FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`
`NYSCEF DOC . NO.
`1
`NYSCEF DOC. NO. 1
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`INDEX NO. 520584/2017
`INDEX NO~ 520584/2017
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`
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`
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`R«.C«.IV«.D \IYSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`Index No.:
`
`COUNTY OF KINGS
`______________________________________________________________________x
`
`Date Purchased:
`
`CAYETANO L. CAMPOVERDE RAMON,
`
`SUMMONS
`
`-against-
`
`Plaintiff,
`
`Plaintiff designates Kings
`County as the place of trial.
`
`HARRINARINE RAGHUBIR and GALAXY GENERAL
`CONTRACTING CORR,
`
`Defendants-
`----------------------------------------------------------------------X
`
`To the above named Defendants:
`
`The basis of venue is:
`maintiff residence
`
`Plaintiff resides at:
`1383 Herkimer Street, Apt. 1
`Brooklyn, NY 11233
`County of Kings
`
`You are hereby summoned to answer the complaint in this action, and to serve a
`copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
`appearance on the Plaintiffs attorneys within twenty (20) days after the service of this summons,
`exclusive of the day of service, where service is made by delivery upon you personally within the
`state, or, within thirty (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: Brooklyn, New York
`
`September 5, 2017
`
`A omeys for Plaintiff
`CAYETANO L. CAMPOVERDE RAMON
`
`1712 Kings Highway, Suite 2
`Brooklyn, New York 1 1229
`718-787-4470
`
`File No.: l 6-O381WCVB-0-1
`
`TO: HARRINARINE RAGHUBIR
`
`GALAXY GENERAL CONTRACTING CORP.
`
`2009 Cruger Avenue, Apt. 3D
`Bronx, NY 10462
`
`3152 Albany Crescent
`Bronx, NY 10463
`
`lof9
`1 of 9
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`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
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`NYSCEF DOC . NO.
`1
`NYSCEF DOC. NO. 1
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`INDEX NO. 520584/2017
`INDEX NO~ 520584/2017
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`
`
`
`
`R«.C«.IV«.D \IYSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`Index No.:
`
`COUNTY OF KINGS
`______________________________________________________________________x
`
`Date Purchased:
`
`CAYETANO L. CAMPOVERDE RAMON,
`
`SUMMONS
`
`-against-
`
`Plaintiff,
`
`Plaintiff designates Kings
`County as the place of trial.
`
`HARRINARINE RAGHUBIR and GALAXY GENERAL
`CONTRACTING CORR,
`
`Defendants-
`----------------------------------------------------------------------X
`
`To the above named Defendants:
`
`The basis of venue is:
`maintiff residence
`
`Plaintiff resides at:
`1383 Herkimer Street, Apt. 1
`Brooklyn, NY 11233
`County of Kings
`
`You are hereby summoned to answer the complaint in this action, and to serve a
`copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
`appearance on the Plaintiffs attorneys within twenty (20) days after the service of this summons,
`exclusive of the day of service, where service is made by delivery upon you personally within the
`state, or, within thirty (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: Brooklyn, New York
`
`September 5, 2017
`
`A omeys for Plaintiff
`CAYETANO L. CAMPOVERDE RAMON
`
`1712 Kings Highway, Suite 2
`Brooklyn, New York 1 1229
`718-787-4470
`
`File No.: l 6-O381WCVB-0-1
`
`TO: HARRINARINE RAGHUBIR
`
`GALAXY GENERAL CONTRACTING CORP.
`
`2009 Cruger Avenue, Apt. 3D
`Bronx, NY 10462
`
`3152 Albany Crescent
`Bronx, NY 10463
`
`lof9
`1 of 9
`
`
`
`FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520584/2017
`INDEX NO- 520584/2017
`
`
`
`
`
`RMCMIVMD YSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`COUNTY OF KINGS
`
`______________________________________________________________________x
`
`CAYETANO L. CAMPOVERDE RAMON,
`
`.
`.
`Plamtlff’
`
`'agams’t'
`
`HARRINARINE RAGHUBIR and GALAXY GENERAL
`
`CONTRACTING CORR,
`
`______________________________________________________________________X
`
`Defendants.
`
`Index No.:
`Date Purchased:
`
`VERIFIED
`COMPLAINT
`
`Plaintiff, by his attorneys, LAW OFFICES OF VEL BELUSHIN, P.C., complaining of
`
`the Defendants, respectfully alleges, as follows:
`
`1.
`
`At all
`
`times herein mentioned, Plaintiff, CAYETANO L. CAMPOVERDE
`
`RAMON, was and still is a resident of the County of Kings, State of New York.
`
`2.
`
`At all times herein mentioned, Defendant, HARRINARINE RAGHUBIR, was
`
`and still is a resident of the County of Bronx, State of New York.
`
`3.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORP., was, and still is, a domestic corporation duly organized and existing
`
`under, and by virtue of the Laws of State of New York.
`
`4.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORP., was, and still is, a foreign corporation duly organized and existing
`
`under, and by virtue of, the Laws of the State of New York.
`
`5.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORR, was, and still is a partnership duly organized and existing under,
`
`and by virtue of, the Laws of the State of New York.
`
`20f9
`2 of 9
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`FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
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`INDEX NO. 520584/2017
`INDEX NO~ 520584/2017
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`
`
`
`
`R«.C«.IV«.D \IYSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`
`
`6.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORP., was, and still
`
`is, a non-profit organization duly organized and
`
`existing under, and by virtue of, the Laws of the State of New York.
`
`7.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORP., maintained a principal place of business in the County of Bronx,
`
`State of New York.
`
`8.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORP., was the owner of a 2000 Ford motor vehicle, bearing New York
`
`State license plate number 62165JX.
`
`9.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORP., was the lessor of the 2000 Ford motor vehicle, bearing New York
`
`State license plate number 62165JX.
`
`10.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORR, managed the 2000 Ford motor vehicle, bearing New York State
`
`license plate number 62165JX.
`
`11.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORP., maintained the 2000 Ford motor vehicle, bearing New York State
`
`license plate number 62165JX.
`
`12.
`
`At
`
`all
`
`times
`
`herein mentioned, Defendant, GALAXY GENERAL
`
`CONTRACTING CORP., controlled the 2000 Ford motor vehicle, bearing New York State
`
`license plate number 62165JX.
`
`30f9
`3 of 9
`
`
`
`FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520584/2017
`INDEX NO- 520584/2017
`
`
`
`
`
`RMCMIVMD YSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`
`
`13.
`
`At all times herein mentioned, Defendant, HARRINARINE RAGHUBIR, was
`
`the operator of the 2000 Ford motor vehicle, bearing New York State license plate number
`
`62165JX.
`
`14.
`
`At all times herein mentioned, Defendant, HARRINARINE RAGHUBIR, was
`
`the lessee of the 2000 Ford motor vehicle, bearing New York State license plate number
`
`62165JX.
`
`15.
`
`At all
`
`times herein mentioned, Defendant, HARRINARINE RAGHUBIR,
`
`managed the 2000 Ford motor vehicle, bearing New York State license plate number 62165JX.
`
`16.
`
`At all
`
`times herein mentioned, Defendant, HARRINARINE RAGHUBIR,
`
`maintained the 2000 Ford motor vehicle, bearing New York State license plate number
`
`62165JX.
`
`17.
`
`At all
`
`times herein mentioned, Defendant, HARRINARINE RAGHUBIR,
`
`controlled the 2000 Ford motor vehicle, bearing New York State license plate number 62165JX.
`
`18.
`
`At all
`
`times herein mentioned, Defendant, HARRINARINE RAGHUBIR,
`
`operated the 2000 Ford motor vehicle, bearing New York State license plate number 62165JX,
`
`with the knowledge of Defendant, GALAXY GENERAL CONTRACTING CORP.
`
`19.
`
`At all
`
`times herein mentioned, Defendant, HARRINARINE RAGHUBIR,
`
`operated the 2000 Ford motor vehicle, bearing New York State license plate number 62165JX,
`
`with the permission of Defendant, GALAXY GENERAL CONTRACTING CORP.
`
`20.
`
`At all
`
`times herein mentioned, Defendant, HARRINARINE RAGHUBIR,
`
`operated the 2000 Ford motor vehicle. bearing New York State license plate number 6216SJX,
`
`with the consent of Defendant. GALAXY GENERAL CONTRACTING CORP.
`
`4of9
`4 of 9
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`
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`FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520584/2017
`INDEX NO~ 520584/2017
`
`
`
`
`
`R«.C«.IV«.D \IYSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`21.
`
`At all
`
`times herein mentioned, Defendant, HARRINARINE RAGHUBIR,
`
`operated the 2000 Ford motor vehicle, bearing New York State license plate number 62165JX,
`
`within the scope of his employment with Defendant, GALAXY GENERAL CONTRACTING
`
`CORP.
`
`22.
`
`At all times herein mentioned, 1321 Oak Point Avenue, in the County of Bronx,
`
`State of New York, were public roadways, streets and/or thoroughfares, used extensively by the
`
`public and in general.
`
`23.
`
`That on November 30, 2016, Defendant, HARRINARINE RAGHUBIR, was
`
`operating the 2000 Ford motor vehicle, bearing New York State license plate number 6216SJX,
`
`at the aforementioned location.
`
`24.
`
`That on November 30, 2016, Plaintiff, CAYETANO L. CAMPOVERDE
`
`RAMON, was operating the 2009 Chevrolet motor vehicle, bearing New York State license
`
`plate number 3673 1 MG, at the aforementioned location.
`
`25.
`
`That on November 30, 2016, at the aforementioned location, the motor vehicle
`
`owned by Defendant, GALAXY GENERAL CONTRACTING CORP., and operated by
`
`Defendant, HARRINARINE RAGHUBIR, bearing New York State license plate number
`
`6216SJX, struck the motor vehicle operated by the Plaintiff, CAYETANO L. CAMPOVERDE
`
`RAMON, bearing New York State license plate number 36731MG.
`
`26.
`
`That
`
`as
`
`a
`
`result of
`
`the aforesaid collision, Plaintiff, CAYETANO L.
`
`CAMPOVERDE RAMON, was seriously and permanently injured.
`
`27.
`
`That the aforesaid occurrence was caused wholly and solely by reason of the
`
`negligence of the Defendants without any fault or negligence on the part of the Plaintiff
`
`contributing thereto.
`
`5of9
`5 of 9
`
`
`
`FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520584/2017
`INDEX NO- 520584/2017
`
`
`
`
`
`RMCMIVMD YSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`
`
`28.
`
`That Defendants were negligent, careless and reckless
`
`in the ownership,
`
`operation, management, maintenance, supervision, use and control of the aforesaid motor vehicle
`
`and the Defendants were otherwise negligent, careless and reckless in the circumstances then and
`
`there prevailing.
`
`29.
`
`That by reason of the foregoing, Plaintiff, CAYETANO L. CAMPOVERDE
`
`RAMON, sustained severe and permanent personal injuries; and Plaintiff, CAYETANO L.
`
`CAMPOVERDE RAMON, was otherwise damaged.
`
`30.
`
`That Plaintiff, CAYETANO L. CAMPOVERDE RAMON, sustained serious
`
`injuries as defined by §5102 of the Insurance Law of the Sate of New York.
`
`31.
`
`That Plaintiff, CAYETANO L. CAMPOVERDE RAMON, sustained serious
`
`injury and economic loss greater than basic economic loss as defined by §5104 of the Insurance
`
`Law of the State of New York.
`
`32.
`
`That Plaintiff, CAYETANO L. CAMPOVERDE RAMON, is not seeking to
`
`recover any damages for which Plaintiff has been reimbursed by no-fault insurance and/or for
`
`which no-fault insurance is obligated to reimburse Plaintiff. Plaintiff is only seeking to recover
`
`those damages not recoverable through no-fault insurance under the facts and circumstances in
`
`this action.
`
`33.
`
`That this action falls within one or more of the exceptions set forth in CPLR
`
`§1602.
`
`34.
`
`That by reason of the foregoing, Plaintiff, CAYETANO L. CAMPOVERDE
`
`RAMON, has been damaged in a sum that exceeds the jurisdictional limits of all lower courts
`
`which would otherwise havejurisdiction.
`
`WHEREFORE, Plaintiff demands judgment against
`
`the Defendants herein,
`
`in a
`
`6of9
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`FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`NYSC 3F DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`IND
`EX NO.
`520584/2017
`INDEX NO. 520584/2017
`
` YSC
`
` MIVM
` 3F:
`10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`sum exceeding thejurisdictional limits of all lower courts that would otherwise have jurisdiction,
`
`together with the costs and disbursements of this action.
`
`Dated: Brooklyn, New York
`September 5, 2017
`
`
`
`ETANO L. CAMPOVERDE RAMON
`
`1712 Kings Highway, Suite 2
`Brooklyn, New York 11229
`718-787-4470
`
`File No.: 16-0381WCVB-0-1
`
`TO: HARRINARINE RAGHUBIR
`
`GALAXY GENERAL CONTRACTING CORP.
`
`2009 Cruger Avenue, Apt. 3D
`Bronx, NY 10462
`
`3152 Albany Crescent
`Bronx, NY 10463
`
`7 of 9
`7 of 9
`
`
`
`FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520584/2017
`INDEX NO- 520584/2017
`
`
`
`
`
`RMCMIVMD YSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`
`
`ATTORNEY'S VERIFICATION
`
`VEL BELUSHIN, an attorney duly admitted to practice before the Courts of the State of
`
`New York, affirms the following to be true under the penalties of perjury:
`
`I am an attorney at
`
`LAW OFFICES OF VEL BELUSHIN, P.C., attorneys of record for Plaintiff, CAYETANO L.
`
`CAMPOVERDE RAMON.
`
`I have read the annexed COMPLAINT and know the contents
`
`thereof, and the same are true to my knowledge, except those matters therein which are stated to
`
`be alleged upon information and belief, and as to those matters I believe them to be true. My
`
`belief, as to those matters therein not stated upon knowledge, is based upon facts, records, and
`
`other pertinent information contained in my files.
`This verification is made by me because Plaintiff is not presently in the county wherein I
`
`maintain my offices.
`
`Dated: Brooklyn, New York
`
`September 5, 2017
`
`8of9
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`FILED: KINGS COUNTY CLERK 10/24/2017 02:57 PM
`FILED: KINGS COUNTY CLERK 10m2017 02:57 PM
`
`NYSCEF DOC. NO.
`1
`NYSCEF DOC. NO. 1
`
`INDEX NO. 520584/2017
`INDEX N0. 52058472017
`
`
`
`
`
`
`R«.C«.IV«.D \IYSCEF: 10/24/2017
`RECEIVED NYSCEF: 10/24/2017
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`COUNTY OF KINGS
`
`______________________________________________________________________x
`
`CAYETANO L. CAMPOVERDE RAMON,
`
`Plaintiff,
`
`-against—
`
`HARRINARINE RAGHUBIR and GALAXY GENERAL
`
`CONTRACTING CORR,
`
`Defendants.
`
`SUMMONS & VERIFIED COMPLAINT
`
`LAW OFFICES OF VEL BELUSHIN, P.C.
`
`Attorneys for Plaintiff
`CAYETANO L. CAMPOVERDE RAMON
`
`1712 Kings Highway, Suite 2
`Brooklyn, New York I 1229
`(718) 787-4470
`
`
`TO: HARRINARINE RAGHUBIR
`
`GALAXY GENERAL CONTRACTING CORP.
`
`2009 Cruger Avenue, Apt. 3D
`Bronx, NY 10462
`
`3152 Albany Crescent
`Bronx, NY 10463
`
`Pursuant to 22NYCR 130-1 .1 the undersigned, an attorney admitted to practice in the
`
`Dated: September 5, 2017
`
`9of9
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