FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF DUTCHESS
`-----------------------------------------------------------------------X
`ELDA PANCIONE, as Executrix of the Estate of
`ANTHONY F. PANCIONE, and ELDA PANCIONE,
`Individually,
`
`
`
`
`
`
`Index No.: 2023-54954
`
`VERIFIED ANSWER
`
`Plaintiffs,
`
`
`
`against
`
`
`ATLANTICARE MANAGEMENT, L.L.C., d/b/a
`PUTNAM RIDGE NURSING HOME, AMBULNZ
`NY 2, LLC, and BREWSTER SOUTHEAST EMS,
`INC.,
`
`
`Defendants.
`-----------------------------------------------------------------------X
`
`
`Defendant AMBULNZ NY 2, LLC, by its attorneys, HEIDELL, PITTONI,
`
`MURPHY & BACH, LLP, upon information and belief, answers the Verified Complaint herein
`
`as follows:
`
`AS AND FOR A FIRST CAUSE OF ACTION
`
`FIRST: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “FIRST” through
`
`“SEVENTIETH”.
`
`AS AND FOR A SECOND CAUSE OF ACTION
`
`SECOND: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “SEVENTY-
`
`FIRST” through “EITHTY-SEVENTH”.
`
`
`
`
`
`
`
`2872175.1
`
`
`
`
`1 of 12
`
`
`
`
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF DUTCHESS
`-----------------------------------------------------------------------X
`ELDA PANCIONE, as Executrix of the Estate of
`ANTHONY F. PANCIONE, and ELDA PANCIONE,
`Individually,
`
`
`
`
`
`
`Index No.: 2023-54954
`
`VERIFIED ANSWER
`
`Plaintiffs,
`
`
`
`against
`
`
`ATLANTICARE MANAGEMENT, L.L.C., d/b/a
`PUTNAM RIDGE NURSING HOME, AMBULNZ
`NY 2, LLC, and BREWSTER SOUTHEAST EMS,
`INC.,
`
`
`Defendants.
`-----------------------------------------------------------------------X
`
`
`Defendant AMBULNZ NY 2, LLC, by its attorneys, HEIDELL, PITTONI,
`
`MURPHY & BACH, LLP, upon information and belief, answers the Verified Complaint herein
`
`as follows:
`
`AS AND FOR A FIRST CAUSE OF ACTION
`
`FIRST: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “FIRST” through
`
`“SEVENTIETH”.
`
`AS AND FOR A SECOND CAUSE OF ACTION
`
`SECOND: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “SEVENTY-
`
`FIRST” through “EITHTY-SEVENTH”.
`
`
`
`
`
`
`
`2872175.1
`
`
`
`
`1 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`AS AND FOR A THIRD CAUSE OF ACTION
`
`THIRD: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “EIGHTY-
`
`EIGHTH” through “NINTY-EIGHTH”.
`
`AS AND FOR A FOURTH CAUSE OF ACTION
`
`FOURTH: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “NINETY-
`
`NINTH” through “ONE HUNDRED FOURTEENTH”.
`
`AS AND FOR A FIFTH CAUSE OF ACTION
`
`FIFTH: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “ONE HUNDRED
`
`FIFTEENTH”.
`
`SIXTH: Denies the allegations contained in the paragraphs of the Verified
`
`Complaint designated “ONE HUNDRED SIXTEENTH” except admits that Defendant
`
`AMBULNZ NY 2, L.L.C., maintains a place of business in the State of New York, County of
`
`Albany, located at 187 Wolf Road, Albany NY 12205, and begs leave to refer all questions of
`
`law to the court and all questions of fact to the trier thereof.
`
`SEVENTH: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraph of the Verified Complaint designated “ONE HUNDRED
`
`SEVENTEENTH”
`
`2872175.1
`
`
`
`
`2 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`EIGHTH: Denies the allegations contained in the paragraphs of the Verified
`
`Complaint designated “ONE HUNDRED EIGHTEENTH” through “ONE HUNDRED
`
`THIRTY-FOURTH”, except admits that AMBULNZ NY 2, L.L.C. is a foreign limited liability
`
`company, and otherwise denies knowledge or information sufficient to form a belief as to the
`
`allegations within these paragraphs and begs leave to refer all questions of law to the court and
`
`all questions of fact to the trier thereof.
`
`NINTH: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “ONE HUNDRED
`
`THIRTY-FIFTH” “ONE HUNDRED FIFTY-FIRST”.
`
`TENTH: Denies knowledge or information sufficient to form a belief as to the
`
`allegations contained in the paragraphs of the Verified Complaint designated “ONE HUNDRED
`
`FIFTY SECOND” through “ONE HUNDRED FIFTY-FIFTH” and otherwise begs leave to refer
`
`all questions of law to the court and all questions of fact to the trier thereof.
`
`ELEVENTH: Denies the allegations contained in the paragraphs of the Verified
`
`Complaint designated “ONE HUNDRED FIFTY-SIXTH” through “ONE HUNDRED FIFTY-
`
`NINTH” and otherwise begs leave to refer all questions of law to the court and all questions of
`
`fact to the trier thereof.
`
`AS AND TO A SIXTH CAUSE OF ACTION
`
`TWELFTH: Answering the paragraph of the Verified Complaint designated
`
`“ONE HUNDRED SIXTIETH” Defendant repeats and realleges each and every denial and
`
`admission in answer to the paragraphs of the Verified Complaint designated “FIRST” through
`
`“ONE HUNDRED SIXTIETH” with the same force and effect as if herein set forth at length.
`
`THIRTEENTH: Denies the allegations contained in the paragraphs of the
`
`Verified Complaint designated “ONE HUNDRED SIXTY-FIRST” through “ONE HUNDRED
`
`2872175.1
`
`
`
`
`3 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`SIXTY-FOURTH” and otherwise begs leave to refer all questions of law to the court and all
`
`questions of fact to the trier thereof.
`
`AS AND TO A SEVENTH CAUSE OF ACTION
`
`FOURTEENTH: Answering the paragraph of the Verified Complaint designated
`
`“ONE HUNDRED SIXTY-FIFTH” Defendant repeats and realleges each and every denial and
`
`admission in answer to the paragraphs of the Verified Complaint designated “FIRST” through
`
`“ONE HUNDRED SIXTY-FOURTH” with the same force and effect as if herein set forth at
`
`length.
`
`FIFTEENTH: Denies the allegations contained in the paragraphs of the Verified
`
`Complaint designated “ONE HUNDRED SIXTY-SIXTH”, ONE HUNDRED SIXTY-EIGHTH”
`
`and “ONE HUNDRED SIXTY-NINTH” and otherwise begs leave to refer all questions of law to
`
`the court and all questions of fact to the trier thereof.
`
`SIXTEENTH: Denies knowledge or information sufficient to form a belief as to
`
`the allegations contained in the paragraphs of the Verified Complaint designated “ONE
`
`HUNDRED SIXTY-SEVENTH” and otherwise begs leave to refer all questions of law to the
`
`court and all questions of fact to the trier thereof.
`
`AS AND TO AN EIGHTH CAUSE OF ACTION
`
`SEVENTEENTH: Answering the paragraph of the Verified Complaint
`
`designated “ONE HUNDRED SEVENTIETH” Defendant repeats and realleges each and every
`
`denial and admission in answer to the paragraphs of the Verified Complaint designated “FIRST”
`
`through “ONE HUNDRED SIXTY-NINTH” with the same force and effect as if herein set forth
`
`at length.
`
`EIGHTEENTH: Denies knowledge or information sufficient to form a belief as
`
`to the allegations contained in the paragraphs of the Verified Complaint designated “ONE
`
`2872175.1
`
`
`
`
`4 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`HUNDRED SEVENTY-FIRST” and otherwise begs leave to refer all questions of law to the
`
`court and all questions of fact to the trier thereof.
`
`NINETEENTH: Denies the allegations contained in the paragraphs of the
`
`Verified Complaint designated “ONE HUNDRED SEVENTY-SECOND” and “ONE
`
`HUNDRED SEVENTY-THIRD” and otherwise begs leave to refer all questions of law to the
`
`court and all questions of fact to the trier thereof.
`
`TWENTIETH: All paragraphs not responded to are herein deemed denied.
`
`FOR A FIRST DEFENSE
`
`TWENTY-FIRST: That this action was not commenced against Defendant until
`
`after the expiration of the time period specified in the applicable statute of limitations and any
`
`recovery based on the alleged causes of action herein is barred.
`
`FOR A SECOND DEFENSE
`
`TWENTY-SECOND: That whatever damages may have been sustained at the
`
`time and place alleged in the Verified Complaint by Plaintiffs were caused, in whole or in part,
`
`by the culpable conduct of the Plaintiffs and without any negligence on the part of Defendant.
`
`Damages, if any, are to be diminished proportionally to the culpable conduct of the Plaintiffs.
`
`FOR A THIRD DEFENSE
`
`TWENTY-THIRD: That as to the cause of action set forth in the Verified
`
`Complaint based upon alleged failure to obtain an informed consent, Defendant pleads the
`
`defenses in Public Health Law, §2805-d.
`
`FOR A FOURTH DEFENSE
`
`TWENTY-FOURTH: That the equitable share of liability, if any, of Defendant,
`
`AMBULNZ NY 2, L.L.C., shall be determined pursuant to the provisions of Article 16 of the
`
`CPLR.
`
`2872175.1
`
`
`
`
`5 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`FOR A FIFTH DEFENSE
`
`TWENTY-FIFTH: That one or more causes of action in the Verified Complaint
`
`fails to state a cause of action upon which relief may be granted.
`
`FOR A SIXTH DEFENSE
`
`TWENTY-SIXTH: That this Defendant reserves the right to amend its answers
`
`and/or affirmative defenses that may be determined applicable in the future by discovery in this
`
`matter.
`
`FOR A SEVENTH DEFENSE
`
`TWENTY-SEVENTH: To the extent Plaintiffs release or otherwise settle with
`
`any other person/entity relative to the alleged injuries/damages in this action, the answering
`
`Defendant will be entitled to have any claim for damages asserted against it reduced to the extent
`
`permitted by operation of New York General Obligations Law Section 15-108 or any other
`
`applicable law.
`
`FOR A EIGHTH DEFENSE
`
`TWENTY-EIGHTH: Plaintiffs have failed to mitigate their alleged damages
`
`claimed herein.
`
`FOR A NINTH DEFENSE
`
`TWENTY-NINTH: The amount of alleged damages claimed by Plaintiffs should
`
`be reduced pursuant to CPLR § 4545 to the extent of any collateral source benefits, remuneration
`
`or compensation received.
`
`FOR A TENTH DEFENSE
`
`THIRTIETH: That the care rendered to the Plaintiffs at issue in this case by the
`
`Defendant was impacted by the COVID-19 outbreak and in support of the State’s directives and,
`
`2872175.1
`
`
`
`
`6 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`therefore, the Defendant is immune from liability under Article 30-D of the Public Health Law as
`
`it existed at the time care was rendered to the patient at issue in this case.
`
`FOR A ELEVENTH DEFENSE
`
`THIRTY-FIRST: The Defendant is immune from liability for the acts, omissions
`
`and injuries alleged in the Verified Complaint, pursuant to Executive Order (A. Cuomo) 2020 et
`
`seq. (N.Y. Comp. Codes R & Regs. tit. 9. §8.202 et seq.), including but not limited to Executive
`
`Order (A. Cuomo) 202.10 (N.Y. Comp. Codes R & Regs. tit. 9. §8.202.10 et seq.), and/or Article
`
`30-D of the Public Health Law and/or pursuant to the United States Public Readiness and
`
`Emergency Preparedness (“PREP”) Act (42 U.S.C.A. §247d-6d et seq.) and/or the Coronavirus
`
`Aid Relief, and Economic Security (“CARES”) Act of 2020, §4113c (42 U.S.C.A. §247d-
`
`6d[i][1], as added by Pub. L. 116-136, 116 U.S. Stat. 3548).
`
`FOR A TWELFTH DEFENSE
`
`THIRTY-SECOND: The court lacks jurisdiction over the subject matter of
`
`Plaintiffs’ claim and the state law claims must be dismisses, as they are preempted by the United
`
`States Public Readiness and Emergency Preparedness (“PREP”) Act of 2020, §4113c (42
`
`U.S.C.A. §247d-6d[i][1], as added by Pub. L. 116-136, 116 U.S. Stat. 3548).
`
`FOR A THIRTEENTH DEFENSE
`
`THIRTY-THIRD: The court does not have jurisdiction of the person of the
`
`Defendant because Defendant was not properly served with a copy of the summons and Verified
`
`Complaint.
`
`FOR A FOURTEENTH DEFENSE
`
`THIRTY-FOURTH: That the Verified Complaint was served in contravention of
`
`CPLR §3012-a and therefore the action is a nullity.
`
`2872175.1
`
`
`
`
`7 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`WHEREFORE, Defendant AMBULNZ NY 2, L.L.C. demands judgment
`
`dismissing the Verified Complaint herein, together with the costs and disbursements of this
`
`action.
`
`Dated: White Plains, New York
`
`March 28, 2024
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`Yours, etc.,
`
`HEIDELL, PITTONI, MURPHY & BACH, LLP
`
`
`
`______________________________
`JENNIFER J. BENNICE
`81 Main Street
`White Plains, New York 10601
`(914) 559-3100
`jbennice@hpmb.com
`
`Attorneys for Defendant
`AMBULNZ NY 2, L.L.C.
`
`
`TO: VIA NYSCEF
`MEAGHER & MEAGHER, P.C.
`Attorneys for Plaintiffs
`111 Church Street
`White Plains, New York 10601
`(914) 328-8844
`
`
`2872175.1
`
`
`
`
`8 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF DUTCHESS
`-----------------------------------------------------------------------X
`ELDA PANCIONE, as Executrix of the Estate of
`ANTHONY F. PANCIONE, and ELDA PANCIONE,
`Individually,
`
`
`
`
`
`
`Index No.: 2023-54954
`
`VERIFICATION
`
`Plaintiffs,
`
`
`
`against
`
`
`ATLANTICARE MANAGEMENT, L.L.C., d/b/a
`PUTNAM RIDGE NURSING HOME, AMBULNZ
`NY 2, LLC, and BREWSTER SOUTHEAST EMS,
`INC.,
`
`
`Defendants.
`-----------------------------------------------------------------------X
`
`I, the undersigned, an attorney admitted to practice law in the Courts of New York
`
`
`State, state that I am a Partner of the firm HEIDELL, PITTONI, MURPHY & BACH, LLP, the
`attorneys of record for Defendant, AMBULNZ NY 2, L.L.C., that I have read the foregoing
`ANSWER and know the contents thereof; the same is true to my own knowledge, except as to
`the matters therein stated to be alleged upon information and belief, and as to those matters, I
`believe them to be true.
`The reason this verification is made by me and not by Defendants, is because
`Defendant, AMBULNZ NY 2, L.L.C., is not present within the County of Westchester which is
`where this attorney maintains her office.
`
`
`The grounds of my belief as to all matters not stated upon my own knowledge are
`as follows:
`
`
`
`
`
`Dated: White Plains, New York
`
`March 28, 2024
`
`
`
`Papers and records of said Defendant.
`I affirm that the foregoing statements are true, under the penalties of perjury.
`
`
`
`JENNIFER BENNICE
`
`2872175.1
`
`
`
`
`9 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF DUTCHESS
`-----------------------------------------------------------------------X
`ELDA PANCIONE, as Executrix of the Estate of
`ANTHONY F. PANCIONE, and ELDA PANCIONE,
`Individually,
`
`
`Plaintiffs,
`
`
`
`
`
`Index No.: 2023-54954
`
`NOTICE OF DEPOSITION
`
`
`
`against
`
`
`ATLANTICARE MANAGEMENT, L.L.C., d/b/a
`PUTNAM RIDGE NURSING HOME, AMBULNZ
`NY 2, LLC, and BREWSTER SOUTHEAST EMS,
`INC.,
`
`
`Defendants.
`-----------------------------------------------------------------------X
`
`
`PLEASE TAKE NOTICE that, pursuant to Article 31 of the Civil Practice Law
`
`and Rules, the deposition upon oral questions of the Plaintiffs, will be taken on the 30th day of
`
`April, 2024 at 10:00 a.m. in the forenoon of that day, before a Notary Public of the State of
`
`New York at the office of HEIDELL, PITTONI, MURPHY & BACH, LLP, 81 Main Street,
`
`White Plains New York 10601. That said party is to be examined on all evidence material and
`
`necessary in the defense of this action.
`
`Dated: White Plains, New York
`
`March 28, 2024
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Yours, etc.,
`
`HEIDELL, PITTONI, MURPHY & BACH, LLP
`
`
`By:
`
`
`
`______________________________
`JENNIFER J. BENNICE
`81 Main Street
`White Plains, New York 10601
`(914) 559-3100
`jbennice@hpmb.com
`
`
`2872175.1
`
`
`
`
`10 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`Attorneys for Defendant
`AMBULNZ NY 2, L.L.C.
`
`TO: VIA NYSCEF
`MEAGHER & MEAGHER, P.C.
`Attorneys for Plaintiffs
`111 Church Street
`White Plains, New York 10601
`(914) 328-8844
`
`
`
`
`2872175.1
`
`
`
`
`11 of 12
`
`
`
`
`
`FILED: DUTCHESS COUNTY CLERK 03/28/2024 12:07 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 2023-54954
`
`RECEIVED NYSCEF: 03/28/2024
`
`Index No.: 2023-54954
`
`
`
`
`
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF DUTCHESS
`
`
`
`
`
`
`
`ELDA PANCIONE, as Executrix of the Estate of
`ANTHONY F. PANCIONE, and ELDA PANCIONE,
`Individually,
`
`
`
`Plaintiffs,
`
`- against –
`ATLANTICARE MANAGEMENT, L.L.C., d/b/a
`PUTNAM RIDGE NURSING HOME, AMBULNZ
`NY 2, LLC, and BREWSTER SOUTHEAST EMS,
`INC.,
`
`
`Defendants.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`HEIDELL, PITTONI, MURPHY & BACH, LLP
`Counsel for AMBULNZ NY, 2 L.L.C.
`81 Main Street – Ste. 112
`White Plains, New York 10601
`
`
`VERIFIED ANSWER AND NOTICE OF DEPOSITION
`
`
`
`
`
`
`
`
`
`
`
`
`Service of a copy of the within
`
`
`
`Dated:
`
`
`
`
`
`
`
`
`PLEASE TAKE NOTICE
`□ NOTICE OF ENTRY
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Signature:
`Attorney(s) for
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`that the within is a (certified) true copy of a
`in the office of the clerk of the within named Court on
`
`
`
` is hereby admitted.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` entered
`, 20 .
`
`
`
` □
`
` NOTICE OF SETTLEMENT
`
`Dated:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2541540.1
`
`
`
`
`that an Order of which the within is a true copy will be presented for settlement to the
`Hon.
`
`
`
` one of the judges of the within named Court,
`at
`
`
`
`
`
` on ,
`
`. 20 . at
`
` a.m./p.m.
`
`
`
`
`12 of 12
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
