Preview
FILED: SUFFOLK COUNTY CLERK 08/17/2022 02:12 PM INDEX NO. 616339/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/23/2022
Supreme Court of the State of New York in
and for the County of Suffolk, at the
Courthouse thereof in Riverhead, New York
on the ____ day of ______________, 2022.
-----------------------------------------------------------------------------------------x
MATTEO RUSSO, AN INFANT OVER THE AGE OF
FOURTEEN (14) YEARS, BY HIS MOTHER AND NATURAL
GUARDIAN, ROSSANA RUSSO, PETITION
Petitioners,
Index No. :
- against - 616339/2022
VICTOR M. CALCANO AND BARBARA A. CALCANO,
Respondents.
------------------------------------------------------------------------------------------x
1. By Affidavit of Petitioner ROSSANA RUSSO, (“Petitioner ROSSANA”),
Mother and Natural Guardian of Infant Petitioner, MATTEO RUSSO, (“Infant Petitioner
MATTEO”) sworn to the 11th day of August, 2022, the Affidavit of Infant Petitioner, MATTEO,
an infant over the age of fourteen (14) years, sworn to the 11th day of August, 2022; an Attorney’s
Affirmation of JOHN C. THEOODORELLIS, ESQ. dated the 11th day of August, 2022; a
Physician’s Affidavit of JOHN A. GRANT, M.D., dated the 2nd day of August, and proof of the
offer of settlement from PROGRESSIVE CASUALTY INSURANCE COMPANY
(“PROGRESSIVE”) dated June 22, 2022, Petitioners, by their attorneys, LAW OFFICES OF
ARNOLD N. KRISS, hereby submit the within Order for Compromise and respectfully request that said
Order be granted by the Court.
2. No previous application has been made for the relief requested.
WHEREFORE, Petitioners respectfully request that the Court consent to the Compromise of Infant
Petitioner MATTEO’s settlement of his personal injury claim against Respondents, VICTOR M.
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FILED: SUFFOLK COUNTY CLERK 08/17/2022 02:12 PM INDEX NO. 616339/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/23/2022
CALCANO AND BARBARA A. CALCANO, together with such other and further relief as the Court
deems just proper and equitable.
Dated: New York, New York
August \ I , 2022 ODORELLIS, ESQ.
ffices ofArnold N. Kriss
Atto eys for Petitioners
Office & P.O. Address
123 William Street, 15th Floor
New York, New York 10038
(212) 577-2000
2 of 3
FILED: SUFFOLK COUNTY CLERK 08/17/2022 02:12 PM INDEX NO. 616339/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/23/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
-------------------------------------------------------------------------------x
MATTEO RUSSO, AN INFANT OVER THE AGE OF
FOURTEEN (14) YEARS, BY HIS MOTHER AND
NATURAL GUARDIAN, ROSSANA RUSSO, Index No.
Petitioners,
- against -
VICTOR M. CALCANO AND BARBARA A. CALCANO,
Respondents.
-------------------------------------------------------------------------------x
PETITION
Law Offices of Arnold N. Kriss
123 William Street, 15th Floor
New York, New York 10038
(212) 577-2000
Counsel for Plaintiff
STATE OF NEW YORK )
ss.:
COUNTY OF NEW YORK )
CERTIFICATION: I, hereby certify that all of the papers that I have served, filed or submitted to the
court in this action are not frivolous as defined in subsection (c) ofSection130-l.1 of the Rules of the Chief
Administrator of the Courts.
\
Dated: August 17, 2022
3 of 3
Preview
FILED: SUFFOLK COUNTY CLERK 08/17/2022 02:12 PM INDEX NO. 616339/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/23/2022 Supreme Court of the State of New York in and for the County of Suffolk, at the Courthouse thereof in Riverhead, New York on the ____ day of ______________, 2022. -----------------------------------------------------------------------------------------x MATTEO RUSSO, AN INFANT OVER THE AGE OF FOURTEEN (14) YEARS, BY HIS MOTHER AND NATURAL GUARDIAN, ROSSANA RUSSO, PETITION Petitioners, Index No. : - against - 616339/2022 VICTOR M. CALCANO AND BARBARA A. CALCANO, Respondents. ------------------------------------------------------------------------------------------x 1. By Affidavit of Petitioner ROSSANA RUSSO, (“Petitioner ROSSANA”), Mother and Natural Guardian of Infant Petitioner, MATTEO RUSSO, (“Infant Petitioner MATTEO”) sworn to the 11th day of August, 2022, the Affidavit of Infant Petitioner, MATTEO, an infant over the age of fourteen (14) years, sworn to the 11th day of August, 2022; an Attorney’s Affirmation of JOHN C. THEOODORELLIS, ESQ. dated the 11th day of August, 2022; a Physician’s Affidavit of JOHN A. GRANT, M.D., dated the 2nd day of August, and proof of the offer of settlement from PROGRESSIVE CASUALTY INSURANCE COMPANY (“PROGRESSIVE”) dated June 22, 2022, Petitioners, by their attorneys, LAW OFFICES OF ARNOLD N. KRISS, hereby submit the within Order for Compromise and respectfully request that said Order be granted by the Court. 2. No previous application has been made for the relief requested. WHEREFORE, Petitioners respectfully request that the Court consent to the Compromise of Infant Petitioner MATTEO’s settlement of his personal injury claim against Respondents, VICTOR M. 1 of 3 FILED: SUFFOLK COUNTY CLERK 08/17/2022 02:12 PM INDEX NO. 616339/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/23/2022 CALCANO AND BARBARA A. CALCANO, together with such other and further relief as the Court deems just proper and equitable. Dated: New York, New York August \ I , 2022 ODORELLIS, ESQ. ffices ofArnold N. Kriss Atto eys for Petitioners Office & P.O. Address 123 William Street, 15th Floor New York, New York 10038 (212) 577-2000 2 of 3 FILED: SUFFOLK COUNTY CLERK 08/17/2022 02:12 PM INDEX NO. 616339/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/23/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK -------------------------------------------------------------------------------x MATTEO RUSSO, AN INFANT OVER THE AGE OF FOURTEEN (14) YEARS, BY HIS MOTHER AND NATURAL GUARDIAN, ROSSANA RUSSO, Index No. Petitioners, - against - VICTOR M. CALCANO AND BARBARA A. CALCANO, Respondents. -------------------------------------------------------------------------------x PETITION Law Offices of Arnold N. Kriss 123 William Street, 15th Floor New York, New York 10038 (212) 577-2000 Counsel for Plaintiff STATE OF NEW YORK ) ss.: COUNTY OF NEW YORK ) CERTIFICATION: I, hereby certify that all of the papers that I have served, filed or submitted to the court in this action are not frivolous as defined in subsection (c) ofSection130-l.1 of the Rules of the Chief Administrator of the Courts. \ Dated: August 17, 2022 3 of 3