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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
-----------------------------------------------------------------------X
KORINA L.GARCIA,
Plaintiff,
VERIFIED COMPLAINT
-against- INDEX NO. 3430/01
MARK DILLEMUTH,
Defendant.
-----------------------------------------------------------------------X
Plaintiff, KORINA GARCIA, by her attorneys, THE LAW OFFICES OF GUS E.
VELEZ & ASSOCIATES complaining of the defendant sets forth as follows:
AS AND FOR A FIRST CAUSE OF ACTION
1. At all times hereinafter mentioned, the plaintiff KORINA GARCIA was and still is
a resident of Nassau County, State of New York.
2. At all times hereinafter mentioned, the plaintiff KORINA GARCIA was and still is the
owner of a 2014 BMW, color grey, model M5 automobile bearing New York State license plate
number 248-PROF.
3. At all times hereinafter mentioned, the plaintiff KORINA GARCIA was the operator or
a 2001 Mercedes-Benz model SL 500 automobile bearing New York State license plate number
240-PROF.
4. At all times hereinafter mentioned, the defendant MARK DILLEMUTH was and still is a
resident of Nassau County, State of New York.
5. At all times hereinafter mentioned, the defendant MARK DILLEMUTH was and still is
the owner of a 1998 Audi A6, color black automobile bearing New York State license plate
number COOLCAL.
6. At all times hereinafter mentioned, the defendant MARK DILLEMUTH was the operator
of a 1998 Audi A6, color black automobile bearing New York State license plate number COOL
CAL.
7. That on the aforesaid date, the motor vehicle owned by defendant MARK DILLEMUTH
bearing New York State license plate number COOLCAB , which was being operated
by defendant MARK DILLEMUTH came into contact with the motor vehicle owned and
operated by plaintiff KORINA GARCIA.
8. At the aforesaid time and place the aforesaid motor vehicle were in a violent collision
that resulted in serious injuries to the plaintiff, KORINA GARCIA.
9. The aforesaid contact and collision and resulting serious injuries to the plaintiff KORINA
GARCIA, as hereinafter alleged, where caused by the carelessness, recklessness and negligence
of the defendant MARK DILLEMUTH.
10. That there was no negligence on the part of the plaintiff KORINA GARCIA contributing
thereto.
11. That the defendant MARK DILLEMUTH, was careless, reckless and negligent in the
ownership, operation, maintenance, management and control of the aforesaid motor vehicle in
that the defendant MARK DILLEMUTH was operated said vehicle while her blood alcohol
content level was above the legal limit.
12. By reason of the negligence of the defendant MARK DILLEMUTH, as herein above
mentioned, the plaintiff, KORINA GARCIA, sustained great bodily injuries with accompanying
pain, he has become and continues to be sick, sore, lame and disabled; his injuries are of a
permanent nature.
13. By reason of the negligence of the defendant MARK DILLEMUTH, as herein above
mentioned, the plaintiff KORINA GARCIA was obliged to incur expenses and obligation to
obtain medical care and attention and will be so compelled in the future; he has sustained a
period of disability and will, in the future, incur further expenses, obligations and disability of a
similar character; and he has been otherwise injured.
14. By reason of the negligence of the defendant MARK DILLEMUTH as aforesaid, the
plaintiff KORINA GARCIA has sustained a serious injury as defined in Subsection D of Section
5102 of the New York State Insurance law and/or economic loss grater than basic economic loss
as defined in Subsection A of Section 5102 of the New York State Insurance Law.
15. By reason of the foregoing, plaintiff KORINA GARCIA has been damaged in the sum
of twenty-five million ($55,000.000.00) dollars.
WHEREFORE, the plaintiff KORINA GARCIA demands judgment against the
defendant MARK DILLEMUTH in the sum of twenty-five million dollars, all together with the
costs, disbursements, interest and attorney’s fees of this action.
Dated: New York, New York
April 14, 2014
Yours, etc.,
The Law Office of Gus E. Velez
and Associates
Attorney for Plaintiff
KORINA GARCIA
3265 Johnson Avenue
Riverdale, New York 10463
(718) 543-1100
VERIFICATION
STATE OF NEW YORK )
) ss.
COUNTY OF NASSAU )
KORINA GARCIA being duly sworn, deposes and says, that he is the plaintiff in the
within action, that he has read the foregoing complaint and knows the contents thereof; that the same is
true of his own knowledge, except as to those matters therein stated to be alleged upon information and
belief, and as to those matters he believes them to be true.
___________________________
KORINA GARCIA
Sworn to before me this
14th
day of April, 2014
___________________________
Notary Public

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4-14 VERIFIED COMPLAINT

  • 1. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU -----------------------------------------------------------------------X KORINA L.GARCIA, Plaintiff, VERIFIED COMPLAINT -against- INDEX NO. 3430/01 MARK DILLEMUTH, Defendant. -----------------------------------------------------------------------X Plaintiff, KORINA GARCIA, by her attorneys, THE LAW OFFICES OF GUS E. VELEZ & ASSOCIATES complaining of the defendant sets forth as follows: AS AND FOR A FIRST CAUSE OF ACTION 1. At all times hereinafter mentioned, the plaintiff KORINA GARCIA was and still is a resident of Nassau County, State of New York. 2. At all times hereinafter mentioned, the plaintiff KORINA GARCIA was and still is the owner of a 2014 BMW, color grey, model M5 automobile bearing New York State license plate number 248-PROF. 3. At all times hereinafter mentioned, the plaintiff KORINA GARCIA was the operator or a 2001 Mercedes-Benz model SL 500 automobile bearing New York State license plate number 240-PROF. 4. At all times hereinafter mentioned, the defendant MARK DILLEMUTH was and still is a resident of Nassau County, State of New York.
  • 2. 5. At all times hereinafter mentioned, the defendant MARK DILLEMUTH was and still is the owner of a 1998 Audi A6, color black automobile bearing New York State license plate number COOLCAL. 6. At all times hereinafter mentioned, the defendant MARK DILLEMUTH was the operator of a 1998 Audi A6, color black automobile bearing New York State license plate number COOL CAL. 7. That on the aforesaid date, the motor vehicle owned by defendant MARK DILLEMUTH bearing New York State license plate number COOLCAB , which was being operated by defendant MARK DILLEMUTH came into contact with the motor vehicle owned and operated by plaintiff KORINA GARCIA. 8. At the aforesaid time and place the aforesaid motor vehicle were in a violent collision that resulted in serious injuries to the plaintiff, KORINA GARCIA. 9. The aforesaid contact and collision and resulting serious injuries to the plaintiff KORINA GARCIA, as hereinafter alleged, where caused by the carelessness, recklessness and negligence of the defendant MARK DILLEMUTH. 10. That there was no negligence on the part of the plaintiff KORINA GARCIA contributing thereto. 11. That the defendant MARK DILLEMUTH, was careless, reckless and negligent in the ownership, operation, maintenance, management and control of the aforesaid motor vehicle in that the defendant MARK DILLEMUTH was operated said vehicle while her blood alcohol content level was above the legal limit. 12. By reason of the negligence of the defendant MARK DILLEMUTH, as herein above mentioned, the plaintiff, KORINA GARCIA, sustained great bodily injuries with accompanying
  • 3. pain, he has become and continues to be sick, sore, lame and disabled; his injuries are of a permanent nature. 13. By reason of the negligence of the defendant MARK DILLEMUTH, as herein above mentioned, the plaintiff KORINA GARCIA was obliged to incur expenses and obligation to obtain medical care and attention and will be so compelled in the future; he has sustained a period of disability and will, in the future, incur further expenses, obligations and disability of a similar character; and he has been otherwise injured. 14. By reason of the negligence of the defendant MARK DILLEMUTH as aforesaid, the plaintiff KORINA GARCIA has sustained a serious injury as defined in Subsection D of Section 5102 of the New York State Insurance law and/or economic loss grater than basic economic loss as defined in Subsection A of Section 5102 of the New York State Insurance Law. 15. By reason of the foregoing, plaintiff KORINA GARCIA has been damaged in the sum of twenty-five million ($55,000.000.00) dollars. WHEREFORE, the plaintiff KORINA GARCIA demands judgment against the defendant MARK DILLEMUTH in the sum of twenty-five million dollars, all together with the costs, disbursements, interest and attorney’s fees of this action. Dated: New York, New York April 14, 2014 Yours, etc., The Law Office of Gus E. Velez and Associates Attorney for Plaintiff KORINA GARCIA 3265 Johnson Avenue Riverdale, New York 10463 (718) 543-1100
  • 4. VERIFICATION STATE OF NEW YORK ) ) ss. COUNTY OF NASSAU ) KORINA GARCIA being duly sworn, deposes and says, that he is the plaintiff in the within action, that he has read the foregoing complaint and knows the contents thereof; that the same is true of his own knowledge, except as to those matters therein stated to be alleged upon information and belief, and as to those matters he believes them to be true. ___________________________ KORINA GARCIA Sworn to before me this 14th day of April, 2014 ___________________________ Notary Public