STATE OF NEW YORK
SUPREME COURT COUNTY OF RENSSELAER
Index No.:
YVONNE KETTER-WALLS and Date Purchased:
THOMAS WALLS,
Plaintiffs designate Rensselaer
- County as the place of trial.
Plaintiffs,
The basis of the venue is
~ against - where the defendant conducts
business.
HUDSON-MOHAWK RECOVERY CENTER, INC.
1724 Fifth Avenue
‘Troy, New York 12180
THOMAS BENDON
1724 Fifth Avenue
Troy, New York 12180
SUMMONS
AUBREE GRAVES
1724 Fifth Avenue
Troy, New York 12180
JOHN and SANE DOES 1-4
1724 Fifth Avenue
Troy, New York 12180
Defendants.
County of Rensselaer
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 attomeys within twenty (20) days after the service of this
summons, exclusive of the day of service (or within thirty (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
DeLorenzo, Grasso & Dalmata, LLP
670 Pranklin Street, Suite 100
Schenectady, New York 12305your failure to appear o answer, judgment will be taken against you by default for the relief
demanded in the complaint.
Dated: January 7, 2019
DeLORE) S80 & DALMATA, LLP
CORY ROSS DALMATA, ESQ.
Attorneys for Plaintiffs
670 Franklin Street, Suite 100
Schenectady, New York 12305
(S18) 374-8494
#*PLEASE FORWARD TO YOUR INSURANCE COMPANY**
DeLorenzo, Grasso & Dalmata, LLP
(670 Franklin Street, Suite 100
Schenectady, New York 12305STATE OF NEW YORK
SUPREME COURT COUNTY OF RENSSELAER
YVONNE KETTER-WALLS and THOMAS WALLS,
Plaintiff,
COMPLAINT
-against- i et
HUDSON-MOHAWK RECOVERY CENTER, INC., Index No.:
THOMAS BENDON, AUBREE GRAVES end
JOHN and JANE DOES 1-4,
Defendants.
Plaintiffs, Yvonne Ketter-Walls and Thomas Walls, by and through their attomeys,
DeLorenzo, Grasso & Dalmata, LLP, state the following as and for their Complaint:
1 ‘That at all times hereinafter mentioned, the plaintiffs, Yvonne Ketter-Walls and
Thomas Walls, were and still are residents of the County of Somerset, State of New Jersey.
2. Plaintiffs, Yvonne Ketter-Walls and Thomas Walls, were and are the next of kin
of Raolik Walls, deceased.
3. That upon information and belief, and at all times hereinafter mentioned, the
defendant, Hudson-Mohawk Recovery Center, Inc., was and continues to be a domestic not-for-
profit corporation and existing under and by virtue of the laws of the State of New York, ha
ig
its office and principal place of business located at 1724 Fifth Avenue, Troy, New York 12180.
4, That upon information and belief, and at all times hereinafter mentioned, Thomas
Bendon, was and individual and the Executive Director at Defendant, Hudson-Mohawk
Recovery Center, Inc,
5. That upon information and belief, and at all times hereinafter mentioned, Aubree
Graves, was and continues to be an individual and the Residential Director at Defendant,
Hudson-Mohawk Recovery Center, Inc.
DeLorenzo, Grasso & Dalmata, LLP
670 Franklin Street, Suite 100
Schenectady, New York 12305