Preview
FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021
SUPREME COURT OF THE STATE OF NEW YORK Index No.
COUNTY OF ORANGE Date Purchased
------ --------------------X
BARBARA LOPANE, Plaintiff designate
Orange County
Plaintiff, as the place of trial.
- against -
The basis of venue is
TERESA C. ORANGE COUNTY MEDI- PlaintifPs Residence
KOLK,
COACH, INC., a/k/aMEDI-COACH, INC., and SUMMONS
TASHENA LATOYA DAVIS,
Plaintiffs'
Defendants. Address:
-------- ---------------- -----X Senior Middletown
Way,
New York 10940
County of Orange
To the above named Defendañt(s)
YOU ARE HEREBY SUMMONED to answer the complaint in thisaction 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
Plaintiff's Attamey(s) within 20 days after the service of thissamacñs, exclusive of the day of service (or
within 30 days after the service is complete ifthis summa= is not delivered to you within the
personally
State ofNew York); and incase ofyour failure to appear or answer, judgmcñt will be taken against you by
default forthe relief demanded in the complaint.
Dated: Goshen, New York
December 20, 2021
Yours, etc.,
D EE Q
...-
Atto ys fo Plaintiff
By:
N C. DUPEE, ESQ.
Ofiice and Post Office Addres
211 Main Street, Box 470
Goshen, New York 10924
Telephone No.: 845-294-8900
TO: Teresa Kolk
76 Uhlig Road Apt. B117
Middletown, New York 10940
Orange County Medi Coach, Inc.
86 Cottage Street
Middletown, New York 10940
Tashena Latoya Davis
22 Fitzgerald Drive B5-9A
Middletown, New York 10940
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
__------------------------------------------------------------
-----¬X
BARBARA LOPANE,
Plaintiff,
-against- VERIFIED COMPLAINT
TERESA C. KOLK, ORANGE COUNTY MEDI-COACH, INC.,
a/k/a MEDI-COACH, INC., and TASHENA LATOYA DAVIS,
Defendants.
----------------------------------. -- ------------------------X
The plaintiff, Barbara Lopane, by her attorneys, Dupee & Monroe, P.C., as and for her
verified complaint, respectively alleges as follows:
AS AND FOR A FIRST CAUSE OF ACTION
ON BEHALF OF BARBARA LOPANE
FIRST: That at all times hereinafter mentioned, the plaintiff Barbara Lopane
was and is a resident of.County of Orange, State of New York.
SECOND: Upon information and belief, and at alltimes hereiñà fter mentioned, the
defendant Teresa C. Kolk, was and is a resident of the County of Orange, State of New York.
THIRD: Upon information and Orange Inc. a/k/a Medi-
belief, County Medi-Coach,
Coach, Inc., (hereinafter "Medi") was and is a domestic corporation duly organized and
registered in the State of New York since July 21, 1995 and maintains offices for the transaction
of business at 86 Cottage Street, City of Middletown, County of Orange, State of New York.
FOURTH: Upon information and belief, Medi is a privately owned company which
provides non-emergency medical transportation services as well as taxi services principally in
the County of Orange.
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"Davis"
FIFTH: Upon information and belief, Tashena Latoya Davis hereinafter
was and is a resident of the County of Orange, State of New York.
SIXTH: That at all times hereiñafter mentioned, the plaintiff Barbara Lopane was a
passenger in a 2009 Ford motor vehicle bearing New York State License Plate No. 105 12TY
which was operated by defendant Teresa Kolk and owned by defendant Medi.
SEVENTH: That at all times hereinafter mendoned, the defendant Davis was the
owner and operator of a 2015 Mazda bearing New York License Plate No. HWM3163.
EIGHTH: Upon information and belief, and at alltimes hereinafter mentioned, the
defendant, Teresa Kolk was the operator of the aforementioned 2009 Ford bearing New York
License Plate Number 10512TY with the expressed and/or implied permission of itsowner,
Medi, and was operating same in the course of her employment on June 21, 2018 at .March 25,
2003 at approximately 5:37 P.M.
NINTH: Upon information and belief, and at all times hereinafter mentioned,
Fitzgerald Drive, in the Town of Wallkill, County of Orange, State of New York was and is a
public highway and thoroughfare open to vehicular traffic and was the situs of the accident
hereinafter described.
TENTH: That on or about Thursday, June 21, 2018 at approximately 5:37 P.M. the
motor vehicle operated by the defendant Kolk was proceeding northbound on Fitzgerald Drive,
Town of Wallkill, County of Orange, State of New York when defendant Latoya attempted to
turn right in front of defendant Kolk's vehicle causing defeñdãñt Kolk to strike the motor vehicle
operated by defendant Latoya as a direct and proximate result of the negligent, careless and/or
reckless conduct of the defendants herein, and each of them.
ELEVENTH: The defendants, Kolk and Davis and each of them, were negligent,
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FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021
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careless and/or reckless in the ownership, operation, maintenance, management and control of
their motor vehicles; in that they failed to look carefully and see what was reasonably there to be
seen; in that they failed to properly operate the braking mechanism on their motor vehicles; in
that failed to keep the horn and braking mechanisms in good repair; in that they operated
they
their motor vehicles at an excessive rate of speed; in that they operated their motor vehicles that
they knew to be in poor mechanical condition and in particular, the brakes, lights, steering,
acceleration and horn devices thereon; in that they failed to observe that degree of caution,
prudence and care which was reasonable and proper under the circumstances; in that they failed
to keep alert and attentive; in that they operated their motor vehicles while using and/or
operating a cell phone; in that they failed to maintain their designated lane of travel; in that
defendants operated their motor vehicles while under the influence of alcohol and/or drugs which
defendants'
impaired each ability to safely operate a motor vehicle; in that defendants operated
their motor vehicles while under the influence of prescription medication which impaired their
ability to safely operate their motor vehicles; in that they failed to keep their motor vehicle under
proper control; in that the defendants and each of them operated their aforementioned motor
vehicles in violation of one or more New York State Vehicle and Traffic Laws and in particular
Vehicle and Traffic Law and the defendants otherwise failed to take those precautions reasonable
and necessary to avoid the occurrence hereinabove described.
TWELFTH: The defendant, Medi, is vicariously liable for the negligent, careless
and/or reckless actions of the defendant Teresa Kolk as set forth herein by operation of law
pursuant to VTL §388 and the Doctrine ofRespondeat Superior and was further negligent
and/or careless in failing to properly maintain the motor vehicle as set forth above.
injury"
THIRTEENTH: That the plaintiff Barbara Lopane has sustained a "serious
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021
as defined by New York State Insurance Law §S102(4) and an economic loss greater than basic
economic loss as defined by New York Insurance Law §5102(1).
FOURTEENTH: Upon information and belief, and at alltimes hereinafter
person"
mentioned, the plaintiff Barbara Lopane was and is a "covered as such term is defined
by the New York State Insurance Law.
FIFTEENTH: That by reason thereof, the plaintiff Barbara Lopane is entitled to
recover for non-economic loss and for such economic losses as are not included within the
loss"
definition of "basic economic as such term is defined in the New York State Insurance
Law.
SIXTEENTH: That by reason of the foregoing, the plaintiff Barbara Lopane was
rendered sick, sore, lame and disabled and was caused to sustain serious and severe personal
injuries to her mind and body, some of which, upon information and belief, are permaneñt with
the permanent effects of pain, disability and loss of bodily function.
SÈVENTEENTH: That as a direct and proximate result of the foregoing the plaintiff
Barbara Lopane has been caused to lose substantial periods of time from her normal vocation
and will continue to suffer similar losses in the future.
EIGHTEENTH: That this action falls within the exceptions of CPLR §1601, in that
it arises out of the use, operation, ownership of a motor vehicle as provided for in CPLR
§I602(6).
NINETEENTH: That by reason of the foregoing, the plaintiff Barbara Lopane has
been dañiaged in an amount in excess of the jurisdictional limits of allother Courts which may
have subject matter jurisdiction hereof.
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FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021
WHEREFORE, the plaintiff Barbara Lopane demands judgment in an amount in excess
of the jurisdictional limits of all other Courts which may have subject matter jurisdiction hereof;
together with such interest, costs and disbursements as are appropriate to this action.
Dated: Goshen, New York
December 20, 2021
Yours, etc.,
DUPEE & MONROE, P.C.
Attorneys for Plaintiff
By:
C. DUPEE, JR. Q.
Office & P.O. Address
211 Main St., Box 470
Goshen, New York 10924
845-294-8900
TO: Teresa Kolk
76 Uhlig Road Apt. B117
Middletown, New York 10940
Orange County Medi Coach, Inc.
86 Cottage Street
Middletown, New York 10940
Tashena Latoya Davis
22 Fitzgerald Drive B5-9A
Middletown, New York 10940
6 of 8
FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021
STATE OF NEW Y , COUN,TY OF ORANGE
I,
Certification
say that:I am the attorney of record,or ofcounsel with the attorney(s)of record,forthe
I haveread the annexed know the contentsthereof and the same are
trueto my knowledge, except those matters thereinin which are statedto be alleged on
information and belief,and asto those matters,Ibelieve them tobe true. My beliefas to those
matters thereinnot stated upon knowledge, isbased upon the following:
Affumation
The reason I make this affirmation insteadof inwhich your deponent
maintains his office.
I affirmthatthe foregoing statements are trueunder penalties of perjury.
Dated:
_____---------------__ --- __.
STATE OF NEW YORK, COUNTY OF ORANGE
Barbara Lopane, being duly sworn says:
That I am the plaintiffinthe actionherein,I have read the annexed Su_m-mons and
VerifiedComplaint know the contents thereofand the same aretrue tomy knowledge, except
those matterstherein which are statedtobe alleged on information and belief,and as tothose
matterI believe them tobe true.
the ofa corporation,one ofthe partiesto theaction; I haveread the annexed
Corporate know the contents thereof and the same are trueto my knowledge, except those
Verification matters therein which arestated tobe alleged on information and belief,and as tothose matters
I believe them to be true.
My belief,as tothose matters therein not statedupon knowledge, is basedupon the following:
five me-en-
orn ecëfñ , 2021
__ __ __ ______ _______ ____
Jo N C D F -JR AYBARA LOPANE
STATE OF NEW YORIC, Ç Î31 i OF ,
being sworn says: I am not a partyto theaction, am over 18 years ofage and
resides at
On I served a truecopy ofthe annexed s
inthe following manner:
mailing the same by regular mail in a sealed envelope, with postage prepaid therein,
By
in a post-office or depository of the U.S. Postal Service with the State of New York,
addressed to the lastknown address.
Sworn to before me on
--________-________________________ __ ----------------------------------
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FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021
SUPREME COUR ''"F THE STATE OF NEW YORK
COUNTY OE ORAn dE
BARBARA LOPANE,
Plaintiff,
TERESA C. KOLK, ORANGE COUNTY MEDI-COACH, INC., a/k/a MEDI-COACH,
INC., and TASHENA LATOYA DAVIS,
Defendants.
SUMMONS AND VERIFIED COMPLAINT
DUPÉE & MONROE, P.C.
Attorneys for Plaintiff
211 Main Street, Box 470
Goshen, New fork 10924
(845) 294-8990
To:
for · . . .
Attorney(s)
Service of a copy ofthe within is hereby a&ûtted..
Dated:
Attorney(s) for
PLEASE TAKE NOTICE
thatthe within is a(certif
led) truecopy ofan
NOT1CE OF entered in th.e office
of the clerkof thewithin named Court on
that an Order.of which the withinisa true copy willbe presented for settle:nentto the
NOTICE OF Hon. one of thejudges ofthe within named Court, at
SETTLEMENT on , at M
. . DUPÈE & P.C. -
.. MONROE,
. Attorneys for Plaintsff
2H Main Street,Box 470
Goshen, New York 10924
(845) 294-8900
8 of 8
Preview
FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021 SUPREME COURT OF THE STATE OF NEW YORK Index No. COUNTY OF ORANGE Date Purchased ------ --------------------X BARBARA LOPANE, Plaintiff designate Orange County Plaintiff, as the place of trial. - against - The basis of venue is TERESA C. ORANGE COUNTY MEDI- PlaintifPs Residence KOLK, COACH, INC., a/k/aMEDI-COACH, INC., and SUMMONS TASHENA LATOYA DAVIS, Plaintiffs' Defendants. Address: -------- ---------------- -----X Senior Middletown Way, New York 10940 County of Orange To the above named Defendañt(s) YOU ARE HEREBY SUMMONED to answer the complaint in thisaction 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 Plaintiff's Attamey(s) within 20 days after the service of thissamacñs, exclusive of the day of service (or within 30 days after the service is complete ifthis summa= is not delivered to you within the personally State ofNew York); and incase ofyour failure to appear or answer, judgmcñt will be taken against you by default forthe relief demanded in the complaint. Dated: Goshen, New York December 20, 2021 Yours, etc., D EE Q ...- Atto ys fo Plaintiff By: N C. DUPEE, ESQ. Ofiice and Post Office Addres 211 Main Street, Box 470 Goshen, New York 10924 Telephone No.: 845-294-8900 TO: Teresa Kolk 76 Uhlig Road Apt. B117 Middletown, New York 10940 Orange County Medi Coach, Inc. 86 Cottage Street Middletown, New York 10940 Tashena Latoya Davis 22 Fitzgerald Drive B5-9A Middletown, New York 10940 1 of 8 FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE __------------------------------------------------------------ -----¬X BARBARA LOPANE, Plaintiff, -against- VERIFIED COMPLAINT TERESA C. KOLK, ORANGE COUNTY MEDI-COACH, INC., a/k/a MEDI-COACH, INC., and TASHENA LATOYA DAVIS, Defendants. ----------------------------------. -- ------------------------X The plaintiff, Barbara Lopane, by her attorneys, Dupee & Monroe, P.C., as and for her verified complaint, respectively alleges as follows: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF BARBARA LOPANE FIRST: That at all times hereinafter mentioned, the plaintiff Barbara Lopane was and is a resident of.County of Orange, State of New York. SECOND: Upon information and belief, and at alltimes hereiñà fter mentioned, the defendant Teresa C. Kolk, was and is a resident of the County of Orange, State of New York. THIRD: Upon information and Orange Inc. a/k/a Medi- belief, County Medi-Coach, Coach, Inc., (hereinafter "Medi") was and is a domestic corporation duly organized and registered in the State of New York since July 21, 1995 and maintains offices for the transaction of business at 86 Cottage Street, City of Middletown, County of Orange, State of New York. FOURTH: Upon information and belief, Medi is a privately owned company which provides non-emergency medical transportation services as well as taxi services principally in the County of Orange. 2 of 8 FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021 "Davis" FIFTH: Upon information and belief, Tashena Latoya Davis hereinafter was and is a resident of the County of Orange, State of New York. SIXTH: That at all times hereiñafter mentioned, the plaintiff Barbara Lopane was a passenger in a 2009 Ford motor vehicle bearing New York State License Plate No. 105 12TY which was operated by defendant Teresa Kolk and owned by defendant Medi. SEVENTH: That at all times hereinafter mendoned, the defendant Davis was the owner and operator of a 2015 Mazda bearing New York License Plate No. HWM3163. EIGHTH: Upon information and belief, and at alltimes hereinafter mentioned, the defendant, Teresa Kolk was the operator of the aforementioned 2009 Ford bearing New York License Plate Number 10512TY with the expressed and/or implied permission of itsowner, Medi, and was operating same in the course of her employment on June 21, 2018 at .March 25, 2003 at approximately 5:37 P.M. NINTH: Upon information and belief, and at all times hereinafter mentioned, Fitzgerald Drive, in the Town of Wallkill, County of Orange, State of New York was and is a public highway and thoroughfare open to vehicular traffic and was the situs of the accident hereinafter described. TENTH: That on or about Thursday, June 21, 2018 at approximately 5:37 P.M. the motor vehicle operated by the defendant Kolk was proceeding northbound on Fitzgerald Drive, Town of Wallkill, County of Orange, State of New York when defendant Latoya attempted to turn right in front of defendant Kolk's vehicle causing defeñdãñt Kolk to strike the motor vehicle operated by defendant Latoya as a direct and proximate result of the negligent, careless and/or reckless conduct of the defendants herein, and each of them. ELEVENTH: The defendants, Kolk and Davis and each of them, were negligent, 3 of 8 FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021 careless and/or reckless in the ownership, operation, maintenance, management and control of their motor vehicles; in that they failed to look carefully and see what was reasonably there to be seen; in that they failed to properly operate the braking mechanism on their motor vehicles; in that failed to keep the horn and braking mechanisms in good repair; in that they operated they their motor vehicles at an excessive rate of speed; in that they operated their motor vehicles that they knew to be in poor mechanical condition and in particular, the brakes, lights, steering, acceleration and horn devices thereon; in that they failed to observe that degree of caution, prudence and care which was reasonable and proper under the circumstances; in that they failed to keep alert and attentive; in that they operated their motor vehicles while using and/or operating a cell phone; in that they failed to maintain their designated lane of travel; in that defendants operated their motor vehicles while under the influence of alcohol and/or drugs which defendants' impaired each ability to safely operate a motor vehicle; in that defendants operated their motor vehicles while under the influence of prescription medication which impaired their ability to safely operate their motor vehicles; in that they failed to keep their motor vehicle under proper control; in that the defendants and each of them operated their aforementioned motor vehicles in violation of one or more New York State Vehicle and Traffic Laws and in particular Vehicle and Traffic Law and the defendants otherwise failed to take those precautions reasonable and necessary to avoid the occurrence hereinabove described. TWELFTH: The defendant, Medi, is vicariously liable for the negligent, careless and/or reckless actions of the defendant Teresa Kolk as set forth herein by operation of law pursuant to VTL §388 and the Doctrine ofRespondeat Superior and was further negligent and/or careless in failing to properly maintain the motor vehicle as set forth above. injury" THIRTEENTH: That the plaintiff Barbara Lopane has sustained a "serious 4 of 8 FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021 as defined by New York State Insurance Law §S102(4) and an economic loss greater than basic economic loss as defined by New York Insurance Law §5102(1). FOURTEENTH: Upon information and belief, and at alltimes hereinafter person" mentioned, the plaintiff Barbara Lopane was and is a "covered as such term is defined by the New York State Insurance Law. FIFTEENTH: That by reason thereof, the plaintiff Barbara Lopane is entitled to recover for non-economic loss and for such economic losses as are not included within the loss" definition of "basic economic as such term is defined in the New York State Insurance Law. SIXTEENTH: That by reason of the foregoing, the plaintiff Barbara Lopane was rendered sick, sore, lame and disabled and was caused to sustain serious and severe personal injuries to her mind and body, some of which, upon information and belief, are permaneñt with the permanent effects of pain, disability and loss of bodily function. SÈVENTEENTH: That as a direct and proximate result of the foregoing the plaintiff Barbara Lopane has been caused to lose substantial periods of time from her normal vocation and will continue to suffer similar losses in the future. EIGHTEENTH: That this action falls within the exceptions of CPLR §1601, in that it arises out of the use, operation, ownership of a motor vehicle as provided for in CPLR §I602(6). NINETEENTH: That by reason of the foregoing, the plaintiff Barbara Lopane has been dañiaged in an amount in excess of the jurisdictional limits of allother Courts which may have subject matter jurisdiction hereof. 5 of 8 FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021 WHEREFORE, the plaintiff Barbara Lopane demands judgment in an amount in excess of the jurisdictional limits of all other Courts which may have subject matter jurisdiction hereof; together with such interest, costs and disbursements as are appropriate to this action. Dated: Goshen, New York December 20, 2021 Yours, etc., DUPEE & MONROE, P.C. Attorneys for Plaintiff By: C. DUPEE, JR. Q. Office & P.O. Address 211 Main St., Box 470 Goshen, New York 10924 845-294-8900 TO: Teresa Kolk 76 Uhlig Road Apt. B117 Middletown, New York 10940 Orange County Medi Coach, Inc. 86 Cottage Street Middletown, New York 10940 Tashena Latoya Davis 22 Fitzgerald Drive B5-9A Middletown, New York 10940 6 of 8 FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021 STATE OF NEW Y , COUN,TY OF ORANGE I, Certification say that:I am the attorney of record,or ofcounsel with the attorney(s)of record,forthe I haveread the annexed know the contentsthereof and the same are trueto my knowledge, except those matters thereinin which are statedto be alleged on information and belief,and asto those matters,Ibelieve them tobe true. My beliefas to those matters thereinnot stated upon knowledge, isbased upon the following: Affumation The reason I make this affirmation insteadof inwhich your deponent maintains his office. I affirmthatthe foregoing statements are trueunder penalties of perjury. Dated: _____---------------__ --- __. STATE OF NEW YORK, COUNTY OF ORANGE Barbara Lopane, being duly sworn says: That I am the plaintiffinthe actionherein,I have read the annexed Su_m-mons and VerifiedComplaint know the contents thereofand the same aretrue tomy knowledge, except those matterstherein which are statedtobe alleged on information and belief,and as tothose matterI believe them tobe true. the ofa corporation,one ofthe partiesto theaction; I haveread the annexed Corporate know the contents thereof and the same are trueto my knowledge, except those Verification matters therein which arestated tobe alleged on information and belief,and as tothose matters I believe them to be true. My belief,as tothose matters therein not statedupon knowledge, is basedupon the following: five me-en- orn ecëfñ , 2021 __ __ __ ______ _______ ____ Jo N C D F -JR AYBARA LOPANE STATE OF NEW YORIC, Ç Î31 i OF , being sworn says: I am not a partyto theaction, am over 18 years ofage and resides at On I served a truecopy ofthe annexed s inthe following manner: mailing the same by regular mail in a sealed envelope, with postage prepaid therein, By in a post-office or depository of the U.S. Postal Service with the State of New York, addressed to the lastknown address. Sworn to before me on --________-________________________ __ ---------------------------------- 7 of 8 FILED: ORANGE COUNTY CLERK 12/20/2021 02:55 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/20/2021 SUPREME COUR ''"F THE STATE OF NEW YORK COUNTY OE ORAn dE BARBARA LOPANE, Plaintiff, TERESA C. KOLK, ORANGE COUNTY MEDI-COACH, INC., a/k/a MEDI-COACH, INC., and TASHENA LATOYA DAVIS, Defendants. SUMMONS AND VERIFIED COMPLAINT DUPÉE & MONROE, P.C. Attorneys for Plaintiff 211 Main Street, Box 470 Goshen, New fork 10924 (845) 294-8990 To: for · . . . Attorney(s) Service of a copy ofthe within is hereby a&ûtted.. Dated: Attorney(s) for PLEASE TAKE NOTICE thatthe within is a(certif led) truecopy ofan NOT1CE OF entered in th.e office of the clerkof thewithin named Court on that an Order.of which the withinisa true copy willbe presented for settle:nentto the NOTICE OF Hon. one of thejudges ofthe within named Court, at SETTLEMENT on , at M . . DUPÈE & P.C. - .. MONROE, . Attorneys for Plaintsff 2H Main Street,Box 470 Goshen, New York 10924 (845) 294-8900 8 of 8