Preview
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
COURTOFTHE STATEOF NEWYORK
SUPREME
COUNTY
OF SUFFOLK
______----------------------______-___,----------------------------Ç
ALLISON GARELLE, Index No.:
Date Purchased:
Plaintiff,
-against-
SUMMONS
STEVEND. COMPTON,
Defendant.
---________-----------------------------------------------------Ç
To the above-named Defendant,
You are hereby summonedto answer the complaint in this action and to serve
a copy of your answer, or, if the complaint is not served with the
summons, to serve a
notice of appearance, on the Plaintiff's Attorney(s) 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 summonsis 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.
The basis of the venue designated is the residence of the laintiff which is 28
Ripley Drive, Northport, NewYork 11768.
Dated: June 6, 2024
West Islip, New York EL PLLC
ttorne f r Plaintiff
ost Office ddress
212 'gble Lane
est Islip, New York 11795
(631) 669-3710
Defendant's address:
STEVEND. COMPTON
7 Gildare Road
East Northport, NewYork 11731
1
1 of 8
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
COURTOF THESTATEOFNEW
SUPREME YORK
COUNTY
OF SUFFOLK
__-________-_____---------.....----____-----___________---...--__-x
ALLISON GARELLE,
Index No.:
Plaintiff,
-against-
VERIFIED
COMPLAINT
STEVEND. COMPTON,
Defendant.
___-_________-..-----______---______---.------------________---------x
Plaintiff, ALLISON GARELLE,by her attorneys, LITE & RUSSELLPLLC, as
and for her Complaint, alleges as follows:
1. That at all times hereinafter mentioned, the plaintiff, ALLISON
GARELLE,was and still is a resident of the County of Suffolk and State of NewYork.
2. That Laurel Road, Village of Northport, Town of Brookhaven, County of
Suffolk, State of NewYork, was and still is a public roadway.
3. That upon information and belief, the motor vehicle accident that is the
subject of the lawsuit which occurred on March 21, 2024, involved the plaintiff,
ALLISON GARELLE,as operator and defendant, STEVEND. COMPTON,
as
operator and which occurred and/or near the roadways described in paragraph two (2)
above.
4. That on or about March 21, 2024, plaintiff, ALLISON GARELLEwas
the operator of a motor vehicle bearing NewYork license plate number GSG3460.
5. That on or about March 21, 2024 the defendant, STEVEND.
2
2 of 8
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
COMPTON,was the operator of a motor vehicle bearing New York license plate
number KWJ7251.
6. Upon information and belief, that on or about March 21, 2024,
defendant, STEVEND. COMPTON
was the title owner of a motor vehicle bearing
New York license plate number KWJ7251.
7. Upon information and belief, that on or about March 21, 2024, defendant
STEVEND. COMPTON,leased the motor vehicle bearing New York license plate
KWJ7251.
8. Upon information and belief, that on or about March 21, 2024, the
vehicle bearing NewYork license plate number KWJ7251 was registered to defendant,
STEVEND. COMPTON.
9. That on the aforementioned date and at the aforesaid place while plaintiff
was operating her motor vehicle as aforesaid, the defendant, STEVEND. COMPTON
carelessly, recklessly, and negligently operated and controlled their motor vehicle so as
to cause the same to collide with the vehicle operated by plaintiff.
10. That the occurrence and injuries which the plaintiff sustained thereby,
were caused by the carelessness, recklessness, and negligence of the defendant,
STEVEND. COMPTON.
11. That by reason of the carelessness, recklessness, and negligence of the
defendant, STEVEND. COMPTON,the plaintiff was rendered sick, sore, lame and
disabled; was severely injured both internally and externally; and has suffered great
pain, shock and mental anguish and will continue to suffer for a long time come and
3
3 of 8
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
upon information and belief has been permanently injured.
12, That by reason of the foregoing, the plaintiff was obliged to and did
necessarily employ hospital and medical aid and medicines in an attempt to cure herself
of the injuries sustained and have been prevented from performing her duties and will
be so prevented for a long time. That plaintiff may incur medical expenses not covered
by collateral sources which may cause plaintiff to incur out of pocket not covered by
collateral source.
13. That the plaintiff has sustained a serious injury as defined in Section
5102(2) of the Insurance Law and/or economic loss greater than basic economic loss as
defined in Sections 5102(a) and 5104 of the Insurance Law.
14. That as a result of the defendant's carelessness, recklessness, and
negligence, the plaintiff has sustained bodily injuries all to her damage in an amount
which exceeds the jurisdictional limits of all lower courts that would otherwise have
jurisdiction.
15. That this action falls within one or more of the exceptions set forth in
CPLRSection 1602.
16. That the causes of action alleged herein have merit and are not
frivolous.
17, That prior hereto no same of similar relief has been pursued on behalf of
the plaintiff against the defendant herein.
WHEREFORE,
plaintiff demands pecuniary judgment against the defendant in
amounts which exceeds the jurisdictional limits of all lower courts that would otherwise
have jurisdiction together with the costs and disbursements of this action.
4
4 of 8
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
Dated: West Islip, NewYork
June 6, 2024
LITE & RUSSELLPLLC
Justin N. Lite, Esq.
Attorney(s) for Plaintiff
212 Higbie Lane
West Islip, New York 11795
(631) 669-3710
5
5 of 8
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
CERTIFICATION
To the best of my
knowledge, infonnation and belief, nned after an inquiry reasonable
under the circumstances, the presentatio11of these pap 9 and the contentions
frivolous as defined in subsection herein are not
(c) of section 130-1 of 22 N.Y.C.R.R.
RJST . ITR ESQ
6 of 8
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
V ERIF I C A T I ON
STATEOFNEW
YORK )
) as.:
COUNTY
OFSUFFOLK )
_..___., being dulysworn, deposes and says:
Deponent s he Plain tif in the within
' action; deponent has read the
+ g b)M hiln and knows the contenta forego
thereof; the same is
deponents o wn knowledge, e cept as to the matters true to
therein stated to be alleged on
and belief, and as to those matters deponent believes infotolation
it to be true.
Sworn to b e Ene this
ay of . 20
Public
JUSTIE N UNNewYMk
NotatyPaobe,Stateof
7 of 8
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
Index No.;
SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOFSUFFOLK
ALLISONGARELLE,
Plaintiff,
-against-
STEVEND. COMPTON,
Defendant.
. .
SUMMONS
ANDVERIFIED COMPLAINT
LITE & RUSSELL, PLLC
Attorneys for Plaintiff
Office & Post Address, Telephone
Office
212 Higbie Lane
West Islip, NewYork 11795
(631) 669-3710
FAX (631) 669-3812
To Attorney(s) for Defendants
Service of a copy of the within is hereby admitted.
Dated,
Attorney(s) for Plaintiff
Sir: Please take notice
NOTICEOF ENTRY
That the within is a (certified) true copy of a duly entered in the office of the clerk of the within namedcourt on, 20_.
NOTICEOFSETTLEMENT
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
namedcourt, at on , 20 at .
Dated,
Yours, etc.
LITE & RUSSELL,PLLC
Attorneys for Plaintiff
Office & P.O.
Address
212 Higbie Lane
West Islip, New York 11795
8 of 8
Preview
FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 COURTOFTHE STATEOF NEWYORK SUPREME COUNTY OF SUFFOLK ______----------------------______-___,----------------------------Ç ALLISON GARELLE, Index No.: Date Purchased: Plaintiff, -against- SUMMONS STEVEND. COMPTON, Defendant. ---________-----------------------------------------------------Ç To the above-named Defendant, You are hereby summonedto answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with the summons, to serve a notice of appearance, on the Plaintiff's Attorney(s) 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 summonsis 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. The basis of the venue designated is the residence of the laintiff which is 28 Ripley Drive, Northport, NewYork 11768. Dated: June 6, 2024 West Islip, New York EL PLLC ttorne f r Plaintiff ost Office ddress 212 'gble Lane est Islip, New York 11795 (631) 669-3710 Defendant's address: STEVEND. COMPTON 7 Gildare Road East Northport, NewYork 11731 1 1 of 8 FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 COURTOF THESTATEOFNEW SUPREME YORK COUNTY OF SUFFOLK __-________-_____---------.....----____-----___________---...--__-x ALLISON GARELLE, Index No.: Plaintiff, -against- VERIFIED COMPLAINT STEVEND. COMPTON, Defendant. ___-_________-..-----______---______---.------------________---------x Plaintiff, ALLISON GARELLE,by her attorneys, LITE & RUSSELLPLLC, as and for her Complaint, alleges as follows: 1. That at all times hereinafter mentioned, the plaintiff, ALLISON GARELLE,was and still is a resident of the County of Suffolk and State of NewYork. 2. That Laurel Road, Village of Northport, Town of Brookhaven, County of Suffolk, State of NewYork, was and still is a public roadway. 3. That upon information and belief, the motor vehicle accident that is the subject of the lawsuit which occurred on March 21, 2024, involved the plaintiff, ALLISON GARELLE,as operator and defendant, STEVEND. COMPTON, as operator and which occurred and/or near the roadways described in paragraph two (2) above. 4. That on or about March 21, 2024, plaintiff, ALLISON GARELLEwas the operator of a motor vehicle bearing NewYork license plate number GSG3460. 5. That on or about March 21, 2024 the defendant, STEVEND. 2 2 of 8 FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 COMPTON,was the operator of a motor vehicle bearing New York license plate number KWJ7251. 6. Upon information and belief, that on or about March 21, 2024, defendant, STEVEND. COMPTON was the title owner of a motor vehicle bearing New York license plate number KWJ7251. 7. Upon information and belief, that on or about March 21, 2024, defendant STEVEND. COMPTON,leased the motor vehicle bearing New York license plate KWJ7251. 8. Upon information and belief, that on or about March 21, 2024, the vehicle bearing NewYork license plate number KWJ7251 was registered to defendant, STEVEND. COMPTON. 9. That on the aforementioned date and at the aforesaid place while plaintiff was operating her motor vehicle as aforesaid, the defendant, STEVEND. COMPTON carelessly, recklessly, and negligently operated and controlled their motor vehicle so as to cause the same to collide with the vehicle operated by plaintiff. 10. That the occurrence and injuries which the plaintiff sustained thereby, were caused by the carelessness, recklessness, and negligence of the defendant, STEVEND. COMPTON. 11. That by reason of the carelessness, recklessness, and negligence of the defendant, STEVEND. COMPTON,the plaintiff was rendered sick, sore, lame and disabled; was severely injured both internally and externally; and has suffered great pain, shock and mental anguish and will continue to suffer for a long time come and 3 3 of 8 FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 upon information and belief has been permanently injured. 12, That by reason of the foregoing, the plaintiff was obliged to and did necessarily employ hospital and medical aid and medicines in an attempt to cure herself of the injuries sustained and have been prevented from performing her duties and will be so prevented for a long time. That plaintiff may incur medical expenses not covered by collateral sources which may cause plaintiff to incur out of pocket not covered by collateral source. 13. That the plaintiff has sustained a serious injury as defined in Section 5102(2) of the Insurance Law and/or economic loss greater than basic economic loss as defined in Sections 5102(a) and 5104 of the Insurance Law. 14. That as a result of the defendant's carelessness, recklessness, and negligence, the plaintiff has sustained bodily injuries all to her damage in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction. 15. That this action falls within one or more of the exceptions set forth in CPLRSection 1602. 16. That the causes of action alleged herein have merit and are not frivolous. 17, That prior hereto no same of similar relief has been pursued on behalf of the plaintiff against the defendant herein. WHEREFORE, plaintiff demands pecuniary judgment against the defendant in amounts which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction together with the costs and disbursements of this action. 4 4 of 8 FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 Dated: West Islip, NewYork June 6, 2024 LITE & RUSSELLPLLC Justin N. Lite, Esq. Attorney(s) for Plaintiff 212 Higbie Lane West Islip, New York 11795 (631) 669-3710 5 5 of 8 FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 CERTIFICATION To the best of my knowledge, infonnation and belief, nned after an inquiry reasonable under the circumstances, the presentatio11of these pap 9 and the contentions frivolous as defined in subsection herein are not (c) of section 130-1 of 22 N.Y.C.R.R. RJST . ITR ESQ 6 of 8 FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 V ERIF I C A T I ON STATEOFNEW YORK ) ) as.: COUNTY OFSUFFOLK ) _..___., being dulysworn, deposes and says: Deponent s he Plain tif in the within ' action; deponent has read the + g b)M hiln and knows the contenta forego thereof; the same is deponents o wn knowledge, e cept as to the matters true to therein stated to be alleged on and belief, and as to those matters deponent believes infotolation it to be true. Sworn to b e Ene this ay of . 20 Public JUSTIE N UNNewYMk NotatyPaobe,Stateof 7 of 8 FILED: SUFFOLK COUNTY CLERK 06/06/2024 04:13 PM INDEX NO. 613961/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 Index No.; SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFSUFFOLK ALLISONGARELLE, Plaintiff, -against- STEVEND. COMPTON, Defendant. . . SUMMONS ANDVERIFIED COMPLAINT LITE & RUSSELL, PLLC Attorneys for Plaintiff Office & Post Address, Telephone Office 212 Higbie Lane West Islip, NewYork 11795 (631) 669-3710 FAX (631) 669-3812 To Attorney(s) for Defendants Service of a copy of the within is hereby admitted. Dated, Attorney(s) for Plaintiff Sir: Please take notice NOTICEOF ENTRY That the within is a (certified) true copy of a duly entered in the office of the clerk of the within namedcourt on, 20_. NOTICEOFSETTLEMENT 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 namedcourt, at on , 20 at . Dated, Yours, etc. LITE & RUSSELL,PLLC Attorneys for Plaintiff Office & P.O. Address 212 Higbie Lane West Islip, New York 11795 8 of 8