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HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 1 of 13 Trans ID: LCV20221930528
VERONICA R. MEDINA, ESQ.
N.J. Attorney ID: 334852021
THE WEISS GROUP, LLC
ATTORNEYS AT LAW
344 Main Street, P.O. Box 311
Metuchen, New Jersey 08840
Phone: (732)-549-2515
Fax: (732)-549-9520
Attorneys for Plaintiff(s)
VALENTINA GRIGORYEVA, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: HUDSON COUNTY
Plaintiff, DOCKET NUMBER: HUD-L-________
-v- Civil Action
FANTICY ACRES, KATRINA
DRAZDOVA, VICTOR a/k/a JOHN DOE 1, COMPLAINT AND JURY DEMAND
CRYSTAL SIMICSAK, CRYSTAL L.
SIMICSAK, JOSEPH SIMICSAK, KAREN
SIMICSAK, KAREN J. SIMICSAK, JOHN
DOES 2-40, AND ABC CORPORATIONS
1-35
Defendants.
Plaintiff Valentina Grigoryeva, residing at 3163 J.F.K. Blvd., Apt. 3, Jersey City, New
Jersey 07306, by way of Complaint against the defendants, says:
COUNT ONE
DEFENDANTS FANTICY ACRES AND KATRINA DRAZDOVA
1. On May 24, 2020, plaintiff Valentina Grigoryeva was lawfully on the premises of
defendant, Fanticy Acres that is located at 27312 Mt. Pleasant Road, Columbus, New
Jersey, as a business invitee after being invited by defendant, Katrina Drazdova, for the
purpose of taking a horseback riding lesson.
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2. At the time and place aforesaid, defendant, Katrina Drazdova, was an employee, agent,
servant, and/or representative of defendant, Fanticy Acres, who acted within the scope
of her employment/authority for all things related to the horseback riding lesson.
3. At the time and place aforesaid, defendant Fanticy Acres was an “operator” of an area
where individuals engage in “equine animal activities” as those terms are defined in
N.J.S.A. 5:15-2.
4. At the time and place aforesaid, defendant Katrina Drazdova was an individual acting
on behalf defendant Fanticy Acres for all or part of such equine animal activities as
aforesaid.
5. At the time and place aforesaid, Plaintiff was a “participant” in equine animal activities
at Fanticy Acres as that term is defined at N.J.S.A. 5:15-2.
6. At the time and place aforesaid, Plaintiff was a beginner level horseback rider, a fact
made known to defendants Katrina Drazdova and Fanticy Acres prior to commencement
of equine animal activity.
7. At the time and place aforesaid, defendant Katrina Drazdova knew or should have
known Plaintiff’s status as a beginner level horseback rider.
8. At the time and place aforesaid, Plaintiff conducted herself within the limits of her
horseback riding ability to maintain control of the equine animal, and refrained from
acting in a manner which may cause or contribute to injury to herself or to others or loss
or damage to person or property, or death.
9. At the time and place aforesaid, defendants Fanticy Acres and Katrina Drazdova owed
to Plaintiff duties pursuant to N.J.S.A. § 5:15-9(b) to make reasonable and prudent
efforts to determine the Plaintiff’s ability to safely manage the specific equine animal.
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10. At the time and place aforesaid, defendants Fanticy Acres and Katrina Drazdova,
knowingly, negligently, carelessly, and/or recklessly provided faulty equipment or tack,
including but not limited to a specific equine animal, which contributed to severe and
permanent bodily injuries later suffered by Plaintiff.
11. At the time and place aforesaid, the defendants, Fanticy Acres and Katrina Drazdova
were negligent and careless in creating a dangerous condition or situation by failing to
give reasonable, prudent, and proper warnings to plaintiff, Valentina Grigoryeva, which
proximately caused said plaintiff’s fall at the premises and suffer severe and permanent
bodily injury.
12. At the time and place aforesaid, the defendants, Fanticy Acres and Katrina Drazdova
committed acts or omissions constituting negligent disregard for Plaintiff’s safety,
which acts and/or omissions caused Plaintiff to suffer severe and permanent bodily
injury.
13. At the time and place aforesaid, defendants Fanticy Acres and Katrina Drazdova owed
duties pursuant to N.J.S.A. § 5:15-9(a) not to knowingly provide equipment or tack that
is faulty so that it does not proximately cause or contribute to injury when permitting
plaintiff, Valentina Grigoryeva, to participate in the horseback riding activity.
14. At the time and place aforesaid, defendant Katrina Drazdova, knowingly provided
equipment or tack that is faulty to the extent that it caused or contributed to plaintiff,
Valentina Grigoryeva’s injury.
15. As a direct and proximate result of the combined aforesaid acts and/or omissions,
negligence, carelessness, and/or recklessness of defendants Fanticy Acres and Katrina
Drazdova, plaintiff Valentina Grigoryeva suffered serious and permanent injuries or
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conditions and/or aggravations, exacerbations and/or accelerations of pre-existing
injuries or conditions which necessitated Plaintiff to obtain medical treatment, caused
her great pain and suffering, incapacitated her from pursuing her usual activities and
have left her with permanent disabilities that will in the future incapacitate her, causing
her great pain and suffering and to require medical treatment in the past, present and
future, caused her to incur medical expenses in an effort to cure herself of her injuries,
and has suffered economic loss and other damages.
WHEREFORE, plaintiff Valentina Grigoryeva demands judgment on this Count against
the defendants, Fanticy Acres and Katrina Drazdova jointly and/or severally and/or vicariously
for damages, costs, interest, counsel fees and all other relief this court deems just.
COUNT TWO
DEFENDANTS FANTICY ACRES AND VICTOR a/k/a JOHN DOE 1
16. Plaintiff Valentina Grigoryeva repeats and realleges each and every allegation of Count
One of this Complaint as if fully set forth herein at length.
17. At the time and place aforesaid, “Victor” (last name unknown) also known as “John Doe
1” was an employee, agent, servant and/or representative of defendant, Fanticy Acres
who acted within the scope of his employment/authority for all things related to the
horseback riding lesson being provided to Plaintiff.
18. At the time and place aforesaid, defendant Victor a/k/a John Doe 1 was an individual
acting on behalf defendant Fanticy Acres for all or part of such equine animal activities
as aforesaid.
19. At the time and place aforesaid, defendant Victor a/k/a John Doe 1 knew or should have
known Plaintiff’s status as a beginner level horseback rider.
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20. At the time and place aforesaid, defendants Fanticy Acres and Katrina Drazdova and
Victor a/k/a John Doe 1 owed to Plaintiff duties pursuant to N.J.S.A. § 5:15-9(b) to make
reasonable and prudent efforts to determine the Plaintiff’s ability to safely manage the
specific equine animal.
21. At the time and place aforesaid, defendants Fanticy Acres, Katrina Drazdova, and Victor
a/k/a John Doe 1 knowingly, negligently, carelessly, and/or recklessly provided faulty
equipment or tack, including but not limited to a specific equine animal, which
contributed to severe and permanent bodily injuries later suffered by Plaintiff.
22. At the time and place aforesaid, the defendants, Fanticy Acres, Katrina Drazdova and
Victor a/k/a John Doe 1 were negligent and careless in creating a dangerous condition
or situation by failing to give reasonable, prudent, and proper warnings to plaintiff,
Valentina Grigoryeva, which proximately caused said plaintiff’s fall at the premises and
suffer severe and permanent bodily injury.
23. At the time and place aforesaid, the defendants, Fanticy Acres, Katrina Drazdova, and
Victor a/k/a John Doe 1 committed acts or omissions constituting negligent disregard
for Plaintiff’s safety, which acts and/or omissions caused Plaintiff to suffer severe and
permanent bodily injury.
24. At the time and place aforesaid, defendants Fanticy Acres, Katrina Drazdova, and Victor
a/k/a John Doe 1 owed duties pursuant to N.J.S.A. § 5:15-9(a) not to knowingly provide
equipment or tack that is faulty so that it does not proximately cause or contribute to
injury when permitting plaintiff, Valentina Grigoryeva, to participate in the horseback
riding activity.
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25. At the time and place aforesaid, defendant Victor a/k/a John Doe 1, knowingly provided
equipment or tack that is faulty to the extent that it caused or contributed to plaintiff,
Valentina Grigoryeva’s injury.
26. As a direct and proximate result of the combined aforesaid acts and/or omissions,
negligence, carelessness, and/or recklessness of defendants Fanticy Acres, Katrina
Drazdova, and Victor a/k/a John Doe 1, Plaintiff suffered severe and permanent injuries
or conditions and/or aggravations, exacerbations and/or accelerations of pre-existing
injuries or conditions which necessitated Plaintiff to obtain medical treatment, caused
her great pain and suffering, incapacitated her from pursuing her usual activities and
have left her with permanent disabilities that will in the future incapacitate her, causing
her great pain and suffering and to require medical treatment in the past, present and
future, caused her to incur medical expenses in an effort to cure herself of her injuries,
and has suffered economic loss and other damages.
WHEREFORE, plaintiff Valentina Grigoryeva demands judgment on this Count against
the defendants Fanticy Acres, Katrina Drazdova, and Victor a/k/a John Doe 1 jointly and/or
severally and/or vicariously for damages, costs, interest, counsel fees.
COUNT THREE
RESPONDEAT SUPERIOR
27. Plaintiff, Valentina Grigoryeva repeats and realleges each and every allegation of
Counts One and Two of this Complaint as if fully set forth herein at length.
28. At the time and place aforesaid, defendants Katrina Drazdova and Victor a/k/a John Doe
1, were the agents, servants, representatives, and/or employees of Fanticy Acres, John
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Does 2-5 (owners of Fanticy Acres, true names unknown) and/or ABC Corporations 1-
20 (corporate owners of Fanticy Acres, true names unknown).
29. Defendants Fanticy Acres, John Does 2-5 and ABC Corporations 1-20 are liable for the
negligence of defendants, Katrina Drazdova and Victor a/k/a John Doe 1 by virtue of
the doctrine of respondeat superior.
30. At the time and place aforesaid, defendants Fanticy Acres, John Does 2-5 and ABC
Corporations 1-20 had a duty to train employees, servants, representatives, agents and/or
licensees to conform with the duties pursuant to N.J.S.A. § 5:15-9(b), which was to make
a reasonable and prudent effort to determine the plaintiff, Valentina Grigoryeva’s ability
to safely manage the particular equine animal, based on said plaintiff’s representation
of her horseback riding ability.
31. At the time and place aforesaid, defendants, Fanticy Acres, John Does 2-5 and ABC
Corporations 1-20 had a duty to train employees to conform with the duties pursuant to
N.J.S.A. § 5:15-9(a) not to knowingly provide faulty equipment or tack so that it does
not cause or contribute to injury of plaintiff, Valentina Grigoryeva, while participating
in the horseback riding activity.
32. At the time and place aforesaid, defendants Fanticy Acres, John Does 2-5 and ABC
Corporations 1-20 had employees, agents, servants and/or representatives who
knowingly provided faulty equipment or tack which caused or contributed to plaintiff,
Valentina Grigoryeva’s injury.
33. As a direct and proximate result of the combined negligence, carelessness, and
recklessness of defendants Fanticy Acres, Katrina Drazdova, John Doe 1, known as
“Victor” (last name unknown), and ABC Corporations 1-20 as aforesaid, plaintiff
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Valentina Grigoryeva suffered serious and permanent injuries and/or conditions and/or
aggravations, exacerbations and/or accelerations of pre-existing injuries or conditions
which necessitated her to obtain medical treatment, caused her great pain and suffering,
incapacitated her from pursuing her usual activities and have left her with permanent
disabilities that will in the future incapacitate her, causing her great pain and suffering
and to require medical treatment in the past, present and future, caused her to incur
medical expenses in an effort to cure herself of her injuries, and has suffered economic
loss and other damages.
WHEREFORE, plaintiff Valentina Grigoryeva, demands judgment on this Count against
the defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, and
ABC Corporations 1-20, jointly and/or severally and/or vicariously for damages, costs, interest,
counsel fees.
COUNT FOUR
MAINTENANCE OF PREMESIS AND EQUIPMENT
34. Plaintiff, Valentina Grigoryeva repeats and realleges each and every allegation of
Counts One, Two, and Three as if fully set forth herein at length.
35. At the time and place aforesaid, ABC Corporations 21-30 and John Does 6-30 were
owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds
keepers, tasked with maintaining the premises of Fanticy Acres.
36. At the time and place aforesaid, defendants Fanticy Acres, Katrina Drazdova, Victor
a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-20, ABC Corporations 21-30
(fictitious names for owners, lessors, sublessors, employees, contractors, and/or
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landscapers and/or grounds keepers, actual names unknown), and John Does 6-30
(fictitious names for owners, lessors, sublessors, employees, contractors, and/or
landscapers and/or grounds keepers, actual names unknown) owed duties pursuant to
N.J.S.A. § 5:15-9(d), and were expected to have made reasonable and prudent efforts
for the participant’s safety, including but not limited to the maintenance of the premises
and of equipment.
37. At the time and place aforesaid, defendants, Fanticy Acres, Katrina Drazdova, Victor
a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-20, ABC Corporations 21-30
(fictitious names for owners, lessors, sublessors, employees, contractors, and/or
landscapers and/or grounds keepers, actual names unknown), and John Does 6-30
(fictitious names for owners, lessors, sublessors, employees, contractors, and/or
landscapers and/or grounds keepers, actual names unknown) owed duties pursuant to
N.J.S.A. § 5:15-9(a) not to knowingly provide faulty equipment or tack that is unsafe to
the extent that it causes or contributes to injury when permitting plaintiff, Valentina
Grigoryeva, to participate in horseback riding.
38. At the time and place aforesaid, defendants Fanticy Acres, Katrina Drazdova, Victor
a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-20, ABC Corporations 21-30
(fictitious names for owners, lessors, sublessors, employees, contractors, and/or
landscapers and/or grounds keepers, actual names unknown), and John Does 6-30
(fictitious names for owners, lessors, sublessors, employees, contractors, and/or
landscapers and/or grounds keepers, actual names unknown) knowingly provided
equipment or tack that is faulty to the extent that it caused or contributed to plaintiff,
Valentina Grigoryeva’s injury.
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39. As a direct and proximate result of the combined negligence, carelessness, and
recklessness of defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1,
John Does 2-5, ABC Corporations 1-20, ABC Corporations 21-30 (fictitious names for
owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds
keepers, actual names unknown), and John Does 6-30 (fictitious names for owners,
lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers,
actual names unknown), plaintiff Valentina Grigoryeva suffered serious and permanent
injuries and/or conditions and/or aggravations, exacerbations and/or accelerations of
pre-existing injuries and/or conditions which necessitated her to obtain medical
treatment, caused her great pain and suffering, incapacitated her from pursuing her usual
activities and have left her with permanent disabilities that will in the future incapacitate
her, causing her great pain and suffering and to require medical treatment in the past,
present and future, caused her to incur medical expenses in an effort to cure herself of
her injuries, and has suffered economic loss and other damages.
WHEREFORE, Plaintiff Valentina Grigoryeva demands judgment against the
defendants, on this Count against the defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a
John Doe 1, John Does 2-5, ABC Corporations 1-30, and John Does 6-30 jointly and/or
severally and/or vicariously for damages, costs, interest, counsel fees and all other relief this
court deems just.
COUNT FIVE
LIABILITY OF INDIVIDUAL PARTNERS OF FANTICY ACRES PURSUANT
TO N.J.S.A. 42:1A-18(a)
40. Plaintiff, Valentina Grigoryeva repeats and realleges each and every allegation of
Counts One, Two, Three and Four as if fully set forth herein at length.
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41. At all times relevant hereto, Fanticy Acres was a partnership as that term is defined at
N.J.S.A. 42:1A-2.
42. At all times relevant hereto, the following persons were partners of Fanticy Acres: a)
Crystal Simicsak; b) Crystal L. Simicsak; c) Joseph Simicsak; d) Karen Simicsak; and
e) Karen J. Simicsak; and f) John Does 31-35 (fictitious names of partners of Fanticy
Acres whose true names are currently unknown).
43. Pursuant to N.J.S.A. 42:1A-18(a), the partners of Fanticy Acres are jointly and severally
liable for the obligations of Fanticy Acres including but not limited to debt incurred for
liability to Plaintiff Valentina Grigoryeva.
WHEREFORE, Plaintiff Valentina Grigoryeva demands judgment on this Count against the
defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, ABC
Corporations 1-30, and John Does 6-30, Crystal Simicsak, Crystal L. Simicsak, Joseph
Simicsak, Karen Simicsak, Karen J. Simicsak, and John Does 31-35 jointly and/or severally
and/or vicariously for damages, costs, interest, and counsel fees.
COUNT SIX
LIABILITY OF OWNER OF HORSE
44. Plaintiff, Valentina Grigoryeva repeats and realleges each and every allegation of
Counts One, Two, Three, Four and Five as if fully set forth herein at length.
45. At all times relevant hereto, defendants John Does 36-40 (fictitious names of individuals
who, on May 24, 2020, owned the horse from which Plaintiff fell, true names unknown)
and/or ABC Corporations 31-35 (fictitious names of business entities who, as of May
24, 2020, owned the horse from which Plaintiff fell, true names unknown) were the
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owners of the horse provided to Plaintiff by defendants Fanticy Acres, Katrina Drazdova
and/or Victor a/k/a John Doe 1 for purposes of horseback riding instruction.
46. At the time and place aforesaid, defendants John Does 36-40 and ABC Corporations 31-
35 owed duties pursuant to N.J.S.A. § 5:15-9(a) not to provide equipment or tack that is
unsafe to the extent that it does not cause or contribute to injury when permitting
plaintiff, Valentina Grigoryeva, to participate in the horseback riding activity.
47. At the time and place aforesaid, defendants John Does 36-40 and ABC Corporations 31-
35 owed duties pursuant to N.J.S.A. § 5:15-9(d), and were required to have made
reasonable and prudent efforts for the Plaintiff’s safety.
48. At the time and place aforesaid, defendants John Does 36-40 and ABC Corporations 31-
35 knowingly provided equipment or tack that is faulty to the extent that it caused or
contributed to plaintiff, Valentina Grigoryeva’s injury.
49. As a direct and proximate result of the combined negligence, carelessness, and
recklessness of defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1,
John Does 2-5, John Does 6-40, ABC Corporations 1-35, Crystal Simicsak, Crystal L.
Simicsak, Joseph Simicsak, Karen Simicsak, and Karen J. Simicsak, Plaintiff Valentina
Grigoryeva suffered serious and permanent injuries and/or conditions and/or
aggravations, exacerbations and/or accelerations of pre-existing injuries and/or
conditions which necessitated her to obtain medical treatment, caused her great pain and
suffering, incapacitated her from pursuing her usual activities and have left her with
permanent disabilities that will in the future incapacitate her, causing her great pain and
suffering and to require medical treatment in the past, present and future, caused her to
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incur medical expenses in an effort to cure herself of her injuries, and has suffered
economic loss and other damages.
JURY DEMAND
Pursuant to R. 4:35-1 of the New Jersey Court Rules, Plaintiff hereby demands a jury trial
on all issues so triable.
NOTICE OF DESIGNATION OF TRIAL COUNSEL
Plaintiff hereby designates Leonard D. Weiss Esq. as Trial Counsel.
DEMAND FOR ANSWERS TO INTERROGATORIES
PLEASE TAKE NOTICE that plaintiff demands answers to Form C and C(2)
interrogatories within 60 days after service of the within pleadings.
DEMAND FOR INSURANCE INFORMATION
Please provide all insurance agreements or policies under which any person or firm
carrying an insurance business may be liable to satisfy part or all of a judgment which may be
entered in this action or to indemnify or reimburse for payments made to satisfy judgment pursuant
to R. 4:10-2(b).
THE WEISS GROUP, LLC
By: /s/Veronica R. Medina, Esq.
DATED: May 17, 2022 Veronica R. Medina, Esq.
THE WEISS GROUP, LLC
Attorneys at Law
344 Main Street, P.O. Box 311
Metuchen, NJ 08840
(732)-549-2515
Fax (732)-549-9520
vm@weisslawyersnj.com
Attorneys for Plaintiff, Valentina Grigoryeva
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Civil Case Information Statement
Case Details: HUDSON | Civil Part Docket# L-001625-22
Case Caption: GRIGORYEVA VALENTINA VS FANTICY Case Type: PERSONAL INJURY
ACRES Document Type: Complaint with Jury Demand
Case Initiation Date: 05/17/2022 Jury Demand: YES - 6 JURORS
Attorney Name: VERONICA R MEDINA Is this a professional malpractice case? NO
Firm Name: WEISS GROUP LLC Related cases pending: NO
Address: 344 MAIN STREET P.O. BOX 311 If yes, list docket numbers:
METUCHEN NJ 08840 Do you anticipate adding any parties (arising out of same
Phone: 7325492515 transaction or occurrence)? NO
Name of Party: PLAINTIFF : Grigoryeva, Valentina Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): None Are sexual abuse claims alleged by: Valentina Grigoryeva? NO
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? NO
If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO
If yes, please identify the requested accommodation:
Will an interpreter be needed? NO
If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
05/17/2022 /s/ VERONICA R MEDINA
Dated Signed
Preview
HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 1 of 13 Trans ID: LCV20221930528 VERONICA R. MEDINA, ESQ. N.J. Attorney ID: 334852021 THE WEISS GROUP, LLC ATTORNEYS AT LAW 344 Main Street, P.O. Box 311 Metuchen, New Jersey 08840 Phone: (732)-549-2515 Fax: (732)-549-9520 Attorneys for Plaintiff(s) VALENTINA GRIGORYEVA, SUPERIOR COURT OF NEW JERSEY LAW DIVISION: HUDSON COUNTY Plaintiff, DOCKET NUMBER: HUD-L-________ -v- Civil Action FANTICY ACRES, KATRINA DRAZDOVA, VICTOR a/k/a JOHN DOE 1, COMPLAINT AND JURY DEMAND CRYSTAL SIMICSAK, CRYSTAL L. SIMICSAK, JOSEPH SIMICSAK, KAREN SIMICSAK, KAREN J. SIMICSAK, JOHN DOES 2-40, AND ABC CORPORATIONS 1-35 Defendants. Plaintiff Valentina Grigoryeva, residing at 3163 J.F.K. Blvd., Apt. 3, Jersey City, New Jersey 07306, by way of Complaint against the defendants, says: COUNT ONE DEFENDANTS FANTICY ACRES AND KATRINA DRAZDOVA 1. On May 24, 2020, plaintiff Valentina Grigoryeva was lawfully on the premises of defendant, Fanticy Acres that is located at 27312 Mt. Pleasant Road, Columbus, New Jersey, as a business invitee after being invited by defendant, Katrina Drazdova, for the purpose of taking a horseback riding lesson. Page 1 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 2 of 13 Trans ID: LCV20221930528 2. At the time and place aforesaid, defendant, Katrina Drazdova, was an employee, agent, servant, and/or representative of defendant, Fanticy Acres, who acted within the scope of her employment/authority for all things related to the horseback riding lesson. 3. At the time and place aforesaid, defendant Fanticy Acres was an “operator” of an area where individuals engage in “equine animal activities” as those terms are defined in N.J.S.A. 5:15-2. 4. At the time and place aforesaid, defendant Katrina Drazdova was an individual acting on behalf defendant Fanticy Acres for all or part of such equine animal activities as aforesaid. 5. At the time and place aforesaid, Plaintiff was a “participant” in equine animal activities at Fanticy Acres as that term is defined at N.J.S.A. 5:15-2. 6. At the time and place aforesaid, Plaintiff was a beginner level horseback rider, a fact made known to defendants Katrina Drazdova and Fanticy Acres prior to commencement of equine animal activity. 7. At the time and place aforesaid, defendant Katrina Drazdova knew or should have known Plaintiff’s status as a beginner level horseback rider. 8. At the time and place aforesaid, Plaintiff conducted herself within the limits of her horseback riding ability to maintain control of the equine animal, and refrained from acting in a manner which may cause or contribute to injury to herself or to others or loss or damage to person or property, or death. 9. At the time and place aforesaid, defendants Fanticy Acres and Katrina Drazdova owed to Plaintiff duties pursuant to N.J.S.A. § 5:15-9(b) to make reasonable and prudent efforts to determine the Plaintiff’s ability to safely manage the specific equine animal. Page 2 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 3 of 13 Trans ID: LCV20221930528 10. At the time and place aforesaid, defendants Fanticy Acres and Katrina Drazdova, knowingly, negligently, carelessly, and/or recklessly provided faulty equipment or tack, including but not limited to a specific equine animal, which contributed to severe and permanent bodily injuries later suffered by Plaintiff. 11. At the time and place aforesaid, the defendants, Fanticy Acres and Katrina Drazdova were negligent and careless in creating a dangerous condition or situation by failing to give reasonable, prudent, and proper warnings to plaintiff, Valentina Grigoryeva, which proximately caused said plaintiff’s fall at the premises and suffer severe and permanent bodily injury. 12. At the time and place aforesaid, the defendants, Fanticy Acres and Katrina Drazdova committed acts or omissions constituting negligent disregard for Plaintiff’s safety, which acts and/or omissions caused Plaintiff to suffer severe and permanent bodily injury. 13. At the time and place aforesaid, defendants Fanticy Acres and Katrina Drazdova owed duties pursuant to N.J.S.A. § 5:15-9(a) not to knowingly provide equipment or tack that is faulty so that it does not proximately cause or contribute to injury when permitting plaintiff, Valentina Grigoryeva, to participate in the horseback riding activity. 14. At the time and place aforesaid, defendant Katrina Drazdova, knowingly provided equipment or tack that is faulty to the extent that it caused or contributed to plaintiff, Valentina Grigoryeva’s injury. 15. As a direct and proximate result of the combined aforesaid acts and/or omissions, negligence, carelessness, and/or recklessness of defendants Fanticy Acres and Katrina Drazdova, plaintiff Valentina Grigoryeva suffered serious and permanent injuries or Page 3 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 4 of 13 Trans ID: LCV20221930528 conditions and/or aggravations, exacerbations and/or accelerations of pre-existing injuries or conditions which necessitated Plaintiff to obtain medical treatment, caused her great pain and suffering, incapacitated her from pursuing her usual activities and have left her with permanent disabilities that will in the future incapacitate her, causing her great pain and suffering and to require medical treatment in the past, present and future, caused her to incur medical expenses in an effort to cure herself of her injuries, and has suffered economic loss and other damages. WHEREFORE, plaintiff Valentina Grigoryeva demands judgment on this Count against the defendants, Fanticy Acres and Katrina Drazdova jointly and/or severally and/or vicariously for damages, costs, interest, counsel fees and all other relief this court deems just. COUNT TWO DEFENDANTS FANTICY ACRES AND VICTOR a/k/a JOHN DOE 1 16. Plaintiff Valentina Grigoryeva repeats and realleges each and every allegation of Count One of this Complaint as if fully set forth herein at length. 17. At the time and place aforesaid, “Victor” (last name unknown) also known as “John Doe 1” was an employee, agent, servant and/or representative of defendant, Fanticy Acres who acted within the scope of his employment/authority for all things related to the horseback riding lesson being provided to Plaintiff. 18. At the time and place aforesaid, defendant Victor a/k/a John Doe 1 was an individual acting on behalf defendant Fanticy Acres for all or part of such equine animal activities as aforesaid. 19. At the time and place aforesaid, defendant Victor a/k/a John Doe 1 knew or should have known Plaintiff’s status as a beginner level horseback rider. Page 4 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 5 of 13 Trans ID: LCV20221930528 20. At the time and place aforesaid, defendants Fanticy Acres and Katrina Drazdova and Victor a/k/a John Doe 1 owed to Plaintiff duties pursuant to N.J.S.A. § 5:15-9(b) to make reasonable and prudent efforts to determine the Plaintiff’s ability to safely manage the specific equine animal. 21. At the time and place aforesaid, defendants Fanticy Acres, Katrina Drazdova, and Victor a/k/a John Doe 1 knowingly, negligently, carelessly, and/or recklessly provided faulty equipment or tack, including but not limited to a specific equine animal, which contributed to severe and permanent bodily injuries later suffered by Plaintiff. 22. At the time and place aforesaid, the defendants, Fanticy Acres, Katrina Drazdova and Victor a/k/a John Doe 1 were negligent and careless in creating a dangerous condition or situation by failing to give reasonable, prudent, and proper warnings to plaintiff, Valentina Grigoryeva, which proximately caused said plaintiff’s fall at the premises and suffer severe and permanent bodily injury. 23. At the time and place aforesaid, the defendants, Fanticy Acres, Katrina Drazdova, and Victor a/k/a John Doe 1 committed acts or omissions constituting negligent disregard for Plaintiff’s safety, which acts and/or omissions caused Plaintiff to suffer severe and permanent bodily injury. 24. At the time and place aforesaid, defendants Fanticy Acres, Katrina Drazdova, and Victor a/k/a John Doe 1 owed duties pursuant to N.J.S.A. § 5:15-9(a) not to knowingly provide equipment or tack that is faulty so that it does not proximately cause or contribute to injury when permitting plaintiff, Valentina Grigoryeva, to participate in the horseback riding activity. Page 5 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 6 of 13 Trans ID: LCV20221930528 25. At the time and place aforesaid, defendant Victor a/k/a John Doe 1, knowingly provided equipment or tack that is faulty to the extent that it caused or contributed to plaintiff, Valentina Grigoryeva’s injury. 26. As a direct and proximate result of the combined aforesaid acts and/or omissions, negligence, carelessness, and/or recklessness of defendants Fanticy Acres, Katrina Drazdova, and Victor a/k/a John Doe 1, Plaintiff suffered severe and permanent injuries or conditions and/or aggravations, exacerbations and/or accelerations of pre-existing injuries or conditions which necessitated Plaintiff to obtain medical treatment, caused her great pain and suffering, incapacitated her from pursuing her usual activities and have left her with permanent disabilities that will in the future incapacitate her, causing her great pain and suffering and to require medical treatment in the past, present and future, caused her to incur medical expenses in an effort to cure herself of her injuries, and has suffered economic loss and other damages. WHEREFORE, plaintiff Valentina Grigoryeva demands judgment on this Count against the defendants Fanticy Acres, Katrina Drazdova, and Victor a/k/a John Doe 1 jointly and/or severally and/or vicariously for damages, costs, interest, counsel fees. COUNT THREE RESPONDEAT SUPERIOR 27. Plaintiff, Valentina Grigoryeva repeats and realleges each and every allegation of Counts One and Two of this Complaint as if fully set forth herein at length. 28. At the time and place aforesaid, defendants Katrina Drazdova and Victor a/k/a John Doe 1, were the agents, servants, representatives, and/or employees of Fanticy Acres, John Page 6 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 7 of 13 Trans ID: LCV20221930528 Does 2-5 (owners of Fanticy Acres, true names unknown) and/or ABC Corporations 1- 20 (corporate owners of Fanticy Acres, true names unknown). 29. Defendants Fanticy Acres, John Does 2-5 and ABC Corporations 1-20 are liable for the negligence of defendants, Katrina Drazdova and Victor a/k/a John Doe 1 by virtue of the doctrine of respondeat superior. 30. At the time and place aforesaid, defendants Fanticy Acres, John Does 2-5 and ABC Corporations 1-20 had a duty to train employees, servants, representatives, agents and/or licensees to conform with the duties pursuant to N.J.S.A. § 5:15-9(b), which was to make a reasonable and prudent effort to determine the plaintiff, Valentina Grigoryeva’s ability to safely manage the particular equine animal, based on said plaintiff’s representation of her horseback riding ability. 31. At the time and place aforesaid, defendants, Fanticy Acres, John Does 2-5 and ABC Corporations 1-20 had a duty to train employees to conform with the duties pursuant to N.J.S.A. § 5:15-9(a) not to knowingly provide faulty equipment or tack so that it does not cause or contribute to injury of plaintiff, Valentina Grigoryeva, while participating in the horseback riding activity. 32. At the time and place aforesaid, defendants Fanticy Acres, John Does 2-5 and ABC Corporations 1-20 had employees, agents, servants and/or representatives who knowingly provided faulty equipment or tack which caused or contributed to plaintiff, Valentina Grigoryeva’s injury. 33. As a direct and proximate result of the combined negligence, carelessness, and recklessness of defendants Fanticy Acres, Katrina Drazdova, John Doe 1, known as “Victor” (last name unknown), and ABC Corporations 1-20 as aforesaid, plaintiff Page 7 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 8 of 13 Trans ID: LCV20221930528 Valentina Grigoryeva suffered serious and permanent injuries and/or conditions and/or aggravations, exacerbations and/or accelerations of pre-existing injuries or conditions which necessitated her to obtain medical treatment, caused her great pain and suffering, incapacitated her from pursuing her usual activities and have left her with permanent disabilities that will in the future incapacitate her, causing her great pain and suffering and to require medical treatment in the past, present and future, caused her to incur medical expenses in an effort to cure herself of her injuries, and has suffered economic loss and other damages. WHEREFORE, plaintiff Valentina Grigoryeva, demands judgment on this Count against the defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, and ABC Corporations 1-20, jointly and/or severally and/or vicariously for damages, costs, interest, counsel fees. COUNT FOUR MAINTENANCE OF PREMESIS AND EQUIPMENT 34. Plaintiff, Valentina Grigoryeva repeats and realleges each and every allegation of Counts One, Two, and Three as if fully set forth herein at length. 35. At the time and place aforesaid, ABC Corporations 21-30 and John Does 6-30 were owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers, tasked with maintaining the premises of Fanticy Acres. 36. At the time and place aforesaid, defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-20, ABC Corporations 21-30 (fictitious names for owners, lessors, sublessors, employees, contractors, and/or Page 8 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 9 of 13 Trans ID: LCV20221930528 landscapers and/or grounds keepers, actual names unknown), and John Does 6-30 (fictitious names for owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers, actual names unknown) owed duties pursuant to N.J.S.A. § 5:15-9(d), and were expected to have made reasonable and prudent efforts for the participant’s safety, including but not limited to the maintenance of the premises and of equipment. 37. At the time and place aforesaid, defendants, Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-20, ABC Corporations 21-30 (fictitious names for owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers, actual names unknown), and John Does 6-30 (fictitious names for owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers, actual names unknown) owed duties pursuant to N.J.S.A. § 5:15-9(a) not to knowingly provide faulty equipment or tack that is unsafe to the extent that it causes or contributes to injury when permitting plaintiff, Valentina Grigoryeva, to participate in horseback riding. 38. At the time and place aforesaid, defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-20, ABC Corporations 21-30 (fictitious names for owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers, actual names unknown), and John Does 6-30 (fictitious names for owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers, actual names unknown) knowingly provided equipment or tack that is faulty to the extent that it caused or contributed to plaintiff, Valentina Grigoryeva’s injury. Page 9 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 10 of 13 Trans ID: LCV20221930528 39. As a direct and proximate result of the combined negligence, carelessness, and recklessness of defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-20, ABC Corporations 21-30 (fictitious names for owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers, actual names unknown), and John Does 6-30 (fictitious names for owners, lessors, sublessors, employees, contractors, and/or landscapers and/or grounds keepers, actual names unknown), plaintiff Valentina Grigoryeva suffered serious and permanent injuries and/or conditions and/or aggravations, exacerbations and/or accelerations of pre-existing injuries and/or conditions which necessitated her to obtain medical treatment, caused her great pain and suffering, incapacitated her from pursuing her usual activities and have left her with permanent disabilities that will in the future incapacitate her, causing her great pain and suffering and to require medical treatment in the past, present and future, caused her to incur medical expenses in an effort to cure herself of her injuries, and has suffered economic loss and other damages. WHEREFORE, Plaintiff Valentina Grigoryeva demands judgment against the defendants, on this Count against the defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-30, and John Does 6-30 jointly and/or severally and/or vicariously for damages, costs, interest, counsel fees and all other relief this court deems just. COUNT FIVE LIABILITY OF INDIVIDUAL PARTNERS OF FANTICY ACRES PURSUANT TO N.J.S.A. 42:1A-18(a) 40. Plaintiff, Valentina Grigoryeva repeats and realleges each and every allegation of Counts One, Two, Three and Four as if fully set forth herein at length. Page 10 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 11 of 13 Trans ID: LCV20221930528 41. At all times relevant hereto, Fanticy Acres was a partnership as that term is defined at N.J.S.A. 42:1A-2. 42. At all times relevant hereto, the following persons were partners of Fanticy Acres: a) Crystal Simicsak; b) Crystal L. Simicsak; c) Joseph Simicsak; d) Karen Simicsak; and e) Karen J. Simicsak; and f) John Does 31-35 (fictitious names of partners of Fanticy Acres whose true names are currently unknown). 43. Pursuant to N.J.S.A. 42:1A-18(a), the partners of Fanticy Acres are jointly and severally liable for the obligations of Fanticy Acres including but not limited to debt incurred for liability to Plaintiff Valentina Grigoryeva. WHEREFORE, Plaintiff Valentina Grigoryeva demands judgment on this Count against the defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, ABC Corporations 1-30, and John Does 6-30, Crystal Simicsak, Crystal L. Simicsak, Joseph Simicsak, Karen Simicsak, Karen J. Simicsak, and John Does 31-35 jointly and/or severally and/or vicariously for damages, costs, interest, and counsel fees. COUNT SIX LIABILITY OF OWNER OF HORSE 44. Plaintiff, Valentina Grigoryeva repeats and realleges each and every allegation of Counts One, Two, Three, Four and Five as if fully set forth herein at length. 45. At all times relevant hereto, defendants John Does 36-40 (fictitious names of individuals who, on May 24, 2020, owned the horse from which Plaintiff fell, true names unknown) and/or ABC Corporations 31-35 (fictitious names of business entities who, as of May 24, 2020, owned the horse from which Plaintiff fell, true names unknown) were the Page 11 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 12 of 13 Trans ID: LCV20221930528 owners of the horse provided to Plaintiff by defendants Fanticy Acres, Katrina Drazdova and/or Victor a/k/a John Doe 1 for purposes of horseback riding instruction. 46. At the time and place aforesaid, defendants John Does 36-40 and ABC Corporations 31- 35 owed duties pursuant to N.J.S.A. § 5:15-9(a) not to provide equipment or tack that is unsafe to the extent that it does not cause or contribute to injury when permitting plaintiff, Valentina Grigoryeva, to participate in the horseback riding activity. 47. At the time and place aforesaid, defendants John Does 36-40 and ABC Corporations 31- 35 owed duties pursuant to N.J.S.A. § 5:15-9(d), and were required to have made reasonable and prudent efforts for the Plaintiff’s safety. 48. At the time and place aforesaid, defendants John Does 36-40 and ABC Corporations 31- 35 knowingly provided equipment or tack that is faulty to the extent that it caused or contributed to plaintiff, Valentina Grigoryeva’s injury. 49. As a direct and proximate result of the combined negligence, carelessness, and recklessness of defendants Fanticy Acres, Katrina Drazdova, Victor a/k/a John Doe 1, John Does 2-5, John Does 6-40, ABC Corporations 1-35, Crystal Simicsak, Crystal L. Simicsak, Joseph Simicsak, Karen Simicsak, and Karen J. Simicsak, Plaintiff Valentina Grigoryeva suffered serious and permanent injuries and/or conditions and/or aggravations, exacerbations and/or accelerations of pre-existing injuries and/or conditions which necessitated her to obtain medical treatment, caused her great pain and suffering, incapacitated her from pursuing her usual activities and have left her with permanent disabilities that will in the future incapacitate her, causing her great pain and suffering and to require medical treatment in the past, present and future, caused her to Page 12 of 13 HUD-L-001625-22 05/17/2022 11:51:19 AM Pg 13 of 13 Trans ID: LCV20221930528 incur medical expenses in an effort to cure herself of her injuries, and has suffered economic loss and other damages. JURY DEMAND Pursuant to R. 4:35-1 of the New Jersey Court Rules, Plaintiff hereby demands a jury trial on all issues so triable. NOTICE OF DESIGNATION OF TRIAL COUNSEL Plaintiff hereby designates Leonard D. Weiss Esq. as Trial Counsel. DEMAND FOR ANSWERS TO INTERROGATORIES PLEASE TAKE NOTICE that plaintiff demands answers to Form C and C(2) interrogatories within 60 days after service of the within pleadings. DEMAND FOR INSURANCE INFORMATION Please provide all insurance agreements or policies under which any person or firm carrying an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse for payments made to satisfy judgment pursuant to R. 4:10-2(b). THE WEISS GROUP, LLC By: /s/Veronica R. Medina, Esq. DATED: May 17, 2022 Veronica R. Medina, Esq. THE WEISS GROUP, LLC Attorneys at Law 344 Main Street, P.O. Box 311 Metuchen, NJ 08840 (732)-549-2515 Fax (732)-549-9520 vm@weisslawyersnj.com Attorneys for Plaintiff, Valentina Grigoryeva Page 13 of 13 HUD-L-001625-22 05/17/2022 HUD-L-001625-22 05/17/202211:51:19 11:51:19AM AM Pg 1 of 1 Trans TransID: ID:LCV20221930528 LCV20221930528 Civil Case Information Statement Case Details: HUDSON | Civil Part Docket# L-001625-22 Case Caption: GRIGORYEVA VALENTINA VS FANTICY Case Type: PERSONAL INJURY ACRES Document Type: Complaint with Jury Demand Case Initiation Date: 05/17/2022 Jury Demand: YES - 6 JURORS Attorney Name: VERONICA R MEDINA Is this a professional malpractice case? NO Firm Name: WEISS GROUP LLC Related cases pending: NO Address: 344 MAIN STREET P.O. BOX 311 If yes, list docket numbers: METUCHEN NJ 08840 Do you anticipate adding any parties (arising out of same Phone: 7325492515 transaction or occurrence)? NO Name of Party: PLAINTIFF : Grigoryeva, Valentina Does this case involve claims related to COVID-19? NO Name of Defendant’s Primary Insurance Company (if known): None Are sexual abuse claims alleged by: Valentina Grigoryeva? NO THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION Do parties have a current, past, or recurrent relationship? NO If yes, is that relationship: Does the statute governing this case provide for payment of fees by the losing party? NO Use this space to alert the court to any special case characteristics that may warrant individual management or accelerated disposition: Do you or your client need any disability accommodations? NO If yes, please identify the requested accommodation: Will an interpreter be needed? NO If yes, for what language: Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO I certify that confidential personal identifiers have been redacted from documents now submitted to the court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b) 05/17/2022 /s/ VERONICA R MEDINA Dated Signed