upon information and belief: 1. That at all times hereinafter mentioned, Plaintiff, TAQUELL M. PLOWDEN, has been a resident of Albany County, State of New York. 2. Upon information and belief, and at all times hereinafter mentioned, the defendant, GEORGE J. MASTRANGELO, has been a resident of Albany County, State of New York. 3. Upon information and belief, and at all times hereinafter mentioned, the defendant, GEORGE J. MASTRANGELO, was the owner and operator of a motor vehicle bearing New York State plate number GSH6876 for the year 2007. 4. Upon information and belief, and at all times hereinafter mentioned, the defendant, TATIANA S. ST. LAURENT has been a resident of Albany County, State of New York. 5. Upon information and belief, and at all times hereinafter mentioned, the defendant, TATIANA S. ST. LAURENT was the owner and operator of a motor vehicle bearing New York State plate number KSK7961 for the year 2006. 6. That on or about January 24, 2022, the plaintiff, TAQUELL M. PLOWDEN, was a passenger of the defendant’s TATIANA S. ST. LAURENT vehicle who, was struck by Defendant GEORGE J. MASTRANGELO’S vehicle. 2 2 of 6 FILED: ALBANY COUNTY CLERK 11/09/2022 11:27 AM INDEX NO. 908442-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022 7. That at all times hereinafter mentioned the accident occurred at the intersection of Quail Street and Elberon Place, Albany County, State of New York, which intersection was and still is a public roadway located within New York State. 8. Upon information and belief and at all times and places hereinafter mentioned, the defendants were fully responsible for the proper and prudent operation, management, maintenance, entrustment, and control of their aforesaid motor vehicles. 9. That on the aforesaid date and at the aforesaid location, the motor vehicle owned and operated by the defendant GEORGE J. MASTRANGELO’s was traveling on Elberton Place failed to stop at the stop sign located at the intersection colliding with the defendant TATIANA S. ST. LAURENT’s vehicle. 10. That the said accident occurred solely and wholly by reason of the carelessness, recklessness and negligence of the defendants in the ownership, operation, maintenance, management and control of their aforementioned motor vehicles and without any negligence on the part of the innocent passenger plaintiff TAQUELL M. PLOWDEN in any manner contributing hereto. 11. That the negligence of the defendant, GEORGE J. MASTRANGELO and TATIANA S. ST. LAURENT consisted of their negligent operation, ownership, maintenance and control of their motor vehicle; in operating their motor vehicle at an excessive rate of speed under the circumstances then and there prevailing; in failing to stop; in failing to slow down; in operating their motor vehicle in a state of disrepair; in failing to keep their motor vehicle under proper control; in operating their motor vehicle in a dangerous and reckless manner; in failing to keep a proper lookout; in failing to give warning of their approach; in failing to observe the traffic controls and rules of the road; in failing to make proper, timely and adequate use of the signal devices, brakes and other safety equipment; in disregarding and disobeying the applicable laws, statutes, 3 3 of 6 FILED: ALBANY COUNTY CLERK 11/09/2022 11:27 AM INDEX NO. 908442-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022 ordinances, rules and regulations governing the movement of motor vehicle traffic at the time and place of the occurrence; and in being in all ways generally careless, reckless and negligent. 12. That as a result of the negligence of the defendant, as hereinbefore alleged, the plaintiff, was caused to be rendered sick, sore, lame and disabled, and to sustain severe and grievous injuries to the head, body and limbs, both internal and external, and to sustain and still sustain severe pain, mental anguish and physical and emotional disability. 13. Upon information and belief, that this action falls within one or more of the exceptions of §1602 of the Civil Practice Law and Rules. 14. That be reason thereof, the plaintiff TAQUELL M. PLOWDEN, is entitled to recover non-economic loss and for such economic losses as set forth in Section 5102(j) of the Insurance Law of the State of New York. 15. That the plaintiff, TAQUELL M. PLOWDEN, is a “covered person” as defined by section 5102(j) of the Insurance Law of the State of New York. 16. That the plaintiff. TAQUELL M. PLOWDEN has sustained serious injuries as defined in Sections 5102 and 5104 of the Insurance Law of the State of New York. 17. That as a result, plaintiff TAQUELL M. PLOWDEN was caused to sustain serious and severe personal injuries. 18. That as a result of said injuries, plaintiff TAQUELL M. PLOWDEN has been caused to incur, and will, upon information and belief, continue to incur expenses for medical care, surgeries and rehabilitation; as a result of said injuries, Plaintiff was and has been unable to perform his usual occupations and activities, and as a further result, Plaintiff was and will continue to be rendered unable to perform his normal daily activities and duties as he could prior to the complained of accident. 4 4 of 6 FILED: ALBANY COUNTY CLERK 11/09/2022 11:27 AM INDEX NO. 908442-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022 19. That by reason of the foregoing negligent hiring and retention, Plaintiff TAQUELL M. PLOWDEN has sustained damages, both general and special, in an amount which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. 20. That as a result of the negligence and/or recklessness of defendants GEORGE J. MASTRANGELO and TATIANA S. ST. LAURENT as alleged above, plaintiff TAQUELL M. PLOWDEN was injured and has suffered damages in an amount which exceeds the monetary jurisdictional limits of all lower New York State Courts. WHEREFORE, plaintiff TAQUELL M. PLOWDEN demands monetary damages and judgment against the defendants GEORGE J. MASTRANGELO and TATIANA S. ST. LAURENT, jointly and severally, as set forth above, for compensatory damages in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with interest thereon from the date of judgment where applicable herein; and plaintiff demands the costs and disbursements of this action as well as such other and further relief as to this Court may seem just, proper and equitable. Dated: New York, New York November 7, 2022 BRANDON J. BRODERICK, ESQ., LLC By:____________________________ JASON A. RICHMAN, ESQ. Attorneys for Plaintiff 11 Broadway Suite 615 New York, New York 10004 Telephone: (201) 746-4528 5 5 of 6 FILED: ALBANY COUNTY CLERK 11/09/2022 11:27 AM INDEX NO. 908442-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/09/2022 ATTORNEY VERIFICATION Jason A. Richman, Esq., an attorney duly admitted to practice law before the Courts of the State of New York, affirms the truth of the following matters under penalty of perjury: I am an associate of the law firm of BRANDON J. BRODERICK LLC attorneys for the plaintiff in the within action, and as such am fully familiar with facts and circumstances constituting the within action. I have read the foregoing Verified Complaint and know the contents thereof to be true to my own knowledge, except as to those matters alleged therein upon information and belief, and as to those matters, I believe them to be true. The sources of my belief as those matters alleged upon information and belief are as follows: conversations with my client, investigation, research, and review of the file in this matter. The reason that this verification is being made by me and not the plaintiff personally is that plaintiff is presently not within the county where I maintain my office for the practice of law. Dated: New York, New York November 7, 2022 BRANDON J. BRODERICK, LLC By:____________________________ JASON A. RICHMAN, ESQ. Attorneys for Plaintiff 11 Broadway Suite 615 New York, New York 10004 Telephone: (201) 746-4528 6 6 of 6