On October 01, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Lorenzo Gabriel,
and
Noel Paul,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 01/10/2020 03:02 PM INDEX NO. 519700/2018
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 01/10/2020
.
EXHIBIT A
FILED: KINGS COUNTY CLERK 01/10/2020 03:02 PM INDEX NO. 519700/2018
|EILED:
NYSCEF KINGSNO.COUNTY
DOC. 26 CLERK 10/_0_1/2018 03:21 RECEIVED INDEX NO. 01/10/2020
NYSCEF: 519700/2018
PM)
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-----------====X
LORENZO GABRIEL,
SUMMONS
Plaintiff,
-against-
NOEL PAUL,
Defendant.
---- -=X
Plaintiff designates Kings County as the place of trialbased upon his residence at 121
2nd
Tapscott Street, Floor, Brooklyn, New York 11212,
To the above-named Defendant:
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a
copy of your Answer, or, ifthe Complaint is not served with this Summons, to serve a Notice of
Appearance on the Plaintiff's Attorneys within 20 days after the service of this Summons,
exclusive of the day of service (or within 30 days after the service is complete ifthis Summons is
not personally delivered to you within the State of New York). In case of your failure to appear
or answer, judgment will be taken against you by default for the relief demanded herem.
Dated: Garden City,.New York
September 28, 2018
Paul Ajlouny & Associates, P,C.
By: Paul Ajlouny, Esq.
Attorneys for Plaintiff
320 Old Country Road, Suite 205
Garden City, New York 11530
(516) 535-5555
Defendant's Address:
NOEL PAUL
681 Howard Avenue
Brooklyn, New York 11212
FILED: KINGS COUNTY CLERK 01/10/2020 03:02 PM INDEX NO. 519700/2018
FILED:
NYSCEF KINGSNO.COUNTY
DOC. 26 CLERK 10/01/2018 03:21 RECEIVED INDEX NO. 01/10/2020
NYSCEF: 519700/2018
PM|
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-- --X
LORENZO GABRIEL,
COMPLAINT
Plaintiff,
-against-
NOEL PAUL,
Defendant.
=X
Plaintiff alleges the following, upon information and belief:
1. Plaintiff resides in Kings County, New York.
2. At all relevant times, Defendant owned and operated a motor vehicle bearing New York
plate number EGF2165 or similar number.
3. At allrelevant times, Blake Avenue at or near Union Street, County of Kings, Stateof New
York was a public highway.
4. On or about October 27, 2016, at the aforementioned place, the aforementioned vehicle
struck Plaintiff, a pedestrian.
5. At the time and place aforesaid, Defendant was negligent in the ownership and operation
of the aforementioned vehicle.
6. Solely by reason of the aforementioned negligence Plaintiff sustained a serious injury and/or
greater than basic ceonomic loss as defined in New York's Insurance Law.
7. This action falls within one or more of the exceptions contained in Article 16 of the
CPLR.
8. Plaintiff's damages exceed the jurisdictional limits of alllower courts.
Plaintiff demands judgment in an amount to be determined at trialwith costs and disbursements.
2 of 4
FILED: KINGS COUNTY CLERK 01/10/2020 03:02 PM INDEX NO. 519700/2018
[F¯I¯LED: DOC.
KINGSNO. COUNTY CLERK 10-/-0-1-/2018 03-f21 PM INDEX NO. 519700/2018
NYSCEF 26 RECEIVED NYSCEF: 01/10/2020
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2018
ATTORNEY'S VERIFICATION
I have read the annexed Summons and Complaint and know the contents thereof, and the
sanie are true to my knowledge, except for those matters therein stated upon information and belief,
and as to those matters, I believe them to be true. The reason I make this verification instead of
the Plaintiff herein isthat said Plaintiff does not reside in the County where I maintain my office.
Dated: Garden City, New York
September 28, 2018
Paul Xjlouny, E .
4 of 4
Document Filed Date
January 10, 2020
Case Filing Date
October 01, 2018
Category
Torts - Motor Vehicle
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Preview
FILED: KINGS COUNTY CLERK 01/10/2020 03:02 PM INDEX NO. 519700/2018 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 01/10/2020 . EXHIBIT A FILED: KINGS COUNTY CLERK 01/10/2020 03:02 PM INDEX NO. 519700/2018 |EILED: NYSCEF KINGSNO.COUNTY DOC. 26 CLERK 10/_0_1/2018 03:21 RECEIVED INDEX NO. 01/10/2020 NYSCEF: 519700/2018 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -----------====X LORENZO GABRIEL, SUMMONS Plaintiff, -against- NOEL PAUL, Defendant. ---- -=X Plaintiff designates Kings County as the place of trialbased upon his residence at 121 2nd Tapscott Street, Floor, Brooklyn, New York 11212, To the above-named Defendant: YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or, ifthe Complaint is not served with this Summons, to serve a Notice of Appearance on the Plaintiff's Attorneys within 20 days after the service of this Summons, exclusive of the day of service (or within 30 days after the service is complete ifthis Summons is not personally delivered to you within the State of New York). In case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herem. Dated: Garden City,.New York September 28, 2018 Paul Ajlouny & Associates, P,C. By: Paul Ajlouny, Esq. Attorneys for Plaintiff 320 Old Country Road, Suite 205 Garden City, New York 11530 (516) 535-5555 Defendant's Address: NOEL PAUL 681 Howard Avenue Brooklyn, New York 11212 FILED: KINGS COUNTY CLERK 01/10/2020 03:02 PM INDEX NO. 519700/2018 FILED: NYSCEF KINGSNO.COUNTY DOC. 26 CLERK 10/01/2018 03:21 RECEIVED INDEX NO. 01/10/2020 NYSCEF: 519700/2018 PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -- --X LORENZO GABRIEL, COMPLAINT Plaintiff, -against- NOEL PAUL, Defendant. =X Plaintiff alleges the following, upon information and belief: 1. Plaintiff resides in Kings County, New York. 2. At all relevant times, Defendant owned and operated a motor vehicle bearing New York plate number EGF2165 or similar number. 3. At allrelevant times, Blake Avenue at or near Union Street, County of Kings, Stateof New York was a public highway. 4. On or about October 27, 2016, at the aforementioned place, the aforementioned vehicle struck Plaintiff, a pedestrian. 5. At the time and place aforesaid, Defendant was negligent in the ownership and operation of the aforementioned vehicle. 6. Solely by reason of the aforementioned negligence Plaintiff sustained a serious injury and/or greater than basic ceonomic loss as defined in New York's Insurance Law. 7. This action falls within one or more of the exceptions contained in Article 16 of the CPLR. 8. Plaintiff's damages exceed the jurisdictional limits of alllower courts. Plaintiff demands judgment in an amount to be determined at trialwith costs and disbursements. 2 of 4 FILED: KINGS COUNTY CLERK 01/10/2020 03:02 PM INDEX NO. 519700/2018 [F¯I¯LED: DOC. KINGSNO. COUNTY CLERK 10-/-0-1-/2018 03-f21 PM INDEX NO. 519700/2018 NYSCEF 26 RECEIVED NYSCEF: 01/10/2020 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2018 ATTORNEY'S VERIFICATION I have read the annexed Summons and Complaint and know the contents thereof, and the sanie are true to my knowledge, except for those matters therein stated upon information and belief, and as to those matters, I believe them to be true. The reason I make this verification instead of the Plaintiff herein isthat said Plaintiff does not reside in the County where I maintain my office. Dated: Garden City, New York September 28, 2018 Paul Xjlouny, E . 4 of 4