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51528/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/25/2019
Index No.
Plaintiff,
Date Filed:
-against-
Defendants.
X
To the above named Defendant:
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 attorney(s) within 20 days after the service
of this summons, exclusive of the day of service, where service is made by delivery upon
you personally within the state, or within 30 days after completion of service where service
is made in any other manner. In case of your failure to appear or answer, judgment will be
taken against you by default for the relief demanded in the Complaint.
Upon your failure to appear, judgment will be taken against you by default for the
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FILED: WESTCHESTER COUNTY CLERK 01/25/2019 12:17 PM INDEX NO. 51528/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/25/2019
GRACE & G CE
(914) 962-6100
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/25/2019
COMPLAINT
Index No.
Plaintiff,
Date Filed:
-against-
Defendants.
=======================================x
following:
THE PARTIES
an attorney licensed to practice law in the Courts of the State of New York with
duly elected Supervisor of the Town of Yorktown, Westchester County, New York
Examiner"
publishes a newspaper called the "Northern Westchester .a free weekly
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/25/2019
Editor"
frequent contributor to the "Letters to ‡he section of the Defendant The
Examiner News..
Melvyn R. Tanzman for the Defendant The Examiner News entitled "Current
Grace"
Yorktown Administration Governs with More published on January 8,
him for what he was: self serving, arrogant, and ünwilling to compromise or
even listen to those who do not agree with him.... I believe he made self
enrichment deals behind the scenes that did not benefit the Town including
properties..."
the transformation of his and former Senator Murphy's
reference herein.
in unethical and/or criminal behavior and of having used his political office for
self enrichment.
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11. The statements published by the Defendants on January 9, 2019 and set
forth herein and incorporated by refe ence herein regarbing the Plaintiff is false.
12. Defendants acted with kno ledge of the falsity of these statements and
the implications therefrom, and knov ingly published said false statements to the
public.
13. Defendants acted with rect less disregard for the truth in knowingly
14. Defendants acted with mallcious intent, both presumed and actual, in
character, integrity, reputation, charg¢ him with a serious crime and disparage the
Plaintiff in his profession, trade and/or business and are libelous per se.
16. Even if the damages are not presumed, Plaintiff has suffered special
damages in lost revenue and lost clie ts as well as othe economic damages to
Plaintiff's livelihood.
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17. That as a result of the foregoing, Plaintiffs heve been damaged in a sum
which exceeds the jurisdictional limits of all lower Courts which would otherwise
have jurisdiction.
published by the Defendants is libel per se and Plaintiff as a result thereof was
subject to malicious and false accusations of being corrupt and aspersions on his
sum that exceeds the jurisdictional limits of all lower Courts tliat would otherwise
have jurisdiction together with such 9ther and further telief as|the Court deems
Yorktown Heights, NY
; Yours, etc.,
GRACE evGI E
WilliadefacprEfsq.
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FILED: WESTCHESTER COUNTY CLERK 01/25/2019 12:17 PM INDEX NO. 51528/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/25/2019
(914) 962-6100
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FILED: WESTCHESTER COUNTY CLERK 01/25/2019 12:17 PM INDEX NO. 51528/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/25/2019
(914) 962-6100
TO:
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/25/2019
INDIVIDUAL VERIFICATION
COUNTY OF WESTCHESTER
I am the Plaintiff in the action herein. I have read the annexed Verified Complaint
know the contents thereof, and the|same are true to my knowledge, except those matters
Notary
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