STATE OF NEW YORK SUPREME COURT: COUNTY OF RENSSELAER GUARDIAN ANGEL SERVICE DOGS, INC., Plaintiff, DCO! -against- Index No. MICHELLE NINSTANT a/l/a MICHELLE A. JOHNSON, Defendant. Plaintiff, complaining of the above entitled defendant, by its attomey, James Kleinbaum, Esq, alleges: 1, Plaintiff GUARDIAN ANGEL SERVICE DOGS, INC, is a foreign corporation doing business in the County of Rensselaer, State of New York. 2. Upon information and belief, the defendant, MICHELLE NINSTANT, is an individual residing in the County of Rensselaer and State of New York, and that the instant causes of action are based upon trained service dog delivered. AS AND FOR A FIRST CAUSE OF ACTION 3. Onor about December 11, 2012, an account was stated in the amount of $14,058.82. 4. No part thereof has been paid although duly demanded, and there is now due and ‘owing from the defendant, to the plaintiff, the sum of $14,058.82, together with interest thereon from December 11, 2012.AS AND FOR A SECOND CAUSE OF ACTION 5. Plaintiff has provided a trained service dog to the defendant with a value of $14,058.82, ©. Defendant accepted said trained service dog, and has failed to pay forthe trained service dog that she received, 7. ‘The defendant has been unjustly enriched by the said trained service dog by the plain CAUSE 8. On or about July 30, 2012 the defendant, MICHELLE NINSTANT, entered into ‘signed contract with plaintiff, agreeing to pay for trained service dog. 9% Defendant breached the contract with Plaintiff by failing to perform to the terms (of said contract to pay for the trained service dog. Plaintiff substantially performed all of their obligations under the contract 10, Said breach caused Plaintiff to be damaged in the amount of Fourteen Thousand, Fifty Bight and 82/100 ($14,058.82) Dollars. WHEREFORE, plaintiff demands judgment as follows: On the first Cause of Action inthe amount of $14,058.82 together with interest running thereon from December 11, 2012 in addition to the costs, disbursements, and reasonable attomey’s fees of this action.: : STATE OF NEW YORK SUPREME COURT: COUNTY OF RENSSELAER GUARDIAN ANGEL SERVICE DOGS, INC, PO Box 647, Madison, VA 22727 Plaintiff, SUMMONS sayin Index No: S4493D . JOHNSON, Defendant. To the above named defendant: ‘Youare hereby summoned and required to serve upon plaintif's attomey an answer to ‘he complaint in this action within twenty days after the service of this summons, exclusive of the Gey of service, or within thirty days after service is complete if his summons is not personally delivered to you within the State of New York, In case of your failure to answer, judgment will be taken against you by default forthe relief demanded in the complaint The basis of the venue designated is the primary place of business of the plaintiffs attomey which is 18 Park Row, Chatham, New York 12037. Dated: October 10, 2013 1am, New York 12037 (818)794-8708