EXHIBIT A
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`NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/25/2025
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`Index No.
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`SUPREME COURT OF THE STATE OF NEW YORK
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`COUNTY OF KINGS Plaintiff designates
`KINGS County as the
`Place of Venue
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`ONEAL KERR
`Basis of Venue:
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`Plaintiff Place of Occurrence
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`SUMMONS
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`- against -
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`MONJORUL SHIAM and 7N86 &7N87 ACQUISITION, LLC
`Place of Occurrence:
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`Defendants
`County of KINGS
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`To The Above Named Defendants:
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`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 Plaintiff's attorneyswithin 20 days after the service of this
`Summons, exclusive of the day of service (of within 30 days after the service is complete
`if this summons is not personally delivered to you within the State of New York); and in the
`case of your failure to appear or answer, judgd aken against you by default for*
`the relief demanded in the Complaint.
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`Dated: Syosset, New York
`August 25, 2025
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`75 Jagkson Avenue
`Syoss ew York 11791
`(516) 496 1777
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`Defendants’ Address:
`MONJORUL SHIAM
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`118 Eldridge Street - Apt. 9
`New York, New York 10002
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`7N86 &7N87 ACQUISITION, LLC
`Secty of State (BCL)
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`NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/25/2025
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`SUPREME COURT OF THE STATE OF NEW YORK Index No.
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`COUNTY OF KINGS
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`X
`ONEAL KERR
`Plaintiff,
`VERIFIED COMPLAINT
`- against -
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`MONJORUL SHIAM and 7N86 &7N87 ACQUISITION, LLC
`Defendants.
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`X
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`Plaintiff, complaining of the Defendants, by attorneys BRIAN J. LEVY &
`ASSOCIATES, PC, respectfully shows to this Court and alleges, upon information and
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`belief, as follows:
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`1. That at all times hereinafter mentioned, Plaintiff owned a certain motor
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`vehicle bearing license plate number JEL6337, New York.
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`2. That at all times hereinafter mentioned, Plaintiff operated, managed,
`maintained and controlled the aforesaid motor vehicle bearing license plate number
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`JEL6337, New York.
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`3. That at all times hereinafter mentioned, Defendant 7N86 &7N87
`ACQUISITION, LLC is a duly organized Domestic Limited Liability Company, existing under
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`and by virtue of the laws of the State of New York.
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`4, That at all times hereinafter mentioned, Defendant 7N86 &7N87
`ACQUISITION, LLC owned a certain motor vehicle bearing license plate number
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`Y204175C, New York.
`5. That at all times hereinafter mentioned, Defendant MONJORUL SHIAM
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`operated the aforesaid motor vehicle bearing license plate number Y2041 75C, New York.
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`6. That at all times hereinafter mentioned, Defendant MONJORUL SHIAM ~
`operated the aforesaid motor vehicle while in the scope of his employment.
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`7. That at all times hereinafter mentioned, Defendant MONJORUL SHIAM
`operated the aforesaid motor vehicle while in the scope of his employment with Defendant
`7N86 &7N87 ACQUISITION, LLC
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`8. That at all times hereinafter mentioned, Defendant MONJORUL SHIAM
`operated the aforesaid motor vehicle with the knowledge, permission and/or consent of the
`Defendant 7N86 &7N87 ACQUISITION, LLC
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`9. That at all times hereinafter mentioned, Defendant 7N86 &7N87 *
`ACQUISITION, LLC managed the aforesaid motor vehicle.
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`10. That at all times hereinafter mentioned, Defendant MONJORUL SHIAM
`managed the aforesaid motor vehicle.
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`11. That at all times hereinafter mentioned, Defendant 7N86 &7N87
`ACQUISITION, LLC maintained the aforesaid motor vehicle.
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`12. That at all times hereinafter mentioned, Defendant MONJORUL SHIAM .
`maintained the aforesaid motor vehicle.
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`13. That at all times hereinafter mentioned, Defendant 7N86 &7N87
`ACQUISITION, LLC controlled the aforesaid motor vehicle.
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`14. That at all times hereinafter mentioned, Defendant MONJORUL SHIAM
`controlled the aforesaid motor vehicle.
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`15. That at all times hereinafter mentioned, Brooklyn Queens Expressway, °
`westbound, at a point approximately 2 miles west of Brooklyn Bridge, is a public highway
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`and thoroughfare in the County of Kings, City and State of New York.
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`16. That on or about the 30" day of May, 2025, at approximately 4:30 P.M., ~
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`the aforesaid motor vehicles were being operated over, along and/or about the
`aforementioned public thoroughfare.
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`17. Thatatalltimes hereinafter mentioned, the aforesaid motor vehicles were
`in a collision.
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`18. Thatat all times hereinafter mentioned, the aforesaid motor vehicles were «
`in contact.
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`19. That at all times hereinafter mentioned, the front of Defendants' motor
`vehicle was in contact with the rear of the Plaintiff's motor vehicle.
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`20. That the aforesaid occurrence was due solely by reason of the
`carelessness, recklessness and negligence of the Defendants, in the ownership, operation,
`management, maintenance and control of Defendants' motor vehicle, in failing to keep said *
`motor vehicle under proper and suitable control, so as to prevent same from running into
`and striking the rear of the Plaintiff's motor vehicle, which was then and there stopped in
`traffic; in tailgating; in failing to keep a proper distance between vehicles; in following too
`closely; in failing to slow down and stop in time to avoid striking the rear of the Plaintiff's
`stopped motor vehicle; in operating said motor vehicle at a high and/or excessive rate of
`speed, under the circumstances then and there existing; in speeding; in failing to keep a
`proper look out; in failing to take cognizance of the traffic conditions which then and there
`existed; in operating said motor vehicle in an unskilled and incompetent manner; in failing
`to make prompt and timely use of the braking and steering mechanisms of said motor
`vehicle; in failing to maintain said motor vehicle and appurtenances thereto in proper and
`adequate condition and repair; in failing to obey the applicable statutes, ordinances, rules .
`and regulations in such case made and provided for; in that Defendant 7N86 &7N87
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`ACQUISITION, LLC was further negligent in knowingly entrusting said motor vehicle to an
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`unskilled, incompetent, dangerous, reckless and careless individual, namely Defendant
`MONJORUL SHIAM; and Defendants were otherwise careless, reckless and negligent.
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`21. Thatthe aforesaid occurrence was due solely by reason of the negligence
`of the Defendants and through no fault or lack of care on the part of the Plaintiff
`contributing thereto.
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`22. That by reason of the aforesaid occurrence, Plaintiff sustained serious
`and severe personal injuries to head, body and limbs; a severe shock to the nervous
`system; suffered great physical pain and mental anguish; was confined to bed and home
`and caused to abstain from usual duties and activities; was forced to seek medical aid and
`attention and to expend diverse sums of money for same, in an endeavor to be healed and
`cured of said injuries, which may be permanent and lasting.
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`23. Thatthis Plaintiff sustained a “serious injury” as defined in §5102(d) of the
`Insurance Law of the State of New York.
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`24. Thatby reason of the foregoing, the Plaintiff is entitled to recover for non-
`economic loss and for such economic losses as are not included within the definition of
`basic economic loss as set forth in §5102(a) of the Insurance Law of the State of New
`York.
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`25. That the Plaintiff is a “covered person” as defined by §5102(j) of the
`Insurance Law of the State of New York.
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`26. That this action falls within one or more exceptions of CPLR §1602. “
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`27. That by reason of the foregoing, Plaintiff has been damaged in a sum
`which exceeds the jurisdictional limits of all lower Courts.
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`WHEREFORE, Plaintif ONEAL KERR demands judgment against the -
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`Defendants MONJORUL SHIAM and 7N86 &7N87 ACQUISITION, LLC, and/or each of
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`them, in a sum which exceeds the jurisdictional limits of all lower Courts, together with the
`costs and disbursements of each action.
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`Dated: Syosset, New York
`August 25, 2025
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`IAN JJ. LEVY & ASSOCIATES, PC
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`sset, New York 11791
`(516) 496-1777
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`NYSCEF DOC. NO. 1 RECEIVED NYSCEEF: 08/~25/2025
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`VERIFICATION
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`STATE OF NEW YORK )
`)ss.:
`COUNTY OF NASSAU )
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`BRIAN J. LEVY, an attorney duly admitted to practice in the Courts of the
`State of New York, states:
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`That | am a member of BRIAN J. LEVY & ASSOCIATES, PC, attorneys of
`record for Plaintiff in the within action. | have read the foregoing Summons and Verified
`Complaint and know the contents thereof; the same is true to my own knowledge except
`as to those matters therein alleged to be on information and belief and, as to those
`matters, | believe them to be true.
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`The reason this verification is made by me and not by Plaintiff is that the
`residence of Plaintiff is outside the County wherein your deponent maintains his office.
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`The grounds of my belief as to allmatters not stated upon my own knowledge
`are information, books, records, data ang€orrespondence contained in deponent’sfileand -
`conversations had with the Plaintiff heyein.
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`| affirm that the foregoing statements are true under the penalty of perjury.
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`Dated: Syooset, New York
`August 25, 2025
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`NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/25/2025
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`Index No.
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF KINGS
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`ONEAL KERR
`Plaintiff,
`- against -
`MONJORUL SHIAM and 7N86 &7N87 ACQUISITION, LLC
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`Defendants.
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`SUMMONS AND VERIFIED COMPLAINT
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`BRIAN J. LEVY & ASSOCIATES, PC
`Attomeys for Plaintiff
`Office and Post Office Address
`75 Jackson Avenue
`Syosset, New York 11791
`Tel (516) 496-1777
`Fax (516) 226-1040
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`ATTORNEY QIFICATION
`The undersigned, an Attorney adpnitted to practice in the Courts of New
`York State, verified that, upan information,. belief and reasonable inquiry, the
`contents contained in the ab ced document(s) are not frivolous.
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