FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 718826/2024
`
`RECEIVED NYSCEF: 09/12/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF QUEENS
`-------------------------------------------------------------------------------------------x
`KERIME YAZAR and RAHMI YAZAR,
`
`Plaintiff(s),
`
`-against-
`
`A.M. HOLIDAYS, LLC and
`M. LEASES, LLC,
`
`Index No.:
`Filed On:
`
`Plaintiff(s) designates Queens
`County as the Place of Trial
`Place of Incidence
`
`SUMMONS
`Plaintiff(s)’ Residence
`57-04 Van Horn Street
`County of Queens
`
`Defendant(s).
`-------------------------------------------------------------------------------------------x
`TO THE ABOVE-NAMED DEFENDANT(S)
`
`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)’ Attorney(s) within (20) days after the service of this
`summons, exclusive of the date of service (or within thirty (30) days after the service is complete
`if this Summons is not personally delivered to you within the State of New York); and in case
`of your failure to appear or answer, judgment will be taken against you by default for the relief
`demanded in the Complaint with interest and cost from the date of occurrence.
`
`Dated: Bronx, New York
`September 12, 2024
`
`Yours, etc.
`
`LESCH & LESCH, P.C.
`
`By: ____________________________
`DAVID P. LESCH, ESQ.
`Attorneys for Plaintiff(s)
`860 Grand Concourse, Suite 2M
`Bronx, New York 10451
`(718) 292-1131
`
`1 of 14
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`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF QUEENS
`-------------------------------------------------------------------------------------------x
`KERIME YAZAR and RAHMI YAZAR,
`
`Plaintiff(s),
`
`-against-
`
`A.M. HOLIDAYS, LLC and
`M. LEASES, LLC,
`
`Index No.:
`Filed On:
`
`Plaintiff(s) designates Queens
`County as the Place of Trial
`Place of Incidence
`
`SUMMONS
`Plaintiff(s)’ Residence
`57-04 Van Horn Street
`County of Queens
`
`Defendant(s).
`-------------------------------------------------------------------------------------------x
`TO THE ABOVE-NAMED DEFENDANT(S)
`
`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)’ Attorney(s) within (20) days after the service of this
`summons, exclusive of the date of service (or within thirty (30) days after the service is complete
`if this Summons is not personally delivered to you within the State of New York); and in case
`of your failure to appear or answer, judgment will be taken against you by default for the relief
`demanded in the Complaint with interest and cost from the date of occurrence.
`
`Dated: Bronx, New York
`September 12, 2024
`
`Yours, etc.
`
`LESCH & LESCH, P.C.
`
`By: ____________________________
`DAVID P. LESCH, ESQ.
`Attorneys for Plaintiff(s)
`860 Grand Concourse, Suite 2M
`Bronx, New York 10451
`(718) 292-1131
`
`1 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`Plaintiff(s) designate Queens County as the place of trial.
`The basis of the designation is:
`
`Defendant(s)’ Address
`A.M. HOLIDAYS, LLC – Served by Secretary of State Only
`95-20 63rd Road, Suite #S
`Rego Park, New York 11374
`
`M. LEASES, LLC – Served by Secretary of State Only
`C/o AVI MANSHER
`95-20 63rd Road, Suite #S
`Rego Park, New York 11374
`
`VENUE:
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`
`
`
`
`
`
`
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`NOTICE: The nature of this action is: Personal Injury
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`The relief sought is: As demanded in complaint
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`Upon your failure to appear, judgment will be taken against you by default for the sum as
`demanded in complaint with interest from March 1, 2024 until the present, and the costs of
`this action.
`
`
`Plaintiff(s)’ residence and place of accident in Queens County: 57-04 Van
`Horn Street
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`2 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF QUEENS
`-------------------------------------------------------------------------------------------x
`KERIME YAZAR and RAHMI YAZAR,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff(s),
`
`
`
`
`
`
`-against-
`
`
`
`
`
`
`A.M. HOLIDAYS, LLC and
`M. LEASES, LLC,
`
`
`Defendant(s).
`
`
`
`
`-------------------------------------------------------------------------------------------x
`
`
`
`
`
`
`
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`
`
`
`
`
`
`
`VERIFIED COMPLAINT
`Index No.:
`
`
`
`
`
`
`
`
`
`
`Plaintiff(s), KERIME YAZAR and RAHMI YAZAR, by their attorneys, LESCH &
`
`LESCH P.C., complaining of the Defendant(s), A.M. HOLIDAYS, LLC and M. LEASES,
`
`LLC and sets forth the following, upon information and belief:
`
`1.
`
`That at all times herein mentioned, Plaintiff(s) were and still are residents of
`
`the County of Queens, City and State of New York.
`
`2.
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`That at all times herein mentioned, the Defendant(s), A.M. HOLIDAYS,
`
`LLC was and still is a domestic limited liability company duly authorized to do business in
`
`the State of New York.
`
`3.
`
`That at all times herein mentioned, the Defendant(s), A.M. HOLIDAYS,
`
`LLC maintained a principal place of business in the County of Queens, City and State of
`
`New York.
`
`4.
`
`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), A.M. HOLIDAYS, LLC, owned the premises and appurtenances and
`
`fixtures thereto, located at 57-04 Van Horn Street, Queens, New York, 11373.
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`5.
`
`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), A.M. HOLIDAYS, LLC, by its agents, servants and/or employees
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`maintained the aforesaid premises.
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`3 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`6.
`
`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), A.M. HOLIDAYS, LLC, by its agents, servants and/or employees
`
`controlled the aforesaid premises.
`
`7.
`
`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), A.M. HOLIDAYS, LLC, by its agents, servants and/or employees
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`operated the aforesaid premises.
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`8.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), A.M. HOLIDAYS, LLC, by its agents, servants and/or employees
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`supervised the aforesaid premises.
`
`9.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), A.M. HOLIDAYS, LLC, by its agents, servants and/or employees repaired
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`the aforesaid premises.
`
`10.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), A.M. HOLIDAYS, LLC, by its agents, servants and/or employees
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`inspected the aforesaid premises.
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`11.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), A.M. HOLIDAYS, LLC, was the lessor of the aforesaid premises.
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`12.
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`That at all times herein mentioned, the Defendant(s), M. LEASES, LLC was
`
`and still is a domestic limited liability company duly authorized to do business in the State of
`
`New York.
`
`13.
`
`That at all times herein mentioned, the Defendant(s), M. LEASES, LLC
`
`maintained a principal place of business in the County of Queens, City and State of New
`
`York.
`
`14.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), M. LEASES, LLC, owned the premises and appurtenances and fixtures
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`thereto, located at 57-04 Van Horn Street, Queens, New York, 11373.
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`4 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`15.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), M. LEASES, LLC, by its agents, servants and/or employees maintained the
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`aforesaid premises.
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`16.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), M. LEASES, LLC, by its agents, servants and/or employees controlled the
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`aforesaid premises.
`
`17.
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`That at all times herein mentioned and from March 1, 2024 until the present,
`
`the Defendant(s), M. LEASES, LLC, by its agents, servants and/or employees operated the
`
`aforesaid premises.
`
`18.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), M. LEASES, LLC, by its agents, servants and/or employees supervised the
`
`aforesaid premises.
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`19.
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`That at all times herein mentioned and from March 1, 2024 until the present,
`
`the Defendant(s), M. LEASES, LLC, by its agents, servants and/or employees repaired the
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`aforesaid premises.
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`20.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), M. LEASES, LLC, by its agents, servants and/or employees inspected the
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`aforesaid premises.
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`21.
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`That at all times herein mentioned and from March 1, 2024 until the present,
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`the Defendant(s), M. LEASES, LLC, was the lessor of the aforesaid premises.
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`22.
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`The building commonly known as 57-04 VAN HORN STREET in the County
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`of Queens, City and State of New York is rented, leased, let, or hired out to be occupied as a
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`residence of three or more families living independent from each other.
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`23.
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`At all times mentioned herein, on or about March 1, 2024 until the present,
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`Plaintiff(s) KERIME YAZAR and RAHMI YAZAR, lawfully leased from the Defendant(s)
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`A.M. HOLIDAYS, LLC the apartment known as 3 in the aforementioned building.
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`5 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`24. On or about March 1, 2024 until the present, while Plaintiff(s) KERIME
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`YAZAR and RAHMI YAZAR, were lawfully about the aforesaid premises, they were caused
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`to sustain serious and permanent injuries as a result of the bed bug infestation and of being
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`bitten by said vermin.
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`25.
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`The above-mentioned occurrence and the result thereof, were caused by the
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`negligence of the Defendant(s) and/or said Defendant(s)’ agents, servants, employees, and/or
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`licensees in the ownership, operation, management, supervision, maintenance, and control of
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`the aforesaid premises.
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`That Defendant(s) had actual notice of this defective condition.
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`That Defendant(s) had constructive notice of this defective/ defective
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`26.
`
`27.
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`condition.
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`28.
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`That Defendant(s) caused and/or created dangerous /defective condition cited
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`above.
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`29.
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`That on or prior to March 1, 2024, Defendant(s) had actual notice of the
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`condition described above and received violations from the New York City Housing
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`Preservation and Development for this condition.
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`30.
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`That from March 1, 2024 until the present, Defendant(s) and/or said
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`Defendant(s)’ servants, agents, employees, and/or licensees were negligent in that they
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`breached their duty to keep the aforementioned premises in a safe, proper and secure
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`condition, in good repair and free from obstruction, defect, nuisance, and hazardous,
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`dangerous and trap like conditions.
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`31.
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`That upon information and belief, Defendant(s) and/or said Defendant(s)’
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`servants, agents, employees and/or licensees had actual/or constructive notice of the
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`aforementioned obstructive, defect, nuisance, and hazardous, dangerous and trap like
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`condition.
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`6 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`32.
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`That the amount of damage sustained by Plaintiff(s) KERIME YAZAR and
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`RAHMI YAZAR, exceeds the jurisdictional limits of the lower courts which would have
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`jurisdiction in all causes of action alleged in this complaint.
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`AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF
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`PLAINTIFF KERIME YAZAR
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`33.
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`Plaintiff(s) repeats and reiterates each and every allegation in paragraph “1”
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`through “32” as set forth fully and at length herein.
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`34.
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`The above-mentioned occurrence and the results thereof, were caused by the
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`negligence of the Defendant(s) and/or said Defendant(s)’ agents, servants, employees and/or
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`licensees in the ownership, operation, management, supervision, maintenance and control of
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`the aforesaid premises.
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`35.
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`That no negligence on the part of the Plaintiff(s) contributed to the occurrence
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`alleged herein in any manner whatsoever.
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`36.
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`That by reason of the foregoing, Plaintiff(s) KERIME YAZAR was caused to
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`sustain serious injuries and to have suffered pain, shock and mental anguish; that these
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`injuries and their effects will be permanent; and as a result of said injuries Plaintiff(s) has been
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`caused to incur, and will continue to incur, expenses for medical care and attention; and, as a
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`further result Plaintiff(s) was, and will continue to be, rendered unable to perform Plaintiff(s)’
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`normal activities and duties and has sustained a resultant loss therefrom.
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`AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF
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`PLAINTIFF RAHMI YAZAR
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`37.
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`Plaintiff(s) repeats and reiterates each and every allegation in paragraph “1”
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`through “36” as set forth fully and at length herein.
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`38.
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`The above-mentioned occurrence and the results thereof, were caused by the
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`negligence of the Defendant(s) and/or said Defendant(s)’ agents, servants, employees and/or
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`7 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`licensees in the ownership, operation, management, supervision, maintenance and control of
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`the aforesaid premises.
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`39.
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`That no negligence on the part of the Plaintiff(s) contributed to the occurrence
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`alleged herein in any manner whatsoever.
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`40.
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`That by reason of the foregoing, Plaintiff(s) RAHMI YAZAR was caused to
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`sustain serious injuries and to have suffered pain, shock and mental anguish; that these injuries
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`and their effects will be permanent; and as a result of said injuries Plaintiff(s) has been caused
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`to incur, and will continue to incur, expenses for medical care and attention; and, as a further
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`result Plaintiff(s) was, and will continue to be, rendered unable to perform Plaintiff(s)’ normal
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`activities and duties and has sustained a resultant loss therefrom.
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`AS AND FOR A THIRD CAUSE OF ACTION FOR
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`VIOLATION OF RPL §235-b
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`41.
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`Plaintiff(s) repeats and re-alleges each and every allegation in paragraph “1”
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`through “40” as set forth fully and at length herein.
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`42.
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`That on or about March 1, 2024 until the present, at the aforementioned
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`location, Plaintiff(s) have been subjected to conditions that are dangerous, hazardous and
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`detrimental to his health, and safety.
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`43.
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`44.
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`That Defendant(s) were given notice of the condition.
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`That the aforementioned condition was not introduced to the subject
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`premises through any fault of Plaintiff(s).
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`45.
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`That Defendant(s) were strictly liable for the condition in the premises, and
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`responsible for taking reasonable actions to eliminate the condition.
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`46.
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`47.
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`That the condition continues and Defendant(s) failed to remedy it.
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`That the presence of bed bugs in the Plaintiff(s)’ apartment constitutes a
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`breach of their warranty of habitability.
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`48.
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`By reason of the foregoing, Plaintiff(s) sustained the damages alleged herein.
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`8 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`49.
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`Accordingly, Plaintiff(s) is entitled to compensatory damages, punitive
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`damages and reasonable attorney’s fees and costs.
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`AS AND FOR A FOURTH OF ACTION FOR
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`RECKLESS CAUSE OF ACTION OF PRIOR NOTICE
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`50.
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`Plaintiff(s) repeats and re-alleges each and every allegation contained in
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`paragraph “1” through “49” as set forth fully and at length herein.
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`51. Upon information and belief, that at all times heretofore mentioned, the
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`Defendant(s) were under the non-delegable duty, pursuant to the laws of the State of New
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`York and the City of New York to maintain the building in a safe and proper condition.
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`52.
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`That on or about March 1, 2024 until the present, Defendant(s) were on
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`notice of a bed bug infestation in the building and took no steps to remedy the condition,
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`illegally delegated their duty to remedy the conditions to individual tenants, and acted
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`recklessly in allowing the condition to spread throughout the building including Plaintiff(s)’
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`apartment causing damage and harm to Plaintiff(s).
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`53.
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`That as a direct and proximate result of Defendant(s)’ actions and failure to
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`act, Plaintiff sustained the damages alleged herein.
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`54.
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`Accordingly, Plaintiff(s) are entitled to compensatory damages, punitive
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`damages and reasonable attorney’s fees and costs.
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`AS AND FOR A FIFTH CAUSE OF ACTION FOR
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`CONSTRUCTIVE EVICTION
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`55.
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`Plaintiff(s) repeats and re-alleges each and every allegation contained in
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`paragraph “1” through “54” as set forth fully and at length herein.
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`56.
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`That the Defendant(s) wrongful acts and omission has substantially and
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`materially deprived the Plaintiff of the beneficial use and enjoyment of their apartment.
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`57.
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`By reason of the foregoing, Plaintiff(s) sustained the damages alleged herein.
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`9 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`58.
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`Accordingly, Plaintiff(s) are entitled to compensatory damages, punitive
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`damages and reasonable attorney’s fees and costs.
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`AS AND FOR A SIXTH CAUSE OF ACTION FOR INTENTIONAL/
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`NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
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`59.
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`Plaintiff(s) repeats and re-alleges each and every allegation contained in
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`paragraph “1” through “58” as set forth fully and at length herein.
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`60.
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`That Defendant(s)’ conduct was extreme and outrageous, and it caused
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`Plaintiff(s) to suffer mental and emotional distress.
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`61.
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`That Defendant(s) intended to cause or recklessly caused Plaintiff(s)’ mental
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`and emotional distress.
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`62.
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`By reason of the foregoing, Plaintiff(s) are entitled to compensatory damages,
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`punitive damages, reasonable attorney’s fee and costs.
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`AS AND FOR A SEVENTH CAUSE OF ACTION FOR NUISANCE
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`63.
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`Plaintiff(s) repeats and re-alleges each and every allegation contained in
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`paragraphs “1” through “62” as set forth fully and at length herein.
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`64.
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`That the presence of bed bugs in Defendant(s)’ apartment constitutes a
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`nuisance.
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`65.
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`66.
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`That Defendant(s) created or maintained that nuisance.
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`That Defendant(s) knew of or had notice of the bed bug infestation yet failed
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`to abate or remedy the condition.
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`67.
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`That Defendant(s) morally culpable and their actions were motivated by
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`reprehensible intentions.
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`68.
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`69.
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`By reasons of the foregoing, Plaintiff(s) sustained the damages alleged herein.
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`Accordingly, Plaintiff(s) are entitled to compensatory damages, punitive
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`damages, reasonable attorney’s fees and costs.
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`10 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`AS AND FOR AN EIGHT CAUSE OF ACTION ON BEHALF OF THE
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`PLAINTIFFS BASED UPON BREACH OF WARRANTY OF HABITABILITY
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`70.
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`That this Plaintiff(s) repeat, restate, and reiterate each paragraph set forth in
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`the First and Second Causes of Action as if fully set forth herein.
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`71.
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`That upon information and belief, and at all times herein mentioned, the
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`premises leased by the Defendant(s) to Plaintiff(s) and/or the common areas were not fit for
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`human habitation and for users reasonably intended by the parties.
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`72.
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`That upon information and belief, and at all times hereinafter mentioned, the
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`Defendant(s) subjected the Plaintiff(s) to conditions which were dangerous, hazardous and/or
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`detrimental to life, health and safety.
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`73.
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`That upon information and belief, and at all times hereinafter mentioned, the
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`Defendant(s) breached the warranty of habitability by causing and/or allowing defects and/or
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`conditions in the dwelling which deprive tenant(s) of those essential functions which an owner
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`and lessor is expected to provide.
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`AS AND FOR A NINTH CAUSE OF ACTION
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`FOR BREACH OF CONTRACT
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`74.
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`Plaintiff(s) repeats and re-alleges each and every allegation set forth in
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`Paragraphs “1” through “73” with the same force and effects as if fully set forth herein in
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`entirety.
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`75. Defendant(s) had a contractual duty to make timely repairs to the Premises,
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`including extermination for infestation of bed bugs. Plaintiff(s) reasonably relied upon that
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`duty to their detriment.
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`76. Defendant(s) breached its contract with Plaintiff(s).
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`77.
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`Plaintiff(s) seeks damages for breach of Contract in the amount of
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`$1,000,000.00.
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`11 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
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`INDEX NO. 718826/2024
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`RECEIVED NYSCEF: 09/12/2024
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`
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`WHEREFORE, Plaintiff(s) KERIME YAZAR and RAHMI YAZAR, demand
`
`judgment against Defendant(s), A.M. HOLIDAYS, LLC and M. LEASES, LLC and in such
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`amount which will fairly compensate Plaintiff(s) for their injuries from March 1, 2024 until the
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`present with interest, costs and disbursements.
`
`
`Dated: Bronx, New York
`September 12, 2024
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`Yours, etc.
`
`LESCH & LESCH, P.C.
`
`By: ____________________________
`DAVID P. LESCH, ESQ.
`Attorneys for Plaintiff(s)
`860 Grand Concourse, Suite 2M
`Bronx, New York 10451
`(718) 292-1131
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`12 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 718826/2024
`
`RECEIVED NYSCEF: 09/12/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF QUEENS
`-------------------------------------------------------------------------------------------x
`
`KERIME YAZAR and RAHMI YAZAR,
`
`Plaintiff(s),
`
`VERIFICATION
`Index No.:
`
`-against-
`
`A.M. HOLIDAYS, LLC and
`M. LEASES, LLC,
`
`-------------------------------------------------------------------------------------------x
`
`Defendant(s).
`
`STATE OF NEW YORK
`
` s.s.:
`
`COUNTY OF BRONX
`
`}
`
`}
`
`DAVID P. LESCH, under the penalty of perjury and pursuant to CPLR, hereby affirms the
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`truth of the following statements:
`
`I am the attorney for the Plaintiff(s) in the within action and have read the foregoing
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`SUMMONS AND COMPLAINT. That the same is true to my knowledge, expect as to
`
`those matters therein stated to be alleged upon information and belief, and as to those
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`matters, I believe them to be true.
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`This verification is made by deponent and not by the Plaintiff(s) since the Plaintiff(s) is not a
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`resident of the County where deponent maintains his office.
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`The grounds of deponent’s belief as to all matters not stated to be alleged upon information
`
`and belief are as follows:
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`COMMUNICATIONS AND CONVERSATIONS HAD WITH PLAINTIFF AND
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`UPON DOCUMENTS AND INFORMATION CONTAINED IN DEPONENT’S FILE.
`
`Dated: Bronx, New York
`
`September 12, 2024
`
`DAVID P. LESCH, ESQ.
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`13 of 14
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`FILED: QUEENS COUNTY CLERK 09/12/2024 09:28 AM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 718826/2024
`
`RECEIVED NYSCEF: 09/12/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF QUEENS
`
`KERIME YAZAR and RAHMI YAZAR,
`
`
`
`
`
`
`
`
`
`
`-against-
`
`
`A.M. HOLIDAYS, LLC and
`M. LEASES, LLC,
`
`
`
`
`
`Plaintiff(s),
`
`
`
`
`
`
`
`Defendant(s).
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Index No.:
`
`
`
`
`
`
`
`
`
`
`SUMMONS & VERIFIED COMPLAINT
`
`
`LESCH & LESCH, P.C.
`Attorneys for Plaintiff(s)
`Office & P.O. Address
`860 Grand Concourse, Suite 2M
`Bronx, New York 10451
`(718) 292-1131
`
`
`
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`
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`14 of 14
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`
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