January 4, 2019
Aminov v Allstate Ins. Co. (2019 NY Slip Op 50056(U))
https://www.beynensonlaw.com/case-law/aminov-v-allstate-ins-co-2019-ny-slip-op-50056u/
- Decided
- January 4, 2019
- Citation
- 2019 NY Slip Op 50056(U)
- Posture
- Default or vacatur
- Outcome
- Provider prevailed
- Later treatment
- Followed in 2 later decisions (see Cited by)
Posture, outcome, issues and treatment by other decisions are Beynenson Law’s classification. Treatment labels are assigned by a language model reading the citing decision; negative and appeal-history labels are checked by a second reader.
Summary
Editorial summary by Beynenson Law, not part of the court’s decision.
Reported in New York Official Reports at Aminov v Allstate Ins. Co. (2019 NY Slip Op 50056(U))
SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT, 2d, 11th and 13th JUDICIAL DISTRICTS
against
Allstate Ins. Co., Respondent.
Gary Tsirelman, P.C. (David M. Gottlieb of counsel), for appellant. Peter C. Merani, P.C. (Eric M. Wahrburg and Smauel Kamara of counsel), for respondent.
Appeal from an order of the Civil Court of the City of New York, Kings County (Robin Kelly Sheares, J.), entered August 9, 2016. The order granted the branches of defendant’s motion seeking, in effect pursuant to CPLR 5015 (a) (1) and (4), to vacate a judgment of that court entered October 31, 2014 upon defendant’s failure to appear or answer the complaint, and to compel plaintiff to accept defendant’s answer.
ORDERED that the order is reversed, with $30 costs, the branches of defendant’s motion seeking, in effect pursuant to CPLR 5015 (a) (1) and (4), to vacate the judgment entered October 31, 2014, and to compel plaintiff to accept defendant’s answer are denied, and the matter is remitted to the Civil Court to determine the remaining branches of defendant’s motion.
In this action by a provider to recover assigned first-party no-fault benefits, the affidavit of service indicates that defendant was served on September 16, 2014 by delivery of the summons and complaint to Grace Annunziata at defendant’s Brooklyn office. The affidavit described Annunziata and stated that she was known to the process server to be defendant’s employee, who was authorized to accept delivery at that Brooklyn address. Defendant failed to appear or answer, and, upon plaintiff’s motion, a default judgment in the amount of $4,057.51 was entered against defendant on October 31, 2014. In October 2015, defendant moved, in effect pursuant to CPLR 5015 (a) (1) and (4), to, among other things, vacate the default judgment and [*2]compel plaintiff to accept defendant’s answer, which was annexed to the motion papers. Defendant’s claim representative asserted in an affidavit in support of the motion that the summons had not been “served on Allstate as alleged.” Defendant’s motion also sought the alternative relief of modification of the judgment on the ground that the interest was not correctly calculated. Plaintiff opposed the motion. By order entered August 9, 2016, the Civil Court granted the branches of defendant’s motion seeking to vacate the default judgment and to compel plaintiff to accept defendant’s answer, finding that defendant had established a reasonable excuse for the default and a potentially meritorious defense to the action.
A defendant seeking to vacate a default in appearing or answering based on an excusable default must demonstrate both a reasonable excuse for the default and the existence of a potentially meritorious defense to the action (see CPLR 5015 [a] [1]; Eugene Di Lorenzo, Inc. v A.C. Dutton Lbr. Co., 67 NY2d 138, 141 [1986]). Here, the summons and complaint were served by a process server, who provided a description of Grace Annunziata, the recipient of service, and attested that Annunziata was known to him to be defendant’s employee who was authorized to accept service at defendant’s address. “A process server’s affidavit of service constitutes prima facie evidence of proper service on a corporation pursuant to CPLR 311 (a) (1)” (Hayden v Southern Wine & Spirits of Upstate NY, Inc., 126 AD3d 673, 673 [2015] [internal citations omitted]).
Although a defendant’s sworn denial of receipt of service may rebut the presumption of proper service established by the process server’s affidavit, defendant did not submit an affidavit from Annunziata denying either that she had been authorized to accept service or that she had accepted service of the summons and complaint (see Pain Mgt. Ctr. of N.J., P.C. v All Car Rent-A-Car, 57 Misc 3d 138[A], 2017 NY Slip Op 51310[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2017]). Rather, defendant proffered an affidavit by its claim representative, who admitted that defendant maintained a claims office at the same Brooklyn address which is listed in the affidavit of service. Defendant’s claim representative’s assertion that the summons was not “served on Allstate as alleged” lacked sufficient detail to rebut the prima facie proof of proper service set forth in the affidavit of service (see Deutsche Bank Natl. Trust Co. v Quinones, 114 AD3d 719 [2014]) and did not demonstrate a reasonable excuse for defendant’s default (see Herrera v MTA Bus Co., 100 AD3d 962 [2012]). We note that defendant also failed to adequately explain its 11-month delay in seeking to vacate its default (see Deutsche Bank Natl. Trust Co. v Gutierrez, 102 AD3d 825 [2013]).
As the Civil Court did not determine the remaining branches of defendant’s motion seeking, in the alternative, to, among other things, modify the judgment, the matter is remitted to the Civil Court for a determination of the remaining branches of defendant’s motion.
Accordingly, the order is reversed, the branches of defendant’s motion seeking, in effect pursuant to CPLR 5015 (a) (1) and (4), to vacate the judgment entered October 31, 2014, and to compel plaintiff to accept defendant’s answer are denied, and the matter is remitted to the Civil Court to determine the remaining branches of defendant’s motion.
PESCE, P.J., ALIOTTA and ELLIOT, JJ., concur.
ENTER:
Paul Kenny
Chief Clerk
Decision Date: January 04, 2019
Legal questions (2)
Questions of no-fault law this decision rules on, from our Legal Questions pages. Bars count the decisions on the question by year and court, coloured by category; circles are this decision and the decisions on the question it cites or that cite it. Point at a bar or circle for details. The categories and summaries are Beynenson Law’s classification, made by a language model and checked by a second reading.
Did the defaulting party show a reasonable excuse (or lack of notice) and a potentially meritorious defense or claim?
This decision: Relief denied because no reasonable excuse (or, under CPLR 317, no lack of actual notice) was shown; meritorious defense accepted or not reached
Held the insurer showed no reasonable excuse because its claim representative's bare assertion that it was not served lacked detail and no affidavit came from the employee served; the unexplained 11-month delay was also noted.
Of the 170 decisions on this question in the Second Department courts and the Court of Appeals, 64 (this one included) are in the same category.
Was the insurer validly served with process, and does the court have personal jurisdiction over it?
This decision: Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (rules on the question, but another ground decided the case)
Held the process server's affidavit describing service on an employee authorized to accept it at the insurer's office was prima facie proof under CPLR 311(a)(1), unrebutted by a claim representative's conclusory denial, so CPLR 5015(a)(4) vacatur was denied.
Of the 129 decisions on this question in the Second Department courts and the Court of Appeals, 31 (this one included) are in the same category.
Cited in this decision
A label shows how this decision treated the case it cites.
- Pain Mgt. Ctr. of N.J., P.C. v All Car Rent-A-Car (2017 NY Slip Op 51310(U)) FollowedThe defendant failed to rebut proof of proper corporate service or reasonably excuse its approximately three-month delay in answering.
Cited by
A label shows how the later decision treated this one.
- Pierre J. Renelique Physician, P.C. v Allstate Ins. Co. (2019 NY Slip Op 29225) FollowedThe insurer failed to establish a reasonable excuse for default by citing the absence of a record of receiving process.
- Art of Healing Medicine, P.C. v Allstate Ins. Co. (2023 NY Slip Op 51471(U)) FollowedThe insurer failed to establish a reasonable excuse for its default based on nonreceipt of process or pandemic-related staffing reductions.
- Milky Way Acupuncture, P.C. v Allstate Ins. Co. (2020 NY Slip Op 50935(U))The insurer failed to establish an excusable default, and the provider's default judgment remained in place.
Similar decisions
- Santomauro v Allstate Ins. Co. (2019 NY Slip Op 51413(U))The insurer's affidavits failed to establish a reasonable excuse for defaulting despite prima facie proof of proper service.
- Premier Surgical Servs., P.C. v Allstate Ins. Co. (2018 NY Slip Op 50273(U))The insurer's conclusory claim of law office failure did not establish a reasonable excuse for its default in appearing or answering.
- S & R Med., P.C. v Allstate Prop. & Cas. Ins. Co. (2017 NY Slip Op 50551(U))The provider failed to establish valid service outside New York City, while the insurer failed to justify acceptance of its late answer.
- GC Chiropractic, P.C. v Allstate Ins. Co. (2019 NY Slip Op 51954(U))The insurer failed to establish a reasonable excuse for its default, and the process server's affidavit showed proper service.
- Diagnostic Medicine, P.C. v Auto One Ins. Co. (2019 NY Slip Op 51891(U))The judgment against the insurer was vacated for inadequate notice, but its unsupported excuse left the underlying default intact.