Preview
FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF KINGS Date Filed:
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SUMMONS
MUBASSHAR AHMAD,
Plaintiff designates KINGS
Plaintiff, County as the place of trial.
-against- The basis of venue is:
Location of Incident
FRANK A. DIMAULO, Location of Incident:
907C Eastbound Belt Parkway
Defendant. County of Kings
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TO THE ABOVE-NAMED DEFEDANT:
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 Plaintiff s attorneys 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
June 28, 2019
Yours, etc.
THE L L FIRM, P.C.
By:
y Solomon, Esq.
ttorneys for Plaintiff
MUBASSHAR AHMAD
45 Broadway, Suite 3120
New York, New York 10006
(212) 285-2100
To:
FRANK A. DIMAULO
14 East Rogues Path
Huntington Station, New York 11746
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FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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MUBASSHAR AHMAD, Index No.:
Plaintiff, VERIFIED COMPLAINT
-against-
FRANK A. DIMAULO,
Defendant.
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Plaintiff MUBASSHAR AHMAD, by his attomeys, THE LAMBROU LAW FIRM,
P.C., as and for his VERIFIED COMPLAINT against Defendant FRANK A. DIMAULO,
states as follows:
1. At the time of the commencement of this action, Plaintiff MUBASSHAR
AHMAD was, and still is,a resident of the County of Queens, State of New York.
2. That on or about February 15, 2019, Defendant FRANK A. DIMAULO was, and
stillis, a resident of the County of Suffolk, State of New York.
3. That on or about February 15, 2019, and upon information and belief, Plaintiff
MUBASSHAR AHMAD owned, operated, and controlled a 2002 Ford type motor vehicle
bearing New York State license plate number GXV7693.
4. That on or about February 15, 2019, and upon information and belief, Defendant
FRANK A. DIMAULO operated and controlled a 2018 Hyundai type motor vehicle bearing
Virginia State license plate number UZW3976.
5. That on or about February 15, 2019, and upon information and belief, the Belt
Parkway, at or near the Jamaica Bay Riding Academy Entrance, in the County of Kings, State of
New York, was, and stillis, a public road used extensively by the public in general.
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FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019
6. That on or about February 15, 2019, at the aforesaid location, Defendant's 2018
Hyundai type motor vehicle bearing Virginia State license plate number UZW3976 negligently
struck the motor vehicle operated and controlled by Plaintiff, a 2002 Ford type motor vehicle
bearing New York State license plate number GXV7693, causing a collision.
7. That the aforesaid collision and the injuries sustained by Plaintiff resulting
therefrom were due solely and wholly as a result of the careless and negligent manner in which
Defendant managed, operated, and controlled his aforementioned motor vehicle, without Plaintiff
in any way contributing thereto.
8. That by reason of the foregoing, culpable conduct and the negligence of Defendant,
Plaintiff sustained serious, severe, and permanent injuries and still suffers and will continue to
suffer for some time from great physical and mental pain and serious bodily injury and so
remained for a considerable length of time.
9. That by reason of the foregoing, culpable conduct and the sole negligence of
Defendant, Plaintiff is informed and verily believes his aforesaid injuries are permanent and that he
will permanently suffer from the effects of his aforesaid injuries and he will be caused to suffer
permanent embarrassment and continuous pain and inconvenience and may require future surgical
intervention.
10. That by reason of the foregoing, Plaintiff was compelled and did necessarily require
medical aid and attention and did necessarily pay and become liable therefore, for medicines and,
upon information and belief, Plaintiff will necessarily incur similar expenses in the future for
medical and rehabilitation costs as well as other related expenses, including physical therapy and
future surgery costs.
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FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019
11. That by reason of the culpable conduct and wrongful, negligent,
actions of Defendant, as aforesaid, Plaintiff was severely injured, bruised and wo
still suffers, and will continue to suffer for some time great physical pain and grea
and became sick, sore, lame, and disabled and so remained for a considerable length
12. That as a result of Defendant's negligence, as aforesaid, Plaintiff
and damaged in a sum which exceeds the jurisdictional limitations of all lowe
would otherwise have jurisdiction in this matter.
WHEREFORE, Plaintiff MUBASSHAR AHMAD demands jud
Defendant FRANK A. DIMAULO on all causes of action in an amount wh
jurisdictional limitations of all lower courts, which would otherwise have jurisdict
action, together with the interest, costs, and disbursements of this action.
Dated: New York, New York
June 28, 2019
Yours, etc.
THE LAMB IRM, P
By:
Ronny Solomon, Esq.
Attorneys for Plaintiff
MUBASSHAR AHMAD
45 Broadway, Suite 3120
4 of 5
New New York 10006
FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019
ATTORNEY'S VERIFICATION
Ronny Solomon, an attorney duly admitted to practice before the Courts
York, affirms the following to be true, under the penalties of perjury:
I am the
attorney of Plaintiff herein. I have read the annexed:
VERIFIED COMPLAINT
and know the content thereof, and the same are true to my knowledge, except
which are stated to be alleged upon information and belief, and as to those matters
true. My belief, as to those matters therein not stated upon knowledge, is based upon
other pertinent information contained in my files.
The reason this verification is made by me and not Plaintiff is that Plaintiff
reside in the county wherein I maintain my offices.
Dated: New York, New York
June 28, 2019
Ronny Solomon, Esq.
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Preview
FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF KINGS Date Filed: --------------------------------------------------------------------X SUMMONS MUBASSHAR AHMAD, Plaintiff designates KINGS Plaintiff, County as the place of trial. -against- The basis of venue is: Location of Incident FRANK A. DIMAULO, Location of Incident: 907C Eastbound Belt Parkway Defendant. County of Kings ---------------------------------------------------X TO THE ABOVE-NAMED DEFEDANT: 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 Plaintiff s attorneys 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 June 28, 2019 Yours, etc. THE L L FIRM, P.C. By: y Solomon, Esq. ttorneys for Plaintiff MUBASSHAR AHMAD 45 Broadway, Suite 3120 New York, New York 10006 (212) 285-2100 To: FRANK A. DIMAULO 14 East Rogues Path Huntington Station, New York 11746 1 of 5 FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------------X MUBASSHAR AHMAD, Index No.: Plaintiff, VERIFIED COMPLAINT -against- FRANK A. DIMAULO, Defendant. -----------------------------------------------------------X Plaintiff MUBASSHAR AHMAD, by his attomeys, THE LAMBROU LAW FIRM, P.C., as and for his VERIFIED COMPLAINT against Defendant FRANK A. DIMAULO, states as follows: 1. At the time of the commencement of this action, Plaintiff MUBASSHAR AHMAD was, and still is,a resident of the County of Queens, State of New York. 2. That on or about February 15, 2019, Defendant FRANK A. DIMAULO was, and stillis, a resident of the County of Suffolk, State of New York. 3. That on or about February 15, 2019, and upon information and belief, Plaintiff MUBASSHAR AHMAD owned, operated, and controlled a 2002 Ford type motor vehicle bearing New York State license plate number GXV7693. 4. That on or about February 15, 2019, and upon information and belief, Defendant FRANK A. DIMAULO operated and controlled a 2018 Hyundai type motor vehicle bearing Virginia State license plate number UZW3976. 5. That on or about February 15, 2019, and upon information and belief, the Belt Parkway, at or near the Jamaica Bay Riding Academy Entrance, in the County of Kings, State of New York, was, and stillis, a public road used extensively by the public in general. 2 of 5 FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019 6. That on or about February 15, 2019, at the aforesaid location, Defendant's 2018 Hyundai type motor vehicle bearing Virginia State license plate number UZW3976 negligently struck the motor vehicle operated and controlled by Plaintiff, a 2002 Ford type motor vehicle bearing New York State license plate number GXV7693, causing a collision. 7. That the aforesaid collision and the injuries sustained by Plaintiff resulting therefrom were due solely and wholly as a result of the careless and negligent manner in which Defendant managed, operated, and controlled his aforementioned motor vehicle, without Plaintiff in any way contributing thereto. 8. That by reason of the foregoing, culpable conduct and the negligence of Defendant, Plaintiff sustained serious, severe, and permanent injuries and still suffers and will continue to suffer for some time from great physical and mental pain and serious bodily injury and so remained for a considerable length of time. 9. That by reason of the foregoing, culpable conduct and the sole negligence of Defendant, Plaintiff is informed and verily believes his aforesaid injuries are permanent and that he will permanently suffer from the effects of his aforesaid injuries and he will be caused to suffer permanent embarrassment and continuous pain and inconvenience and may require future surgical intervention. 10. That by reason of the foregoing, Plaintiff was compelled and did necessarily require medical aid and attention and did necessarily pay and become liable therefore, for medicines and, upon information and belief, Plaintiff will necessarily incur similar expenses in the future for medical and rehabilitation costs as well as other related expenses, including physical therapy and future surgery costs. 3 of 5 FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019 11. That by reason of the culpable conduct and wrongful, negligent, actions of Defendant, as aforesaid, Plaintiff was severely injured, bruised and wo still suffers, and will continue to suffer for some time great physical pain and grea and became sick, sore, lame, and disabled and so remained for a considerable length 12. That as a result of Defendant's negligence, as aforesaid, Plaintiff and damaged in a sum which exceeds the jurisdictional limitations of all lowe would otherwise have jurisdiction in this matter. WHEREFORE, Plaintiff MUBASSHAR AHMAD demands jud Defendant FRANK A. DIMAULO on all causes of action in an amount wh jurisdictional limitations of all lower courts, which would otherwise have jurisdict action, together with the interest, costs, and disbursements of this action. Dated: New York, New York June 28, 2019 Yours, etc. THE LAMB IRM, P By: Ronny Solomon, Esq. Attorneys for Plaintiff MUBASSHAR AHMAD 45 Broadway, Suite 3120 4 of 5 New New York 10006 FILED: KINGS COUNTY CLERK 06/28/2019 12:15 PM INDEX NO. 514359/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/28/2019 ATTORNEY'S VERIFICATION Ronny Solomon, an attorney duly admitted to practice before the Courts York, affirms the following to be true, under the penalties of perjury: I am the attorney of Plaintiff herein. I have read the annexed: VERIFIED COMPLAINT and know the content thereof, and the same are true to my knowledge, except which are stated to be alleged upon information and belief, and as to those matters true. My belief, as to those matters therein not stated upon knowledge, is based upon other pertinent information contained in my files. The reason this verification is made by me and not Plaintiff is that Plaintiff reside in the county wherein I maintain my offices. Dated: New York, New York June 28, 2019 Ronny Solomon, Esq. 5 of 5