Preview
FILED: FRANKLIN COUNTY CLERK 02/19/2019 09:29 AM INDEX NO. E2019-152
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/19/2019
STATE OF NEW YORK SUPREME COURT
COUNTY OF FRANKLIN
REBECCA CHARLAND,
Plaintiff, SUMMONS
-against- Index Number:
ADIRONDACK REGION CHIROPRACTIC, PC, and
JOHN FLEURY d/b/a FLEURY REAL ESTATE,
Defendants.
TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED to answer the Verified Complaint in this action and to
serve a copy of your answer, or,ifthe Verified Complaint is not served with this Summons, to serve
a notice of appearañce, on the Plaintiff's attorneys within twenty (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 reliefdemanded in
the Verified Complaint.
Dated: February 15, 2019. STAFFORD, OWENS, PILLER, MURNANE,
KELLEHER & TROMBLEY, PLLC
By:
M in R. Meyér, Esq.
ttorneys for Plaint
One Cumberlan venue
Post Office Box 2947
Plattsburgh, New York, 12901
(518) 561-4400
(518) 561-4848
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STATE OF NEW YORK SUPREME COURT
COUNTY OF FRANKLIN
REBECCA CHARLAND,
Plaintiff, VERIFIED
COMPLAINT
-against-
Index Number:
ADIRONDACK REGION CHIROPRACTIC, PC, and
JOHN FLEURY d/b/a FLEURY REAL ESTATE,
Defendants.
Plaintiff, Rebecca Charland, by and through her attorneys, Stafford, Owens, Piller,
Murnane, Kelleher & Trombley, does hereby respectfully show and allege as follows:
1. That at alltimes hereafter mentioned, the Plaintiff, Rebecca Charland, was a resident of
the Town of North Bangor, County of Franklin, and State of New York.
2. That upon information and belief, the Defendant, Adirondack Region Chiropractic, PC is
a professional corporation with a principal place of business at 9 Finney Blvd., Malone,
New York, 12953.
3. That upon information and belief, Defendant, John Fleury d/b/a Fleury Real Estate
maintains a principal place of business at 9 Finney Blvd., Malone, New York, 12953.
4. At alltimes hereafter mentioned, Adirondack Region Chiropractic leased, maintained,
and controlled certain real property located at 9 Finney Blvd., in the Town of Malone,
County of Franklin and State of New York.
5. Upon information and belief, at alltimes relevant hereto, Defendant, John Fleury, d/b/a
Fleury Real Estate, owned, occupied, maintained and controlled a certain real property
located at 9 Finney Blvd., Town of Malone, County of Franklin, State of New York.
6. Upon information and belief, the Defendants had a joint in several duty for the care,
maintenance, inspection and upkeep of the premises located at 9 Finney Blvd., Town of
Malone, County of Franklin, State of New York.
AS IN FOR A FIRST, SEPARATE AND DISTINCT CAUSE OF ACTION.
7. Plaintiff repeats and realleges each and every paragraph of this complaint numbered one
through six as if more fully set forth herein at length and with the same force and effect.
8. On or about February 22, 2016, the Plaintiff, Rebecca Charland, was lawfully present at
the premises at 9 Finney Blvd. and the office of Adirondack Region Chiropractic, PC,
when by reason of the negligence, carelessness and recklessness of the Defendants, the
STAFFORD • OWENS
PILLER· ·KELLEHER
MURNAN£ &TRUM8LEY,PLLC
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Plaintiff, Rebecca Charland was caused to slip and fall in the walkway/parking lot
thereof, causing her to sustain serious and severe injuries as hereinafter set forth.
9. Attached is a statement from Tracy A. Trudel, B.S.C, D.C., who upon information and
belief is a principal of Adirondack Region Chiropractic, PC, which states "Rebecca
Charland slipped and fell on the ice in the parking lot at 9 Finney Blvd., Malone, New
York on 2/22/16. She complained of severe pain in her leftshoulder. She was referred
for an x-ray and subsequently an MRI of her leftshoulder which revealed partial tears of
the supraspinatus tendon, bursitis of the subdeltoid bursa, moderate to severe edema in
the deltoid muscle with tear, a fusion of the glenoid humoral joint. She was referred for
therapy."
orthopedic consult with Dr. Bullock, who referred her for physical
10. Upon information and belief, the negligence of the Defendants consisted of the
following:
a. Failure to warn pedestrians lawfully present upon premises of the defective and
dangerous condition then and there existing;
b. Failing to inspect, repair, maintain or correct said dangerous and defective
conditions;
c. Failing to utilize proper measures and ensuring safe conditions on the walkway and
parking lot area of the said premises;
d. Failing to utilize measures to eliminate or alleviate the dangerous and defective
conditions on the premises;
e. Creating the said dangerous conditions by methods of maintenance used;
f. Failing to properly train employees, agents and/or servants in how to inspect and
maintain said premises in a safe condition;
g. Failing to erect signs, or in any manner warn of the dangerous and defective
conditions then and there existing;
h. In violating the statutes, town rules and regulations in such cases made and provided;
i. In their failure to use reasonable care to keep the walkway and parking lot in a safe
condition;
j. Creating said condition by utilizing inferior or defective materials and maintenance
of the area;
k. Creating said condition by utilizing improper and/or defective techniques in
maintaining the walkway and parking lot areas;
1. Failing to properly inspect and supervise the said walkway and parking lot areas;
m. In knowing that said property was in a dangerous and defective condition, and for
allowing an unreasonable length of time to pass in ensuring that said walkway was
maintained in a safe, proper and suitable condition;
n. In failing to provide adequate lighting for the walkways and parking lot areas;
STAFFORD • OWENS
PILLER-MEMANE.
EELLEREI
GTROMBLEY.PLLC
II
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0. In failing to repair a recurring situation of snow and/or ice accumulation on the
premises;
p. In failing to salt, sand or otherwise maintain the walkway and parking lot areas in a
safe and appropriate condition;
11. Upon information and belief, the Defendants had actual knowledge of the said defective
and dangerous condition or conditions or the same existed for such a period of time that
in the exercise of reasonable care, the Defendants should have had such knowledge.
12. The premises located at 9 Finney Blvd., Malone, New York, so-called, is located in the
Town of Malone, County of Franklin and State of New York was open for use by
members of the general public, and specifically patrons of Adirondack Region
Chiropractic, PC.
13. That the accident and injuries sustained by Plaintiff were caused solely and by reason of
negligence of the Defendant without any culpable conduct on the part of the Plaintiff
contributing thereto.
14. As a result of the negligence by the Defendants, the following injuries were either
caused, or alternatively, aggravated, accelerated, exacerbated, precipitated and otherwise
enhanced, the Plaintiff, Rebecca Charland, suffered serious and severe injuries, and was
rendered sick, sore, lame, and disabled; specifically, injuries included, but are not limited
to:
a. Suffered shock
b. Mental upset and mental embarrassments
c. Left shoulder pain
d. Loss of range of motion in left shoulder
e. Left shoulder stiffness
f. Partial tear of rotator cuff
g. Difficulty with flection of leftshoulder
h. Difficulty with abduction of left shoulder
i. Pain in the left shoulder
j. Weakness, damage to the tendon of the supraspinatus tendinosis in the left
shoulder
k. Partial thickness tear of the supraspinatus tendon
1. Edema within the leftdeltoid muscle
m. Mild arthrosis at the AC joint;
STAFFORD • OWENS
PILLER- *IELLENER
MBAHANE CTRGMBLET,PLLC
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15. At the aforesaid accident and injuries alleged herein were caused by the negligent,
wanton, reckless and careless acts of the Defendants, their agents, servants and/or
employees.
16. That the Limited Liability Provisions set forth in section 1601 of the CPLR do not apply
pursuant to one or more of the exceptions of CPLR section 1602
17. That as a result of this accident, the Plaintiff herein was caused to sustain severe and
serious personal injuries to her mind and body, the same of which, upon information and
belief, are permanent with the permanent effects of pain, disability, disfigurement and
loss of body function.
18. Further, this Plaintiff was caused to expend and become obligated for diverse sums of
money for the purposes of obtaining medical care and/or cure and in an effort to alleviate
the suffering and ills sustained as a result of this accident; the Plaintiff further was
caused to lose substantial periods of time from her normal vocation, and upon
information and belief, may continue in that way into the future and suffer similar losses.
19. By reason of the foregoing, this Plaintiff was damaged in a sum which exceeds the
jurisdictional limits of all lower courts which would have jurisdiction over this matter.
WHEREFORE, Plaintiff demands a judgment against the Defendant in a sum which exceeds the
jurisdictional limits of all lower courts which the jury would find to be fair, adequate and just
together with the costs and disbursements of this action.
Dated: February 15, 2019.
STAFFORD, OWENS, PILLER, MURNANE,
KELLEHER & TROMBLEY, PLLC
By:
u e er, E(q.
On Cumberland AvenuÓ
st Office Box 2947
Plattsburgh, New York, 12901
Phone: (518) 561-4400
Fax: (518) 561-4848
S S
I1
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VERIFICATION
STATE OF NEW YORK )
) ss.:
COUNTY OF CLINTON )
JUSTIN R. MEYER, ESQ., being duly sworn, deposes and says that he is an attorney and counsellor
at law duly admitted to practice his profession in the State of New York and a member of the finn of
Stafford, Owens, Piller, Murnane, Kelleher & Trombley, PLLC, attorneys for the Plaintiff in the
within action, with offices at One Cumberland Avenue, Plattsburgh, New York.
That he has read the foregoing COMPLAINT and knows the contents thereof, and that the same is
true to his own knowledge, except as to the matters therein stated to be on information and belief,
and as to those matters he believes itto be true.
That the reason this verification is made by deponent and not by said Plaintiff isthat said Plaintiff is
not located within the County of Clinton which is the county where deponent resides and has his
office for the practice of law. Deponent further says that the grounds of his belief as to allmatters in
the said COMPLAINT not stated upon his own knowledge are as follows: investigative file
material, correspondence and advice and information furniphed to him, by or on behalf of said
Plaintiff and others.
JUST1N R. MEYE ESQ.
Sworn to before me this
15th
day of Feb , 2 19.
"'*~ m
BRENDAN P
Public Notary Pubic, Str rk
Nofary
No. 020V 4
Qualifiedin C y
Commission Expiresr .a 301\
BRENDAN P. OWENS
Notary Pubic,Stateof New York
No.020W6276996
Qualifiedin Clinton
County
Commission ExpiresFebruary 25,
STAFFORD • OWENS
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ADIRONDACK REGION
.
CHIROPRACTIC, P.C.
A.Trudel
Dr.Tracy
· l'1/30/2016
.. . eAttn: Tom Marnane
...........
.. . . .
.... . ... . . . ... . . . . . .. . ....
. .....
. .
Re: Rebecca Charland
Mrs..Rebec a Charland slipped and fellon the ice in the parking lot at 9 Finney
Boulevard, Malcñc NY on 2/22/16. She cornplained of severe pain in her left shoulder.
She was referred for an x-ray and subsequently an.MRI of her left shoulder which
revealed partial tears of the supraspinatas tendon, bursitis of the subdelteid bursa,
moderate to severe edema in the deltoid muscle with tear, effusion of the gicñchs-cr:1
joint. She was referred for orthopedic consult with Dr. Bullock who referred her for
.
physical therapy.
If you should need any further..information please do not hesitte to contact the office.
- Yours truly,
Tracy A. Trudel, B.Sc. D.C.
:
.
9 Finney Blvd.,Malone, New York 12953 Tê!êphane:(518) 483-2804 Fax:(S18) 483-2872 .
7 of 7
Preview
FILED: FRANKLIN COUNTY CLERK 02/19/2019 09:29 AM INDEX NO. E2019-152 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/19/2019 STATE OF NEW YORK SUPREME COURT COUNTY OF FRANKLIN REBECCA CHARLAND, Plaintiff, SUMMONS -against- Index Number: ADIRONDACK REGION CHIROPRACTIC, PC, and JOHN FLEURY d/b/a FLEURY REAL ESTATE, Defendants. TO THE ABOVE-NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED to answer the Verified Complaint in this action and to serve a copy of your answer, or,ifthe Verified Complaint is not served with this Summons, to serve a notice of appearañce, on the Plaintiff's attorneys within twenty (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 reliefdemanded in the Verified Complaint. Dated: February 15, 2019. STAFFORD, OWENS, PILLER, MURNANE, KELLEHER & TROMBLEY, PLLC By: M in R. Meyér, Esq. ttorneys for Plaint One Cumberlan venue Post Office Box 2947 Plattsburgh, New York, 12901 (518) 561-4400 (518) 561-4848 1 of 7 FILED: FRANKLIN COUNTY CLERK 02/19/2019 09:29 AM INDEX NO. E2019-152 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/19/2019 STATE OF NEW YORK SUPREME COURT COUNTY OF FRANKLIN REBECCA CHARLAND, Plaintiff, VERIFIED COMPLAINT -against- Index Number: ADIRONDACK REGION CHIROPRACTIC, PC, and JOHN FLEURY d/b/a FLEURY REAL ESTATE, Defendants. Plaintiff, Rebecca Charland, by and through her attorneys, Stafford, Owens, Piller, Murnane, Kelleher & Trombley, does hereby respectfully show and allege as follows: 1. That at alltimes hereafter mentioned, the Plaintiff, Rebecca Charland, was a resident of the Town of North Bangor, County of Franklin, and State of New York. 2. That upon information and belief, the Defendant, Adirondack Region Chiropractic, PC is a professional corporation with a principal place of business at 9 Finney Blvd., Malone, New York, 12953. 3. That upon information and belief, Defendant, John Fleury d/b/a Fleury Real Estate maintains a principal place of business at 9 Finney Blvd., Malone, New York, 12953. 4. At alltimes hereafter mentioned, Adirondack Region Chiropractic leased, maintained, and controlled certain real property located at 9 Finney Blvd., in the Town of Malone, County of Franklin and State of New York. 5. Upon information and belief, at alltimes relevant hereto, Defendant, John Fleury, d/b/a Fleury Real Estate, owned, occupied, maintained and controlled a certain real property located at 9 Finney Blvd., Town of Malone, County of Franklin, State of New York. 6. Upon information and belief, the Defendants had a joint in several duty for the care, maintenance, inspection and upkeep of the premises located at 9 Finney Blvd., Town of Malone, County of Franklin, State of New York. AS IN FOR A FIRST, SEPARATE AND DISTINCT CAUSE OF ACTION. 7. Plaintiff repeats and realleges each and every paragraph of this complaint numbered one through six as if more fully set forth herein at length and with the same force and effect. 8. On or about February 22, 2016, the Plaintiff, Rebecca Charland, was lawfully present at the premises at 9 Finney Blvd. and the office of Adirondack Region Chiropractic, PC, when by reason of the negligence, carelessness and recklessness of the Defendants, the STAFFORD • OWENS PILLER· ·KELLEHER MURNAN£ &TRUM8LEY,PLLC 2 of 7 FILED: FRANKLIN COUNTY CLERK 02/19/2019 09:29 AM INDEX NO. E2019-152 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/19/2019 Plaintiff, Rebecca Charland was caused to slip and fall in the walkway/parking lot thereof, causing her to sustain serious and severe injuries as hereinafter set forth. 9. Attached is a statement from Tracy A. Trudel, B.S.C, D.C., who upon information and belief is a principal of Adirondack Region Chiropractic, PC, which states "Rebecca Charland slipped and fell on the ice in the parking lot at 9 Finney Blvd., Malone, New York on 2/22/16. She complained of severe pain in her leftshoulder. She was referred for an x-ray and subsequently an MRI of her leftshoulder which revealed partial tears of the supraspinatus tendon, bursitis of the subdeltoid bursa, moderate to severe edema in the deltoid muscle with tear, a fusion of the glenoid humoral joint. She was referred for therapy." orthopedic consult with Dr. Bullock, who referred her for physical 10. Upon information and belief, the negligence of the Defendants consisted of the following: a. Failure to warn pedestrians lawfully present upon premises of the defective and dangerous condition then and there existing; b. Failing to inspect, repair, maintain or correct said dangerous and defective conditions; c. Failing to utilize proper measures and ensuring safe conditions on the walkway and parking lot area of the said premises; d. Failing to utilize measures to eliminate or alleviate the dangerous and defective conditions on the premises; e. Creating the said dangerous conditions by methods of maintenance used; f. Failing to properly train employees, agents and/or servants in how to inspect and maintain said premises in a safe condition; g. Failing to erect signs, or in any manner warn of the dangerous and defective conditions then and there existing; h. In violating the statutes, town rules and regulations in such cases made and provided; i. In their failure to use reasonable care to keep the walkway and parking lot in a safe condition; j. Creating said condition by utilizing inferior or defective materials and maintenance of the area; k. Creating said condition by utilizing improper and/or defective techniques in maintaining the walkway and parking lot areas; 1. Failing to properly inspect and supervise the said walkway and parking lot areas; m. In knowing that said property was in a dangerous and defective condition, and for allowing an unreasonable length of time to pass in ensuring that said walkway was maintained in a safe, proper and suitable condition; n. In failing to provide adequate lighting for the walkways and parking lot areas; STAFFORD • OWENS PILLER-MEMANE. EELLEREI GTROMBLEY.PLLC II 3 of 7 FILED: FRANKLIN COUNTY CLERK 02/19/2019 09:29 AM INDEX NO. E2019-152 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/19/2019 0. In failing to repair a recurring situation of snow and/or ice accumulation on the premises; p. In failing to salt, sand or otherwise maintain the walkway and parking lot areas in a safe and appropriate condition; 11. Upon information and belief, the Defendants had actual knowledge of the said defective and dangerous condition or conditions or the same existed for such a period of time that in the exercise of reasonable care, the Defendants should have had such knowledge. 12. The premises located at 9 Finney Blvd., Malone, New York, so-called, is located in the Town of Malone, County of Franklin and State of New York was open for use by members of the general public, and specifically patrons of Adirondack Region Chiropractic, PC. 13. That the accident and injuries sustained by Plaintiff were caused solely and by reason of negligence of the Defendant without any culpable conduct on the part of the Plaintiff contributing thereto. 14. As a result of the negligence by the Defendants, the following injuries were either caused, or alternatively, aggravated, accelerated, exacerbated, precipitated and otherwise enhanced, the Plaintiff, Rebecca Charland, suffered serious and severe injuries, and was rendered sick, sore, lame, and disabled; specifically, injuries included, but are not limited to: a. Suffered shock b. Mental upset and mental embarrassments c. Left shoulder pain d. Loss of range of motion in left shoulder e. Left shoulder stiffness f. Partial tear of rotator cuff g. Difficulty with flection of leftshoulder h. Difficulty with abduction of left shoulder i. Pain in the left shoulder j. Weakness, damage to the tendon of the supraspinatus tendinosis in the left shoulder k. Partial thickness tear of the supraspinatus tendon 1. Edema within the leftdeltoid muscle m. Mild arthrosis at the AC joint; STAFFORD • OWENS PILLER- *IELLENER MBAHANE CTRGMBLET,PLLC 4 of 7 FILED: FRANKLIN COUNTY CLERK 02/19/2019 09:29 AM INDEX NO. E2019-152 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/19/2019 15. At the aforesaid accident and injuries alleged herein were caused by the negligent, wanton, reckless and careless acts of the Defendants, their agents, servants and/or employees. 16. That the Limited Liability Provisions set forth in section 1601 of the CPLR do not apply pursuant to one or more of the exceptions of CPLR section 1602 17. That as a result of this accident, the Plaintiff herein was caused to sustain severe and serious personal injuries to her mind and body, the same of which, upon information and belief, are permanent with the permanent effects of pain, disability, disfigurement and loss of body function. 18. Further, this Plaintiff was caused to expend and become obligated for diverse sums of money for the purposes of obtaining medical care and/or cure and in an effort to alleviate the suffering and ills sustained as a result of this accident; the Plaintiff further was caused to lose substantial periods of time from her normal vocation, and upon information and belief, may continue in that way into the future and suffer similar losses. 19. By reason of the foregoing, this Plaintiff was damaged in a sum which exceeds the jurisdictional limits of all lower courts which would have jurisdiction over this matter. WHEREFORE, Plaintiff demands a judgment against the Defendant in a sum which exceeds the jurisdictional limits of all lower courts which the jury would find to be fair, adequate and just together with the costs and disbursements of this action. Dated: February 15, 2019. STAFFORD, OWENS, PILLER, MURNANE, KELLEHER & TROMBLEY, PLLC By: u e er, E(q. On Cumberland AvenuÓ st Office Box 2947 Plattsburgh, New York, 12901 Phone: (518) 561-4400 Fax: (518) 561-4848 S S I1 5 of 7 FILED: FRANKLIN COUNTY CLERK 02/19/2019 09:29 AM INDEX NO. E2019-152 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/19/2019 VERIFICATION STATE OF NEW YORK ) ) ss.: COUNTY OF CLINTON ) JUSTIN R. MEYER, ESQ., being duly sworn, deposes and says that he is an attorney and counsellor at law duly admitted to practice his profession in the State of New York and a member of the finn of Stafford, Owens, Piller, Murnane, Kelleher & Trombley, PLLC, attorneys for the Plaintiff in the within action, with offices at One Cumberland Avenue, Plattsburgh, New York. That he has read the foregoing COMPLAINT and knows the contents thereof, and that the same is true to his own knowledge, except as to the matters therein stated to be on information and belief, and as to those matters he believes itto be true. That the reason this verification is made by deponent and not by said Plaintiff isthat said Plaintiff is not located within the County of Clinton which is the county where deponent resides and has his office for the practice of law. Deponent further says that the grounds of his belief as to allmatters in the said COMPLAINT not stated upon his own knowledge are as follows: investigative file material, correspondence and advice and information furniphed to him, by or on behalf of said Plaintiff and others. JUST1N R. MEYE ESQ. Sworn to before me this 15th day of Feb , 2 19. "'*~ m BRENDAN P Public Notary Pubic, Str rk Nofary No. 020V 4 Qualifiedin C y Commission Expiresr .a 301\ BRENDAN P. OWENS Notary Pubic,Stateof New York No.020W6276996 Qualifiedin Clinton County Commission ExpiresFebruary 25, STAFFORD • OWENS II 6 of 7 FILED: FRANKLIN COUNTY CLERK 02/19/2019 09:29 AM INDEX NO. E2019-152 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/19/2019 ADIRONDACK REGION . CHIROPRACTIC, P.C. A.Trudel Dr.Tracy · l'1/30/2016 .. . eAttn: Tom Marnane ........... .. . . . .... . ... . . . ... . . . . . .. . .... . ..... . . Re: Rebecca Charland Mrs..Rebec a Charland slipped and fellon the ice in the parking lot at 9 Finney Boulevard, Malcñc NY on 2/22/16. She cornplained of severe pain in her left shoulder. She was referred for an x-ray and subsequently an.MRI of her left shoulder which revealed partial tears of the supraspinatas tendon, bursitis of the subdelteid bursa, moderate to severe edema in the deltoid muscle with tear, effusion of the gicñchs-cr:1 joint. She was referred for orthopedic consult with Dr. Bullock who referred her for . physical therapy. If you should need any further..information please do not hesitte to contact the office. - Yours truly, Tracy A. Trudel, B.Sc. D.C. : . 9 Finney Blvd.,Malone, New York 12953 Tê!êphane:(518) 483-2804 Fax:(S18) 483-2872 . 7 of 7