On December 28, 2023 a
Summons
was filed
involving a dispute between
Rose Brown,
and
Chase Johnson,
Daniel Romitelli,
Steady Stone Construction,
for Commercial - Contract
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 12/28/2023 03:59 PM INDEX NO. 816548/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/28/2023
STATE OF NEW YORK
SUPREME COURT: COUNTY OF ERIE
ROSE BROWN
Plaintiff,
SUMMONS
v.
Index No.:
STEADY STONE
CONSTRUCTION,
CHASE JOHNSON and
DANIEL ROMITELLI
Defendants.
To the above named Defendants:
YOU ARE HEREBY SUMMONED AND REQ to respond
relief UIRED, to the claim for the
sought by the PlaintifT by either a written Demand for a Complaint or a written
Appearance on the Notice of
Plaintiff s Attomey, at the address stated below.
If this Summons and Notice is served upon you within the State of New York
service you must respond by personal
within days after
Twenty (20) service, not
If this including the day of service.
Summons and Notice is not
personally delivered to you within the State
must respond within
of New York, you
Thirty (30) days aller service is completed. as provided law.
by
If you do not respond to the attached Summons and Notice within the
limitation a Judgment applicable time
stated, will be entered agamst you, for
without by default, the relief
further notice to you. demanded,
This action is to be held in the of Erie
County based on the residence of
location of cause the plaintiff and
of action
DATED: Buffalo. New York
December 18, 2023
LAW OFFICE OF TH ART .'AN
TheArthur A. benesidf Esq
Attorney for
Plainny
Rose Brown
484 Delaware Ave
Buffalo, New York 14203
Telephone (716) 348-0992
1 of 2
FILED: ERIE COUNTY CLERK 12/28/2023 03:59 PM INDEX NO. 816548/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/28/2023
STATE OF NEW YORK
SUPREME COURT: COUNTY OF ERIE
ROSE BROWN
Plaintiff, NOTICE OF MOTION
FOR SUMMARY
JUDSMENT IN LIEU OF
COMPLAINT
v. Index No.:
STEADY STONE CONSTRUCTION,
CHASE JOHNSON and
DANIEL ROMITELLI
Defendants.
PLEASE TAKE NOTICE that, upon the at rmation dated December 18, 2023, Plaintiff will
move this court
on
or as soon thereafter as the parties be
may
heard, for and Order pursuant to NY CPLR 3213:
1. PlaintifT Judgement
Granting Summary
a. Find Defendants in breach of and
contract
b. Return of $6,95I.00 and
deposit,
c. $10.000 in punitive damages for Pain and Suffering, and
d. Attorney's fee and costs associated with the action, and
e. For other such relief as the Court deems just and proper
PI.EASE TAKE FURTHER NOTICE. that pursuant to NY CPLR 2214(b), answering papers
and notice of cross-motion with if any,
supporting papers, must be served upon the undersigned
at least seven days prior to the return
(7) date of this motion.
DATED: December 18, 2023
Buffalo, New York --
h r A acan , Esq
Attorney for Plaintiff
484 Delaware Ave
ButTalo, New York 14202
(716) 348-0992
2 of 2
Document Filed Date
December 28, 2023
Case Filing Date
December 28, 2023
Category
Commercial - Contract
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: ERIE COUNTY CLERK 12/28/2023 03:59 PM INDEX NO. 816548/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/28/2023 STATE OF NEW YORK SUPREME COURT: COUNTY OF ERIE ROSE BROWN Plaintiff, SUMMONS v. Index No.: STEADY STONE CONSTRUCTION, CHASE JOHNSON and DANIEL ROMITELLI Defendants. To the above named Defendants: YOU ARE HEREBY SUMMONED AND REQ to respond relief UIRED, to the claim for the sought by the PlaintifT by either a written Demand for a Complaint or a written Appearance on the Notice of Plaintiff s Attomey, at the address stated below. If this Summons and Notice is served upon you within the State of New York service you must respond by personal within days after Twenty (20) service, not If this including the day of service. Summons and Notice is not personally delivered to you within the State must respond within of New York, you Thirty (30) days aller service is completed. as provided law. by If you do not respond to the attached Summons and Notice within the limitation a Judgment applicable time stated, will be entered agamst you, for without by default, the relief further notice to you. demanded, This action is to be held in the of Erie County based on the residence of location of cause the plaintiff and of action DATED: Buffalo. New York December 18, 2023 LAW OFFICE OF TH ART .'AN TheArthur A. benesidf Esq Attorney for Plainny Rose Brown 484 Delaware Ave Buffalo, New York 14203 Telephone (716) 348-0992 1 of 2 FILED: ERIE COUNTY CLERK 12/28/2023 03:59 PM INDEX NO. 816548/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/28/2023 STATE OF NEW YORK SUPREME COURT: COUNTY OF ERIE ROSE BROWN Plaintiff, NOTICE OF MOTION FOR SUMMARY JUDSMENT IN LIEU OF COMPLAINT v. Index No.: STEADY STONE CONSTRUCTION, CHASE JOHNSON and DANIEL ROMITELLI Defendants. PLEASE TAKE NOTICE that, upon the at rmation dated December 18, 2023, Plaintiff will move this court on or as soon thereafter as the parties be may heard, for and Order pursuant to NY CPLR 3213: 1. PlaintifT Judgement Granting Summary a. Find Defendants in breach of and contract b. Return of $6,95I.00 and deposit, c. $10.000 in punitive damages for Pain and Suffering, and d. Attorney's fee and costs associated with the action, and e. For other such relief as the Court deems just and proper PI.EASE TAKE FURTHER NOTICE. that pursuant to NY CPLR 2214(b), answering papers and notice of cross-motion with if any, supporting papers, must be served upon the undersigned at least seven days prior to the return (7) date of this motion. DATED: December 18, 2023 Buffalo, New York -- h r A acan , Esq Attorney for Plaintiff 484 Delaware Ave ButTalo, New York 14202 (716) 348-0992 2 of 2