ROCKLAND COUNTY CLERK 08/19/2019 0?:48 INDEX NO- 034%9/2019 230C. NO. 2 RECEZZVEES NYSCEF: (38;;192'2019 SUPREME COURT THE STATE OF NEW YORK CGUNTY 0F ROCKLAND RANK TRAMQNTANO individually and as Traasurer of Indax N0. THE TC) ELECT BUBEL DQWNEY AND PESANTE, Date Filed: mama, VERIFIED COMPLAINT MIGDALIA PESANTE, Dafaadaaz. Plaintiff, aomplainiag 9f tha defendant, by his attomeya Rainer: L. Reda, RC, respectfully shaws t0 this Coax? and alleges as follows: THE PARTIES FIRST: That at all times mentioned herein, plaintiff Frank m?m?rza?v a; ?far af 'E?aa Caamaittaa is Elect Baaci, air and was, and still is, a rasidaat ofihe Caunty of Kings and the Stata of New Yerk. That ai all times hareina?er mentioned, dafendant Migdalia was, and still is, a resident oftha Village afAirmont, County of Rocklaad, Saae afNaw York. FACTS THIRB: That at all times hereinafter mentioned, plaintiff Frank Tramontana was the Treasurer of the unincorporated association The Cammi?z?taa t0 Elect. Babel, Bawney and Pesanta. 10554 ROCKLAND COUNTY CLERK 08/19/2019 0?:48 INDEX NO- 034%9/2019 230C. NO. 2 RECEZZVEES NYSCEF: (38;;192'2019 FOURTH: That at all times heminafter mentioned, defendant Migd?ia Pemte was a member {If the auincorparated assog?zEation Th? Committee to Elem 8:111:61a Dewey and Pasante. {311 March 19, 2019, the Village ofAizment held a genaral eleciian allawing rasidents of the Villageto vote various members to its Bayard {3f Trustees? In the months preceding th?: electian, The Coma?itee to Eiect Babel, Dewey and Pesante was (hereina?er the ?Organization?). SEVENTH: Part ef the Grganizatiim?s duties and wsporzsibilities was to support three: candidates for various positions is the Village of Airmont?s Board. EIGHTH: The Defendant was a member of the Organizatien and a candidate fer whom the Grganizaiion supportad, and due to that. support? the Defendam ultimataly was} ef?ctien to the Village 0f r?aimont?s Beard as a Tmstee, Tha Defendant had agreed that as a member if the: Qrganizatian and in return far tha Organizatimz?s support of her ampaign it} be: elected Trustea, she Wculd contribute anewthird cf?the expenses incurred by the Organization during tha campaign. TENTH: That the Organization incurred signi?cant costs associated with the suppert of its candidates for the March 19, 2019 election. ELEVENTH: That the: costs are in excess 0f Twenty?Thousand dollars EU 20:54 ROCKLAND COUNTY CLERK 08/19/2019 0?:48 INDEX NO- 034%9/2019 230C. NO. 2 RECEZZVEES NYSCEF: (38;;192'2019 TWELFTH: That the Defendant, in breach of the agreement betwean himself and the Qrganizaticm failed and cantinues it: fail ta pay the om~?hird (1X3) portien of the costs incurred by the Organizatian in suppo? Cf hat carapaign. THIRTEENTH: That the Befandmt has 331d centinues to af?rmatively mate: she will mt pay her pm?tion ofthe expenses incurred by the Organizaticn. FOURTEENTH: That by mama of the foregaing, plaintiff has suffered damages in an amount to: be detemlined at trial, but in no Event lass that: RISER THOUSAND, FIVEHUNDRED DOLLARS WHEREFGRE, plaintiff demands judgmem against defendant MIGDALIA PBSANTE, in an amount to be determined at trial, but in 110 event 1653 than EIGHT- THOUSAND, DOLLARS on the ?rst cause of actien and $8,580.09; togather with the intcrest, costs and disbursemants? Dated: Suffem, New Yark August 19, 2019 REDA By: Javier A. Resada Esq Attorneys for Plaintiff 1 Executive Bwlevard Suite 201 Saffem, New York 10901 (345) 3576555 jrosado@redalaw.com 30:54 ROCKLAND COUNTY CLERK 08/19/2019 0?:48 INDEX NO- 034%9/2019 230C. NO. 2 RECEZZVEES NYSCEF: (38;;192'2019 SUPREME COURT OF THE STAT OF NEW YORK COWTY QF ROCKLAND mm FRANK TRAMONTANO individually and as Treagumr 0f Index N0. THE COMMITTEE TO ELECT BUBEL, BOWEY AND PESANTE, Dam Filed: Plaintiff; VERIFICATION ?against? MIGDALIA PESANTE, Befendant, X. STATE OF NEW YGRK COUNTY OF ROCKLAND Javier A. R?sado? Esq? an attorney duly admitted t0 practice law in the suite of New Yark af?ms the fellawing under penalty of perjury: Thai: he is an associate attomey for the Law Qf?ces Qf Robert L. Reda, P.C., the attorneys fer the plaintiff in the above antitled actien with of?ces located at One Executive Boulevard, Suite 2016 Suffern, NY 18901; that he has read the foregoing varified cemplaint and the contents film-30f: that the: same is true: is his knowledge, exam: as to the matters; siaied ta he aileged upm"; infermatian and beiie? and that 33 it: those matters; he beliaws than: to be trues; That the reason Why this veri?catian is made by deponent instead efthe plaintiff is because the plaintiff does not maizztain a r?sidanca or an office in the want}! 9f Rockiand, which is the county when depenmt has his e?'ztsas. Depcmm further says the grounds if his belief as {a all} matters in the complaint not stated to 13% upon mate?ts of my file and communications with my client. I affirm that the foregoing statements are true, under the penalties of perjury. Dated: Rockland New Yark August 19 2619 40554