Defendants, RAISER-NY LLC D/B/A UBER TECHNOLOGIES, INC., by and through their attorneys, WOOD, SMITH, HENNING & BERMAN LLP, as and for their Verified Answer to the Complaint, respond, upon information and belief, as follows:

Uber alleges that the Plaintiff’s claims for punitive damages violate, and are therefore barred by, the Fourth, Fifth, Sixth, Eighth, and Fourteenth Amendments of the United States Constitution.

Answering Defendants, under General Business Obligations Law § 15-108, seeks an offset for the amount of any settlements reached with any other tortfeasor(s) related to the accident at issue in this case, irrespective of whether that party is named herein.

WHEREFORE, Answering Defendants, RAISER-NY LLC D/B/A UBER TECHNOLOGIES, INC., demands judgment dismissing the Plaintiff’s Complaint herein, together with fees, costs and disbursements herein incurred in the defense of this action, and such other and further relief which the Court deems just and proper.

The reason this verification is made by the undersigned is because said Defendants' representative was not present within New York County wherein my offices were maintained at the time the answer was prepared.

That at all times hereinafter mentioned, the aforementioned automobile insurance contained a provision policy Uninsured Motorist Coverage."

That at all times hereinafter mentioned, the aforementioned automobile insurance policy provided or afforded uninsured/supplementary motorist benefits/coverage in the amount currently unknown.

Lux Credit Consultants LLL and operated by Makeunder Rahmanwith New York license number T807771C("the host vehicle").

That the plaintiff, has complied with all terms and conditions regarding underinsured motorist benefits under the aforementioned policy of insurance issued by defendants.

That this action is brought pursuant to the insurance policy issued to RASIER-NY LLC d/b/a UBERTECHNOLOGIES,INC, to recover uninsured motorist defendants on the behalf of the Plaintiff, BOBACARFADIGA.

is over 18 years of age and resides That on 11/12/2024 at 10:14 AMat 123 William Street, 2nd FL NewYork, NY 10038 the office of the Secretary Of State, the State of NewYork, deponent served Summonsand Complaint with Notice of Commencementof Action Subject to Mandatory Electronic Filing on OLEREPUBLICINSURANCECOMPANY (Defendant/Respondent) is not a party to this action, of Said service was effected in the following manner; to and leaving with Lorna Tate a copy of said Summonsand Complaint with Notice of Commencement By delivering of Action Subject and that at to Mandatory Electronic the time of making such service, deponent paid the Filing of State the sumof $10.00, such service: that being the lawful fee of the Secretary of the State for accepting Secretary further says that such service was madepursuant to Sec.

253/254 N. Y. S. VTL Law of the State of NewYork and deponent the said Lorna Tate was designated of State and person authorized that by law to accept service in clerk of the Secretary such cases.

Description: Gender: Female Brown Other: Race/Skin: Black Age: 37 Weight: 161-200 Lbs.

Height: 5ft4in-5ft8in Hair: I affirm on this day November 12 2024 , under the penalties of under the laws of NewYork, which mayinclude a fine or imprisonment, perjury the foregoing is true, and I understand that this document maybe filed in that an action or proceeding in a court of law.

1188546 2464358 Server's JoblD# Lic p "

is over 18 years of age and resides at 3:15 PMat 28 LIBERTY STREET, NEWYORK,NY10005, Deponent served the within Summons That on 11/11/2024, and Complaint with Notice of Commencementof Action Subject to Mandatory Electronic the index ,with Filing number and the filing date of the action were endorsed upon the face of the papers so served herein.

is not a party to this action, to and leaving a true copy with SamWeber said individual to accept service on behalf of the Corporation/Government to be Authorized Agent whospecifically A description Agency/Entity/Partnership.

stated he/she was of SamWeber is as By delivering authorized follows: Sex: Male Height: Color of hair: Brown Age: 32 Color of skin: White Weight: 161-200 Lbs.

Other 5ft9in-6ft0in : I affirm on this day November 12 2024 under the laws of NewYork, which perjury s true, and I un erst the foregoin that an act or p ceeding in a s law.

rt , under the penalties of a fine or imprisonment, y3include th (this document maybe filed in

is over 18 years of age and resides at 3:15 PMat 28 LIBERTY STREET, NEWYORK,NY10005, Deponent served the within Summons That on 11/11/2024, and Complaint with Notice of Commencementof Action Subject to Mandatory Electronic the index ,with Filing number and the filing date of the action were endorsed upon the face of the papers so served herein.

is not a party to this action, to and leaving a true copy with SamWeber said individual to accept service on behalf of the Corporation/Government to be Authorized Agent whospecifically A description Agency/Entity/Partnership.

stated he/she was of SamWeber is as By delivering authorized follows: Sex: Male Height: Color of hair: Brown Age: 32 Color of skin: White Weight: 161-200 Lbs.

Other 5ft9in-6ft0in : I affirm on this day November 12 2024 under the laws of NewYork, which perjury s true, and I un erst the foregoin that an act or p ceeding in a s law.

rt , under the penalties of a fine or imprisonment, y3include th (this document maybe filed in