2020 06:01 PM - Courthouse News Service · mayerly mejias . 71-15 beach channel drive -apt 10g . far rockaway, ny 11692 . megan mattis . 832 e 52nd st - apt 4 . brooklyn, ny 11203

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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX

THE GENERAL INSURANCE, PERMANENT GENERAL ASSURANCE CORPORATION, PERMANENT GENERAL ASSURANCE CORPORATION OF OHIO, THE GENERAL AUTOMOBILE INSURANCE COMPANY, INC.,

Plaintiffs,

- against - AYANNA PIQUION, BARBARA ALTIME, CAMILLE DEROSE, CHEYENNE VAZQUEZ, CLYFFORD MAURICE, DAVID BROWN, ERIQUE BERTRAND, FARAH FELIX, FLIGHTDENICA PERARD, GREGORY REMEDOR, JOHN FRANCOIS, JUNIOR BEAUZILE, KINET DATILIEN, LORENZO DERBERRY, LOVENS FONTILUS, MARIE SYLVERT, MIKE PIERRE-PAUL, NASIA GASPARD, QUENCY NOEL, RAHEEM GILLESPIE, RASHEKA BRYAN, RUYSS ST FLEURANT, SACHA DESRAVINES, SADE LONG, SANDY CABA-DURAN, SEAN CARY FRANCIS, STEEVE GUILLAUME, TYREIK WILLIAMSON, (collectively the “Policy Defendants”)

-and-

ANASIA DESTINY SMITH, BETINA LAFORTUNE, BILLY SMITH, CHEYENNE VAZQUEZ, CLAUDY BELLANGER, DANA WHITE, DARRYN RIDDICK, DEJANE VERA, DONALD DEBROSSE, DUANE BOUCHER, EL DORVILE, ELIRUS WALTHUST, EMIYA TOLEDO, EVENSON SOUVERAIN, FARAH FELIX, FRANCESCA SYLVERT, FRANCKLIN ETIENNE, GUY JEAN-MICHEL, JAMES ANDERSON, JAMES CLARKE, JAMES COLEMAN, JAMES ELIASSAINT, JAMES JOSEPH, JAYDEN JULIEN, JEAN DREGEN, JEAN-SAMSON ZAMOR, JOSEPH BARKLEY, JOSEPH ROBERT, JOSEPH WILLIAMS, JUNIOR GREEN, KERVENS LEANDRE, KERVIN RAMEAU, LAURA CELESTIN, LAWAN REESE, LEMAITRE VIDEAU, LEONARDO BEAUVAIS, LEONIE TRENCH, MARCELINE JULES, MARCO OREILLUS, MARIE ALTIME, MARIE JEAN, MARK CHERY, MAYERLY MEJIAS, MEGAN MATTIS, MIESHAWN MOORE,

Index No.: ________/2020E

Date Filed: 02/14/2020

SUMMONS

Plaintiff(s) designates BRONX COUNTY as the

place of trial. Basis of venue: Defendant resides in

Bronx County

FILED: BRONX COUNTY CLERK 02/14/2020 06:01 PM INDEX NO. 22825/2020E

NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2020

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MIKERSON ELIASSAINT, MILTON MARSHALL, MOSES FALL, NADEGE CANDIO, O’NIEL PERRISSAINT, ORELIEN HUGGINS, PETER JACKSON, PIERRIE METIVIER, PRESUME VILLER, RANDY HONORA, RAYMOND COLETTI, REGINALD IRIZARRY, REGGIE ROB, RODNEY-PIERRE PAUL, ROODY VIDO, RUSLEE SMARTT, SERGE CASTOR, SHAKEIM PETERS, SHALA UDDIN, SHARON CARTER-ROSS, SHAWN WILLIAMS, RICKY DORVIL, SHAYLIA WALTON, SHAZI MARAV, STEVE JOHNSON, TAIHEEN SHULER, TAREK BECKLES, (collectively the “Staged Loss Defendants”)

-and-

5 BOROUGH ANESTHESIA, PLLC, ACCESS CARE PT, P.C., ACTION CHIROPRACTIC, P.C., ACUCARE4U ACUPUNCTURE PLLC,AHMED ABDELAAL PT, DPT, ALL CITY FAMILY HEALTHCARE, ALTAI CORP. DBA GET READY MEDICAL SUPPLY, ANDREW J DOWD MD, ARD RX INC, ARISTA PHYSICAL THERAPY PC, ARON ROVNER MD, PLLC, ATLAS PHARMACY LLC, ATLAS RADIOLOGY, P.C., AVERROES PHYSICAL THERAPY PC, AXIAL CHIROPRACTIC, PC, BIG APPLE MED EQUIPMENT INC, BILLY H. FORD, MD PC, BROOKLYN MCDONALD MEDICAL CARE, PLLC, BURKE PHYSICAL THERAPY PC, CAVALLARO MEDICAL SUPPLY, CHI LEE ACUPUNCTURE PC, CHIROPRACTIC PAIN SOLUTIONS, P.C., CITY WIDE HEALTH FACILITY, INC, CLASS POINT ACUPUNCTURE, PLLC, CMA PSYCHOLOGY, P.C, COMPREHENSIVE PSYCHOLOGICAL PC, CONTEMPORARY DIAGNOSTIC IMAGING, CONTEMPORARY OTHOPEDICS, CORRECTALIGN CHIROPRACTIC PC, CUSTOM RX PHARMACY, DANIMARK PHYSICAL THERAPY PC, DELPHI CHIROPRACTIC PC, DIANA BEYNIN, DC, DNA PHARMACY INC, DOS MANOS CHIROPRACTIC PC, DR. OFFENBACHER MEDICAL IMAGING, PLLC, DR. S. MATRANGOLO, DC, DR. WATSON CHIROPRACTIC, PC, EAST 19 MEDICAL SUPPLY CORP., ENGLEWOOD ORTHOPEDICS GROUP PC, EZ ORTHO SUPPLY INC., FAIRPOINT ACUPUNCTURE PC, FLORID LEISURE ACUPUNCTURE P.C., FRANK ZHAN BEST PHYSICAL THERAPY, P.C., GC ACUPUNCTURE PC, GESHER



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PSYCHOLOGICAL SERVICES, P.C., GOOD LIFE ACUPUNCTURE, P.C., GOOD SPACE ACUPUNCTURE P.C, HAZAQ PSYCHOLOGICAL SERVICES, P.C., HEALTH AND COMFORT RX, INC, HEALTH EAST MED ALLIANCE, HMP ORTHOPAEDICS, HUDSON REGIONAL HOSPITAL, IGOR MAYZENBERG, LAC, JOHN LYONS MD, JOINT PHYSICAL THERAPY P C, JOSEPH A RAIA MD PC, JSJ ANESTHESIA PAIN MANAGEMENT PLLC, JULES F PARISIEN, KH LEE ACUPUNCTURE P C, KINGS COUNTY HOSPITAL, LINWOOD WEST MEDICAL, P.C., LONGEVITY MEDICAL SUPPLY, INC., LPM PHARMACY INC LR MEDICAL PLLC, M&D ELITE PHARMACY LLC, MACCABI PHARMACY RX INC, MALVINA DRUG CORP, LPM PHARMACY INC, MATTHEW HARLAN HOOVIS, MC PHYSICAL THERAPY, PC, MEDICAL PLAZA, METRO PAIN SPECIALISTS, PC, METROPOLITAN MEDICAL AND SURGICAL, P.C., MICHELE B. GLISPY, LAC., MIDWOOD METROPOLITAN MEDICAL, P.C., MILL NECK CHIROPRACTIC, MIN PHYSICAL THERAPY P.C., MOLNAR MEDICAL SERVICES PC, MOTION MEDICAL DIAGNOSTICS, PC, MULTISPECIALTY HEALTH GROUP, NEW CAPITAL 1 INC., NEW MILLENNIUM MEDICAL IMAGING, P.C., NEW YORK CORE CHIROPRACTIC PC, NEW YORK INJURY CHIROPRACTIC REHAB PC, NEW YORK THERA PT PC, NEXRAY MEDICAL IMAGING PC, NOVA MEDICAL DIAGNOSTIC, P.C., NY BEST SUPPLY, INC, NYC CARE CHIROPRACTIC P C., NYC CARE PT, PC, NYWWQASC, LLC, OP ACUPUNCTURE, P.C., PERFORMANCE CHIRO, P.C., PONCE ACUPUNCTURE, P.C., PROTECHMED INC., QIXIA ACUPUNCTURE PC, RAF SPORTS CHIROPRACTIC PC, RAINE M PESIDAS PHYSICAL THERAPY PC, RANDALL ACUPUNCTURE P.C., REHAB TIME PT PC REHABILITATION MEDICAL CENTER, RENAN MACIAS MD, ROMEO MARIMAT PHYSICAL THERAPY, ROXBURY ANESTHESIA, LLC RUN HONG LI, SABAS NY SERVICES INC, SAFE ANESTHESIA AND PAIN, LLC, SCOB, LLC, SEAN L. THOMPSON, SEDATION VACATION, PERIOP MED PLLC, SHAMAYIM CHIROPRACTIC, P.C., SHASHEK CHIROPRACTIC PC, SKY RADIOLOGY, SOLID ROK PHYSICAL THERAPY, P.C, SONIA ARMENGOL, MD, SORREL ACUPUNCTURE P.C., ST. KYROLLOS PHYSICAL THERAPY, P.C., STRAND PHARMACY D/B/A



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ASTORIA DRUGS, INC., STRUCTURAL SYNERGYPHYSICAL THERAPY, PC, SURGERY CENTER OF

ORADELL, SURGICORE OF JERSEY CITY, LLC, TAI QI

WELLNESS ACUPUNCTURE PC, TANUJ PALVIA, TIMETO CARE MEDICAL, P.C., TIME TO CARE PHARMACYINC, TOPLAB UNICAST INC, UNION DME,UNIVERSITY HOSPITAL OF BROOKLYN, WELLNESSDIAGNOSTIC IMAGING, PC, YELLOWSTONE MEDICALREHAB P.C.,

(collectively the "Provider Defendants")Defendants.

YOU ARE HEREBY SUMMONED to answer the verified complaint in this action and

to serve a copy of your verified answer, or, if the verified complaint is not served with this

summons, to serve a notice of appearance, on the plaintiff(s)'s attorneys within twenty (20) days

after the service of this summons, exclusive of the day of service, or within thirty (30) days after

the services is complete if this summons is not personally delivered to you within the State of New

York.

PLEASE TAKE FURTHER NOTICE in case ofdefendants'

failure to appear to answer,

judgment will be taken against you both jointly and severally by default for the relief demanded

in the verified complaint.

DATED: February 14, 2020 .

Nicole R. McErlean

FREIBERG, PECK & KANG, LLP

Attorneys for Plaintiff(s)200 Business Park Drive, Suite 202

Armonk, New York 10504

P: (212) 252-9550

F: (212) 252-9552

File No.: 4700.0409

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TO: AYANNA PIQUION 8 LAWRENCE AVE - APT 1 POTSDAM, NY 13676 BARBARA ALTIME 13 DANA AVE ALBANY, NY 12208 CAMILLE DEROSE 6 ELM ST - STE 1 POTSDAM, NY 13676 CHEYENNE VAZQUEZ 495 WYONA ST - APT 3C BROOKLYN, NY 11207 CLYFFORD MAURICE 6 ELM ST - STE 1 POTSDAM, NY 13676 DAVID BROWN 328 MACKEY PL ELMIRA, NY 14904 ERIQUE BERTRAND 162 LARK ST - APT 1 ALBANY, NY 12210 FARAH FELIX 45 MAIN ST POTSDAM, NY 13676 FLIGHTDENICA PERARD 27 BEECH RD POTSDAM, NY 13676 GREGORY REMEDOR 27 BEECH RD POTSDAM, NY 13676 JOHN FRANCOIS 1067 MADISON AVE - APT 1 ALBANY, NY 12208 JUNIOR BEAUZILE 417 BROADWAY ST - APT 1 ELMIRA, NY 14904 KINET DATILIEN 933 US ROUTE 11 - APT S6 KIRKWOOD, NY 23795

LORENZO DERBERRY 48 DOVE ST ALBANY, NY 12210 LOVENS FONTILUS 417 BROADWAY ST - APT 1 ELMIRA, NY 14904 MARIE SYLVERT 133 JAY ST ALBANY, NY 12210 MIKE PIERRE-PAUL 678 PERINE ST ELMIRA, NY 14904 NASIA GASPARD 68 MILLER RD POTSDAM, NY 13676 QUENCY NOEL 343 STATE ST ALBANY, NY 12210 RAHEEM GILLESPIE 153 HANEY ST WATERTOWN, NY 13601 RASHEKA BRYAN 761 MADISON AVE ALBANY, NY 12208 RUYSS ST FLEURANT 291 LARK ST ALBANY, NY 12210 SACHA DESRAVINES 1200 CHARLES ST ELMIRA, NY 14904 SADE LONG 343 STATE ST ALBANY, NY 12210 SANDY CABA-DURAN 41 GREENWAY TER MIDDLETOWN, NY 10941 SEAN CARY FRANCIS 307 FULTON ST ELMIRA, NY 14904



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STEEVE GUILLAUME 1518 CEDAR ST ELMIRA, NY 14904 TYREIK WILLIAMSON 27 LAWRENCE AVE POTSDAM, NY 13676 ANASIA DESTINY SMITH 330 E 19TH ST - APT 5H BROOKLYN, NY 11226 BETINA LAFORTUNE 2014 DITMAS AVE - #D4 BROOKLYN, NY 11226 BILLY SMITH 140-32 172ND ST JAMAICA, NY 11434 CHEYENNE VAZQUEZ 495 WYONA ST - APT 3C BROOKLYN, NY 11207 CLAUDY BELLANGER 150 E 28TH ST - 1ST FLOOR BROOKLYN, NY 11226 DANA WHITE 328 MACKEY PL ELMIRA, NY 14904 DARRYN RIDDICK 220 MONTGOMERY ST BROOKLYN, NY 11225 DEJANE VERA 186 CLAREMONT AVE NEW YORK, NY 10027 DONALD DEBROSSE 920 E 45TH ST BROOKLYN, NY 11203 DUANE BOUCHER 107-18 171 ST - APT B4 JAMAICA, NY 11433 EL DORVILE 326 LINCOLN PL BROOKLYN, NY 11238 ELIRUS WALTHUST 1383 FLATBUSH AVE BROOKLYN, NY 11210

EMIYA TOLEDO 1015 WASHINGTON AVE - APT #6 BROOKLYN, NY 11225 EVENSON SOUVERAIN 933 NEW YORK AVE BROOKLYN, NY 11203 FARAH FELIX 270 CROWN ST - APT 3B BROOKLYN, NY 11225 FRANCESCA SYLVERT 2416 NEWKIRK AVE - APT 1F BROOKLYN, NY 11226 FRANCKLIN ETIENNE 162 STERLING ST BROOKLYN, NY 11225 GUY JEAN-MICHEL 450 4TH ST ELMONT QUEENS, NY 11563 JAMES ANDERSON 1067 EAST 84TH ST BROOKLYN, NY 11236 JAMES CLARKE 3054 AVE W BROOKLYN, NY 11229 JAMES COLEMAN 832 HERKIMER ST BROOKLYN, NY 11233 JAMES ELIASSAINT 1366 NEW YORK AVE - APT 6G BROOKLYN, NY 11210 JAMES JOSEPH 45 LINDEN BLVD - APT 3D BROOKLYN, NY 11226 JAYDEN JULIEN 759 EAST 82 ST - 1ST FLR BROOKLYN, NY 11236 JEAN DREGEN 1302 AVE K BROOKLYN, NY 11230 JEAN-SAMSON ZAMOR 979 E 45TH ST BROOKLYN, NY 11203



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JOSEPH BARKLEY 446 E 53RD ST JAMAICA, NY 11432 JOSEPH ROBERT 1219 E 73RD ST - #2F BROOKLYN, NY 11234 JOSEPH WILLIAMS 2411 CLARENDON RD BROOKLYN, NY 11226 JUNIOR GREEN 675 LINCOLN AVE BROOKLYN, NY 11218 KERVENS LEANDRE 1357 EAST 95TH ST BROOKLYN, NY 11212 KERVIN RAMEAU 2225 FAR ROCKAWAY BLVD ROCKAWAY, NY 11691 LAURA CELESTIN 2212 DITMAS AVE - #6C BROOKLYN, NY 11226 LAWAN REESE 789 MACDONOUGH ST - APT 3A BROOKLYN, NY 11233 LEMAITRE VIDEAU 2044 E 41ST BROOKLYN, NY 11234 LEONARDO BEAUVAIS 801 ALBANY AVE - APT 1F BROOKLYN, NY 11203 LEONIE TRENCH 2678 LINDEN BLVD BROOKLYN, NY 11208 MARCELINE JULES 2678 LINDEN BLVD BROOKLYN 2B, NY 11208 MARCO OREILLUS 1402 EASTERN PARKWAY BROOKLYN, NY 11233 MARIE ALTIME 135 OCEAN AVE BROOKLYN, NY 11225

MARIE JEAN 521 E 22ND ST BROOKLYN, NY 11226 MARK CHERY 19315 A 73RD AVENUE - APT 1B FRESH MEADOWS, NY 11365 MAYERLY MEJIAS 71-15 BEACH CHANNEL DRIVE - APT 10G FAR ROCKAWAY, NY 11692 MEGAN MATTIS 832 E 52ND ST - APT 4 BROOKLYN, NY 11203 MIESHAWN MOORE 721 HERKIMER ST BROOKLYN, NY 11223 MIKERSON ELIASSAINT 1366 NEW YORK AVE - APT 6G BROOKLYN, NY 11210 MILTON MARSHALL 1019 HENDRIX ST BROOKLYN, NY 11207 MOSES FALL 98 VERONICA PL BROOKLYN, NY 11226 NADEGE CANDIO 9407 KINGS HIGHWAY - 6D BROOKLYN, NY 11212 O’NIEL PERRISSAINT 378 E 24TH ST - APT 3F BROOKLYN, NY 11203 ORELIEN HUGGINS 3325 NEPTUNE AVE - APT 1101 BROOKLYN, NY 11224 PETER JACKSON 2716 CORTELYOU RD BROOKLYN, NY 11226 PIERRIE METIVIER 340 THOMAS BOYLAND ST BROOKLYN, NY 11233 PRESUME VILLER 45 HAWTHORNE BROOKLYN, NY 11225



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RANDY HONORA 127 EAST 96 ST BROOKLYN, NY 11212 RAYMOND COLETTI 27 BEECH RD POTSDAM, NY 13676 REGGIE ROB 1789 NOSTRAND AVE BROOKLYN, NY 11226 REGINALD IRIZARRY 626 EAST 43RD ST BROOKLYN, NY 11203 RICKY DORVIL 4113 CHURCH AVE BROOKLYN, NY 11203 RODNEY-PIERRE PAUL 580 E 21ST ST - APT 3D BROOKLYN, NY 11226 ROODY VIDO 690 E 45TH ST BROOKLYN, NY 11203 RUSLEE SMARTT 753 MACDONOUGH ST BROOKLYN, NY 11223 SERGE CASTOR 1204 BROOKLYN AVENUE BROOKLYN, NY 11203 SHAKEIM PETERS 291 MARTENSE ST BROOKLYN, NY 11226 SHALA UDDIN 364 ATKINS AVE - APT. 2A BROOKLYN, NY 11208 SHARON CARTER-ROSS 485 WEST BROAD ST - APT 3 HAZELTON, PA 18201 SHAWN WILLIAMS 1788 NOSTRAND RD BROOKLYN, NY 11226 SHAYLIA WALTON 160-09 111 AVE QUEENS, NY 11433

SHAZI MARAV 88 MARION ST BROOKLYN, NY 11226 STEVE JOHNSON 2916 CLARENDON RD BROOKLYN, NY 11226 TAIHEEN SHULER 1820 KINGS HIGHWAY BROOKLYN, NY 11229 TAREK BECKLES 224 EAST 16TH ST BROOKLYN, NY 11226 5 BOROUGH ANESTHESIA, PLLC 1400 5TH AVENUE, SUITE #3E NEW YORK, NEW YORK 10026 ACCESS CARE PT, P.C. 34 TUXEDO AVE. NEW HYDE PARK, NEW YORK 11040 ACTION CHIROPRACTIC P.C. 54 COUNTRY DRIVE PLAINVIEW, NEW YORK 11803 ACUCARE4U ACUPUNCTURE PLLC 1210 NOSTRAND AVE BROOKLYN, NEW YORK 11225 AHMED ABDELAAL PT, DPT 2896 SHELL ROAD, #82 BROOKLYN, NEW YORK 11224 ALL CITY FAMILY HEALTHCARE CTR, INC. 3632 NOSTRAND AVE BROOKLYN, NEW YORK 11229 ALTAI CORP. DBA GET READY MEDICAL SUPPLY 7122 BAY PKWY FL 2ND BROOKLYN, NEW YORK 11204 ANDREW J DOWD MD 3771 NESCONSET HWY SOUTH SETAUKET, NEW YORK 11720 ARD RX INC 60-61 MYRTLE AVE RIDGEWOOD, NEW YORK 11385 ARISTA PHYSICAL THERAPY P.C. 1324 FOREST AVENUE, SUITE 257 STATEN ISLAND, NEW YORK 10302



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ARON ROVNER MD, PLLC 245 E. 84TH STREET NEW YORK, NEW YORK 10028 ATLAS PHARMACY LLC 92-13 JAMAICA AVE. WOODHAVEN, NEW YORK 11427 ATLAS RADIOLOGY P.C. 11 BRITTANY COURT, PO BOX 252 CHAPPAQUA, NEW YORK 10514 AVERROES PHYSICAL THERAPY P.C. 10510 FLATLANDS AVE. BROOKLYN, NEW YORK 11236 AXIAL CHIROPRACTIC, P.C. 54 COUNTRY DRIVE PLAINVIEW, NEW YORK 11803 BIG APPLE MED EQUIPMENT INC 16102 UNION TPKE STE B FRESH MEADOWS, NEW YORK 11366 BILLY H. FORD, MD P.C. 103 PIERSON AVENUE HEMPSTEAD, NEW YORK 11550 BROOKLYN MCDONALD MED. CARE PLLC 486 MCDONALD AVE. BROOKLYN, NEW YORK 11432 BURKE PHYSICAL THERAPY, P.C. 38 THOMPSON ST VALLEY STREAM, NEW YORK 11580 CAVALLARO MEDICAL SUPPLY INC 2520 KINGS HWY SUITE 1B BROOKLYN, NEW YORK 11229 CHI LEE ACUPUNCTURE P.C. 6707 YELLOWSTONE BLVD. #2E FOREST HILLS, NEW YORK 11375 CHIROPRACTIC PAIN SOLUTIONS P.C. 3393 LONG BEACH RD. OCEANSIDE, NEW YORK 11572 CITY WIDE HEALTH FACILITY, INC. 105 KINGS HIGHWAY BROOKLYN, NEW YORK 11214 CLASS POINT ACUPUNCTURE, PLLC PO BOX 618 WESTBURY, NEW YORK 11590

CMA PSYCHOLOGY, P.C 3098 ANN STREET BALDWIN, NEW YORK 11510 COMPREHENSIVE PSYCHOLOGICAL PC 1663 EAST 17TH STREET BROOKLYN, NEW YORK 11229 CONTEMPORARY MED. DIAG. SERV., P.C. 4050 NOSTRAND AVNUE SUITE M-1 BROOKLYN, NEW YORK 11235 CONTEMPORARY OTHOPEDICS, PLLC 83 LEE AVENUE ALBERSTON, NEW YORK 11507 CORRECTALIGN CHIROPRACTIC P.C. 84 LINDEN BOULEVARD BROOKLYN, NEW YORK 11226 CUSTOM RX PHARMACY LLC 102-03A QUEENS BLVD FOREST HILLS, NEW YORK 11375 DANIMARK PHYSICAL THERAPY, P.C. 6 GRAMATAN AVENUE, SUITE 203 MOUNT VERNON, NEW YORK 10550 DELPHI CHIROPRACTIC P.C. 5 AMHERST STREET BROOKLYN, NEW YORK 11235 DIANA BEYNIN, DC 515 MAIN ST, 9A CHATHAM, NEW JERSEY 07928 DNA PHARMACY INC. 283 COMMACK ROAD SUITE 210 COMMACK, NEW YORK 11725 DOS MANOS CHIROPRACTIC P.C. 170 WEST 233RD STREET BRONX, NEW YORK 10463 DR. OFFENBACHER MED. IMAGING, PLLC 3852 NOSTRAND AVENUE BROOKLYN, NEW YORK 11235 STEPHEN A. MATRANGOLO, D.C., P.C. 3419 QUENTIN ROAD BROOKLYN, NEW YORK 11234 DR. WATSON CHIROPRACTIC, P.C. 101 CAMBON AVENUE ST. JAMES, NEW YORK 11780



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EAST 19 MEDICAL SUPPLY CORP. 2083 EAST 19 STREET BROOKLYN, NEW YORK 11229 ENGLEWOOD ORTHOPEDICS GROUP PC 401 SOUTH VAN BRUNT STREET ENGLEWOOD, NEW JERSEY 07631 EZ ORTHO SUPPLY INC 2119 EAST 15TH ST BROOKLYN, NEW YORK 11229 FAIRPOINT ACUPUNCTURE P.C. 853 PEPPERIDGE RD WESTBURY, NEW YORK 11590 FLORID LEISURE ACUPUNCTURE P.C. 81-20 DONGAN AVE #2F ELMHURST, NEW YORK 11373 LEISURE TECHNOLOGY OF FLORIDA, INC. 111 EIGHTH AVENUE NEW YORK, NEW YORK 10011 FRANK ZHAN BEST PHYS. THERAPY P.C 185 CANAL STREET, SUITE 505 NEW YORK, NEW YORK 10013 GC ACUPUNCTURE, P.C. 19 E. BROADWAY NEW YORK, NEW YORK 10002 GESHER PSYCHOLOGICAL SERVICES P.C. 821 NEWBURG AVE VALLEY STREAM, NEW YORK 11581 GOOD LIFE ACUPUNCTURE P.C. 175D MANORHAVEN BLVD PORT WASHINGTON, NEW YORK 11050 GOOD SPACE ACUPUNCTURE P.C 114-59 TAIPEI COURT COLLEGE POINT, NEW YORK 11356 HAZAQ PSYCHOLOGICAL SERVICES P.C. 821 NEWBURG AVE VALLEY STREAM, NEW YORK 11581 HEALTH AND COMFORT RX, INC 147-16 JAMAICA AVE JAMAICA, NEW YORK 11435 HMP ORTHOPAEDICS, P.C. 50 EAST 77TH STREET, APT 1C NEW YORK, NEW YORK 10075

HUDSON REGIONAL HOSPITAL 55 MEADOWLANDS PARKWAY SECAUCUS, NEW JERSEY 07094 IGOR MAYZENBERG, LAC 2166 79TH ST BROOKLYN, NEW YORK 11214 JOHN S. LYONS, M.D., P.C. 164-25 NORTHERN BOULEVARD FLUSHING, NEW YORK 11358 JOINT PHYSICAL THERAPY P.C. 164-10 CROCHERON AVENUE FLUSHING, NEW YORK 11358 JOSEPH A RAIA, M.D.,P.C. 9101 4TH AVE BROOKLYN, NEW YORK 11209 JSJ ANESTHESIA AND PAIN MGMT, PLLC 813 QUENTIN ROAD, STE 200 BROOKLYN, NEW YORK 11223 FRANCOIS JULES PARISIEN, M.D., P.C. 105 STEVENS AVE. MOUNT VERNON, NEW YORK 10550 KH LEE ACUPUNCTURE, P.C. 512 EAST 88TH STREET #3D NEW YORK, NEW YORK 10128 KINGS COUNTY HOSPITAL 451 CLARKSON AVE BROOKLYN, NEW YORK 11203 LINWOOD WEST MEDICAL, P.C. 84 LINDEN BLVD BROOKLYN, NEW YORK 11226 LONGEVITY MEDICAL SUPPLY, INC. 7323 20TH AVENUE BROOKLYN, NEW YORK 11204 LPM PHARMACY INC 7537 MAIN STREET FLUSHING, NEW YORK 11367 LR MEDICAL, PLLC 2277-83 CONEY ISLAND AVE. BROOKLYN, NEW YORK 11234 M&D ELITE PHARMACY LLC 23919 BRADDOCK AVE BELLROSE, NEW YORK 11426



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MACCABI PHARMACY RX INC 9825 65TH ROAD APT 2D REGO PARK, NEW YORK 11374 MALVINA DRUG CORP, LPM PHARM. INC 300 HEMPSTEAD TPKE WEST HEMPSTEAD, NEW YORK 11552 DR .MATTHEW HARLAN HOOVIS 1835 BAY RIDGE PARKWAY 3RD FLOOR BROOKLYN, NEW YORK 11204 MC PHYSICAL THERAPY, P.C. 75-10 YELLOWSTONE BLVD, APT. 4F REGO PARK, NEW YORK 11374 MEDICAL PLAZA 3040 NOSTRAND AVE BROOKLYN, NEW YORK 11229 METRO PAIN SPECIALISTS P. C. 790 BLOOMFIELD AVE SUITE 1A CLIFTON, NEW JERSEY 7012 METROPOLITAN MED. AND SURGICAL P.C. 2076 E 13TH ST BROOKLYN, NEW YORK 11229 MICHELE B. GLISPY, LAC 2266 BATH AVE #055 BROOKLYN, NEW YORK 11214 MIDWOOD METROPOLITAN MEDICAL P.C. 1720 EAST 14TH STREET, UNIT M-1 BROOKLYN, NEW YORK 11229 MILL NECK CHIROPRACTIC 219-16 LINDEN BOULEVARD 1ST FLOOR JAMAICA, NEW YORK 11411 MIN PHYSICAL THERAPY, P.C. 17163 46TH AVENUE #2RR FLUSHING, NEW YORK 11358 MOLNAR MEDICAL SERVICES PC 8339 DANIELS ST JAMAICA, NEW YORK 11435 MOTION MEDICAL DIAGNOSTICS P.C. 591 STEWART AVE - SUITE 400 GARDEN CITY, NEW YORK 11530 MULTISPECIALTY HEALTH GROUP 632 UTICA AVE BROOKLYN, NEW YORK 11203

NEW CAPITAL 1 INC. 90-20 138 PLACE JAMAICA, NEW YORK 11435 NEW MILLENNIUM MED. IMAGING, P.C. 138-48 ELDER AVENUE FLUSHING, NEW YORK 11355 NEW YORK CORE CHIROPRACTIC P.C. 208-10 CROSS ISLAND PKWY #528 BAYSIDE, NEW YORK 11360 NEW YORK INJURY CHIRO. REHAB P.C. 45 PARK STREET MONTCLAIR, NEW JERSEY 7042 NEW YORK THERA PT P.C., 172 92ND STREET, 1ST FLOOR BROOKLYN, NEW YORK 11209 NEXRAY MEDICAL IMAGING, P.C. 8 LEONARD DRIVE EAST ROCKAWAY, NEW YORK 11518 NOVA MEDICAL DIAGNOSTIC P.C 6317 AVENUE N BROOKLYN, NEW YORK 11234 NY BEST SUPPLY INC 74 QUENTIN RD BROOKLYN, NEW YORK 11223 NYC CARE CHIROPRACTIC P C. 1204 AVE. U #1210 BROOKLYN, NEW YORK 11229 NYC CARE PT, P.C. 1101 66TH ST 2F BROOKLYN, NEW YORK 11219 NYWWQASC, LLC 45-64 FRANCIS LEWIS BLVD #200 BAYSIDE, NEW YORK 11361 OP ACUPUNCTURE, P.C. 1959 EAST 17 STREET, APT 3 BROOKLYN, NEW YORK 11229 PERFORMANCE CHIROPRACTIC, P.C. 2052 RICHMOND ROAD STATEN ISLAND, NEW YORK 10306 PONCE ACUPUNCTURE, P.C. 10 WHISPERING FIELD DR. NORTHPORT, NEW YORK 11768



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PROTECHMED INC. 7064 KISSENA BLVD, 3FL FLUSHING, NEW YORK 11367 QIXIA ACUPUNCTURE P.C. 4801 66TH STREET 1FL WOODSIDE, NEW YORK 11377 RAF SPORTS CHIROPRACTIC P.C. 149 TWIN LANE N WANTAGH, NEW YORK 11793 RAINE M PESIDAS PHYSICAL THERAPY P.C. 4150 78TH STREET, APT 728 ELMHURST, NEW JERSEY 11373 RANDALL ACUPUNCTURE, P.C. 80-10 165TH STREET HILLCREST, NEW YORK 11432 REHAB TIME PT,P.C. 324 E 25TH ST BROOKLYN, NEW YORK 11226 REHABILITATION MEDICAL CENTER 1835 BAY RIDGE PKWY BROOKLYN, NEW YORK 11204 RENAN MACIAS MD 94-27 59TH AVE UNIT F6 ELMHURST, NEW YORK 11373 ROMEO MARIMAT PHYSICAL THERAPY 501 5TH AVE, 1202 NEW YORK, NEW YORK 10017 ROXBURY ANESTHESIA, LLC 550 NEWARK AVE, 5TH FLOOR JERSEY CITY, NEW JERSEY 7306 RUN HONG LI ACUPUNCTURE P.C. 1720 AVENUE U BROOKLYN, NEW YORK 11229 SABAS NY SERVICES INC 70 E SUNRISE HIGHWAY, STE 500 VALLEY STREAM, NEW YORK 11581 SAFE ANESTHESIA, PLLC 110-09 67TH DRIVE FOREST HILLS, NEW YORK 11375 SCOB, LLC 80 STATE STREET ALBANY, NEW YORK 12207

SEAN L. THOMPSON, MD 175-61 HILLSIDE AVENUE #400 JAMAICA, NEW YORK 11432 SEDATION VACATION PERIOP MED PLLC 811 WILSON STREET VALLEY STREAM, NEW YORK 11581 SHAMAYIM CHIROPRACTIC, P.C. 241 37TH STREET, SUITE B439 BROOKLYN, NEW YORK 11232 SHASHEK CHIROPRACTIC, P.C. 15 PARENTE LANE NORTH ISLAND PARK, NEW YORK 11558 SKY RADIOLOGY P.C. 140-15 HOLLY AVE. FLUSHING, NEW YORK 11355 SOLID ROK PHYSICAL THERAPY P.C 5607 AVENUE L BROOKLYN, NEW YORK 11234 ARMENGOL MEDICAL, P.C. 2474 MCDONALD AVE, 2ND FL BROOKLYN, NEW YORK 11223 SORREL ACUPUNCTURE P.C. 174 BRIGHTON 11TH ST BROOKLYN, NEW YORK 11235 ST. KYROLLOS PHYSICAL THERAPY P.C. 6309 BAY PARKWAY AVENUE, SUITE A11 BROOKLYN, NEW YORK 11204 STRAND PHARMACY D/B/A ASTORIA DRUGS, INC. 2501 BROADWAY 1 FLOOR ASTORIA, NEW YORK 11106 STRUCTURAL SYNERGY P.T., P.C. 160 BROADWAY 16TH FL NEW YORK, NEW YORK 10038 SURGERY CENTER OF ORADELL 680 KINDERKAMACK RD #100 ORADELL, NEW JERSEY 07649 SURGICORE OF JERSEY CITY, LLC 550 NEWARK AVE JERSEY CITY, NEW JERSEY 07306 TAI QI WELLNESS ACUPUNCTURE PC, 141-05 33RD AVE FLUSHING, NEW YORK 11354



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TANUJ PALVIA, MD 409 FULTON STREET, 2ND FLOOR BROOKLYN, NEW YORK 11201 TIME TO CARE MEDICAL, P.C. 852 AVENUE Z BROOKLYN, NEW YORK 11235 TIME TO CARE PHARMACY INC 2080 84TH STREET, STE A4 BROOKLYN, NEW YORK 11214 TOPLAB 67-71 EAST WILLOW ST MILLBURN, NEW JERSEY 07041

UNICAST INC 20 WEST 47TH STREET NEW YORK, NEW YORK 10036 UNION DME CORP 162-16 UNION TURNPIKE, SUITE 202 FRESH MEADOWS, NEW YORK 11367 UNIVERSITY HOSPITAL OF BROOKLYN 450 CLARKSON AVENUE BROOKLYN, NEW YORK 11203 WELLNESS DIAGNOSTIC IMAGING, PC 1608 59TH ST BROOKLYN, NEW YORK 11204 YELLOWSTONE MEDICAL REHAB P.C. 18 GREENLAWN ROAD HUNTINGTON, NEW YORK 11743



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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX

THE GENERAL INSURANCE, PERMANENT GENERAL ASSURANCE CORPORATION, PERMANENT GENERAL ASSURANCE CORPORATION OF OHIO, THE GENERAL AUTOMOBILE INSURANCE COMPANY, INC.,

Plaintiffs,

- against - AYANNA PIQUION, BARBARA ALTIME, CAMILLE DEROSE, CHEYENNE VAZQUEZ, CLYFFORD MAURICE, DAVID BROWN, ERIQUE BERTRAND, FARAH FELIX, FLIGHTDENICA PERARD, GREGORY REMEDOR, JOHN FRANCOIS, JUNIOR BEAUZILE, KINET DATILIEN, LORENZO DERBERRY, LOVENS FONTILUS, MARIE SYLVERT, MIKE PIERRE-PAUL, NASIA GASPARD, QUENCY NOEL, RAHEEM GILLESPIE, RASHEKA BRYAN, RUYSS ST FLEURANT, SACHA DESRAVINES, SADE LONG, SANDY CABA-DURAN, SEAN CARY FRANCIS, STEEVE GUILLAUME, TYREIK WILLIAMSON, (collectively the “Policy Defendants”)

-and-

ANASIA DESTINY SMITH, BETINA LAFORTUNE, BILLY SMITH, CHEYENNE VAZQUEZ, CLAUDY BELLANGER, DANA WHITE, DARRYN RIDDICK, DEJANE VERA, DONALD DEBROSSE, DUANE BOUCHER, EL DORVILE, ELIRUS WALTHUST, EMIYA TOLEDO, EVENSON SOUVERAIN, FARAH FELIX, FRANCESCA SYLVERT, FRANCKLIN ETIENNE, GUY JEAN-MICHEL, JAMES ANDERSON, JAMES CLARKE, JAMES COLEMAN, JAMES ELIASSAINT, JAMES JOSEPH, JAYDEN JULIEN, JEAN DREGEN, JEAN-SAMSON ZAMOR, JOSEPH BARKLEY, JOSEPH ROBERT, JOSEPH WILLIAMS, JUNIOR GREEN, KERVENS LEANDRE, KERVIN RAMEAU, LAURA CELESTIN, LAWAN REESE, LEMAITRE VIDEAU, LEONARDO BEAUVAIS, LEONIE TRENCH, MARCELINE JULES, MARCO OREILLUS, MARIE ALTIME, MARIE JEAN, MARK CHERY, MAYERLY MEJIAS, MEGAN MATTIS, MIESHAWN MOORE, MIKERSON ELIASSAINT, MILTON MARSHALL, MOSES FALL, NADEGE CANDIO, O’NIEL PERRISSAINT, ORELIEN HUGGINS, PETER JACKSON,

Index No.: _____/2020E

VERIFIED COMPLAINT



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PIERRIE METIVIER, PRESUME VILLER, RANDY HONORA, RAYMOND COLETTI, REGINALD IRIZARRY, REGGIE ROB, RODNEY-PIERRE PAUL, ROODY VIDO, RUSLEE SMARTT, SERGE CASTOR, SHAKEIM PETERS, SHALA UDDIN, SHARON CARTER-ROSS, SHAWN WILLIAMS, RICKY DORVIL, SHAYLIA WALTON, SHAZI MARAV, STEVE JOHNSON, TAIHEEN SHULER, TAREK BECKLES (collectively the “Staged Loss Defendants”)

-and- 5 BOROUGH ANESTHESIA, PLLC, ACCESS CARE PT, P.C., ACTION CHIROPRACTIC, P.C., ACUCARE4U ACUPUNCTURE PLLC,AHMED ABDELAAL PT, DPT, ALL CITY FAMILY HEALTHCARE, ALTAI CORP. DBA GET READY MEDICAL SUPPLY, ANDREW J DOWD MD, ARD RX INC, ARISTA PHYSICAL THERAPY PC, ARON ROVNER MD, PLLC, ATLAS PHARMACY LLC, ATLAS RADIOLOGY, P.C., AVERROES PHYSICAL THERAPY PC, AXIAL CHIROPRACTIC, PC, BIG APPLE MED EQUIPMENT INC, BILLY H. FORD, MD PC, BROOKLYN MCDONALD MEDICAL CARE, PLLC, BURKE PHYSICAL THERAPY PC, CAVALLARO MEDICAL SUPPLY, CHI LEE ACUPUNCTURE PC, CHIROPRACTIC PAIN SOLUTIONS, P.C., CITY WIDE HEALTH FACILITY, INC, CLASS POINT ACUPUNCTURE, PLLC, CMA PSYCHOLOGY, P.C, COMPREHENSIVE PSYCHOLOGICAL PC, CONTEMPORARY DIAGNOSTIC IMAGING, CONTEMPORARY OTHOPEDICS, CORRECTALIGN CHIROPRACTIC PC, CUSTOM RX PHARMACY, DANIMARK PHYSICAL THERAPY PC, DELPHI CHIROPRACTIC PC, DIANA BEYNIN, DC, DNA PHARMACY INC, DOS MANOS CHIROPRACTIC PC, DR. OFFENBACHER MEDICAL IMAGING, PLLC, DR. S. MATRANGOLO, DC, DR. WATSON CHIROPRACTIC, PC, EAST 19 MEDICAL SUPPLY CORP., ENGLEWOOD ORTHOPEDICS GROUP PC, EZ ORTHO SUPPLY INC., FAIRPOINT ACUPUNCTURE PC, FLORID LEISURE ACUPUNCTURE P.C., FRANK ZHAN BEST PHYSICAL THERAPY, P.C., GC ACUPUNCTURE PC, GESHER PSYCHOLOGICAL SERVICES, P.C., GOOD LIFE ACUPUNCTURE, P.C., GOOD SPACE ACUPUNCTURE P.C, HAZAQ PSYCHOLOGICAL SERVICES, P.C., HEALTH AND COMFORT RX, INC, HEALTH EAST MED ALLIANCE, HMP ORTHOPAEDICS, HUDSON REGIONAL HOSPITAL, IGOR



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MAYZENBERG, LAC, JOHN LYONS MD, JOINT PHYSICAL THERAPY P C, JOSEPH A RAIA MD PC, JSJ ANESTHESIA PAIN MANAGEMENT PLLC, JULES F PARISIEN, KH LEE ACUPUNCTURE P C, KINGS COUNTY HOSPITAL, LINWOOD WEST MEDICAL, P.C., LONGEVITY MEDICAL SUPPLY, INC., LPM PHARMACY INC LR MEDICAL PLLC, M&D ELITE PHARMACY LLC, MACCABI PHARMACY RX INC, MALVINA DRUG CORP, LPM PHARMACY INC, MATTHEW HARLAN HOOVIS, MC PHYSICAL THERAPY, PC, MEDICAL PLAZA, METRO PAIN SPECIALISTS, PC, METROPOLITAN MEDICAL AND SURGICAL, P.C., MICHELE B. GLISPY, LAC., MIDWOOD METROPOLITAN MEDICAL, P.C., MILL NECK CHIROPRACTIC, MIN PHYSICAL THERAPY P.C., MOLNAR MEDICAL SERVICES PC, MOTION MEDICAL DIAGNOSTICS, PC, MULTISPECIALTY HEALTH GROUP, NEW CAPITAL 1 INC., NEW MILLENNIUM MEDICAL IMAGING, P.C., NEW YORK CORE CHIROPRACTIC PC, NEW YORK INJURY CHIROPRACTIC REHAB PC, NEW YORK THERA PT PC, NEXRAY MEDICAL IMAGING PC, NOVA MEDICAL DIAGNOSTIC, P.C., NY BEST SUPPLY, INC, NYC CARE CHIROPRACTIC P C., NYC CARE PT, PC, NYWWQASC, LLC, OP ACUPUNCTURE, P.C., PERFORMANCE CHIRO, P.C., PONCE ACUPUNCTURE, P.C., PROTECHMED INC., QIXIA ACUPUNCTURE PC, RAF SPORTS CHIROPRACTIC PC, RAINE M PESIDAS PHYSICAL THERAPY PC, RANDALL ACUPUNCTURE P.C., REHAB TIME PT PC REHABILITATION MEDICAL CENTER, RENAN MACIAS MD, ROMEO MARIMAT PHYSICAL THERAPY, ROXBURY ANESTHESIA, LLC RUN HONG LI, SABAS NY SERVICES INC, SAFE ANESTHESIA AND PAIN, LLC, SCOB, LLC, SEAN L. THOMPSON, SEDATION VACATION, PERIOP MED PLLC, SHAMAYIM CHIROPRACTIC, P.C., SHASHEK CHIROPRACTIC PC, SKY RADIOLOGY, SOLID ROK PHYSICAL THERAPY, P.C, SONIA ARMENGOL, MD, SORREL ACUPUNCTURE P.C., ST. KYROLLOS PHYSICAL THERAPY, P.C., STRAND PHARMACY D/B/A ASTORIA DRUGS, INC., STRUCTURAL SYNERGY PHYSICAL THERAPY, PC, SURGERY CENTER OF ORADELL, SURGICORE OF JERSEY CITY, LLC, TAI QI WELLNESS ACUPUNCTURE PC, TANUJ PALVIA, TIME TO CARE MEDICAL, P.C., TIME TO CARE PHARMACY INC, TOPLAB UNICAST INC, UNION DME, UNIVERSITY HOSPITAL OF BROOKLYN, WELLNESS DIAGNOSTIC IMAGING, PC, YELLOWSTONE MEDICAL REHAB P.C.



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(collectively the “Provider Defendants”) Defendants

THE GENERAL AUTOMOBILE INSURANCE SERVICES, INC., PERMANENT

GENERAL ASSURANCE CORPORATION, PERMANENT GENERAL ASSURANCE

CORPORATION OF OHIO, THE GENERAL AUTOMOBILE INSURANCE COMPANY,

INC., (collectively hereinafter “The General” or “plaintiffs”), above named by its attorneys,

Freiberg, Peck & Kang, LLP, for its verified complaint to obtain a judgment herein declaring the

rights and legal relations of the parties to this action in the respects hereinafter set forth, alleges:

INTRODUCTION

1. This action seeks to terminate a massive, ongoing, fraudulent scheme perpetrated

against The General, whereby individuals and their associates obtain automobile insurance policies

from The General (the “Subject Policies”) typically through false and fraudulent policy

applications.

2. These individuals and their associates then stage automobile “accidents” involving

the vehicles insured under the Subject Policies.

3. A series of fraudulent claims for personal injury protection (“No-Fault”) benefits

uninsured/underinsured motorist benefits and liability coverage are then submitted in connection

with these staged “accidents” that have each been intentionally caused;

4. The policies and claims described herein are interrelated in that they share common

circumstances, parties, pedigree information including IP addresses, policy addresses and medical

providers, among other information.



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5. There are common ringleaders that permeate these claims and it is evident that the

insureds and claimants herein are willfully causing these “accidents” in an attempt to commit

insurance fraud.

6. Additionally, many of the purported “accident victims” of these “accidents” fail to

respond to The General’s requests for additional verification, including requests that they appear

for examinations under oath as required under the Subject Policies and No-Fault regulations and

the Insurance Law. When these purported victims do appear for their respective examinations

under oath, there are frequently clear contradictions within and between their testimony and

material misrepresentations are made with respect to the losses at issue and the resulting claims.

7. Accordingly, The General seeks declaratory judgment, pursuant to CPLR 3001,

declaring that:

i) the pertinent accidents were staged, not genuine, and The General is not

obligated to pay any first-party benefits on the Subject Policies to the

healthcare providers or to the named insureds and/or claimants, including

but not limited to No-Fault benefits, uninsured/underinsured motorist

benefits, nor is The General obligated to defend nor provide indemnification

for the named insureds or the individuals who operated or occupied the

insured vehicles for claims that are made against them seeking damages and

payment under the Subject Policies;

ii) the Subject Policies were procured through fraud, and The General

therefore is not obligated to pay any claims that arise from the Subject

Policies; including but not limited to first-party benefits to the healthcare

providers or to the named insureds and/or claimants, including but not



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limited to No-Fault benefits, uninsured/underinsured motorist benefits, nor

is The General obligated to defend nor provide indemnification for the

named insureds or the individuals who operated or occupied the insured

vehicles for claims that are made against them seeking damages and

payment under the Subject Policies; and

iii) to the extent that insureds and/or claimants who seek to collect first-party

benefits The General and systematically fail to respond to The General’s

requests for additional verification, including examinations under oath

and/or independent medical examinations, such conduct constitutes a

material breach of a condition to coverage which relieves The General from

its obligation to pay the claims.

8. The defendants are categorized into the following categories:

i) AYANNA PIQUION, BARBARA ALTIME, CAMILLE DEROSE,

CHEYENNE VAZQUEZ, CLYFFORD MAURICE, DAVID BROWN,

ERIQUE BERTRAND, FARAH FELIX, FLIGHTDENICA PERARD,

GREGORY REMEDOR, JOHN FRANCOIS, JUNIOR BEAUZILE,

KINET DATILIEN, LORENZO DERBERRY, LOVENS FONTILUS,

MARIE SYLVERT, MIKE PIERRE-PAUL, NASIA GASPARD,

QUENCY NOEL, RAHEEM GILLESPIE, RASHEKA BRYAN, RUYSS

ST FLEURANT, SACHA DESRAVINES, SADE LONG, SANDY

CABA-DURAN, SEAN CARY FRANCIS, STEEVE GUILLAUME and

TYREIK WILLIAMSON (collectively the “Policy Defendants”) are

individuals who procure automobile insurance policies through false and



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fraudulent policy applications and, in many instances, are knowingly

involved in staging the incidents at issue that result in false and fraudulent

claims;

ii) ANASIA DESTINY SMITH, BETINA LAFORTUNE, BILLY SMITH,

CHEYENNE VAZQUEZ, CLAUDY BELLANGER, DANA WHITE,

DARRYN RIDDICK, DEJANE VERA, DONALD DEBROSSE, DUANE

BOUCHER, EL DORVILE, ELIRUS WALTHUST, EMIYA TOLEDO,

EVENSON SOUVERAIN, FARAH FELIX, FRANCESCA SYLVERT,

FRANCKLIN ETIENNE, GUY JEAN-MICHEL, JAMES ANDERSON,

JAMES CLARKE, JAMES COLEMAN, JAMES ELIASSAINT, JAMES

JOSEPH, JAYDEN JULIEN, JEAN DREGEN, JEAN-SAMSON

ZAMOR, JOSEPH BARKLEY, JOSEPH ROBERT, JOSEPH

WILLIAMS, JUNIOR GREEN, KERVENS LEANDRE, KERVIN

RAMEAU, LAURA CELESTIN, LAWAN REESE, LEMAITRE

VIDEAU, LEONARDO BEAUVAIS, LEONIE TRENCH, MARCELINE

JULES, MARCO OREILLUS, MARIE ALTIME, MARIE JEAN, MARK

CHERY, MAYERLY MEJIAS, MEGAN MATTIS, MIESHAWN

MOORE, MIKERSON ELIASSAINT, MILTON MARSHALL, MOSES

FALL, NADEGE CANDIO, O’NIEL PERRISSAINT, ORELIEN

HUGGINS, PETER JACKSON, PIERRIE METIVIER, PRESUME

VILLER, RANDY HONORA, RAYMOND COLETTI, REGINALD

IRIZARRY, REGGIE ROB, RODNEY-PIERRE PAUL, ROODY VIDO,

RUSLEE SMARTT, SERGE CASTOR, SHAKEIM PETERS, SHALA



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UDDIN, SHARON CARTER-ROSS, SHAWN WILLIAMS, RICKY

DORVIL, SHAYLIA WALTON, SHAZI MARAV, STEVE JOHNSON,

TAIHEEN SHULER and TAREK BECKLES (collectively the “Staged

Loss Defendants”) are individuals knowingly involved in the staged

accidents and who assign their rights to No-Fault benefits to the Provider

Defendants and /or file claims for personal injuries against the Policy

Defendants; and

iii) 5 BOROUGH ANESTHESIA, PLLC, ACCESS CARE PT, P.C., ACTION

CHIROPRACTIC, P.C., ACUCARE4U ACUPUNCTURE

PLLC,AHMED ABDELAAL PT, DPT, ALL CITY FAMILY

HEALTHCARE, ALTAI CORP. DBA GET READY MEDICAL

SUPPLY, ANDREW J DOWD MD, ARD RX INC, ARISTA PHYSICAL

THERAPY PC, ARON ROVNER MD, PLLC, ATLAS PHARMACY

LLC, ATLAS RADIOLOGY, P.C., AVERROES PHYSICAL THERAPY

PC, AXIAL CHIROPRACTIC, PC, BIG APPLE MED EQUIPMENT INC,

BILLY H. FORD, MD PC, BROOKLYN MCDONALD MEDICAL

CARE, PLLC, BURKE PHYSICAL THERAPY PC, CAVALLARO

MEDICAL SUPPLY, CHI LEE ACUPUNCTURE PC, CHIROPRACTIC

PAIN SOLUTIONS, P.C., CITY WIDE HEALTH FACILITY, INC,

CLASS POINT ACUPUNCTURE, PLLC, CMA PSYCHOLOGY, P.C,

COMPREHENSIVE PSYCHOLOGICAL PC, CONTEMPORARY

DIAGNOSTIC IMAGING, CONTEMPORARY OTHOPEDICS,

CORRECTALIGN CHIROPRACTIC PC, CUSTOM RX PHARMACY,



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DANIMARK PHYSICAL THERAPY PC, DELPHI CHIROPRACTIC PC,

DIANA BEYNIN, DC, DNA PHARMACY INC, DOS MANOS

CHIROPRACTIC PC, DR. OFFENBACHER MEDICAL IMAGING,

PLLC, DR. S. MATRANGOLO, DC, DR. WATSON CHIROPRACTIC,

PC, EAST 19 MEDICAL SUPPLY CORP., ENGLEWOOD

ORTHOPEDICS GROUP PC, EZ ORTHO SUPPLY INC., FAIRPOINT

ACUPUNCTURE PC, FLORID LEISURE ACUPUNCTURE P.C.,

FRANK ZHAN BEST PHYSICAL THERAPY, P.C., GC

ACUPUNCTURE PC, GESHER PSYCHOLOGICAL SERVICES, P.C.,

GOOD LIFE ACUPUNCTURE, P.C., GOOD SPACE ACUPUNCTURE

P.C, HAZAQ PSYCHOLOGICAL SERVICES, P.C., HEALTH AND

COMFORT RX, INC, HEALTH EAST MED ALLIANCE, HMP

ORTHOPAEDICS, HUDSON REGIONAL HOSPITAL, IGOR

MAYZENBERG, LAC, JOHN LYONS MD, JOINT PHYSICAL

THERAPY P C, JOSEPH A RAIA MD PC, JSJ ANESTHESIA PAIN

MANAGEMENT PLLC, JULES F PARISIEN, KH LEE

ACUPUNCTURE P C, KINGS COUNTY HOSPITAL, LINWOOD WEST

MEDICAL, P.C., LONGEVITY MEDICAL SUPPLY, INC., LPM

PHARMACY INC LR MEDICAL PLLC, M&D ELITE PHARMACY

LLC, MACCABI PHARMACY RX INC, MALVINA DRUG CORP,,

LPM PHARMACY INC, MATTHEW HARLAN HOOVIS, MC

PHYSICAL THERAPY, PC, MEDICAL PLAZA, METRO PAIN

SPECIALISTS, PC, METROPOLITAN MEDICAL AND SURGICAL,



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P.C., MICHELE B. GLISPY, LAC., MIDWOOD METROPOLITAN

MEDICAL, P.C., MILL NECK CHIROPRACTIC, MIN PHYSICAL

THERAPY P.C., MOLNAR MEDICAL SERVICES PC, MOTION

MEDICAL DIAGNOSTICS, PC, MULTISPECIALTY HEALTH

GROUP, NEW CAPITAL 1 INC., NEW MILLENNIUM MEDICAL

IMAGING, P.C., NEW YORK CORE CHIROPRACTIC PC, NEW YORK

INJURY CHIROPRACTIC REHAB PC, NEW YORK THERA PT PC,

NEXRAY MEDICAL IMAGING PC, NOVA MEDICAL DIAGNOSTIC,

P.C., NY BEST SUPPLY, INC, NYC CARE CHIROPRACTIC P C., NYC

CARE PT, PC, NYWWQASC, LLC, OP ACUPUNCTURE, P.C.,

PERFORMANCE CHIRO, P.C., PONCE ACUPUNCTURE, P.C.,

PROTECHMED INC., QIXIA ACUPUNCTURE PC, RAF SPORTS

CHIROPRACTIC PC, RAINE M PESIDAS PHYSICAL THERAPY PC,

RANDALL ACUPUNCTURE P.C., REHAB TIME PT PC

REHABILITATION MEDICAL CENTER, RENAN MACIAS MD,

ROMEO MARIMAT PHYSICAL THERAPY, ROXBURY

ANESTHESIA, LLC RUN HONG LI, SABAS NY SERVICES INC, SAFE

ANESTHESIA AND PAIN, LLC, SCOB, LLC, SEAN L. THOMPSON,

SEDATION VACATION, PERIOP MED PLLC, SHAMAYIM

CHIROPRACTIC, P.C., SHASHEK CHIROPRACTIC PC, SKY

RADIOLOGY, SOLID ROK PHYSICAL THERAPY, P.C, SONIA

ARMENGOL, MD, SORREL ACUPUNCTURE P.C., ST. KYROLLOS

PHYSICAL THERAPY, P.C., STRAND PHARMACY D/B/A ASTORIA



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DRUGS, INC., STRUCTURAL SYNERGY PHYSICAL THERAPY, PC,

SURGERY CENTER OF ORADELL, SURGICORE OF JERSEY CITY,

LLC, TAI QI WELLNESS ACUPUNCTURE PC, TANUJ PALVIA, TIME

TO CARE MEDICAL, P.C., TIME TO CARE PHARMACY INC,

TOPLAB UNICAST INC, UNION DME, UNIVERSITY HOSPITAL OF

BROOKLYN, WELLNESS DIAGNOSTIC IMAGING, PC, and

YELLOWSTONE MEDICAL REHAB P.C. (collectively the “Provider

Defendants”) are healthcare goods and services providers who are assigned

rights to No-Fault benefits by the Staged Loss Defendants.

JURISDICTION, VENUE AND PARTIES

9. This Court has jurisdiction over the defendants because they reside in the State of

New York and the conduct which forms the basis for this declaratory judgment action took place

in the State of New York. Venue is proper in the County of Bronx pursuant to C.P.L.R. § 503(a)

inasmuch as at least one defendant resides in Bronx County.

10. At all times hereinafter mentioned the defendants PERMANENT GENERAL

ASSURANCE CORPORATION, PERMANENT GENERAL ASSURANCE CORPORATION

OF OHIO, and THE GENERAL AUTOMOBILE INSURANCE COMPANY, INC., were and are

insurance companies, organized and existing under the laws of the State of Tennessee and

authorized to conduct a general insurance business under the laws of the State of New York.

11. At all times hereinafter mentioned the defendant THE GENERAL AUTOMOBILE

INSURANCE SERVICES, INC., was and is a company, organized and existing under the laws of

the State of Tennessee and authorized to conduct business under the laws of the State of New York.

12. Upon information and belief, the Policy Defendants are natural persons who reside



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in the State of New York.

13. Upon information and belief, the Staged Accident Defendants are natural persons

who reside in the State of New York.

14. Upon information and belief, the Provider Defendants are either natural persons

who reside in the State of New York, or New York business entities with their principal places of

business in New York. All of the Provider Defendants transact business in the State of New York.

ALLEGATIONS COMMON TO ALL CAUSES OF ACTION

An Overview of The Scheme to Defraud The General

15. As more fully discussed below, the Policy Defendants and the Staged Loss

defendants herein have fraudulently procured automobile insurance policies from The General,

staged a series of phony automobile “accidents” and sought treatment from the Provider

Defendants for alleged “injuries” that they never sustained or that were sustained by intentional

acts. The Provider Defendants have then sought payments from The General pursuant to the Policy

Defendants’ automobile insurance policies.

16. This action seeks declaratory judgments and injunctive relief based on this scheme

to defraud The General by obtaining automobile insurance policies for the sole purpose of making

fraudulent claims to collect benefits under those policies.

17. Numerous claims were made against policies written by The General that are linked

to the Policy Defendants and have been determined to be intentional incidents not eligible for No-

Fault benefits due to fraud. Most of these purported “accidents” and the policies under which the

fraudulent claims were made share common variables including, but not limited to, the following:



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i) The garaging addresses listed for the Subject Policies are generally bogus

addresses in either Albany, New York, Elmira, New York or Potsdam, New

York;

ii) The Subject Policies that list Albany, New York, as the garaging address

were generally effective/issued around proximate dates;

iii) The Subject Policies that list Potsdam, New York, as the garaging address

were generally effective/issued around proximate dates;

iv) Despite the fact that the policy addresses are Albany and/or Potsdam, the

majority of the losses are in Kings and Queens Counties in New York City;

v) The social security numbers provided by the named insureds in applying for

the Subject Policies do not correspond to the particular named insured;

vi) In addition to the bogus social security numbers many of the Subject

Policies were procured using inaccurate underwriting information given at

the inception of the respective policies including but not limited to incorrect

dates of birth and false addresses and false contact telephone numbers and

bank account information;

vii) When calls are made to customer service the parties alleging to be the

policyholders are unable to answer the simple verification questions such as

confirming date of birth, policy address, zip code, etc.;

viii) Payments and policy changes are usually made/attempted by individuals

who are the cousin or boyfriend/girlfriend of the named insured and not the

named insureds themselves.



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ix) Perpetrators of the staged “accidents” seek treatment from a similar network

of medical providers;

x) Many of the staged “accidents” occur shortly after the inception of the

policies in question;

xi) Many of the staged “accidents” occur late at night;

xii) Many of the staged “accidents” occur at intersections

xiii) Many of the claims resulting from the incidents at issue would frequently

involve medically unnecessary services and testing by healthcare providers

with excessive and inflated costs. In many cases, no injury was reported on

the police accident report, nor was any treatment provided at the time of the

accident. Injuries were only reported later when treatment was sought, and

often, the first report of injuries and treatment was offered by the medical

provider;

xiv) In many of these claims, the purported “accident victims” failed to respond

to The General’s repeated requests for additional verification, including

requests that they appear for examinations under oath as required under the

insurance policies and No-Fault laws. When the insureds and claimants do

appear for their examinations under oath, there have been admissions that

the insured vehicles never were garaged in the upstate New York policy

address;

An Overview of the No-Fault Laws



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18. The State of New York requires that insurers provide No-Fault insurance benefits

to persons injured in automobile accidents pursuant to Article 51 of the Insurance Law. The

General underwrites automobile insurance in the State of New York.

19. New York's No-Fault laws are designed to ensure that injured victims of motor

vehicle accidents have an efficient mechanism to pay for and receive the medically necessary

healthcare services that they require. Under New York's Comprehensive Motor Vehicle Insurance

Reparations Act (N.Y. Ins. Law §§ 5101 et seq.) and the regulations promulgated pursuant thereto

(11 N.Y.C.R.R. §§ 65 et seq.) (collectively referred to herein as the "No-Fault laws"), automobile

insurers are required to provide Personal Injury Protection Benefits ("No-Fault benefits") to

insureds.

20. No-fault benefits include up to $50,000.00 per insured for necessary expenses

incurred for health care goods and services.

21. An insured can assign his or her right to No-Fault benefits to health care service

providers in exchange for those services. Pursuant to a duly executed assignment, a health care

provider may submit claims directly to an insurance company and receive payment for medically

necessary services provided, using the claim form required by the New York State Department of

Insurance (known as the "Verification of Treatment by Attending Physician or Other Provider of

Health Service," or, more commonly, as an "NF-3"). In the alternative, healthcare providers

sometimes submit claims using the Health Care Financing Administration insurance claim form

(known as the "HCFA-1500 Form").

22. Additionally, pursuant to Section 403 of the New York State Insurance Law, the

NF-3s and HCFA-1500 Forms submitted by healthcare providers to The General, and to all other

insurers, must be verified subject to the following warning:



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Any person who knowingly and with intent to defraud any insurance company or other person files an application for insurance or statement of claim containing any materially false information, or conceals for the purpose of misleading, information concerning any fact material thereto, commits a fraudulent insurance act, which is a crime.

23. The No-Fault laws obligate individuals and healthcare providers that seek payment

of No-Fault benefits to provide insurers with additional verification in order to establish proof of

their claims.

24. The prescribed No-Fault policy endorsement set forth in 11 N.Y.C.R.R. § 65-1.1

provides, in relevant part, that “upon request by the Company, the eligible injured person or that

person’s assignee . . . shall (b) as may reasonably be required, submit to an examination under oath

by any person named by the Company, and shall subscribe to same . . . , and (d) provide any other

pertinent information that may assist the Company in determining the amount that is payable.”

25. The prescribed No-Fault policy endorsement set forth in 11 N.Y.C.R.R. § 65-1.1

also states that “[n]o action shall lie against the Company, unless, as a condition precedent thereto,

there shall have been full compliance with the terms of this coverage.”

26. In addition, 11 N.Y.C.R.R. § 65-3.5 states, in pertinent part, that:

i) Subsequent to the receipt of one or more of the completed verification forms, any additional verification required by the insurer to establish proof of claim shall be requested within 15 business days of receipt of the prescribed verification forms. Any requests by an insurer for additional verification need not be made on any prescribed or particular form. . .

ii) The insurer is entitled to receive all items necessary to verify the claim directly from the parties from whom such verification was requested.

iii) All examinations under oath . . . requested by the insurer shall be held at a

place and time reasonably convenient to the applicant. . . . The insurer shall inform the applicant at the time the examination is scheduled that the applicant will be reimbursed for any loss of earnings and reasonable transportation expenses incurred in complying with the request. When an insurer requires an examination under oath of an applicant to establish proof



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of claim, such requirement must be based upon the application of objective standards so that there is specific objective justification supporting the use of such examination. . . .

27. An insurer may deny a claim using the form required by the New York State

Department of Insurance (known as the "Denial of Claim" form or, more commonly, as an "NF-

10").

28. Because an examination under oath is a condition of coverage, an insurer may deny

a healthcare provider’s or individual’s claim for No-Fault benefits if the healthcare provider or

individual claimant refuses to appear for an examination under oath.

29. Each of the Subject Policies, as more fully discussed below, provided coverage for

“accidents.” Deliberate, staged collisions caused in furtherance of insurance fraud schemes are

not covered “accidents” under the Subject Policies and do not, as a matter of law, trigger an

obligation by an insurer to afford coverage.

30. Pursuant to N.Y. Ins. Law § 2307(b), which prohibits insurers from issuing any

policy forms that have not been approved by the New York Insurance Superintendent, No-Fault

benefits must be provided using the endorsement form prescribed by 11 N.Y.C.R.R. § 65-1.1, and

automobile liability insurance policies are subject to the minimum requirements prescribed by 11

N.Y.C.R.R. § 60-1.1.

An Overview of the Pertinent Policy Provisions

31. As discussed above, The General is authorized to engage in the business of

insurance in the State of New York and has issued the Subject Policies for the claims set forth

herein. The policies include coverage for No-Fault insurance, as discussed above, in addition to

liability and uninsured motorist/underinsured motorist coverage, also known as “SUM” coverage

(“UM/UIM coverage”).



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32. Liability coverage generally refers to insurance coverage for damages which an

insured becomes legally obligated to pay because of bodily injury sustained by a person and

property damage arising out of the ownership, maintenance or use of the insured vehicle. This

coverage also includes the defense of any suit for damages payable under the terms of the policy.

33. UM/UIM coverage generally refers to insurance coverage for bodily injury and

property damage incurred by an insured when an accident arises out of an uninsured or

underinsured motor vehicle's ownership, maintenance or use.

34. Pursuant to the requirements described above, each of the Subject Policies contains

certain exclusions. The Subject Policies do not provide bodily injury liability coverage or property

damage liability coverage for bodily injury or property damage caused intentionally by or at the

direction of an insured.

35. Further, the Subject Policies and the No-Fault laws do not provide No-Fault

coverage for personal injury sustained by any person who intentionally causes his or her own

personal injury and/or for personal injury sustained by any person while committing an act which

would constitute a felony or seeking to avoid lawful apprehension or arrest by a law enforcement

officer.

36. The Subject Policies do not provide coverage to any person who knowingly

conceals or misrepresents any material fact or circumstance relating to the insurance coverage at

the time of application, at any time during the policy period; or in connection with the presentation

or settlement of a claim.

37. The Subject Policies require insureds or any other person seeking coverage under

the policies to submit to examination under oath by any person named by The General when and

as often as we may require.



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CLAIM # 1: INSURED – SANDY CABA-DURAN

(CLAIM # PA0002498172; POLICY # NY4592088)

38. On June 28, 2019, The General issued a motor vehicle insurance policy to defendant

Sandy Caba-Duran (hereinafter “Caba-Duran”).

39. This policy provides liability coverage for bodily injury and property damage

claims brought against covered persons, mandatory personal injury protection for eligible injured

persons and UM/UIM coverage as a result of an accident.

40. Caba-Duran made a claim to The General for liability and/or No-Fault benefits

arising out of an “accident” allegedly occurring on August 9, 2019. The “accident” allegedly

occurred shortly after the policy’s inception on June 28, 2019 in Brooklyn.

41. Defendant Mayerly Mejias (hereinafter “Mejias”) made additional claims under

said policy stemming from this same alleged “accident.”

42. For the treatment of injuries allegedly sustained as a result of this “accident,” Caba-

Duran and Mejias allegedly treated and/or received services from Provider defendants Ponce

Acupuncture, P.C., Dr. Offenbacher Medical Imaging, PLLC, Chiropractic Pain Solutions, P.C.,

Yellowstone Medical Rehab P.C., Motion Medical Diagnostics, PC, Big Apple Med Equipment

Inc and Kings County Hospital.

43. Thereafter, the above-referenced Provider Defendants submitted billing to The

General seeking to recover No-Fault benefits under the policy for the treatments they allegedly

provided to the claimants.

44. This claim fits the pattern of other claims involved in the overarching staged

accident scheme against The General.

45. At the time of the alleged “accident,” the policy had been recently issued.



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46. The staged “accident” allegedly occurred early in the morning at an intersection in

Brooklyn and there was no report of any injury at the scene of the loss.

47. This policy was also procured through fraud and/or material misrepresentation.

48. During the investigation it was revealed that the policyholder never lived at the

policy address of 41 Greenway Ter Middletown, NY 10941 but instead at all relevant times resided

at 1410 East New York Ave #1L Brooklyn, NY 11212 which was not disclosed on the policy

application.

49. The named insured and insured vehicle were involved on another loss with GEICO

on May 18, 2019. The named insured did not disclose this accident on the policy application.

50. Had the Policy Defendant disclosed her actual address and driving record, the

policy in question would never have issued. Knowledge by The General of the facts

misrepresented by the Policy Defendant would have led to a refusal by The General to make the

contract.

CLAIM # 2: INSURED – ERIQUE BERTRAND


51. The General issued a motor vehicle insurance policy to Policy Defendant Erique

Bertrand (hereinafter “Bertrand”).




53. Bertrand made a claim to The General for liability and/or No-Fault benefits arising

out of an “accident” allegedly occurring on April 8, 2019. The “accident” allegedly occurred

shortly after the policy’s inception on March 23, 2019, in Brooklyn.



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54. Defendants Steve Johnson and El Dorvile (hereinafter “Johnson” and “Dorvile,”

respectively) made or will make additional claims under said policy stemming from this same

alleged “accident.”

55. For the treatment of injuries allegedly sustained as a result of this “accident,”

Bertrand, Johnson and Dorvile allegedly treated and/or received services from Provider

Defendants Longevity Medical Supply, Inc., Health and Comfort Rx, Inc., Gesher Psychological

Services, P.C., New York Thera PT PC, Shamayim Chiropractic, P.C., Nova Medical Diagnostic,

P.C., Midwood Metropolitan Medical, P.C., OP Acupuncture, P.C., GC Acupuncture PC and

Ahmed Abdelaal PT, DPT.





accident scheme.


59. The staged “accident” allegedly occurred in the evening at an intersection and there

was no report of any injury at the scene of the loss.

60. Bertrand, Johnson and Dorvile all failed to appear for duly scheduled examinations

under oath.

61. The policy and claim in question has clear links to other policies and claims

involved in the scheme.

62. The email used to establish the policy is [email protected]. This email was

also used to establish policy NY4353445 which is linked to an alleged “accident” assigned claim



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number PA0002433105 that is also part of this ring and will be discussed in greater detail in the

subsection for Claim # 14 herein.

63. The phone number the insured supplied at policy inception, 845-504-7775, was also

supplied for the policy application for policy NY4345327 which is linked to an another alleged

“accident” assigned claim number PA0002430081 that is also part of this ring and will be

discussed in greater detail in the subsection for Claim # 11 below.

64. Bertrand also reported an accident on June 3, 2019, involving his vehicle which

was insured by GEICO at the time, where Gregory Remedor was the driver of Bertrand’s vehicle.

Gregory Remedor subsequently insured a vehicle through The General, policy number

NY4708353 effective as of September 25, 2019, and reported an “accident” on October 5, 2019

which was assigned claim number PA0002515202 that is also part of this ring and will be discussed

in greater detail in the subsection for Claim # 4 below. Gregory Remedor is a defendant in the

instant matter.

65. Bertrand was involved as the driver in a motor vehicle accident on August 27, 2019

which was referred to NICB for Faked/Exaggerated Injury, Staged/Caused Accident and

Organized Group/Ring Activity. The a passenger in the vehicle in that accident was Ayanna

Piquion. Ayanna Piquion is a defendant in the instant matter in a different motor vehicle accident

that is part of this ring and is discussed in greater detail in the subsection for Claim #10 herein

(The General claim number PA0002532548).



policy address of 162 Lark St Apt 1 Albany, NY 12210 but instead at all relevant times resided at

182 East 19th St Brooklyn, NY 11226 which was not disclosed on the policy application.



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68. Bertrand also has an has an extensive loss history including a prior referral to

National Insurance Crime Bureau (“NICB”) for a questionable claim. Bertrand did not disclose

all the details of his loss history on the policy application.

69. Had the Policy Defendant disclosed his actual address and driving record, the policy

in question would never have issued. Knowledge by The General of the facts misrepresented by

the Policy Defendant would have led to a refusal by The General to make the contract.

CLAIM # 3: INSURED – QUENCY NOEL


70. The General issued a motor vehicle insurance policy to Policy Defendant Quency

Noel (hereinafter “Noel”).




72. Noel made a claim to The General for liability and/or No-Fault benefits arising out

of an “accident” allegedly occurring on April 16, 2019. The “accident” allegedly occurred shortly

after the policy’s inception on April 4, 2019, in Brooklyn.

73. Defendants Ruslee Smartt and Junior Green (hereinafter “Smartt” and “Green,”



74. For the treatment of injuries allegedly sustained as a result of this “accident,” Noel,

Smartt and Green allegedly treated and/or received services from Provider Defendants Action

Chiropractic P.C., Acucare4u Acupuncture PLLC, Billy H. Ford, MD PC, Structural Synergy

Physical Therapy, PC, Tai Qi Wellness Acupuncture PC, Wellness Diagnostic Imaging, PC, MC



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Physical Therapy, PC, Roxbury Anesthesia, LLC, Surgicore of Jersey City, LLC, Randall

Acupuncture P.C., Tanuj Palvia, DNA Pharmacy Inc, LR Medical PLLC, and JSJ Anesthesia Pain

Management PLLC.





accident scheme.


78. The staged “accident” allegedly occurred in the evening at an intersection in


79. Noel and Green failed to appear for duly scheduled examinations under oath.

80. The policy and claim in question is clearly linked to other policies and claims


81. The same policy address used to establish the policy, 343 State St Albany, NY

12210, is the same address used to establish policy NY4353445 which is linked to an alleged

“accident” assigned claim number PA0002433105 that is also part of this ring and will be

discussed in greater detail in the subsection for Claim # 14 below.



policy address of 343 State St Albany, NY 12210 but instead at all relevant times resided at 3018

Cortelyou Rd Brooklyn, NY 11226 which was not disclosed on the policy application.



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CLAIM # 4: INSURED – GREGORY REMEDOR


85. The General issued a motor vehicle insurance policy to Policy Defendant Gregory

Remedor (hereinafter “Remedor”).




87. Remedor made a claim to The General for liability and/or No-Fault benefits arising

out of an “accident” allegedly occurring on October 5, 2019. The “accident” allegedly occurred

shortly after the policy’s inception on September 25, 2019, in Brooklyn.

88. Defendants Presume Viller and Joseph Barkley (hereinafter “Viller” and “Barkley,”




Remedor, Viller and Barkley allegedly treated and/or received services from Provider Defendants

Randall Acupuncture P.C., John Lyons MD, Action Chiropractic, P.C., Strand Pharmacy d/b/a

Astoria Drugs, Inc., Atlas Radiology, P.C., Performance Chiro, P.C., Cavallaro Medical Supply,

Altai Corp. DBA Get Ready Medical Supply and Health East Med Alliance.



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accident scheme.




94. The policy and claim in question have clear links to other policies and claims


95. The same policy address used to establish the policy, 27 Beech Rd Potsdam, NY

13676, is the same address used to establish policy NY4704308 which is linked to two (2 alleged

“accidents” assigned claim numbers PA0002520775 and PA0002520281 that are also part of this

ring and will be discussed in greater detail in the subsection for Claim # 7 below.

96. Remedor was also involved in an accident reported to have occurred on June 3,

2019, involving the same vehicle he claims was involved in the October 5, 2019 accident. At the

time the vehicle was insured by GEICO with Erique Bertrand as the policyholder. Erique Bertrand

is a defendant in this action and reported an “accident” on April 8, 2019 which was assigned claim

number PA0002452475 that is also part of this ring and which is discussed in greater detail in the


97. The email used to establish the instant policy, NY4708353, was

[email protected]. This is the email for Roody Vido who is a Staged Loss Defendant in this



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action that reported injuries from a different staged “accident” part of this ring. That claim, claim

number PA0002532548, is discussed in greater detail in the subsection for Claim # 10 herein.



policy address of 27 Beech Rd Potsdam, NY 13676 but instead at all relevant times resided at 4

Straut Ave Spring Valley, NY 10977 which was not disclosed on the policy application.




CLAIM # 5: INSURED – CLYFFORD MAURICE

(CLAIM # PA0002512383 & PA0002527344; POLICY # NY4686525)

101. The General issued a motor vehicle insurance policy to Policy Defendant Clyfford

Maurice (hereinafter “Maurice”).




103. A claim was reported to The General arising out of an “accident” allegedly

occurring on September 18, 2019. The “accident” allegedly occurred shortly after the policy’s

inception on September 9, 2019.

104. Another claim was reported to The General arising out of an “accident” allegedly

occurring on October 3, 2019. The “accident” allegedly occurred shortly after the policy’s




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105. Defendants Clyfford Maurice, Tonica Emmanuel, Kervens Leandre. James

Anderson and Jayden Julien (hereinafter collectively “claimants”) made or will make claims under

said policy stemming from these alleged “accidents.”

106. For the treatment of injuries allegedly sustained as a result of this “accident,” the

claimants allegedly treated and/or received services from Provider Defendants Randall

Acupuncture P.C., Romeo Marimat Physical Therapy, Tanuj Palvia, Performance Chiro, PC,

Action Chiropractic P.C., TopLab, RAF Sports Chiropractic PC, Health East Med Alliance, Dr. S.

Matrangolo, DC, Arista Physical Therapy PC, MC Physical Therapy PC, Igor Mayzenberg, L.Ac.,

Cavallaro Medical Supply, Renan Macias MD, Solid Rok Physical Therapy, P.C., and Sonia

Armengol, MD, Contemporary Othopedics, Protechmed Inc., and Altai Corp. DBA Get Ready

Medical Supply.




108. These claims fit the pattern of other claims involved in the overarching staged

accident scheme.

109. At the time of the alleged “accidents,” the policy had been recently issued.

110. The staged “accidents” allegedly occurred in the evening at an intersection and

there was no report of any injury at the scenes of the losses.



112. The policy address was also used to obtain policy number NY4628995. Policy

NY4628995 is tied to the IP address of 68.198.160.145. The IP address has been used to acquire



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13 other policies issued by The General (NY4310832, NY3990111, NY4127670, NY4310832,

NY4626656, NY4666044, NY4685694, NY4688347, NY4709222, NY4711429, NY4749857,

NY4751031 and NY4758580) in Albany, Binghamton, Potsdam, Poughkeepsie and Elmira.

113. The IP address was used to secure the policies in Claim #5, #8, #17, #21, #22, #23

and #24 in this action.

114. The email used to establish the policy is [email protected].

Numerous attempts for quotes for Potsdam addresses were made for Ricardo Mathurin.


116. The address used to establish the policy, 6 Elm St Ste 1 Potsdam, NY 13676 belongs

to Saint Larry’s Bar and Grill. There are no residential quarters at the address.


policy address of 6 Elm St Ste 1 Potsdam, NY 13676 but instead at all relevant times resided at

2657 Bedford Ave, Apt 2c, Brooklyn, NY 11210 which was not disclosed on the policy

application.

118. Maurice was also involved in an accident reported to have occurred on August 25,

2019 while insured with GEICO and provided an address of 19 Chenango St Binghamton, NY

13090. This address is a mail drop only used in similar schemes as the one discussed herein. This

loss occurred within 13 days of the inception of the GEICO policy.




CLAIM # 6: INSURED – TYREIK WILLIAMSON

(CLAIM # PA0002516118 & PA0002509206; POLICY #NY4676352)



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120. The General issued a motor vehicle insurance policy to Policy Defendant Tyreik

Williamson (hereinafter “Williamson”).






inception on August 31, 2019.


occurring on September 11,2019. The “accident” allegedly also occurred shortly after the policy’s

inception on August 31 2019.

124. Defendants Tyreik Williamson, Tarek Beckles, Shala Uddin and Lawan Reese

(hereinafter collectively “claimants”) made or will make claims under said policy stemming from

these alleged “accidents.”


claimants allegedly treated and/or received services from Provider Defendants Randall

Acupuncture P.C., Romeo Marimat Physical Therapy, Tanuj Palvia, Action Chiropractic P.C.,

Solid Rok Physical Therapy, P.C., John Lyons MD, NYWWQASC, LLC and Unicast INC





accident scheme.



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129. The staged “accidents” allegedly occurred in the evening at an intersection and

while merging.



policy address of 27 Lawrence Ave Potsdam, NY 13676 but instead at all relevant times resided

at 1704 Saint Johns Brooklyn, NY 11233 which was not disclosed on the policy application.




CLAIM # 7: INSURED – FLIGHTDENICA PERARD

(CLAIM # PA0002520775 & PA0002520281; POLICY # NY4704308)

133. The General issued a motor vehicle insurance policy to Policy Defendant

Flightdenica Perard (hereinafter “Perard”).












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137. Defendants Flightdenica Perard, Raymond Coletti, Joseph Williams, Darryn

Riddick and Milton Marshall (hereinafter collectively “claimants”) made or will make claims

under said policy stemming from these alleged “accidents.”


claimants allegedly treated and/or received services from Provider Defendants Brooklyn

McDonald Medical Care, PLLC, Access Care PT, P.C., Run Hong Li, ARD RX INC,

Contemporary Diagnostic Imaging, Hudson Regional Hospital, New Capital 1 Inc., and

Englewood Orthopedics Group PC.





accident scheme.


142. The staged “accident” assigned claim number Claim PA0002520281 allegedly

occurred in the evening and both losses are merging/turn losses with no report of any injury at the

scenes of the losses.



144. The same policy address used to establish the policy, 27 Beech Rd Potsdam, NY

13676, is the same address used to establish policy NY4708353 is linked to an alleged “accident”

assigned claim number PA0002515202 that is also part of this ring and will be discussed in greater

detail in the subsection for Claim # 4 above.



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146. The address used to establish the policy, 27 Beech Rd Potsdam, NY 13676 was

vacant and listed for sale at the time of policy inception. The named insured is not known to the

owner of the address.


policy address of 27 Beech Rd Potsdam, NY 13676 but instead at all relevant times resided at 5108

Avenue I Brooklyn, NY 11226 which was not disclosed on the policy application.

148. The named insured’s husband contacted The General and advised that his wife only

has her learner’s permit and did not take out a policy.

149. An altered proof of garaging was submitted to The General underwriting. A bill

from Xfinity was submitted with the alleged policy address, however Xfinity confirmed that the

listed account number was not valid.




CLAIM # 8: INSURED – FARAH FELIX


151. The General issued a motor vehicle insurance policy to Policy Defendant Farah

Felix (hereinafter “Felix”).






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154. Defendants Cheyenne Vazquez, Moses Fall and Orelien Huggins (hereinafter

collectively “claimants”) made or will make claims under said policy stemming from this alleged

“accident.”


claimants allegedly treated and/or received services from Provider Defendants Joseph A Raia MD

PC, Midwood Metropolitan Medical, PC, Shamayim Chiropractic, P.C., GC Acupuncture PC,

Longevity Medical Supply, Inc., Rehab Time PT PC, Delphi Chiropractic PC, Class Point

Acupuncture, PLLC, M&D Elite Pharmacy LLC, Health and Comfort Rx, INC, CMA Psychology,

P.C., Ahmed Abdelaal PT, DPT, Metropolitan Medical and Surgical, P.C., New Millennium

Medical Imaging, P.C., Time to Care Pharmacy INC, John Lyons MD, Hazaq Psychological

Services, P.C., SCOB, LLC, and Aron Rovner MD, PLLC.





accident scheme.


159. The staged “accident” allegedly occurred in the evening while the vehicle adverse

to the insured vehicle was making a turn and struck at a high rate of speed by the insured driver in

Brooklyn.



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161. The policy address was also used to obtain policy number NY4628995. Policy

NY4628995 is tied to the IP address of 68.198.160.145. The IP address has been used to acquire

13 policies (NY4310832, NY3990111, NY4127670, NY4310832, NY4626656, NY4666044,

NY4685694, NY4688347, NY4709222, NY4711429, NY4749857, NY4751031 and NY4758580)

in Albany, Binghamton, Potsdam, Poughkeepsie and Elmira.



163. Defendant Cheyenne Vazquez, the driver in this loss, is the policyholder for policy

number NY4758580 which was issued online with the applicant using the IP address of

68.198.160.145. The vehicle insured under policy NY4758580 has an Elmira, New York, garaging

address. Defendant Cheyenne Vazquez submitted a PIP application with a Brooklyn address.

164. Defendant Orelien Huggins has an extensive claims history including three (3)

losses flagged for involvement in ring activity. He was involved in a loss with State Farm on

October 17, 2018 for a policy which was rated for 409 Madison Ave Albany, NY 12210.

165. Another involved party in this loss was defendant Oneil Pierreisant. Oniel

Pierreisant was involved in claim PA0002370845 which is also part of this ring and will be

discussed in greater detail herein in the subsection for Claim #12.

166. Defendant Moses Fall was involved in a claim on December 12, 2018 with

Progressive which was flagged for application fraud, staged/caused loss and ring activity. The

policy address for that policy was 63 Oakwood St Albany, NY 12208. He also was involved in a



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loss with State Farm on October 20, 2018. The loss was flagged as the policy address for that

policy was a mail drop.

167. Claim number PA0002430881 under policy number NY4345327, which is also part

of this ring and is discussed in greater detail herein in the subsection for Claim #11, was denied

for fraud in the procurement as it was determined the garaging address was vacant at the time of

policy inception. The email address associated to that policy is [email protected],

defendant Moses Fall’s email address.



policy address of 45 Main St Potsdam, NY 13676 but instead at all relevant times resided at 3325

Neptune Avenue Brooklyn, NY 11224 which was not disclosed on the policy application.

170. The owner of the policy address has confirmed the named insured does not reside

at the policy address.

171. The policy address was also used to establish a policy for Moleron Nivose on

September 27, 2019.




contract.

CLAIM # 9: INSURED – NASIA GASPARD


173. The General issued a motor vehicle insurance policy to Policy Defendant Nasia

Gaspard (hereinafter “Gaspard”).



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occurring on November 23, 2019.

176. Defendants Lemaitre Videau, Evenson Souverain and Nadege Candio (hereinafter


“accident.”


claimants allegedly treated and/or received services from Provider Defendants Jules F. Parisien,

Diana Beynin, DC, Metro Pain Specialists PC, Raine M Pesidas Physical Therapy PC, Qixia

Acupuncture PC., Comprehensive Psychological PC, and EZ Ortho Supply Inc.

178. Thereafter, the above-referenced Provider Defendant submitted billing to The

General seeking to recover No-Fault benefits under the policy for the treatments allegedly provided

to the claimants.

179. This claim fit the pattern of other claims involved in the overarching staged accident

scheme.

180. The staged “accident” allegedly occurred in the evening while the vehicle adverse

to the insured vehicle was making a turn in Brooklyn.



182. The policyholder, defendant Gaspard has an extensive claims history of eight

separate claims since 2013 including one loss referred to the NICB as a caused/staged loss.



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183. Defendant Lemaitre Gaspard has a previous loss on May 8, 2010 referred to NICB

for application misrepresentation and organized group/ring activity.



policy address of 68 Miller Rd Potsdam, NY 13676.

186. The policy address was listed for sale on August 19, 2019 and the policy was

incepted on September 10, 2019.




contract.

CLAIM # 10: INSURED – AYANNA PIQUION


188. The General issued a motor vehicle insurance policy to Policy Defendant Ayanna

Piquion (hereinafter “Piquion”).




190. Piquion made a claim to The General for liability and/or No-Fault benefits arising

out of an “accident” allegedly occurring on November 23, 2019. The “accident” allegedly

occurred shortly after the policy’s inception on November 11, 2019, in Queens.



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191. Defendants Roody Vido and Mark Chery (hereinafter “Vido” and “Chery,”




Piquion, Vido and Chery allegedly treated and/or received services from Provider Defendant Mill

Neck Chiropractic, Ahmed Abdelaal PT, DPT, Health and Comfort Rx, Inc, Shamayim

Chiropractic, PC, and GC Acupuncture PC, City Wide Health Facility Inc, Midwood Metropolitan

Medical P.C., Maccabi Pharmacy RX Inc. Hazaq Psychological Services, P.C., and Longevity

Medical Supply, Inc.



to the claimants.


accident scheme.


196. The staged “accident” allegedly occurred in the evening as one of the vehicles was

turning.



198. The policyholder, defendant Piquion was involved in a motor vehicle accident on

August 27, 2019 which was referred to NICB for Faked/Exaggerated Injury, Staged/Caused

Accident and Organized Group/Ring Activity. The driver of the vehicle in that accident was

Enrique Bertrand. Enrique Bertrand is a defendant in the instant matter as a part of this ring and



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is discussed in greater detail in the subsection for Claim # 2 herein (The General claim number

PA0002452475).

199. Staged Loss Defendant Roody Vido is also linked to another staged “accident” in

the ring. The email used to establish policy NY4708353 was Vido’s email,

[email protected]. That policy is linked to an alleged “accident” assigned claim number

PA0002515202 that is also part of this ring and is discussed in greater detail in the subsection for

Claim # 4 herein.



policy address of 8 Lawrence Ave Apt 1 Potsdam, NY 13676.

202. When the policy was obtained online, the applicant misspelled the policyholder’s

first name. It was obtained under the name “Ayana” rather than “Ayanna.” Further this policy

was obtained via IP address 172.58.230.154 which is affiliated to the Bronx.




contract.

CLAIM # 11: INSURED – KINET DATILIEN


204. The General issued a motor vehicle insurance policy to Policy Defendant Kinet

Datilien (hereinafter “Datilien”).



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occurring on February 5, 2019. The “accident” allegedly occurred shortly after the policy’s

inception on January 22, 2019.

207. Policy Defendant Datilien and Staged Loss Defendants, Elirus Walthust and Jean-

Samson Zamor (hereinafter collectively “claimants”), made or will make claims under said policy

stemming from this alleged “accident.”


claimants allegedly treated and/or received services from Provider Defendants

Molnar Medical Services PC, Malvina Drug Corp, LPM Pharmacy INC, Joint Physical Therapy P

C, Atlas Pharmacy LLC, Nexray Medical Imaging PC, KH Lee Acupuncture P C, Sabas NY

Services Inc, and NYC Care Chiropractic P C.





accident scheme.


212. The staged “accident” allegedly occurred in the evening in an intersection with no

report of any injury at the scene of the alleged “accident.”



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214. The email address for this policy is [email protected], defendant Moses

Fall’s email address. Moses Fall is a Staged Loss Defendant in the instant matter and is a claimant

as a result of a separate staged “accident” in this ring which is discussed in greater detail herein in

the subsection for Claim # 8.

215. The policyholder, defendant Datilien was involved in a motor vehicle accident on

July 12, 2017 in Brooklyn which was referred to NICB.



policy address of 933 US Route 11, Apt S6, Kirkwood, NY 23795 but instead at all relevant times

resided at 520 East 34th St Brooklyn, NY 11203which was not disclosed on the policy application.

218. Had the Policy Defendant disclosed their actual address and driving record, the



contract.

CLAIM # 12: INSURED – RASHEKA BRYAN


219. The General issued a motor vehicle insurance policy to Policy Defendant Rasheka

Bryan (hereinafter “Bryan”).






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occurring on August 27, 2018. The “accident” allegedly occurred shortly after the policy’s

inception on July 26, 2018.

222. Defendants O’niel Perrissaint, Betina Lafortune, Laura Celestin and Joseph Robert


this alleged “accident.”


claimants allegedly treated and/or received services from Provider Defendants Sedation Vacation

Periop Med PLLC, MICHELE B. GLISPY, LAc., Hmp Orthopaedics, Axial Chiropractic, PC, All

City Family Healthcare and Surgicore of Jersey City, LLC.





accident scheme.


227. The staged “accident” allegedly occurred in the evening at an intersection with no

reports of injuries at the scene of the alleged “accident.”



229. O’niel Perrissaint, the reported driver and a claimant in this staged “accident” is an

involved party in claim PA0002518572 which is also part of this ring and is discussed in greater

detail herein in the subsection for Claim # 8.



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230. O’niel Perrissaint admitted that he was not in fact involved in this claim. He stated

that his identity was stolen because he lost his driver’s license in June 2018.

231. This policy’s email address, [email protected], is also the listed email address

for policy NY4030331. That policy and associated claim, PA0002354458, is part of this ring and

is discussed in greater detail herein in the subsection for Claim # 18.

232. The policyholder, defendant Bryan was involved in two prior reported losses

referred to NICB for fraud ring association.

233. Staged Loss Defendant Lafortune has 1 prior loss also reported to NICB for an

intersection collision as a staged loss, organized fraud and lack of cooperation from the insured.



policy address of 761 Madison Ave Albany, NY 12208 but instead at all relevant times resided at

27 Lloyd St, Brooklyn, NY 11226 which was not disclosed on the policy application.




contract.

CLAIM # 13: INSURED – LORENZO DERBERRY


237. The General issued a motor vehicle insurance policy to Policy Defendant Lorenzo

Derberry (hereinafter “Derberry”).



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occurring on November 27, 2018. The “accident” allegedly occurred shortly after the policy’s

inception on October 23, 2018.

240. Defendants Mieshawn Moore, Duane Boucher and James Coleman (hereinafter


“accident.”


claimants allegedly treated and/or received services from Provider Defendants Axial Chiropractic,

PC, Florida Leisure Acupuncture P.C., New York Core Chiropractic PC, NY Best Supply, Inc.,

and Dos Manos Chiropractic PC.





accident scheme.


245. The staged “accident” allegedly occurred in the evening at an intersection and there

was no report of any injury at the scene of the loss.





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247. The email used to establish the policy, [email protected], was used

to establish five (5) policies written by The General linked to the claims in this action: NY4225142,

NY4263843, NY4049448, NY4081513, NY4312078.

248. While contacting customer service, the caller was initially unable to verify phone

number on policy and refused to provide last 4 of SSN to verify identity.

249. Per public records query, the correct spelling of the insured’s last name is

“Deberry,” but the policy was taken out with the last name spelled as “Derberry.”

250. Defendant Mieshawn Moore has 3 prior losses and a loss reported to GEICO for a

September 18, 2018 date of loss was reported to NICB for excessive treatment, exaggerated injury,

staged accident, medical provider/attorney relationship. Additionally billing for similar

acupuncture and chiropractor treatments as other parties previously listed in this investigation were

submitted.

251. Defendant James Coleman is associated with nine (9) prior losses reported to NICB

with application misrepresentation, fictitious loss, organized ring, premium avoidance, excessive

treatment, exaggerated injury, staged accident, medical provider/attorney relationship, billing for

services not rendered.



policy address of 48 Dove St Albany, NY 12210 but instead at all relevant times resided at 204

Cozine Ave, Brooklyn, NY 11207 which was not disclosed on the policy application. In fact, upon

information and belief, the policy address was vacant at the time of policy inception.



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CLAIM # 14: INSURED – SADE LONG


255. The General issued a motor vehicle insurance policy to Policy Defendant Sade

Long (hereinafter “Long”).




257. Long made a claim to The General for liability and/or No-Fault benefits arising out

of an “accident” allegedly occurring on February 16, 2019. The “accident” allegedly occurred

shortly after the policy’s inception on January 28, 2019.

258. Defendants Shakeim Peters and Anasia Destiny Smith (hereinafter “Peters” and

“Smith,” respectively) made or will make additional claims under said policy stemming from this

same alleged “accident.”

259. For the treatment of injuries allegedly sustained as a result of this “accident,” Long,

Peters and Smith allegedly treated and/or received services from Provider Defendants Sky

Radiology, Good Life Acupuncture, P.C., NYC Care PT, PC, and University Hospital of Brooklyn.






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accident scheme.


263. The staged “accident” allegedly occurred in the evening as a sideswipe, turning

accident and there was no report of any injury at the scene of the loss.

264. Long failed to appear for duly scheduled examinations under oath.



266. The garaging address used to establish this policy is 343 State St Albany, NY

12210. This address was also used to establish The General policy number NY4481552 which is

linked to an alleged “accident” assigned claim number PA0002453148 that is also part of this ring

and will be discussed in greater detail in the subsection for Claim # 3 herein.

267. The email used to establish the policy is [email protected]. This email was

also used to establish policy NY4462352 which is linked to an alleged “accident” assigned claim

number PA0002452475 that is also part of this ring and will be discussed in greater detail in the




policy address of 343 State St Albany, NY 12210 but instead at all relevant times resided at 22-51

Dix Ave Far Rockaway, NY 11691 which was not disclosed on the policy application.






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CLAIM # 15: INSURED – BARBARA ALTIME


271. The General issued a motor vehicle insurance policy to Policy Defendant Barbara

Altime (hereinafter “Altime”).




273. Altime made a claim to The General for liability and/or No-Fault benefits arising

out of an “accident” allegedly occurring on April 29, 2018. The “accident” allegedly occurred

shortly after the policy’s inception on April 25, 2018.

274. Defendants Marceline Jules, Marie Altime and Leonie Trench (collectively, with

Barbara Altime, hereinafter “claimants”) made or will make additional claims under said policy

stemming from this same alleged “accident.”


claimants allegedly treated and/or received services from Provider Defendants Danimark Physical

Therapy PC, Metro Pain Specialists, PC, Shashek Chiropractic PC, City Wide Health Facility, Inc,

Burke Physical Therapy PC, and East 19 Medical Supply Corp.



to the claimants.


scheme.

278. The staged “accident” allegedly occurred in the evening in an intersection.



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280. The policyholder, Altime and Staged Loss Defendant Leonie Trench have a prior

claim from July 11, 2017 that was referred to SIU, flagged as a mail drop and attached to numerous

NICB ForeWarn Notices.



policy address of 13 Dana Ave Albany, NY 12208. Instead she lived at 284 Fountain Ave 2R

Brooklyn, NY 11208 at all relevant time periods. This was confirmed by Altime at her EUO.




contract.

CLAIM # 16: INSURED – MARIE SYLVERT


284. The General issued a motor vehicle insurance policy to Policy Defendant Marie

Sylvert.




286. Sylvert made a claim to The General for liability and/or No-Fault benefits arising

out of an “accident” allegedly occurring on November 5, 2018. The “accident” allegedly occurred

shortly after the policy’s inception on October 23, 2018.



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287. Defendants Marie Sylvert, Francesca Sylvert and Billy Smith (hereinafter

collectively “claimants”) made or will make additional claims under said policy stemming from

this same alleged “accident.”


claimants allegedly treated and/or received services from Provider Defendants Protechmed, INC,

Surgery Center of Oradell, Safe Anesthesia and Pain, LLC, Sean L. Thompson, Axial Chiropractic,

PC, Surgicore of Jersey City, LLC, Union DME and Sorrel Acupuncture P.C.





accident scheme.


292. The staged “accident” allegedly occurred in the evening at an intersection.



294. The garaging address used to establish this policy is 133 Jay St Albany, NY 12210.

This address was also used to establish The General policy number NY4302055 which is a policy

linked to another alleged “accident” that is also part of this ring and will be discussed in greater

detail in the subsection for Claim # 17 herein.

295. Marie Sylvert also reported an accident from February 5, 2019 that was flagged for

being a mail drop and attached to several NICB ForeWarn notices. The driver involved in that



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loss is John Francois, a defendant in this matter who was also the driver under claim

PA0002375695 which is part of the instant action discussed further for Claim #17.

296. Marie Sylvert and Francesca Sylvert also have a loss from June 8, 2014 flagged for

30-day Pre/Post Policy Inception/Cancellation.

297. Francesca Sylvert has an additional loss on December 15, 2018 that was referred to

SIU and tied to NICB ForeWarns. For that policy, she provided an address of 506 Madison Ave

Albany, NY 12208.



policy address of 133 Jay St Albany, NY 12210 but instead at all relevant times resided at 2416

Newkirk Ave Apt 1F Brooklyn, NY 11226 which was not disclosed on the policy application.

300. Had the Policy Defendant disclosed his actual address, loss history and driving

record, the policy in question would never have issued. Knowledge by The General of the facts


contract.

CLAIM # 17: INSURED – JOHN FRANCOIS


301. The General issued a motor vehicle insurance policy to Policy Defendant John

Francois.






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occurring on September 4, 2018. The “accident” allegedly occurred shortly after the policy’s

inception on August 17, 2018.

304. Defendants Shaylia Walton, Emiya Toledo, Reggie Rob and Dejane Vera


this alleged “accident.”





claimants allegedly treated and/or received services from no-fault medical providers.


accident scheme.


309. The staged “accident” allegedly occurred in the evening at an intersection.



311. This policy was obtained online through the IP address of 68.198.160.145. This IP

address was also used to secure the policies in Claim #5, #8, #21, #22, #23 and #24 in this action.

The IP address has been used to acquire 13 policies (NY4310832, NY3990111, NY4127670,

NY4310832, NY4626656, NY4666044, NY4685694, NY4688347, NY4709222, NY4711429,

NY4749857, NY4751031 and NY4758580) in Albany, Binghamton, Potsdam, Poughkeepsie and

Elmira.



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312. The email used to establish the policy is [email protected]. This email

was also used to establish policy number NY4302055 issued by The General.

313. Defendant John Francois has 3 additional losses, 2 of which were referred to SIU.

One loss, reported to have occurred on February 5, 2019, involved a vehicle insured by defendant

Marie Sylvert who is linked to an alleged “accident” assigned claim number that is also part of this

ring is discussed in greater detail in the subsection for Claim # 16 above.

314. Defendant Shaylia Walton has 2 additional losses. One of these losses, allegedly

occurring on June 1, 2018 involved a claimant named Keith Dumont. Dumont is involved in

another claim against The General, claim number PA0002424676, from January 22, 2019.



policy address of 1067 Madison Ave Apt 1 Albany, NY 12208 but instead at all relevant times

resided at 3324 Clarendon Rd Brooklyn. NY 11203which was not disclosed on the policy

application.




contract.

CLAIM # 18: INSURED – RUYSS ST FLEURANT


318. The General issued a motor vehicle insurance policy to Policy Defendant Ruyss St

Fleurant (hereinafter “St Fleurant”).



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occurring on July 11, 2018. The “accident” allegedly occurred shortly after the policy’s inception

on June 8, 2018.

321. Defendants Pierrie Metivier, Marie Jean and Marco Oreillus (hereinafter

collectively “claimants”) made or will make claims under said policy stemming from these alleged

“accidents.”


claimants allegedly treated and/or received services from Provider Defendant Andrew J Dowd

MD.





scheme.


326. The staged “accidents” allegedly occurred in the evening in Brooklyn.


involved in the scheme and was also procured through fraud and/or material misrepresentation.

328. The contact phone number provided at policy inception, 845-200-4797, was also

provided to obtain policy NY4049448. As set forth above, the email used to establish that policy,



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[email protected], was used to establish five (5) other policies written by The

General linked to claims in this action: NY4225142, NY4263843, NY4049448, NY4081513,

NY4312078.

329. This policy’s email address, [email protected], is also the listed email address

for policy NY4093099. That policy and associated claim, PA0002370845, is part of this ring and

is discussed in greater detail herein in the subsection for Claim # 12.

CLAIM # 19: INSURED – SACHA DESRAVINES


330. The General issued a motor vehicle insurance policy to Policy Defendant Sacha

Desravines (“Desravines”).





occurring on November 20, 2019. The “accident” allegedly occurred shortly after the policy’s

inception on November 8, 2019.

333. Defendants Desravines, Randy Honora and Peter Jackson (hereinafter collectively

“claimants”) made or will make claims under said policy stemming from this alleged “accident.”





claimants allegedly treated and/or received services from Provider Defendants Fairpoint



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Acupuncture PC, Medical Plaza, Midwood Metropolitan Medical P.C., Ahmed Abdelaal PT, DPT,

Delphi Chiropractic PC, Joseph A Raia MD PC, Class Point Acupuncture, PLLC, Rehab Time PT

PC, Time to Care Pharmacy Inc, Shamayim Chiropractic, PC, GC Acupuncture PC, Midwood

Metropolitan Medical PC, New Millennium Medical Imaging, P.C., Longevity Medical Supply,

Inc., and Health and Comfort Rx, Inc


accident scheme.



Brooklyn and there was no report of any injury at the scenes of the losses. Additionally the

passengers were not listed on the police report.



340. This policy was obtained online through the IP address of 172.58.227.50. This IP

address was also used to secure The General policy number NY4768338. The policy address given

in for that policy was 719 Southport Street, Elmira, NY 14904. That property was listed for sale

on October 29, 2019 and the policy was incepted on November 7, 2019.

341. Defendants Desravines and Randy Honora have extensive claim histories.

342. Desravines was involved in a loss on November 9, 2018 that was referred to NICB

for faked/exaggerated injury, staged/caused accident and organized group/ring activity.

343. Defendant Randy Honora was involved in a loss on July 6, 2014 which was referred

to NICB for staged/caused accident and organized group/ring activity. Also occupying the vehicle

in that accident was Orelien Huggins, another Staged Loss Defendant in this matter who made



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claims to The General following the staged accident assigned claim number PA0002518572 which

is discussed in Claim #8 herein.



policy address of 1200 Charles St Elmira, NY 14904 but instead at all relevant times resided at

2104 Foster Ave Brooklyn, NY 11210 which was not disclosed on the policy application. In fact,

the policy address was listed for sale on November 6, 2019 and the inception date of the policy

was November 8, 2019.

346. The policy address of 1200 Charles St Elmira, NY 14904 was also used to purchase

a different policy for a different vehicle on November 9, 2019.




contract.

CLAIM # 20: INSURED – STEEVE GUILLAUME


348. The General issued a motor vehicle insurance policy to Policy Defendant Steeve

Guillaume (“Guillaume”).






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occurring on December 1, 2019. The “accident” allegedly occurred shortly after the policy’s


351. Defendants Guillaume, Guy Jean-Michel and Serge Castor (hereinafter collectively






claimants allegedly treated and/or received services from Provider Defendants Time to Care

Medical, P.C., Midwood Metropolitan Medical P.C., Linwood West Medical, P.C., Ahmed

Abdelaal PT, DPT, Jules F Parisien, Health and Comfort Rx, Inc, Frank Zhan Best Physical

Therapy, P.C., Good Space Acupuncture P.C., 5 Borough Anesthesia, PLLC, Averroes Physical

Therapy PC, Shamayim Chiropractic, PC, New York Injury Chiropractic Rehab PC, Dr. Watson

Chiropractic, PC, Florid Leisure Acupuncture P.C., Chi Lee Acupuncture PC, Longevity Medical

Supply, Inc, GC Acupuncture PC, CorrectAlign Chiropractic PC, and Custom Rx Pharmacy.


accident scheme.


356. The staged “accident” allegedly occurred in the evening with the claimant making

a U-turn in Queens.





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358. Defendant Guillaume has 2 prior losses. An accident occurring on November 16,

2017 was referred to NICB for suspicion of being a staged/caused loss.

359. The named insured’s name is spelled as “Steeve Guillaumet” on the policy

application. It appears that he did not obtain the policy.



policy address of 1518 Cedar St Elmira, NY 14904 but instead at all relevant times resided at 326

East 29 St Brooklyn, NY 11226 which was not disclosed on the policy application. In fact, the

policy address was listed for sale on November 11, 2019 and the inception date of this policy was

November 13, 2019 when the residence at the policy address was vacant.

362. The policy address of 1200 Charles St Elmira, NY 14904 was also used to purchase

a different policy for a different vehicle on November 9, 2019.




contract.

CLAIM # 21: INSURED – CAMILLE DEROSE


364. The General issued a motor vehicle insurance policy to Policy Defendant Camille

Derose.






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occurring on November 20, 2019.

367. Defendants Farah Felix, Mikerson Eliassaint, James Eliassaint (hereinafter


“accident.”


claimants allegedly treated and/or received services from Provider Defendants Jules F Parisien,

Joseph A Raia MD PC, Florid Leisure Acupuncture P.C., Renan Macias MD, and Min Physical

Therapy P.C.





accident scheme.


372. The staged “accident” allegedly occurred in the evening in an intersection in

Brooklyn.



374. The driver Farah Felix also has a policy, NY470922, written by The General. The

policy address on that policy is 45 Main St Potsdam, NY 13676. Felix’s policy is linked to an

alleged “accident” assigned claim number PA0002518572 that is also part of this ring and will be

discussed in greater detail in the subsection for Claim #8 above.



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375. Camille Derose obtained a quote using the IP Address 68.198.160.145. That IP

address has been used to acquire 13 policies (NY4310832, NY3990111, NY4127670,

NY4310832, NY4626656, NY4666044, NY4685694, NY4688347, NY4709222, NY4711429,

NY4749857, NY4751031 and NY4758580) in Albany, Binghamton, Potsdam, Poughkeepsie and

Elmira.



377. The policy address, 6 Elm St Ste 1 Potsdam, NY 13676, was also used to obtain

policy number NY4686525. Claim numbers PA0002512383 and PA0002527344 are also part of

this ring and are discussed in greater detail herein in the subsection for Claim #5.

378. Defendant Mikerson Eliassaint has 5 prior losses. A claim from March 20, 2019

was referred to NICB for Application Misrepresentation, Organized Group/Ring Activity and

Premium Avoidance.


380. The address used to establish the policy, 6 Elm St Ste 1 Potsdam, NY 13676 belongs

to Saint Larry’s Bar and Grill. There are no residential quarters at the address.


policy address of 6 Elm St Ste 1 Potsdam, NY 13676 but instead at all relevant times resided at

405 E 16st Brooklyn, NY 11226 which was not disclosed on the policy application.




contract.



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CLAIM # 22: INSURED – DAVID BROWN


383. The General issued a motor vehicle insurance policy to Policy Defendant David

Brown.







386. Defendants David Brown, Dana White and Taiheen Shuler (hereinafter collectively




Joseph A Raia MD PC, Florid Leisure Acupuncture P.C., Renan Macias MD, and Min Physical

Therapy P.C.





accident scheme.




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Brooklyn.



393. The policy was obtained using the IP Address 68.198.160.145. That IP address has

been used to acquire 13 policies (NY4310832, NY3990111, NY4127670, NY4310832,

NY4626656, NY4666044, NY4685694, NY4688347, NY4709222, NY4711429, NY4749857,




395. The social security number supplied by defendant David Brown on the policy

application is the same one Kervens Leandre (claim PA0002512383) supplied on his PIP

application. Kervens Leandre is a defendant in this matter and claim number PA0002512383 is

also part of this ring and are discussed in greater detail herein in the subsection for Claim #5.



policy address of 328 Mackey Pl Elmira, NY 14904 but instead at all relevant times resided at 198

Putnam Ave Brooklyn, NY 11216 which was not disclosed on the policy application. In fact, the

policy address was listed for sale on November 17, 2019 and the inception date of this policy was

November 23, 2019 and the owner of the property confirmed that David Brown has never been

affiliated with the property.



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CLAIM # 23: INSURED – CHEYENNE VAZQUEZ


399. The General issued a motor vehicle insurance policy to Policy Cheyenne Vazquez.







402. Defendants Megan Mattis, Shazi Marav, James Clarke, Jean Dregen (hereinafter


“accident.”



Rehabilitation Medical Center, St. Kyrollos Physical Therapy, P.C., and Matthew Harlan Hoovis.





accident scheme.



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407. The staged “accident” allegedly occurred in the evening with dash cam footage

showing the impact was a low speed collision in Brooklyn.



409. The policy was obtained via the IP address of 68.198.160.145. The IP address has


NY4626656, NY4666044, NY4685694, NY4688347, NY4709222, NY4711429, NY4749857,




411. Defendant Cheyenne Vazquez, the policyholder in this loss, was involved in a loss

under claim number PA0002518572 which is also part of this ring and is discussed in greater detail

herein in the subsection for Claim #8.



policy address of 602 Howard St Elmira, NY 14904 and her true Brooklyn address was not

disclosed on the policy application.

414. In fact, the policy address was listed for sale on October 31, 2019 and the inception

date of this policy was November 1, 2019 and the listing realtor confirmed that the address was

vacate as of October 31, 2019.





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contract.

CLAIM # 24: INSURED – MIKE PIERRE-PAUL

(CLAIM #PA0002542560; POLICY # NY4751031)

416. The General issued a motor vehicle insurance policy to Policy Defendant Mike

Pierre-Paul.






inception on October 26, 2019.

419. Defendants Mike Pierre-Paul, Leonardo Beauvais, Kervin Rameau, Rodney-Pierre

Paul, Donald Debrosse and Reginald Irizarry (hereinafter collectively “claimants”) made or will

make claims under said policy stemming from this alleged “accident.”


claimants allegedly treated and/or received services from Provider Defendants Multispecialty

Health Group, Rehabilitation Medical Center and Florid Leisure Acupuncture P.C.





accident scheme.



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426. The policy was obtained via the IP address of 68.198.160.145. The IP address has


NY4626656, NY4666044, NY4685694, NY4688347, NY4709222, NY4711429, NY4749857,


427. The same IP address was used to secure the policies in Claim #5, #8, #17, #21, #22,

#23 and #24 in this action.

428. Policy Defendant Mike Pierre-Paul has an extensive claims history of four (4) prior

losses, two (2) of which were referred to NICB for staged/caused accident and organized

group/ring activity.

429. Staged Loss Defendant Kervin Rameau has an extensive claims history. He has ten

(10) prior losses, three (3) of which were referred to NICB for staged/caused accident, application

misrepresentation and organized group/ring activity.



policy address of 678 Perine St Elmira, NY 14904 instead he lived at 3215 Ave J Apt 1 Brooklyn,

NY 11210 during the relevant time periods.

432. In fact, the policy address was listed for sale on October 24, 2019 and the inception

date of this policy was October 26, 2019 and the listing realtor confirmed that the the Policy

Defendant has no affiliation with the policy address.



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CLAIM # 25: INSURED – SEAN CARY FRANCIS


434. The General issued a motor vehicle insurance policy to Policy Defendant Sean Cary

Francis.





occurring on January 4, 2020. The “accident” allegedly occurred shortly after the policy’s

inception on December 20, 2019.

437. Defendants Sean Cary Francis, James Joseph, Sharon Carter-Ross (hereinafter


“accident.”


claimants allegedly treated and/or received services from various medical providers.


accident scheme.





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443. The policy was obtained via the IP address of 172.58.231.119. This IP address is

housed out of Brooklyn.



policy address of 307 Fulton St Elmira, NY 14904 instead he lived at 501 E 93rd St Apt 1

Brooklyn, NY 11212 during the relevant time periods.

446. In fact, the policy address was listed as foreclosed since December 19, 2019 and

the inception date of this policy was December 20, 2019.




CLAIM # 26: INSURED – LOVENS FONTILUS


448. The General issued a motor vehicle insurance policy to Policy Defendant Lovens

Fontilus.









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451. Defendants Lovens Fontilus, Shawn Williams and Ricky Dorvil (hereinafter


“accident.”




accident scheme.



Queens with not report of injury at the time of the accident.





458. The same policy address used to establish the policy, 417 Broadway St Apt 1

Elmira, NY 14904, is the same address used to establish policy NY4818783 which is linked to an

alleged “accident” assigned claim number PA0002544684 that is also part of this ring and will be

discussed in greater detail in the subsection for Claim #27 herein.



policy address of 417 Broadway St Apt 1 Elmira, NY 14904 instead he lived at 1410 E 85th St Fl

1 Brooklyn, NY 11236 during the relevant time periods.



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72 4700.0409

461. Further, the property manager at the policy address confirmed that the policy

address is vacant and has been for a year. Other pertinent facts are that the apartments are A, B &

C not 1, 2 &3.




CLAIM # 27: INSURED – JUNIOR BEAUZILE


463. The General issued a motor vehicle insurance policy to Policy Defendant Lovens

Fontilus.





occurring on January 7, 2020. The “accident” allegedly occurred shortly after the policy’s


466. Defendants Junior Beauzile, Claudy Bellanger and Francklin Etienne (hereinafter


“accident.”




accident scheme.



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73 4700.0409







473. The same policy address used to establish the policy, 417 Broadway St Apt 1

Elmira, NY 14904, is the same address used to establish policy NY4810105 which is linked to an

alleged “accident” assigned claim number PA0002544285 that is also part of this ring and is

discussed in greater detail in the subsection for Claim #26 herein.



policy address of 417 Broadway St Apt 1 Elmira, NY 14904 instead he lived 1480 E 94th St Apt

1 Brooklyn, NY 11236 during the relevant time periods.

476. Further, the property manager at the policy address confirmed that the policy

address is vacant and has been for a year. Other pertinent facts are that the apartments are A, B &

C not 1, 2 &3.




CLAIM # 28: INSURED – RAHEEM GILLESPIE

(CLAIM #PA0002540721 & PA0002541897; POLICY # NY4820529)



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478. The General issued a motor vehicle insurance policy to Policy Defendant Raheem

Gillespie.







481. Defendant Raheem Gillespie made or will make claims under said policy stemming

from this alleged “accident.”


claimant allegedly treated and/or received services from various medical providers.


accident scheme.



Brooklyn.





policy address of 153 Haney St Watertown, NY 13601 instead he lived 257 E 32nd St Apt 2F

Brooklyn, NY 11226 during the relevant time periods.



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75 4700.0409

489. Further, the property has been listed for sale since September 27, 2019 and has been

vacant since it was listed.




AS AND FOR A FIRST CAUSE OF ACTION AGAINST ALL DEFENDANTS

(Declaratory Judgment)

491. The General incorporates, as though fully set forth herein, each and every allegation

in set forth above. There is an actual case in controversy between The General and the defendants

regarding the nature of the respective “accidents” described above.

492. The General contends that each of the “accidents” described above were staged,

deliberately caused by the respective defendants, or never occurred at all, and that The General

therefore is not obligated to pay any first-party benefits on the subject policies to the defendants,

nor is The General obligated to defend the Policy Defendants or the Staged Loss Defendants who

operated the insured vehicles.

493. Under New York Law, there is no motor vehicle liability insurance coverage or

unisured/underinsured motorist coverage for injuries arising from an intentional act. Further,

pursuant to New York No-Fault Law injuries arising from intentional acts are not reimbursable.

494. Upon information and belief, the respective defendants contend that the “accidents”

described above involved genuine automobile accidents, and that The General therefore is

obligated to pay first-party benefits on the subject policies to the defendants, and The General is

obligated to defend the Policy Defendants or the Staged Loss Defendants who operated the insured

vehicles.



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76 4700.0409

495. Accordingly, The General requests a judgment pursuant to C.P.L.R. § 3001,

declaring that the pertinent accidents were staged, not genuine, and The General therefore is not

obligated to pay any first-party benefits on the Subject Policies to the healthcare providers, named

insureds and /or claimants, including but not limited to No-Fault, uninsured motorist and/or

underinsured motorist benefits. Additionally, The General seeks a judgment pursuant to CPLR §

3001, declaring that The General is not obligated to defend nor provide indemnification for any of

the Policy Defendants or the Staged Loss Defendants who operated or occupied the insured

vehicles for claims that are made against them seeking damages and payment under the Subject

Policies.

AS AND FOR A SECOND CAUSE OF ACTION AGAINST ALL DEFENDANTS

(Declaratory Judgment)

496. The General incorporates, as though fully set forth herein, each and every allegation

set forth above.

497. There is an actual case in controversy between The General and the defendants

regarding the validity of each policy procured in the name of any of the Policy Defendants and

described above.

498. The General contends that each policy procured in the name of any of the Policy

Defendants and described above was procured through fraud, inasmuch as the Policy Defendants

did not reside at the policy addresses given to The General and that that each such policy actually

was procured solely for the purpose of staging phony “accidents” and thereby generating

fraudulent claims for No-Fault benefits that could be submitted to The General and other insurers.

Accordingly, The General contends that it is not obligated to pay any claims that arise from such

“policies”.



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77 4700.0409

499. Upon information and belief, the respective Defendants contend that each policy

procured in the name of any of the Policy Defendants was legitimately obtained and valid.

500. Accordingly, The General requests a judgment pursuant to C.P.L.R. § 3001,

declaring that the pertinent “policies” were procured through fraud, and The General therefore is

not obligated to pay any claims that arise from the Subject Policies; including but not limited to

first-party benefits to the healthcare providers or to the named insureds, including but not limited

to No-Fault, uninsured motorist and/or underinsured motorist benefits. Additionally, The General

seeks a judgment pursuant to CPLR § 3001 declaring that The General is not obligated to defend

nor provide indemnification for the named insureds or the individuals who operated the insured

vehicles for claims that are made against them seeking damages and payment under the Subject

Policies.

WHEREFORE, The General respectfully requests that this Court enter a declaratory

judgment pursuant to CPLR § 3001 in its favor and against the defendants, as follows:

I. on the First Cause of Action, (i) a declaratory judgment that the pertinent

accidents were staged, not genuine, and The General therefore is not

obligated to pay any first-party benefits on the Subject Policies to the

healthcare providers, named insureds and/or claimants, including but not

limited to No-Fault, uninsured motorist and/or underinsured motorist

benefits, and (ii) a declaratory judgment that The General is not obligated to

defend nor provide indemnification for the named insureds or the individuals

who operated or occupied the insured vehicles for claims that are made

against them seeking damages and payment under the Subject Policies;



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II. on the Second Cause of Action, (i) a declaratory judgment that the pertinent

"policies"were procured through fraud, and The General therefore is not

obligated to pay any claims that arise from the Subject Policies; including

but not limited to first-party benefits to the healthcare providers or to the

named insureds, including but not limited to No-Fault, uninsured motorist

and/or underinsured motorist benefits, and (ii) a declaratory judgment that

The General is not obligated to defend nor provide indemnification for the

named insureds or the individuals who operated or occupied the insured

vehicles for claims that are made against them seeking damages and payment

under the Subject Policies; and

III. the costs and disbursements associated with the prosecution of this action,

and such other and further relief as the Court may deem just and proper.

DATED: February 14, 2020

icole R. McErlean

FREIBERG, PECK & KANG, LLP

Attorneys for Plaintiff(s)200 Business Park Drive, Suite 202

Armonk, New York 10504

P: (212) 252-9550

F: (212) 252-9552

File No.: 4700.0409

78 4700.0409



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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF BRONX-- ----------------------------------XTHE GENERAL INSURANCE, PERMANENT GENERAL Index No.:

ASSURANCE CORPORATION, PERMANENT GENERAL

ASSURANCE CORPORATION OF OHIO, THE GENERAL

AUTOMOBILE INSURANCE COMPANY, INC.,

Plaintiffs, VERIFICATION-against-

AYANNA PIQUION, BARBARA ALTIME, et. al.

(collectively the "Policy Defendants")-and-

ANASIA SMITH, BETINA LAFORTUNE, et al,

(collectively the "Staged Loss Defeñdañts")-and-

5 BOROUGH ANESTHESIA, PLLC,

ACCESS CARE PT, P.C., et al,

(collectively the "Provider Defendants")Defendants.

-------------..-------------------- -------X

STATE OF NEW YORK )

) ss.:

COUNTY OF ALBANY )

Jonathan Cerone, being duly sworn, deposes and says:

Deponent is employed by the plaintiffs, corporations in the within action, and has read

the foregoing Complaint and knows the contents thereof. That the same is true to deponent's

own knowledge, except as to those matters therein stated to be alleged upon information and

belief, and as to those matters deponent believes it to be true. This verification is made bydeponent because plaintiffs consists of corporations, and deponent is a representative thereof.

The grounds of deponent's belief as to all matters not stated upon deponent's general

knowledge are upon information and belief.

Sworn to before me this

y: Jonathan Cerone

V)*day of bonue ,2020

KRISTINAA. RONALDNOTARY PUBUC, STATE OF NEW YORK

ÑOTARY PUBLIC Registration No. 01R06394124Qualified in Albany County

Commission Expires July 1, 20.1}__



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