Preview
FILED: KINGS COUNTY CLERK 12/28/2023 03:59 PM INDEX NO. 504378/2019
NYSCEF DOC. NO. 125 RECEIVED NYSCEF: 12/28/2023
EXHIBIT “A”
FILED: KINGS COUNTY CLERK 12/28/2023
02/27/2019 03:59
05:44 PM INDEX NO. 504378/2019
NYSCEF DOC. NO. 125
1 RECEIVED NYSCEF: 12/28/2023
02/27/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-----------------------------------------------------------------X Index No.:
JOSE ANDALUZ, also known as JOSE GABRIEL
ANDALUZ ESPEJO, SUMMONS
Plaintiff, Plaintiff designates Kings
County as the place of trial.
-against-
The basis of venue is the
SNL ORIX FORT HAMILTON, LLC, SNL/ERI FORT location of the incident:
HAMILTON, LLC, SNL/ERI HOLDINGS LLC, SNL 3491 Fort Hamilton Pkwy
DEVELOPMENT GROUP, LLC, SAFE N LOCK SELF Brooklyn, NY 11218
STORAGE, LLC, SNL IX LLC and SNL
CONSTRUCTION, LLC,
Defendants.
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To the above-named defendants:
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to
serve a copy of your Answer, or, if the Complaint is not served with this Summons, to serve
a Notice of Appearance, on the plaintiffs attorneys within 20 days after the service of this
Summons, exclusive of the day of service (or within 30 days after the service is complete, if
this Summons is not personally delivered to you within the State of New York); and in case
of your failure to appear or answer, judgment will be taken against you by default for the relief
demanded in the Complaint.
DATED: New York, New York
February 27, 2019
Yours, etc.,
Carmine J. Goncalves, Esq.
WINGATE, RUSSOTTI, SHAPIRO & HALPERIN, LLP
Attorneys for Plaintiff
JOSE ANDALUZ, also known as
JOSE GABRIEL ANDALUZ ESPEJ O
420 Lexington Avenue, Suite 2750
New York, NY 10170
(212) 986-7353
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TO: SNL ORIX FORT HAMILTON, LLC
3333 New Hyde Park Road, Suite 200
Lake Success, New York 11042
SNL/ERI FORT HAMILTON, LLC
3333 New Hyde Park Road, Suite 200
Lake Success, New York 11042
SNL/ERI HOLDINGS, LLC
3333 New Hyde Park Road, Suite 200
Lake Success, New York 11042
SNL DEVELOPMENT GROUP, LLC
3333 New Hyde Park Road, Suite 200
Lake Success, New York 11042
SAFE N LOCK SELF STORAGE LLC
3333 New Hyde Park Road, Suite 200
Lake Success, New York 11042
SNL IX LLC
3333 New Hyde Park Road, Suite 200
Lake Success, New York 11042
SNL CONSTRUCTION LLC
3333 New Hyde Park Road, Suite 200
Lake Success, New York 11042
2 of 45
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NYSCEF DOC. NO. 125
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------X
JOSE ANDALUZ, also known as JOSE GABRIEL
ANDALUZ ESPEJO, VERIFIED COMPLAINT
Plaintiff, Index No.:
-against-
SNL ORIX FORT HAMILTON, LLC, SNL/ERI FORT
HAMILTON, LLC, SNL/ERI HOLDINGS LLC, SNL
DEVELOPMENT GROUP, LLC, SAFE N LOCK SELF
STORAGE, LLC, SNL IX LLC and SNL
CONSTRUCTION, LLC
Defendants.
-----~~~---------~~-~~~~------~~-------~X
Plaintiff, by his attorneys, WINGATE, RUSSOTTI, SHAPIRO & HALPERIN, LLP,
complaining of the defendants herein, respectfully show to this Court, and allege as follows:
AS AND FOR A FIRST CAUSE OF ACTION ON
BEHALF OF THE PLAINTIFF, IOSE ANDALUZ
1. That on or about January 19, 2019, and at all times hereinafter mentioned, the
plaintiff, JOSE ANDALUZ, also known as JOSE GABRIEL ANDALUZ ESPEJO (hereinafter
referred to as "JOSE ANDALUZ"), was and still is a resident of Kings County and the State
of New York.
2. That on or about J anuary 19, 2019, at all times mentioned herein, the
defendant, SNL ORIX FORT HAMILTON, LLC, is was and has been a domestic
corporation duly organized and existing
under and by virtue of the laws of the State of New
York.
3. That at all times mentioned herein, the defendant, SNL ORIX FORT
3 of 45
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HAMILTON, LLC, is, was and has been a foreign corporation and/or other foreign business
entity, duly authorized to do business in the State of New York.
4. That at all times mentioned herein the defendant, SNL ORIX FORT
HAMILTON, LLC, is, was and has been a domestic and/or other domestic
partnership
business entity doing business in the State of New York.
5. That at all times mentioned herein the defendant, SNL ORIX FORT
HAMILTON, LLC, is, was and has been a franchisee authorized to do business in the State
of New York.
6. That at all times mentioned herein, the defendant, SNL ORIX FORT
HAMILTON, LLC, transacted business within the State of New York; regularly did or
solicited business within the State of New York or engaged in other persistent courses
conduct and/or derived substantial revenue from goods used or consumed or services
rendered in the State of New York and expected or should have reasonably expected its acts
to have consequences within the State of NewYork and/or derived substantial revenue from
interstate or international commerce.
7. That on or about January 19, 2019, at all times mentioned herein, the
defendant, SNL/ERI FORT HAMILTON, LLC, is was and has been a domestic corporation
duly organized and existing
under and by virtue of the laws of the State of New York.
8. That at all times mentioned herein, the defendant, SNL/ERI FORT
HAMILTON, LLC, is, was and has been a foreign corporation and/or other foreign business
entity, duly authorized to do business in the State ofNew York.
9. That at all times mentioned herein the defendant, SNL/ERI FORT
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HAMILTON, LLC, is, was and has been a domestic and/or other domestic
partnership
business entity doing business in the State of New York.
10. That at all times mentioned herein the defendant, SNL/ERI FORT
HAMILTON, LLC, is, was and has been a franchisee authorized to do business in the State
of New York.
11. That at all times mentioned herein, the defendant, SNL/ERI FORT
HAMILTON, LLC, transacted business within the State of New York; regularly did or
solicited business within the State of New York or engaged in other persistent courses
conduct and/or derived substantial revenue from goods used or consumed or services
rendered in the State of New York and expected or should have reasonably expected its acts
to have consequences within the State of New York and/or derived substantial revenue from
..
interstate or international commerce.
12. That on or about January 19, 2019, at all times mentioned herein, the
defendant, SNL/ERI HOLDINGS, LLC, is was and has been a domestic corporation duly
organized and existing
under and by virtue of the laws of the State of New York.
13. That at all times mentioned herein, the defendant, SNL/ERI HOLDINGS,
LLC, is, was and has been a foreign corporation and/or other foreign business entity, duly
authorized to do business in the State of New York.
14. That at all times mentioned herein the defendant, SNL/ERI HOLDINGS, LLC,
is, was and has been a domestic partnership and/or other domestic business entity doing
business in the State ofNew York.
15. Thatatalltimesmentionedhereinthedefendant,SNL/ERI HOLDINGS, LLC,
3
5 of 45
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NYSCEF DOC. NO. 125
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is, was and has been a franchisee authorized to do business in the State of New York.
16. That at all times mentioned herein, the defendant, SNL/ERI HOLDINGS,
LLC, transacted business within the State of New York; regularly did or solicited business
within the State of New York or engaged in other persistent courses conduct and/or derived
substantial revenue from goods used or consumed or services rendered in the State of New
York and expected or should have reasonably expected its acts to have consequences within
the State of New York and/or derived substantial revenue from interstate or international
commerce.
17. That on or about January 19, 2019, at all times mentioned herein, the
defendant, SNL DEVELOPMENT GROUP, LLC, is was and has been a domestic
corporation duly organized and existing
under and by virtue of the laws of the State of New
York.
18. That at all times mentioned herein, the defendant, SNL DEVELOPMENT
GROUP, LLC, is, was and has been a foreign corporation and/or other foreign business
entity, duly authorized to do business in the State of New York.
19. That at all times mentioned herein the defendant, SNL DEVELOPMENT
GROUP, LLC, is, was and has been a domestic partnership and/or other domestic business
entity doing business in the State of New York.
20. That at all times mentioned herein the defendant, SNL DEVELOPMENT
GROUP, LLC, is, was and has been a franchisee authorized to do business in the State of
New York.
21. That at all times mentioned herein, the defendant, SNL DEVELOPMENT
4
6 of 45
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GROUP, LLC, transacted business within the State of New York; regularly did or solicited
business within the State of New York or engaged in other persistent courses conduct and/or
derived substantial revenue from goods used or consumed or services rendered in the State
of New York and expected or should have reasonably expected its acts to have consequences
within the State of New York and/or derived substantial revenue from interstate or
international commerce.
22. That on or about January 19, 2019, at all times mentioned herein, the
defendant, SAFE N LOCK SELF STORAGE LLC, is was and has been a domestic
corporation duly organized and existing
under and by virtue of the laws of the State of New
York.
23. That at all times mentioned herein, the defendant, SAFE N LOCK SELF
STORAGE LLC, is, was and has been a foreign corporation and/or other foreign business
entity, duly authorized to do business in the State of New York.
24. That at all times mentioned herein the defendant, SAFE N LOCK SELF
STORAGE LLC, is, was and has been a domestic partnership and/or other domestic business
entity doing business in the State of New York.
25. That at all times mentioned herein the defendant, SAFE N LOCK SELF
STORAGE LLC, is, was and has been a franchisee authorized to do business in the State of
New York.
26. That at all times mentioned herein, the defendant, SAFE N LOCK SELF
STORAGE LLC, transacted business within the State of New York; regularly did or solicited
business within the State of New York or engaged in other persistent courses conduct and/or
5
7 of 45
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derived substantial revenue from goods used or consumed or services rendered in the State
of New York and expected or should have reasonably expected its acts to have consequences
within the State of New York and/or derived substantial revenue from interstate or
international commerce.
27. That on or about January 19, 2019, at all times mentioned herein, the
defendant, SNL IX LLC, is was and has been a domestic corporation duly organized and
existing under and by virtue of the laws of the State of New York.
28. That at all times mentioned herein, the defendant, SNL IX LLC, is, was and
has been a foreign corporation and/or other foreign business entity, duly authorized to do
business in the State of New York.
29. That at all times mentioned herein the defendant, SNL IX LLC, is, was and has
been a domestic partnership and/or other domestic business entity doing business in the State
of New York.
30. That at all times mentioned herein the defendant, SNL IX LLC, is, was and has
been a franchisee authorized to do business in the State of New York.
31. That at all times mentioned herein, the defendant, SNL IX LLC, transacted
business within the State of New York; regularly did or solicited business within the State of
New York or engaged in other persistent courses conduct and/or derived substantial revenue
from goods used or consumed or services rendered in the State of New York and expected
or should have reasonably expected its acts to have consequences within the State of New
York and/or derived substantial revenue from interstate
Preview
FILED: KINGS COUNTY CLERK 12/28/2023 03:59 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 RECEIVED NYSCEF: 12/28/2023 EXHIBIT “A” FILED: KINGS COUNTY CLERK 12/28/2023 02/27/2019 03:59 05:44 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 1 RECEIVED NYSCEF: 12/28/2023 02/27/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -----------------------------------------------------------------X Index No.: JOSE ANDALUZ, also known as JOSE GABRIEL ANDALUZ ESPEJO, SUMMONS Plaintiff, Plaintiff designates Kings County as the place of trial. -against- The basis of venue is the SNL ORIX FORT HAMILTON, LLC, SNL/ERI FORT location of the incident: HAMILTON, LLC, SNL/ERI HOLDINGS LLC, SNL 3491 Fort Hamilton Pkwy DEVELOPMENT GROUP, LLC, SAFE N LOCK SELF Brooklyn, NY 11218 STORAGE, LLC, SNL IX LLC and SNL CONSTRUCTION, LLC, Defendants. -----------------------------------------------------------------X To the above-named defendants: YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of Appearance, on the plaintiffs attorneys within 20 days after the service of this Summons, exclusive of the day of service (or within 30 days after the service is complete, if this Summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the Complaint. DATED: New York, New York February 27, 2019 Yours, etc., Carmine J. Goncalves, Esq. WINGATE, RUSSOTTI, SHAPIRO & HALPERIN, LLP Attorneys for Plaintiff JOSE ANDALUZ, also known as JOSE GABRIEL ANDALUZ ESPEJ O 420 Lexington Avenue, Suite 2750 New York, NY 10170 (212) 986-7353 1 of 45 FILED: KINGS COUNTY CLERK 12/28/2023 02/27/2019 03:59 05:44 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 1 RECEIVED NYSCEF: 12/28/2023 02/27/2019 TO: SNL ORIX FORT HAMILTON, LLC 3333 New Hyde Park Road, Suite 200 Lake Success, New York 11042 SNL/ERI FORT HAMILTON, LLC 3333 New Hyde Park Road, Suite 200 Lake Success, New York 11042 SNL/ERI HOLDINGS, LLC 3333 New Hyde Park Road, Suite 200 Lake Success, New York 11042 SNL DEVELOPMENT GROUP, LLC 3333 New Hyde Park Road, Suite 200 Lake Success, New York 11042 SAFE N LOCK SELF STORAGE LLC 3333 New Hyde Park Road, Suite 200 Lake Success, New York 11042 SNL IX LLC 3333 New Hyde Park Road, Suite 200 Lake Success, New York 11042 SNL CONSTRUCTION LLC 3333 New Hyde Park Road, Suite 200 Lake Success, New York 11042 2 of 45 FILED: KINGS COUNTY CLERK 12/28/2023 02/27/2019 03:59 05:44 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 1 RECEIVED NYSCEF: 12/28/2023 02/27/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------X JOSE ANDALUZ, also known as JOSE GABRIEL ANDALUZ ESPEJO, VERIFIED COMPLAINT Plaintiff, Index No.: -against- SNL ORIX FORT HAMILTON, LLC, SNL/ERI FORT HAMILTON, LLC, SNL/ERI HOLDINGS LLC, SNL DEVELOPMENT GROUP, LLC, SAFE N LOCK SELF STORAGE, LLC, SNL IX LLC and SNL CONSTRUCTION, LLC Defendants. -----~~~---------~~-~~~~------~~-------~X Plaintiff, by his attorneys, WINGATE, RUSSOTTI, SHAPIRO & HALPERIN, LLP, complaining of the defendants herein, respectfully show to this Court, and allege as follows: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF THE PLAINTIFF, IOSE ANDALUZ 1. That on or about January 19, 2019, and at all times hereinafter mentioned, the plaintiff, JOSE ANDALUZ, also known as JOSE GABRIEL ANDALUZ ESPEJO (hereinafter referred to as "JOSE ANDALUZ"), was and still is a resident of Kings County and the State of New York. 2. That on or about J anuary 19, 2019, at all times mentioned herein, the defendant, SNL ORIX FORT HAMILTON, LLC, is was and has been a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 3. That at all times mentioned herein, the defendant, SNL ORIX FORT 3 of 45 FILED: KINGS COUNTY CLERK 12/28/2023 02/27/2019 03:59 05:44 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 1 RECEIVED NYSCEF: 12/28/2023 02/27/2019 HAMILTON, LLC, is, was and has been a foreign corporation and/or other foreign business entity, duly authorized to do business in the State of New York. 4. That at all times mentioned herein the defendant, SNL ORIX FORT HAMILTON, LLC, is, was and has been a domestic and/or other domestic partnership business entity doing business in the State of New York. 5. That at all times mentioned herein the defendant, SNL ORIX FORT HAMILTON, LLC, is, was and has been a franchisee authorized to do business in the State of New York. 6. That at all times mentioned herein, the defendant, SNL ORIX FORT HAMILTON, LLC, transacted business within the State of New York; regularly did or solicited business within the State of New York or engaged in other persistent courses conduct and/or derived substantial revenue from goods used or consumed or services rendered in the State of New York and expected or should have reasonably expected its acts to have consequences within the State of NewYork and/or derived substantial revenue from interstate or international commerce. 7. That on or about January 19, 2019, at all times mentioned herein, the defendant, SNL/ERI FORT HAMILTON, LLC, is was and has been a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 8. That at all times mentioned herein, the defendant, SNL/ERI FORT HAMILTON, LLC, is, was and has been a foreign corporation and/or other foreign business entity, duly authorized to do business in the State ofNew York. 9. That at all times mentioned herein the defendant, SNL/ERI FORT 4 of 45 FILED: KINGS COUNTY CLERK 12/28/2023 02/27/2019 03:59 05:44 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 1 RECEIVED NYSCEF: 12/28/2023 02/27/2019 HAMILTON, LLC, is, was and has been a domestic and/or other domestic partnership business entity doing business in the State of New York. 10. That at all times mentioned herein the defendant, SNL/ERI FORT HAMILTON, LLC, is, was and has been a franchisee authorized to do business in the State of New York. 11. That at all times mentioned herein, the defendant, SNL/ERI FORT HAMILTON, LLC, transacted business within the State of New York; regularly did or solicited business within the State of New York or engaged in other persistent courses conduct and/or derived substantial revenue from goods used or consumed or services rendered in the State of New York and expected or should have reasonably expected its acts to have consequences within the State of New York and/or derived substantial revenue from .. interstate or international commerce. 12. That on or about January 19, 2019, at all times mentioned herein, the defendant, SNL/ERI HOLDINGS, LLC, is was and has been a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 13. That at all times mentioned herein, the defendant, SNL/ERI HOLDINGS, LLC, is, was and has been a foreign corporation and/or other foreign business entity, duly authorized to do business in the State of New York. 14. That at all times mentioned herein the defendant, SNL/ERI HOLDINGS, LLC, is, was and has been a domestic partnership and/or other domestic business entity doing business in the State ofNew York. 15. Thatatalltimesmentionedhereinthedefendant,SNL/ERI HOLDINGS, LLC, 3 5 of 45 FILED: KINGS COUNTY CLERK 12/28/2023 02/27/2019 03:59 05:44 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 1 RECEIVED NYSCEF: 12/28/2023 02/27/2019 is, was and has been a franchisee authorized to do business in the State of New York. 16. That at all times mentioned herein, the defendant, SNL/ERI HOLDINGS, LLC, transacted business within the State of New York; regularly did or solicited business within the State of New York or engaged in other persistent courses conduct and/or derived substantial revenue from goods used or consumed or services rendered in the State of New York and expected or should have reasonably expected its acts to have consequences within the State of New York and/or derived substantial revenue from interstate or international commerce. 17. That on or about January 19, 2019, at all times mentioned herein, the defendant, SNL DEVELOPMENT GROUP, LLC, is was and has been a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 18. That at all times mentioned herein, the defendant, SNL DEVELOPMENT GROUP, LLC, is, was and has been a foreign corporation and/or other foreign business entity, duly authorized to do business in the State of New York. 19. That at all times mentioned herein the defendant, SNL DEVELOPMENT GROUP, LLC, is, was and has been a domestic partnership and/or other domestic business entity doing business in the State of New York. 20. That at all times mentioned herein the defendant, SNL DEVELOPMENT GROUP, LLC, is, was and has been a franchisee authorized to do business in the State of New York. 21. That at all times mentioned herein, the defendant, SNL DEVELOPMENT 4 6 of 45 FILED: KINGS COUNTY CLERK 12/28/2023 02/27/2019 03:59 05:44 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 1 RECEIVED NYSCEF: 12/28/2023 02/27/2019 GROUP, LLC, transacted business within the State of New York; regularly did or solicited business within the State of New York or engaged in other persistent courses conduct and/or derived substantial revenue from goods used or consumed or services rendered in the State of New York and expected or should have reasonably expected its acts to have consequences within the State of New York and/or derived substantial revenue from interstate or international commerce. 22. That on or about January 19, 2019, at all times mentioned herein, the defendant, SAFE N LOCK SELF STORAGE LLC, is was and has been a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 23. That at all times mentioned herein, the defendant, SAFE N LOCK SELF STORAGE LLC, is, was and has been a foreign corporation and/or other foreign business entity, duly authorized to do business in the State of New York. 24. That at all times mentioned herein the defendant, SAFE N LOCK SELF STORAGE LLC, is, was and has been a domestic partnership and/or other domestic business entity doing business in the State of New York. 25. That at all times mentioned herein the defendant, SAFE N LOCK SELF STORAGE LLC, is, was and has been a franchisee authorized to do business in the State of New York. 26. That at all times mentioned herein, the defendant, SAFE N LOCK SELF STORAGE LLC, transacted business within the State of New York; regularly did or solicited business within the State of New York or engaged in other persistent courses conduct and/or 5 7 of 45 FILED: KINGS COUNTY CLERK 12/28/2023 02/27/2019 03:59 05:44 PM INDEX NO. 504378/2019 NYSCEF DOC. NO. 125 1 RECEIVED NYSCEF: 12/28/2023 02/27/2019 derived substantial revenue from goods used or consumed or services rendered in the State of New York and expected or should have reasonably expected its acts to have consequences within the State of New York and/or derived substantial revenue from interstate or international commerce. 27. That on or about January 19, 2019, at all times mentioned herein, the defendant, SNL IX LLC, is was and has been a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 28. That at all times mentioned herein, the defendant, SNL IX LLC, is, was and has been a foreign corporation and/or other foreign business entity, duly authorized to do business in the State of New York. 29. That at all times mentioned herein the defendant, SNL IX LLC, is, was and has been a domestic partnership and/or other domestic business entity doing business in the State of New York. 30. That at all times mentioned herein the defendant, SNL IX LLC, is, was and has been a franchisee authorized to do business in the State of New York. 31. That at all times mentioned herein, the defendant, SNL IX LLC, transacted business within the State of New York; regularly did or solicited business within the State of New York or engaged in other persistent courses conduct and/or derived substantial revenue from goods used or consumed or services rendered in the State of New York and expected or should have reasonably expected its acts to have consequences within the State of New York and/or derived substantial revenue from interstate