Preview
FILED: NASSAU COUNTY CLERK 10/14/2022 04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 10/14/2022
EXHIBIT B
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU Date Filed:
__________________________ ------X
HYACINTH REID, Index No.:
Plaintiff, SUMMONS
-against- Plaintiff designates Nassau
County as the place of trial
COUNTY OF NASSAU,
The basis of the venue designated is:
ACCIDENT SITUS
Defendant.
---------------------------------------------------X
To the above-named Defendant:
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 20 days after the service of this summons, exclusive
of the day 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: Mineola, New York
January 22, 2019
Yours, etc.,
Jarad L. Siegel, Esq.
MONTELEONE & SIEGEL, PLLC.
Attorneys for Plaintiff
HYACINTH REID
114 Old Country Road, Suite 216
Mineola, New York 11501
(516) 590-0550
To:
Defendant's Address:
COUNTY OF NASSAU
c/o NASSAU COUNTY ATTORNEY'S OFFICE
1 West Street
Mineola, New York 11501
1 of 9
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
_____________________ X
HYACINTH REID, Index No.:
Plaintiff, VERIFIED COMPLAINT
-against-
COUNTY OF NASSAU,
Defendant.
--------------- ¬--------------------------------------------X
Plaintiff HYACINTH REID, as and for her VERIFIED COMPLA1NT, by her attorneys
MONTELEONE & SIEGEL, PLLC., respectfully alleges the following, upon information and
belief:
1. That at all times hereinafter mentioned, the Plaintiff HYACINTH REID, was and
stillis a resident of the County of Queens, State of New York.
2. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, was
and stillis a municipal corporation duly organized and existing under and by virtue of the laws of
the State of New York and maintains its principal place of business located at One West Street,
Mineola, New York.
3. That at alltimes hereinafter mentioned, Defendant COUNTY OF NASSAU, owned
the courthouse building located at 99 Main Street, Hempstead, New York, known as the "Nassau
Building."
County District Court
4. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU,
operated the courthouse building located at 99 Main Street, Hempstead, New York, known as the
Building."
"Nassau County District Court
2 of 9
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
5. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU,
managed the courthouse building located at 99 Main Street, Hempstead, New York, known as the
Building."
"Nassau County District Court
6. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU,
maintained the courthouse building located at 99 Main Street, Hempstead, New York, known as
Building."
the "Nassau County District Court
7. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU,
controlled the courthouse building located at 99 Main Street, Hempstead, New York, known as
Building."
the "Nassau County District Court
8. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU,
performed work at the courthouse building located at 99 Main Street, Hempstead, New York,
Building."
known as the "Nassau County District Court
9. That at alltimes hereinafter mentioned, Defendant COUNTY OF NASSAU, caused
and created a hazardous condition within the courthouse building located at 99 Main Street,
Building."
Hempstead, New York, known as the "Nassau County District Court
10. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, had a
non-delegable duty to maintain the said courthouse building, inclusive of the light switch located
in Room L89, for the use of Plaintiff HYACINTH REID and other persons lawfully thereat.
11. That on February 18, 2018 at approximately 1:00 P.M. while Plaintiff HYACINTH
REID was working in Room L89 of the Nassau County District Court Building, located at 99 Main
Street, Hempstead, New York 11550, she was caused to be electrocuted due to a dangerous and
hazardous condition thereat, to wit: a defective and hazardous light switch thereby causing Plaintiff
to sustain severe and permanent personal injuries.
3 of 9
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
12. That on February 18, 2018 Defendant COUNTY OF NASSAU, failed to place
proper warning of a hazardous condition in the premises.
13. Upon information and belief, at all times hereinafter mentioned, Defendant
COUNTY OF NASSAU their agents, servants and/or employees had actual and/or constructive
notice and/or received prior notice of the dangerous light switch condition in that they created
same, were present on a daily basis prior to the underlying accident, and the Defendant by their
agents, servants and/or employees were further negligent in failing to exercise ordinary care in
maintaining the premises in a proper and reasonably safe condition and failing to warn Plaintiff of
the said dangerous and unsafe condition then and there existing.
14. That the said accident and resulting injuries to the PlaintiffHYACINTH REID were
caused solely by reason of the culpable conduct of the Defendant COUNTY OF NASSAU, its
agents, servants and/or employees without any culpable conduct on the part of the Plaintiff
contributing thereto.
15. That Defendant COUNTY OF NASSAU, its agents, servants and/or employees
were careless, reckless and negligent in the ownership, operation, management, maintenance and
control of the subject premises, to wit: by permitting and allowing said area to become and remain
in a dangerous condition; in failing to repair; in improperly repairing the premises; in using
improper materials to repair said premises; in allowing the light switch to become and remain in a
dangerous condition; in allowing and permitting the missing portion of the light switch to create a
trap-like and hazardous condition; in having incompetent employees, servants and/or agents; in
doing construction and repair in a negligent manner; in employing incompetent help; in failing to
erect guards or barriers; in permitting and allowing said light switch to be in a state of disrepair;
in creating said dangerous condition; in creating and permitting a trap; in failing to warn; in failing
4 of 9
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
to use due care and caution under the circumstances; in failing to remedy a hazardous condition
within a reasonable period of time; in failing to utilize ordinary and reasonable care to protect the
Plaintiff from risk of injuries; in failing to take proper precautions after having notice of the
condition complained of;in failing to adopt or enforce rules concerning light switches and building
maintenance; in allowing, permitting, maintaining a defective and dangerous light switch to exist
thereat; in failing to correct, remedy, remove or repair the defective, unsafe and hazardous light
switch condition so that the Defendant, by itsagents, servants and employees knew or should have
known about the dangerous condition and should have remedied same in the exercise of due care;
in failing to make timely and necessary and indicated inspections and repairs or were doing same
in a negligent and incompetent and haphazard manner; in causing the Plaintiff to become an
innocent victim of a dangerous condition; in failing to properly maintain the said light switch area
so as to provide a safe area where Plaintiff was injured; in failing to undertake proper and/or
adequate safety studies and/or surveys; in launching a force or instrument of harm; in creating a
hazardous condition; in failing to place safety warnings around the aforesaid dangerous and
hazardous light switch condition; in failing to rope off, close off or place barriers, barricades or
stanchions around the aforesaid dangerous and defective condition; in failing to make timely and
necessary and indicated inspections and repairs; in failing to remedy the conditions; in violating
all applicable statutes, rules, regulations and ordinances; and in being otherwise negligent,
careless, reckless and grossly negligent in the premises.
16. That on or about May 17, 2018, and within ninety (90) days after the accrual of the
claim sued upon herein, Plaintiff served upon the Defendant COUNTY OF NASSAU, a duly
executed Verified Notice of Claim setting forth the name and post office address of the Plaintiff
5 of 9
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
and her attorneys, the nature of the claim, the time when, the place where and the manner in which
the claim arose and the items of damages claimed.
17. That pursuant to Section 50 of the General Municipal Law, a 50-H hearing was held
by the Defendant COUNTY OF NASSAU on November 14, 2018.
18. That more than thirty (30) days have elapsed since the service of said Notice of
Claim and that payment or adjustment has been neglected or refused.
19. That this action was commenced within one (1) year and ninety (90) days from the
date the cause of action accrued.
20. That solely as a result of the foregoing, Plaintiff HYACINTH REID, has sustained
serious and catastrophic injuries and has experienced and will continue to experience physical and
mental suffering and distress.
21. That solely as a result of the foregoing, Plaintiff HYACINTH REID has incurred
medical expenses and a loss of income.
22. That the limitations set forth in Article 16 of the CPLR do not apply to this action.
23. That solely as a result of the foregoing, Plaintiff HYACINTH REID, has been
damaged in an amount which exceeds the jurisdictional limits of all lower courts which would
otherwise have jurisdiction herein.
6 of 9
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
WHEREFORE, Plaintiff HYACINTH REID, demands judgment against Defendant
COUNTY OF NASSAU, herein on all causes of action, in an amount exceeding the jurisdictional
limits of all lower courts which would otherwise have jurisdiction, together with the costs and
disbursements of this action.
Dated: Mineola, New York
January 22, 2019
Yours, etc.
Jarad L. Siegel, Esq.
MONTELEONE & SIEGEL, PLLC.
Attorney for Plaintiff
HYACINTH REID
114 Old Country Road, Suite 216
Mineola, New York 11501
(516) 590-0550
7 of 9
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
ATTORNEY VERIFICATION
Jarad L. Siegel, Esq., an attorney admitted to practice before the Courts of the State ofNew
York, hereby affirms as true under the penalties of perjury:
I am a Partner with the law firm of MONTELEONE & SIEGEL, PLLC. the attorneys of
record for the Plaintiff in the within action. I have read the foregoing Summons and Verified
Complaint and know the contents thereof, the same are true to affirmant's own knowledge, except
as to matters therein stated to be alleged on information and belief, and as to those matters, I believe
to be true. My belief, as to those matters therein not stated upon knowledge, is based upon facts,
records, and other pertinent information contained in our files.
The reason I make the foregoing affinnation instead of Plaintiff is because Plaintiff does
not reside in the county where the attorneys for the Plaintiff maintain their offices.
Dated: Mineola, New York
January 22, 2019
JAP L. SIEGEL, ESQ.
8 of 9
FILED: NASSAU COUNTY CLERK 01/22/2019
10/14/2022 02:25
04:27 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 1
48 RECEIVED NYSCEF: 01/22/2019
10/14/2022
Index No.: Year
HYACINTH REID,
Plaintiff(s),
-against-
COUNTY OF NASSAU.,
Defendant(s).
SUMMONS & VER1FIED COMPLAINT
MONTELEONE & SIEGEL, PLLC.
Attorneys for Plaintiff
114 Old Country Road, Suite 216
Mineola, New York 11501
(516) 590-0550
To
Signature ule 130-1.1-al
Jarad L Siegel, Esq.
Attorney(s) for
Service of a copyof thewithin is hereby admitted
Dated: January 22, 2019
Attorney(s) forPlaintiff
Please take notice
o Notice ofEntry
thatthe within is a (certified)
true copy of an Order duly entered inthe office of theclerk of thewithin named court
on
a Notice of Settlement
thatan order of Settlement of which the within isa true copy willbe presented for settlement to theHon. one
of the judges of thewithin named courtat on .
Dated: January 22, 2019
Yours, etc.
MONTELEONE & SIEGEL, PLLC.
Attorneys for Plaintiff
114 Old Country Road, Suite 216
Mineola, New York 11501
(516) 590-0550
9 of 9
Preview
FILED: NASSAU COUNTY CLERK 10/14/2022 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 10/14/2022 EXHIBIT B FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU Date Filed: __________________________ ------X HYACINTH REID, Index No.: Plaintiff, SUMMONS -against- Plaintiff designates Nassau County as the place of trial COUNTY OF NASSAU, The basis of the venue designated is: ACCIDENT SITUS Defendant. ---------------------------------------------------X To the above-named Defendant: 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 20 days after the service of this summons, exclusive of the day 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: Mineola, New York January 22, 2019 Yours, etc., Jarad L. Siegel, Esq. MONTELEONE & SIEGEL, PLLC. Attorneys for Plaintiff HYACINTH REID 114 Old Country Road, Suite 216 Mineola, New York 11501 (516) 590-0550 To: Defendant's Address: COUNTY OF NASSAU c/o NASSAU COUNTY ATTORNEY'S OFFICE 1 West Street Mineola, New York 11501 1 of 9 FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU _____________________ X HYACINTH REID, Index No.: Plaintiff, VERIFIED COMPLAINT -against- COUNTY OF NASSAU, Defendant. --------------- ¬--------------------------------------------X Plaintiff HYACINTH REID, as and for her VERIFIED COMPLA1NT, by her attorneys MONTELEONE & SIEGEL, PLLC., respectfully alleges the following, upon information and belief: 1. That at all times hereinafter mentioned, the Plaintiff HYACINTH REID, was and stillis a resident of the County of Queens, State of New York. 2. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, was and stillis a municipal corporation duly organized and existing under and by virtue of the laws of the State of New York and maintains its principal place of business located at One West Street, Mineola, New York. 3. That at alltimes hereinafter mentioned, Defendant COUNTY OF NASSAU, owned the courthouse building located at 99 Main Street, Hempstead, New York, known as the "Nassau Building." County District Court 4. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, operated the courthouse building located at 99 Main Street, Hempstead, New York, known as the Building." "Nassau County District Court 2 of 9 FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 5. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, managed the courthouse building located at 99 Main Street, Hempstead, New York, known as the Building." "Nassau County District Court 6. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, maintained the courthouse building located at 99 Main Street, Hempstead, New York, known as Building." the "Nassau County District Court 7. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, controlled the courthouse building located at 99 Main Street, Hempstead, New York, known as Building." the "Nassau County District Court 8. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, performed work at the courthouse building located at 99 Main Street, Hempstead, New York, Building." known as the "Nassau County District Court 9. That at alltimes hereinafter mentioned, Defendant COUNTY OF NASSAU, caused and created a hazardous condition within the courthouse building located at 99 Main Street, Building." Hempstead, New York, known as the "Nassau County District Court 10. That at all times hereinafter mentioned, Defendant COUNTY OF NASSAU, had a non-delegable duty to maintain the said courthouse building, inclusive of the light switch located in Room L89, for the use of Plaintiff HYACINTH REID and other persons lawfully thereat. 11. That on February 18, 2018 at approximately 1:00 P.M. while Plaintiff HYACINTH REID was working in Room L89 of the Nassau County District Court Building, located at 99 Main Street, Hempstead, New York 11550, she was caused to be electrocuted due to a dangerous and hazardous condition thereat, to wit: a defective and hazardous light switch thereby causing Plaintiff to sustain severe and permanent personal injuries. 3 of 9 FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 12. That on February 18, 2018 Defendant COUNTY OF NASSAU, failed to place proper warning of a hazardous condition in the premises. 13. Upon information and belief, at all times hereinafter mentioned, Defendant COUNTY OF NASSAU their agents, servants and/or employees had actual and/or constructive notice and/or received prior notice of the dangerous light switch condition in that they created same, were present on a daily basis prior to the underlying accident, and the Defendant by their agents, servants and/or employees were further negligent in failing to exercise ordinary care in maintaining the premises in a proper and reasonably safe condition and failing to warn Plaintiff of the said dangerous and unsafe condition then and there existing. 14. That the said accident and resulting injuries to the PlaintiffHYACINTH REID were caused solely by reason of the culpable conduct of the Defendant COUNTY OF NASSAU, its agents, servants and/or employees without any culpable conduct on the part of the Plaintiff contributing thereto. 15. That Defendant COUNTY OF NASSAU, its agents, servants and/or employees were careless, reckless and negligent in the ownership, operation, management, maintenance and control of the subject premises, to wit: by permitting and allowing said area to become and remain in a dangerous condition; in failing to repair; in improperly repairing the premises; in using improper materials to repair said premises; in allowing the light switch to become and remain in a dangerous condition; in allowing and permitting the missing portion of the light switch to create a trap-like and hazardous condition; in having incompetent employees, servants and/or agents; in doing construction and repair in a negligent manner; in employing incompetent help; in failing to erect guards or barriers; in permitting and allowing said light switch to be in a state of disrepair; in creating said dangerous condition; in creating and permitting a trap; in failing to warn; in failing 4 of 9 FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 to use due care and caution under the circumstances; in failing to remedy a hazardous condition within a reasonable period of time; in failing to utilize ordinary and reasonable care to protect the Plaintiff from risk of injuries; in failing to take proper precautions after having notice of the condition complained of;in failing to adopt or enforce rules concerning light switches and building maintenance; in allowing, permitting, maintaining a defective and dangerous light switch to exist thereat; in failing to correct, remedy, remove or repair the defective, unsafe and hazardous light switch condition so that the Defendant, by itsagents, servants and employees knew or should have known about the dangerous condition and should have remedied same in the exercise of due care; in failing to make timely and necessary and indicated inspections and repairs or were doing same in a negligent and incompetent and haphazard manner; in causing the Plaintiff to become an innocent victim of a dangerous condition; in failing to properly maintain the said light switch area so as to provide a safe area where Plaintiff was injured; in failing to undertake proper and/or adequate safety studies and/or surveys; in launching a force or instrument of harm; in creating a hazardous condition; in failing to place safety warnings around the aforesaid dangerous and hazardous light switch condition; in failing to rope off, close off or place barriers, barricades or stanchions around the aforesaid dangerous and defective condition; in failing to make timely and necessary and indicated inspections and repairs; in failing to remedy the conditions; in violating all applicable statutes, rules, regulations and ordinances; and in being otherwise negligent, careless, reckless and grossly negligent in the premises. 16. That on or about May 17, 2018, and within ninety (90) days after the accrual of the claim sued upon herein, Plaintiff served upon the Defendant COUNTY OF NASSAU, a duly executed Verified Notice of Claim setting forth the name and post office address of the Plaintiff 5 of 9 FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 and her attorneys, the nature of the claim, the time when, the place where and the manner in which the claim arose and the items of damages claimed. 17. That pursuant to Section 50 of the General Municipal Law, a 50-H hearing was held by the Defendant COUNTY OF NASSAU on November 14, 2018. 18. That more than thirty (30) days have elapsed since the service of said Notice of Claim and that payment or adjustment has been neglected or refused. 19. That this action was commenced within one (1) year and ninety (90) days from the date the cause of action accrued. 20. That solely as a result of the foregoing, Plaintiff HYACINTH REID, has sustained serious and catastrophic injuries and has experienced and will continue to experience physical and mental suffering and distress. 21. That solely as a result of the foregoing, Plaintiff HYACINTH REID has incurred medical expenses and a loss of income. 22. That the limitations set forth in Article 16 of the CPLR do not apply to this action. 23. That solely as a result of the foregoing, Plaintiff HYACINTH REID, has been damaged in an amount which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction herein. 6 of 9 FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 WHEREFORE, Plaintiff HYACINTH REID, demands judgment against Defendant COUNTY OF NASSAU, herein on all causes of action, in an amount exceeding the jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with the costs and disbursements of this action. Dated: Mineola, New York January 22, 2019 Yours, etc. Jarad L. Siegel, Esq. MONTELEONE & SIEGEL, PLLC. Attorney for Plaintiff HYACINTH REID 114 Old Country Road, Suite 216 Mineola, New York 11501 (516) 590-0550 7 of 9 FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 ATTORNEY VERIFICATION Jarad L. Siegel, Esq., an attorney admitted to practice before the Courts of the State ofNew York, hereby affirms as true under the penalties of perjury: I am a Partner with the law firm of MONTELEONE & SIEGEL, PLLC. the attorneys of record for the Plaintiff in the within action. I have read the foregoing Summons and Verified Complaint and know the contents thereof, the same are true to affirmant's own knowledge, except as to matters therein stated to be alleged on information and belief, and as to those matters, I believe to be true. My belief, as to those matters therein not stated upon knowledge, is based upon facts, records, and other pertinent information contained in our files. The reason I make the foregoing affinnation instead of Plaintiff is because Plaintiff does not reside in the county where the attorneys for the Plaintiff maintain their offices. Dated: Mineola, New York January 22, 2019 JAP L. SIEGEL, ESQ. 8 of 9 FILED: NASSAU COUNTY CLERK 01/22/2019 10/14/2022 02:25 04:27 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 1 48 RECEIVED NYSCEF: 01/22/2019 10/14/2022 Index No.: Year HYACINTH REID, Plaintiff(s), -against- COUNTY OF NASSAU., Defendant(s). SUMMONS & VER1FIED COMPLAINT MONTELEONE & SIEGEL, PLLC. Attorneys for Plaintiff 114 Old Country Road, Suite 216 Mineola, New York 11501 (516) 590-0550 To Signature ule 130-1.1-al Jarad L Siegel, Esq. Attorney(s) for Service of a copyof thewithin is hereby admitted Dated: January 22, 2019 Attorney(s) forPlaintiff Please take notice o Notice ofEntry thatthe within is a (certified) true copy of an Order duly entered inthe office of theclerk of thewithin named court on a Notice of Settlement thatan order of Settlement of which the within isa true copy willbe presented for settlement to theHon. one of the judges of thewithin named courtat on . Dated: January 22, 2019 Yours, etc. MONTELEONE & SIEGEL, PLLC. Attorneys for Plaintiff 114 Old Country Road, Suite 216 Mineola, New York 11501 (516) 590-0550 9 of 9