Preview
FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023
STATE OF NEW YORK
SUPREME COURT COUNTY OF RENS SELAER
JACQUELINE BRENNAN,
Plaintiff,
-against- SUMMONS
Index No.:
KAYLEIGH TEAL Date Filed:
3Blue Heron Way
Wynantskill, New York 12198
DANIEL LUCZKOWEC
3Blue Heron Way
Wynantskill, New York 12198
REGINAL STAN CIL
316 Chiswell Road
Schenectady, NY 12304,
Defendants.
TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to serve upon plaintiffs attorney
an Answer to the Complaint in this action Within twenty days (20) after the service of this
Summons, exclusive of the date of service, or within thirty (30) days after service is
complete if this Summons is not personally delivered to you Within the State of New
York. In case of your failure to answer, judgment will be taken against you by default for
the relief demanded in the Complaint.
DEFENDANTS’ ADDRESSES: see above.
Trial is desired in the County of Rensselaer.
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FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023
The basis of venue is plaintiff’s residence.
Plaintiff resides in Rensselaer, New York, County of Rensselaer.
DATED: September 27, 2023
m/%%/'
ANDERSObefiSCHETTWFFyV,
By: David J. Taffany, Esq.
PLLC
Attorneys for Plaintiff
Office and PO. Address
26 Century Hill Drive, Suite 206
Latham, New York 12110
(518) 785-4900
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FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023
STATE OF NEW YORK
SUPREME COURT COUNTY OF RENSSELAER
JACQUELINE BRENNAN,
Plaintiff,
-against— COMPLAINT
Index No.:
KAYLEIGH TEAL, DANIEL LUCZKOWEC Date Filed:
and REGINAL STAN CIL,
Defendants.
The plaintiff, Jacqueline Brennan, by and through her attorneys, Anderson,
Moschetti & Taffany, PLLC, complaining of the defendants, alleges as follows:
1. That at all times relevant, the plaintiff was a resident of the City of
Rensselaer, County of Rensselaer and State of New York.
2. That at all times relevant, the defendant, Kayleigh Teal, was, fipon
information and belief, a resident of the Town of Wynantskill, County of Rensselaer and
State of New York.
3. That at all times relevant, the defendant, Daniel Luczkowec, was, upon
information and belief a resident of the Town of Wynantskill, County of Rensselaer and
State of New York.
4. That at all times relevant, the defendant, Reginal Stancil, was, upon
information and belief, a resident of the City of Schenectady, County of Schenectady and
State of New York.
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FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023
5. That at all times relevant, the defendant, Kayleigh Teal, was the operator of
a 2020 Chevrolet two-door sedan owned by the defendant, Daniel Luczkowec, and which
was, upon information and belief, duly registered in the State of New York for the year
2023.
6. That at all times relevant, the defendant, Kayleigh Teal was operating said
2020 Chevrolet four-door sedan automobile with the consent and permission of the
defendant, Daniel Luczkowec.
7. That at all times relevant, the defendant, Reginal Stancil, was the owner
and operator of a 2009 Chevrolet pickufi truck.
8. That on June 19, 2023, the plaintiff was the owner and operator of a 2014
Suzuki motorcycle.
9. That on June 19, 2023, all three vehicles were being operated in the same
direction on Quay Street in the City and County of Albany.
10. That on June 19, 2023, at approximately 4:06 p.m., the plaintiff was riding
her 2014 Suzuki motorcycle on Quay Street.
11. That at the aforesaid time and place, the defendant, Kayleigh Teal, struck
the motorcycle the plaintiff was operating.
12. That after the initial impact, the defendant, Reginal Stancil, struck the
motorcycle that plaintiff was operating and caused her to fall.
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FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023
13. That the accident herein was caused by the negligence of the defendants,
who were traveling too fast for the conditions and failed to keep control and too close to
the plaintiffs vehicle and did not otherwise see What was there to be seen.
14. That the accident herein has caused the plaintiff serious personal injury and
conscious pain and» suffering.
15. That pursuant to New York State Vehicle and Traffic Law §3 88, the
negligence of the defendant, Kayleigh Teal, shall be and is imputed to the owner of the
vehicle, Daniel Luczkowec.
16. That the collision herein was caused by the negligence of the defendants
without any fault on the part of the plaintiff herein.
17. That the plaintiff is entitled to the full amount of her economic and non-
economic damages from the above-named defendants as the present action falls within at
least one of the exceptions of §1602 of the Civil Practice Law and Rules.
18. That this action is being brought in the Supreme Court of the State of New
York as the damages herein exceed the jurisdictional levels of all lower courts.
19. That by reason of the foregoing, the plaintiff has been damaged in a
substantial monetafy amount.
WHEREFORE, plaintiff demands judgment against the defendants in the manner
and form recited, together with the costs and disbursements of this action.
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FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023
DATED : September 27, 2023
Wfl/fiflfl
ANbERSO oscWW8; TAFFANY, PLLC
By: DaV1d J. Taffany, Esq.
Attorneys for Plaintiff
Office and PO. Address
26 Century Hill Drive, Suite 206
Latham, New York 12110
(518) 785-4900
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Preview
FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023 STATE OF NEW YORK SUPREME COURT COUNTY OF RENS SELAER JACQUELINE BRENNAN, Plaintiff, -against- SUMMONS Index No.: KAYLEIGH TEAL Date Filed: 3Blue Heron Way Wynantskill, New York 12198 DANIEL LUCZKOWEC 3Blue Heron Way Wynantskill, New York 12198 REGINAL STAN CIL 316 Chiswell Road Schenectady, NY 12304, Defendants. TO THE ABOVE-NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED and required to serve upon plaintiffs attorney an Answer to the Complaint in this action Within twenty days (20) after the service of this Summons, exclusive of the date of service, or within thirty (30) days after service is complete if this Summons is not personally delivered to you Within the State of New York. In case of your failure to answer, judgment will be taken against you by default for the relief demanded in the Complaint. DEFENDANTS’ ADDRESSES: see above. Trial is desired in the County of Rensselaer. 1 of 6 FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023 The basis of venue is plaintiff’s residence. Plaintiff resides in Rensselaer, New York, County of Rensselaer. DATED: September 27, 2023 m/%%/' ANDERSObefiSCHETTWFFyV, By: David J. Taffany, Esq. PLLC Attorneys for Plaintiff Office and PO. Address 26 Century Hill Drive, Suite 206 Latham, New York 12110 (518) 785-4900 2 of 6 FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023 STATE OF NEW YORK SUPREME COURT COUNTY OF RENSSELAER JACQUELINE BRENNAN, Plaintiff, -against— COMPLAINT Index No.: KAYLEIGH TEAL, DANIEL LUCZKOWEC Date Filed: and REGINAL STAN CIL, Defendants. The plaintiff, Jacqueline Brennan, by and through her attorneys, Anderson, Moschetti & Taffany, PLLC, complaining of the defendants, alleges as follows: 1. That at all times relevant, the plaintiff was a resident of the City of Rensselaer, County of Rensselaer and State of New York. 2. That at all times relevant, the defendant, Kayleigh Teal, was, fipon information and belief, a resident of the Town of Wynantskill, County of Rensselaer and State of New York. 3. That at all times relevant, the defendant, Daniel Luczkowec, was, upon information and belief a resident of the Town of Wynantskill, County of Rensselaer and State of New York. 4. That at all times relevant, the defendant, Reginal Stancil, was, upon information and belief, a resident of the City of Schenectady, County of Schenectady and State of New York. 3 of 6 FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023 5. That at all times relevant, the defendant, Kayleigh Teal, was the operator of a 2020 Chevrolet two-door sedan owned by the defendant, Daniel Luczkowec, and which was, upon information and belief, duly registered in the State of New York for the year 2023. 6. That at all times relevant, the defendant, Kayleigh Teal was operating said 2020 Chevrolet four-door sedan automobile with the consent and permission of the defendant, Daniel Luczkowec. 7. That at all times relevant, the defendant, Reginal Stancil, was the owner and operator of a 2009 Chevrolet pickufi truck. 8. That on June 19, 2023, the plaintiff was the owner and operator of a 2014 Suzuki motorcycle. 9. That on June 19, 2023, all three vehicles were being operated in the same direction on Quay Street in the City and County of Albany. 10. That on June 19, 2023, at approximately 4:06 p.m., the plaintiff was riding her 2014 Suzuki motorcycle on Quay Street. 11. That at the aforesaid time and place, the defendant, Kayleigh Teal, struck the motorcycle the plaintiff was operating. 12. That after the initial impact, the defendant, Reginal Stancil, struck the motorcycle that plaintiff was operating and caused her to fall. 4 of 6 FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023 13. That the accident herein was caused by the negligence of the defendants, who were traveling too fast for the conditions and failed to keep control and too close to the plaintiffs vehicle and did not otherwise see What was there to be seen. 14. That the accident herein has caused the plaintiff serious personal injury and conscious pain and» suffering. 15. That pursuant to New York State Vehicle and Traffic Law §3 88, the negligence of the defendant, Kayleigh Teal, shall be and is imputed to the owner of the vehicle, Daniel Luczkowec. 16. That the collision herein was caused by the negligence of the defendants without any fault on the part of the plaintiff herein. 17. That the plaintiff is entitled to the full amount of her economic and non- economic damages from the above-named defendants as the present action falls within at least one of the exceptions of §1602 of the Civil Practice Law and Rules. 18. That this action is being brought in the Supreme Court of the State of New York as the damages herein exceed the jurisdictional levels of all lower courts. 19. That by reason of the foregoing, the plaintiff has been damaged in a substantial monetafy amount. WHEREFORE, plaintiff demands judgment against the defendants in the manner and form recited, together with the costs and disbursements of this action. 5 of 6 FILED: RENSSELAER COUNTY CLERK 09/27/2023 03:36 PM INDEX NO. EF2023-275007 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/27/2023 DATED : September 27, 2023 Wfl/fiflfl ANbERSO oscWW8; TAFFANY, PLLC By: DaV1d J. Taffany, Esq. Attorneys for Plaintiff Office and PO. Address 26 Century Hill Drive, Suite 206 Latham, New York 12110 (518) 785-4900 6 of 6