Preview
FILED: RICHMOND COUNTY CLERK 02/28/2019 10:51 AM INDEX NO. 150453/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF RICHMOND Date of Purchase:
X
AMANDA FELTHAM, SUMMONS
Plaintiff, Plaintiff designates
RICHMOND
-against- as place of trial
County
ROBERT PETER MOUMBLOW, The basis of venue is:
Plaintiff s Residence
Defendants.
X Plaintiff Resides:
122 Hampton Place
Staten Island, NY
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, ifthe complaint is not served with this summons, to serve a notice of
appearance on the Plaintiffs 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 New York); and in case of your failure to appear or answer,
judgment will be taken against you by default for the relief demanded herein.
Dated: Brooklyn, New York
February 27, 2019
ANDREA M. ARRIGO, P.C.
ANDREA M. ARRI
Attorneys for Plaintiff
Address and Telephone Number
8118 13th Avenue
Brooklyn, New York 11228
718-680-0612
Defendant's Address:
ROBERT PETER MOUMBLOW
70 Domain Street
Staten Island, New York 10314
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF RICHMOND Date of Purchase:
X
AMANDA FELTHAM, VERIFIED COMPLAINT
Plaintiff,
-against-
ROBERT PETER MOUMBLOW,
Defendants.
-X
Plaintiff by her attorneys ANDREA M. ARRIGO, P.C., comp!±ln;; of the defendant
herein, respwfully show to this court and alleges as follows:
1. That at all times hereinafter alleged, plaintiff was and stillis a resident of the County
of RICHMOND, City and State of New York.
2. That on May 4, 2018, and upon information and belief, the defendant ROBERT
PETER MOUMBLOW, was the owner of a motor vehicle bearing New York liceme number
404EMT.
3. That on May 4, 2018, and upon information and belief, the defendant ROBERT
PETER MOUMBLOW, operated a motor vehicle bearing New York license number 404EMT.
4. That on May 4, 2018, and upon information and belief, the defendant ROBERT
PETER MOUMBLOW, m-in+-ined a motor vehicle bearing New York license number
404EMT.
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5. That on May 4, 2018, and upon information and belief, the defendant ROBERT
PETER MOUMBLOW, managed a motor vehicle bearing New York license number 404EMT.
6. That on May 4, 2018, and upon information and belief, the defendat ROBERT
PETER MOUMBLOW, controlled a motor vehicle bearing New York licence number 404EMT.
7. That at all of the times hereinafter mentioned, Lander Avenue at or near its
intersectioñ with Richmond Avenue, in the County of RICHMOND, City and State of New
York, was and still is a public highway used exteñsively by the public in general.
8. That on May 4, 2018, the plaintifE AMANDA FELTHAM, was a pedestrian at
the location hereinafter described.
9. That on May 4, 2018, at the aforesaid location, the aforesaid motor vehicle came
in contact with a pedestrian.
10. That on May 4, 2018, at the aforesaid location, the aforesaid motor vehicle came
in contact with the plaintiff, AMANDA FELTHAM.
11. That by reason of the foreguing and the negligence of the dafandant, the plaintiff,
AMANDA FELTHAM, was severely iñjured, 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.
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12. That by reason of the foregoing, the plaintiff, AMANDA FELTHAM, was
compell-1 to and did necessarily require medical aid and attertdon, and did necessarily pay and
become liable therefor for medicines and upon information and belief, the plaintiff, AMANDA
FELTHAM, will necessarily incur similar expenses.
13. That by reason of the foregoing, the plaintiff, AMANDA FELTHAM, has been
unable to attend to her usual occupation in the manner required.
14. That by reason of the wrongful, negligent and unlavâñ actions of the defendant,
as aforesaid, the plaintiff; AMANDA FELTHAM, sustaiñêd 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 ecanemic loss as defined in Section 5102 of the said Insurance Law.
15. That the aforesaid accident and iñjuries resultiñg therefrom were due solely and
wholly as a result of the careless and negligent maññct in which the defendant owned, operated,
maintai-ed and controlled his motor vehicle without this plaintiff in any way contributing
thereto.
16. That one or more of the provisions of §1602 of the Civil Practice Law and Rules
do apply to the within action.
17. That as a result of the foregoing, the plaintiff, AMANDA FELTHAM, sustained
damages in an amount in excess of the jurisdictional amounts of the lower Courts.
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WHEREFORE, plaintiff, AMANDA FELTHAM, demands judgment against the
defendants in an amount in excess of the jurisdictional amounts of the lower Courts, all together
with the costs and disbursements of this action.
Dated: Brooklyn, New York
February 27, 2019 ANDREA M. ARRIGO, P.C.
BY:
__ __ _ ____ _ __________________
ANDREA M. ARRI , ESQ.
Attorneys for Plaintiff
Address and Telephone Number
13*
8118 Avenue
Brooklyn, New York 11228
718-680-0612
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STATE OF NEW YORK, COUNTY OF KINGS ss:
I, the undersigned, an attorney admitted to practice in the courts of New York State, state under
penalty of perjury that I am one of the attorneys for the Plaintiffs 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 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 clients are not presently in the County where I maintain my
offices. The grounds of my belief as to all matters not stated upon my own knowledge are the
materials in my fileand the investigations conducted by my office.
Dated: Brooklyn, New York
February 27, 2019
AND A GO, ESQ.
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Index No.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
AMANDA FELTHAM,
Plaintiff,
-against-
ROBERT PETER MOUMBLOW,
Defendant.
SUMMONS AND VERIFIED COMPLAINT
ANDREA M. ARRIGO, P.C.
Attomeys for Plaintiffs
Office and Post Office Address, Telephone
8118 13th Avenue
Brooklyn, New York 11228
718-680-0612
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Preview
FILED: RICHMOND COUNTY CLERK 02/28/2019 10:51 AM INDEX NO. 150453/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF RICHMOND Date of Purchase: X AMANDA FELTHAM, SUMMONS Plaintiff, Plaintiff designates RICHMOND -against- as place of trial County ROBERT PETER MOUMBLOW, The basis of venue is: Plaintiff s Residence Defendants. X Plaintiff Resides: 122 Hampton Place Staten Island, NY 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, ifthe complaint is not served with this summons, to serve a notice of appearance on the Plaintiffs 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 New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein. Dated: Brooklyn, New York February 27, 2019 ANDREA M. ARRIGO, P.C. ANDREA M. ARRI Attorneys for Plaintiff Address and Telephone Number 8118 13th Avenue Brooklyn, New York 11228 718-680-0612 Defendant's Address: ROBERT PETER MOUMBLOW 70 Domain Street Staten Island, New York 10314 1 1 of 7 FILED: RICHMOND COUNTY CLERK 02/28/2019 10:51 AM INDEX NO. 150453/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF RICHMOND Date of Purchase: X AMANDA FELTHAM, VERIFIED COMPLAINT Plaintiff, -against- ROBERT PETER MOUMBLOW, Defendants. -X Plaintiff by her attorneys ANDREA M. ARRIGO, P.C., comp!±ln;; of the defendant herein, respwfully show to this court and alleges as follows: 1. That at all times hereinafter alleged, plaintiff was and stillis a resident of the County of RICHMOND, City and State of New York. 2. That on May 4, 2018, and upon information and belief, the defendant ROBERT PETER MOUMBLOW, was the owner of a motor vehicle bearing New York liceme number 404EMT. 3. That on May 4, 2018, and upon information and belief, the defendant ROBERT PETER MOUMBLOW, operated a motor vehicle bearing New York license number 404EMT. 4. That on May 4, 2018, and upon information and belief, the defendant ROBERT PETER MOUMBLOW, m-in+-ined a motor vehicle bearing New York license number 404EMT. 2 2 of 7 FILED: RICHMOND COUNTY CLERK 02/28/2019 10:51 AM INDEX NO. 150453/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019 5. That on May 4, 2018, and upon information and belief, the defendant ROBERT PETER MOUMBLOW, managed a motor vehicle bearing New York license number 404EMT. 6. That on May 4, 2018, and upon information and belief, the defendat ROBERT PETER MOUMBLOW, controlled a motor vehicle bearing New York licence number 404EMT. 7. That at all of the times hereinafter mentioned, Lander Avenue at or near its intersectioñ with Richmond Avenue, in the County of RICHMOND, City and State of New York, was and still is a public highway used exteñsively by the public in general. 8. That on May 4, 2018, the plaintifE AMANDA FELTHAM, was a pedestrian at the location hereinafter described. 9. That on May 4, 2018, at the aforesaid location, the aforesaid motor vehicle came in contact with a pedestrian. 10. That on May 4, 2018, at the aforesaid location, the aforesaid motor vehicle came in contact with the plaintiff, AMANDA FELTHAM. 11. That by reason of the foreguing and the negligence of the dafandant, the plaintiff, AMANDA FELTHAM, was severely iñjured, 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. 3 3 of 7 FILED: RICHMOND COUNTY CLERK 02/28/2019 10:51 AM INDEX NO. 150453/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019 12. That by reason of the foregoing, the plaintiff, AMANDA FELTHAM, was compell-1 to and did necessarily require medical aid and attertdon, and did necessarily pay and become liable therefor for medicines and upon information and belief, the plaintiff, AMANDA FELTHAM, will necessarily incur similar expenses. 13. That by reason of the foregoing, the plaintiff, AMANDA FELTHAM, has been unable to attend to her usual occupation in the manner required. 14. That by reason of the wrongful, negligent and unlavâñ actions of the defendant, as aforesaid, the plaintiff; AMANDA FELTHAM, sustaiñêd 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 ecanemic loss as defined in Section 5102 of the said Insurance Law. 15. That the aforesaid accident and iñjuries resultiñg therefrom were due solely and wholly as a result of the careless and negligent maññct in which the defendant owned, operated, maintai-ed and controlled his motor vehicle without this plaintiff in any way contributing thereto. 16. That one or more of the provisions of §1602 of the Civil Practice Law and Rules do apply to the within action. 17. That as a result of the foregoing, the plaintiff, AMANDA FELTHAM, sustained damages in an amount in excess of the jurisdictional amounts of the lower Courts. 4 4 of 7 FILED: RICHMOND COUNTY CLERK 02/28/2019 10:51 AM INDEX NO. 150453/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019 WHEREFORE, plaintiff, AMANDA FELTHAM, demands judgment against the defendants in an amount in excess of the jurisdictional amounts of the lower Courts, all together with the costs and disbursements of this action. Dated: Brooklyn, New York February 27, 2019 ANDREA M. ARRIGO, P.C. BY: __ __ _ ____ _ __________________ ANDREA M. ARRI , ESQ. Attorneys for Plaintiff Address and Telephone Number 13* 8118 Avenue Brooklyn, New York 11228 718-680-0612 5 5 of 7 FILED: RICHMOND COUNTY CLERK 02/28/2019 10:51 AM INDEX NO. 150453/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019 STATE OF NEW YORK, COUNTY OF KINGS ss: I, the undersigned, an attorney admitted to practice in the courts of New York State, state under penalty of perjury that I am one of the attorneys for the Plaintiffs 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 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 clients are not presently in the County where I maintain my offices. The grounds of my belief as to all matters not stated upon my own knowledge are the materials in my fileand the investigations conducted by my office. Dated: Brooklyn, New York February 27, 2019 AND A GO, ESQ. 6 6 of 7 FILED: RICHMOND COUNTY CLERK 02/28/2019 10:51 AM INDEX NO. 150453/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/28/2019 Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND AMANDA FELTHAM, Plaintiff, -against- ROBERT PETER MOUMBLOW, Defendant. SUMMONS AND VERIFIED COMPLAINT ANDREA M. ARRIGO, P.C. Attomeys for Plaintiffs Office and Post Office Address, Telephone 8118 13th Avenue Brooklyn, New York 11228 718-680-0612 7 7 of 7