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FILED: WESTCHESTER COUNTY CLERK 02/25/2014 INDEX NO. 52793/2014
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/25/2014
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
----------------------------------------------------------------------- x
CONSOLIDATED EDISON COMPANY OF NEW YORK, Index No.:
INC.,
Date Purchased:
Plaintiff designates
Plaintiff, Westchester County as the
place of trial.
- against –
The basis of the venue is
MV PUBLIC TRANSPORTATION, INC. and MACDANIEL Plaintiff maintains place of
TAHKEEN, business in Westchester
County
Defendants.
Summons
Plaintiff’s Address:
4 Irving Place
----------------------------------------------------------------------- X New York, NY 10003
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 attorney(s) within 20 days after the service of this summons,
exclusive of the day of service (or within 30 days after the service is complete if this
summons is not personally delivered to you within the State of New York); and in case of
your failure to appear or answer, judgment will be taken against you by default for the
relief demanded in the complaint.
GOTTLIEB OSTRAGER LLP
Attorneys for Plaintiff
By:________________________
Warren S. Gottlieb, Esq.
333 Westchester Ave, Suite S2205
White Plains, New York 10604
Dated: White Plains, New York (914) 909-4646 (telephone)
February 25, 2014
DEFENDANT ADDRESSES:
MV PUBLIC TRANSPORTATION, INC.: C/O Secretary of State, One Commerce
Plaza, 99 Washington Avenue, Albany, NY 12231
MACDANIEL TAHKEEN: 226 Alanede St., Rochester, NY 14613
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC., Court Index No.
Plaintiff(s), GO File No.
-against-
COMPLAINT
MV PUBLIC TRANSPORTATION, INC. and MACDANIEL
TAHKEEN
Defendant(s).
Plaintiff CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. (hereinafter
“CON ED”), by its attorneys, complaining against the defendant(s), sets forth and alleges
as follows:
1. CON ED is a New York corporation and transacts business in Westchester County,
New York.
2. Upon information and belief, Defendant MV PUBLIC TRANSPORTATION, INC.
is a California corporation with a place of business at 1957 Richmond Terrace, Staten
Island, NY 10302.
3. Upon information and belief, Defendant MACDANIEL TAHKEEN is an
individual residing at 226 Alanede St., Rochester, NY 14613.
AS AND FOR A FIRST CAUSE OF ACTION
4. Plaintiff repeats and realleges each and every allegation contained in Paragraphs "1"
through "3" inclusive, as if more fully set forth herein at length.
5. At all times hereinafter mentioned, CON ED owned certain property located at Arden
Avenue and Service Road, in Richmond County, State of New York (“Property”).
6. That on October 26, 2012, Defendant MACDANIEL TAHKEEN was entrusted with
a motor vehicle (“Vehicle”), owned by Defendant MV PUBLIC TRANSPORTATION,
INC.
7. That at the aforesaid time and place, the operator of Defendant MV PUBLIC
TRANSPORTATION, INC.’s Vehicle, Defendant MACDANIEL TAHKEEN, caused
damage to the Property. The damage occurred by reason of the negligence of the Defendant
MV PUBLIC TRANSPORTATION, INC. and Defendant MACDANIEL TAHKEEN.
8. That by reason of the foregoing, Plaintiff CON ED has sustained property damage.
9. That as a result of the Defendants’ negligence, Plaintiff CON ED sought repairs to
their Property.
10. Defendant MV PUBLIC TRANSPORTATION, INC. was negligent in the
ownership and maintenance of the Vehicle.
11. That Plaintiff CON ED, sustained damages in the amount of $34,191.99 due to the
negligence of the Defendants.
12. That the proximate cause of the loss to Plaintiff CON ED was the negligence of the
Defendants.
WHEREFORE, Plaintiff demands judgment against Defendants for the sum of
$34,191.99, with interest from October 26, 2012, together with costs and disbursements of
this action.
Dated: White Plains, New York
February 25, 2014
Rule 130-1.1-a Certification
________________________
Warren S. Gottlieb, Esq.
Gottlieb Ostrager LLP
Attorneys for Plaintiff
333 Westchester Ave, Ste S2205
White Plains, NY 10604
Telephone: (914) 909-4646
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FILED: WESTCHESTER COUNTY CLERK 02/25/2014 INDEX NO. 52793/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/25/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER ----------------------------------------------------------------------- x CONSOLIDATED EDISON COMPANY OF NEW YORK, Index No.: INC., Date Purchased: Plaintiff designates Plaintiff, Westchester County as the place of trial. - against – The basis of the venue is MV PUBLIC TRANSPORTATION, INC. and MACDANIEL Plaintiff maintains place of TAHKEEN, business in Westchester County Defendants. Summons Plaintiff’s Address: 4 Irving Place ----------------------------------------------------------------------- X New York, NY 10003 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 attorney(s) within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. GOTTLIEB OSTRAGER LLP Attorneys for Plaintiff By:________________________ Warren S. Gottlieb, Esq. 333 Westchester Ave, Suite S2205 White Plains, New York 10604 Dated: White Plains, New York (914) 909-4646 (telephone) February 25, 2014 DEFENDANT ADDRESSES: MV PUBLIC TRANSPORTATION, INC.: C/O Secretary of State, One Commerce Plaza, 99 Washington Avenue, Albany, NY 12231 MACDANIEL TAHKEEN: 226 Alanede St., Rochester, NY 14613 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER CONSOLIDATED EDISON COMPANY OF NEW YORK, INC., Court Index No. Plaintiff(s), GO File No. -against- COMPLAINT MV PUBLIC TRANSPORTATION, INC. and MACDANIEL TAHKEEN Defendant(s). Plaintiff CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. (hereinafter “CON ED”), by its attorneys, complaining against the defendant(s), sets forth and alleges as follows: 1. CON ED is a New York corporation and transacts business in Westchester County, New York. 2. Upon information and belief, Defendant MV PUBLIC TRANSPORTATION, INC. is a California corporation with a place of business at 1957 Richmond Terrace, Staten Island, NY 10302. 3. Upon information and belief, Defendant MACDANIEL TAHKEEN is an individual residing at 226 Alanede St., Rochester, NY 14613. AS AND FOR A FIRST CAUSE OF ACTION 4. Plaintiff repeats and realleges each and every allegation contained in Paragraphs "1" through "3" inclusive, as if more fully set forth herein at length. 5. At all times hereinafter mentioned, CON ED owned certain property located at Arden Avenue and Service Road, in Richmond County, State of New York (“Property”). 6. That on October 26, 2012, Defendant MACDANIEL TAHKEEN was entrusted with a motor vehicle (“Vehicle”), owned by Defendant MV PUBLIC TRANSPORTATION, INC. 7. That at the aforesaid time and place, the operator of Defendant MV PUBLIC TRANSPORTATION, INC.’s Vehicle, Defendant MACDANIEL TAHKEEN, caused damage to the Property. The damage occurred by reason of the negligence of the Defendant MV PUBLIC TRANSPORTATION, INC. and Defendant MACDANIEL TAHKEEN. 8. That by reason of the foregoing, Plaintiff CON ED has sustained property damage. 9. That as a result of the Defendants’ negligence, Plaintiff CON ED sought repairs to their Property. 10. Defendant MV PUBLIC TRANSPORTATION, INC. was negligent in the ownership and maintenance of the Vehicle. 11. That Plaintiff CON ED, sustained damages in the amount of $34,191.99 due to the negligence of the Defendants. 12. That the proximate cause of the loss to Plaintiff CON ED was the negligence of the Defendants. WHEREFORE, Plaintiff demands judgment against Defendants for the sum of $34,191.99, with interest from October 26, 2012, together with costs and disbursements of this action. Dated: White Plains, New York February 25, 2014 Rule 130-1.1-a Certification ________________________ Warren S. Gottlieb, Esq. Gottlieb Ostrager LLP Attorneys for Plaintiff 333 Westchester Ave, Ste S2205 White Plains, NY 10604 Telephone: (914) 909-4646