INDEX NO. UNASSIGNED

CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 10/27/2017

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
WILLIAM J. O'REILLY,
SUMMONS WITH NOTICE

Plaintiff,

Index No.

-against-

Venue is proper in this Court pursuant to
C.P.L.R. § 503

MICHAEL J. PANTER,
Defendant.
TO THE ABOVE-NAMED DEFENDANT:

YOU ARE HEREBY SUMMONED and required to appear in this action by serving a
copy of your notice of appearance upon the undersigned within 20 days after the service of this
summons, exclusive of the day of service (or within 30 days after the service is complete if this
summons is not personally delivered to you within the State of New York).
YOU ARE HEREBY NOTIFED THAT should you fail to answer or appear, a
judgment will be entered against you by a default for the relief demanded below.
Dated: October 27, 2017
New York, New York

Respectfully submitted,
HOGUET NEWMAN
REGAL & KENNEY, LLP
By:
Fredric S. Newman
Andrew N. Bourne
10 East 40th Street, 35th Floor
New York, NY 10016
Phone: 212-689-8808
Attorneys for Plaintiff

1
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
1 of
accepted for filing by the County Clerk.

2

 INDEX NO. UNASSIGNED

CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

To the Defendant:

RECEIVED NYSCEF: 10/27/2017

Michael J. Panter
P.O. Box 8635
Red Bank, New Jersey 07701

NOTICE: This action seeks redress for Defendant Panter’s intentional, malicious, and
bad faith actions in making defamatory and false statements in a publicly-available social media
post. Plaintiff seeks damages for the public hatred, ridicule, disgrace, and permanent harm to his
professional and personal reputations as a result of Defendant Panter’s publication of knowingly
false defamatory statements about Plaintiff, which were made with actual malice, as well as
Defendant Panter’s intentional infliction of emotional distress upon Plaintiff.
The relief includes, but is not limited to, reputational damages, monetary damages,
special damages, punitive damages, costs, fees, injunctive relief, and such other relief as is just
and proper, in an amount not less than $5 million.
Should Defendant fail to appear herein, judgment will be entered by default for the sum
of $5 million, plus statutory interest, fess, and the costs of this action, as the Court may award.
VENUE: Plaintiff designates Nassau County as the place of trial. The basis of this
designation is Plaintiff’s residence in Nassau County, pursuant to C.P.L.R. § 503.

2
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
2 of
accepted for filing by the County Clerk.

2