Preview
FILED: QUEENS COUNTY CLERK 10/05/2012 INDEX NO. 702367/2012
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/05/2012
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF QUEENS Date Purchased:
-X
LEONARD WATSON Plaintiff designates
Queens County as the
Plaintiff, place of trial.
-against- The basis of venue is:
Plaintiffs Residence
CHARLES THOMPSON, JR. and DONNA THOMPSON
Defendants. SUMMONS
_X Plaintiff resides at:
118-32 203rd Street
St. Albans, NY 11412
To the above named Defendant:
You are hereby summoned 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 Plaintiffs attorneys within twenty days after the service afthis summons,
exclusive of the day of service, where sendee is made by delivery upon you personally within the
state, or, within 30 days after completion of sendee where service is made in any other manner.
In case of your failure to appear or answer, judgment wiJJr-^e taken againsj/you by default for the
relief demanded in the complaint.
Dated: New York, New York
October 5, 2012
JAY^H.
LAW O-FFltES pF JAY H. TANENBAUM
Attorneys for Plaintiff
LEONARD WATSON
110 Wall Street, 16th Floor
New York, New York 10005
(212)422-1765
Our File No. 555-12J-0094
TO:
CHARLES THOMPSON, JR.
188-48 Woodhull Avenue
Hollis, NY 11423
DONNA THOMPSON
188-48 Woodhull Avenue
Hollis, NY 11423
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF QUEENS Date Purchased:
------------------------------------------ ........ -------------------- X
LEONARD WATSON VERIFIED COMPLAINT
Plaintiff,
-against-
CHARLES THOMPSON, JR. and DONNA THOMPSON
Defendants.
Plaintiff, by his attorneys, LAW OFFICES OF JAY H. TANENBAUM, complaining of
the Defendant, respectfully alleges, upon information and belief, as follows:
1. At all times herein mentioned, Plaintiff LEONARD WATSON was, and still is, a
resident of the County of Queens, State of New York.
2. At all times herein mentioned, Defendant CHARLES THOMPSON, JR. was, and
stillis a resident of the Count}' of Queens, State of New York.
3. At all times herein mentioned, Defendant DONNA THOMPSON, was and still is
a resident of the County of Queens, State of New York.
4. That on August 25, 2012, and at all times mentioned herein, Defendant CHARLES
THOMPSON, JR. owned the premises located at 188-48 Woodhull Avenue.
5. That on August 25, 2012, and at all times mentioned herein, Defendant DONNA
THOMPSON owned the premises located at 188-48 Woodhull Avenue
6. That on August 25, 2012, and at all times mentioned herein, Defendant CHARLES
THOMPSON, JR. operated, managed, maintained and controlled the aforesaid premises.
7. That on August 25, 2012, and at all times mentioned herein, Defendant DONNA
THOMPSON operated, managed, maintained and controlled the aforesaid premises.
8. That on August 25, 2012, and at all times mentioned herein, the Defendant
CHARLES THOMPSON, JR. owned a certain dog.
9. That on August 25, 2012, and at all times mentioned herein, the Defendant
DONNA THOMPSON owned a certain dog.
10. That on August 25, 2012, Defendant CHARLES THOMPSON, JR. managed and
controlled a certain dog at, near or about the above mentioned premises.
11. That on August 25, 2012, Defendant DONNA THOMPSON managed and
controlled a certain dog at, near or about the above mentioned premises.
12. That on August 25, 2012, and prior thereto, the aforesaid dog was known to
Defendant, CHARLES THOMPSON, JR, herein to be wild, unruly, vicious and possessed of a
ferocious nature and disposition with a propensity to attack other dogs and human beings.
13. That on August 25, 2012, and prior thereto, the aforesaid dog was known to
Defendant DONNA THOMPSON, herein to be wild, unruly, vicious and possessed of a
ferocious nature and disposition with a propensity to attack other dogs and human beings.
14. That on August 25, 2012, the Plaintiff LEONARD WATSON was lawfully
present at or near the premises 188-48 Woodhull Avenue, Hollis, New York, in the County of
Queens, State of New York.
15. That on August 25, 2012, while Plaintiff was lawfully present at the aforesaid
location, the aforesaid dog was caused, allowed and/or permitted to approach, menace, attack and
bite the Plaintiff causing him to be severely injured.
16. That the aforesaid occurrence, and the results thereof, were in no way caused by
any carelessness or negligence on the part of the Plaintiff, but were due solely and wholly to the
joint, several and/or concurrent negligence of the Defendants, their agents, servants, employees
and/or licensees in wrongfully and unlawfully causing, allowing and/or permitting said dog to
approach, menace and attack the Plaintiff; and in being otherwise careless, reckless and negligent.
17. That Defendants were negligent, careless and reckless and grossly negligent in the
ownership, operation, management, maintenance, supervision, use and control of the aforesaid dog
and the Defendants were otherwise negligent, careless and reckless in the premises.
18. That as a result of the foregoing, the Plaintiff LEONARD WATSON was caused
to sustain severe and permanent injuries, has suffered and will continue to suffer great pain, shock
and mental anguish, has incurred and will continue to incur expenses for medical care and
treatment, has been unable and will continue to be unable to attend to his normal duties and
pursuits with resultant loss thereby.
19. As a result of all of the foregoing, Plaintiff LEONARD WATSON was injured
and damaged in a sum which exceeds the jurisdictional limits of all lower courts which would
otherwise have jurisdiction.
WHEREFORE, Plaintiff demands judgment against the Defendants herein, in an
amount exceeding the jurisdictional limits of all lower courts which would otherwise have
jurisdiction, together with the costs and disbursements of this action'
Dated: New York, New York
October 5, 2012
Yours, etc.
JAY H. TANENB'AUM
LAW OFFICES ©F JAY H. TANENBAUM
Attorneys for Plaintiff
LEONARD WATSON
110 Wall Street, 16th Floor
New York, New York 10005
(212) 422-1765
Our File No. 555-12J-0094
ATTORNEY'S VERIFICATION
JAY H. TANENBAUM, an attorney duly admitted to practice before the Courts of the
State of New York, affirms the following to be true under the penalties of perjury: I am
an attorney at LAW OFFICES OF JAY H. TANENBAUM, attorneys of record for
Plaintiff,Leonard Watson. I have read the annexed COMPLAINT and know the contents
thereof, and the same are true to my knowledge, except those matters therein which are stated
to be alleged upon information and belief, and as to those matters I believe them to be true.
My belief, as to those matters therein not stated upon knowledge, is based upon facts, records,
and other pertinent information contained in my files. /
This verification is made by me because• Plaintiffs) is/are not presently in the county
wherein I maintain my offices.
DATED: New York, New York
October5, 2012
ENBAUM
No.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
LEONARD WATSON
Plaintiff,
-against-
CHARLES THOMPSON, JR. and DONNA THOMPSON
Defendants
SUMMONS AND COMPLAINT
LAW OFFICES OF JAY H. TANENBAUM
Attorney for PLAINTIFF
110 Wall Street, 16th Floor
New York, New York 10005
(212)422-176^
Fax No.: (212) 425-7492
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the
Courts of New York State, certified that, upon information arid belief and reasonable
inquiry, the contentions contained in the annexed document are not frivolous.
Dated: Octobers, 2012 Signature\
LAWO'FSICES OF JAY H. TANENBAUM
Preview
FILED: QUEENS COUNTY CLERK 10/05/2012 INDEX NO. 702367/2012 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/05/2012 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF QUEENS Date Purchased: -X LEONARD WATSON Plaintiff designates Queens County as the Plaintiff, place of trial. -against- The basis of venue is: Plaintiffs Residence CHARLES THOMPSON, JR. and DONNA THOMPSON Defendants. SUMMONS _X Plaintiff resides at: 118-32 203rd Street St. Albans, NY 11412 To the above named Defendant: You are hereby summoned 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 Plaintiffs attorneys within twenty days after the service afthis summons, exclusive of the day of service, where sendee is made by delivery upon you personally within the state, or, within 30 days after completion of sendee where service is made in any other manner. In case of your failure to appear or answer, judgment wiJJr-^e taken againsj/you by default for the relief demanded in the complaint. Dated: New York, New York October 5, 2012 JAY^H. LAW O-FFltES pF JAY H. TANENBAUM Attorneys for Plaintiff LEONARD WATSON 110 Wall Street, 16th Floor New York, New York 10005 (212)422-1765 Our File No. 555-12J-0094 TO: CHARLES THOMPSON, JR. 188-48 Woodhull Avenue Hollis, NY 11423 DONNA THOMPSON 188-48 Woodhull Avenue Hollis, NY 11423 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF QUEENS Date Purchased: ------------------------------------------ ........ -------------------- X LEONARD WATSON VERIFIED COMPLAINT Plaintiff, -against- CHARLES THOMPSON, JR. and DONNA THOMPSON Defendants. Plaintiff, by his attorneys, LAW OFFICES OF JAY H. TANENBAUM, complaining of the Defendant, respectfully alleges, upon information and belief, as follows: 1. At all times herein mentioned, Plaintiff LEONARD WATSON was, and still is, a resident of the County of Queens, State of New York. 2. At all times herein mentioned, Defendant CHARLES THOMPSON, JR. was, and stillis a resident of the Count}' of Queens, State of New York. 3. At all times herein mentioned, Defendant DONNA THOMPSON, was and still is a resident of the County of Queens, State of New York. 4. That on August 25, 2012, and at all times mentioned herein, Defendant CHARLES THOMPSON, JR. owned the premises located at 188-48 Woodhull Avenue. 5. That on August 25, 2012, and at all times mentioned herein, Defendant DONNA THOMPSON owned the premises located at 188-48 Woodhull Avenue 6. That on August 25, 2012, and at all times mentioned herein, Defendant CHARLES THOMPSON, JR. operated, managed, maintained and controlled the aforesaid premises. 7. That on August 25, 2012, and at all times mentioned herein, Defendant DONNA THOMPSON operated, managed, maintained and controlled the aforesaid premises. 8. That on August 25, 2012, and at all times mentioned herein, the Defendant CHARLES THOMPSON, JR. owned a certain dog. 9. That on August 25, 2012, and at all times mentioned herein, the Defendant DONNA THOMPSON owned a certain dog. 10. That on August 25, 2012, Defendant CHARLES THOMPSON, JR. managed and controlled a certain dog at, near or about the above mentioned premises. 11. That on August 25, 2012, Defendant DONNA THOMPSON managed and controlled a certain dog at, near or about the above mentioned premises. 12. That on August 25, 2012, and prior thereto, the aforesaid dog was known to Defendant, CHARLES THOMPSON, JR, herein to be wild, unruly, vicious and possessed of a ferocious nature and disposition with a propensity to attack other dogs and human beings. 13. That on August 25, 2012, and prior thereto, the aforesaid dog was known to Defendant DONNA THOMPSON, herein to be wild, unruly, vicious and possessed of a ferocious nature and disposition with a propensity to attack other dogs and human beings. 14. That on August 25, 2012, the Plaintiff LEONARD WATSON was lawfully present at or near the premises 188-48 Woodhull Avenue, Hollis, New York, in the County of Queens, State of New York. 15. That on August 25, 2012, while Plaintiff was lawfully present at the aforesaid location, the aforesaid dog was caused, allowed and/or permitted to approach, menace, attack and bite the Plaintiff causing him to be severely injured. 16. That the aforesaid occurrence, and the results thereof, were in no way caused by any carelessness or negligence on the part of the Plaintiff, but were due solely and wholly to the joint, several and/or concurrent negligence of the Defendants, their agents, servants, employees and/or licensees in wrongfully and unlawfully causing, allowing and/or permitting said dog to approach, menace and attack the Plaintiff; and in being otherwise careless, reckless and negligent. 17. That Defendants were negligent, careless and reckless and grossly negligent in the ownership, operation, management, maintenance, supervision, use and control of the aforesaid dog and the Defendants were otherwise negligent, careless and reckless in the premises. 18. That as a result of the foregoing, the Plaintiff LEONARD WATSON was caused to sustain severe and permanent injuries, has suffered and will continue to suffer great pain, shock and mental anguish, has incurred and will continue to incur expenses for medical care and treatment, has been unable and will continue to be unable to attend to his normal duties and pursuits with resultant loss thereby. 19. As a result of all of the foregoing, Plaintiff LEONARD WATSON was injured and damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. WHEREFORE, Plaintiff demands judgment against the Defendants herein, in an amount exceeding the jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with the costs and disbursements of this action' Dated: New York, New York October 5, 2012 Yours, etc. JAY H. TANENB'AUM LAW OFFICES ©F JAY H. TANENBAUM Attorneys for Plaintiff LEONARD WATSON 110 Wall Street, 16th Floor New York, New York 10005 (212) 422-1765 Our File No. 555-12J-0094 ATTORNEY'S VERIFICATION JAY H. TANENBAUM, an attorney duly admitted to practice before the Courts of the State of New York, affirms the following to be true under the penalties of perjury: I am an attorney at LAW OFFICES OF JAY H. TANENBAUM, attorneys of record for Plaintiff,Leonard Watson. I have read the annexed COMPLAINT and know the contents thereof, and the same are true to my knowledge, except those matters therein which are stated to be alleged upon information and belief, and as to those matters I believe them to be true. My belief, as to those matters therein not stated upon knowledge, is based upon facts, records, and other pertinent information contained in my files. / This verification is made by me because• Plaintiffs) is/are not presently in the county wherein I maintain my offices. DATED: New York, New York October5, 2012 ENBAUM No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS LEONARD WATSON Plaintiff, -against- CHARLES THOMPSON, JR. and DONNA THOMPSON Defendants SUMMONS AND COMPLAINT LAW OFFICES OF JAY H. TANENBAUM Attorney for PLAINTIFF 110 Wall Street, 16th Floor New York, New York 10005 (212)422-176^ Fax No.: (212) 425-7492 Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the Courts of New York State, certified that, upon information arid belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: Octobers, 2012 Signature\ LAWO'FSICES OF JAY H. TANENBAUM