Preview
FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOFSUFFOLK
---------------------------------------------------------------------X INDEXNO.:
VINAY MADISETTY, FILING DATE:
Plaintiff, SUMMONS
Plaintiff Designates
-against- Suffolk County as the
Place of Trial
The Basis of Venue is
COLLEENA. REHA, Plaintiff's Address
Defendant. Plaintiff resides at:
53 Maryland Street
----------------------------------------------------------------------X Dix Hills, NY 11746
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 Attorney 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 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.
Dated: Melville, NewYork
May 24, 2024
Defendant's address:
COLLEENA. REHA
33 GLEELANDSTREET
DEERPARK, NY 11729
BY: MICHAELR. SORCE,ESQ.
BRAGOLI& ASSOCIATES, P.C.
Attorneys for Plaintiff
VINAY MADISETTY
300 Broadhollow Road, Suite 100W
Melville, New York 11747
(631) 423-7755
1 of 7
FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOFSUFFOLK
----------------------------------------------------------------------X Index No.:
VINAY MADISETTY,
Filing date:
Plaintiff,
VERIFIED
-against- COMPLAINT
COLLEENA. REHA,
Defendant.
---------------------------------------------------------------------X
PLAINTIFF, by her attorneys, BRAGOLI& ASSOCIATES, P.C., complains of the
Defendant and alleges, upon information and belief, the following:
1. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA,
resided in the COUNTYOFSUFFOLKand State of NewYork, at the time of the occurrence.
2. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA, was
the registrant owner of a certain motor vehicle bearing New York State License Plate Number
JSC1726.
3. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA, was
operating a certain motor vehicle bearing New York State License Plate Number JSC1726.
4. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA, had
the duty and/or assumed the duty to properly own, control, manage, maintain, operate, inspect
and repair the aforesaid motor vehicle bearing New York State License Plate Number JSC1726.
5. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA,
breached his duty to properly own, control, manage, maintain, operate, inspect and repair the
aforesaid motor vehicle bearing New York State License Plate Number JSC1726.
6. That at all times hereinafter mentioned, the location in front of/near/adjacent to 33
2 of 7
FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
Gleeland Street, in the County and State of New York, were and are public roadways in common
usage.
7. That Plaintiff, VINAY MADISETTY, was the registrant owner of a certain
motor vehicle bearing New York State License Plate NumberKSM9293.
8. That Plaintiff, VINAY MADISETTY, was operating a certain motor vehicle
bearing NewYork State License Plate Number KSM9293.
9. That on or about April 4, 2022, the aforesaid motor vehicle bearing New York
License Plate Number HKP7204was involved in a motor vehicle accident.
10. That on or about April 4, 2022, the aforesaid motor vehicle owned and operated
by Defendant, COLLEENA. REHA, was in contact with the aforesaid motor vehicle owned
and operated by Plaintiff, VINAY MADISETTY.
11. That on or about April 4, 2022, the aforesaid motor vehicle owned and operated
by Defendant, COLLEENA. REHA, came into violent contact and collision with the motor
vehicle owned and operated by Plaintiff, VINAY MADISETTY.
12. That on or about April 4, 2022, the aforesaid motor vehicle owned and operated
by Defendant, COLLEENA. REHA, came into violent contact and collision with the motor
vehicle owned and operated by Plaintiff, VINAY MADISETTY, at the location in front
of/near/adjacent to 33 Gleeland Street, in the County and State of New York.
13. That as a result of the foregoing, Plaintiff, VINAY MADISETTY, sustained
certain severe personal injuries.
14. That the aforesaid collision and the injuries sustained by Plaintiff, VINAY
MADISETTY, was caused solely by reason of the negligence of the Defendant, and without any
negligence or fault on the part of the Plaintiff contributing thereto.
3 of 7
FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
15. That Defendant, COLLEEN A. REHA, was careless and negligent in the
ownership, operation, management, maintenance, inspection, supervision, repair and control of
his motor vehicle; in failing to look, in failing to see, in failing to be observant of the
surrounding circumstances; in operating the motor vehicle at a greater rate of speed than care
and caution would permit under the circumstances; in causing, allowing and permitting said
motor vehicle to strike and come in contact with another motor vehicle; in failing to take due
and proper notice of the presence of other vehicles on the roadway; in failing to make prompt,
proper and timely use of the steering and braking mechanisms of the motor vehicle; in failing to
observe the traffic signs and controls then and there in effect; in failing to yield the right of way;
in failing to proceed in a safe and proper manner; in failing to maintain the braking and steering
mechanisms of the motor vehicle in proper adequate condition and/or repair; in failing to give
any signal, sound or warning of the approach of the motor vehicle; in failing to exercise due care
and caution in the operation and control of the motor vehicle so as to have avoided this accident
and the injuries to the Plaintiff herein; in violating rules of the road, statutes, ordinances and/or
regulations; and Defendant was otherwise reckless, negligent and careless in the operation,
ownership, management, maintenance, inspection, supervision, repair and control of the
aforementioned motor vehicle.
16. That as a result of the foregoing, Plaintiff, VINAY MADISETTY, suffered a
serious injury as defined in Section 5102(d) of the Insurance Law of the State of NewYork.
18. That as a result of the foregoing, Plaintiff, VINAY MADISETTY, sustained
serious, severe and permanent personal injuries and was rendered sick, sore, lame and disabled;
Plaintiff, VINAY MADISETTY, was caused to suffer great physical pain, discomfort and
disability and will continue to suffer pain, discomfort and disability in the future; Plaintiff,
4 of 7
FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
VINAY MADISETTY, was caused to undergo medical care, aid and treatment, and may
continue to undergo medical care, aid and treatment for a long period of time to come in the
future; Plaintiff, VINAY MADISETTY, incurred large sums of expenses for medical care, aid
and attention and may continue to incur large sums of expenses for future medical care, aid and
attention; Plaintiff, VINAY MADISETTY, was further caused to become incapacitated from
and hindered in the progress of her usual pursuits, duties and activities and may continue to be
hindered in her pursuits, duties and activities for a long period of time to come in the future.
19. That as a result of the foregoing, Plaintiff, VINAY MADISETTY, has been
damaged by Defendant, COLLEENA. REHA, in an amount which exceeds the jurisdictional
limits of all lower courts which would otherwise have jurisdiction.
WHEREFORE,Plaintiff, VINAY MADISETTY, demands judgment against
Defendant, COLLEENA. REHA; together with the costs and disbursements of this action.
Dated: Melville, NewYork
May24, 2024
Yours e c.,
BY: MICHAELR. SORCE,ESQ.
BRAGOLI& ASSOCIATES, P.C.
Attomeys for Plaintiff
VINAY MADISETTY
300 Broadhollow Road, Suite 100W
Melville, New York 11747
(631) 423-7755
5 of 7
FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
VERIFICATION
STATEOFNEWYORK )
) ss.:
COUNTYOFSUFFOLK )
VINAY MADISETTY,being duly sworn states that he is the Plaintiff in this action and
that the foregoing VERIFIED COMPLAINTis true to his own knowledge, except as to matters
therein stated to be alleged on information and belief and as to those matters he believes them to
be true.
.
Vinay Madisetty (May 30, 2024 13:51 EDT)
VINAY MADISETTY
Sworn to methis day
of MG , 203j.
TARYPU C
JENNYY. MAGANA
NOTARY
PUBLIC, STATEOF NEWYORK
Registration No. 01MA6444804
Qualified in Nassau County
Commission Expires
12/05/2026
6 of 7
FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
COURTOF THESTATEOFNEWYORK
SUPREME
COUNTY
OF SUFFOLK
VINAY MADISETTY,
Plaintiff,
-against-
COLLEENA. REHA,
Defendant.
SUMMONS
and VERIFIED COMPLAINT
BRAGOLI& ASSOCIATES,P.C.
Attorneys for the Plaintiff
VINAYMADISE1TY
300 Broadhollow Road, Suite 100W
Melville, New York 11747
(631) 423-7755
To:>
Attorney(s) for>
Service of a copy of the within is hereby admitted.
Dated,
Attorney(s) for
Sir: - Please take notice
that the within is a true copy of a duly entered in the office of the clerk of the within named
court on
, 2024
Dated:
Attorney signature pursuant to Sec. 130-1.1-a of the
Rules of the Chief Administrator (22NYCRR)
Yours, etc.
BY: MICHAELR. SORCE, Q.
BRAGOLI& ASSOCIATES,P.C.
Attorneys for the Plaintif
300 Broadhollow Road, Suite 100W
Melville, New York 11747
(631) 423-7755
7 of 7
Preview
FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFSUFFOLK ---------------------------------------------------------------------X INDEXNO.: VINAY MADISETTY, FILING DATE: Plaintiff, SUMMONS Plaintiff Designates -against- Suffolk County as the Place of Trial The Basis of Venue is COLLEENA. REHA, Plaintiff's Address Defendant. Plaintiff resides at: 53 Maryland Street ----------------------------------------------------------------------X Dix Hills, NY 11746 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 Attorney 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 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. Dated: Melville, NewYork May 24, 2024 Defendant's address: COLLEENA. REHA 33 GLEELANDSTREET DEERPARK, NY 11729 BY: MICHAELR. SORCE,ESQ. BRAGOLI& ASSOCIATES, P.C. Attorneys for Plaintiff VINAY MADISETTY 300 Broadhollow Road, Suite 100W Melville, New York 11747 (631) 423-7755 1 of 7 FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFSUFFOLK ----------------------------------------------------------------------X Index No.: VINAY MADISETTY, Filing date: Plaintiff, VERIFIED -against- COMPLAINT COLLEENA. REHA, Defendant. ---------------------------------------------------------------------X PLAINTIFF, by her attorneys, BRAGOLI& ASSOCIATES, P.C., complains of the Defendant and alleges, upon information and belief, the following: 1. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA, resided in the COUNTYOFSUFFOLKand State of NewYork, at the time of the occurrence. 2. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA, was the registrant owner of a certain motor vehicle bearing New York State License Plate Number JSC1726. 3. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA, was operating a certain motor vehicle bearing New York State License Plate Number JSC1726. 4. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA, had the duty and/or assumed the duty to properly own, control, manage, maintain, operate, inspect and repair the aforesaid motor vehicle bearing New York State License Plate Number JSC1726. 5. That at all times hereinafter mentioned, Defendant, COLLEENA. REHA, breached his duty to properly own, control, manage, maintain, operate, inspect and repair the aforesaid motor vehicle bearing New York State License Plate Number JSC1726. 6. That at all times hereinafter mentioned, the location in front of/near/adjacent to 33 2 of 7 FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 Gleeland Street, in the County and State of New York, were and are public roadways in common usage. 7. That Plaintiff, VINAY MADISETTY, was the registrant owner of a certain motor vehicle bearing New York State License Plate NumberKSM9293. 8. That Plaintiff, VINAY MADISETTY, was operating a certain motor vehicle bearing NewYork State License Plate Number KSM9293. 9. That on or about April 4, 2022, the aforesaid motor vehicle bearing New York License Plate Number HKP7204was involved in a motor vehicle accident. 10. That on or about April 4, 2022, the aforesaid motor vehicle owned and operated by Defendant, COLLEENA. REHA, was in contact with the aforesaid motor vehicle owned and operated by Plaintiff, VINAY MADISETTY. 11. That on or about April 4, 2022, the aforesaid motor vehicle owned and operated by Defendant, COLLEENA. REHA, came into violent contact and collision with the motor vehicle owned and operated by Plaintiff, VINAY MADISETTY. 12. That on or about April 4, 2022, the aforesaid motor vehicle owned and operated by Defendant, COLLEENA. REHA, came into violent contact and collision with the motor vehicle owned and operated by Plaintiff, VINAY MADISETTY, at the location in front of/near/adjacent to 33 Gleeland Street, in the County and State of New York. 13. That as a result of the foregoing, Plaintiff, VINAY MADISETTY, sustained certain severe personal injuries. 14. That the aforesaid collision and the injuries sustained by Plaintiff, VINAY MADISETTY, was caused solely by reason of the negligence of the Defendant, and without any negligence or fault on the part of the Plaintiff contributing thereto. 3 of 7 FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 15. That Defendant, COLLEEN A. REHA, was careless and negligent in the ownership, operation, management, maintenance, inspection, supervision, repair and control of his motor vehicle; in failing to look, in failing to see, in failing to be observant of the surrounding circumstances; in operating the motor vehicle at a greater rate of speed than care and caution would permit under the circumstances; in causing, allowing and permitting said motor vehicle to strike and come in contact with another motor vehicle; in failing to take due and proper notice of the presence of other vehicles on the roadway; in failing to make prompt, proper and timely use of the steering and braking mechanisms of the motor vehicle; in failing to observe the traffic signs and controls then and there in effect; in failing to yield the right of way; in failing to proceed in a safe and proper manner; in failing to maintain the braking and steering mechanisms of the motor vehicle in proper adequate condition and/or repair; in failing to give any signal, sound or warning of the approach of the motor vehicle; in failing to exercise due care and caution in the operation and control of the motor vehicle so as to have avoided this accident and the injuries to the Plaintiff herein; in violating rules of the road, statutes, ordinances and/or regulations; and Defendant was otherwise reckless, negligent and careless in the operation, ownership, management, maintenance, inspection, supervision, repair and control of the aforementioned motor vehicle. 16. That as a result of the foregoing, Plaintiff, VINAY MADISETTY, suffered a serious injury as defined in Section 5102(d) of the Insurance Law of the State of NewYork. 18. That as a result of the foregoing, Plaintiff, VINAY MADISETTY, sustained serious, severe and permanent personal injuries and was rendered sick, sore, lame and disabled; Plaintiff, VINAY MADISETTY, was caused to suffer great physical pain, discomfort and disability and will continue to suffer pain, discomfort and disability in the future; Plaintiff, 4 of 7 FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 VINAY MADISETTY, was caused to undergo medical care, aid and treatment, and may continue to undergo medical care, aid and treatment for a long period of time to come in the future; Plaintiff, VINAY MADISETTY, incurred large sums of expenses for medical care, aid and attention and may continue to incur large sums of expenses for future medical care, aid and attention; Plaintiff, VINAY MADISETTY, was further caused to become incapacitated from and hindered in the progress of her usual pursuits, duties and activities and may continue to be hindered in her pursuits, duties and activities for a long period of time to come in the future. 19. That as a result of the foregoing, Plaintiff, VINAY MADISETTY, has been damaged by Defendant, COLLEENA. REHA, in an amount which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. WHEREFORE,Plaintiff, VINAY MADISETTY, demands judgment against Defendant, COLLEENA. REHA; together with the costs and disbursements of this action. Dated: Melville, NewYork May24, 2024 Yours e c., BY: MICHAELR. SORCE,ESQ. BRAGOLI& ASSOCIATES, P.C. Attomeys for Plaintiff VINAY MADISETTY 300 Broadhollow Road, Suite 100W Melville, New York 11747 (631) 423-7755 5 of 7 FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 VERIFICATION STATEOFNEWYORK ) ) ss.: COUNTYOFSUFFOLK ) VINAY MADISETTY,being duly sworn states that he is the Plaintiff in this action and that the foregoing VERIFIED COMPLAINTis true to his own knowledge, except as to matters therein stated to be alleged on information and belief and as to those matters he believes them to be true. . Vinay Madisetty (May 30, 2024 13:51 EDT) VINAY MADISETTY Sworn to methis day of MG , 203j. TARYPU C JENNYY. MAGANA NOTARY PUBLIC, STATEOF NEWYORK Registration No. 01MA6444804 Qualified in Nassau County Commission Expires 12/05/2026 6 of 7 FILED: SUFFOLK COUNTY CLERK 06/06/2024 12:38 PM INDEX NO. 613927/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 COURTOF THESTATEOFNEWYORK SUPREME COUNTY OF SUFFOLK VINAY MADISETTY, Plaintiff, -against- COLLEENA. REHA, Defendant. SUMMONS and VERIFIED COMPLAINT BRAGOLI& ASSOCIATES,P.C. Attorneys for the Plaintiff VINAYMADISE1TY 300 Broadhollow Road, Suite 100W Melville, New York 11747 (631) 423-7755 To:> Attorney(s) for> Service of a copy of the within is hereby admitted. Dated, Attorney(s) for Sir: - Please take notice that the within is a true copy of a duly entered in the office of the clerk of the within named court on , 2024 Dated: Attorney signature pursuant to Sec. 130-1.1-a of the Rules of the Chief Administrator (22NYCRR) Yours, etc. BY: MICHAELR. SORCE, Q. BRAGOLI& ASSOCIATES,P.C. Attorneys for the Plaintif 300 Broadhollow Road, Suite 100W Melville, New York 11747 (631) 423-7755 7 of 7