Preview
FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023
STATE OF NEW YORK
SUPREME COURT : COUNTY OF ERIE
KERA M. CHILCOTT
8 Cumberland Street
Lancaster, New York 14086,
Plaintiff
SUMMONS
-vs-
ANNIE Y. YU
5567 Via Marina Drive
Williamsville, New York 14221,
YUEJIN E. YU
5567 Via Marina Drive
Williamsville, New York 14221,
Defendants
TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to serve upon the Plaintiffs
attorneys, at their address stated below, an Answer to the attached Complaint.
If this Summons was personally served upon you in the State of New York, the
Answer must be served within twenty (20) days after such service of the Summons,
excluding the date of service. If the Summons was not personally delivered to you within
the State of New York, the Answer must be served within thirty (30) days after service of
the Summons is complete as provided by law.
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If you do nol serve an Answer to the attached Complaint within the applicable
time limitation stated above, a judgment will be entered against you. by default, for the
relief demanded in the Complaint, without further notice to you.
The Plaintiff designates Erie County as the place of trial. The basis of venue is the
residence address of the Plaintiff which is 8 Cumberland Street, Lancaster, New York
14086.
DATED: Buffalo, New York Yours, etc.
June 30, 2023
)
JOHN HOME
John* rop^n, Atto: aw, P.C.
Attorneys for Elartftiff
Office & Post Office Address
4367 Harlem Road
Snyder, New York 14226
(716) 855-1222
-2-
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STATE OF NEW YORK
SUPREME COURT : COUNTY OF ERIE
KERA M. CHILCOTT
Plaintiff
COMPLAINT
-vs-
ANNIE Y. YU,
YUEJIN E. YU
Defendants
The Plaintiff, complaining of the Defendants, by JOFIN J. FROMEN.
ATTORNEYS AT LAW, P.C., her attorneys, alleges:
FIRST: That at all times hereinafter mentioned the Plaintiff was and still is a
resident of the County of Erie and State of New York.
SECOND: That upon information and belief, and at all times hereinafter
mentioned, the Defendant. ANNIE Y. YU (hereinafter referred to as ‘‘A YU"), was a
resident of the County of Erie and State of New York.
THIRD: That upon information and belief, and at all times hereinafter mentioned.
the Defendant, YUEJIN E. YU (hereinafter referred to as “Y YU”), was a resident of the
County of Erie and State of New York.
FOURTH: That on or about the 6th day of July, 2020 the Plaintiff, KERA M.
CHILCOTT, was the registered owner of a certain 2018 Land Rover motor vehicle
bearing New York State registration plate number GRD9752.
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FIFTH: That upon infonnation and belief, at all times hereinafter mentioned, and
on or about the 6th day of July. 2020, the Defendant, Y YU, was a titled owner of a
certain 2015 Subaru motor vehicle bearing New York State registration plate number
CMA2514.
SIXTH: That upon information and belief, at all times hereinafter mentioned, and
on or about the 6th day of July, 2020, the Defendant, A YU, was a titled and registered
owner of a certain 2015 Subaru motor vehicle bearing New York State registration plate
number CMA2514.
SEVENTH: That at all times hereinafter mentioned, and on the 6th day of July,
2020, at approximately 7:35 pm, the Plaintiff was operating the aforementioned motor
vehicle owned by and registered to her in an easterly direction on Wehrle Drive at or near
its intersection with Transit Road in the Town of Clarence, County of Erie and State of
New York.
EIGHTH: That upon infonnation and belief, at all times hereinafter mentioned,
and on or about the 6th day of July, 2020, at approximately 7:35 pm, the Defendant, A
YU, was operating the aforementioned motor vehicle registered to and/or owned by the
Defendants in a northerly direction on 'fransit Road at or near its intersection with
Wehrle Drive in the Town of Clarence, County of Erie and State of New York.
NINTH: That at the time and place aforementioned, the motor vehicle registered
to and/or owned by the Defendants and being operated by the Defendant, A YU, came
-2-
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into collision with and struck the aforesaid motor vehicle owned and being operated by
the Plaintiff.
TENTH: That upon information and belief, and at the time and place
aforementioned the Defendant, A YU, was operating the aforementioned motor vehicle
owned by the Defendant, Y YU, with his permission and consent, express and/or implied.
ELEVENTH: That upon information and belief the Defendants were negligent,
careless and reckless in operating the aforementioned motor vehicle at an excessive rate
of speed; in operating said motor vehicle at an excessive rate of speed in view of the
conditions and circumstances present at the time and place aforementioned; in failing to
keep said motor vehicle under control at all times; in failing to keep a sufficient and
proper lookout; in failing to use reasonable care in controlling the operation and direction
of said motor vehicle; in making an illegal, unlawful and unsafe entry into the aforesaid
intersection; in failing to operate said motor vehicle within the properly designated lane
of traffic; in failing to obey the traffic control devices, signs and/or pavement markings
provided for motor vehicle traffic at or near the scene of this accident; in failing to yield
the right of way; in failing to observe motor vehicle traffic prior to entering the aforesaid
intersection; in entering the subject intersection when said Defendants knew or should
have known that it was unsafe to do so; in failing to stop for a red light; in entering the
subject intersection without warning motorists traveling in an easterly direction on
Wehrle Drive at or near the aforesaid intersection; in failing to observe eastbound traffic
on Wehrle Drive; in failing to observe the Plaintiffs aforementioned motor vehicle on
-3-
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Wehrle Drive at or near its intersection with Transit Road in the manner and condition as
it then and there existed at the time this accident occurred; in failing to take any evasive
action in the operation and direction of said motor vehicle to avoid collision with the
motor vehicle being operated by the Plaintiff; in failing to provide the Plaintiff with any
warning of the approach of said motor vehicle and the proximity of same to that of the
Plaintiffs motor vehicle; in failing to make necessary observations, to take proper
precautions, and/or to give adequate warnings to the Plaintiff; in failing to obey the traffic
control devices which govern the intersection including the red light; in failing to
properly and adequately maintain said motor vehicle while driving the same upon the
highways of the State of New York; in failing to take necessary precautions and/or
actions to avoid collision with the aforementioned motor vehicle being operated by the
Plaintiff; in maintaining and operating said motor vehicle while the same was defective.
unsafe, unfit, in a state of disrepair, and/or lacking the proper, necessary and lawfully
required equipment for the safe operation and use of motor vehicles upon the roadways of
the State of New York; in operating said motor vehicle in such a manner that it
unreasonably interfered with the free and proper use of the public highway or
unreasonably endangered users of the public highway; in operating said motor vehicle
recklessly and without regard for the safety and welfare of other users of the public
highway; in operating said motor vehicle in violation of the Vehicle & Traffic Laws of
the State of New York; and were otherwise negligent, reckless and careless in said
collision and the resulting injuries to the Plaintiff as hereinafter alleged.
-4-
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TWELFTH: That as a result of the negligence, recklessness and carelessness of
the Defendants, the Plaintiff was injured externally, internally and permanently in and
about the head, body, limbs and nervous system so that she became and will continue to
be disabled and will continue to suffer pain, discomfort, disfigurement and distress. That
by reason of the aforesaid injuries said Plaintiff required the services of physicians.
surgeons, nurses, hospitals, therapy, manipulations and medicines and will continue to
incur such expenses in the future; that as a result of the aforesaid injuries and resulting
pennanent disabilities, said Plaintiff has been incapacitated from her educational pursuits,
profession and/or employment and will continue to be incapacitated from her educational
pursuits, profession and/or employment in the future and as a result of the aforesaid
injuries and permanent disabilities the future earning capacity, profession, livelihood and
social and personal endeavors, hobbies and activities of said Plaintiff will be partially
and/or permanently impaired; and as a result of all of the aforesaid the Plaintiff has
otherwise been damaged in a sum which exceeds the jurisdictional limits of all lower
Courts which would otherwise have jurisdiction and as may be awarded by the trier of
facts herein.
THIRTEENTH: That if it be determined that all or any part of the within action
is subject to the provisions of Section 5104(a) of the Insurance Law of the State of New
York, then and in that event, the Plaintiff has sustained a serious injury as defined in
Section 5102(d) of the Insurance Law of the State of New York and has sustained
5-
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economic loss greater than basic economic loss, as defined in Section 5102(a) of the
Insurance Law of the State of New York.
FOURTEENTH: That the limitations on joint and several liability established
under Article 16 of the Civil Practice Laws and Rules of the State of New York do not
apply herein on the grounds that the exceptions enumerated under CPLR Section 1602(6)
and (7) are applicable to the Plaintiffs claims in the within action.
WHEREFORE, Plaintiff demands judgment against the Defendants for a sum
which exceeds the jurisdictional limits of all lower courts which would otherwise have
jurisdiction and as may be awarded by the trier of facts herein, together with the costs and
disbursements of this action and for such other and further relief as to this Court may
seem just and proper.
DATED: Buffalo, New York
June 30, 2023
’Y-
\ JOHN J OMEN, JR., ES'
JohnL Fro] 'n. Attorneys at
Attorneys^ Plaintiff
Office & P( Office ress
4367 Harlem Road
Snyder, New York 14226
(716)855-1222
-6-
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023
STATE OF NEW YORK
SUPREME COURT : COUNTY OF ERIE
KERA M. CHILCOTT,
Plaintiff
-vs-
ANNIE Y. YU.
YUEJIN E. YU,
Defendants
NOTICE OF ELECTRONIC FILING
(Mandatory Case)
(Uniform Rule § 202.5-bb)
You have received this Notice because:
1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New
York State Courts E-filing system (“NYSCEF”), and
2) You are a Defendant/Respondent (a party) in this case.
● If you are represented by an attorney:
Give this Notice to your attorney. (Attorneys: see ‘‘Information for Attorneys” pg. 2).
● If you are not represented bv an attorney:
You will be served with all documents in paper and you must serve and file your
documents in paper, unless you choose to participate in e-filing.
If you choose to participate in e-filing, you must have access to a computer and a
scanner or other device to convert documents into electronic format, a connection to the
internet, and an e-mail address to receive service of documents.
The benefits of participating in e-filing include:
● serving and filing your documents electronically
● free access to view and print your e-filed documents
● limiting your number of trips to the courthouse
● paying any court fees on-line (credit card needed)
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To register for e-filing or for more information about how e-filing works:
● visit: www.nvcourts.gov/efile-unrepresented or
● contact the Clerk’s Office or Help Center at the court where the case was filed. Court
contact information can be found at www.nvcourts.gov
To find legal infomiation to help you represent yourself visit www.nvcourthelp.gov
Information for Attorneys
(E-filing is Mandatory for Attorneys)
An attorney representing a party who is served with this notice must either:
1) immediately record his or her representation within the e-filed matter on the
NYSCEF site www.nvcourts.gov/efile; or
2) file the Notice of Opt-Out form with the clerk of the court where this action is pending
and serve on all parties. Exemptions from mandatory e-filing are limited to attorneys who
certify in good faith that they lack the computer hardware and/or scanner and/or internet
connection or that they lack (along with all employees subject to their direction) the
knowledge to operate such equipment. [Section 202.5-bb(e)]
For additional information about electronic filing and to create a NYSCEF account, visit the
NYSCEF website at www.nvcourts.gov/e-filc or contact the NYSCEF Resource Center (phone:
646-386-3033; email: nyscef@nycourls.gov).
Dated: June 3
716-855-1222
/Signature) (Phone)
John J. From^n, Jr. ^ (Name) 716-855-1239
(Fax)
John J. F/6men, Attorneys at (Firm) iifir@fromenlaw.com (E-mail)
~>563J:farlem Road
(Address)
SnyderNSY 14226
Attorney(s) for Plaintiff
TO; ANNIE Y. YU,
YUEJIN E. YU
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Preview
FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 STATE OF NEW YORK SUPREME COURT : COUNTY OF ERIE KERA M. CHILCOTT 8 Cumberland Street Lancaster, New York 14086, Plaintiff SUMMONS -vs- ANNIE Y. YU 5567 Via Marina Drive Williamsville, New York 14221, YUEJIN E. YU 5567 Via Marina Drive Williamsville, New York 14221, Defendants TO THE ABOVE-NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED and required to serve upon the Plaintiffs attorneys, at their address stated below, an Answer to the attached Complaint. If this Summons was personally served upon you in the State of New York, the Answer must be served within twenty (20) days after such service of the Summons, excluding the date of service. If the Summons was not personally delivered to you within the State of New York, the Answer must be served within thirty (30) days after service of the Summons is complete as provided by law. 1 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 If you do nol serve an Answer to the attached Complaint within the applicable time limitation stated above, a judgment will be entered against you. by default, for the relief demanded in the Complaint, without further notice to you. The Plaintiff designates Erie County as the place of trial. The basis of venue is the residence address of the Plaintiff which is 8 Cumberland Street, Lancaster, New York 14086. DATED: Buffalo, New York Yours, etc. June 30, 2023 ) JOHN HOME John* rop^n, Atto: aw, P.C. Attorneys for Elartftiff Office & Post Office Address 4367 Harlem Road Snyder, New York 14226 (716) 855-1222 -2- 2 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 STATE OF NEW YORK SUPREME COURT : COUNTY OF ERIE KERA M. CHILCOTT Plaintiff COMPLAINT -vs- ANNIE Y. YU, YUEJIN E. YU Defendants The Plaintiff, complaining of the Defendants, by JOFIN J. FROMEN. ATTORNEYS AT LAW, P.C., her attorneys, alleges: FIRST: That at all times hereinafter mentioned the Plaintiff was and still is a resident of the County of Erie and State of New York. SECOND: That upon information and belief, and at all times hereinafter mentioned, the Defendant. ANNIE Y. YU (hereinafter referred to as ‘‘A YU"), was a resident of the County of Erie and State of New York. THIRD: That upon information and belief, and at all times hereinafter mentioned. the Defendant, YUEJIN E. YU (hereinafter referred to as “Y YU”), was a resident of the County of Erie and State of New York. FOURTH: That on or about the 6th day of July, 2020 the Plaintiff, KERA M. CHILCOTT, was the registered owner of a certain 2018 Land Rover motor vehicle bearing New York State registration plate number GRD9752. 3 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 FIFTH: That upon infonnation and belief, at all times hereinafter mentioned, and on or about the 6th day of July. 2020, the Defendant, Y YU, was a titled owner of a certain 2015 Subaru motor vehicle bearing New York State registration plate number CMA2514. SIXTH: That upon information and belief, at all times hereinafter mentioned, and on or about the 6th day of July, 2020, the Defendant, A YU, was a titled and registered owner of a certain 2015 Subaru motor vehicle bearing New York State registration plate number CMA2514. SEVENTH: That at all times hereinafter mentioned, and on the 6th day of July, 2020, at approximately 7:35 pm, the Plaintiff was operating the aforementioned motor vehicle owned by and registered to her in an easterly direction on Wehrle Drive at or near its intersection with Transit Road in the Town of Clarence, County of Erie and State of New York. EIGHTH: That upon infonnation and belief, at all times hereinafter mentioned, and on or about the 6th day of July, 2020, at approximately 7:35 pm, the Defendant, A YU, was operating the aforementioned motor vehicle registered to and/or owned by the Defendants in a northerly direction on 'fransit Road at or near its intersection with Wehrle Drive in the Town of Clarence, County of Erie and State of New York. NINTH: That at the time and place aforementioned, the motor vehicle registered to and/or owned by the Defendants and being operated by the Defendant, A YU, came -2- 4 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 into collision with and struck the aforesaid motor vehicle owned and being operated by the Plaintiff. TENTH: That upon information and belief, and at the time and place aforementioned the Defendant, A YU, was operating the aforementioned motor vehicle owned by the Defendant, Y YU, with his permission and consent, express and/or implied. ELEVENTH: That upon information and belief the Defendants were negligent, careless and reckless in operating the aforementioned motor vehicle at an excessive rate of speed; in operating said motor vehicle at an excessive rate of speed in view of the conditions and circumstances present at the time and place aforementioned; in failing to keep said motor vehicle under control at all times; in failing to keep a sufficient and proper lookout; in failing to use reasonable care in controlling the operation and direction of said motor vehicle; in making an illegal, unlawful and unsafe entry into the aforesaid intersection; in failing to operate said motor vehicle within the properly designated lane of traffic; in failing to obey the traffic control devices, signs and/or pavement markings provided for motor vehicle traffic at or near the scene of this accident; in failing to yield the right of way; in failing to observe motor vehicle traffic prior to entering the aforesaid intersection; in entering the subject intersection when said Defendants knew or should have known that it was unsafe to do so; in failing to stop for a red light; in entering the subject intersection without warning motorists traveling in an easterly direction on Wehrle Drive at or near the aforesaid intersection; in failing to observe eastbound traffic on Wehrle Drive; in failing to observe the Plaintiffs aforementioned motor vehicle on -3- 5 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 Wehrle Drive at or near its intersection with Transit Road in the manner and condition as it then and there existed at the time this accident occurred; in failing to take any evasive action in the operation and direction of said motor vehicle to avoid collision with the motor vehicle being operated by the Plaintiff; in failing to provide the Plaintiff with any warning of the approach of said motor vehicle and the proximity of same to that of the Plaintiffs motor vehicle; in failing to make necessary observations, to take proper precautions, and/or to give adequate warnings to the Plaintiff; in failing to obey the traffic control devices which govern the intersection including the red light; in failing to properly and adequately maintain said motor vehicle while driving the same upon the highways of the State of New York; in failing to take necessary precautions and/or actions to avoid collision with the aforementioned motor vehicle being operated by the Plaintiff; in maintaining and operating said motor vehicle while the same was defective. unsafe, unfit, in a state of disrepair, and/or lacking the proper, necessary and lawfully required equipment for the safe operation and use of motor vehicles upon the roadways of the State of New York; in operating said motor vehicle in such a manner that it unreasonably interfered with the free and proper use of the public highway or unreasonably endangered users of the public highway; in operating said motor vehicle recklessly and without regard for the safety and welfare of other users of the public highway; in operating said motor vehicle in violation of the Vehicle & Traffic Laws of the State of New York; and were otherwise negligent, reckless and careless in said collision and the resulting injuries to the Plaintiff as hereinafter alleged. -4- 6 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 TWELFTH: That as a result of the negligence, recklessness and carelessness of the Defendants, the Plaintiff was injured externally, internally and permanently in and about the head, body, limbs and nervous system so that she became and will continue to be disabled and will continue to suffer pain, discomfort, disfigurement and distress. That by reason of the aforesaid injuries said Plaintiff required the services of physicians. surgeons, nurses, hospitals, therapy, manipulations and medicines and will continue to incur such expenses in the future; that as a result of the aforesaid injuries and resulting pennanent disabilities, said Plaintiff has been incapacitated from her educational pursuits, profession and/or employment and will continue to be incapacitated from her educational pursuits, profession and/or employment in the future and as a result of the aforesaid injuries and permanent disabilities the future earning capacity, profession, livelihood and social and personal endeavors, hobbies and activities of said Plaintiff will be partially and/or permanently impaired; and as a result of all of the aforesaid the Plaintiff has otherwise been damaged in a sum which exceeds the jurisdictional limits of all lower Courts which would otherwise have jurisdiction and as may be awarded by the trier of facts herein. THIRTEENTH: That if it be determined that all or any part of the within action is subject to the provisions of Section 5104(a) of the Insurance Law of the State of New York, then and in that event, the Plaintiff has sustained a serious injury as defined in Section 5102(d) of the Insurance Law of the State of New York and has sustained 5- 7 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 economic loss greater than basic economic loss, as defined in Section 5102(a) of the Insurance Law of the State of New York. FOURTEENTH: That the limitations on joint and several liability established under Article 16 of the Civil Practice Laws and Rules of the State of New York do not apply herein on the grounds that the exceptions enumerated under CPLR Section 1602(6) and (7) are applicable to the Plaintiffs claims in the within action. WHEREFORE, Plaintiff demands judgment against the Defendants for a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction and as may be awarded by the trier of facts herein, together with the costs and disbursements of this action and for such other and further relief as to this Court may seem just and proper. DATED: Buffalo, New York June 30, 2023 ’Y- \ JOHN J OMEN, JR., ES' JohnL Fro] 'n. Attorneys at Attorneys^ Plaintiff Office & P( Office ress 4367 Harlem Road Snyder, New York 14226 (716)855-1222 -6- 8 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 STATE OF NEW YORK SUPREME COURT : COUNTY OF ERIE KERA M. CHILCOTT, Plaintiff -vs- ANNIE Y. YU. YUEJIN E. YU, Defendants NOTICE OF ELECTRONIC FILING (Mandatory Case) (Uniform Rule § 202.5-bb) You have received this Notice because: 1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New York State Courts E-filing system (“NYSCEF”), and 2) You are a Defendant/Respondent (a party) in this case. ● If you are represented by an attorney: Give this Notice to your attorney. (Attorneys: see ‘‘Information for Attorneys” pg. 2). ● If you are not represented bv an attorney: You will be served with all documents in paper and you must serve and file your documents in paper, unless you choose to participate in e-filing. If you choose to participate in e-filing, you must have access to a computer and a scanner or other device to convert documents into electronic format, a connection to the internet, and an e-mail address to receive service of documents. The benefits of participating in e-filing include: ● serving and filing your documents electronically ● free access to view and print your e-filed documents ● limiting your number of trips to the courthouse ● paying any court fees on-line (credit card needed) 9 of 10 FILED: ERIE COUNTY CLERK 07/05/2023 07:18 AM INDEX NO. 808218/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/05/2023 To register for e-filing or for more information about how e-filing works: ● visit: www.nvcourts.gov/efile-unrepresented or ● contact the Clerk’s Office or Help Center at the court where the case was filed. Court contact information can be found at www.nvcourts.gov To find legal infomiation to help you represent yourself visit www.nvcourthelp.gov Information for Attorneys (E-filing is Mandatory for Attorneys) An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site www.nvcourts.gov/efile; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending and serve on all parties. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)] For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nvcourts.gov/e-filc or contact the NYSCEF Resource Center (phone: 646-386-3033; email: nyscef@nycourls.gov). Dated: June 3 716-855-1222 /Signature) (Phone) John J. From^n, Jr. ^ (Name) 716-855-1239 (Fax) John J. F/6men, Attorneys at (Firm) iifir@fromenlaw.com (E-mail) ~>563J:farlem Road (Address) SnyderNSY 14226 Attorney(s) for Plaintiff TO; ANNIE Y. YU, YUEJIN E. YU 10 of 10