Claudia P. Riley v. Syracuse University
Claudia P. Riley v. Syracuse University
EK12020000407
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/10/2020
CLAUDIA P. RILEY
184 Temple Street
Fredonia, NY 14063,
Plaintiff, SUMMONS
v. Index No.:
SYRACUSE UNIVERSITY
900 South Crouse Avenue
Syracuse, NY 13244,
Defendant.
YOU ARE HEREBY SUMMONED to Answer the Complaint in this action and to serve
a copy of your Answer on the Plaintiffs Attorneys within 20 days after the service of this
Summons, exclusive of the day of service (or within 30 days after the service if this Summons is
not personally delivered to you within the State) and in case of your failure to Answer, Judgment
will be entered against you by default for the relief demanded in the Complaint. Plaintiffs
complaint against you is in excess of the jurisdictional limits of al er Courts for causes of
action based upon negligence. Chautauqua County is designat(d t e lace of trial based upon
Williamsville, NY 14221-5986
(716) 633-3535
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FILED: CHAUTAUQUA COUNTY CLERK 03/10/2020 09:34 AM INDEX NO. EK12020000407
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/10/2020
CLAUDIA P. RILEY,
Plaintiff, COMPLAINT
v. Index No.:
SYRACUSE UNIVERSITY,
Defendants.
and for her complaint against the Defendant, SYRACUSE UNIVERSITY, herein, alleges:
a private research university existing under and by virtue of the laws of the State of New York,
with its principal place of business located in Syracuse, New York in the County of Onondsga,
and with agents for service of process located in the City of Syracuse and State of New York, also
owned the aforementioned premises known as Schine Student Center located at 303 University
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FILED: CHAUTAUQUA COUNTY CLERK 03/10/2020 09:34 AM INDEX NO. EK12020000407
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maintained the aforementioned premises known as Schine Student Center located at 303
inspected the aforementioned premises known as Schine Student Center located at 303 University
controlled the aforementioned premises known as Schine Student Center located at 303 University
employees and/or personnel for the purposes of repairing and maintaining said premises known as
Schine Student Center located at 303 University Place, City of Syracuse, and State of New York.
operated said premises known as Schine Student Center located at 303 University Place, City of
9) That on or about July 21, 2017, Plaintiff CLAUDIA P. RILEY, while lawfully upon
the aforementioned premises was caused to trip and fall on the sidewalk thereby causing her to
sustain severe and permanent personal injuries as a result of the carelessness and negligence of
10) Upon information and belief and at all times hereinafter mentioned, the Defendant,
SYRACUSE UNIVERSITY through their agents, servants, representatives and/or employees had
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FILED: CHAUTAUQUA COUNTY CLERK 03/10/2020 09:34 AM INDEX NO. EK12020000407
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actual notice and knowledge of the dangerous and defective conditions on the premises hereinafter
mentioned, or created said dangerous conditions, or said conditions had existed for such a long
period of time prior to the happening of this accident that Defendant could and should have had
11) That the aforementioned incident was caused or contributed to solely and wholly
due to the negligence and carelessness on the part of Defendant, SYRACUSE UNIVERSITY,
12) Upon information and belief this action falls within one or more of the exceptions
enumernated in Article 16 of the CPLR and/or said article is inapplicable to the within action.
13) That as a result of the foregoing, Plaintiff, CLAUDIA P. RILEY, was rendered sick,
sore, lame and disabled; suffered injuries both intemal and external; suffered from and contiñües
to experience pain and suffering; was compelled to seek medical attention and care; all to her
damage in a sum in excess of the jurisdictional limits of the lower courts of the State of New York.
limits of all lower Courts which would otherwise have jurisdiction, together with the costs and
disbursements of said action and any such other and further relief as the Court may deem just
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and proper.
Edward A. GibsohEsq.
Williamsville, NY 14221-5986
(716) 633-3535
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