Preview
FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
GOVERNMENT EMPLOYEES INSURANCE Index No:
COMPANY AS SUBROGEE OF RANDOLPH ELLIS,
SUMMONS
Plaintiff(s),
Plaintiff'saddress:
-against- 750 Road
Woodbury
Woodbury, NY 11797
ALEXIS RATTRAY and "JOHN DOE", BEING A
FICTITIOUS NAME,
Venue designated is:
Place of Occurrence
Defendant(s).
To the above named defendant(s):
YOU ARE HEREBY SUMMONED and required to appear in the Court
of the at the office of the Clerk of said Court at 88-11 Sutphin Boulevard, Jamaica, NY
11435, County of Queens, State of New York by serving an Answer to the annexed
Complaint upon Clerk of the Court, at the address stated above within the time provided by
law as noted below; upon your failure to answer, judgment will be taken against you for the
sum of $33,504.29 with interest thereon from July 20, 2020, together with the costs of this
action.
Dated: MELVILLE, NEW YORK
December 23, 2020
Defendant(s) Address(es) Law fffee of Ricky J. Lucyk
By: Angelo Urso, Esq.
Alexis Rattray Attorney for Plaintiff(s)
2288 Baylis Avenue 2 Huntington Quadrangle, Suite 2N01
Elmont, NY 11003 Melville, NY 11747
File No. 0621069500101014
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FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021
NOTE: The law or rules of law provides that:
(a) If this surnmons is served by its delivery to you, or (for a corporation) an agent
authorized to receive service, personally within the , you must answer within twenty
(20) days after such service;
(b) If this surnmons is served otherwise than as designated in subdivision (a) above,
you are allowed thirty (30) days to answer after the proof of service is filedwith the
Clerk of this Court.
(c) You are required to filea copy of your answer together with proof of service with
the clerk of the district in which the action is brought within ten (10) days of the
service of the answer.
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FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
GOVERNMENT EMPLOYEES INSURANCE Index No:
COMPANY AS SUBROGEE OF RANDOLPH ELLIS,
VERIFIED COMPLAINT
Plaintiff(s),
Plaintiff's address:
-against- 750 Road
Woodbury
Woodbury, NY 11797
ALEXIS RATTRAY and "JOHN DOE", BEING A
FICTITIOUS NAME,
Venue designated is:
Place of Occurrence
Defendant(s).
Plaintiff(s), by its attorney, Angelo Urso, complaidñg of the defendant(s),
alleges as follows:
1. At alltimes herein stated and hereinafter mentioned the plaintiff was and still
is a
corporation authorized to do business in the State of New York, doing so in the
County of Queens.
2. That on June 1, 2020, the defendant Alexis Rattray owned a motor vehicle bearing
New York State license plate number JLS6555.
3. That on June 1, 2020, the defendant "John Doe", being afictitious name, operated a
motor vehicle bearing New York State license plate number JLS6555.
4. That on June 1, 2020, the defendant "John Doe", being afictitious name, operated a
motor vehicle bearing New York State license plate number JLS6555 with consent of
its owner.
5. That on or about June 1, 2020, plaintiff subrogor's automobile sustained damages
because of an accident which occurred at or near 915 East 92nd Of
Street, County
Kings, City and State of New York.
6. Said accident was due to the negligence of the defendants in the ownership, operation,
maintenance, management and control of a motor vehicle bearing New York State
license plate number JLS6555.
7. That as a result of said accident, plaintiff subrogor's automobile was damaged in the
amount of $32,076.45.
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FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021
8. That as a result of said accident, plaintiff subrogor's suffered $1,427.84 in loss of use.
WHEREFORE, plaintiff(s) demand(s) judgment against said defendant(s) for
the sum of $33,504.29 with iñterest thereon from July 20, 2020, the date of payment,
from plaineff subrogee to plaintiff subrogor, together with costs an bursements.
Dated: Melville, New York
December 23, 2020
Lk 6'ffice of Ricky J. Lucyk
By: Angelo Urso, Esq.
Attorney for Plaintiff(s)
2 Huntington Quadrangle, Suite 2N01
Melville, NY 11747
File No. 0621069500101014
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FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021
VERIFICATION
STATE OF NEW YORK )
COUNTY OF SUFFOLK )SS.:
)
Angelo Urso, Esq., an attorney duly authorized to practice in the State of New
York and not a party to this action, does hereby affirm that the following is true under the
penalties of perjury:
That he/she is an at law associated with Law Office of Ricky J. Lucyk,
attorney
attorneys for the Plaintiff.
That he/she has read the foregoing COMPLAINT and knows the contents thereof
and that same is true to his/her own knowledge except as to the matters therein stated to be
alleged upon information and belief, and as to those matters he/she believes to be true.
Affiant further says that the reason this verification is made by the affiant and not
the PLAINTIFF is because the said PLAINTIFF is a foreign corporation authorized to do
business in the State.
Ange o o, Esq.
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Preview
FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS GOVERNMENT EMPLOYEES INSURANCE Index No: COMPANY AS SUBROGEE OF RANDOLPH ELLIS, SUMMONS Plaintiff(s), Plaintiff'saddress: -against- 750 Road Woodbury Woodbury, NY 11797 ALEXIS RATTRAY and "JOHN DOE", BEING A FICTITIOUS NAME, Venue designated is: Place of Occurrence Defendant(s). To the above named defendant(s): YOU ARE HEREBY SUMMONED and required to appear in the Court of the at the office of the Clerk of said Court at 88-11 Sutphin Boulevard, Jamaica, NY 11435, County of Queens, State of New York by serving an Answer to the annexed Complaint upon Clerk of the Court, at the address stated above within the time provided by law as noted below; upon your failure to answer, judgment will be taken against you for the sum of $33,504.29 with interest thereon from July 20, 2020, together with the costs of this action. Dated: MELVILLE, NEW YORK December 23, 2020 Defendant(s) Address(es) Law fffee of Ricky J. Lucyk By: Angelo Urso, Esq. Alexis Rattray Attorney for Plaintiff(s) 2288 Baylis Avenue 2 Huntington Quadrangle, Suite 2N01 Elmont, NY 11003 Melville, NY 11747 File No. 0621069500101014 1 of 5 FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 NOTE: The law or rules of law provides that: (a) If this surnmons is served by its delivery to you, or (for a corporation) an agent authorized to receive service, personally within the , you must answer within twenty (20) days after such service; (b) If this surnmons is served otherwise than as designated in subdivision (a) above, you are allowed thirty (30) days to answer after the proof of service is filedwith the Clerk of this Court. (c) You are required to filea copy of your answer together with proof of service with the clerk of the district in which the action is brought within ten (10) days of the service of the answer. 2 of 5 FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS GOVERNMENT EMPLOYEES INSURANCE Index No: COMPANY AS SUBROGEE OF RANDOLPH ELLIS, VERIFIED COMPLAINT Plaintiff(s), Plaintiff's address: -against- 750 Road Woodbury Woodbury, NY 11797 ALEXIS RATTRAY and "JOHN DOE", BEING A FICTITIOUS NAME, Venue designated is: Place of Occurrence Defendant(s). Plaintiff(s), by its attorney, Angelo Urso, complaidñg of the defendant(s), alleges as follows: 1. At alltimes herein stated and hereinafter mentioned the plaintiff was and still is a corporation authorized to do business in the State of New York, doing so in the County of Queens. 2. That on June 1, 2020, the defendant Alexis Rattray owned a motor vehicle bearing New York State license plate number JLS6555. 3. That on June 1, 2020, the defendant "John Doe", being afictitious name, operated a motor vehicle bearing New York State license plate number JLS6555. 4. That on June 1, 2020, the defendant "John Doe", being afictitious name, operated a motor vehicle bearing New York State license plate number JLS6555 with consent of its owner. 5. That on or about June 1, 2020, plaintiff subrogor's automobile sustained damages because of an accident which occurred at or near 915 East 92nd Of Street, County Kings, City and State of New York. 6. Said accident was due to the negligence of the defendants in the ownership, operation, maintenance, management and control of a motor vehicle bearing New York State license plate number JLS6555. 7. That as a result of said accident, plaintiff subrogor's automobile was damaged in the amount of $32,076.45. 3 of 5 FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 8. That as a result of said accident, plaintiff subrogor's suffered $1,427.84 in loss of use. WHEREFORE, plaintiff(s) demand(s) judgment against said defendant(s) for the sum of $33,504.29 with iñterest thereon from July 20, 2020, the date of payment, from plaineff subrogee to plaintiff subrogor, together with costs an bursements. Dated: Melville, New York December 23, 2020 Lk 6'ffice of Ricky J. Lucyk By: Angelo Urso, Esq. Attorney for Plaintiff(s) 2 Huntington Quadrangle, Suite 2N01 Melville, NY 11747 File No. 0621069500101014 4 of 5 FILED: QUEENS COUNTY CLERK 01/20/2021 08:04 AM INDEX NO. 701299/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 VERIFICATION STATE OF NEW YORK ) COUNTY OF SUFFOLK )SS.: ) Angelo Urso, Esq., an attorney duly authorized to practice in the State of New York and not a party to this action, does hereby affirm that the following is true under the penalties of perjury: That he/she is an at law associated with Law Office of Ricky J. Lucyk, attorney attorneys for the Plaintiff. That he/she has read the foregoing COMPLAINT and knows the contents thereof and that same is true to his/her own knowledge except as to the matters therein stated to be alleged upon information and belief, and as to those matters he/she believes to be true. Affiant further says that the reason this verification is made by the affiant and not the PLAINTIFF is because the said PLAINTIFF is a foreign corporation authorized to do business in the State. Ange o o, Esq. 5 of 5