Plaintiff summons defendants for negligence resulting in serious injury.

Summons & Complaint

SUPREME COURT: NEW YORK STATE

COUNTY OF WARREN

IESHA JACKSON, Plaintiff

-against-

HANNAH SMITH and JOY REYNOLDS, Defendants.

SUMMONS

Index No.: 
Date Purchased: 
Plaintiff designates Warren County as the place of trial. 

The basis of the venue is the residence of Plaintiff

Plaintiff resides at 420 Canada St

Lake George, NY 12845-1100




To the above-named Defendants:

YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff's Attorney 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); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint.

Dated: July 30, 2025

Kingston, New York

COMPLAINT

The Plaintiff, lesha Jackson, as and for her Complaint, Complaining of the Defendants, Hannah Smith and Joy Reynolds, does hereby respectfully allege and show to the Court the following:

PARTIES

1. At all times hereinafter alleged, the Plaintiff, lesha Jackson, was a resident of 420 Canada Street, Lake George, New York.

2. Upon information and belief, at all times hereinafter alleged, the Defendant, Hannah Smith, was a resident of 18 Meadow Lane, Rensselaer, New York.

3. Upon information and belief, at all times hereinafter alleged, the Defendant, Joy Reynolds, was a resident of 8 A Spyglass Hill, Clifton Park, New York.

4. At all times hereinafter alleged, the Plaintiff, Iesha Jackson, was a passenger in a 2018 Chevy Suburban.

5. Upon information and belief, the Defendant, Hannah Smith, was operating a 2012 Ford, bearing New York State License Plate Number AND3084, for the then current period of registration.

6. Upon information and belief, the Defendant, Joy Reynolds, was the registered owner of the 2012 Ford.

7. Upon information and belief, the Defendant, Hannah Smith, was operating the 2012 Ford, with the permission or consent, whether implied or expressed, of the Defendant, Joy Reynolds.

8. At all times hereinafter alleged, and specifically on, April 21, 2025, the Defendant, Hannah Smith, owed the Plaintiff a duty of reasonable care.

9. On April 21, 2025, the Defendant, Hannah Smith, breached her duty of care by failing to operate her vehicle in a reasonably safe manner.

10. Upon information and belief, Quaker Road and Upper Glen Street in the Town of Queensbury, Warren County, New York were public thoroughfares.

11. As a result of the Defendant's negligence, the Plaintiff, lesha Jackson, sustained "serious injury" as that term is defined by New York State's Insurance Law.

12. The Defendant, Joy Reynolds, is vicariously responsible for the negligent acts committed by Hannah Smith, on April 21, 2025, pursuant to common law principles of vicarious liability and New York State's Vehicle and Traffic Law.

13. The Defendants, Hannah Smith and Joy Reynolds, are jointly and severally liable to the Plaintiff for her injuries.

WHEREFORE the plaintiff demands judgement against the Defendants in an amount that exceeds the monetary jurisdictional limits of this or any other Court, together with the costs and disbursements of this action, attorney's fees, and all such other and further relief as this Court deems just and proper.

Dated: July 30, 2025

Kingston, NY 12401

NEW YORK INJURY LAW, LLP

/s/ John DeGasperis, Esq.

John DeGasperis, Esq.

New York Injury Law, LLP Attorney for Plaintiff

326 Washington Ave, Suite 2

PO Box 3037 Kingston, New York 12402

Tel: 845-777-9467

Email: jad@newyorkinjurylaw.net

PUB: MARCH 26, APRIL 2, 9, 16, 2026 

COL-NY-4086