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STATE OF NEW YORK


SUPREME COURT COUNTY OF CAYUGA

THE ESTATE OF BRIAN G. HOUGH by


JACLYN SCHNURR, ADMINISTRATRIX and
JACLYN SCHNURR, INDIVIDUALLY,
COMPLAINT

Plaintiffs,
Index No.

SHAHED HUSSAIN d/b/a PRESTIGE


LIMOUSINE & CHAUFFEUR SERVICE,
NAUMAN HUSSAIN, THE ESTATE OF
SCOTT T. LISINICCHIA, MAVIS DISCOUNT
TIRE, INC., THE APPLE BARREL COUNTRY
STORE, and JOHN DOES 1-10

Defendants.

Plaintiffs, Jaclyn Schnurr, as Administratrix for the Estate of Brian G.

Hough, and individually (hereinafter collectively referred to as "Plaintiffs") by and

through their attorneys, The Wolford Law Firm LLP, set forth the following as and

for their Complaint against Defendants Shahed Hussain d/b/a Prestige Limousine

& Chauffeur Service, Nauman Hussain, the Estate of Scott T. Lisiñicchia, Mavis

Discount Tire, Inc., The Apple Barrel Country Store and John Does 1-10:

THE PARTIES

1. At all relevant times herein, Brian G. Hough (hereinafter referred to

as "Decedent") was a resident of the County of Cayuga, State of New York.

2. Jaclyn Schnurr, is and was at all relevant times, the wife of

Decedent, and was and is a resident of the County of Cayuga, State of New York.

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3. On January 9, 2019, by Decree of the Cayuga County Surrogate's

Court, Jaclyn Schnurr was issued Letters of Administration for the Estate of Brian

G. Hough.

4. Defendant Shahed Hussain d/b/a Prestige Limousine & Chauffer

Service (hereinafter referred to as "Defendant Shahed Hussain") was and is a

resident of the County of Saratoga, New York.

5. Upon information and belief, Defendant Shahed Hussain operated a

limousine leasing and rental business with a principal place of business located at

776 Saratoga Road, Gansevoort, New York.

6. At all relevant times, Defendant Shahed Hussain is and was the

owner of, and doing business as, Prestige Limousine & Chauffeur Service

(hereinafter referred to as "Prestige Limousine").

7. At all relevant times, Defendant Shahed Hussain is and was a

registered carrier with the Federal Motor Carrier Safety Administration and had a

United States Department of Transportation number of 3180110.

8. At all relevant times, Defendant Nauman Hussain is and was the son

of Defendant Shahed Hussain and is a resident of the County of Albany, State of

New York.

9. At all relevant times, Defendant Nauman Hussain oversaw the daily

operations of Prestige Limousine as an employee and/or agent and/or

representative of Defendant Shahed Hussain.

10. Defendant Shahed Hussain owned and operated a certain 2001 Ford

Excursion Limousine (hereinafter referred to as the "limousine").

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11. The limousine, bearing license plate number TOGALUX1, was a

hire."
vehicle "for

12. Upon information and belief, Defendants Shahed Hussain and

Nauman Hussain (hereinafter co!!ectively "Hussain Defendants") exercised control

over the hiring, retention, and/or trainiñÿ of limousine drivers, and over the

ownership and maintenance of all vehicles used in the business operations of

Prestige Limousine.

13. Upon information and belief, Scott T. Lisinicchia was an employee or

agent of Prestige Limousine, and was hired and/or retained by Defendant Nauman

Hussain and/or Shahed Hussain to serve as a limousine driver.

14. Upon information and belief, Scott T. Lisiñicchia was the driver of the

limousine on October 6, 2018, which crashed and resulted in the deaths of 20

people (including his own).

15. Upon information and belief, no representative has yet been

appointed as the executor or administra(tor)(trix) of Mr. Lisiñicchia's estate.

16. Upon information and belief, Defendant Mavis Discount Tire, Inc.

(hereinafter "Mavis") is a domestic corporation authorized to do business and

doing business in the State of New York with a principal place of business located

at 145 South Broadway in Saratoga Springs, New York, and routinely performed

maiñteñance and repairs on the limousines owned and/or operated by the Hussain

Defendants, including the limousine driven on the day of the accident.

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17. The Apple Barrel Country Store (hereinafter referred to as "Apple

Barrel") is located at 115 NY-30A, Schoharie, New York and is the owner of the

parking lot where Decedent was killed on October 6, 2018.

18. Upon information and belief, Defendants John Does 1 through 10 are

individuals, corporate entities and/or State and/or municipal entities, whose names

and addresses of residences are unknown and who may be responsible, in part,

for causing or contributing to cause the subject accident herein by their action(s)

and/or inaction(s) and/or breach of duty owed to Decedent, Jaclyn Schnurr and the

general public.

19. John Does 1 through 10 are hereinafter collectively referred to as

"John Doe Defendants".

FACTUAL ALLEGATIONS

THE ACCIDENT

20. On October 6, 2018, a group of 17 individuals hired the limousine

from Prestige Limousine for a day trip.

21. Upon information and belief, those 17 individuals were picked up by

the limousine and its driver, Scott T. Lisinicchia, on October 6, 2018, from

Amsterdam, New York, and left the city by heading south on State Route 30.

22. At approximately 1:55 p.m. on October 6, 2018, Decedent, who was

46 years old at the time, was standing in the parking lot of Apple Barrel with his

wife, Jaclyn Schnurr, and his wife's father, James J. Schnurr, where Decedent had

parked his wife's car.

23. At that same time, the limousine operated by Scott T. Lisinicchia

was traveling southwest down a steep hill on State Route 30.

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24. Upon information and belief, Scott T. Lisinicchia may have been

under the influence of marijuana at the time that he drove the limousine southwest

down a steep hill on State Route 30.

25. Upon information and belief, as the limousine neared the bottom of

the hill, the limousine accelerated in speed and the driver of the limousine began

to lose control of the vehicle.

26. At the bottom of the hill, the limousine, which was out of control, ran

through the stop sign located at the intersection of State Routes 30 and 30A.

27. Upon information and belief, the limousine was traveling at an unsafe

speed when it passed through the stop sign and crossed over Route 30A.

28. After crossing over Route 30A, the limousine then crossed the lawn

of Apple Barrel and entered the parking lot.

29. Upon information and belief, at the time the limousine entered Apple

Barrel's property and parking lot, it was out of control and traveling at an unsafe

speed.

30. Upon information and belief, Apple Barrel had not erected any

barriers, bellards or any other means of preventing a vehicle that was traveling too

fast, and out of control, as was the limousine on that date, to prevent vehicles from

driving over the grass into the parking lot from State Route 30.

31. Upon information and belief, Apple Barrel had not posted any

signage informing its patrons that they should not park in the section of the parking

lot located at the bottom of the hill where State Routes 30 and 30A meet.

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32. After entering Apple Barrel's parking lot, the limousine crashed into

Jaclyn Schnurr's parked and unoccupied vehicle.

33. Upon impact from the limousine, Jaclyn Schnurr's vehicle then struck

Decedent, and Jaclyn Schnurr's father, James J. Schnurr, killing both of them.

34. Upon information and belief, after striking Jaclyn Schnurr's vehicle

and killing Decedent, the limousine continued traveling out of control and

eventually crashed into a ravine, killing the driver, Scott T. Lisinicchia, and every

one of the other 17 passengers in the limousine.

35. Jaclyn Schnurr was just a couple of feet away from her husband and

her father at the time they were struck and killed by the parked vehicle and she

feared for her own life and personal safety, and suffers from extreme emotional

distress as a result.

36. Jaclyn Schnurr also suffers from extreme emotional distress as a

result of witnessing the sudden and gruesome deaths of her husband, Decedent,

and her father, James J. Schnurr, when they were struck and killed by the

limousine.

FAILED VEHICLE INSPECTIONS, CITATIONS AND INADEQUATE VEHICLE


MAINTENANCE

37. Upon information and belief, the Hussain Defendants failed to apply

for Operating Authority from the New York State Department of Transportation

(hereinafter referred to as "DOT") despite having been informed by DOT that they

had to obtain such authority given that the limousine carried ten or more

passengers.

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38. Upon information and belief, if the Hussain Defendants had properly

applied for Operating Authority, the limousine would have undergone a rigorous

inspection pursuant to 22 NYCRR 720, including undergoing a break test.

39. Instead, however, upon information and belief, the Hussain

Defendants were able to avoid the rigorous DOT inspection and instead only

underwent the less stringent inspection required by the New York State

Department of Motor Vehicles (hereinafter referred to as "DMV").

40. Upon information and belief, prior to the accident the limousine had

been inspected by DOT on multiple occasions, and had failed those inspections.

41. Upon information and belief, in June 2017, a DOT Inspector saw the

limousine at Mavis and knew that, given its size, it should be not inspected by

Mavis.

42. Upon information and belief, following up in March, 2018, the DOT

Inspector visited a location where the limousine was parked, inspected it and

issued violations for, among other things, having more than 25% of brakes

defective and operating a motor coach or other passenger carrier vehicle with

seating in excess of the manufacturer seating capacity. The DOT Inspector

Service"
placed an "Out of sticker on the vehicle.

43. Upon information and belief, the Hussain Defendants and/or their

agents were aware that the limousine was modified to expand the capacity of the

limousine to transport up to eighteen (18) people, when it had only been certified

to carry no more than ten (10) passengers, including the driver of the limousine.

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44. Upon information and belief, in August, 2018, after being pulled over

by a New York State Trooper, Scott T. Lisinicchia was issued a citation for

operating the limousine without the proper license and because the limousine was

not properly registered with DOT.

45. Upon information and belief, the limousine was also inspected by

DOT in September, 2018, and once again failed inspection for, among other

things, failing to have a federal certificate to operate, as well as mechanical issues

concerning the brake systems and defective windshield wipers.

46. Upon information and belief, there was evidence at that time that the

limousine had been driven over one thousand miles since the citation was issued

in August and the vehicle was ordered out of service.

47. Upon information and belief, between March 2018 and September

2018, DOT found at least 22 violations during inspections of the limousine and

ordered that the limousine be taken out of service until the safety violations,

including the defective breaks, were remedied.

48. Upon information and belief, after failing the aforementioned

inspections, the Hussain Defendants were informed that the limousine was illegal

to drive on public roads until the defects leading to the failed inspections were

addressed and repaired.

49. Upon information belief, Mavis had been hired by the Hussain

Defendants to perform inspections and regular maintenance and repairs on the

limousine.

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50. Upon information and belief, DOT had ordered the limousine be

taken out of service on numerous occasions, most recently in September, 2018,

and had placed a sticker on the windshield of such vehicle marking it

"unserviceable."

51. Upon information and belief, the Hussain Defendants and/or their

"unserviceable"
agents removed the sticker from the windshield before dispatching

it to pick up occupants of the limousine on October 6, 2018.

MAINTENANCE AND INSPECTION OF VEHICLES BY MAVIS

52. Upon information and belief, Mavis illegally inspected the limousine

as a passenger vehicle on May 11, 2018, rather than referring or reporting it to

DOT to be inspected pursuant to 17 NYCRR 720. As a result, Mavis subjected the

limousine to a far less rigorous inspection than should have been conducted. Upon

information and belief, Mavis was aware that the vehicle required an inspection

pursuant to 17 NYCRR 720 because one could easily observe from looking at the

vehicle that it carried far more than 10 passengers.

53. Upon information and belief, none of Mavis's employees possessed

the requisite training and certification to inspect a vehicle that had a passenger

capacity in excess of 10.

54. Upon information and belief, because Mavis performed an illegal

inspection of the limousine as a passenger vehicle, rather than a passenger

carrying vehicle inspected pursuant to 17 NYCRR 720, the limousine's brakes

were not adequately inspected and repaired to ensure that the limousine was in a

safe condition to carry the 18 occupants that it was carrying on the day of the

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accident. Mavis's illegal inspections and negligence in failing to properly inspect

and repair the brakes contributed to the accident and the deaths that occurred on

October 6, 2018.

55. Upon information and belief, Mavis issued a DMV sticker for the

limousine, despite the existence at the time of the inspection of numerous defects

that were open and obvious, and progressive in nature.

56. Upon information and belief, Mavis inspected, maintained and

repaired the limousine at issue in a negligent and substandard manner, which

resulted in the accident on October 6, 2018, and the death of Decedent.

57. Upon information and belief, Mavis inspected and repaired the

limousine on numerous occasions including, but not limited to: July, 2016, January

12, 2018, May 11, 2018, June 8 and 9, 2018, and most recently July 28, 2018,

approximately two months prior to the accident. Mavis's negligent inspection and

repair of the limousine in July, 2018, or sometime thereafter contributed to the

accident's occurrence on October 6, 2018.

PRIOR ACCIDENTS AT APPLE BARREL

58. Prior to October 6, 2018, there were other car accidents that

occurred in Apple Barrel's parking lot as a result of a vehicle passing through the

stop sign at the intersection of State Routes 30 and 30A.

59. These accidents, which occurred in 2012 and 2014, were caused

when vehicles traveling down State Route 30 went through the stop sign located at

State Route 30A as a result of their breaks being unable to slow them down

quickly enough.

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60. Upon information and belief, the vehicles in each of these accidents

was out of control as a result of their drive down the steep hill on Route 30.

61. Upon information and belief, each of the vehicles were able to enter

Apple Barrel's parking lot (and building area) as a result of there being an

inadequate barricade to prevent these out of control vehicles from entering Apple

Barrel's property and parking lot.

62. Upon information and belief, Apple Barrel did not have any signage

posted informing its patrons not to park in the area of the parking lot where cars

had previously plowed through.

63. Upon information and belief, Apple Barrel did not in any way block off

the section of the parking lot where cars had previously plowed through to prevent

its patrons from parking there.

FIRST CAUSE OF ACTION


(Negligence/Gross Negligsñcs/Pain and Suffering against the Hussain

Defendants and the Estate of Scott Lisinicchia)

64. Plaintiffs repeat and reallege each of the allegations set forth in

paragraphs 1 through 63, as though fully set forth herein.

65. The Hussain Defendants, as common carriers of passengers, had a

duty to exercise reasonable care in coññection with their operation, ownership,

maintenance, repair and/or control of the limousine for use by the general public,

including a duty to Decedent and Jaclyn Schnurr to ensure that the limousine

would not be rendered dangerous and result in harmful injuries or death.

66. The Hussain Defendants had actual and/or constructive notice that

the limousine was not properly licensed, had failed inspections, had significant and

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serious defects, that the vehicle was both illegal and dangerous if placed on public

roadways without proper repairs and/or maintenance, and that the driver of the

limousine was not licensed to operate such a vehicle.

67. Scott T. Lisinicchia was aware that he was not properly licensed to

drive the limousine, and upon information and belief, had notice that the limousine

was not properly licensed, had failed inspections and had significant and serious

defects, rendering it illegal and dangerous to drive on the day of the accident.

68. The Hussain Defendants and Scott T. Lisinicchia failed to exercise

reasonable care in the ownership, maintenance, operation and/or control of the

limousine, and further breached their duty to Decedent and Jaclyn Schnurr by

knowingly placing and driving a limousine on public roadways, which was not

properly licensed, had failed inspections and had significant and serious defects,

all without performing the legally required and necessary repairs and/or

maintenance.

69. The Hussain Defendants and Scott T. Lisinicchia are responsible for

the acts and omissions of Scott T. Lisinicchia who failed to maintain control of the

limousine which caused and/or contributed to the accident by failing to prevent the

collision which occurred resulting in the death of Decedent.

70. The negligent acts of the Hussain Defendants and Scott T.

Lisinicchia were the proximate cause of Decedent's physical, mental, and

emotional injuries and harm, including conscious pain and suffering.

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71. As a result of the October 6, 2018 crash, Decedent sustained a

"serious"
injury as that term is defined in Subdivision (d) of Section 5102 of the

Insurance Law of the State of New York.

72. The accident, personal injuries and death sustained by Decedent

were proximately caused by the negligence and/or gross negligence of the

Hussain Defendants and Scott T. Lisinicchia, their agents, employees, or other

individuals under their control, without any negligence contributing thereto on the

part of Decedent.

73. Upon information and belief, as a result of the October 6, 2018 crash

Decedent experienced pre-impact terror, pain and suffering prior to his death.

74. By reason of the foregoing acts and omissions by the Hussain

Defendants and Scott T. Lisinicchia in knowingly placing and driving a dangerous

and defective limousine on public roadways, Defendants acted with reckless

indifference to the health and safety of others.

75. Based on the grossly negligent, willful misconduct and complete

indifference exemplified by the Hussain Defendants and Scott T. Lisinicchia, and

their conscious disregard for the health and safety of the public, Plaintiffs demand

an award of punitive and exemplary damages.

76. By reason of the facts stated above, Plaintiffs have been damaged in

a sum of money which exceeds the jurisdictional limits of all lower courts that

would otherwise have jurisdiction over this matter.

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SECOND CAUSE OF ACTION


(Negligence/Gross Negligence/Pain and Suffering against Apple Barrel)

77. Plaintiffs repeat and reallege each of the allegations set forth in

paragraphs 1 through 76, as though fully set forth herein.

78. Apple Barrel had a duty to exercise reasonable care in connection

with its ownership, maintenance and/or control of its premises and parking lot for

use by the general public, including a duty to Decedent and Jaclyn Schnurr to

ensure that the parking lot of Apple Barrel was not dangerous to its customers and

to the public.

79. Apple Barrel had actual and/or constructive notice that vehicles had

previously gone through the stop sign at the bottom of the hill at the intersection of

State Routes 30 and 30A at a high rate of speed and crossed into Apple Barrel's

parking lot.

80. Apple Barrel was aware that vehicles had previously entered its

parking lot traveling in an out of control manner, and at a speed that was

dangerous to customers and vehicles that were located in the parking lot.

81. Apple Barrel failed to exercise reasonable care in the ownership,

maintenance, operation and/or control of its parking lot by knowingly allowing a

dangerous condition to persist in its parking lot, failing to place barricades,

ballards, or some other safety device to prevent vehicles from entering the parking

lot in an out of control manner, failing to post any signage informing its patrons not

to park in the area of the parking lot directly across from the intersection of State

Routes 30 and 30A and failing to block off that portion of the parking lot to prevent

patrons from parking there.

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82. Apple Barrel's negligence was the proximate cause of Decedent's

physical, mental and emotional injuries and harm, including conscious pain and

suffering.

83. As a result of the October 6, 2018 crash, Decedent sustained a

"serious"
injury as that term is defined in Subdivision (d) of Section 5102 of the

Insurance Law of the State of New York.

84. The accident, personal injuries and death sustained by Decedent

were proximately caused by the negligence and/or gross negligence of Apple

Barrel, its agents, employees, or other individuals under its control, without any

negligence contributing thereto on the part of Decedent.

85. Upon information and belief, as a result of the October 6, 2018 crash

Decedent experienced pre-impact terror, pain and suffering prior to his death.

86. By reason of the foregoing acts and omissions by Apple Barrel in

knowingly allowing a dangerous and defective condition to persist in its parking lot,

it acted with reckless indifference to the health and safety of others.

87. By reason of the facts stated above, Plaintiffs have been damaged in

a sum of money which exceeds the jurisdictional limits of all lower courts that

would otherwise have jurisdiction over this matter.

THIRD CAUSE OF ACTION


(Negligence/Gross Negligence/Pain and Suffering against Mavis)

88. Plaintiffs repeat and reallege each of the allegations set forth in

paragraphs 1 through 87, as though fully set forth herein.

89. Mavis has a duty to exercise reasonable care in connection with its

inspection, maintenance and repair of the vehicles it services for use by the

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general pub!ic, including a duty to Decedent, to ensure that the limousine would

not be rendered dañÿerous and result in harmful injuries or death.

90. Mavis did not have the authority to inspect an 18 passenger common

carrier vehicle nor did it have any employee with the necessary qualifications to

inspect such a vehicle.

91. Despite knowing that it lacked authority to inspect the limousine, it

agreed to inspect it and undertook the inspection of said vehicle.

92. Mavis negligently failed to observe open and obvious defects of the

limousine during its inspection.

93. Upon information and belief, Mavis created the dangerous condition

or had actual and/or constructive notice that it was illegally inspecting the

limousine in May, 2018, and failed to properly inspect and repair the limousine on

numerous other occasions, that the limousine had significant and serious defects

and that the limousine was both illegal and dangerous if placed on the public

roadways without proper repairs and/or maintenance.

94. Mavis failed to exercise reasonable care in the inspection,

maintenance, and/or repair of the limousine, and further breached its duty to

Decedent in knowingly placing a limousine on public roadways, which was not

properly licensed, had not been properly inspected, had failed inspections, and

had significant and serious defects, all without performing the legally required and

necessary repairs and/or maintenance.

95. Mavis's negligence was the proximate cause of Decedent's physical,

mental, and emotional injuries and harm, including conscious pain and suffering.

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96. As a result of the October 6, 2018 crash, Decedent sustained a

"serious"
injury as that term is defined in Subdivision (d) of Section 5102 of the

Insurance Law of the State of New York.

97. The accident, personal injuries and death sustained by Decedent

were proximately caused by the negligence and/or gross negligence of Mavis, its

agents, employees, or other individuals under its control, without any negligence

contributing thereto on the part of Decedent.

98. Upon information and belief, as a result of the October 6, 2018

crash, Decedent experienced pre-impact terror, pain and suffering prior to his

death.

99. By reason of the foregoing acts and omissions by Mavis in knowingly

conducting illegal inspections of the limousine and knowingly placing a dangerous

and defective vehicle on public roadways, Mavis acted with reckless indifference

to the health and safety of others.

100. Based on the grossly negligent, willful misconduct and complete

indifference exemplified by Mavis, and its conscious disregard for the health and

safety of the public, Plaintiffs demand an award of punitive and exemplary

damages.

101. By reason of the facts stated above, Plaintiffs have been damaged in

a sum of money which exceeds the jurisdictional limits of all lower courts that

would otherwise have jurisdiction over this matter.

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FOURTH CAUSE OF ACTION


(Wrongful Death against the Hussain Defendants, the Estate of Scott

Lisinicchia, Mavis and Apple Barrel)

102. Plaintiffs repeat and reallege each of the a!!egations set forth in

paragraphs 1 through 101, as though fully set forth herein.

103. Decedent died as a direct result of his injuries sustained in the

October 6, 2018 accident.

104. At the time of his death, Decedent left his surviving family, kin and

heirs at law for whose benefit this claim is connected, including his wife and young

son.

105. Prior to his death, Decedent was a healthy 46-year-old man who

attended to and was able to perform his usual personal and employment duties,

including working as a college professor. Decedent contributed to the support of

his family, and by virtue of his wrongful death, his family was deprived of his

comfort, society, services and support.

106. By reason of Decedent's death, Plaintiffs have incurred costs and

expenses in connection with funeral, burial, and related arrangements, and will

incur additional administration expenses and other expenses in the settlement of

the Decedent's estate.

107. By reason of the foregoing, the next of kin of Decedent, including

Jaclyn Schnurr and her son, have been damaged in a sum of money which

exceeds the jurisdictional limits of all lower courts that would otherwise have

jurisdiction of this matter.

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FIFTH CAUSE OF ACTION


(Extreme Emotional Distress suffered by Jaclyn Schnurr against the Hussain

Defendants, the Estate of Scott Lisinicchia, Mavis and Apple Barrel)

108. Plaintiffs repeat and reallege each of the allegations set forth in

paragraphs 1 through 107, as though fully set forth herein.

109. Plaintiff Jaclyn Schnurr has suffered ongoing emotional distress

resulting from the trauma caused by witnessing the death of Decedent and her

father on October 6, 2018, as well as from the fear of impending death resulting in

conscious pain and suffering, discomfort, disability, mental and emotional suffering

Defendants'
and medical expenses caused by negligence, gross negligence,

recklessness and carelessness.

110. Plaintiff Jaclyn Schnurr has and continues to suffer emotional

distress from witnessing the death of Decedent (her husband) and father, who

were standing just a couple of feet from her before being violently struck by the

limousine and killed.

111. By reason of the foregoing, Jaclyn Schnurr has been damaged in a

sum of money which exceeds the jurisdictional limits of all lower courts that would

otherwise have jurisdiction of this matter.

WHEREFORE, Plaintiffs Jaclyn Schnurr as Administratrix of the Estate of

Brian G. Hough, and individually, demand judgment against the Defendants as

follows:

a) On the first, second and third causes of action for negligence/gross

negligence/conscious pain and suffering, in a sum of money that exceeds

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the jurisdictional limits of all lower courts that would otherwise have

jurisdiction of this matter;

b) On the fourth cause of action for wrongful death, in a sum of money that

exceeds the jurisdictional limits of all lower courts that would otherwise

have jurisdiction of this matter;

c) On the fifth cause of action for extreme emotional distress, that was

traumatic and is ongoing, in a sum of money that exceeds the jurisdictional

limits of all lower courts that would otherwise have jurisdiction of this matter;

Defendants'
d) Punitive and exemplary damages by reason of wanton,

reckless and gross negligence;

e) Together with the costs and disbursements of this action; and

f) And such other and further relief as this Court deems just and proper.

Dated: September 17, 2019 THE WOLFORD LAW FIRM LLP

J/ JÊ. -

Michael R. Wolford, Esq.


Laura M. Myers, Esq.

Victoria S. Gleason, Esq.


Attorneys for Plaintiffs Jaclyn

Schnurr, and Estate of Brian


Hough by Jaclyn Schnurr as
Administratrix

600 Reynolds Arcade Building


16 East Main Street

Rochester, New York 14614


Telephone: (585) 325-8000
Emails:mwolford@wolfordfirm.com
Imyers@wolfordfirm.com
vqleason@wolfordfirm.com

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