Preview
FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF WESTCHESTER Date Filed:
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JOSEPH SEAWRIGHT, SUMMONS
Plaintiff designates
Plaintiff, WESTCHESTER
County as the place of
trial.
-against-
The basis of venue is
DENISE OZEROFF, location of occurrence.
Defendant.
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To the above named Defendants:
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 Plaintiff's attorneys within twenty days after the service of this summons,
exclusive of the day of service, where service is made by delivery upon you personally within the
state, or, within 30 days after completion of service where service is made in any other manner.
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: NEW YORK, N.Y.
February 10, 2021
THE LAW OFFICES OF DAVID J. KRESMAN
Attorneys for Plaintiff
JOSEPH SEAWRIGHT
Seven Penn Plaza - Suite 720
New York, New York 10001
(212) 563-1100
by_____________________________
DAVID J. KRESMAN
TO:
DENISE OZEROFF
100 Columbus Avenue, Apt. 4N
Tuckahoe, NY 10707
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YOU MUST FORWARD TO YOUR CAR INSURANCE CARRIER IMMEDIATELY-
YOUR FAILURE TO DO SO MAY RESULT IN YOUR INSURANCE COMPANY
DENYING YOUR INSURANCE COVERAGE!!!!!
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SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF WESTCHESTER Date Filed:
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JOSEPH SEAWRIGHT, VERIFIED
COMPLAINT
Plaintiff,
-against-
DENISE OZEROFF,
Defendant.
--------------------------------------------------------------------------X
Plaintiff JOSEPH SEAWRIGHT, by her attorneys, THE LAW OFFICES OF DAVID J.
KRESMAN, complaining of the defendant, DENISE OZEROFF, respectfully alleges, upon
information and belief, as follows:
1. That at all times hereinafter mentioned, Plaintiff JOSEPH SEAWRIGHT was still
is a resident of the County of Westchester and State of New York.
2. That at all times hereinafter mentioned, Defendant DENISE OZEROFF was and
still is a resident of the County of Westchester and State of New York.
3. That at all times hereinafter mentioned, Defendant DENISE OZEROFF
committed a tortious act within the County of Westchester and State of New York.
4. That on September 26, 2018, Defendant DENISE OZEROFF was the registered
owner of a certain Toyota motor vehicle bearing New York State license plate number DFJ3367.
5. That on September 26, 2018, Defendant DENISE OZEROFF was the titled owner
of a certain Toyota motor vehicle bearing New York State license plate number DFJ3367.
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6. That on September 26, 2018, Defendant DENISE OZEROFF was the operator of
a certain Toyota motor vehicle bearing New York State license plate number DFJ3367.
7. That on September 26, 2018, Defendant DENISE OZEROFF was the lessee of a
certain Toyota motor vehicle bearing New York State license plate number DFJ3367.
8. That on September 26, 2018, Defendant DENISE OZEROFF was the lessor of a
certain Toyota motor vehicle bearing New York State license plate number DFJ3367.
9. That on September 26, 2018, Defendant DENISE OZEROFF controlled,
maintained, managed and supervised a certain Toyota motor vehicle bearing New York State
license plate number DFJ3367.
10. That on September 26, 2018, Plaintiff JOSEPH SEAWRIGHT was the operator of
a certain Toyota motor vehicle bearing New York State license plate number DWT1241.
11. That at all times hereinafter mentioned, Tarrytown Road near its intersection with
Chatterton Avenue was and still is a public roadway and/or thoroughfare in the County of
Westchester and State of New York.
12. That on September 26, 2018, at the aforesaid location, the aforementioned Toyota
motor vehicle owned and operated by Defendant DENISE OZEROFF bearing New York State
license plate number DFJ3367 and the aforementioned Toyota motor vehicle operated by
plaintiff JOSEPH SEAWRIGHT bearing New York State license plate number DWT1241 came
into contact and had a collision.
13. That on September 26, 2018, at the aforesaid location, the aforementioned Toyota
motor vehicle owned and operated by Defendant DENISE OZEROFF bearing New York State
license plate number DFJ3367 struck the rear of the aforementioned Toyota motor vehicle
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operated by plaintiff JOSEPH SEAWRIGHT bearing New York State license plate number
DWT1241 .
14. That as a result of the aforesaid contact and collision, Plaintiff JOSEPH
SEAWRIGHT sustained serious and permanent personal injuries.
15. The aforesaid contact and occurrence and the resulting injuries were caused solely
and wholly by reason of the negligence and carelessness of the defendant DENISE OZEROFF in
his ownership, operation, maintenance, supervision, management and control of his motor
vehicle; in causing, permitting, and/or allowing her motor vehicle to come into contact with the
motor vehicle operated by plaintiff; that the defendant’s actions were negligent and careless; in
failing to keep her motor vehicle under proper control; in failing to drive her motor vehicle with
due regard to the position of other motor vehicles on the public way; in failing to keep a proper
lookout for and to take heed and cognizance of other motor vehicle on the public way; in failing
to look; in failing to see; in failing to yield the right of way; in failing to keep her vehicle in the
proper lane of traffic; in failing to change lanes without signaling; in failing to apply and/or
maintain the braking system of her motor vehicle so as to avoid said occurrence; in failing to be
and remain alert while driving; in driving her motor vehicle at an unreasonable rate of speed
under the circumstances; in failing to use that degree of care, caution and prudence required
under the circumstances then and there existing; in driving and operating her motor vehicle at a
greater rate of speed than was prudent and reasonable and sufficiently slow so as to prevent the
incident under the circumstances and conditions then and there prevailing to the knowledge of
the defendant; in failing to operate her vehicle so that it came to a timely halt; in failing to
maintain her vehicle a safe distance behind the plaintiffs vehicle; in following the plaintiffs
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vehicle more closely than is reasonable and prudent; in failing to stop, signal and/or slow down
and in carelessly and negligently omitting and failing to provide and/or equip and make use of
and/or keep in proper working order and/or permit timely use of adequate and efficient brakes,
braking mechanisms, acceleration, steering devices, signaling devices and other mechanisms of
the instant motor vehicle under the prevailing circumstances of the roadway and traffic
conditions at the point or space of accident; in failing to take any and all precautions for the
avoidance of the accident and in failing to warn the plaintiff of the impending collision, although
in the exercise of reasonable care, the defendant could have and should have done so; in failing
to keep a safe and proper distance from other vehicles on the roadway, specifically the plaintiff’s
herein; in following too closely behind the plaintiffs vehicle; in failing to heed and obey the
traffic rules and regulations at and governing the operation of motor vehicles in the State of New
York; and that the defendant was otherwise careless, reckless and negligent.
16. That solely as a result of the defendant, DENISE OZEROFF’s negligence and
carelessness, the plaintiff, JOSEPH SEAWRIGHT was caused to suffer severe and serious
personal injuries to his mind and body, and further, that the plaintiff was subjected to great
physical pain and mental anguish, as a result of the negligence, carelessness and recklessness of
the defendant in causing this accident.
17. The aforesaid occurrence was caused by the negligence of the defendant, without
any culpable conduct on the part of the plaintiff JOSEPH SEAWRIGHT contributing thereto.
18. The limitations set forth in CPLR Section 1601 do not apply by reason of one or
more of the exceptions of CPLR Section 1602, and more specifically 1602(6).
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19. That as a result of the foregoing, plaintiff, JOSEPH SEAWRIGHT, suffered a
serious injury as defined in Section 5102(d) of the Insurance Law of the State of New York and
has sustained economic loss in excess of basic economic loss as defined in subsection (a) of
section 5102 of the Insurance law of the State of New York.
20. As a result of the foregoing, plaintiff JOSEPH SEAWRIGHT sustained serious,
severe and permanent personal injuries and was rendered sick, sore, lame, and disabled; plaintiff
JOSEPH SEAWRIGHT was caused to suffer great pain, discomfort, and disability and, upon
information and belief, will continue to suffer pain, discomfort, and disability in the future;
plaintiff JOSEPH SEAWRIGHT was caused to undergo hospital and medical care, aid and
attention, and upon information and belief, may continue to require to undergo medical care, aid
and attention for a long period of time to come in the future; plaintiff was obliged to expend and
incur large sums of monies for medical care, aid and attention and, upon information and belief,
will continue to be obliged to expend and incur large sums of monies for future medical care, aid
and attention; plaintiff JOSEPH SEAWRIGHT was caused to become incapacitated from his
usual vocation and avocation, and upon information and belief, may continue to be caused to
remain away from his usual vocation and avocation for a long period of time to come in the
future.
21. By reason of the foregoing, the plaintiff has been damaged in a sum of money having
a present value that exceeds the jurisdictional limits of all lower courts which would otherwise
have jurisdiction of this matter.
WHEREFORE, plaintiff demands judgment against the defendant on each and every
cause of action contained herein in a sum of money having a present value that exceeds the
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jurisdictional limits of all lower courts which would otherwise have jurisdiction of this matter,
together with the cost and disbursements of this matter, and such other and further relief as to this
Court seems just and proper.
Dated: NEW YORK, N.Y.
February 10, 2021
THE LAW OFFICES OF DAVID J. KRESMAN
Attorneys for Plaintiff
JOSEPH SEAWRIGHT
Seven Penn Plaza - Suite 720
New York, New York 10001
(212) 563-1100
by_____________________________
DAVID J. KRESMAN
TO:
DENISE OZEROFF
100 Columbus Avenue, Apt. 4N
Tuckahoe, NY 10707
YOU MUST FORWARD TO YOUR CAR INSURANCE CARRIER IMMEDIATELY-
YOUR FAILURE TO DO SO MAY RESULT IN YOUR INSURANCE COMPANY
DENYING YOUR INSURANCE COVERAGE!!!!!
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ATTORNEY'S VERIFICATION
State of New York}
}SS.:
County of New York}
DAVID J. KRESMAN, 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 THE LAW OFFICES OF DAVID J. KRESMAN, attorneys of record
for Plaintiff, JOSEPH SEAWRIGHT 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.
The reason this verification is made by affirmant and not by plaintiff is that plaintiff was
not in the county where affirmant’s office is located at the time the Complaint was prepared.
DATED: New York, NY
February 10, 2021
__________________________________
DAVID J. KRESMAN
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
JOSEPH SEAWRIGHT, Index No:
Plaintiff,
-against-
DENISE OZEROFF,
Defendant.
=========================================================================
SUMMONS AND VERIFIED COMPLAINT
========================================================================
LAW OFFICES OF DAVID J. KRESMAN
Attorneys for : Plaintiff(s)
Seven Penn Plaza • 370 Seventh Avenue • Suite 720
New York, New York 10001
(212) 563-1100
========================================================================
===
To
Attorney(s) for
========================================================================
===
Service of a copy of the within
is hereby admitted.
Dated, ________________________________
ATTORNEY(S) FOR
========================================================================
===
PLEASE TAKE NOTICE:
o NOTICE OF ENTRY
that the within is a (certified) true copy of an duly entered in the office
of the clerk of the within named court on __________________200__.
o NOTICE OF SETTLEMENT
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 named Court, at on 200___
at________ O’clock ___.M.
Dated, _________________________
Yours, etc.
LAW OFFICES OF DAVID J. KRESMAN
10 of 10
Preview
FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF WESTCHESTER Date Filed: --------------------------------------------------------------------X JOSEPH SEAWRIGHT, SUMMONS Plaintiff designates Plaintiff, WESTCHESTER County as the place of trial. -against- The basis of venue is DENISE OZEROFF, location of occurrence. Defendant. --------------------------------------------------------------------------X To the above named Defendants: 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 Plaintiff's attorneys within twenty days after the service of this summons, exclusive of the day of service, where service is made by delivery upon you personally within the state, or, within 30 days after completion of service where service is made in any other manner. 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: NEW YORK, N.Y. February 10, 2021 THE LAW OFFICES OF DAVID J. KRESMAN Attorneys for Plaintiff JOSEPH SEAWRIGHT Seven Penn Plaza - Suite 720 New York, New York 10001 (212) 563-1100 by_____________________________ DAVID J. KRESMAN TO: DENISE OZEROFF 100 Columbus Avenue, Apt. 4N Tuckahoe, NY 10707 Page 1 1 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 YOU MUST FORWARD TO YOUR CAR INSURANCE CARRIER IMMEDIATELY- YOUR FAILURE TO DO SO MAY RESULT IN YOUR INSURANCE COMPANY DENYING YOUR INSURANCE COVERAGE!!!!! Page 2 2 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF WESTCHESTER Date Filed: --------------------------------------------------------------------X JOSEPH SEAWRIGHT, VERIFIED COMPLAINT Plaintiff, -against- DENISE OZEROFF, Defendant. --------------------------------------------------------------------------X Plaintiff JOSEPH SEAWRIGHT, by her attorneys, THE LAW OFFICES OF DAVID J. KRESMAN, complaining of the defendant, DENISE OZEROFF, respectfully alleges, upon information and belief, as follows: 1. That at all times hereinafter mentioned, Plaintiff JOSEPH SEAWRIGHT was still is a resident of the County of Westchester and State of New York. 2. That at all times hereinafter mentioned, Defendant DENISE OZEROFF was and still is a resident of the County of Westchester and State of New York. 3. That at all times hereinafter mentioned, Defendant DENISE OZEROFF committed a tortious act within the County of Westchester and State of New York. 4. That on September 26, 2018, Defendant DENISE OZEROFF was the registered owner of a certain Toyota motor vehicle bearing New York State license plate number DFJ3367. 5. That on September 26, 2018, Defendant DENISE OZEROFF was the titled owner of a certain Toyota motor vehicle bearing New York State license plate number DFJ3367. Page 3 3 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 6. That on September 26, 2018, Defendant DENISE OZEROFF was the operator of a certain Toyota motor vehicle bearing New York State license plate number DFJ3367. 7. That on September 26, 2018, Defendant DENISE OZEROFF was the lessee of a certain Toyota motor vehicle bearing New York State license plate number DFJ3367. 8. That on September 26, 2018, Defendant DENISE OZEROFF was the lessor of a certain Toyota motor vehicle bearing New York State license plate number DFJ3367. 9. That on September 26, 2018, Defendant DENISE OZEROFF controlled, maintained, managed and supervised a certain Toyota motor vehicle bearing New York State license plate number DFJ3367. 10. That on September 26, 2018, Plaintiff JOSEPH SEAWRIGHT was the operator of a certain Toyota motor vehicle bearing New York State license plate number DWT1241. 11. That at all times hereinafter mentioned, Tarrytown Road near its intersection with Chatterton Avenue was and still is a public roadway and/or thoroughfare in the County of Westchester and State of New York. 12. That on September 26, 2018, at the aforesaid location, the aforementioned Toyota motor vehicle owned and operated by Defendant DENISE OZEROFF bearing New York State license plate number DFJ3367 and the aforementioned Toyota motor vehicle operated by plaintiff JOSEPH SEAWRIGHT bearing New York State license plate number DWT1241 came into contact and had a collision. 13. That on September 26, 2018, at the aforesaid location, the aforementioned Toyota motor vehicle owned and operated by Defendant DENISE OZEROFF bearing New York State license plate number DFJ3367 struck the rear of the aforementioned Toyota motor vehicle Page 4 4 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 operated by plaintiff JOSEPH SEAWRIGHT bearing New York State license plate number DWT1241 . 14. That as a result of the aforesaid contact and collision, Plaintiff JOSEPH SEAWRIGHT sustained serious and permanent personal injuries. 15. The aforesaid contact and occurrence and the resulting injuries were caused solely and wholly by reason of the negligence and carelessness of the defendant DENISE OZEROFF in his ownership, operation, maintenance, supervision, management and control of his motor vehicle; in causing, permitting, and/or allowing her motor vehicle to come into contact with the motor vehicle operated by plaintiff; that the defendant’s actions were negligent and careless; in failing to keep her motor vehicle under proper control; in failing to drive her motor vehicle with due regard to the position of other motor vehicles on the public way; in failing to keep a proper lookout for and to take heed and cognizance of other motor vehicle on the public way; in failing to look; in failing to see; in failing to yield the right of way; in failing to keep her vehicle in the proper lane of traffic; in failing to change lanes without signaling; in failing to apply and/or maintain the braking system of her motor vehicle so as to avoid said occurrence; in failing to be and remain alert while driving; in driving her motor vehicle at an unreasonable rate of speed under the circumstances; in failing to use that degree of care, caution and prudence required under the circumstances then and there existing; in driving and operating her motor vehicle at a greater rate of speed than was prudent and reasonable and sufficiently slow so as to prevent the incident under the circumstances and conditions then and there prevailing to the knowledge of the defendant; in failing to operate her vehicle so that it came to a timely halt; in failing to maintain her vehicle a safe distance behind the plaintiffs vehicle; in following the plaintiffs Page 5 5 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 vehicle more closely than is reasonable and prudent; in failing to stop, signal and/or slow down and in carelessly and negligently omitting and failing to provide and/or equip and make use of and/or keep in proper working order and/or permit timely use of adequate and efficient brakes, braking mechanisms, acceleration, steering devices, signaling devices and other mechanisms of the instant motor vehicle under the prevailing circumstances of the roadway and traffic conditions at the point or space of accident; in failing to take any and all precautions for the avoidance of the accident and in failing to warn the plaintiff of the impending collision, although in the exercise of reasonable care, the defendant could have and should have done so; in failing to keep a safe and proper distance from other vehicles on the roadway, specifically the plaintiff’s herein; in following too closely behind the plaintiffs vehicle; in failing to heed and obey the traffic rules and regulations at and governing the operation of motor vehicles in the State of New York; and that the defendant was otherwise careless, reckless and negligent. 16. That solely as a result of the defendant, DENISE OZEROFF’s negligence and carelessness, the plaintiff, JOSEPH SEAWRIGHT was caused to suffer severe and serious personal injuries to his mind and body, and further, that the plaintiff was subjected to great physical pain and mental anguish, as a result of the negligence, carelessness and recklessness of the defendant in causing this accident. 17. The aforesaid occurrence was caused by the negligence of the defendant, without any culpable conduct on the part of the plaintiff JOSEPH SEAWRIGHT contributing thereto. 18. The limitations set forth in CPLR Section 1601 do not apply by reason of one or more of the exceptions of CPLR Section 1602, and more specifically 1602(6). Page 6 6 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 19. That as a result of the foregoing, plaintiff, JOSEPH SEAWRIGHT, suffered a serious injury as defined in Section 5102(d) of the Insurance Law of the State of New York and has sustained economic loss in excess of basic economic loss as defined in subsection (a) of section 5102 of the Insurance law of the State of New York. 20. As a result of the foregoing, plaintiff JOSEPH SEAWRIGHT sustained serious, severe and permanent personal injuries and was rendered sick, sore, lame, and disabled; plaintiff JOSEPH SEAWRIGHT was caused to suffer great pain, discomfort, and disability and, upon information and belief, will continue to suffer pain, discomfort, and disability in the future; plaintiff JOSEPH SEAWRIGHT was caused to undergo hospital and medical care, aid and attention, and upon information and belief, may continue to require to undergo medical care, aid and attention for a long period of time to come in the future; plaintiff was obliged to expend and incur large sums of monies for medical care, aid and attention and, upon information and belief, will continue to be obliged to expend and incur large sums of monies for future medical care, aid and attention; plaintiff JOSEPH SEAWRIGHT was caused to become incapacitated from his usual vocation and avocation, and upon information and belief, may continue to be caused to remain away from his usual vocation and avocation for a long period of time to come in the future. 21. By reason of the foregoing, the plaintiff has been damaged in a sum of money having a present value that exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction of this matter. WHEREFORE, plaintiff demands judgment against the defendant on each and every cause of action contained herein in a sum of money having a present value that exceeds the Page 7 7 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 jurisdictional limits of all lower courts which would otherwise have jurisdiction of this matter, together with the cost and disbursements of this matter, and such other and further relief as to this Court seems just and proper. Dated: NEW YORK, N.Y. February 10, 2021 THE LAW OFFICES OF DAVID J. KRESMAN Attorneys for Plaintiff JOSEPH SEAWRIGHT Seven Penn Plaza - Suite 720 New York, New York 10001 (212) 563-1100 by_____________________________ DAVID J. KRESMAN TO: DENISE OZEROFF 100 Columbus Avenue, Apt. 4N Tuckahoe, NY 10707 YOU MUST FORWARD TO YOUR CAR INSURANCE CARRIER IMMEDIATELY- YOUR FAILURE TO DO SO MAY RESULT IN YOUR INSURANCE COMPANY DENYING YOUR INSURANCE COVERAGE!!!!! Page 8 8 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 ATTORNEY'S VERIFICATION State of New York} }SS.: County of New York} DAVID J. KRESMAN, 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 THE LAW OFFICES OF DAVID J. KRESMAN, attorneys of record for Plaintiff, JOSEPH SEAWRIGHT 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. The reason this verification is made by affirmant and not by plaintiff is that plaintiff was not in the county where affirmant’s office is located at the time the Complaint was prepared. DATED: New York, NY February 10, 2021 __________________________________ DAVID J. KRESMAN Page 9 9 of 10 FILED: WESTCHESTER COUNTY CLERK 02/11/2021 11:37 AM INDEX NO. 51583/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/11/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER JOSEPH SEAWRIGHT, Index No: Plaintiff, -against- DENISE OZEROFF, Defendant. ========================================================================= SUMMONS AND VERIFIED COMPLAINT ======================================================================== LAW OFFICES OF DAVID J. KRESMAN Attorneys for : Plaintiff(s) Seven Penn Plaza • 370 Seventh Avenue • Suite 720 New York, New York 10001 (212) 563-1100 ======================================================================== === To Attorney(s) for ======================================================================== === Service of a copy of the within is hereby admitted. Dated, ________________________________ ATTORNEY(S) FOR ======================================================================== === PLEASE TAKE NOTICE: o NOTICE OF ENTRY that the within is a (certified) true copy of an duly entered in the office of the clerk of the within named court on __________________200__. o NOTICE OF SETTLEMENT 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 named Court, at on 200___ at________ O’clock ___.M. Dated, _________________________ Yours, etc. LAW OFFICES OF DAVID J. KRESMAN 10 of 10