Preview
FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
GEICO GENERAL INSURANCE COMPANY AS Index No:
SUBROGEE OF JESSE WARD,
SUMMONS
Plaintiff(s),
Defendant Jeffri Then
resides at:
-against- 760 East 222 Street, Apt #2
Bronx, NY 10467
JEFFRI THEN and "JOHN DOE", BEING A FICTITIOUS
NAME,
Venue designated is:
Defendant Jeffri Then’s
Residence
County of Bronx
Defendant(s).
To the above-named defendant(s):
YOU ARE HEREBY SUMMONED and required to appear in the
Supreme Court of the State of New York at the office of the Clerk of said Court at 851
Grand Concourse, Bronx, NY 10451, County of Bronx, State of New York by serving an
Answer to the annexed Complaint upon Clerk of the Court, at the address stated above
within the time provided by law as noted below; upon your failure to answer, judgment
will be taken against you for $20,425.55 with interest thereon together with the costs and
disbursements of this action.
Dated: MELVILLE, NEW YORK
October 9, 2023
Defendant(s) Address(es) Law Office of Ricky J. Lucyk
By: Evan Przebowski, Esq.
Jeffri Then 2 Huntington Quadrangle, STE 1N01
760 E 222 Street, Apt #2 Melville, New York 11747
Bronx, NY 10467 516-496-5717
GEICO Claim No. 0063761350101041
Staff Counsel File No. 22-0093346 (APIP)
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FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023
NOTE: The law or rules of law provide that:
(a) If the summons is served by its delivery to you, or (for a corporation) an agent
authorized to receive service, personally within the City of New York, you must
answer within TWENTY (20) days after such service;
(b) If this summons is served otherwise than as designated in subdivision (a) above,
you are allowed THIRTY (30) days to answer after the proof of service is filed with
the Clerk of this Court.
(c) You are required to file a copy of your answer together with proof of service with
the clerk of the district in which the action is brought within TEN (10) days of the
service of the answer.
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FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
GEICO GENERAL INSURANCE COMPANY AS Index No:
SUBROGEE OF JESSE WARD,
VERIFIED COMPLAINT
Plaintiff(s),
Defendant Jeffri Then
resides at:
-against- 760 East 222 Street, Apt #2
Bronx, NY 10467
JEFFRI THEN and "JOHN DOE", BEING A FICTITIOUS
NAME,
Venue designated is:
Defendant Jeffri Then’s
Residence
County of Bronx
Defendant(s).
Plaintiff(s), by its attorney, Evan Przebowski, Esq., complaining of the defendant(s),
alleges as follows:
1. At all times herein stated and hereinafter mentioned the plaintiff was and still is a
corporation authorized to do business in the State of New York, doing so in the
County of Bronx.
2. That on October 22, 2021, the defendant Jeffri Then owned a motor vehicle bearing
New York State license plate number 122291T.
3. That on October 22, 2021, the defendant "John Doe", being a fictitious name
operated a motor vehicle bearing New York State license plate number 122291T.
4. That on October 22, 2021, the defendant "John Doe", being a fictitious name
operated a motor vehicle bearing New York State license plate number 122291T with
consent of its owner.
5. That on or about October 22, 2021 plaintiff subrogor sustained injuries because of an
accident which occurred at or near East 63rd Street & 1st Avenue, County of New
York, City and State of New York.
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FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023
6. Said accident was due to the negligence of the defendants in the ownership,
operation, maintenance, management and control of a motor vehicle bearing New
York State license plate number 122291T.
7. That as a result of said accident, plaintiff subrogor sustained medical bills and or
additional economic loss in the amount of $20,425.55 above and beyond basic
economic loss as defined in §5102(a) of the Insurance Law.
8. That plaintiff paid its subrogor the additional economic loss sustained pursuant to the
additional personal injury protection benefits section of the insurance policy, and
plaintiff has been damaged for the sum of $20,425.55.
WHEREFORE, plaintiff(s) demand(s) judgment against said defendant(s) for
the sum of $20,425.55 with interest thereon together with costs and disbursements of
this action.
D AT ED : MELVILLE , N EW Y OR K
O C TO B ER 9, 2023
________________________________
Law Office of Ricky J. Lucyk
By: Evan Przebowski, Esq.
2 Huntington Quadrangle, STE 1N01
Melville, New York 11747
516-496-5717
GEICO Claim No. 0063761350101041
Staff Counsel File No. 22-0093346 (APIP)
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FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023
VERIFICATION
STATE OF NEW YORK )
COUNTY OF SUFFOLK )SS.:
)
Evan Przebowski, Esq., an attorney duly authorized to practice in the State of
New York and not a party to this action, does hereby affirm that the following is true
under the penalties of perjury:
That he/she is an attorney at law associated with Law Office of Ricky J. Lucyk,
attorneys for the Plaintiff.
That he/she has read the foregoing COMPLAINT and knows the contents thereof
and that same is true to his/her own knowledge except as to the matters therein stated to
be alleged upon information and belief, and as to those matters he/she believes to be true.
Affiant further says that the reason this verification is made by the affiant and not
the PLAINTIFF is because the said PLAINTIFF is a foreign corporation authorized to do
business in the State.
_______________________________
Evan Przebowski, Esq.
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Preview
FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX GEICO GENERAL INSURANCE COMPANY AS Index No: SUBROGEE OF JESSE WARD, SUMMONS Plaintiff(s), Defendant Jeffri Then resides at: -against- 760 East 222 Street, Apt #2 Bronx, NY 10467 JEFFRI THEN and "JOHN DOE", BEING A FICTITIOUS NAME, Venue designated is: Defendant Jeffri Then’s Residence County of Bronx Defendant(s). To the above-named defendant(s): YOU ARE HEREBY SUMMONED and required to appear in the Supreme Court of the State of New York at the office of the Clerk of said Court at 851 Grand Concourse, Bronx, NY 10451, County of Bronx, State of New York by serving an Answer to the annexed Complaint upon Clerk of the Court, at the address stated above within the time provided by law as noted below; upon your failure to answer, judgment will be taken against you for $20,425.55 with interest thereon together with the costs and disbursements of this action. Dated: MELVILLE, NEW YORK October 9, 2023 Defendant(s) Address(es) Law Office of Ricky J. Lucyk By: Evan Przebowski, Esq. Jeffri Then 2 Huntington Quadrangle, STE 1N01 760 E 222 Street, Apt #2 Melville, New York 11747 Bronx, NY 10467 516-496-5717 GEICO Claim No. 0063761350101041 Staff Counsel File No. 22-0093346 (APIP) 1 of 5 FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023 NOTE: The law or rules of law provide that: (a) If the summons is served by its delivery to you, or (for a corporation) an agent authorized to receive service, personally within the City of New York, you must answer within TWENTY (20) days after such service; (b) If this summons is served otherwise than as designated in subdivision (a) above, you are allowed THIRTY (30) days to answer after the proof of service is filed with the Clerk of this Court. (c) You are required to file a copy of your answer together with proof of service with the clerk of the district in which the action is brought within TEN (10) days of the service of the answer. 2 of 5 FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX GEICO GENERAL INSURANCE COMPANY AS Index No: SUBROGEE OF JESSE WARD, VERIFIED COMPLAINT Plaintiff(s), Defendant Jeffri Then resides at: -against- 760 East 222 Street, Apt #2 Bronx, NY 10467 JEFFRI THEN and "JOHN DOE", BEING A FICTITIOUS NAME, Venue designated is: Defendant Jeffri Then’s Residence County of Bronx Defendant(s). Plaintiff(s), by its attorney, Evan Przebowski, Esq., complaining of the defendant(s), alleges as follows: 1. At all times herein stated and hereinafter mentioned the plaintiff was and still is a corporation authorized to do business in the State of New York, doing so in the County of Bronx. 2. That on October 22, 2021, the defendant Jeffri Then owned a motor vehicle bearing New York State license plate number 122291T. 3. That on October 22, 2021, the defendant "John Doe", being a fictitious name operated a motor vehicle bearing New York State license plate number 122291T. 4. That on October 22, 2021, the defendant "John Doe", being a fictitious name operated a motor vehicle bearing New York State license plate number 122291T with consent of its owner. 5. That on or about October 22, 2021 plaintiff subrogor sustained injuries because of an accident which occurred at or near East 63rd Street & 1st Avenue, County of New York, City and State of New York. 3 of 5 FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023 6. Said accident was due to the negligence of the defendants in the ownership, operation, maintenance, management and control of a motor vehicle bearing New York State license plate number 122291T. 7. That as a result of said accident, plaintiff subrogor sustained medical bills and or additional economic loss in the amount of $20,425.55 above and beyond basic economic loss as defined in §5102(a) of the Insurance Law. 8. That plaintiff paid its subrogor the additional economic loss sustained pursuant to the additional personal injury protection benefits section of the insurance policy, and plaintiff has been damaged for the sum of $20,425.55. WHEREFORE, plaintiff(s) demand(s) judgment against said defendant(s) for the sum of $20,425.55 with interest thereon together with costs and disbursements of this action. D AT ED : MELVILLE , N EW Y OR K O C TO B ER 9, 2023 ________________________________ Law Office of Ricky J. Lucyk By: Evan Przebowski, Esq. 2 Huntington Quadrangle, STE 1N01 Melville, New York 11747 516-496-5717 GEICO Claim No. 0063761350101041 Staff Counsel File No. 22-0093346 (APIP) 4 of 5 FILED: BRONX COUNTY CLERK 10/16/2023 04:44 PM INDEX NO. 816188/2023E NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2023 VERIFICATION STATE OF NEW YORK ) COUNTY OF SUFFOLK )SS.: ) Evan Przebowski, Esq., an attorney duly authorized to practice in the State of New York and not a party to this action, does hereby affirm that the following is true under the penalties of perjury: That he/she is an attorney at law associated with Law Office of Ricky J. Lucyk, attorneys for the Plaintiff. That he/she has read the foregoing COMPLAINT and knows the contents thereof and that same is true to his/her own knowledge except as to the matters therein stated to be alleged upon information and belief, and as to those matters he/she believes to be true. Affiant further says that the reason this verification is made by the affiant and not the PLAINTIFF is because the said PLAINTIFF is a foreign corporation authorized to do business in the State. _______________________________ Evan Przebowski, Esq. 5 of 5