• UN) 1:71 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF THE BRONX x WILLIAM GUTIERREZ SUMMONS Plaintiff, -against- Index No.: THE CITY OF NEW YORK; NEW YORK CITY POLICE PENSION FUND; WILLIAM J. BRATTON, as Police Commissioner and Chairman of the Board of Trustees of the New York City Pension Fund; ROSEMARY DeBELLIS, as Chairperson, Board of Trustees, New York City Police Pension Fund; RUBY MARIN-JORDAN, ESQ., as Trustee, New York City Police Pension Fund; CAROLYN WOLPERT, as Trustee, New York City Police Pension Fund; SUSANNAH VICKERS, as Trustee, New York City Police Pension Fund; JACQUELINE GOLD, as Trustee, New York City Police Pension Fund; JOHN DORSA, as Trustee, New York City Police Pension Fund and ANTONIO RODRIGUEZ, as Trustee, New York City Police Pension Fund each being sued individually in their official capacities as employees of defendant THE CITY OF NEW YORK and NEW YORK CITY POLICE PENSION FUND Defendants' x N) To the above-named defendants' THE CITY OF NEW YORK; NEW YORK CITY POLICE — PENSION FUND; WILLIAM J. BRATTON; ROSEMARY DeBELLIS; RUBY MARIN- JORDAN, ESQ.; CAROLYN WOLPERT; SUSANNAH VICKERS; JACQUELINE GOLL), — JOHN DORSA and ANTONIO RODRIGUEZ: You are hereby summoned and required to serve upon plaintiff's attorney, at the address stated below, an answer to the attached Verified Complaint. If this summons was personally served upon you by the State of New York, the answer must be served within twenty days after such service of the summons, excluding the date of service. If the summons was not personally delivered to you within the State of New York, the answer must be served within thirty days after service of the summons is complete as provided SI AZ 83S 12 by law. Lt
Retired NYPD Captain William Gutierrez sues the New York City Police Pension Fund alleging he has been discriminated against due to his race, national origin and retaliated against
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•
UN)
1:71
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF THE BRONX
x WILLIAM GUTIERREZ
SUMMONS Plaintiff,
-against- Index No.:
THE CITY OF NEW YORK; NEW YORK CITY POLICE PENSION FUND; WILLIAM J. BRATTON, as Police Commissioner and Chairman of the Board of Trustees of the New York City Pension Fund; ROSEMARY DeBELLIS, as Chairperson, Board of Trustees, New York City Police Pension Fund; RUBY MARIN-JORDAN, ESQ., as Trustee, New York City Police Pension Fund; CAROLYN WOLPERT, as Trustee, New York City Police Pension Fund; SUSANNAH VICKERS, as Trustee, New York City Police Pension Fund; JACQUELINE GOLD, as Trustee, New York City Police Pension Fund; JOHN DORSA, as Trustee, New York City Police Pension Fund and ANTONIO RODRIGUEZ, as Trustee, New York City Police Pension Fund each being sued individually in their official capacities as employees of defendant THE CITY OF NEW YORK and NEW YORK CITY POLICE PENSION FUND
Defendants' x
N)
To the above-named defendants' THE CITY OF NEW YORK; NEW YORK CITY POLICE—PENSION FUND; WILLIAM J. BRATTON; ROSEMARY DeBELLIS; RUBY MARIN-JORDAN, ESQ.; CAROLYN WOLPERT; SUSANNAH VICKERS; JACQUELINE GOLL),— JOHN DORSA and ANTONIO RODRIGUEZ:
You are hereby summoned and required to serve upon plaintiff's attorney, at the address
stated below, an answer to the attached Verified Complaint.
If this summons was personally served upon you by the State of New York, the answer
must be served within twenty days after such service of the summons, excluding the date of
service. If the summons was not personally delivered to you within the State of New York, the
answer must be served within thirty days after service of the summons is complete as provided
SI AZ 83S 12 by law. Lt
If you do not serve an answer to the attached complaint within the applicable time
limitation stated above, a judgment may be entered against you, by default, for the relief
demanded in the complaint, without further notice to you.
The action will be heard in the Supreme Court of the State of New York, in and for the
County of the Bronx, 851 Grand Concourse, Bronx, N.Y. 10451. This action is brought in the
County of the Bronx because the defendant's actions occurred in the County of the Bronx.
Dated: September 11, 2015 New York, NY
Respectfully submitted,
By: Eric Sanders
Eric Sanders, Esq. THE SANDERS FIRM, P.C. 230 Park Avenue, Suite 1000 New York, NY 10169 (212) 808-6515 (Business Telephone) (212) 729-3062 (Facsimile)
Website: http://www.thesandersfirmpc.com
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF THE BRONX
WILLIAM GUTIERREZ x
VERIFIED COMPLAINT Plaintiff,
-against- Index No.: „1014
THE CITY OF NEW YORK; NEW YORK CITY POLICE PENSION FUND; WILLIAM J. BRATTON, as Police Commissioner and Chairman of the Board of Trustees of the New York City Pension Fund; ROSEMARY DeBELLIS, as Chairperson, Board of Trustees, New York City Police Pension Fund; RUBY MARIN-JORDAN, ESQ., as Trustee, New York City Police Pension Fund; CAROLYN WOLPERT, as Trustee, New York City Police Pension Fund; SUSANNAH VICKERS, as Trustee, New York City Police Pension Fund; JACQUELINE GOLD, as Trustee, New York City Police Pension Fund; JOHN DORSA, as Trustee, New York City Police Pension Fund and ANTONIO RODRIGUEZ, as Trustee, New York City Police Pension Fund each being sued individually in their official capacities as employees of defendant THE CITY OF NEW YORK and NEW YORK CITY POLICE PENSION FUND
Defendants'
T
N.)
CJ1 C.J1
x
The plaintiff WILLIAM GUTIERREZ by his attorney THE SANDERS FIRM, P.C., as
and for his verified complaint against defendants' THE CITY OF NEW YORK; NEW YORK
CITY POLICE PENSION FUND; WILLIAM J. BRATTON; ROSEMARY DeBELLIS; RUBY
WOLPERT; SUSANNAH VICKERS; JACQUELINE GOLD; JOHN DORSA and ANTONIO
RODRIGUEZ jointly and severally, in an amount to be determined at trial, plus any all available
statutory remedies, both legal and equitable, and interests and costs.
Dated: September 11, 2015 New York, NY
Respectfully submitted,
By: Eric Sanders
Eric Sanders, Esq. THE SANDERS FIRM, P.C. 230 Park Avenue, Suite 1000 New York, NY 10169 (212) 808-6515 (Business Telephone) (212) 729-3062 (Facsimile)
Website: http://www.thesandersfirmpc.com
11
ATTORNEY VERIFICATION
STATE OF NEW YORK ss:
COUNTY OF NEW YORK
ERIC SANDERS, ESQ., affirms as follows:
I am an attorney at law admitted to practice in the Courts of the State of New York, and I
am the attorney for the plaintiff in the within action, and as such, am familiar with all the facts
and circumstances therein.
That the foregoing Verified Complaint is true to the knowledge of affirmant, except as to
those matters therein stated to be alleged upon information and belief, and that as to those
matters he believes it to be true.
Affirmant further states that the reason that this verification is made by affirmant and not
by plaintiff is that plaintiff is not within the county of New York, where affirmant maintains his
office.
Affirmant further states, that the sources of his knowledge and information are reports of
investigations, conversations, writings memoranda and other data concerning the subject matter
of the litigation.
The undersigned attorney affirms that the foregoing statements are true, under the
penalties of perjury and pursuant to Rule 2106 CPLR.
Dated: September 11, 2015 New York, NY
Respectfully submitted,
By: Eric Sanders
Eric Sanders, Esq. THE SANDERS FIRM, P.C. 230 Park Avenue, Suite 1000 New York, NY 10169 (212) 808-6515 (Business Telephone) (212) 729-3062 (Facsimile)
Website: http://www.thesandersfirmpc.com
Index No.:
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF THE BRONX
WILLIAM GUTIERREZ
Plaintiff,
-against-
THE CITY OF NEW YORK; NEW YORK CITY POLICE PENSION FUND; WILLIAM J. BRATTON, as Police Commissioner and Chairman of the Board of Trustees of the New York City Pension Fund; ROSEMARY DeBELLIS, as Chairperson, Board of Trustees, New York City Police Pension Fund; RUBY MARIN-JORDAN, ESQ., as Trustee, New York City Police Pension Fund; CAROLYN WOLPERT, as Trustee, New York City Police Pension Fund; SUSANNAH VICKERS, as Trustee, New York City Police Pension Fund; JACQUELINE GOLD, as Trustee, New York City Police Pension Fund; JOHN DORSA, as Trustee, New York City Police Pension Fund and ANTONIO RODRIGUEZ, as Trustee, New York City Police Pension Fund each being sued individually in their official capacities as employees of defendant THE CITY OF NEW YORK and NEW YORK CITY POLICE PENSION FUND
Defendants'
VERIFIED COMPLAINT
Duly submitted by: Eric Sanders, Esq. Attorney for Petitioner WILLIAM GUTIERREZ THE SANDERS FIRM, P.C. 230 Park Avenue, Suite 1000 New York, NY 10169 (212) 808-6515 (Business Telephone) (212) 729-3062 (Facsimile)
To: Attorney(s) for:
Dated:
Sir(s): Please take notice that the legal papers within is/are certijLd ow3 and original under the jurisdiction referenced above and are properly submittedfiled by the respeciive counsel so referenced.