On July 17, 2019 a
Exhibit,Appendix
was filed
involving a dispute between
Leander Knust,
and
Amritpal Singh,
Mdamrit Taxi Inc,
for Torts - Motor Vehicle
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 10/25/2022 02:37 PM INDEX NO. 156977/2019
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2022
EXHIBIT F
FILED: NEW YORK COUNTY CLERK 10/25/2022 02:37 PM INDEX NO. 156977/2019
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------_______________________________Ç
LEANDER KNUST, AFFIDAVIT OF
MERITS
Plaintiff,
Index No.: 156977/2019
-against-
AMRITPAL SINGH and MDAMRIT TAXI INC.,
Defendants.
______________________________________________________________Ç
STATE OF ILLINOIS)
SS.:
COUNTY OF COOK )
Leander Knust, being duly sworn, deposes and says:
1, I am the plaintiff in the above action.
2. I submit this affidavit in support of my Motion for Summary Judgment on the issue of
liability.
3. On October 22, 2018, at approximately 1:00 a.m., I was operating my bicycle when I
was struck by a motor vehicle owned by defendant MDAMRIT TAXI INC., and operated by
866
defendant AMRITPAL SINGH at the intersection of Street and Amsterdam Avenue, New
York, New York.
4. At the time of the accident, I was biking northbound in the firstright or eastern-most
driving lane of Amsterdam Avenue. Traffic was very light and the roads were dry. Had the
accident not occurred, my intention was to continue straight through the intersection, northbound.
86*
5. Amsterdam is a one-way street with traffic travelling northbound. Street is a two-
way roadway running east and west with a totalof six lanes. There are parking lanes on each side
86*
of Street and four lanes of moving traffic with two lanes travelling in each direction.
FILED: NEW YORK COUNTY CLERK 10/25/2022 02:37 PM INDEX NO. 156977/2019
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2022
86*
6. As I was approaching the intersection of Amsterdam Avenue and street, I observed
the traffic light controlling my direction and lane of travel and itwas green. I looked both ways
86*
on Street and observed two cars adjacent to each other waiting to cross the intersection from
the west (to my left)and one car stopped waiting to cross the intersection from the east (to my
right). I made eye contact with the drivers and proceeded into the intersection. I was travelling at
approximately 15 miles per hour.
7. I kept the traffic light governing my lane and direction of travel under constant
surveillance and never observed it to be red. I am familiar with the intersection and know that
when the light is green for traffic on Amsterdam Avenue to proceed straight through the
86*
intersection, the light for trafficon Street to proceed into the intersection is red.
8. The impact occurred on my right side when I was almost completely through the
intersection crossing the most northern lane of traffic on 86th street and approaching the crosswalk
on the northern boundary of the intersection.
9. I never saw the vehicle that ran the red light and hit me prior to the impact, but know
that the vehicle was travelling westbound, coming from my right at the time of the accident. The
vehicle that struck me was not one of the vehicles that I observed stopped on 86th Street as I
entered the intersection. As a result of the impact, I lost consciousness and did not regain
consciousness until after I arrived at the hospital. I have no memory of the events at the scene
after the impact.
defendants'
10. As a result of the accident and negligence, I suffered serious and severe
personal injuries, including but not limited to a fractured fibula in my right leg, a tear to my right
eyelid and facial lacerations necessitating 47 stitches, injuries to my neck and back and head
trauma.
FILED: NEW YORK COUNTY CLERK 10/25/2022 02:37 PM INDEX NO. 156977/2019
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2022
11. There is nothing I could have done to avoid the happening of this accident. In no way
did I contribute to the causation of the occurrence. I was lawfully operating my bicycle through
the intersection when the defendant ran a steady red light and struck me. At the time of the
accident, my bicycle had reflectors on both wheels and had lights which were on.
12. Based upon these facts,itis clear that the defendants were negligent in the ownership,
operation, and control of their vehicle and their conduct fellwell below the standard of reasonable
care in disobeying a steady red light and failing to observe my bicycle on the roadway as it was
stopped at a red light.
13. Thus, based on the foregoing facts, I respectfully request that summary judgment
on the issue of liability be granted in my favor against the defendants.
Leander Knust
Swopito before me this
1 f of October, 2022
DANtEL W WINSTON
Seal
Official
Public- State
of !llinois
Notary
Commission ExpiresSep 20,2025
My
ÑÓTARY PUBLIC
Document Filed Date
October 25, 2022
Case Filing Date
July 17, 2019
Category
Torts - Motor Vehicle
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FILED: NEW YORK COUNTY CLERK 10/25/2022 02:37 PM INDEX NO. 156977/2019 NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2022 EXHIBIT F FILED: NEW YORK COUNTY CLERK 10/25/2022 02:37 PM INDEX NO. 156977/2019 NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------_______________________________Ç LEANDER KNUST, AFFIDAVIT OF MERITS Plaintiff, Index No.: 156977/2019 -against- AMRITPAL SINGH and MDAMRIT TAXI INC., Defendants. ______________________________________________________________Ç STATE OF ILLINOIS) SS.: COUNTY OF COOK ) Leander Knust, being duly sworn, deposes and says: 1, I am the plaintiff in the above action. 2. I submit this affidavit in support of my Motion for Summary Judgment on the issue of liability. 3. On October 22, 2018, at approximately 1:00 a.m., I was operating my bicycle when I was struck by a motor vehicle owned by defendant MDAMRIT TAXI INC., and operated by 866 defendant AMRITPAL SINGH at the intersection of Street and Amsterdam Avenue, New York, New York. 4. At the time of the accident, I was biking northbound in the firstright or eastern-most driving lane of Amsterdam Avenue. Traffic was very light and the roads were dry. Had the accident not occurred, my intention was to continue straight through the intersection, northbound. 86* 5. Amsterdam is a one-way street with traffic travelling northbound. Street is a two- way roadway running east and west with a totalof six lanes. There are parking lanes on each side 86* of Street and four lanes of moving traffic with two lanes travelling in each direction. FILED: NEW YORK COUNTY CLERK 10/25/2022 02:37 PM INDEX NO. 156977/2019 NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2022 86* 6. As I was approaching the intersection of Amsterdam Avenue and street, I observed the traffic light controlling my direction and lane of travel and itwas green. I looked both ways 86* on Street and observed two cars adjacent to each other waiting to cross the intersection from the west (to my left)and one car stopped waiting to cross the intersection from the east (to my right). I made eye contact with the drivers and proceeded into the intersection. I was travelling at approximately 15 miles per hour. 7. I kept the traffic light governing my lane and direction of travel under constant surveillance and never observed it to be red. I am familiar with the intersection and know that when the light is green for traffic on Amsterdam Avenue to proceed straight through the 86* intersection, the light for trafficon Street to proceed into the intersection is red. 8. The impact occurred on my right side when I was almost completely through the intersection crossing the most northern lane of traffic on 86th street and approaching the crosswalk on the northern boundary of the intersection. 9. I never saw the vehicle that ran the red light and hit me prior to the impact, but know that the vehicle was travelling westbound, coming from my right at the time of the accident. The vehicle that struck me was not one of the vehicles that I observed stopped on 86th Street as I entered the intersection. As a result of the impact, I lost consciousness and did not regain consciousness until after I arrived at the hospital. I have no memory of the events at the scene after the impact. defendants' 10. As a result of the accident and negligence, I suffered serious and severe personal injuries, including but not limited to a fractured fibula in my right leg, a tear to my right eyelid and facial lacerations necessitating 47 stitches, injuries to my neck and back and head trauma. FILED: NEW YORK COUNTY CLERK 10/25/2022 02:37 PM INDEX NO. 156977/2019 NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2022 11. There is nothing I could have done to avoid the happening of this accident. In no way did I contribute to the causation of the occurrence. I was lawfully operating my bicycle through the intersection when the defendant ran a steady red light and struck me. At the time of the accident, my bicycle had reflectors on both wheels and had lights which were on. 12. Based upon these facts,itis clear that the defendants were negligent in the ownership, operation, and control of their vehicle and their conduct fellwell below the standard of reasonable care in disobeying a steady red light and failing to observe my bicycle on the roadway as it was stopped at a red light. 13. Thus, based on the foregoing facts, I respectfully request that summary judgment on the issue of liability be granted in my favor against the defendants. Leander Knust Swopito before me this 1 f of October, 2022 DANtEL W WINSTON Seal Official Public- State of !llinois Notary Commission ExpiresSep 20,2025 My ÑÓTARY PUBLIC