Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 1 of 15

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF NEW YORK

JOHN G. ROBERTS, JR, and ) CASE NO

CAROLE ANN ROBERTS, as AdministratOls ofthe )
Estate of JOHN G. ROBERTS, III, Deceased ) COMPLAINT
)
) JURY TRIAL
Plaintiffs, ) DEMANDED
)
)
Y.. )
)
CONTINENTAL AIRLINES, INC.; )
PINNACLE AIRLINES CORP . ; )
COLGAN AIR, INc..; BOMBARDIER )
AEROSPACE CORPORATION, )
)
Defimdants. )
)

COMPLAINT

The Plaintiffs, John G. Roberts, JI. and Carole Ann Roberts, as Administrators of the

Estate of John G. Roberts, III, Deceased, by their attorneys, Lewis & Lewis, P .c.., for their

complaint against the defendants herein, allege as follows:

PARTIES

L Plaintiff, John G. Roberts, Jr, is a resident and a citizen of New YOlk State and

was duly appointed Co-AdministratOl of the Estate of John G. Roberts, III, Deceased, by the

Niagara County Surrogate's Court on the 30 th day ofJuly, 2009 .

 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 2 of 15

2 Plaintiff Carole Ann Roberts, is a resident and a citizen of New York State and

was duly appointed Co-Administrator of the Estate of John G. Roberts, III, Deceased, by the

Niagara County Surrogate's Court on the 30 th day ofJuly, 2009.

3.. The decedent, John G. Roberts, III, died in an airplane crash on February 12, 2009

in Clar·ence, New York.

4. The Plaintiffs, Co-Administrators of the Estate ofJohn G. Roberts, III, bring this

action as Co-Administrators and personal representatives of the Estate of John G. Roberts, III,

Deceased, and on behalf of each and every beneficiary, survivor and heir of John G. Roberts, III,

Deceased.

5.. Defendant, Continental Airlines, Inc . (hereinafter "Continental"), is a corporation

organized under the laws of the State of Delaware, with its principal place of business located in

Houston, TX. Continental is licensed to conduct business and does conduct business in the State

of New York The agent for service of process on Continental is CT Corporation Systems, 111

Eighth Avenue, New York, NY 1001 L

6. The Defendant, Pinnacle Airlines Corp. (hereinafter "Pinnacle"), is a corporation

organized under the laws of the State of Delaware with its principal place of business located in

Memphis, TN. Pinnacle is licensed to conduct business in the State of New York and does

conduct business in the State of New York The agent for service of process on Pinnacle is CT

Corporation Systems, 800 S . Gay Street, Suite 2021, Knoxville, TN 37929-9710

7. The Defendant, Colgan Air, Inc., (hereinafter "Colgan"), is a corporation

organized under the laws of the State of Virginia, with its principal place of business located in

Manassas, VA Colgan is licensed to conduct business in the State of New York and does
 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 3 of 15

conduct business in the State of New York The agent for seIvice of process on Colgan is CT

Corporation Systems, 111 Eighth Avenue, New York, NY 10011

8. The defendant, Bombardier Aerospace Corporation, (hereinafter "Bombardier"),

is a corporation organized under the laws of the State of Texas and maintains its principal place

of business in Quebec, Canada. Bombardier is licensed to conduct business in the State of New

York and does conduct business in the State of New York The agent for service of process on

Bombardier is CT Corporation Systems, 350 N . S1. Paul Street, Dallas, TX 75201

JURISDICTION AND VENUE

9.. This Court has jurisdiction over this action pursuant to 28 U.SC §1332(a)(l)..

The matter in controversy exceeds the sum of$75,000 . 00, exclusive of interest and costs .

10.. Venue is proper based on 28 USc. §1391(a) because a substantial part of the

events or omissions giving rise to the claim occurred in this Judicial District. The plaintiffs and

the decedent were and are residents of this Judicial District. All defendants conduct business in

this Judicial District

COMMON ALLEGATIONS OF FACT

11 . At all times relevant hereto, Defendants Continental, Pimrac1e, and Colgan were

common carriers for hire

12.. On or before February 12, 2009, Defendants, Colgan andlor Pinnacle andlor

Continental owned, managed, maintained, scheduled, supervised and operated a Bombardier

Dash 8-Q400 twin-engine turboprop airplane bearing a registration number of N200WQ.

(Hereinafter refeued to as "aircraft").

13 On February 12, 2009 the Defendant Colgan andlor the Defendant Continental

operated the above-referenced aircraft, as Colgan Air Flight 3407 d/b/a Continental Flight 3407,
 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 4 of 15

as a scheduled flight flam Newark Liberty International Airport, located at Newark, New Jersey,

to Buffalo Niagara International Airport located in Buffa!o, New York.

14. Flight 3407 was marketed as Continental Flight 3407 under the Continental brarrd

arrd Defendarrt, Colgarr, operated said aircraft under the name "Continental Connection" .

15.. At all times mentioned hereafter, Defendarrt Colgarr, operated under the name

"Continental Connection" under a contractual agreement with Defendarrt, Continental.

16 On February 12, 2009, Plaintiffs decedent, John G. Roberts, III, was a fiue-

paying passenger onboard Flight 3407.

17.. Upon information arrd belief, at all times hereinafter mentioned, Defendarrts,

Pinnacle arrd Colgarr had a parent/subsidiary and/or principal/agent relationship.. Defendarrt,

Pinnacle is a parent and/or principal arrd/or alter ego of Colgarr Pinnacle utilizes Colgan to

conduct business in certain areas of the United States, including the State of New York. As a

result of the above, both Pinnacle arrd Colgarr are liable to the Plaintiffs for the crash of Flight

3407 on February 12, 2009 resulting in injury arrd death to the Plaintiffs decedent, John G

Roberts, IlL

18. Upon information arrd belief, the aircraft was purchased by Defendarrt, Pinnacle

flam Defimdarrt, Bombardier arrd was thereafter trarrsferred to Defendarrt, Colgan .

19.. Upon information and belief; on February 12, 2009, Marvin Renslow (hereinafter

"Renslow"), was a resident of the State of Florida, Captain of Flight 3407, arrd arr employee of

the Defendarrt, Colgarr.

20. Upon information arrd belief; on February 12, 2009, Rebecca Shaw (hereinafter

"Shaw"), was a resident of the State of Washington, First Officer of Flight 3407, arrd arr

employee ofthe Defendant, Colgan.

 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 5 of 15

2L On Febrmny 12,2009 at approximately 10:17 p.m., the subject aircraft was flying

on auto-pilot in known icing conditions on its instrument approach to Runway 23 at the Buffhlo

Niagara International Airport when the flight crew lost control of the aircraft

22. At said time and place the flight crew allowed the aircraft to fly too slow which

caused the aircraft's Stall Warning and Protection System to activate .

21 After the flight crew lost control of the aircraft, and in the period of time leading

to the crash, the aircraft flew out of control, rolled, dived and ultimately crashed into a house on

Long Road in Clarence Center, New York. The sudden, violent and unexpected movements of

the aircraft resulted in the passengers onboard the aircraft, including the Plaintiffs' Decedent,

John G., Roberts, III, being sUJ:>iected to forces which caused bodily injmy, pain and suffering,

pre-impact terror, mental anguish, emotional distress and other damages,

24, On and before February 12, 2009, the Defendants, Colgan, Pinnacle and

Continental, owned, controlled, inspected, serviced, maintained, repaired, trained the Pilot and

Flight Crew, monitored, loaded and operated Flight 3407, its aircraft and its component parts,

including but not limited to the de-icing systems, flight control systems, electrical systems and

with the Defendant, Bombardier, wrote and/or approved instructions and warnings for the

aircraft and for the crew of Flight 3407,

25 Defendant Bombardier designed, manufactmed, assembled, inspected, tested,

serviced, maintained, monitored, the subject aircraft and its component parts.,

26 The Defendants actions as described in this complaint were wanton and reckless

and demonstrated a conscious indifference and utter disregard of their effects upon the health and

safety of the passengers on Flight 3407, including the Plaintiffs' Decedent, John G.. Roberts, III,
 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 6 of 15

27, As a direct and proximate result of the acts of the Defendants, the Plaintiffs'

Decedent, John G, Roberts, III, sustained serious injUlies which resulted in his death, and his

beneficiaries, heirs and sUlvivors have incmred funeral, bmial and related expenditmes"

28, As a direct and proximate result ofthe acts of the Defendants, his parents and his

adult siblings, have been damaged and will continue to be damaged and deprived of the

Decedent's services, companionship, guidance, increased inheritance and support in the futme

and have sustained and will continue to sustain other pecuniary loss, as well as other

compensable damages UIIder the applicable Law

29 The Plaintiffs' Decedent, JOM G Roberts, III, was at all times in the exercise of

due care and in no way contributed to or caused his injUlies or death,

COUNT I
NEGLIGENCE - DEFENDANTS CONTINENTAL,
PINNACLE AND COLGAN

30., Plaintiffs repeat and reallege all of the allegations contained above with the same

force and effect as if more fully setforth herein,

31., On or before Febmary 12, 2009, Defendants, Continental, Pinnacle and Colgan by

and through their agents, servants and employees, as cornmon carriers for hire, were obligated to

exercise the highest degree of care and to provide safe transportation to all passengers on Flight

3407,

32., On or before Febmary 12, 2009 notwithstanding their legal duty, the Defendants,

Continental, Pinnacle and Colgan by and through their employees, servants and/or agents,

including but not limited to Renslow and Shaw, breached their legal duty of car'e and acted in a

negligent, reckless and car'eless manner in the following respects:

 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 7 of 15

a. Improperly flew the approach to Runway 23 at the Buffalo-Niagara

International Airport;

b Allowed and caused the aircraft to fly at an inadequate speed and

improperly reacted to the activation of the subject aircraft's Stall Warning and Protection
Systems;

c Failed to propeJly use and operate all available de-icing andlor anti-icing
equipment;

d. Failed to properly monitor ice accumulation during flight;

e Failed to properly and safely operate and control the subject aircraft;

f Negligently caused the subject aircraft to enter an aerodynamic stall;

g Failed to perform all appropriate procedures to accomplish a safe landing;

h. Failed to avoid andlor exit atmospheric icing conditions;

L Allowed an unsafe ice accumulation to develop on the subject aircraft;

J. Failed to properly train its pilots and flight crew;

k. Failed to maintain a sterile cockpit;

L Failed to properly train its pilot and flight crew in low-airspeed awareness;

m. Failed to properly note readings on instrument panel;

n. Negligently hired, supervised, and trained the flight crew of Flight 3407;

o Failed to provide the pilot and flight crew of Flight 3407 with the
necessary information of meteorological conditions;

p Dispatched the subject aircraft into known areas of atmospheric icing

conditions;

q. Failed to provide the pilot and flight crew of Flight 3407 with propel
andlor adequate training as to the proper control, management and response to adverse weather
andlor atmospheric icing conditions;

L Failed to properly train the pilot and flight crew of Flight 3407 regarding
roll anomalies;
 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 8 of 15

s. Failed to avoid atmospheric icing conditions when it was known or should

have been known that the subject aircraft was unsuited for flight in such atmospheric icing
conditions;

t Was otherwise careless, reckless, and negligent

COUNTn
STRICT LIABILITY - DEFENDANT BOMBARDIER

33. Plaintiffs repeat and reallege all of the allegations contained above with the same

force and effect as if more fully setforth herein.

34 At all times hereinafter mentioned, the subject aircraft as Flight 3407 was being

used for its intended and/or reasonably foreseeable purpose.

35 Bombardier manufactured the subject aircraft designated as Flight 3407 and its

component parts, systems, manuals, instructions and warnings were defective and unreasonably

dangerous by reason of defective design and manufacture, and the failure of Defendant,

Bombardier to give adequate and proper warnings of the dangers existing and adequate

instructions regarding the avoidance of such dangers.. The defective and dangerous condition of

the subject aircraft exposed the Plaintiffs' Decedent, John G Roberts, III, and others similarly

situated on Flight 3407 as well as the general public to unreasonable risk of harm and was a

proximate and producing cause of the Plaintiffs' Decedent's injuries, death and damages .

36. The unreasonably dangerous conditions and/or defects include, but are not limited

to, the de-icing system, the pilot's operation manual, the flight control systems, maintenance

manuals and procedures, and the absence of adequate warnings and instructions regarding the

danger. At the time the subject aircraft and its components, maintenance procedures were sold

andlor marketed and/or placed into the str·eam of commerce by the Defendant, Bombardier, such

product was defective and unreasonably dangerous to persons including the Plaintiffs' Decedent,
 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 9 of 15

John G. Roberts, III, who could reasonably be expected to use or benefit fiom them, and which

defective and unreasonably dangerous conditions were, a direct and proximate cause of the

Plaintiffs' Decedent's injuries, death and damages .

37.. The subject aircraft was also defective by reason of the Defendant, Bombardier's

failure to include or place within the subject aircraft adequate or proper warnings andlor

instIUctions as to the dangers associated with the design and foreseeable maintenance and use of

the subject aircraft and how to avoid such dangers, and which defects rendered the subject

aircraft dangerous and a direct and proximate cause of the Plaintiffs' Decedent's injuries, death

and damages.

38.. The defective subject aircraft and inadequate warnings provided by the Defendant

Bombardier was a substantial factor in causing the Plaintiffs' Decedent's injuries, death and

damages.. Therefore, Defendant, Bombardier is strictly liable for Plaintiffs' damages and for the

Decedent's injuries and death.

39 As a direct and proximate result of the Defendant, Bombardier's actions, Flight

3407 crashed causing the death of John G. Roberts, III and resulted in damages to the Plaintiffs,

to the Estate oDohn G. Roberts, III, and to the Decedent's beneficiaries, Mother, Father, siblings

and all other beneficiaries, survivors and heirs under applicable law, as well as causing pre-

impact tenor, pain, suffering, injuries and death to John G Roberts, III. As a result, the

distributees and survivors of John G. Roberts, III, have suffered pecuniary loss, have incurred

funeral expenses and have suffered the loss of pecuniary benefits they had a reasonable right to

expect had John G. Roberts, III, lived, including but not limited to loss of support, guidance, and

assistance, as well as inheritance

 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 10 of 15

COUNT III
RES IPSA LOOUITUR - DEFENDANTS.
CONTINENTAL. PINNCALE AND COLGAN

40.. Plaintiffs repeat and reallege all of the allegations contained above with the same

force and effect as ifmore fully setforth herein.

41.. The Plaintiffs plead the Doctrine of "Res Ipsa Loquitur". The occunence speaks

for itself; that is an event such as the crash of Flight 3407 would not usually occur absent

negligence; the instrumentality being the subject aircraft was within the Defendant's Continental,

Pinnacle and Colgan's exclusive control; and the Plaintiffs' Decedent, John G Roberts, III, did

not contribute to the cause of the crash of Flight 3407 .

42, As a direct and proximate result of the negligence of the Defendants, Continental,

Pinnacle and Colgan, Flight 3407, crashed causing injuries and then death to John G, Roberts, III

and resulted in damages to the PlaintifIs, to the Estate of John G Roberts, III, and to the

Decedent's Mother, Father, siblings and all other beneficiaries, survivors and heirs under

applicable law, as well as causing pre-impact terror, pain, suffering, injuries and death to John G

Roberts, III As a result, the distributees and survivors of John G, Roberts, III, have suffered

pecuniary loss, have incurred funeral expenses and have suffered a loss of pecuniary benefits

they had a reasonable right to expect had John G, Roberts III lived, including but not limited to

the loss of support, guidance, and assistance as well as possible inheritance,

COUNT IV
NEGLIGENCE - DEFENDANT BOMBARDIER

43" Plaintiffs repeat and reallege all of the allegations contained above with the same

force and effect as if more fully setforth herein,

 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 11 of 15

44. Defendant Bombardier negligently designed, marrufactured, tested, the subject

aircraft and its component parts, systems, marruals, instIUctions arrd warnings .

45. Defendarrt Bombardier's negligence was a proximate cause of the crash of Flight

3407 .

46.. Defendarrt Bombardier knew, or in the exercise of reasonable care should have

known, tlrat the subject aircraft arrd its components parts, systems, marruals, instructions arrd

warnings were defective arrd unreasonably darrgerous to tlrose persons likely to use tire subject

aircraft arrd its component parts for tire plUposes arrd for tire marrner in which tlrey were intended

to be used arrd for plUposes reasonably foreseeable to the Defendant Bombardier including the

plUpose for which tire subject aircraft was designated as Flight 3407 on FebIUary 12,2009

47.. Defendarrt Bombardier's negligence was the proximate cause of the Plaintiffs

damages arrd the Decedent's injlUies arrd deatlr .

48.. Defendarrt Bombardier was negligent in tlrat it failed to give adequate arrd proper

warnings arrd instIUctions to ordinary arrd foreseeable users of tire subject aircraft, including

Defendarrts, Continental, Pinnacle arrd Colgarr, as well as the Plaintiffs Decedent, John G.

Ro belts, IlL

49.. Defendarrt Bombardier owed tire Plaintiffs' Decedent, John G Roberts, III, a duty

of reasonable care in the design, marrufacture and testing of tire subject aircraft arrd its

component parts.

50.. Defendarrt Bombardier breached their legal duty arrd were negligent in one or

more of tire following respects:

a. Failed to design, marrufactlUe arrd assemble tire subject aircraft free of all
defects;
 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 12 of 15

h. Failed to design, manufactme and assemble the subject aircraft in such a

way as to assme that it was safe and appropriate for its intended use;

c.. Failed to properly and adequately test and monitor the subject aircraft so
as to learn of its inherent inability to perform safely in atmospheric icing conditions;

d.. Failed to design, manufactme and assemble the subject aircraft with an
adequate Low-Airspeed Alert System;

e.. Failed to design, manufactme and assemble the subject aircraft with an
adequate Auto- Throttle System in order to assure appropriate airspeed was maintained in icing
conditions;

f Failed to correct known wing structure icing problems;

g. Failed to provide adequate instructions and warning to the flight crews of

the su~ject aircraft and the flying public, including Plaintiffs' Decedent, John G. Roberts, III, of
the potential hazards associated with the operation of the subject aircraft in atmospheric icing
conditions, and how to avoid or preclude those hazards in the operation of the subject aircraft;

h. Designed, manufactmed, distributed and sold the subject aircraft with a

wing structme that resulted in an unsafe accumulation of ice;

1. Was otherwise cardess, reckless and negligent

51 . Defendant Bombardier's negligent acts were a proximate cause of the crash, the

Plaintiffs' damages and the injury and death ofthe Plaintiffs' Decedent, John G. Roberts, III.

COUNT V
BREACH OF EXPRESS AND IMPLIED WARRANTY
- DEFENDANT BOMBARDIER

52. PlaintifIs repeat and reallege all of the allegations contained above with the same

force and effect as if more fully setforth herein.

53. Defendant Bombardier is an aerospace manufacturer that holds itself out to the

public as having exceptional knowledge, skill and experience in the design, construction,

assembly, manufacturing, testing and maintenance of aircraft and in the preparation of flight and

maintenance manuals, and inspection of transport category aircraft and their components.
 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 13 of 15

54. In the course of its business, Defendant Bombardier designed, constIUcted,

assembled, manufactured, inspected, tested and published flight opemtions and maintenance

manuals, and caused the subject aircraft to be certified, including the subject aircmft that was

designated as Flight 3407 on FebIUary 12, 2009, which Defendant Bombardier expressly and

impliedly warranted was fit for its intended purposes and use as an aircraft in commercial air

transportation, being airworthy and free of unreasonably dangerous defects.

55 Defendant Bombardier marketed, sold, distributed and caused the subject aircraft

designated as Flight 3407 on February 12, 2009, to be introduced into the stream of commerce

by sale or lease to the Defendants, Continental, Pinnacle and Colgan

56. Defendant Bombardier expressly and impliedly warmnted to the geneml public,

including the Plaintiffs' Decedent, John G Roberts, III, that the subject aircraft was fit for the

purpose for which it was intended.

57. As a fare-paying passenger, the PlaintifIs' Decedent, John G. Roberts, III, made

use ofthe subject aircraft designated as Flight 3407 in an intended and foreseeable manner, and

he relied upon the express and implied warranties made by the Defendant Bombardier .

58.. In direct contradiction to the warranties, the subject aircraft was not fit for its

intended and foreseeable use, thereby rendering the aircraft unreasonably dangerous.

59.. Defendant Bombardier breached the aforementioned express and implied

warranties because of the aircmft's inadequate and defective components which included but was

not limited to, Defendant Bombardier's failure to provide warning of the aircraft's inadequacies

and defects and the failure to provide proper and adequate instruction in the safe opemtion and

maintenance of the subject aircraft .

 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 14 of 15

60. Defendant Bombardier's breach of wauanties and the defects refened to above

rendered the subject aircraft umeasonably dangerous and was a proximate and producing cause

of the crash of Flight 3407, the damages sustained by the Plaintiffs, and the injUly and death of

the Plaintiffs' Decedent, John G.. Roberts, IlL

61. As a member of the traveling public, the Plaintiffs' Decedent, John G. Roberts,

III, relied to his detriment upon Defendant, Bombardier's express and implied representations of

safety and fitness fOl the use which the subject aircraft designated as Flight 3407 was put to on

FeblUary 12,2009 .

COUNT VI
PUNITIVE DAMAGES ALL OF THE DEFENDANTS

62. Plaintiffs repeat and reallege all of the allegations contained above with the same

force and effect as if more fully setfOlth herein

63 . The actions and admissions of the Defendants named herein, including their own

conduct as well as the actions and omissions of their officers, agents, servants and/or employees

as setfOlth above was grossly negligent and said Defendants acted with wanton and/or reckless

disregard for the safety of others including the Plaintiffs' Decedent, John G.. Roberts, III, and as

such said conduct wan ants the imposition of punitive damages .

64.. One or more of the allegations of gross negligence and/or reckless conduct on the

part of the Defendants was a substantial factor in causing the Plaintiffs' damages and the injUles

and death of the Plaintiffs' Decedent, John G. Roberts, IlL

65.. Based upon the foregoing, the Plaintiffs are entitled to punitive damages pUlsuant

to applicable Law.
 Case 1:09-cv-00825-WMS Document 1 Filed 09/18/09 Page 15 of 15

WHEREFORE, the Plaintiffs demand judgment, jointly and sevelally as follows:

1. CompensatOlY damages for the wrongful death suffered and to be suffered

by the Plaintiffs, the Decedent's sUlviving adult siblings and all otheJ
beneficiaJies, sUlvivors and heiIs UIIdel applicable Law in an amoUllt
which exceeds the jUlisdictionai amoUllt of $75,000 . 00, exclusive of
interest and costs . (NY EPLL §5-4.3);

2. CompensatOlY damages for the injUlies and losses sustained by the

PlaintifIs' Decedent, John G. Robelts, III, befOle he died. (NY EPLL
§1133);

3.. FUllerai expenses (NY EPTL §5-4.3);

4. Damages aJising from the pre-impact physical pain and suffering, mental
tellO!, and mental anguish ofthe Plaintiffs' Decedent, John G. Robelts, III,
(N.YEP.TL §11-33);

5.. Punitive damages in an amoUllt to be fixed by the JUly;

6.. Interest from the date ofthe OCCUlTence, FeblUaJy 12, 2009, upon the
Plincipal SUlll recovered by the Plaintiffs . (N.Y EPTL §5-4.J);

7 The costs and disbUlsements incUlred in the prosecution of this action;

8.. That all issues offact in this action be detelmined by a jUly;

9.. Any other and further relief which the COUlt deems just and propel

Dated: September 17, 2009

Buffalo, New York

BY'~~~~~-+=7~~-
S, ESQ .
Attorneys for Plaintiffi
LEWIS & LEWIS, PC
800 Cathedral PaJk Tower
37 Franklin Street
Buffalo, NY 14202
(716) 854-2100
alewis@lewislawcom