Preview
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
Index No.:
SUPREME COURT OF THE STATE OF NEW YORK
Date Purchased:
COUNTY OF KINGS
----------------------------------------------------------------------X SUMMONS
EMILY LONGFIELD
Plaintiff designates Kings
Plaintiff(s), County as the place of trial.
-against- The basis of venue is:
Plaintiff's Residence
BROOKLYN BRIDGE PARK CORPORATION, ST.
ANN'S WAREHOUSE, INC., BROOKLYN BRIDGE Plaintiff resides at:
PARK DEVELOPMENT CORPORATION, and 22 Remsen Street, Apt. 2
NEW YORK STATE URBAN DEVELOPMENT Brooklyn, NY 11201
CORPORATION D/B/A EMPIRE STATE County of Kings
DEVELOPMENT CORPORATION
Defendant(s).
----------------------------------------------------------------------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: Great Neck, NY
March 21, 2022
HOWARD SCHATZ
SILBOWITZ, GARAFOLA, SILBOWITZ &
SCHATZ LLP
ATTORNEY FOR PLAINTIFF(S)
EMILY LONGFIELD
55 WATER MILL LANE, SUITE 400
GREAT NECK, NY 11021
(212) 354-6800
Our File No. 202200439
1 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
TO:
Brooklyn Bridge Park Corporation
334 Furman Street, Suite 1
Brooklyn, NY 11201
St. Ann's Warehouse, Inc.
55 Washington Street, Suite 458
Brooklyn, NY 11201
Brooklyn Bridge Park Development Corporation
633 Third Avenue, 33rd Floor
New York, NY 10017
New York State Urban Development Corporation d/b/a Empire State Development Corporation
633 3rd Avenue, 34
New York, NY 10017
2 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No.:
----------------------------------------------------------------------------X Date Purchased:
EMILY LONGFIELD
VERIFIED
Plaintiff(s), COMPLAINT
-against-
BROOKLYN BRIDGE PARK CORPORATION, ST. ANN'S
WAREHOUSE, INC., BROOKLYN BRIDGE PARK
DEVELOPMENT CORPORATION, and NEW YORK STATE
URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE
STATE DEVELOPMENT CORPORATION
Defendant(s).
----------------------------------------------------------------------------X
Plaintiff by her attorneys, SILBOWITZ, GARAFOLA, SILBOWITZ & SCHATZ LLP
complaining of the Defendants, respectfully alleges, upon information and belief:
1. That at all times herein mentioned, the Plaintiff was, and still is a resident of the
County of Kings, State of New York.
2. That at all times herein mentioned, the Defendant BROOKLYN BRIDGE PARK
CORPORATION was and still is a domestic not-for-profit corporation, duly organized and
existing under and by virtue of the laws of the State of New York.
3. That at all times herein mentioned, the Defendant BROOKLYN BRIDGE PARK
CORPORATION maintained a principal place of business in the County of Kings, State of New
York.
4. That at all times herein mentioned, the Defendant ST. ANN'S WAREHOUSE,
INC. was and still is a domestic not-for-profit corporation duly organized and existing under and
by virtue of the laws of the State of New York.
5. That at all times herein mentioned, the Defendant, ST. ANN'S WAREHOUSE,
INC. maintained a principal place of business in the County of Kings, State of New York.
3 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
6. That at all times herein mentioned, the Defendant BROOKLYN BRIDGE PARK
DEVELOPMENT CORPORATION was and still is a domestic not-for-profit corporation, duly
organized and existing under and by virtue of the laws of the State of New York.
7. That at all times herein mentioned, the Defendant BROOKLYN BRIDGE PARK
DEVELOPMENT CORPORATION maintained a principal place of business in the County,
City and State of New York.
8. That at all times herein mentioned, the Defendant NEW YORK STATE URBAN
DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT
CORPORATION was and still is a domestic not-for-profit corporation, duly organized and
existing under and by virtue of the laws of the State of New York.
9. That at all times herein mentioned, the Defendant NEW YORK STATE URBAN
DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT
CORPORATION maintained a principal place of business in the County, City and State of New
York.
10. That at all times herein mentioned, the Defendant, BROOKLYN BRIDGE PARK
CORPORATION owned the premises and appurtenances and fixtures thereto, located at 11
Water Street also identified as Block 25, Lot 12R, in the County of Kings, City and State of New
York.
11. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK CORPORATION managed the aforesaid premises.
12. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK CORPORATION controlled the aforesaid premises.
2
4 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
13. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK CORPORATION maintained the aforesaid premises.
14. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK CORPORATION repaired the aforesaid premises.
15. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK CORPORATION was the lessee of the aforesaid premises.
16. That at all times herein mentioned, the Defendant, BROOKLYN BRIDGE PARK
DEVELOPMENT CORPORATION owned the premises and appurtenances and fixtures
thereto, located at 11 Water Street also identified as Block 25, Lot 12R, in the County of Kings,
City and State of New York.
17. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION managed the aforesaid
premises.
18. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION controlled the aforesaid
premises.
19. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION maintained the aforesaid
premises.
20. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION repaired the aforesaid
premises.
3
5 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
21. That at all times herein mentioned, and upon information and belief, the Defendant,
BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION was the lessor of the
aforesaid premises.
22. That at all times herein mentioned, the Defendant, NEW YORK STATE URBAN
DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT
CORPORATION owned the premises and appurtenances and fixtures thereto, located at 11
Water Street also identified as Block 25, Lot 12R, in the County of Kings, City and State of New
York.
23. That at all times herein mentioned, and upon information and belief, the Defendant,
NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE
STATE DEVELOPMENT CORPORATION managed the aforesaid premises.
24. That at all times herein mentioned, and upon information and belief, the Defendant,
NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE
STATE DEVELOPMENT CORPORATION controlled the aforesaid premises.
25. That at all times herein mentioned, and upon information and belief, the Defendant,
NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE
STATE DEVELOPMENT CORPORATION maintained the aforesaid premises.
26. That at all times herein mentioned, and upon information and belief, the Defendant,
NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE
STATE DEVELOPMENT CORPORATION repaired the aforesaid premises.
27. That at all times herein mentioned, and upon information and belief, the Defendant,
NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE
STATE DEVELOPMENT CORPORATION was the lessor of the aforesaid premises.
4
6 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
28. That at all times herein mentioned, and upon information and belief, the Defendant,
ST. ANN'S WAREHOUSE, INC. managed the aforesaid premises.
29. That at all times herein mentioned, and upon information and belief, the Defendant,
ST. ANN'S WAREHOUSE, INC. controlled the aforesaid premises.
30. That at all times herein mentioned, and upon information and belief, the Defendant,
ST. ANN'S WAREHOUSE, INC. maintained the aforesaid premises.
31. That at all times herein mentioned, and upon information and belief, the Defendant,
ST. ANN'S WAREHOUSE, INC. repaired the aforesaid premises.
32. That at all times herein mentioned, and upon information and belief, the Defendant,
ST. ANN'S WAREHOUSE, INC. was the lessee of the aforesaid premises.
33. That on April 28, 2020, Plaintiff EMILY LONGFIELD was lawfully on the public
sidewalk in front of the aforesaid premises.
34. That on April 28, 2020, while Plaintiff EMILY LONGFIELD was lawfully on the
public sidewalk in front of the aforesaid premises, she was caused to trip and fall and sustain
serious and permanent injuries.
35. That the above-mentioned occurrence, and the results thereof, were caused by the
joint, several and concurrent negligence of the Defendants and/or said Defendants' agents,
servants, employees and/or licensees in the ownership, operation, management, supervision,
maintenance and control of the aforesaid premises.
36. That no negligence on the part of the Plaintiff contributed to the occurrence alleged
herein in any manner whatsoever.
37. That by reason of the foregoing, Plaintiff EMILY LONGFIELD was caused to
sustain serious injuries and to have suffered pain and suffering; that these injuries and their effects
5
7 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
will be permanent; and as a result of said injuries, Plaintiff has been caused to incur, and will
continue to incur, expenses for medical care and attention; and, as a further result, Plaintiff was,
and will continue to be, rendered unable to perform Plaintiff's normal activities and duties and has
sustained a resultant loss therefrom.
38. That as a result of the foregoing, Plaintiff was damaged in a sum which exceeds
the jurisdictional limits of all lower courts which would otherwise have jurisdiction.
WHEREFORE, Plaintiff(s) demand(s) judgment against the Defendants herein, in a
sum exceeding the jurisdictional limits of all lower courts which would otherwise have
jurisdiction, together with the costs and disbursements of this action.
Dated: Great Neck, NY
March 21, 2022
Yours, etc.
HOWARD SCHATZ
SILBOWITZ, GARAFOLA, SILBOWITZ &
SCHATZ LLP
ATTORNEY FOR PLAINTIFF(S)
EMILY LONGFIELD
55 WATER MILL LANE, SUITE 400
GREAT NECK, NY 11021
(212) 354-6800
Our File No. 202200439
6
8 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
ATTORNEY'S VERIFICATION
HOWARD SCHATZ, 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 SILBOWITZ, GARAFOLA, SILBOWITZ & SCHATZ LLP,
attorneys of record for Plaintiff(s), EMILY LONGFIELD. I have read the annexed
COMPLAINT and know the contents thereof, and the same are true to my knowledge, except
those matters therein which are stated to be alleged upon information and belief, and as to those
matters I believe them to be true. My belief, as to those matters therein not stated upon
knowledge, is based upon facts, records, and other pertinent information contained in my files.
This verification is made by me because Plaintiff(s) is/are not presently in the county
wherein I maintain my offices.
DATED: Great Neck, NY
March 21, 2022
_________________________________________
HOWARD SCHATZ
7
9 of 10
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022
Index No.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
EMILY LONGFIELD
Plaintiff(s),
-against-
BROOKLYN BRIDGE PARK CORPORATION, ST. ANN'S WAREHOUSE, INC.,
BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION, and NEW YORK STATE
URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT
CORPORATION
Defendant(s).
SUMMONS AND VERIFIED COMPLAINT
Silbowitz, Garafola, Silbowitz & Schatz LLP
Attorneys for Plaintiff(s)
55 Water Mill Lane, Suite 400
Great Neck, NY 11021
(212) 354-6800
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts
of New York State, certifies that, upon, information and belief and reasonable inquiry, the
contentions contained in the annexed document are not frivolous.
Dated: March 21, 2022
Signature___________________________
Howard Schatz
8
10 of 10
Preview
FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 Index No.: SUPREME COURT OF THE STATE OF NEW YORK Date Purchased: COUNTY OF KINGS ----------------------------------------------------------------------X SUMMONS EMILY LONGFIELD Plaintiff designates Kings Plaintiff(s), County as the place of trial. -against- The basis of venue is: Plaintiff's Residence BROOKLYN BRIDGE PARK CORPORATION, ST. ANN'S WAREHOUSE, INC., BROOKLYN BRIDGE Plaintiff resides at: PARK DEVELOPMENT CORPORATION, and 22 Remsen Street, Apt. 2 NEW YORK STATE URBAN DEVELOPMENT Brooklyn, NY 11201 CORPORATION D/B/A EMPIRE STATE County of Kings DEVELOPMENT CORPORATION Defendant(s). ----------------------------------------------------------------------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: Great Neck, NY March 21, 2022 HOWARD SCHATZ SILBOWITZ, GARAFOLA, SILBOWITZ & SCHATZ LLP ATTORNEY FOR PLAINTIFF(S) EMILY LONGFIELD 55 WATER MILL LANE, SUITE 400 GREAT NECK, NY 11021 (212) 354-6800 Our File No. 202200439 1 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 TO: Brooklyn Bridge Park Corporation 334 Furman Street, Suite 1 Brooklyn, NY 11201 St. Ann's Warehouse, Inc. 55 Washington Street, Suite 458 Brooklyn, NY 11201 Brooklyn Bridge Park Development Corporation 633 Third Avenue, 33rd Floor New York, NY 10017 New York State Urban Development Corporation d/b/a Empire State Development Corporation 633 3rd Avenue, 34 New York, NY 10017 2 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No.: ----------------------------------------------------------------------------X Date Purchased: EMILY LONGFIELD VERIFIED Plaintiff(s), COMPLAINT -against- BROOKLYN BRIDGE PARK CORPORATION, ST. ANN'S WAREHOUSE, INC., BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION, and NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION Defendant(s). ----------------------------------------------------------------------------X Plaintiff by her attorneys, SILBOWITZ, GARAFOLA, SILBOWITZ & SCHATZ LLP complaining of the Defendants, respectfully alleges, upon information and belief: 1. That at all times herein mentioned, the Plaintiff was, and still is a resident of the County of Kings, State of New York. 2. That at all times herein mentioned, the Defendant BROOKLYN BRIDGE PARK CORPORATION was and still is a domestic not-for-profit corporation, duly organized and existing under and by virtue of the laws of the State of New York. 3. That at all times herein mentioned, the Defendant BROOKLYN BRIDGE PARK CORPORATION maintained a principal place of business in the County of Kings, State of New York. 4. That at all times herein mentioned, the Defendant ST. ANN'S WAREHOUSE, INC. was and still is a domestic not-for-profit corporation duly organized and existing under and by virtue of the laws of the State of New York. 5. That at all times herein mentioned, the Defendant, ST. ANN'S WAREHOUSE, INC. maintained a principal place of business in the County of Kings, State of New York. 3 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 6. That at all times herein mentioned, the Defendant BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION was and still is a domestic not-for-profit corporation, duly organized and existing under and by virtue of the laws of the State of New York. 7. That at all times herein mentioned, the Defendant BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION maintained a principal place of business in the County, City and State of New York. 8. That at all times herein mentioned, the Defendant NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION was and still is a domestic not-for-profit corporation, duly organized and existing under and by virtue of the laws of the State of New York. 9. That at all times herein mentioned, the Defendant NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION maintained a principal place of business in the County, City and State of New York. 10. That at all times herein mentioned, the Defendant, BROOKLYN BRIDGE PARK CORPORATION owned the premises and appurtenances and fixtures thereto, located at 11 Water Street also identified as Block 25, Lot 12R, in the County of Kings, City and State of New York. 11. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK CORPORATION managed the aforesaid premises. 12. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK CORPORATION controlled the aforesaid premises. 2 4 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 13. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK CORPORATION maintained the aforesaid premises. 14. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK CORPORATION repaired the aforesaid premises. 15. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK CORPORATION was the lessee of the aforesaid premises. 16. That at all times herein mentioned, the Defendant, BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION owned the premises and appurtenances and fixtures thereto, located at 11 Water Street also identified as Block 25, Lot 12R, in the County of Kings, City and State of New York. 17. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION managed the aforesaid premises. 18. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION controlled the aforesaid premises. 19. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION maintained the aforesaid premises. 20. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION repaired the aforesaid premises. 3 5 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 21. That at all times herein mentioned, and upon information and belief, the Defendant, BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION was the lessor of the aforesaid premises. 22. That at all times herein mentioned, the Defendant, NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION owned the premises and appurtenances and fixtures thereto, located at 11 Water Street also identified as Block 25, Lot 12R, in the County of Kings, City and State of New York. 23. That at all times herein mentioned, and upon information and belief, the Defendant, NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION managed the aforesaid premises. 24. That at all times herein mentioned, and upon information and belief, the Defendant, NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION controlled the aforesaid premises. 25. That at all times herein mentioned, and upon information and belief, the Defendant, NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION maintained the aforesaid premises. 26. That at all times herein mentioned, and upon information and belief, the Defendant, NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION repaired the aforesaid premises. 27. That at all times herein mentioned, and upon information and belief, the Defendant, NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION was the lessor of the aforesaid premises. 4 6 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 28. That at all times herein mentioned, and upon information and belief, the Defendant, ST. ANN'S WAREHOUSE, INC. managed the aforesaid premises. 29. That at all times herein mentioned, and upon information and belief, the Defendant, ST. ANN'S WAREHOUSE, INC. controlled the aforesaid premises. 30. That at all times herein mentioned, and upon information and belief, the Defendant, ST. ANN'S WAREHOUSE, INC. maintained the aforesaid premises. 31. That at all times herein mentioned, and upon information and belief, the Defendant, ST. ANN'S WAREHOUSE, INC. repaired the aforesaid premises. 32. That at all times herein mentioned, and upon information and belief, the Defendant, ST. ANN'S WAREHOUSE, INC. was the lessee of the aforesaid premises. 33. That on April 28, 2020, Plaintiff EMILY LONGFIELD was lawfully on the public sidewalk in front of the aforesaid premises. 34. That on April 28, 2020, while Plaintiff EMILY LONGFIELD was lawfully on the public sidewalk in front of the aforesaid premises, she was caused to trip and fall and sustain serious and permanent injuries. 35. That the above-mentioned occurrence, and the results thereof, were caused by the joint, several and concurrent negligence of the Defendants and/or said Defendants' agents, servants, employees and/or licensees in the ownership, operation, management, supervision, maintenance and control of the aforesaid premises. 36. That no negligence on the part of the Plaintiff contributed to the occurrence alleged herein in any manner whatsoever. 37. That by reason of the foregoing, Plaintiff EMILY LONGFIELD was caused to sustain serious injuries and to have suffered pain and suffering; that these injuries and their effects 5 7 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 will be permanent; and as a result of said injuries, Plaintiff has been caused to incur, and will continue to incur, expenses for medical care and attention; and, as a further result, Plaintiff was, and will continue to be, rendered unable to perform Plaintiff's normal activities and duties and has sustained a resultant loss therefrom. 38. That as a result of the foregoing, Plaintiff was damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. WHEREFORE, Plaintiff(s) demand(s) judgment against the Defendants herein, in a sum exceeding the jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with the costs and disbursements of this action. Dated: Great Neck, NY March 21, 2022 Yours, etc. HOWARD SCHATZ SILBOWITZ, GARAFOLA, SILBOWITZ & SCHATZ LLP ATTORNEY FOR PLAINTIFF(S) EMILY LONGFIELD 55 WATER MILL LANE, SUITE 400 GREAT NECK, NY 11021 (212) 354-6800 Our File No. 202200439 6 8 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 ATTORNEY'S VERIFICATION HOWARD SCHATZ, 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 SILBOWITZ, GARAFOLA, SILBOWITZ & SCHATZ LLP, attorneys of record for Plaintiff(s), EMILY LONGFIELD. I have read the annexed COMPLAINT and know the contents thereof, and the same are true to my knowledge, except those matters therein which are stated to be alleged upon information and belief, and as to those matters I believe them to be true. My belief, as to those matters therein not stated upon knowledge, is based upon facts, records, and other pertinent information contained in my files. This verification is made by me because Plaintiff(s) is/are not presently in the county wherein I maintain my offices. DATED: Great Neck, NY March 21, 2022 _________________________________________ HOWARD SCHATZ 7 9 of 10 FILED: KINGS COUNTY CLERK 03/21/2022 09:00 AM INDEX NO. 508119/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/21/2022 Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS EMILY LONGFIELD Plaintiff(s), -against- BROOKLYN BRIDGE PARK CORPORATION, ST. ANN'S WAREHOUSE, INC., BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION, and NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION Defendant(s). SUMMONS AND VERIFIED COMPLAINT Silbowitz, Garafola, Silbowitz & Schatz LLP Attorneys for Plaintiff(s) 55 Water Mill Lane, Suite 400 Great Neck, NY 11021 (212) 354-6800 Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that, upon, information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: March 21, 2022 Signature___________________________ Howard Schatz 8 10 of 10