SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS
Index No.: 104/2012
SUMMONS AND COMPLAINT
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USAA GENERAL INDEMNITY COMPANY,
Plaintiff,
-against-
KEVIN RIVERA a/k/a KEVIN RIVERA, JR., et al.,
Defendants.
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To the following defendants:
APRIL COOPER, ICYDOR COOPER, JANISE VASQUEZ, EDGAR RODRIGUEZ, JHON VASQUEZ a/k/a JHON VASQUEZ-RAMOS, ALEJANDRO ALVAREZ a/k/a ALEJANDRO ALVAREZ-DARVIN, PRINCESS LAWSON, ARCADIA ADAMS, GABRIEL OSIKOYA, STEVEN DIAZ, MANUEL SANCHEZ a/k/a MANUEL E. SANCHEZ, RAYMON PEREZ, HU-NAM NAM, MENE STATE MEDICAL SUPPLIES, PAIN MANAGEMENT CENTER OF NJ, POMONA PAIN MANAGEMENT, PROFESSIONAL HEALTH CARE, VG CHIROPRACTIC CARE AND V&H REHABILITATION MEDICAL CARE
YOU ARE HEREBY SUMMONED to appear and answer the summons and complaint of USAA GENERAL INDEMNITY COMPANY in the declaratory judgment action filed against you as defendants and to serve a copy of your answers within 30 days after service is complete, 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.
TO THE DEFENDANTS NAMED ABOVE: The foregoing summons are served upon you by publication pursuant to an order of the Hon. Sylvia G. Ash, Justice of the Supreme Court of the State of New York, Kings County, dated July 22, 2013, and filed with the complaint and other papers in the Kings County Clerk’s Office, located at 360 Adams Street, Brooklyn, New York.
NOTICE OF NATURE OF ACTION AND RELIEF SOUGHT: The object of the above-captioned action is for a determination by the court as to whether or not the alleged motor vehicle accidents of 01/24/10, 05/07/10, 05/15/10, 05/23/10, 07/04/10, 07/09/10, 07/13/10, 07/26/10 and 10/05/10, which gave rise to alleged medical care for alleged personal injuries, were legitimate accidents or were staged incidents. USAA INDEMNITY COMPANY seeks a DECLARATION that all nine losses enumerated above were staged, intentional and therefore uncovered losses. USAA further contends that USAA has no duty to defend or indemnify APRIL COOPER, ICYDOR COOPER, JANISE VASQUEZ, EDGAR RODRIGUEZ, JHON VASQUEZ a/k/a JHON VASQUEZ-RAMOS, ALEJANDRO ALVAREZ a/k/a ALEJANDRO ALVAREZ-DARVIN, PRINCESS LAWSON, ARCADIA ADAMS, GABRIEL OSIKOYA, STEVEN DIAZ, MANUEL SANCHEZ a/k/a MANUEL E. SANCHEZ, RAYMON PEREZ, HU-NAM NAM, MENE STATE MEDICAL SUPPLIES, PAIN MANAGEMENT CENTER OF NJ, POMONA PAIN MANAGEMENT, PROFESSIONAL HEALTH CARE, VG CHIROPRACTIC CARE AND V&H REHABILITATION MEDICAL CARE and/or their assignees, for any claims of no-fault, UM, SUM, or BI coverage in connection with the underlying nine incidents noted above.
By: McDONNELL & ADELS, PLLC
401 Franklin Avenue
Garden City, New York 11530
Tel.: 516-328-3500
