Preview
FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
________________________________________________________________________Ç
EDNA OTTON, SUMMONS
Plaintiff, Index No.:
-against-
Date Filed:
BRYAN SAZO and GERBER SAZO,
Defendants.
________________________________________________________________________Ç
TO THE ABOVE NAMED DEFENDANT(s):
YOU ARE HEREBY SUMMONED to answer the complaint in this action by serving an
plaintiffs'
answer, or notice of appearance, on the attorneys within 20 days after the service of
this summons, exclusive of the day of service, or within 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.
Plaintiff designates Suffolk County as the place of venue based on plaintiff's place of
residence.
Dated: Garden City, New York
April 11, 2024
Yours, etc.
Decolator, Cohen & DiPrisco, LLP
Attorneys for Plaintiff
1399 Franklin Avenue, Suite 300
Garden City, New York 11530
(516) 742-6575
DEFENDANTS'
ADDRESSES:
BRYAN SAZO GERBER SAZO
140 East Avenue 91 Wood Road Trail
Flanders, New York 11901 Flanders, New York I1901
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
------------------------------------------------------------------------X Index No.:
EDNA OTTON,
Plaintiff, VERIFIED
-against- COMPLAINT
BRYAN SAZO and GERBER SAZO,
Defendants.
______________------____________....______________________________________Ç
Plaintiff, by her attorneys, Decolator, Cohen & DiPrisco, LLP, as and for her Verified
Complaint, respectfully alleges, upon information and belief, as follows:
AS AND FOR A FIRST CAUSE OF ACTION
ON BEHALF OF PLAINTIFF
1. At all times hereinafter mentioned, plaintiff was and still is a resident of the
County of Suffolk, State of New York.
2. At all times hereinafter mentioned, plaintiff was a police officer employed by the
New York State Police Department, and was acting within the scope and furtherance of her
duties as a police officer.
3. Upon information and belief, at all times hereinafter mentioned, defendant,
BRYAN SAZO, was and still is a resident of the County of Suffolk, State of New York.
4. Upon information and belief, at all times hereinafter mentioned, defendant,
GERBER SAZO, was and still is a resident of the County of Suffolk, State of New York.
5. Upon information and belief, at all times hereinafter mentioned, the defendant,
GERBER SAZO, owned a certain 2004 Ford motor vehicle, bearing New York registration
number KWB6843.
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6. That all times hereinafter mentioned, the defendant, BRYAN SAZO, operated
and controlled a certain 2004 Ford motor vehicle, bearing New York registration number
KWB6843.
7. That at all times hereinafter mentioned, the defendant, BRYAN SAZO, operated
and controlled the said motor vehicle with the express and/or implied permission and consent of
the owner/defendant, GERBER SAZO, thereof.
8. At all times hereinafter mentioned, New York State Police Department, was the
owner of a certain 2022 Dodge motor vehicle, bearing New York State Police Department
registration number POLICE.
9. That at all times hereinafter mentioned, Plaintiff, EDNA OTTON, operated and
controlled a certain 2022 Dodge motor vehicle, bearing New York State Police Department
registration number POLICE.
10. That at all times hereinafter mentioned, Plaintiff, EDNA OTTON, operated the
aforesaid motor vehicle with the expressed and/or implied consent and permission of the owner,
New York State Police Department, thereof.
11. On or about April 6, 2023, at or about Montauk Highway with its intersection at
County Road 31, County of Suffolk, City and State of New York, were and still are public
highways.
12. At the time and place aforesaid, the vehicle operated by defendant, BRYAN
SAZO and owned by defendant, GERBER SAZO, and the vehicle which the plaintiff operated
were in contact.
3
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13. On or about April 6, 2023, at approximately 4:18 p.m., thereof, while the plaintiff
was lawfully and properly operating her vehicle at the location of Montauk Highway at County
Road 31, County of Suffolk, State of New York, defendant, BRYAN SAZO, at the time operated
the vehicle in such negligent and careless fashion as to cause a collision to occur, causing severe
personal injuries to the plaintiff.
14. The said collision was caused solely and wholly by reason of the negligence and
carelessness of the defendants, with no fault or culpable conduct on the part of the plaintiff
contributing thereto.
15. The said defendants, so negligently and carelessly owned, managed, operated and
controlled the said motor vehicle, that without any negligence or fault on the part of the plaintiff,
defendants'
and solely by reason of the negligence and carelessness of said defendants, motor
vehicle suddenly came into violent contact with the plaintiff s vehicle and, as a result, the
plaintiff sustained the injuries hereinafter described.
16. Plaintiff has sustained serious injuries as same are defined in Subdivision (d) of
Section 5102 of the Insurance Law of the State of New York and economic loss greater than
basic loss as defined in said section of the law.
17. This action falls within one or more of the exceptions set forth in CPLR Section
1601 and 1602.
defendants'
18. As a result of negligence as aforesaid, plaintiff was severely injured
both internally and externally, that plaintiff became sick, sore, lame and disabled, and has
suffered great pain, shock and mental anguish and will continue to suffer for a long time to come
and, upon information and belief, has been permanently injured; that by reason of the foregoing,
4
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the plaintiff, has been obligated to and did necessarily employ medical aid and medicines in an
attempt to cure said injuries; that plaintiff was incapacitated from work by reason, and by reason
of said disabilities plaintiff lost wages, salary and earnings all to plaintiff's damage in an amount
in excess of the maximum monetary jurisdiction of all lower Courts.
19. Solely by reason of the foregoing, plaintiff has sustained damages in an amount in
excess of the maximum monetary jurisdiction of all lower courts.
AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF
PLAINTIFF AS AGAINST DEFENDANTS
20. The plaintiff repeats, reiterates and realleges all of the facts set forth in
"1" "19"
paragraphs numbered through inclusive with the same force and effect as though more
fully set forth herein.
21. At all times hereinafter mentioned, plaintiff was a police officer employed by the
New York City Police Department, and was acting within the scope and furtherance of his duties
as a police officer,
22. Defendants, were negligent in that the said defendants did own, operate, maintain,
supervise and control said motor vehicle in a dangerous, negligent, reckless and careless fashion,
including but not limited to the following: failed to exercise proper, reasonable and prudent
control over said motor vehicle; did operate the said motor vehicle in a reckless, careless and
negligent manner; operated the said motor vehicle at a dangerous, reckless, careless and
negligent rate of speed; failed to properly control the speed of the said motor vehicle; failed to
properly check the speed of the said motor vehicle; failed and omitted to operate the said motor
vehicle at a speed that was reasonable and prudent under the conditions then and there existent;
5
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failed and omitted to give due regard to the actual and potential hazards then and there existent;
failed to properly bring the said motor vehicle to a halt; failed to properly control the said motor
vehicle; failed to yield the right of way; failed to yield to an emergency vehicle; operated the
said motor vehicle in an unskillful manner; operating a vehicle without a proper license; failed to
keep to the right; failed to properly apply the brakes to the said motor vehicle; failed to observe
the plaintiff; failed to warn the plaintiff upon approach; failed to properly and prudently observe
the road, roadway and traffic conditions then and there existent; failed to properly and prudently
maintain the said motor vehicle; failed to avoid the happening of the accident complained of;
operated the said motor vehicle in a dangerous, illegal, and unsafe fashion; failed to observe the
traffic conditions and traffic control devices, signs and signals; failed to stop; failed to slow
down and stop; failing to see what ought to be seen; made an improper left hand turn; failed to
signal; failed to honk its horn; failed to observe, obey and give due regard for the rules of the
road; in failing to stop; operating the vehicle with a revoked license; driving without a license;
disregarded traffic signals, signs and devices; the defendants further neglected, omitted and/or
were willfully and/or culpably negligent in failing to comply with Vehicle and Traffic Law
Sections 1144(a), 509, 1160, I141, 116, 388, 1140, 1128, 1180(a), 1212, 375, 1144, 1144a-a,
1140, 1141. The Court will take judicial notice of all rules, violations, laws, codes and statutes
violated at the time of trial.
23. Solely by reason of the foregoing, plaintiff asserts a cause of action against the
defendant under Section 205-e of the General Municipal Law of the State of New York and a
General Obligations Law Section 11-106 claim.
6
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24. Solely by reason of the foregoing, plaintiff has sustained damages in an amount in
excess of the maximum monetary jurisdiction of all lower courts of the State of New York.
WHEREFORE, plaintiff demands judgment against defendants in the First, and Second
Causes of Action in an amount in excess of the maximum monetary jurisdiction of all lower
Courts of the State of New York, together with the interest, costs and disbursements of this
action.
Dated: Garden City, New York
April 11, 2024
Yours, etc.
Decolator, Cohen & DiPrisco, LLP
Attorneys for Plaintiff
1399 Franklin Avenue, Suite 300
Garden City, New York 11530
(516) 742-6575
7
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
C 1995 BlumbergEfcelsior.
Inc.
STATE OF NEW YORK, COUNTY OF 33
NASSAU
I, the undersigned, an attorney admitted to practice in the courts of New York State,
O certification
certify that the within
ByAttorney
has been compared by me with the original and found to be a true and complete copy.
PO
d'
Attomey's state that I am
Affirmation .
the attorney(s) of record for Plamtiff in the within
action; I have read the foregoing Summons and Complaint and know the contents thereof;
the same is true to my own knowledge, except as to the matters therein alleged to be on information and belief, and as to those matters
I believe it to be true. The reason this verification is made by me and not by
plaintiff iS because the plaintiff resides
in a county other than the one in which your deponent maintains his office.
The grounds of my belief as to all matters not stated upon my own knowledge are as follows: conversations with
plaintiff and office records.
I affirm that the foregoing statements are true, under the penalties of perjury.
Dated. he namesigned
mustbeprintedbeneath
STATE OF NÎ h ,i&WFSy yprk; April 11, 2024
ss Decolator, Cohen & DiPrisco, LLP
I, the undersigned, being duly sworn, depose and say: I am
O a "a in the action; I have read the foregoing
and know the contents thereof; the same is true to my own knowledge, except
as to the matters therein stated to be alleged on information and belief, and as to those matters I believe it to be true.
Corporate the of
a Verification
a corporation and a party in the within action; I have read the foregoing
and know the contents thereof; and the same is true to my own knowledge,
except as to the matters therein stated to be alleged upon information and belief, and as to those matters I believe it to be true. This
verification is made by me because the above party is a corporation and I am an officer thereof.
The grounds of my belief as to all matters not stated upon my own knowledge are as follows:
................................................................
Sworn to before me on Be namesignedmustbeprintedbeneath
STATE OF NEW YORK, COUNTY OF ss.: ormore manoneboxis check-indicateafternamestypeof serviceused.)
I, the undersigned, being sworn, say: I am not a party to the action, am over 18 years of age and reside at
On I served the within
O se persons at the last known address set forth after each name below.
by mailing a copy to each of the following
by delivering a true copy of each personally to each person named below at the address indicated. I knew each person served
= O servcean to be the person mentioned and described in said papers as a party therein:
by transmitting a copy to the following persons by O FAX at the telephone number set forth after each name below O E-MAIL
a O Electronic at the E-Mail address set forth after each name below, which was designated by the attorney for such purpose, and by mailing a
copy to the address set forth after each name.
6 O oeilvery by dispatching a copy by overnight delivery to each of the following persons at the last known address set forth after each
8'"©°
name below.
Sworn to before me on
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FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
Index No. Year RJI No. Hon.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
EDNA OTTON,
Plaintiff
-against-
BRYAN SAZO and GERBER SAZO,
Defendants.
SUMMONS AND COMPLAINT
DECOLATOR, COHEN, & DIPRISCO, LLP
ATTORNEYS AT LAW
Attorneys for
Plaintiff
Office and Post Office Address, Telephone
1399 Franklin Avenue " Suite 300
GARDEN CITY, NEW YORK 11530
TEL: (516) 742-6575
FAX: (516) 742-6706
Signature (Rule 1 0- .1-a)
To
Attorney(s) for Decolator, Cohen & DiPrisco, LLP
Service of a copy of the within is hereby admitted.
Dated,
................................................................
Attorney(s) for
Please take notice
NOTICEOF ENTRY
thatthe within is a (certified) true copy of a
duly entered in the office of the clerk of the within named court on
NOTICEOF SETTLEMENT
that an order of which the within is a true copy will be presented for
settlement to the HON. one of the judges
of the within named court, at
on at M
Dated,
Yours, etc.
DECOLATOR, COHEN, & DIPRISCO, LLP
ATTORNEYS AT LAW
To Attorneys for
Office and Post Office Address
Attorney(s) for " Suite
1399 Franklin Avenue 300
GARDEN CITY, NEW YORK 11530
1501-DISTRIBUTEDBYBlumbergÇxcelsIorInc.. Nye soons
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Preview
FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ________________________________________________________________________Ç EDNA OTTON, SUMMONS Plaintiff, Index No.: -against- Date Filed: BRYAN SAZO and GERBER SAZO, Defendants. ________________________________________________________________________Ç TO THE ABOVE NAMED DEFENDANT(s): YOU ARE HEREBY SUMMONED to answer the complaint in this action by serving an plaintiffs' answer, or notice of appearance, on the attorneys within 20 days after the service of this summons, exclusive of the day of service, or within 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. Plaintiff designates Suffolk County as the place of venue based on plaintiff's place of residence. Dated: Garden City, New York April 11, 2024 Yours, etc. Decolator, Cohen & DiPrisco, LLP Attorneys for Plaintiff 1399 Franklin Avenue, Suite 300 Garden City, New York 11530 (516) 742-6575 DEFENDANTS' ADDRESSES: BRYAN SAZO GERBER SAZO 140 East Avenue 91 Wood Road Trail Flanders, New York 11901 Flanders, New York I1901 1 of 9 FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ------------------------------------------------------------------------X Index No.: EDNA OTTON, Plaintiff, VERIFIED -against- COMPLAINT BRYAN SAZO and GERBER SAZO, Defendants. ______________------____________....______________________________________Ç Plaintiff, by her attorneys, Decolator, Cohen & DiPrisco, LLP, as and for her Verified Complaint, respectfully alleges, upon information and belief, as follows: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF PLAINTIFF 1. At all times hereinafter mentioned, plaintiff was and still is a resident of the County of Suffolk, State of New York. 2. At all times hereinafter mentioned, plaintiff was a police officer employed by the New York State Police Department, and was acting within the scope and furtherance of her duties as a police officer. 3. Upon information and belief, at all times hereinafter mentioned, defendant, BRYAN SAZO, was and still is a resident of the County of Suffolk, State of New York. 4. Upon information and belief, at all times hereinafter mentioned, defendant, GERBER SAZO, was and still is a resident of the County of Suffolk, State of New York. 5. Upon information and belief, at all times hereinafter mentioned, the defendant, GERBER SAZO, owned a certain 2004 Ford motor vehicle, bearing New York registration number KWB6843. 2 of 9 FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 6. That all times hereinafter mentioned, the defendant, BRYAN SAZO, operated and controlled a certain 2004 Ford motor vehicle, bearing New York registration number KWB6843. 7. That at all times hereinafter mentioned, the defendant, BRYAN SAZO, operated and controlled the said motor vehicle with the express and/or implied permission and consent of the owner/defendant, GERBER SAZO, thereof. 8. At all times hereinafter mentioned, New York State Police Department, was the owner of a certain 2022 Dodge motor vehicle, bearing New York State Police Department registration number POLICE. 9. That at all times hereinafter mentioned, Plaintiff, EDNA OTTON, operated and controlled a certain 2022 Dodge motor vehicle, bearing New York State Police Department registration number POLICE. 10. That at all times hereinafter mentioned, Plaintiff, EDNA OTTON, operated the aforesaid motor vehicle with the expressed and/or implied consent and permission of the owner, New York State Police Department, thereof. 11. On or about April 6, 2023, at or about Montauk Highway with its intersection at County Road 31, County of Suffolk, City and State of New York, were and still are public highways. 12. At the time and place aforesaid, the vehicle operated by defendant, BRYAN SAZO and owned by defendant, GERBER SAZO, and the vehicle which the plaintiff operated were in contact. 3 3 of 9 FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 13. On or about April 6, 2023, at approximately 4:18 p.m., thereof, while the plaintiff was lawfully and properly operating her vehicle at the location of Montauk Highway at County Road 31, County of Suffolk, State of New York, defendant, BRYAN SAZO, at the time operated the vehicle in such negligent and careless fashion as to cause a collision to occur, causing severe personal injuries to the plaintiff. 14. The said collision was caused solely and wholly by reason of the negligence and carelessness of the defendants, with no fault or culpable conduct on the part of the plaintiff contributing thereto. 15. The said defendants, so negligently and carelessly owned, managed, operated and controlled the said motor vehicle, that without any negligence or fault on the part of the plaintiff, defendants' and solely by reason of the negligence and carelessness of said defendants, motor vehicle suddenly came into violent contact with the plaintiff s vehicle and, as a result, the plaintiff sustained the injuries hereinafter described. 16. Plaintiff has sustained serious injuries as same are defined in Subdivision (d) of Section 5102 of the Insurance Law of the State of New York and economic loss greater than basic loss as defined in said section of the law. 17. This action falls within one or more of the exceptions set forth in CPLR Section 1601 and 1602. defendants' 18. As a result of negligence as aforesaid, plaintiff was severely injured both internally and externally, that plaintiff became sick, sore, lame and disabled, and has suffered great pain, shock and mental anguish and will continue to suffer for a long time to come and, upon information and belief, has been permanently injured; that by reason of the foregoing, 4 4 of 9 FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 the plaintiff, has been obligated to and did necessarily employ medical aid and medicines in an attempt to cure said injuries; that plaintiff was incapacitated from work by reason, and by reason of said disabilities plaintiff lost wages, salary and earnings all to plaintiff's damage in an amount in excess of the maximum monetary jurisdiction of all lower Courts. 19. Solely by reason of the foregoing, plaintiff has sustained damages in an amount in excess of the maximum monetary jurisdiction of all lower courts. AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF PLAINTIFF AS AGAINST DEFENDANTS 20. The plaintiff repeats, reiterates and realleges all of the facts set forth in "1" "19" paragraphs numbered through inclusive with the same force and effect as though more fully set forth herein. 21. At all times hereinafter mentioned, plaintiff was a police officer employed by the New York City Police Department, and was acting within the scope and furtherance of his duties as a police officer, 22. Defendants, were negligent in that the said defendants did own, operate, maintain, supervise and control said motor vehicle in a dangerous, negligent, reckless and careless fashion, including but not limited to the following: failed to exercise proper, reasonable and prudent control over said motor vehicle; did operate the said motor vehicle in a reckless, careless and negligent manner; operated the said motor vehicle at a dangerous, reckless, careless and negligent rate of speed; failed to properly control the speed of the said motor vehicle; failed to properly check the speed of the said motor vehicle; failed and omitted to operate the said motor vehicle at a speed that was reasonable and prudent under the conditions then and there existent; 5 5 of 9 FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 failed and omitted to give due regard to the actual and potential hazards then and there existent; failed to properly bring the said motor vehicle to a halt; failed to properly control the said motor vehicle; failed to yield the right of way; failed to yield to an emergency vehicle; operated the said motor vehicle in an unskillful manner; operating a vehicle without a proper license; failed to keep to the right; failed to properly apply the brakes to the said motor vehicle; failed to observe the plaintiff; failed to warn the plaintiff upon approach; failed to properly and prudently observe the road, roadway and traffic conditions then and there existent; failed to properly and prudently maintain the said motor vehicle; failed to avoid the happening of the accident complained of; operated the said motor vehicle in a dangerous, illegal, and unsafe fashion; failed to observe the traffic conditions and traffic control devices, signs and signals; failed to stop; failed to slow down and stop; failing to see what ought to be seen; made an improper left hand turn; failed to signal; failed to honk its horn; failed to observe, obey and give due regard for the rules of the road; in failing to stop; operating the vehicle with a revoked license; driving without a license; disregarded traffic signals, signs and devices; the defendants further neglected, omitted and/or were willfully and/or culpably negligent in failing to comply with Vehicle and Traffic Law Sections 1144(a), 509, 1160, I141, 116, 388, 1140, 1128, 1180(a), 1212, 375, 1144, 1144a-a, 1140, 1141. The Court will take judicial notice of all rules, violations, laws, codes and statutes violated at the time of trial. 23. Solely by reason of the foregoing, plaintiff asserts a cause of action against the defendant under Section 205-e of the General Municipal Law of the State of New York and a General Obligations Law Section 11-106 claim. 6 6 of 9 FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 24. Solely by reason of the foregoing, plaintiff has sustained damages in an amount in excess of the maximum monetary jurisdiction of all lower courts of the State of New York. WHEREFORE, plaintiff demands judgment against defendants in the First, and Second Causes of Action in an amount in excess of the maximum monetary jurisdiction of all lower Courts of the State of New York, together with the interest, costs and disbursements of this action. Dated: Garden City, New York April 11, 2024 Yours, etc. Decolator, Cohen & DiPrisco, LLP Attorneys for Plaintiff 1399 Franklin Avenue, Suite 300 Garden City, New York 11530 (516) 742-6575 7 7 of 9 FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 C 1995 BlumbergEfcelsior. Inc. STATE OF NEW YORK, COUNTY OF 33 NASSAU I, the undersigned, an attorney admitted to practice in the courts of New York State, O certification certify that the within ByAttorney has been compared by me with the original and found to be a true and complete copy. PO d' Attomey's state that I am Affirmation . the attorney(s) of record for Plamtiff in the within action; I have read the foregoing Summons and Complaint and know the contents thereof; the same is true to my own knowledge, except as to the matters therein alleged to be on information and belief, and as to those matters I believe it to be true. The reason this verification is made by me and not by plaintiff iS because the plaintiff resides in a county other than the one in which your deponent maintains his office. The grounds of my belief as to all matters not stated upon my own knowledge are as follows: conversations with plaintiff and office records. I affirm that the foregoing statements are true, under the penalties of perjury. Dated. he namesigned mustbeprintedbeneath STATE OF NÎ h ,i&WFSy yprk; April 11, 2024 ss Decolator, Cohen & DiPrisco, LLP I, the undersigned, being duly sworn, depose and say: I am O a "a in the action; I have read the foregoing and know the contents thereof; the same is true to my own knowledge, except as to the matters therein stated to be alleged on information and belief, and as to those matters I believe it to be true. Corporate the of a Verification a corporation and a party in the within action; I have read the foregoing and know the contents thereof; and the same is true to my own knowledge, except as to the matters therein stated to be alleged upon information and belief, and as to those matters I believe it to be true. This verification is made by me because the above party is a corporation and I am an officer thereof. The grounds of my belief as to all matters not stated upon my own knowledge are as follows: ................................................................ Sworn to before me on Be namesignedmustbeprintedbeneath STATE OF NEW YORK, COUNTY OF ss.: ormore manoneboxis check-indicateafternamestypeof serviceused.) I, the undersigned, being sworn, say: I am not a party to the action, am over 18 years of age and reside at On I served the within O se persons at the last known address set forth after each name below. by mailing a copy to each of the following by delivering a true copy of each personally to each person named below at the address indicated. I knew each person served = O servcean to be the person mentioned and described in said papers as a party therein: by transmitting a copy to the following persons by O FAX at the telephone number set forth after each name below O E-MAIL a O Electronic at the E-Mail address set forth after each name below, which was designated by the attorney for such purpose, and by mailing a copy to the address set forth after each name. 6 O oeilvery by dispatching a copy by overnight delivery to each of the following persons at the last known address set forth after each 8'"©° name below. Sworn to before me on 8 of 9 FILED: SUFFOLK COUNTY CLERK 04/16/2024 11:13 AM INDEX NO. 609755/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 Index No. Year RJI No. Hon. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK EDNA OTTON, Plaintiff -against- BRYAN SAZO and GERBER SAZO, Defendants. SUMMONS AND COMPLAINT DECOLATOR, COHEN, & DIPRISCO, LLP ATTORNEYS AT LAW Attorneys for Plaintiff Office and Post Office Address, Telephone 1399 Franklin Avenue " Suite 300 GARDEN CITY, NEW YORK 11530 TEL: (516) 742-6575 FAX: (516) 742-6706 Signature (Rule 1 0- .1-a) To Attorney(s) for Decolator, Cohen & DiPrisco, LLP Service of a copy of the within is hereby admitted. Dated, ................................................................ Attorney(s) for Please take notice NOTICEOF ENTRY thatthe within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on NOTICEOF SETTLEMENT that an order of which the within is a true copy will be presented for settlement to the HON. one of the judges of the within named court, at on at M Dated, Yours, etc. DECOLATOR, COHEN, & DIPRISCO, LLP ATTORNEYS AT LAW To Attorneys for Office and Post Office Address Attorney(s) for " Suite 1399 Franklin Avenue 300 GARDEN CITY, NEW YORK 11530 1501-DISTRIBUTEDBYBlumbergÇxcelsIorInc.. Nye soons 9 of 9