CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO.

INDEX NO. UNASSIGNED

NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/27/2017

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NASSAU
WILLIAM J. O'REILLY,

Plaintiff, SUMMONS WITH NOTICE

-against- Index No.

MICHAEL J. PANTER, Venue is proper in this Court pursuant to

C.P.L.R. 503
Defendant.

TO THE ABOVE-NAMED DEFENDANT:

YOU ARE HEREBY SUMMONED and required to appear in this action by serving a

copy of your notice of appearance upon the undersigned within 20 days after the service of this

summons, exclusive of the day of service (or within 30 days after the service is complete if this

summons is not personally delivered to you within the State of New York).

YOU ARE HEREBY NOTIFED THAT should you fail to answer or appear, a

judgment will be entered against you by a default for the relief demanded below.

Dated: October 27, 2017 Respectfully submitted,

New York, New York
HOGUET NEWMAN
REGAL & KENNEY, LLP

By:
Fredric S. Newman
Andrew N. Bourne
10 East 40th Street, 35th Floor
New York, NY 10016
Phone: 212-689-8808

Attorneys for Plaintiff

1
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR 202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR 202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 1 of 2
CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/27/2017

To the Defendant: Michael J. Panter

P.O. Box 8635
Red Bank, New Jersey 07701

NOTICE: This action seeks redress for Defendant Panters intentional, malicious, and

bad faith actions in making defamatory and false statements in a publicly-available social media

post. Plaintiff seeks damages for the public hatred, ridicule, disgrace, and permanent harm to his

professional and personal reputations as a result of Defendant Panters publication of knowingly

false defamatory statements about Plaintiff, which were made with actual malice, as well as

Defendant Panters intentional infliction of emotional distress upon Plaintiff.

The relief includes, but is not limited to, reputational damages, monetary damages,

special damages, punitive damages, costs, fees, injunctive relief, and such other relief as is just

and proper, in an amount not less than $5 million.

Should Defendant fail to appear herein, judgment will be entered by default for the sum

of $5 million, plus statutory interest, fess, and the costs of this action, as the Court may award.

VENUE: Plaintiff designates Nassau County as the place of trial. The basis of this

designation is Plaintiffs residence in Nassau County, pursuant to C.P.L.R. 503.

2
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR 202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR 202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 2 of 2