Preview
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NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019
EXHIBIT B
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CLERK INDEX NO. 521855/2018
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
Filed: __
HOWARD LOCKRIDGE, INDEX NO.
Plaintiff, Plaintiffdesignates Kings
County as the place of trial.
-against-
S U M M O N S
TALLA REALTY LLC,
The basis of venue is
Defendant. the County in which the
cause of action arose.
To the above named Defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in thisaction and to serve
a copy of your answer on the plaintiffs attorneys within 20 days afterthe service of this
summons, exclusive of the day of service of this summons, or within 30 days afterservice of this
summons iscomplete ifthis summons isnot personally delivered to you within the State of New
York.
In case of your failureto answer this summons, a judgment by default will be taken
against you for the reliefdemanded in the complaint, together with the costs of thisaction.
Dated: New York, New York
October 30, 2018
ASHER & ASSOCIATES, P.C.
Attorneys for Plaintiff
11 1 John Street
Fourteenth Floor
New York, New York 10038
(212) 227-5000
TALLA REALTY LLC
704 Hillside Avenue
New Hyde Park.,New York 1 wWC
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
INDEX NO.
HOWARD LOCKRIDGE,
Plaintiff,
VERIFIED COMPLAINT
-against-
TALLA REALTY LLC,
Defendant.
Plaintiff,by his attorneys, ASHER & ASSOCIATES, P.C., as and for his Verified
Complaint, respectfully alleges, upon information and belief:
1. The plaintiff, HOWARD LOCKR1DGE, at alltimes herein mentioned was and still is
a resident of the County of Kings and the State of New York.
2. The defendant TALLA REALTY LLC, at alltimes herein mentioned, was and stillisa
corporation organized and existing under the laws of the State of New York.
3. The defendant, TALLA REALTY LLC, at alltimes herein mentioned was and stillis a
limited liabilitycorporation doing business in the County of Nassau and the Stateof New York.
4. On September 17, 2018, HOWARD LOCKRIDGE was lawfully upon defendant's
premises.
5. On September 17, 2018, the premises located at 427 Throop Avenue, Brooklyn, New
York was under construction of a multiple dwelling as defined by theMultiple Dwelling Law of
the State of New York.
6, On September 17, 2018, the premises located at 427 Throop Avenue, Brooklyn, New
York was intended to be occupied as the residence of at leastthree families living independently
ofone another.
7. On September 17, 2018, the defendant TALLA REALTY LLC owned the premises
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located at 427 Throop Avenue, Brooklyn, New York.
8. On September 17, 2018, the defendant TALLA REALTY LLC was one of the owners
ofthe premises located at 427 Throop Avenue, Brooklyn. New York.
9. On September 17, 2018, the defendant TALLA REALTY LLC was a lessee of the
premises located at 427 Throop Avenue, Brooklyn, New York.
10. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants,
agents and/or employees operated the premises located at 427 Throop Avenue, Brooklyn, New
York.
11. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants,
agents and/or employees maintained the premises located at 427 Throop Avenue, Brooklyn, New
York.
12. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants,
agents and/or employees managed the premises located at 427 Throop Avenue, Brooklyn, New
York.
13. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants
agents and/or employees controlled the premises located at 427 Throop Avenue,.Brooklyrt New
York.
14. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants,
agents and/or employees supervised the premises located at 427 Throop Avenue, Brooklyn. New
York.
15. On or before September 17, 2018, the defendant TALLA REALTY LLC, defendant's
servants, agents and/or employees repaired the premises located at 427 Throop Avenue,
2
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Brooklyn, New York.
16. On or before September 17, 2018, the defendant TALLA REALTY LLC, defendant's
servants, agents and/or employees inspected the premises located at 427 Throop Avenue,
Brooklyn, New York.
17. On or before September 17, 2018, the defendant TALLA REALTY LLC, defendant's
servants, agents and/or employees constructed the premises located at 427 Throop Avenue,
Brooklyn, New York.
I8. On or before September 17, 2018, the defendant TALLA REALTY LLC, defendant's
servants, agents and/or employees designed the premises located at 427 Throop Avenue,
Brooklyn, New York.
19. On September I7, 2018, itwas the duty of the defendant TALLA REALTY LLC,
defendant's servants, agents and/or employees to maintain said premises located at 427 Throop
Avenue, Brooklyn, New York, in a reasonably safe and suitable condition and ingood repair.
20. On September 17, 2018,while plaintiffwas lawfully traversingthe sidewalk adjacentto
theaforementioned premises he was caused to and
trip fall.
21. On September 17,2018, while plaintiffwas lawfullytraversing the aforementioned
sidewalk he was caused to sustain severe and protracted personalinjuries.
22. On September 17, 2018, while plaintiffwas lawfully on the aforementioned sidewalk
he was caused to be injured due to the negligence, carelessness and recklessness ofthe defendants
herein.
23. That the said accident and theinjuries and damages to the plaintiffresulting
therefrom were caused solely and wholly by reason of the negligence, carelessness and
3
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recklessness of the defendants, theiragents, servants, employees and/or licensees in the
ownership, operation, control and maintenance of the premises located as aforesaid in thatthey
caused, permitted and/or allowed the aforementioned sidewalk to be, become and remain for a
period of time after notice, either actual or constructive, in a defective, dangerous and
hazardous condition and to be so maintained and constructed as to prevent safe passage over
and along the same by plaintiff and other pedestrians lawfully traversing said sidewalk; in that
they failedto make timely, adequate and proper inspections of the condition of said sidewalk;
in that they failed to make timely, adequate and proper maintenance to said sidewalk and/or
made improper and inadequate maintenance to same; in that they failed to employ adequate
and competent personnel to inspect, maintain and/or repair said sidewalk; in thatthey
maintained said sidewalk in reckless disregard for the safety of plaintiffand others lawfully
traversing the same; in thatthey failedto warn plaintiff of the dangerous, traplike, unsafe and
hazardous condition of said sidewalk and inthat they failed to take allnecessary and proper
means and precautions to avoid the said accident.
24. The defendant TALLA REALTY LLC caused and created said dangerous, defective
and unsafe condition.
25. Solely as a resultof the defendant's negligence, carelessness and recklessness,
HOWARD LOCKRIDGE was caused to suffer severe and serious personal injuries to mind and
body, and further,that HOWARD LOCKRIDGE was subjected to great physical pain and
mental anguish.
26. By reason of the foregoing, HOWARD LOCKRIDGE was severely injured and
damaged, sustained severe nervous shock and mental anguish, great physical pain and emotional
4
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upset, some of which injuries are believed to be permanent in nature and duration, and
HOWARD LOCKRIDGE will be permanently caused to suffer pain, inconvenience and other
effects of such injuries; HOWARD LOCKRIDGE incurred and in the future will necessarily
incur further hospital and/or medical expenses in an effort to be cured of said injuries; and
HOWARD LOCKRIDGE will be unable to pursue HOWARD LOCKRIDGE's usual duties with
the same degree of efficiency as prior to this accident, all to HOWARD LOCKRIDGE's great
damage.
27. This action falls within one or more of the exceptions set forth in Section 1602.of the
Civil Practice Law and Rules.
28. Due to defendant's negligence, plaintiff is entitled to damages.
WHEREFORE, the plaintiff demands judgment awarding damages, in an
amount exceeding the monetary jurisdictional limits of all lower courts which would otherwise
have jurisdiction, together with interest and the costs and disbursem.ents of this action, and such
other and further relief as to this Court seems just and proper.
Dated: New York, New York
October 30, 2018
Roberts D. Arlur
By: Roberta D. Asher
ASHER & ASSOCIATES, P.C.
Attorneys for Plaintiff
111 John Street
Fourteenth Floor
New York, New York 10038
(212) 227-5000
5
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
INDEX NO.
HOWARD LOCKRIDGE,
Plaintiff, ATTORNEY'S
VERIFICATION
-against-
TALLA REALTY LLC,
Defendant.
Roberta D. Asher, an attorney duly admitted topractice law in the Stateof New York,
makes the following affirmation under the penalty of perjury:
I am ofthe firm of ASHER & ASSOCI.ATES, P.C., the attorneys of record for the
plaintiff.
I have read the foregoing Complaint and know the contents thereof; the same is trueto
my own knowledge except as tothe matters therein stated to be alleged on information and belief
and that as to those matters, I believe them to be true.
This verification is made by affirmant and not by plaintiff because he is not in theCounty
of New York, which isthe County where your affirmant maintains offices.
The grounds of affirmant's belief as to allmatters not stated upon affirmant's knowledge
are correspondence had with the said plaintiff,information contained in the saidplaintiffs file,
which isin affirmant's possession, and other pertinent data relating thereto.
Dated: New York, New York
October 30, 2018
ROBERTA D. ASHER
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Index No.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
HOWARD LOCKRIDGE,
Plaintiff,
-against-
TALLA REALTY LLC,
Defendant.
SUMMONS and VERIFIED COMPLAINT
The Documents within are hereby certified pursuant to 22 N.Y.C.R.R. 130-1.1-a:
By:
Doth' D.
Arltef-
Roberta D. Asher
ASHER & ASSOCIATES, P.C.
Attorneys for Plaintiff
111 John Street
Fourteenth Floor
New York, New York 10038
(2I2) 227-5000
PLEASE TAKE NOTICE
NOTICE OF
ENTRY
that thewithin is a (certified)true copy of a duly entered in the officeof the Clerk
of the
within named Court on , 2018 .
NOTICE OF
SETTLEMENT
that an of which the within isa true copy will be presented to the Hon. one of
the
of the within named Court, at New York, on , 2018 , at9:30
A.M.
Dated:
8 of 8
Preview
FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 EXHIBIT B FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 CLERK INDEX NO. 521855/2018 LED : KINGS COUNTY 10 /3 0 / 2 018 0 6 : 07 PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Filed: __ HOWARD LOCKRIDGE, INDEX NO. Plaintiff, Plaintiffdesignates Kings County as the place of trial. -against- S U M M O N S TALLA REALTY LLC, The basis of venue is Defendant. the County in which the cause of action arose. To the above named Defendant: YOU ARE HEREBY SUMMONED to answer the complaint in thisaction and to serve a copy of your answer on the plaintiffs attorneys within 20 days afterthe service of this summons, exclusive of the day of service of this summons, or within 30 days afterservice of this summons iscomplete ifthis summons isnot personally delivered to you within the State of New York. In case of your failureto answer this summons, a judgment by default will be taken against you for the reliefdemanded in the complaint, together with the costs of thisaction. Dated: New York, New York October 30, 2018 ASHER & ASSOCIATES, P.C. Attorneys for Plaintiff 11 1 John Street Fourteenth Floor New York, New York 10038 (212) 227-5000 TALLA REALTY LLC 704 Hillside Avenue New Hyde Park.,New York 1 wWC 1 of G FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 INDEX O. 521855/2018 ILED: KINGS COUNTY CLERK 10/30 /2018 06 : 07 PM) NYSCEF DOC. NC. 1 RECEIVED NYSCEF: 10/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS INDEX NO. HOWARD LOCKRIDGE, Plaintiff, VERIFIED COMPLAINT -against- TALLA REALTY LLC, Defendant. Plaintiff,by his attorneys, ASHER & ASSOCIATES, P.C., as and for his Verified Complaint, respectfully alleges, upon information and belief: 1. The plaintiff, HOWARD LOCKR1DGE, at alltimes herein mentioned was and still is a resident of the County of Kings and the State of New York. 2. The defendant TALLA REALTY LLC, at alltimes herein mentioned, was and stillisa corporation organized and existing under the laws of the State of New York. 3. The defendant, TALLA REALTY LLC, at alltimes herein mentioned was and stillis a limited liabilitycorporation doing business in the County of Nassau and the Stateof New York. 4. On September 17, 2018, HOWARD LOCKRIDGE was lawfully upon defendant's premises. 5. On September 17, 2018, the premises located at 427 Throop Avenue, Brooklyn, New York was under construction of a multiple dwelling as defined by theMultiple Dwelling Law of the State of New York. 6, On September 17, 2018, the premises located at 427 Throop Avenue, Brooklyn, New York was intended to be occupied as the residence of at leastthree families living independently ofone another. 7. On September 17, 2018, the defendant TALLA REALTY LLC owned the premises FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 INDEX NO. 521855/2e18 ILED: KINGS COUNTY CLERK 10 /30 /2 018 0 6 : 07 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018 located at 427 Throop Avenue, Brooklyn, New York. 8. On September 17, 2018, the defendant TALLA REALTY LLC was one of the owners ofthe premises located at 427 Throop Avenue, Brooklyn. New York. 9. On September 17, 2018, the defendant TALLA REALTY LLC was a lessee of the premises located at 427 Throop Avenue, Brooklyn, New York. 10. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees operated the premises located at 427 Throop Avenue, Brooklyn, New York. 11. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees maintained the premises located at 427 Throop Avenue, Brooklyn, New York. 12. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees managed the premises located at 427 Throop Avenue, Brooklyn, New York. 13. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants agents and/or employees controlled the premises located at 427 Throop Avenue,.Brooklyrt New York. 14. On September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees supervised the premises located at 427 Throop Avenue, Brooklyn. New York. 15. On or before September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees repaired the premises located at 427 Throop Avenue, 2 3 of 8 FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 (F1LED : KINGS COUNTY CLERK 10 3 O/ 2 018 0 6 07 INDEX NO. 52185s/2013 / : PMl NYBCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018 Brooklyn, New York. 16. On or before September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees inspected the premises located at 427 Throop Avenue, Brooklyn, New York. 17. On or before September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees constructed the premises located at 427 Throop Avenue, Brooklyn, New York. I8. On or before September 17, 2018, the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees designed the premises located at 427 Throop Avenue, Brooklyn, New York. 19. On September I7, 2018, itwas the duty of the defendant TALLA REALTY LLC, defendant's servants, agents and/or employees to maintain said premises located at 427 Throop Avenue, Brooklyn, New York, in a reasonably safe and suitable condition and ingood repair. 20. On September 17, 2018,while plaintiffwas lawfully traversingthe sidewalk adjacentto theaforementioned premises he was caused to and trip fall. 21. On September 17,2018, while plaintiffwas lawfullytraversing the aforementioned sidewalk he was caused to sustain severe and protracted personalinjuries. 22. On September 17, 2018, while plaintiffwas lawfully on the aforementioned sidewalk he was caused to be injured due to the negligence, carelessness and recklessness ofthe defendants herein. 23. That the said accident and theinjuries and damages to the plaintiffresulting therefrom were caused solely and wholly by reason of the negligence, carelessness and 3 4 of 8 FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 CLERK INDEX No , 521855/2018 FILED: KINGS COUNTY 10 /X0 / 2018 06 : 07 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018 recklessness of the defendants, theiragents, servants, employees and/or licensees in the ownership, operation, control and maintenance of the premises located as aforesaid in thatthey caused, permitted and/or allowed the aforementioned sidewalk to be, become and remain for a period of time after notice, either actual or constructive, in a defective, dangerous and hazardous condition and to be so maintained and constructed as to prevent safe passage over and along the same by plaintiff and other pedestrians lawfully traversing said sidewalk; in that they failedto make timely, adequate and proper inspections of the condition of said sidewalk; in that they failed to make timely, adequate and proper maintenance to said sidewalk and/or made improper and inadequate maintenance to same; in that they failed to employ adequate and competent personnel to inspect, maintain and/or repair said sidewalk; in thatthey maintained said sidewalk in reckless disregard for the safety of plaintiffand others lawfully traversing the same; in thatthey failedto warn plaintiff of the dangerous, traplike, unsafe and hazardous condition of said sidewalk and inthat they failed to take allnecessary and proper means and precautions to avoid the said accident. 24. The defendant TALLA REALTY LLC caused and created said dangerous, defective and unsafe condition. 25. Solely as a resultof the defendant's negligence, carelessness and recklessness, HOWARD LOCKRIDGE was caused to suffer severe and serious personal injuries to mind and body, and further,that HOWARD LOCKRIDGE was subjected to great physical pain and mental anguish. 26. By reason of the foregoing, HOWARD LOCKRIDGE was severely injured and damaged, sustained severe nervous shock and mental anguish, great physical pain and emotional 4 5 of 8 FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 COUNTY INDEX NO. 521855/20 ! 8 FILED: KINGS CLERK 10 /30 /2018 O 6 : 07 PM1 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 1C/30/2018 upset, some of which injuries are believed to be permanent in nature and duration, and HOWARD LOCKRIDGE will be permanently caused to suffer pain, inconvenience and other effects of such injuries; HOWARD LOCKRIDGE incurred and in the future will necessarily incur further hospital and/or medical expenses in an effort to be cured of said injuries; and HOWARD LOCKRIDGE will be unable to pursue HOWARD LOCKRIDGE's usual duties with the same degree of efficiency as prior to this accident, all to HOWARD LOCKRIDGE's great damage. 27. This action falls within one or more of the exceptions set forth in Section 1602.of the Civil Practice Law and Rules. 28. Due to defendant's negligence, plaintiff is entitled to damages. WHEREFORE, the plaintiff demands judgment awarding damages, in an amount exceeding the monetary jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with interest and the costs and disbursem.ents of this action, and such other and further relief as to this Court seems just and proper. Dated: New York, New York October 30, 2018 Roberts D. Arlur By: Roberta D. Asher ASHER & ASSOCIATES, P.C. Attorneys for Plaintiff 111 John Street Fourteenth Floor New York, New York 10038 (212) 227-5000 5 6 of 8 FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 INDEX No. 521855/2038 FILED : KINGS COUNTY CLERK 10 /30/2018 0 6 : 07 PM1 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS INDEX NO. HOWARD LOCKRIDGE, Plaintiff, ATTORNEY'S VERIFICATION -against- TALLA REALTY LLC, Defendant. Roberta D. Asher, an attorney duly admitted topractice law in the Stateof New York, makes the following affirmation under the penalty of perjury: I am ofthe firm of ASHER & ASSOCI.ATES, P.C., the attorneys of record for the plaintiff. I have read the foregoing Complaint and know the contents thereof; the same is trueto my own knowledge except as tothe matters therein stated to be alleged on information and belief and that as to those matters, I believe them to be true. This verification is made by affirmant and not by plaintiff because he is not in theCounty of New York, which isthe County where your affirmant maintains offices. The grounds of affirmant's belief as to allmatters not stated upon affirmant's knowledge are correspondence had with the said plaintiff,information contained in the saidplaintiffs file, which isin affirmant's possession, and other pertinent data relating thereto. Dated: New York, New York October 30, 2018 ROBERTA D. ASHER 7 of 8 FILED: KINGS COUNTY CLERK 02/15/2019 03:31 PM INDEX NO. 521855/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/15/2019 (FILED: KINGS COUNTY CLERK 10 /3 0 /2 018 0 6 : 07 INDEX NO. 521855/2018 PMI NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018 Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS HOWARD LOCKRIDGE, Plaintiff, -against- TALLA REALTY LLC, Defendant. SUMMONS and VERIFIED COMPLAINT The Documents within are hereby certified pursuant to 22 N.Y.C.R.R. 130-1.1-a: By: Doth' D. Arltef- Roberta D. Asher ASHER & ASSOCIATES, P.C. Attorneys for Plaintiff 111 John Street Fourteenth Floor New York, New York 10038 (2I2) 227-5000 PLEASE TAKE NOTICE NOTICE OF ENTRY that thewithin is a (certified)true copy of a duly entered in the officeof the Clerk of the within named Court on , 2018 . NOTICE OF SETTLEMENT that an of which the within isa true copy will be presented to the Hon. one of the of the within named Court, at New York, on , 2018 , at9:30 A.M. Dated: 8 of 8