Preview
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
SUPREMECOURTOFTHESTATEOFNEWYORK Index No.:
COUNTYOFNASSAU Date of Purchase:
========================================Ç
WENDY MATIAS and FUNDADOR MATIAS, SUMMONS
Plaintiffs designate
Plaintiffs, NASSAU
County as place of trial
-against-
The basis of venue is:
ANDREAALEJANDRAPEREZ, Place of Occurrence:
Old Country Road approximately
Defendant. 100 feet East of Zeckendorf Blvd,
Westbury, NY
========================================Ç
To the above named defendant:
YOUAREHEREBYSUMMONED
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 Plaintiff s 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 NewYork); and in case of your failure to appear or
answer, judgment will be taken against you by default for the relief demanded herein.
Dated: Garden City, New York
May 17, 2024
Yours, etc.
CHOP &NO O, LLP
BY: SAMEER
CH PRA, ESQ.
Attorneys for Plaintiffs
100 Quentin Roosevelt Blvd
Unit 107
Garden City, NewYork 11530
(212) 868-3600
Our File No.: 2386.AN
To: Defendant's Address:
ANDREA
ALEJANDRAPEREZ
15 Juniper Rd
Apt A
Port Washington, NY 11050
1 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
SUPREMECOURTOFTHESTATEOF NEWYORK Index No.:
COUNTYOFNASSAU
========================================X Date of Purchase:
WENDY MATIAS and FUNDADOR MATIAS,
Plaintiffs, VERIFIED COMPLAINT
-against-
ANDREAALEJANDRAPEREZ,
Defendant.
Plaintiffs by their attorneys CHOPRA& NOCERINO,LLP., complaining of the defendants
herein, respectfully show to this court and alleges as follows:
1. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, owned a motor vehicle bearing
NewYork registration number KHT1357.
2. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, operated a motor vehicle bearing
NewYork registration number KHT1357.
3. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, maintained a motor vehicle
bearing NewYork registration number KHT1357.
4. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREA
ALEJANDRAPEREZ, managed a motor vehicle bearing
NewYork registration number KHT1357.
2 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
5. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREA
ALEJANDRAPEREZ, controlled a motor vehicle bearing
NewYork registration number KHT1357.
6. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, leased a motor vehicle bearing
NewYork registration number KHT1357.
7. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, rented a motor vehicle bearing
NewYork registration number KHT1357.
8. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, owned a dash camera within a
vehicle bearing NewYork registration number KHT1357.
9. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, operated a dash camera within a
vehicle bearing NewYork registration number KHT1357.
10. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREA
ALEJANDRAPEREZ, maintained a dash camera within a
vehicle bearing NewYork registration number KHT1357.
3 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
11. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, managed a dash camera within a
vehicle bearing New York registration number KHT1357.
12. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, controlled a dash camera within a
vehicle bearing New York registration number KHT1357.
13. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREA
ALEJANDRAPEREZ, had access to dash camera footage
taken from a vehicle bearing New York registration number KHT1357 and stored to an iCloud.
14. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREAALEJANDRAPEREZ, was acting within her scope of
employment at the time her vehicle came into contact with the plaintiff's vehicle.
15. That on April 21, 2024, and at all times hereinafter alleged, and upon information
and belief, the defendant ANDREA
ALEJANDRAPEREZwas employed by and/or acting on
behalf of her employer at the time of the accident.
16. That on April 21, 2024, and at all of the times hereinafter mentioned, at or on Old
Country Road approximately 100 feet East of Zeckendorf Blvd, in the Village of Westbury, in the
County of Nassau, in the State of NewYork, was and still is a public highway used extensively by
the public in general.
4 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
17. That on April 21, 2024, the plaintiff, WENDYMATIAS, was operating a vehicle
at the location hereinafter described.
18. That on April 21, 2024, the plaintiff, FUNDADOR
MATIAS, was a passenger in a
vehicle at the location hereinafter described.
19. That on April 21, 2024, the plaintiff, FUNDADOR
MATIAS, was a passenger in a
vehicle operated by the plaintiff, WENDY
MATIAS.
20. That on April 21, 2024, at the aforesaid location, the aforesaid motor vehicle came
in contact with another vehicle.
21. That on April 21, 2024, at the aforesaid location, the aforesaid motor vehicle came
in contact with the plaintiff's vehicle.
22. That the aforesaid accident and injuries resulting therefrom were due solely and
wholly as a result of the careless and negligent manner in which the defendant owned, operated,
maintained, managed and controlled her motor vehicle without these plaintiffs in any way
contributing thereto.
23. That the aforesaid accident and injuries resulting therefrom were due solely and
wholly as a result of the careless and negligent manner in which the defendant maintained,
inspected, repaired, renovated and/or failed to repair or renovate the motor vehicle and/or parts
therein on the date of accident and prior to the date of accident.
5 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
24. That by reason of the foregoing and the negligence of the defendant, the plaintiff
WENDYMATIAS, was severely injured, bruised and wounded, suffered, still suffers and will
continue to suffer for some time physical pain and bodily injuries and became sick, sore, lame and
disabled and so remained for a considerable length of time.
25. That by reason of the foregoing and the negligence of the defendant, the plaintiff
FUNDADOR
MATIAS, was severely injured, bruised and wounded, suffered, still suffers and will
continue to suffer for some time physical pain and bodily injuries and became sick, sore, lame and
disabled and so remained for a considerable length of time.
26. That by reason of the foregoing, the plaintiff, WENDY
MATIAS, was compelled to
and did necessarily require medical aid and attention, and did necessarily pay and become liable
therefor for medicines and upon information and belief, the plaintiff, WENDY
MATIAS, will
necessarily incur similar expenses.
27. That by reason of the foregoing, the plaintiff, FUNDADOR
MATIAS, was
compelled to and did necessarily require medical aid and attention, and did necessarily pay and
become liable therefor for medicines and upon information and belief, the plaintiff, FUNDADOR
MATIAS, will necessarily incur similar expenses.
28. That by reason of the foregoing, the plaintiff, WENDYMATIAS, has been unable
to attend to her usual occupation in the manner required.
29. That by reason of the foregoing, the plaintiff, FUNDADOR
MATIAS, has been
unable to attend to his usual occupation in the manner required.
6 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
30. That by reason of the wrongful, negligent and unlawful actions of the defendant, as
aforesaid, the plaintiff, WENDYMATIAS, sustained serious injuries as defined in Section 5102(d)
of the Insurance Law of The State of NewYork, and has sustained economic loss greater than basic
economic loss as defined in Section 5102 of the said Insurance Law.
31. That by reason of the wrongful, negligent and unlawful actions of the defendant, as
aforesaid, the plaintiff, FUNDADOR
MATIAS, sustained serious injuries as defined in Section
5102(d) of the Insurance Law of The State of New York, and has sustained economic loss greater
than basic economic loss as defined in Section 5102 of the said Insurance Law.
32. That one or more of the exceptions of §1602 of the Civil Practice Law and Rules do
apply to the within action.
33. That as a result of the foregoing, the plaintiff, WENDYMATIAS, was damagedin
an amount exceeds the jurisdictional limits of the lower courts.
34. That as a result of the foregoing, the plaintiff, FUNDADOR
MATIAS, was
damagedin an amount exceeds the jurisdictional limits of the lower courts.
WHEREFORE,
plaintiffs demandjudgment against the defendant on each cause of action in
the amount that exceeds the jurisdictional limits of the lower courts, all together with cost and
disbursements of this action.
Dated: Garden City, NewYork
May 17, 2024
7 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
CHOP & O O, LLP.
BY:
VAMEERC RA, ESQ.
Attorneys for Plaintiffs
100 Quentin Roosevelt Blvd, Suite 107
Garden City, NewYork 11530
(212) 868-3600
File No.: 2386.AN
8 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
STATEOFNEWYORK, COUNTY
OFNASSAU ss:
I, the undersigned,an attomey admitted to practice in the courts of New York State, stateunder
penalty of perjury that I am one of the attorneys for the Plaintiffs in the within action; I have read
the foregoing VERIFIED ANDCOMPLAINTand
SUMMONS 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 to be true. The reason this verification is
made by me and not by my clients, is that my are not presently
clients County where I
in the
maintain my offices. The grounds of my belief as to all matters not stated upon my own knowledge
are the materials in my file and the investigations conducted by my office.
Dated: Garden City, NewYork
May 17, 2024
Sameer Chopra
9 of 10
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024
Index No.:
SUPREMECOURTOF THESTATE OFNEWYORK
COUNTYOFNASSAU
==---=-----===============================
WENDY
MATIASand FUNDADOR
MATIAS,
Plaintiffs,
-against-
ANDREAALEJANDRAPEREZ,
Defendant.
===============--=====================
SUMMONS ANDVERIFIED COMPLAINT
____________________________________________
CHOPRA& NOCERINO,LLP
Attorneys for Plaintiffs
Office and Post Office Address, Telephone
100 Quentin Roosevelt Blvd
Unit 107
Garden City, NewYork 11530
212-868-3600
====---=======--===---================---
...
10 of 10
Preview
FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 SUPREMECOURTOFTHESTATEOFNEWYORK Index No.: COUNTYOFNASSAU Date of Purchase: ========================================Ç WENDY MATIAS and FUNDADOR MATIAS, SUMMONS Plaintiffs designate Plaintiffs, NASSAU County as place of trial -against- The basis of venue is: ANDREAALEJANDRAPEREZ, Place of Occurrence: Old Country Road approximately Defendant. 100 feet East of Zeckendorf Blvd, Westbury, NY ========================================Ç To the above named defendant: YOUAREHEREBYSUMMONED 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 Plaintiff s 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 NewYork); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein. Dated: Garden City, New York May 17, 2024 Yours, etc. CHOP &NO O, LLP BY: SAMEER CH PRA, ESQ. Attorneys for Plaintiffs 100 Quentin Roosevelt Blvd Unit 107 Garden City, NewYork 11530 (212) 868-3600 Our File No.: 2386.AN To: Defendant's Address: ANDREA ALEJANDRAPEREZ 15 Juniper Rd Apt A Port Washington, NY 11050 1 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 SUPREMECOURTOFTHESTATEOF NEWYORK Index No.: COUNTYOFNASSAU ========================================X Date of Purchase: WENDY MATIAS and FUNDADOR MATIAS, Plaintiffs, VERIFIED COMPLAINT -against- ANDREAALEJANDRAPEREZ, Defendant. Plaintiffs by their attorneys CHOPRA& NOCERINO,LLP., complaining of the defendants herein, respectfully show to this court and alleges as follows: 1. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, owned a motor vehicle bearing NewYork registration number KHT1357. 2. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, operated a motor vehicle bearing NewYork registration number KHT1357. 3. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, maintained a motor vehicle bearing NewYork registration number KHT1357. 4. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREA ALEJANDRAPEREZ, managed a motor vehicle bearing NewYork registration number KHT1357. 2 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 5. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREA ALEJANDRAPEREZ, controlled a motor vehicle bearing NewYork registration number KHT1357. 6. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, leased a motor vehicle bearing NewYork registration number KHT1357. 7. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, rented a motor vehicle bearing NewYork registration number KHT1357. 8. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, owned a dash camera within a vehicle bearing NewYork registration number KHT1357. 9. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, operated a dash camera within a vehicle bearing NewYork registration number KHT1357. 10. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREA ALEJANDRAPEREZ, maintained a dash camera within a vehicle bearing NewYork registration number KHT1357. 3 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 11. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, managed a dash camera within a vehicle bearing New York registration number KHT1357. 12. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, controlled a dash camera within a vehicle bearing New York registration number KHT1357. 13. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREA ALEJANDRAPEREZ, had access to dash camera footage taken from a vehicle bearing New York registration number KHT1357 and stored to an iCloud. 14. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREAALEJANDRAPEREZ, was acting within her scope of employment at the time her vehicle came into contact with the plaintiff's vehicle. 15. That on April 21, 2024, and at all times hereinafter alleged, and upon information and belief, the defendant ANDREA ALEJANDRAPEREZwas employed by and/or acting on behalf of her employer at the time of the accident. 16. That on April 21, 2024, and at all of the times hereinafter mentioned, at or on Old Country Road approximately 100 feet East of Zeckendorf Blvd, in the Village of Westbury, in the County of Nassau, in the State of NewYork, was and still is a public highway used extensively by the public in general. 4 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 17. That on April 21, 2024, the plaintiff, WENDYMATIAS, was operating a vehicle at the location hereinafter described. 18. That on April 21, 2024, the plaintiff, FUNDADOR MATIAS, was a passenger in a vehicle at the location hereinafter described. 19. That on April 21, 2024, the plaintiff, FUNDADOR MATIAS, was a passenger in a vehicle operated by the plaintiff, WENDY MATIAS. 20. That on April 21, 2024, at the aforesaid location, the aforesaid motor vehicle came in contact with another vehicle. 21. That on April 21, 2024, at the aforesaid location, the aforesaid motor vehicle came in contact with the plaintiff's vehicle. 22. That the aforesaid accident and injuries resulting therefrom were due solely and wholly as a result of the careless and negligent manner in which the defendant owned, operated, maintained, managed and controlled her motor vehicle without these plaintiffs in any way contributing thereto. 23. That the aforesaid accident and injuries resulting therefrom were due solely and wholly as a result of the careless and negligent manner in which the defendant maintained, inspected, repaired, renovated and/or failed to repair or renovate the motor vehicle and/or parts therein on the date of accident and prior to the date of accident. 5 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 24. That by reason of the foregoing and the negligence of the defendant, the plaintiff WENDYMATIAS, was severely injured, bruised and wounded, suffered, still suffers and will continue to suffer for some time physical pain and bodily injuries and became sick, sore, lame and disabled and so remained for a considerable length of time. 25. That by reason of the foregoing and the negligence of the defendant, the plaintiff FUNDADOR MATIAS, was severely injured, bruised and wounded, suffered, still suffers and will continue to suffer for some time physical pain and bodily injuries and became sick, sore, lame and disabled and so remained for a considerable length of time. 26. That by reason of the foregoing, the plaintiff, WENDY MATIAS, was compelled to and did necessarily require medical aid and attention, and did necessarily pay and become liable therefor for medicines and upon information and belief, the plaintiff, WENDY MATIAS, will necessarily incur similar expenses. 27. That by reason of the foregoing, the plaintiff, FUNDADOR MATIAS, was compelled to and did necessarily require medical aid and attention, and did necessarily pay and become liable therefor for medicines and upon information and belief, the plaintiff, FUNDADOR MATIAS, will necessarily incur similar expenses. 28. That by reason of the foregoing, the plaintiff, WENDYMATIAS, has been unable to attend to her usual occupation in the manner required. 29. That by reason of the foregoing, the plaintiff, FUNDADOR MATIAS, has been unable to attend to his usual occupation in the manner required. 6 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 30. That by reason of the wrongful, negligent and unlawful actions of the defendant, as aforesaid, the plaintiff, WENDYMATIAS, sustained serious injuries as defined in Section 5102(d) of the Insurance Law of The State of NewYork, and has sustained economic loss greater than basic economic loss as defined in Section 5102 of the said Insurance Law. 31. That by reason of the wrongful, negligent and unlawful actions of the defendant, as aforesaid, the plaintiff, FUNDADOR MATIAS, sustained serious injuries as defined in Section 5102(d) of the Insurance Law of The State of New York, and has sustained economic loss greater than basic economic loss as defined in Section 5102 of the said Insurance Law. 32. That one or more of the exceptions of §1602 of the Civil Practice Law and Rules do apply to the within action. 33. That as a result of the foregoing, the plaintiff, WENDYMATIAS, was damagedin an amount exceeds the jurisdictional limits of the lower courts. 34. That as a result of the foregoing, the plaintiff, FUNDADOR MATIAS, was damagedin an amount exceeds the jurisdictional limits of the lower courts. WHEREFORE, plaintiffs demandjudgment against the defendant on each cause of action in the amount that exceeds the jurisdictional limits of the lower courts, all together with cost and disbursements of this action. Dated: Garden City, NewYork May 17, 2024 7 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 CHOP & O O, LLP. BY: VAMEERC RA, ESQ. Attorneys for Plaintiffs 100 Quentin Roosevelt Blvd, Suite 107 Garden City, NewYork 11530 (212) 868-3600 File No.: 2386.AN 8 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 STATEOFNEWYORK, COUNTY OFNASSAU ss: I, the undersigned,an attomey admitted to practice in the courts of New York State, stateunder penalty of perjury that I am one of the attorneys for the Plaintiffs in the within action; I have read the foregoing VERIFIED ANDCOMPLAINTand SUMMONS 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 to be true. The reason this verification is made by me and not by my clients, is that my are not presently clients County where I in the maintain my offices. The grounds of my belief as to all matters not stated upon my own knowledge are the materials in my file and the investigations conducted by my office. Dated: Garden City, NewYork May 17, 2024 Sameer Chopra 9 of 10 FILED: NASSAU COUNTY CLERK 05/22/2024 11:12 AM INDEX NO. 608873/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/22/2024 Index No.: SUPREMECOURTOF THESTATE OFNEWYORK COUNTYOFNASSAU ==---=-----=============================== WENDY MATIASand FUNDADOR MATIAS, Plaintiffs, -against- ANDREAALEJANDRAPEREZ, Defendant. ===============--===================== SUMMONS ANDVERIFIED COMPLAINT ____________________________________________ CHOPRA& NOCERINO,LLP Attorneys for Plaintiffs Office and Post Office Address, Telephone 100 Quentin Roosevelt Blvd Unit 107 Garden City, NewYork 11530 212-868-3600 ====---=======--===---================--- ... 10 of 10