WHEREFORE, Defendants, MICHAEL A. URCIUOLI and GOOD SHEPHERD SERVICES, demand judgment dismissing the cross-complaint together with the costs and disbursements of this action.

Jessica Peterson, Esq. Law Office of Dennis C. Bartling Attorneys for Defendant

That I am not a party to the within action, am over 18 years of age and reside in Staten Island, New York.

That on the 3rd day of August, 2023, deponent served the within ANSWER TO CROSS- COMPLAINT Via NYSCEF and Via E-mail upon the attorneys and parties listed below:

┌─┐ that the within is a (certified) true copy of a └─┘ entered in the office of the clerk of the within named Court on

Index No.: Date Filed: Plaintiff, by her attorneys, LAW OFFICES OF DANIEL CHAVEZ, P.C. complaining of the defendants MICHAEL A. URCIUOLI, GOOD SHEPHERD SERVICES, and LOURDES M. LORA, alleges upon information and belief as follows:

That as a result of the foregoing, plaintiff MARY GRACE HERNANDEZ suffered a serious injury as defined in Section 5102(d) of the Insurance Law of the State of New York.

That as a result of the foregoing, plaintiff MARY GRACE HERNANDEZ sustained serious, severe and permanent personal injuries and was rendered sick, sore, lame, and disabled; plaintiff MARY GRACE HERNANDEZ was caused to suffer great pain, discomfort, and disability and, upon information and belief, will continue to suffer pain, discomfort, and disability in the future; plaintiff MARY GRACE HERNANDEZ was caused to undergo hospital and medical care, aid and attention, and upon information and belief, may continue to require to undergo medical care, aid and attention for a long period of time to come in the future; plaintiff MARY GRACE HERNANDEZ was obliged to expend and incur large sums of monies for medical care, aid and attention and, upon information and belief, will continue to be obliged to expend and incur large sums of monies for future medical care, aid and attention; plaintiff MARY GRACE HERNANDEZ was caused to become incapacitated from her usual vocation and avocation, and upon information and belief, may continue to be caused to remain away from her usual vocation and avocation for a long period of time to come in the future.

WHEREFORE, plaintiff MARY GRACE HERNANDEZ demands a money judgment against the defendants MICHAEL A. URCIUOLI, GOOD SHEPHERD SERVICES, and LOURDES M. LORA, together with the costs and disbursements of this action.

Daniel Chavez, an attorney duly admitted to practice law before the Courts of the State of New York affirms the truth of the following under penalties of perjury: I am a member of the firm of LAW OFFICES OF DANIEL CHAVEZ, P.C., attorneys of record for MARY GRACE HERNANDEZ, the Plaintiff in the within action; I have read the foregoing VERIFIED COMPLAINT and know the contents thereof; the same is true to my own knowledge except as to those matters said to be upon information and belief and as to those matters I believe them to be true.