Your recipients will receive an email with this envelope shortly and will be able to access it on trellis. You can always see your envelopes by clicking the Inbox on the top right hand corner.
Michael E Cirenza As Executor Of The Estate Of ANNE REGINA CIRENZA, Gerard X Mccarthy v. Kathleen Flynn, Jeffrey D Munjack, Jdm Financial Group, Elizabeth Andronica Defalco, Gregory Andronica, Joyce Mccarthy
On July 29, 2021 a commercial division case was filed by (Subcribe to view) represented by (Subcribe to view) against (Subscribe to view) represented by (Subscribe to view) in the jurisdiction of Nassau County. Judge Timothy Driscoll presiding.
Case Details
Case Number
Filing Date
July 29, 2021
Last Refreshed
May 28, 2024
Filing Location
Nassau County, NY
Filing Court House
Supreme
Category
Commercial Division
Practice Area
Commercial
Matter Type
General Commercial
Status
Active
Overview
Causes of Action
1. DECLARATORY JUDGMENT against Flynn, Munjack and JDM
2. CONVERSION against Flynn
3. MONEY HAD AND RECEIVED against Flynn
4. UNJUST ENRICHMENT against Flynn
5. FRAUD - COUNT I against Flynn
6. UNDUE INFLUENCE against Flynn
7. FRAUD - COUNT II against Flynn
8. BREACH OF FIDUCIARY DUTY against Flynn
9. (ACCOUNTING against Flynn
10. AIDING AND ABETTING FRAUD against Munjack & JDM
11. AIDING AND ABETTING BREACH OF FIDUCIARY DUTY against Muniack & JDM_
TWELFTHCAUSE OF ACTION AIDING AND ABETTING CONVERSION against Munjack & JDM
Case Complaint Summary
This complaint is a legal document filed in the Supreme Court of the State of New York, County of Nassau. The plaintiffs in this case are Anne Regina Cirenza and Gerard X. McCarthy, and the defendants are Kathleen Flynn, Jeffrey D. Munjack, and J…...
Parties
Plaintiffs
Anne Regina Cirenza
Gerard X Mccarthy
Michael E Cirenza As Executor Of The Estate Of
Anne Regina Cirenza
Attorneys for Plaintiffs
Bladykas, Lois Ann
Farinacci, John G.
Morgenstern, Rachel Anne
Sy, Elizabeth S.
Defendants
Elizabeth Andronica Defalco
Gregory Andronica
Jdm Financial Group
Jeffrey D Munjack
Joyce Mccarthy
Kathleen Flynn
Attorneys for Defendants
Lacoff, Brian Andrew
Mintz, Cheryl Felice
Parkas, Bill P.
Ronan, Christopher Prior
Stagg, Thomas E
Truitt, Alexander Asher
Case Documents
LETTER / CORRESPONDENCE TO JUDGE
Date: May 20, 2024
COURT NOTICE
Date: May 15, 2024
TRANSCRIPT OF PROCEEDINGS
Date: May 06, 2024
TRANSCRIPT OF PROCEEDINGS
Date: Apr 23, 2024
TRANSCRIPT OF PROCEEDINGS - CERTIFIED
Date: Apr 16, 2024
STATEMENT OF MATERIAL FACTS (Motion 006)
Date: Apr 12, 2024
MEMORANDUM OF LAW IN REPLY (Motion 006)
Date: Apr 12, 2024
RESPONSE TO STATEMENT OF MATERIAL FACTS (Motion 007)
Date: Apr 12, 2024
EXHIBIT(S) - U (Motion 007)
Date: Apr 12, 2024
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion 007)
Date: Apr 12, 2024
MEMORANDUM OF LAW IN REPLY (Motion 007)
Date: Apr 12, 2024
COURT NOTICE
Date: Apr 08, 2024
LETTER / CORRESPONDENCE TO JUDGE (Motion 006)
Date: Apr 05, 2024
LETTER / CORRESPONDENCE TO JUDGE (Motion 006)
Date: Apr 04, 2024
RESPONSE TO STATEMENT OF MATERIAL FACTS (Motion 007)
Date: Apr 03, 2024
RESPONSE TO STATEMENT OF MATERIAL FACTS (Motion 006)
Date: Apr 03, 2024
MEMORANDUM OF LAW IN OPPOSITION (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - N (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - M (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - L (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - K (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - J (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - I (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - A (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - H (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - R (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - G (Motion 006)
Date: Apr 03, 2024
AFFIDAVIT (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - T (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - Q (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - F (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - A (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - V (Motion 006)
Date: Apr 03, 2024
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - U (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - S (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - E (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - P (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - O (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - D (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - A (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - C (Motion 006)
Date: Apr 03, 2024
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion 006)
Date: Apr 03, 2024
EXHIBIT(S) - B (Motion 006)
Date: Apr 03, 2024
NOTE OF ISSUE:WITH JURY
Date: Apr 02, 2024
COURT NOTICE
Date: Mar 28, 2024
LETTER / CORRESPONDENCE TO JUDGE (Motion 006)
Date: Mar 27, 2024
MEMORANDUM OF LAW IN SUPPORT (Motion 007)
Date: Mar 11, 2024
STATEMENT OF MATERIAL FACTS (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - T (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - S (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - R (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - Q (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - P (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - O (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - N (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - M (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - L (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - A (Motion 007)
Date: Mar 11, 2024
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion 007)
Date: Mar 11, 2024
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - K (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - J (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - I (Motion 007)
Date: Mar 11, 2024
NOTICE OF MOTION (Motion 007) Corrected
Date: Mar 11, 2024
EXHIBIT(S) - H (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - G (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - F (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - C (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - E (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - D (Motion 007)
Date: Mar 11, 2024
EXHIBIT(S) - B (Motion 007)
Date: Mar 11, 2024
STIPULATION - SO ORDERED
Date: Mar 07, 2024
STIPULATION - CONFIDENTIALITY ( REQUEST TO SO ORDER )
Date: Feb 28, 2024
COURT NOTICE
Date: Feb 27, 2024
LETTER / CORRESPONDENCE TO JUDGE
Date: Feb 23, 2024
EXHIBIT(S) - A
Date: Feb 23, 2024
LETTER / CORRESPONDENCE TO JUDGE
Date: Feb 23, 2024
LETTER / CORRESPONDENCE TO JUDGE
Date: Feb 23, 2024
EXHIBIT(S) - B
Date: Feb 23, 2024
EXHIBIT(S) - A
Date: Feb 23, 2024
LETTER / CORRESPONDENCE TO JUDGE (Motion 006)
Date: Feb 20, 2024
COURT NOTICE
Date: Feb 20, 2024
LETTER / CORRESPONDENCE TO JUDGE
Date: Feb 14, 2024
ORDER - CERTIFICATION
Date: Feb 07, 2024
LETTER / CORRESPONDENCE TO JUDGE
Date: Feb 02, 2024
COURT NOTICE
Date: Feb 02, 2024
EXHIBIT(S) - M (Motion 006)
Date: Jan 12, 2024
MEMORANDUM OF LAW IN SUPPORT (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - L (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - R (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - K (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - J (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - Q (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - F (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - P (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - I (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - O (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - E (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - H (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - N (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - G (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - D (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - C (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - B (Motion 006)
Date: Jan 12, 2024
EXHIBIT(S) - A (Motion 006)
Date: Jan 12, 2024
STATEMENT OF MATERIAL FACTS (Motion 006)
Date: Jan 12, 2024
AFFIRMATION (Motion 006)
Date: Jan 12, 2024
AFFIRMATION (Motion 006)
Date: Jan 12, 2024
NOTICE OF MOTION (Motion 006) Corrected
Date: Jan 12, 2024
LETTER / CORRESPONDENCE TO JUDGE
Date: Jan 04, 2024
COURT NOTICE
Date: Jan 04, 2024
LETTER / CORRESPONDENCE TO JUDGE
Date: Jan 04, 2024
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Jan 03, 2024
CONSENT TO CHANGE ATTORNEY (POST RJI)
Date: Dec 27, 2023
COURT NOTICE
Date: Dec 06, 2023
AFFIRMATION
Date: Dec 06, 2023
ORDER TO SHOW CAUSE - CONFORMED COPY
Date: Dec 06, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: Dec 05, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: Dec 05, 2023
COURT NOTICE
Date: Dec 01, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: Dec 01, 2023
COURT NOTICE
Date: Jul 25, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: Jul 24, 2023
ANSWER (AMENDED)
Date: Jun 06, 2023
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Jun 06, 2023
ANSWER (AMENDED)
Date: Jun 06, 2023
COURT NOTICE
Date: Jun 06, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: May 31, 2023
EXHIBIT(S) - A
Date: May 30, 2023
ANSWER (AMENDED)
Date: May 30, 2023
ANSWER (AMENDED)
Date: May 26, 2023
COMPLAINT (AMENDED)
Date: May 08, 2023
DECISION ORDER ON MOTION (Motion 005)
Date: Apr 19, 2023
STIPULATION - SO ORDERED
Date: Mar 28, 2023
STIPULATION - OTHER - ( REQUEST TO SO ORDER )
Date: Mar 23, 2023
MEMORANDUM OF LAW IN REPLY (Motion 005)
Date: Feb 02, 2023
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion 005)
Date: Feb 02, 2023
EXHIBIT(S) - B (Motion 005)
Date: Feb 02, 2023
EXHIBIT(S) - A (Motion 005)
Date: Feb 02, 2023
EXHIBIT(S) - C (Motion 005)
Date: Feb 02, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: Feb 01, 2023
MEMORANDUM OF LAW IN OPPOSITION (Motion 005)
Date: Jan 27, 2023
AFFIRMATION (Motion 005)
Date: Jan 27, 2023
STIPULATION - ADJOURNMENT OF MOTION (Motion 005)
Date: Jan 06, 2023
MEMORANDUM OF LAW IN SUPPORT (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - O (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - M (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - I (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - L (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - K (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - J (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - N (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - F (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - H (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - E (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - D (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - C (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - B (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - A (Motion 005)
Date: Dec 12, 2022
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion 005)
Date: Dec 12, 2022
NOTICE OF MOTION (Motion 005)
Date: Dec 12, 2022
EXHIBIT(S) - G (Motion 005)
Date: Dec 12, 2022
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Oct 12, 2022
ANSWER
Date: Oct 12, 2022
ORDER - PRELIMINARY CONFERENCE
Date: Oct 12, 2022
ANSWER
Date: Oct 03, 2022
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Sep 28, 2022
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Sep 28, 2022
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Sep 28, 2022
NOTICE OF ENTRY (Motion 004)
Date: Sep 09, 2022
COMPLAINT (AMENDED) Corrected
Date: Sep 09, 2022
ORDER - AMENDING CAPTION (Motion 004)
Date: Sep 08, 2022
EXHIBIT(S) - A (Motion 004)
Date: Jul 27, 2022
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 004)
Date: Jul 27, 2022
NOTICE OF MOTION (Motion 004) Corrected
Date: Jul 27, 2022
ATTACHMENT TO COURT NOTICE
Date: May 05, 2022
COURT NOTICE
Date: May 05, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: May 02, 2022
ORDER - AMENDING CAPTION (Motion 001)
Date: Mar 24, 2022
DECISION ORDER ON MOTION (Motion 003)
Date: Mar 03, 2022
MEMORANDUM OF LAW IN SUPPORT (Motion 003)
Date: Feb 09, 2022
ORDER ( PROPOSED ) (Motion 003)
Date: Feb 09, 2022
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion 003)
Date: Feb 09, 2022
AFFIDAVIT (Motion 003)
Date: Feb 09, 2022
NOTICE OF MOTION (Motion 003) Corrected
Date: Feb 07, 2022
MEMORANDUM OF LAW IN REPLY (Motion 001)
Date: Jan 20, 2022
EXHIBIT(S) - A (Motion 001)
Date: Jan 06, 2022
NOTICE OF CROSS-MOTION (Motion 002) Corrected
Date: Jan 06, 2022
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 001)
Date: Jan 06, 2022
EXHIBIT(S) - C (Motion 001)
Date: Jan 06, 2022
EXHIBIT(S) - B (Motion 001)
Date: Jan 06, 2022
STIPULATION - OTHER
Date: Nov 22, 2021
MEMORANDUM OF LAW IN SUPPORT (Motion 001)
Date: Oct 20, 2021
NOTICE OF MOTION (Motion 001)
Date: Oct 20, 2021
ADDENDUM - COMMERCIAL DIVISION (840C) (Motion 001)
Date: Oct 20, 2021
RJI -RE: NOTICE OF MOTION (Motion 001)
Date: Oct 20, 2021
EXHIBIT(S) - A (Motion 001)
Date: Oct 20, 2021
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 001)
Date: Oct 20, 2021
ANSWER
Date: Sep 27, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Aug 31, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Aug 31, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Aug 16, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Aug 16, 2021
NOTICE OF APPEARANCE (PRE RJI)
Date: Aug 02, 2021
SUMMONS COMPLAINT
Date: Jul 29, 2021Case Events
| Date | Type | Description | |
|---|---|---|---|
| May 20, 2024 |
LETTER / CORRESPONDENCE TO JUDGE Letter to the Honorable Timothy S. Driscoll dated May 20, 2024 |
||
| May 15, 2024 | COURT NOTICE | ||
| May 06, 2024 |
TRANSCRIPT OF PROCEEDINGS Transcript of Proceeding - April 19, 2024 |
||
| April 23, 2024 | TRANSCRIPT OF PROCEEDINGS | ||
| April 16, 2024 |
TRANSCRIPT OF PROCEEDINGS - CERTIFIED Transcript of hearing dated February 28, 2024 |
||
| April 12, 2024 |
STATEMENT OF MATERIAL FACTS (Motion #006) Statement of Material Facts Reply and Response to Counterstatement |
||
| April 12, 2024 | MEMORANDUM OF LAW IN REPLY (Motion #006) | ||
| April 12, 2024 |
RESPONSE TO STATEMENT OF MATERIAL FACTS (Motion #007) Defendant Kathleen Flynn's Response to Plaintiffs' Counter-Statement of Material Facts |
||
| April 12, 2024 |
EXHIBIT(S) - U (Motion #007) Exhibit U - Medical Records of Memorial Sloan Kettering Cancer Center |
||
| April 12, 2024 |
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #007) Reply Affirmation in Support of Motion for Summary Judgment |
||
| April 12, 2024 |
MEMORANDUM OF LAW IN REPLY (Motion #007) Reply Memorandum of Law |
||
| April 08, 2024 | COURT NOTICE | ||
| April 05, 2024 |
LETTER / CORRESPONDENCE TO JUDGE (Motion #006) Request For Expansion Of Word Count For JDM Defendants' Reply Brief ISO MSJ |
||
| April 04, 2024 |
LETTER / CORRESPONDENCE TO JUDGE (Motion #006) Letter to the Hon. Timothy S. Driscoll (Motion Seq. 006 and 007) |
||
| April 03, 2024 |
RESPONSE TO STATEMENT OF MATERIAL FACTS (Motion #007) Response and Counter-Statement of Material Facts |
||
| April 03, 2024 |
RESPONSE TO STATEMENT OF MATERIAL FACTS (Motion #006) Response and Counter Statement of Material Facts Motion Sequence 6 |
||
| April 03, 2024 |
MEMORANDUM OF LAW IN OPPOSITION (Motion #006) Plantiff's Memorandum of Law in Opposition To Motions For Summary Judgment By Kathleen Flynn and the JDM Defendants |
||
| April 03, 2024 |
EXHIBIT(S) - N (Motion #006) Verizon Wireless Bill for Jeffrey Munjacks Call to Kathleen Flynn on Jan. 30, 2017 |
||
| April 03, 2024 |
EXHIBIT(S) - M (Motion #006) Email, dated Jan. 29, 2017, from Jeffrey Munjack to Kathleen Flynn Re: Plans to Have Phone Call on Morning of Jan. 30, 2017 |
||
| April 03, 2024 |
EXHIBIT(S) - L (Motion #006) Emails, dated January 29, 2017, Between Jeffrey Munjack and Kathleen Flynn Re: Decedents Aggressive Cancer and Ability to Sign IRA Distribution Paperwork |
||
| April 03, 2024 |
EXHIBIT(S) - K (Motion #006) Email, dated Jan. 30, 2017, from Jeffrey Munjack to Kathleen Flynn Requesting the Names of the Three New Beneficiaries |
||
| April 03, 2024 |
EXHIBIT(S) - J (Motion #006) Email, dated Jan. 27, 2017, from Kathleen Flynn to Jeffrey Munjack Enclosing January 10th Form |
||
| April 03, 2024 |
EXHIBIT(S) - I (Motion #006) Text Messages Belonging to Elizabeth Andronica |
||
| April 03, 2024 |
EXHIBIT(S) - A (Motion #006) Report of Findings For Signature and Handwriting Examinations dated August 30 2023 |
||
| April 03, 2024 |
EXHIBIT(S) - H (Motion #006) Text Message Chain Between Joyce, Gina, and Patty, dated Nov. 22, 2017 to Jan. 1, 2019 |
||
| April 03, 2024 |
EXHIBIT(S) - R (Motion #006) Second of Two Emails, dated Jan. 30, 2017, from Jeffrey Munjack to Decedent Re: Fraud Alert |
||
| April 03, 2024 |
EXHIBIT(S) - G (Motion #006) Change of Beneficiary Form dated Jan. 10, 2017 |
||
| April 03, 2024 |
AFFIDAVIT (Motion #006) Certification of Business Record sworn to by Richard T. Picciochi Motion Sequences 006 and 007 |
||
| April 03, 2024 |
EXHIBIT(S) - T (Motion #006) Change of Beneficiary Form dated Jan. 30, 2017 |
||
| April 03, 2024 |
EXHIBIT(S) - Q (Motion #006) First of Two Emails, dated Jan. 30, 2017, from Jeffrey Munjack to Decedent Re: Fraud Alert |
||
| April 03, 2024 |
EXHIBIT(S) - F (Motion #006) Decedents Application for an IRA Account with TD Ameritrade Listing Brother and Sister as Beneficiaries, dated Nov. 29, 2006 |
||
| April 03, 2024 |
EXHIBIT(S) - A (Motion #006) Transcription of message |
||
| April 03, 2024 |
EXHIBIT(S) - V (Motion #006) JDM Financial Groups All-Inclusive Fee Disclosure Brochure |
||
| April 03, 2024 |
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #006) Affirmation of Michael E. Cirenza dated March 26 2024 Motion Sequences 006 and 007 |
||
| April 03, 2024 |
EXHIBIT(S) - U (Motion #006) TD America IRA Beneficiary Designation Form, Updated 2023 |
||
| April 03, 2024 |
EXHIBIT(S) - S (Motion #006) Verizon Wireless Bill for Call to Munjack from Decedents Phone on Jan. 30, 2017 at 8:57 p.m |
||
| April 03, 2024 |
EXHIBIT(S) - E (Motion #006) Email, dated Aug. 15, 2008, from Jeffrey Munjack to Kathleen Flynn Re: Updated Financial Projections |
||
| April 03, 2024 |
EXHIBIT(S) - P (Motion #006) Email, dated Jan. 30, 2017, from Jessica Rosenberg to TD Ameritrade Submitting January 30th Form |
||
| April 03, 2024 |
EXHIBIT(S) - O (Motion #006) Email, dated Jan. 30, 2017, from Jeffrey Munjack to Jessica Rosenberg Re: New Beneficiary Designation Form |
||
| April 03, 2024 |
EXHIBIT(S) - D (Motion #006) JDM Defendants IRA Custodial Agreements |
||
| April 03, 2024 |
EXHIBIT(S) - A (Motion #006) Excerpts of Decedents Medical Records from Memorial Sloan Kettering Hospital |
||
| April 03, 2024 |
EXHIBIT(S) - C (Motion #006) Email Chain Between Jeffrey Munjack and Jessica Rosenberg Re: Puported Reason for Difference Between Decedents Current and Prior Signatures |
||
| April 03, 2024 |
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #006) John G. Farinacci Affirmation in Opposition dated April 3, 2024 Motion Sequences 006 and 007 |
||
| April 03, 2024 |
EXHIBIT(S) - B (Motion #006) JDM Financial Groups Client Agreement for Discretionary Services |
||
| April 02, 2024 |
NOTE OF ISSUE:WITH JURY Note of Issue with Order dated February 7 2024 |
||
| March 28, 2024 | COURT NOTICE | ||
| March 27, 2024 |
LETTER / CORRESPONDENCE TO JUDGE (Motion #006) Letter to the Hon. Timothy S. Driscoll dated March 27, 2024 (Motion Sequences 006 and 007) |
||
| March 11, 2024 |
MEMORANDUM OF LAW IN SUPPORT (Motion #007) Memorandum of Law in Support of Motion for Summary Judgment |
||
| March 11, 2024 |
STATEMENT OF MATERIAL FACTS (Motion #007) Statement of Material Facts |
||
| March 11, 2024 |
EXHIBIT(S) - T (Motion #007) Ex T - Verified Answer with Affirmative Defenses to Second Amended Complaint - Munjack - JDM Financial |
||
| March 11, 2024 |
EXHIBIT(S) - S (Motion #007) Ex S - Verified Answer to Second Amended Complaint |
||
| March 11, 2024 |
EXHIBIT(S) - R (Motion #007) Ex R - Verified Answer with Affirmative Defenses - Munjack - JDM Financial |
||
| March 11, 2024 |
EXHIBIT(S) - Q (Motion #007) Ex Q - Verified Answer - DeFalco - Andronica - McCarthy |
||
| March 11, 2024 |
EXHIBIT(S) - P (Motion #007) Ex P - Amended Summons and Amended Complaint |
||
| March 11, 2024 |
EXHIBIT(S) - O (Motion #007) Ex O - TDA Beneficiary Designation Form for Qualified Accounts |
||
| March 11, 2024 |
EXHIBIT(S) - N (Motion #007) Ex N - TDA IRA Custodial Agreement |
||
| March 11, 2024 |
EXHIBIT(S) - M (Motion #007) Ex M - Medical Records |
||
| March 11, 2024 |
EXHIBIT(S) - L (Motion #007) Ex L - Deposition Transcript of Jeffrey Munjack |
||
| March 11, 2024 |
EXHIBIT(S) - A (Motion #007) Ex A - Summons and Verified Complaint |
||
| March 11, 2024 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion #007) Affirmation of Brian A. Lacoff, Esq. |
||
| March 11, 2024 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #007) Affidavit of Kathleen Flynn |
||
| March 11, 2024 |
EXHIBIT(S) - K (Motion #007) Ex K - Deposition Transcript of Elizabeth DeFalco |
||
| March 11, 2024 |
EXHIBIT(S) - J (Motion #007) Ex J - Deposition Transcript of Joyce McCarthy |
||
| March 11, 2024 |
EXHIBIT(S) - I (Motion #007) Ex I - Deposition Transcript of Michael Cirenza |
||
| March 11, 2024 |
NOTICE OF MOTION (Motion #007) *Corrected* Notice of Motion for Summary Judgment |
||
| March 11, 2024 |
EXHIBIT(S) - H (Motion #007) Ex H - Deposition Transcript of Gerard McCarthy |
||
| March 11, 2024 |
EXHIBIT(S) - G (Motion #007) Ex G - Deposition Transcript of Gregory Andronica |
||
| March 11, 2024 |
EXHIBIT(S) - F (Motion #007) Ex F - Deposition Transcript of Patricia Andronica |
||
| March 11, 2024 |
EXHIBIT(S) - C (Motion #007) Ex C - Second Amended Complaint |
||
| March 11, 2024 |
EXHIBIT(S) - E (Motion #007) Ex E - Deposition Transcript of Kathleen Flynn |
||
| March 11, 2024 |
EXHIBIT(S) - D (Motion #007) Ex D - Verified Answer to Second Amended Complaint |
||
| March 11, 2024 |
EXHIBIT(S) - B (Motion #007) Ex B - Verified Answer |
||
| March 07, 2024 | STIPULATION - SO ORDERED | ||
| February 28, 2024 |
STIPULATION - CONFIDENTIALITY ( REQUEST TO SO ORDER ) Confidentiality Stipulation and Order |
||
| February 27, 2024 | COURT NOTICE | ||
| February 23, 2024 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Hon. Driscoll from Lois Bladykas, Esq. concerning Defendant Flynn's Request to Adjourn Trial |
||
| February 23, 2024 |
EXHIBIT(S) - A Letter dated December 5, 2023 |
||
| February 23, 2024 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Hon. Driscoll from Lois Bladykas, Esq. concerning Discovery |
||
| February 23, 2024 | LETTER / CORRESPONDENCE TO JUDGE | ||
| February 23, 2024 |
EXHIBIT(S) - B Rose v. Arthur J. Gallagher, et al. Decision and Order of Hon. DeStefano |
||
| February 23, 2024 |
EXHIBIT(S) - A Stipulation Regarding Expert Disclosure |
||
| February 20, 2024 |
LETTER / CORRESPONDENCE TO JUDGE (Motion #006) Lttr Concerning Court Notice |
||
| February 20, 2024 | COURT NOTICE | ||
| February 14, 2024 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Honorable Timothy S. Driscoll |
||
| February 07, 2024 | ORDER - CERTIFICATION | ||
| February 02, 2024 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Hon. Timothy S. Driscoll dated February 2, 2024 |
||
| February 02, 2024 | COURT NOTICE | ||
| January 12, 2024 |
EXHIBIT(S) - M (Motion #006) 1.30.17 Email |
||
| January 12, 2024 |
MEMORANDUM OF LAW IN SUPPORT (Motion #006) Memorandum of Law In Support of Summary Judgment |
||
| January 12, 2024 |
EXHIBIT(S) - L (Motion #006) Follow Up Email Chain |
||
| January 12, 2024 |
EXHIBIT(S) - R (Motion #006) Second Amended Complaint |
||
| January 12, 2024 |
EXHIBIT(S) - K (Motion #006) 1.29.17 Email Chain |
||
| January 12, 2024 |
EXHIBIT(S) - J (Motion #006) 1.27.17 Email |
||
| January 12, 2024 |
EXHIBIT(S) - Q (Motion #006) IRa Custodial Agreement |
||
| January 12, 2024 |
EXHIBIT(S) - F (Motion #006) January 30, 2017 Form |
||
| January 12, 2024 |
EXHIBIT(S) - P (Motion #006) 1.31.17 Email Correspondence |
||
| January 12, 2024 |
EXHIBIT(S) - I (Motion #006) Email Correspondence |
||
| January 12, 2024 |
EXHIBIT(S) - O (Motion #006) TD Ameritrade Records |
||
| January 12, 2024 |
EXHIBIT(S) - E (Motion #006) Flynn Depo Transcript |
||
| January 12, 2024 |
EXHIBIT(S) - H (Motion #006) Joint Financial Planning Records For Flynn And Decedent |
||
| January 12, 2024 |
EXHIBIT(S) - N (Motion #006) Verizon Records |
||
| January 12, 2024 |
EXHIBIT(S) - G (Motion #006) Client Agreement For Discretionary Services |
||
| January 12, 2024 |
EXHIBIT(S) - D (Motion #006) Cirenza Depo Transcript |
||
| January 12, 2024 |
EXHIBIT(S) - C (Motion #006) Andronica Depo Transcript |
||
| January 12, 2024 |
EXHIBIT(S) - B (Motion #006) McCarthy Depo Transcript |
||
| January 12, 2024 |
EXHIBIT(S) - A (Motion #006) Decedent's Account Application |
||
| January 12, 2024 |
STATEMENT OF MATERIAL FACTS (Motion #006) Statement of Material Facts |
||
| January 12, 2024 |
AFFIRMATION (Motion #006) Wertman Aff. |
||
| January 12, 2024 |
AFFIRMATION (Motion #006) Munjack Aff |
||
| January 12, 2024 |
NOTICE OF MOTION (Motion #006) *Corrected* JDM Notice of Motion for Summary Judgment |
||
| January 04, 2024 |
LETTER / CORRESPONDENCE TO JUDGE Letter to the Hon. Timothy S. Driscoll dated January 4, 2024 |
||
| January 04, 2024 | COURT NOTICE | ||
| January 04, 2024 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Honorable Timothy S. Driscoll |
||
| January 03, 2024 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service for Consent to Change Attorney |
||
| December 27, 2023 |
CONSENT TO CHANGE ATTORNEY (POST RJI) Consent to Change Attorney |
||
| December 06, 2023 | COURT NOTICE | ||
| December 06, 2023 | AFFIRMATION | ||
| December 06, 2023 |
ORDER TO SHOW CAUSE - CONFORMED COPY Order to Show Case |
||
| December 05, 2023 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Justice Driscoll dated December 5, 2023 |
||
| December 05, 2023 |
LETTER / CORRESPONDENCE TO JUDGE Letter to the Honorable Timothy S. Driscoll dated December 5, 2023 |
||
| December 01, 2023 | COURT NOTICE | ||
| December 01, 2023 |
LETTER / CORRESPONDENCE TO JUDGE Letter to the Hon. Timothy S. Driscoll dated December 1, 2023 |
||
| July 25, 2023 | COURT NOTICE | ||
| July 24, 2023 |
LETTER / CORRESPONDENCE TO JUDGE Letter to the Court dated July 24, 2023 requesting adjournment of conference on consent |
||
| June 06, 2023 |
ANSWER (AMENDED) Answer with verification |
||
| June 06, 2023 | AFFIRMATION/AFFIDAVIT OF SERVICE | ||
| June 06, 2023 | ANSWER (AMENDED) | ||
| June 06, 2023 | COURT NOTICE | ||
| May 31, 2023 |
LETTER / CORRESPONDENCE TO JUDGE JDM Defendants' Lttr Concerning June 16 Appearance |
||
| May 30, 2023 |
EXHIBIT(S) - A Letter dated May 12, 2023 |
||
| May 30, 2023 | ANSWER (AMENDED) | ||
| May 26, 2023 |
ANSWER (AMENDED) JDM and Munjack Answer to SAC |
||
| May 08, 2023 |
COMPLAINT (AMENDED) Second Amended Verified Complaint |
||
| April 19, 2023 | DECISION + ORDER ON MOTION (Motion #005) | ||
| March 28, 2023 | STIPULATION - SO ORDERED | ||
| March 23, 2023 |
STIPULATION - OTHER - ( REQUEST TO SO ORDER ) Stipulation dated March 23, 2023 requested to be So Ordered |
||
| February 02, 2023 | MEMORANDUM OF LAW IN REPLY (Motion #005) | ||
| February 02, 2023 | AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #005) | ||
| February 02, 2023 |
EXHIBIT(S) - B (Motion #005) Power of Attorney |
||
| February 02, 2023 |
EXHIBIT(S) - A (Motion #005) Custodial Agreement |
||
| February 02, 2023 |
EXHIBIT(S) - C (Motion #005) Cirenza v. Flynn |
||
| February 01, 2023 | LETTER / CORRESPONDENCE TO JUDGE | ||
| January 27, 2023 |
MEMORANDUM OF LAW IN OPPOSITION (Motion #005) JDM Defendants' Memorandum In Opposition |
||
| January 27, 2023 | AFFIRMATION (Motion #005) | ||
| January 06, 2023 |
STIPULATION - ADJOURNMENT OF MOTION (Motion #005) Stip Adjourning Ps' Mot. To Reargue |
||
| December 12, 2022 | MEMORANDUM OF LAW IN SUPPORT (Motion #005) | ||
| December 12, 2022 |
EXHIBIT(S) - O (Motion #005) Redline Second Amended Complaint |
||
| December 12, 2022 |
EXHIBIT(S) - M (Motion #005) March 23, 2022 Order |
||
| December 12, 2022 |
EXHIBIT(S) - I (Motion #005) Exhibit C to Farinacci Affirmation (redline of amended complaint) |
||
| December 12, 2022 |
EXHIBIT(S) - L (Motion #005) JDM Reply MOL |
||
| December 12, 2022 |
EXHIBIT(S) - K (Motion #005) Flynn Affirmation in Support of JDM Defendants MTD |
||
| December 12, 2022 |
EXHIBIT(S) - J (Motion #005) Plaintiffs's MOL in Opposition to JDM Defendant's Motion to Dismiss and in Support of Cross Motion |
||
| December 12, 2022 |
EXHIBIT(S) - N (Motion #005) Second Amended Complaint |
||
| December 12, 2022 |
EXHIBIT(S) - F (Motion #005) Farinacci Affirmation in Support of Plaintiffs' Notice of Cross Motion and in Opposition to JDM Motion to Dismiss |
||
| December 12, 2022 |
EXHIBIT(S) - H (Motion #005) Exhibit B to Farinacci Affirmation (proposed amended complaint) |
||
| December 12, 2022 |
EXHIBIT(S) - E (Motion #005) Plaintiffs' Notice of Cross Motion |
||
| December 12, 2022 |
EXHIBIT(S) - D (Motion #005) Exhibit A to Affirmation in Support of JDM Defendants Motion to Dismiss |
||
| December 12, 2022 |
EXHIBIT(S) - C (Motion #005) Affirmation in Support of JDM Defendants Motion to Dismiss |
||
| December 12, 2022 |
EXHIBIT(S) - B (Motion #005) Memo of Law in Support of JDM Defendants Motion to Dismiss |
||
| December 12, 2022 |
EXHIBIT(S) - A (Motion #005) Notice of Motion to Dismiss |
||
| December 12, 2022 | AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion #005) | ||
| December 12, 2022 | NOTICE OF MOTION (Motion #005) | ||
| December 12, 2022 |
EXHIBIT(S) - G (Motion #005) Exhibit A to Farinacci Affirmation (complaint) |
||
| October 12, 2022 | AFFIRMATION/AFFIDAVIT OF SERVICE | ||
| October 12, 2022 | ANSWER | ||
| October 12, 2022 | ORDER - PRELIMINARY CONFERENCE | ||
| October 03, 2022 |
ANSWER JDM Defendants' Answer |
||
| September 28, 2022 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service of Amended Summons with Amended Verified Complaint on Gregory Adronica |
||
| September 28, 2022 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service of Amended Summons with Amended Verified Complaint on Elizabeth Adronica DeFalco |
||
| September 28, 2022 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service of Amended Summons with Amended Verified Complaint on Joyce McCarthy |
||
| September 09, 2022 |
NOTICE OF ENTRY (Motion #004) Notice of Entry with Decision and Order dated September 8, 2022 |
||
| September 09, 2022 |
COMPLAINT (AMENDED) *Corrected* Amended Verified Complaint with Amended Summons |
||
| September 08, 2022 | ORDER - AMENDING CAPTION (Motion #004) | ||
| August 17, 2022 | hearing |
(Motion #004)
Judge: Driscoll, Hon. Timothy S. |
|
| July 28, 2022 | Motion |
Parties - Add/Substitute/Intervene (Motion #004) Before Justice: Driscoll, Hon. Timothy S. Answer demanded: Yes
Judge: Driscoll, Hon. Timothy S. |
|
| July 27, 2022 |
EXHIBIT(S) - A (Motion #004) Letters Testamentary issued June 24, 2022 |
||
| July 27, 2022 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #004) Affirmation of Lois Bladykus in Support of Motion to Substitute dated July 27, 2022 |
||
| July 27, 2022 |
NOTICE OF MOTION (Motion #004) *Corrected* Notice of Motion |
||
| June 06, 2022 | hearing |
Stay virtual
Judge: Driscoll, Hon. Timothy S. |
|
| May 05, 2022 | ATTACHMENT TO COURT NOTICE | ||
| May 05, 2022 | COURT NOTICE | ||
| May 02, 2022 |
LETTER / CORRESPONDENCE TO JUDGE Letter from Lois A. Bladykas, Esq. to Hon. Timothy S. Driscoll regarding the death of plaintiff Anne Regina Cirenza |
||
| March 24, 2022 |
ORDER - AMENDING CAPTION (Motion #001) Seq# 001,002 |
||
| March 03, 2022 | DECISION + ORDER ON MOTION (Motion #003) | ||
| March 02, 2022 | hearing |
Held
Judge: Driscoll, Hon. Timothy S. |
|
| March 02, 2022 | hearing |
Fully Submitted (Motion #002)
Judge: Driscoll, Hon. Timothy S. |
|
| March 02, 2022 | hearing |
Fully Submitted (Motion #001)
Judge: Driscoll, Hon. Timothy S. |
|
| February 16, 2022 | hearing |
Fully Submitted - No Opposition (Motion #003)
Judge: Driscoll, Hon. Timothy S. |
|
| February 09, 2022 |
MEMORANDUM OF LAW IN SUPPORT (Motion #003) Memorandum ISO Pro Hac Vice Application |
||
| February 09, 2022 |
ORDER ( PROPOSED ) (Motion #003) Proposed Order |
||
| February 09, 2022 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion #003) Truitt Affirmation |
||
| February 09, 2022 |
AFFIDAVIT (Motion #003) Wertman Affidavit |
||
| February 09, 2022 | Motion |
Pro Hac Vice (Motion #003) Decided: 02/17/2022Granted Before Justice: Driscoll, Hon. Timothy S. Answer demanded: Yes
Judge: Driscoll, Hon. Timothy S. |
|
| February 07, 2022 |
NOTICE OF MOTION (Motion #003) *Corrected* Notice of Motion Joel Wertman PHV Application on Consent |
||
| January 21, 2022 | hearing |
Adjourned (Motion #002)
Judge: Driscoll, Hon. Timothy S. |
|
| January 21, 2022 | hearing |
Adjourned (Motion #001)
Judge: Driscoll, Hon. Timothy S. |
|
| January 20, 2022 |
MEMORANDUM OF LAW IN REPLY (Motion #001) JDM Defendants' Reply ISO MTD |
||
| January 10, 2022 | Motion |
Amend Caption/Pleadings (Motion #002) Decided: 03/23/2022Granted Before Justice: Driscoll, Hon. Timothy S. Answer demanded: No
Judge: Driscoll, Hon. Timothy S. |
|
| January 06, 2022 |
EXHIBIT(S) - A (Motion #001) Verified Complaint |
||
| January 06, 2022 |
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION (Motion #001) Affirmation of John G. Farinacci in Opposition to Motion to Dismiss and in Support of Cross-Motion for Leave to Amend Complaint and to Dismiss Affirmative Defense |
||
| January 06, 2022 |
NOTICE OF CROSS-MOTION (Motion #002) *Corrected* Notice of Cross-Motion for Leave to Amend Complaint and to Dismiss Affirmative Defense |
||
| January 06, 2022 | AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #001) | ||
| January 06, 2022 |
MEMORANDUM IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION (Motion #001) Plaintiffs' Memorandum of Law in Opposition to Motion to Dismiss and in Support of Cross-Motion for Leave to Amend Complaint and to Dismiss Affirmative Defense |
||
| January 06, 2022 |
EXHIBIT(S) - C (Motion #001) Redline Showing the Changes in the Amended Verified Complaint |
||
| January 06, 2022 |
EXHIBIT(S) - B (Motion #001) Proposed Amended Verified Complaint |
||
| December 09, 2021 | hearing |
Adjourned (Motion #001)
Judge: Driscoll, Hon. Timothy S. |
|
| November 22, 2021 |
STIPULATION - OTHER Stipulation to Adjourn Motion to Dismiss |
||
| October 20, 2021 |
MEMORANDUM OF LAW IN SUPPORT (Motion #001) Memorandum of Law |
||
| October 20, 2021 |
NOTICE OF MOTION (Motion #001) Notice of Motion |
||
| October 20, 2021 | ADDENDUM - COMMERCIAL DIVISION (840C) (Motion #001) | ||
| October 20, 2021 | RJI -RE: NOTICE OF MOTION (Motion #001) | ||
| October 20, 2021 |
EXHIBIT(S) - A (Motion #001) Complaint |
||
| October 20, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #001) Truitt Affirmation |
||
| October 20, 2021 | Motion |
Dismiss (Motion #001) Decided: 03/23/2022Decided Before Justice: Driscoll, Hon. Timothy S. Answer demanded: Yes
Judge: Driscoll, Hon. Timothy S. |
|
| September 27, 2021 | ANSWER | ||
| August 31, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service of Summons and Complaint upon Jeffrey D. Munjack |
||
| August 31, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service of Summons and Verified Complaint upon JDM Financial Group |
||
| August 16, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service for Kathleen Flynn for additional mailing |
||
| August 16, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service for Kathleen Flynn |
||
| August 02, 2021 |
NOTICE OF APPEARANCE (PRE RJI) Notice of Appearance for Lois Bladykas, Esq. |
||
| July 29, 2021 |
SUMMONS + COMPLAINT Summons and Verified Complaint |
