Preview
FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
__----____--..____--___--_____---X
GEICO INDEMNITY COMPANY Index No:
A/S/O CHARLES DAVIS,
Plaintiff(s) designates
Orange County
Plaintiff(s)
as the place of trial
-against- The basis of venue is
Plaintiff's place of business
PARYSS HARRIS, SUMMONS
Defendant(s).
-------------------------------X
To the above-named Defendant(s):
You are hereby summoned and required to appear in the Orange
County Supreme Court at the office of the Clerk of said Court at 285 Main Street,
Goshen, NY, 10924, County of Orange, 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 the relief demanded in the complaint, together with the costs of this
action.
DATED: Middletown, New York
March 26, 2024
Defendant's Address: a«/
Suzanne Ginexi Esq.
Law Office of Bryan M. Kulak
Paryss Harris for Plaintiff
Attorney
714 Brown St. 90 Crystal Run Road, STE 409
Rochester, New York 14611 Middletown, New York 10941
Tele: 845-673-8080
File No.: 23-0114867
Filed in Orange County 04/01/2024 02:04:10 PM $0.00 1 of
Bk: 5157 6 Pg: 407 Index: # EF002605-2024 Clerk: SW
FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024
NOTE: The law provides that: (a) if this Summons is served by its delivery to you
personally within the County of Orange, you must appear and answer within TWENTY
(20) days after such service; or (b) If this Summons is served by delivery to any person
other than you personally, or is served outside the County of Orange, or by publication, or
by any means other than personal delivery to you within the County of Orange you are
allowed THIRTY (30) days after the proof of service thereof is filed with the Clerk of this
Court within which time to appear and answer.
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FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
--------------------------------------------------X
GEICO INDEMNITY COMPANY Index No:
A/S/O CHARLES DAVIS,
Plaintif(s) designates
Orange County
Plaintiff(s)
as the place of trial
-against- The basis ofvenue is
Plaintiff's place of business
PARYSS HARRIS, COMPLAINT
Defendant(s).
--------------------------------------------------X
Plaintiff, GEICO INDEMNITY COMPANY as Subrogee of CHARLES DAVIS,
by its attorney, Suzanne Ginexi, Esq., of the Law Office of Bryan M. Kulak, complaining
of the defendant, PARYSS HARRIS, as and for its complaint against the defendants
herein allege:
AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF THE
PLAINTIFF(S)
1. At all times herein stated and hereinafter mentioned the plaintiff, GEICO Indemnity
Company, was and still is a foreign corporation authorized to do business in the
State of New York.
2. At all times herein stated and hereinafter mentioned, the plaintiff, GEICO Indemnity
Company, maintains an ofHee in the County of Orange, State of New York.
3. At all times herein stated and hereinafter mentioned the plaintiff subrogor, Charles
Davis, was and still is a resident of the County of Monroe, State of New York.
4. At all times herein stated and hereinafter mentioned, the defendant, Paryss Harris,
was and still is a resident of the County of Monroe, State of New York.
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FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024
5. That at all times hereinafter mentioned, Dewey Avenue, was and still is a public
street and thoroughfare located in the City of Rochester, County of Westchester,
State of New York, and was the situs of the accident herein.
6. That at all times hereinafter mentioned the plaintiff subrogor, Charles Davis, was the
owner of a 2013 Ford Econoline E-350 bearing New York State license plate number
93617MK.
7. That for all times hereinafter mentioned the defendant, Paryss Harris, was the titled
owner and operator of a 2014 Toyota Camry bearing New York State license plate
number KXU8148.
8. That at all times hereinafter mentioned the plaintiff subrogor, Charles Davis, was
insured by the plaintiff, GEICO Indemnity Company, for collision loss under policy
number 4538794977.
9. That by virtue of the terms and conditions of the said policy of insurance, the
plaintiff, GEICO Indemnity Company, is subrogee of Charles Davis.
10. That on or about March 11, 2023, the motor vehicle operated and owned by the
defendant, Paryss Harris, came into contact with the motor vehicle owned by the
plaintiff subrogor, Charles Davis.
11. That the said accident and damages alleged herein were caused solely by the
negligent, wanton, reckless and careless acts of the defendant herein.
12. The damages as set forth herein are more particularized in the police accident report,
repair estimates, photographs, and proof of payments, as provided in EXHIBIT A,
which is hereby made a part of this Complaint.
13. That by reason of the foregoing, the motor vehicle owned by the plaintiff subrogor,
Charles Davis, sustained property damage in the sum of ONE THOUSAND NINE
HUNDRED FIFTY-SEVEN DOLLARS AND FOUR CENTS ($1,957.04).
14. That by reason of the foregoing, the plaintiff was damaged in the sum of ONE
THOUSAND NINE HUNDRED FIFTY-SEVEN DOLLARS AND FOUR CENTS
($1,957.04).
WHEREFORE, plaintiff demands judgment against said defendant for the
sum of $1,957.04 with interest thereon from March 16, 2023, the date of payment,
from plaintiff subrogee to plaintiff subrogor, together with costs and disbursements.
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FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024
DATED: Middletown, New York
March 26, 2024
Suzanne Ginexi, Esq.
Law Office of Bryan M. Kulak
Attorneys for Plaintiff(s)
90 Crystal Run Road STE 409
Middletown, New York 10941
Tele: 845-673-8080
File No.: 23-0114867
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FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024
Index No.: YEAR: 2024
SUPREME COURT OF THE STATE OF NEW YORK
_COUNTY_OF ORANGE
GEICO INDEMNITY COMPANY
A/S/O CHARLES DAVIS,
Plaintiff(s)
- against -
|
PARYSS HARRIS,
Defendant(s)
SUMMONS AND COMPLAINT
LAW OFFICE OF BRYAN M. KULAK
Attorneys for Plaintiff
90 Crystal Run Road, STE 409
Middletown, New York 10941
845-673-8080
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Preview
FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE __----____--..____--___--_____---X GEICO INDEMNITY COMPANY Index No: A/S/O CHARLES DAVIS, Plaintiff(s) designates Orange County Plaintiff(s) as the place of trial -against- The basis of venue is Plaintiff's place of business PARYSS HARRIS, SUMMONS Defendant(s). -------------------------------X To the above-named Defendant(s): You are hereby summoned and required to appear in the Orange County Supreme Court at the office of the Clerk of said Court at 285 Main Street, Goshen, NY, 10924, County of Orange, 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 the relief demanded in the complaint, together with the costs of this action. DATED: Middletown, New York March 26, 2024 Defendant's Address: a«/ Suzanne Ginexi Esq. Law Office of Bryan M. Kulak Paryss Harris for Plaintiff Attorney 714 Brown St. 90 Crystal Run Road, STE 409 Rochester, New York 14611 Middletown, New York 10941 Tele: 845-673-8080 File No.: 23-0114867 Filed in Orange County 04/01/2024 02:04:10 PM $0.00 1 of Bk: 5157 6 Pg: 407 Index: # EF002605-2024 Clerk: SW FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024 NOTE: The law provides that: (a) if this Summons is served by its delivery to you personally within the County of Orange, you must appear and answer within TWENTY (20) days after such service; or (b) If this Summons is served by delivery to any person other than you personally, or is served outside the County of Orange, or by publication, or by any means other than personal delivery to you within the County of Orange you are allowed THIRTY (30) days after the proof of service thereof is filed with the Clerk of this Court within which time to appear and answer. 2 of 6 FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE --------------------------------------------------X GEICO INDEMNITY COMPANY Index No: A/S/O CHARLES DAVIS, Plaintif(s) designates Orange County Plaintiff(s) as the place of trial -against- The basis ofvenue is Plaintiff's place of business PARYSS HARRIS, COMPLAINT Defendant(s). --------------------------------------------------X Plaintiff, GEICO INDEMNITY COMPANY as Subrogee of CHARLES DAVIS, by its attorney, Suzanne Ginexi, Esq., of the Law Office of Bryan M. Kulak, complaining of the defendant, PARYSS HARRIS, as and for its complaint against the defendants herein allege: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF THE PLAINTIFF(S) 1. At all times herein stated and hereinafter mentioned the plaintiff, GEICO Indemnity Company, was and still is a foreign corporation authorized to do business in the State of New York. 2. At all times herein stated and hereinafter mentioned, the plaintiff, GEICO Indemnity Company, maintains an ofHee in the County of Orange, State of New York. 3. At all times herein stated and hereinafter mentioned the plaintiff subrogor, Charles Davis, was and still is a resident of the County of Monroe, State of New York. 4. At all times herein stated and hereinafter mentioned, the defendant, Paryss Harris, was and still is a resident of the County of Monroe, State of New York. 3 of 6 FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024 5. That at all times hereinafter mentioned, Dewey Avenue, was and still is a public street and thoroughfare located in the City of Rochester, County of Westchester, State of New York, and was the situs of the accident herein. 6. That at all times hereinafter mentioned the plaintiff subrogor, Charles Davis, was the owner of a 2013 Ford Econoline E-350 bearing New York State license plate number 93617MK. 7. That for all times hereinafter mentioned the defendant, Paryss Harris, was the titled owner and operator of a 2014 Toyota Camry bearing New York State license plate number KXU8148. 8. That at all times hereinafter mentioned the plaintiff subrogor, Charles Davis, was insured by the plaintiff, GEICO Indemnity Company, for collision loss under policy number 4538794977. 9. That by virtue of the terms and conditions of the said policy of insurance, the plaintiff, GEICO Indemnity Company, is subrogee of Charles Davis. 10. That on or about March 11, 2023, the motor vehicle operated and owned by the defendant, Paryss Harris, came into contact with the motor vehicle owned by the plaintiff subrogor, Charles Davis. 11. That the said accident and damages alleged herein were caused solely by the negligent, wanton, reckless and careless acts of the defendant herein. 12. The damages as set forth herein are more particularized in the police accident report, repair estimates, photographs, and proof of payments, as provided in EXHIBIT A, which is hereby made a part of this Complaint. 13. That by reason of the foregoing, the motor vehicle owned by the plaintiff subrogor, Charles Davis, sustained property damage in the sum of ONE THOUSAND NINE HUNDRED FIFTY-SEVEN DOLLARS AND FOUR CENTS ($1,957.04). 14. That by reason of the foregoing, the plaintiff was damaged in the sum of ONE THOUSAND NINE HUNDRED FIFTY-SEVEN DOLLARS AND FOUR CENTS ($1,957.04). WHEREFORE, plaintiff demands judgment against said defendant for the sum of $1,957.04 with interest thereon from March 16, 2023, the date of payment, from plaintiff subrogee to plaintiff subrogor, together with costs and disbursements. 4 of 6 FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024 DATED: Middletown, New York March 26, 2024 Suzanne Ginexi, Esq. Law Office of Bryan M. Kulak Attorneys for Plaintiff(s) 90 Crystal Run Road STE 409 Middletown, New York 10941 Tele: 845-673-8080 File No.: 23-0114867 5 of 6 FILED: ORANGE COUNTY CLERK 04/01/2024 02:04 PM INDEX NO. EF002605-2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/01/2024 Index No.: YEAR: 2024 SUPREME COURT OF THE STATE OF NEW YORK _COUNTY_OF ORANGE GEICO INDEMNITY COMPANY A/S/O CHARLES DAVIS, Plaintiff(s) - against - | PARYSS HARRIS, Defendant(s) SUMMONS AND COMPLAINT LAW OFFICE OF BRYAN M. KULAK Attorneys for Plaintiff 90 Crystal Run Road, STE 409 Middletown, New York 10941 845-673-8080 6 of 6