FILED: KINGS COUNTY CLERK 10/18/2017 05:10 PM
`FILED: KINGS COUNTY CLERK 10m2017 05:10 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520191/2017
`INDEX NO. 520191/2017
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`
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`
`
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`RaCaIVaD VYSCEF: 10/18/2017
`RECEIVED NYSCEF: 10/18/2017
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`COUNTY or KINGS
`————————————————————————————————————————————————————————————————————X
`JILL REED,
`
`Index No
`
`fivummnng
`
`Plaintiff,
`
`.
`against
`
`DHANPAUL SINGHa
`
`Defendant,
`_____________________________________________________________________X
`
`To the above named Defendant(s)
`
`Plaintifl’s Residence
`60 Carlton Avenue Apt.11E
`Brooklyn, NY 11205
`
`The basis of venue designated is:
`Plaintiff(s) residence.
`
`~@1311 are hereby summoneh to answer the complaint in this action, and to serve a copy
`of your answer, of if the complaint
`is not served with this summons,
`to serve a notice of
`appearance on the plaintiffs attorney(s) within twenty days after the services of this summons
`exclusive of the day of service, where service is made by delivery upon you personally within the
`state, or within 30 days after completion of service where service is made in any other manner.
`In
`case of your failure to appear or answer, judgment will be taken against you by default for the
`relief demanded in the complaint.
`
`DATED: New York, New York
`October 17, 2017
`
`_,____.__..;___-_____.
`
`Harmon, Linder'& Rogowsky
`Attorneysfor Plaintiffls)
`3 Park Menue, 23rd Floor
`Suite 230013
`New York, NY 10016
`
`Defendant’s Address:
`
`DHANPAUL SINGH
`
`304 2nd Street
`
`Albany, NY 12206
`
`lof7
`1 of 7
`
`
`FILED: KINGS COUNTY CLERK 10m2017 05:10 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520191/2017
`INDEX NO. 520191/2017
`
`
`
`
`
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`RaCaIVaD VYSCEF: 10/18/2017
`RECEIVED NYSCEF: 10/18/2017
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`COUNTY or KINGS
`————————————————————————————————————————————————————————————————————X
`JILL REED,
`
`Index No
`
`fivummnng
`
`Plaintiff,
`
`.
`against
`
`DHANPAUL SINGHa
`
`Defendant,
`_____________________________________________________________________X
`
`To the above named Defendant(s)
`
`Plaintifl’s Residence
`60 Carlton Avenue Apt.11E
`Brooklyn, NY 11205
`
`The basis of venue designated is:
`Plaintiff(s) residence.
`
`~@1311 are hereby summoneh to answer the complaint in this action, and to serve a copy
`of your answer, of if the complaint
`is not served with this summons,
`to serve a notice of
`appearance on the plaintiffs attorney(s) within twenty days after the services of this summons
`exclusive of the day of service, where service is made by delivery upon you personally within the
`state, or within 30 days after completion of service where service is made in any other manner.
`In
`case of your failure to appear or answer, judgment will be taken against you by default for the
`relief demanded in the complaint.
`
`DATED: New York, New York
`October 17, 2017
`
`_,____.__..;___-_____.
`
`Harmon, Linder'& Rogowsky
`Attorneysfor Plaintiffls)
`3 Park Menue, 23rd Floor
`Suite 230013
`New York, NY 10016
`
`Defendant’s Address:
`
`DHANPAUL SINGH
`
`304 2nd Street
`
`Albany, NY 12206
`
`lof7
`1 of 7
`
`
`
`FILED: KINGS COUNTY CLERK 10/18/2017 05:10 PM
`FILED: KINGS COUNTY CLERK 10 m 2017 05 2 10 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`520191/2017
`INDEX NO. 520191/2017
`INDEX NO~
`
`
`
`
`
`«.
`3F:
`4.«
`R C Iv D wrsc
`10/18/2017
`RECEIVED NYSCEF: 10/18/2017
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF KINGS
`
`
`
`—against—
`
`DHANPAUL SINGH,
`
`Plaintiff,
`
`VERIFIED COMPLAINT
`
`______________________________________ x
`
`Defendant.
`
`Plaintiff, complaining of the defendant herein by her attorneys,
`
`HARMON, LINDER & ROGOWSKY, ESQS., respectfully sets forth and
`
`
`alleges, as follows:
`
`AS AND FOR A FIRST CAUSE OF ACTION
`
`ON BEHALF OF JILL REED
`
`1. That at the time of the commencement of this action plaintiff
`
`was a resident of the County of KINGS, State of New York.
`
`2. That at all times herein mentioned defendant, DHANPAUL SINGH,
`
`
`was the owner and the operator of an automobile bearing
`
`registration number GZD3217, State of New York.
`
`3. That at all times herein mentioned plaintiff, JILL REED was
`
`the owner and operator of an automobile bearing registration
`
`number HDV1661, State of New York.
`
`2 of 7
`2 of 7
`
`
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`FILED: KINGS COUNTY CLERK 10/18/2017 05:10 PM
`FILED: KINGS COUNTY CLERK 10 m 2017 05 2 10 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
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`520191/2017
`INDEX NO. 520191/2017
`INDEX NO~
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`
`
`
`«.
`3F:
`4.«
`R c Iv D vysc
`10/18/2017
`RECEIVED NYSCEF: 10/18/2017
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`
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`4. That on the Fifteenth day of January, 2017, at approximately
`
`2:50 a.m.,
`
`the aforesaid vehicles came into contact with
`
`plaintiff‘s vehicle at Rockaway Boulevard, at or near its
`
`intersection with Woodhaven Boulevard, a public street and
`
`thoroughfare,
`
`in the County of Queens, State of New York.
`
`5. The defendant so carelessly and negligently operated their
`
`aforesaid respective vehicles so as to cause the aforesaid
`
`contact.
`
`6. That as a result of the foregoing,
`
`this plaintiff was caused
`
`to and did sustain severe and serious injuries and was required
`
`to seek and obtain medical care and attention in an effort to
`
`cure and alleviate same and, upon information and belief, will
`
`be compelled to do so in the future.
`
`7. That the aforesaid occurrence and the injuries sustained by
`
`this plaintiff were caused by the negligence of the defendant.
`
`8. That this plaintiff has sustained a serious injury as the
`
`same is defined in Subdivision "d" of Section 5102 of the
`
`Insurance Law of the State of New York.
`
`3 of 7
`3 of 7
`
`
`
`FILED: KINGS COUNTY CLERK 10/18/2017 05:10 PM
`FILED: KINGS COUNTY CLERK 10 m 2017 05 2 10 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`520191/2017
`INDEX NO. 520191/2017
`INDEX NO~
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`
`
`
`
`a
`Y CEF:
`4.«
`R c Iv D v s
`10/18/2017
`RECEIVED NYSCEF: 10/18/2017
`
`
`
`9. This action fall within one or more of the exceptions set
`
`
`forth in CPLR section 1602.
`
`
`10. That by reason of the foregoing, plaintiff, JILL REED, has
`
`been damaged in an amount which exceeds the jurisdiction limits
`
`of all lower courts that would otherwise have jurisdiction.
`
`AS AND FOR A SECOND CAUSE OF ACTION ON
`
`BEHALF OF PLAINTIFF JILL REED
`
`11. This plaintiff repeats, reiterates and realleges each and
`
`every allegation contained in paragraphs of this complaint
`
`numbered "1" through "10",
`
`inclusive, with the same force and
`
`effect as though the same were more fully set forth at length
`
`herein.
`
`12. That defendant so carelessly and negligently operated their
`
`aforesaid respective motor vehicle so as to cause the aforesaid
`
`contact.
`
`13. That as a result of the foregoing,
`
`this plaintiff‘s
`
`aforesaid vehicle was caused to and did sustain property damage
`
`and this plaintiff was required to seek and obtain mechanical
`
`attention in an effort to repair the damages.
`
`4 of 7
`4 of 7
`
`
`
`FILED: KINGS COUNTY CLERK 10/18/2017 05:10 PM
`FILED: KINGS COUNTY CLERK 10 m 2017 05 2 10 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`520191/2017
`INDEX NO. 520191/2017
`INDEX NO~
`
`
`
`
`
`« NYSCEF:
`«
`«
`R C Iv D
`10/18/2017
`RECEIVED NYSCEF: 10/18/2017
`
`
`
`14. That the aforesaid occurrence and property damage sustained
`
`by this plaintiff's vehicle was caused by the negligence of the
`
`defendants and not by any act or omission on the part of this
`
`plaintiff contributing thereto.
`
`WHEREFORE, plaintiff, JILL REED, demands judgement against
`
`the defendant
`
`in the First Cause of Action in an amount which
`
`exceeds the jurisdictional limits of all lower courts that would
`
`otherwise have jurisdiction and plaintiff, JILL REED, demands
`
`judgement against the defendant
`
`in the Second Cause of Action;
`
`all together with the costs and disbursements of this action.
`
`Dated: New York, NY
`September 30, 2017
`
`[.3
`HARMON, LINDER &JROGOWSKY, ESQS.
`Attorney(s)§forgPlaintiff(s)
`f
`.
`3 Park Avenue,;Suite 2300
`New York,"NegéQork 10016
`
`(212) 732-36
`
`)
`
`MJL/mj
`
`5 of 7
`5 of 7
`
`
`
`FILED: KINGS COUNTY CLERK 10/18/2017 05:10 PM
`FILED: KINGS COUNTY CLERK 10m2017 05:10 PM
`NYSC 3F DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`520191/2017
`INDEX NO. 520191/2017
`INDEX NO.
`
`
`
`
`
`RfiCfiIVfiD VYSCEF:
`10/18/2017
`RECEIVED NYSCEF: 10/18/2017
`
`ATTORNEY'S VERIFICATION
`
`STATE OF NEW YORK )
`
`COUNTY OF NEW YORK) ) SS:
`
`I, the undersigned, am an attorney admitted to practice in the Courts of New York State,
`
`and say that:
`
`I am the attorney of record or of counsel with the attorney(s) of record for plaintiff.
`
`I have read the annexed SUMMONS AND VERIFIED COMPLAINT and know the
`
`contents thereof and the same are true to my knowledge, except those matters therein which are
`
`stated to be alleged on information and belief. As to those matters, I believe them to be true.
`
`My belief, as to those matters therein not stated upon knowledge is based upon the following:
`
`Interviews and/or discussions with the plaintiff(s) and papers and/or documents in the file.
`
`The reasons I make this affirmation instead of the plaintiff is because said plaintiff
`
`resides outside of the county from where your deponent maintains his office for the practice of
`
`law.
`
`Dated:
`
`New York, New York
`
`October 17, 2017
`
`
`
`6 of 7
`6 of 7
`
`
`
`FILED: KINGS COUNTY CLERK 10/18/2017 05:10 PM
`FILED: KINGS COUNTY CLERK 10m2017 05:10 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520191/2017
`INDEX N0. 520191/2017
`
`
`
`
`
`RaCaIVaD VYSCEF: 10/18/2017
`RECEIVED NYSCEF: 10/18/2017
`
`
`
`Index No.
`
`Year
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`COUNTY OF KINGS
`
`I111:TEE;"""""""""""""""""""""""""""""""""""""""""""""""""""""""""""""
`
`against
`
`DHANPAUL SINGH,
`
`Plaintiff,
`
`Defendant,
`
`HARMON, LINDER & ROGOSWKY, ESQS.
`Attorney for Plaintiff(s)
`3 Park Avenue, 23rd Floor
`Suite 2300
`
`New York, NY 10016
`
`(212) 732-3665 Phone
`(212) 732—1462 Facsimile
`
`To:
`
`Attorney(s) for Defendant
`
`Service of a copy of the within Summons and Complaint is hereby admitted.
`Dated:
`
`Attorney(s) for
`
`PLEASE TAKE NOTICE
`
`[1 Notice of Entry
`
`that the within is a (certified) true copy ofa
`entered in the office ofthe clerk ofthe within named Court on
`
`1:] Notice of Settlement
`that an order of which the within is a true copy will be presented for settlement to the
`Hon.
`, one ofthe judges ofthe within named Court, at
`on
`
`Dated: October 17, 2017
`
`Yours, etc.
`Harmon, Linder & Rogowsky
`Altorneysfor Plaintiff
`3 Park Avenue, 23rd Floor
`Suite 2300
`
`New York, NY 10016
`(212) 732-3665
`
`7of7
`7 of 7
`
`
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