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FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 03/19/2020
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FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--.---------..--___---------.-------x
MILDRED J. FANA .10 O
Plalntiff/Petitioner' 521793/2018
-against- Index No.
ANTHONY MARANDO, JOHN DOE
Defendant/Respondent.
--------------------------------x
NOTICE OF ELECTRONIC FILING
You have received this Notice because:
• The Plaintiff/Petitioner, whose name is listed above, has filed this case the
using
New York State Courts e-fillngsystem, and
• You are a Defendant/Respondent (a party) inthis case.
(CPLR § 2111, Uniform Rule § 202.5-bb)
Ifyou are represented by an attorney: give this Notice to your attorney. (Attornevs: see
Attorneys"
"Information for pg. 2),
If you are not represented by an attorney: you are not required to e-file. You may
serve and file documents in paper form and you must be served with documants in
paper form. as a without an you participate in e-
However, pad·y attorney, may
filing. .
Benefits of E-Filing
You can:
• serve and fileyour documents electronically
• view your case file on-line
• limityour number of trips to the courthouse
• court fees on-line.
pay any
There are no additional fees to e-file,view, or print your case records.
To sign up fore-filing or for rnore information about how e-filingworks, you may:
• visit:www.nvcourts,qov/efile-unrepresented or
• go to the Center or Clerk's Office at the court where the case was filed. To find
Help
legal information to help you represent yourself visit www.nvcourthelp.aov
Page 1 of 2 EFM-1
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NYSCEF (Page 2
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Information for Attorneys
An attorney representing a party-who is served with this notice must either:
1) immediately record his orher representation within-the e-filed matter on the NYSCEF
site https://iapps.courts.state.ny,us/nvscef/HomePage: or
2) filethe Notice of Opt-Out form with the clerk of the court where this action is pending.
Exemptions from mandatory e-filing are Ilmited to attorneys who certify in good faith that
they lack the computer hardware and/or scanner and/or internet connection or that they
lack (along with allemployees subject to their direction) the operational knowledge to
comply with e-filingrequirements. [5ection 202.5-bb(e)]
For additional information about electronic filing and to create a NYSCEF account, visitthe
NYSCEF website at www.nvcourts.cov/efile or.contact the NYSCEF Resource Center (phone:
646-386-3033; e-mail: efileanvcourts.oovi
Dated: 10/30/2018
1723 East 12th 4th
Street, Floor
ALEKSANDR SIMON CHERNY
Name Address
CHERNY & PODOLSKY, PLLC Brooklyn,NY 11229
Firm Name
..
718-449-5100
Phone
alekcherny gmnitcom
E-Mail
. .
--o ANTHONY MARANDO
264 Bay 11thStreet,2nd Floor
Brooklyn, NY 11228
JOHN DOE
c/o ANTHONY MARANDO .
11/20/17
Index No. Page 2 of 2 EFM-1
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'NYSCEF DOC. NO. 1 RECEIVED NYSCEF: -10/30/2018
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF KINGS Date Filed:
--___.....-a________-_________ .--.-----X
MILDRED J. FANA, SUMMONS ..
Plaintiff, Plaintiffdesignates KINGS
County as theplace of Trial.
-against- The basis of venue is
The Plaintiff'sresidence,
ANTHONY MARANDO and JOHN DOE, namefictiticas Plaintiffresidesat:
. - 6th
an2l)MREown to theplaintiff
at this
time, 5314 Avenue
Brooklyn, NY 11220
Defendants, County of KINGS.
---- -------- -- ----X
TO THE ABOVE NAMED DEFENDANTS:
YOU ARE REREBY SUMMONED toanswer the complaint in thisaction and.to serve
a copy of your ariswer,or, ifthe complaint isnot served with the summons, to serve a notice of
appearance on plaintiff'sattorneys within twenty (20) days after service of thissummehs,
exclusive of the day of service, or within thirty (30) days afterservice is complete ifthis
summcas is not personally delivered to you within the State of New Yo1t In case of your
failureto answer, Judgment will be taken.against you by default forthe reliefdemanded in the
Complaint.
DATED: Brooklyn, New York
October.30, 2018
Yours, etc.,
By:
Mari Milorava Kelman, Esq
CHERNY & PODOLSKY, PLLC
Attorneys forPlaintiff
MILDRED J. FANA
126 45
.1723 East Street, Floor
Brooklyn, NY 11229
(718) 449-5100
FileNo.: 8959
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. .
. .
.DEVENDXNTS'
ADDRESSES:
ANTHONY MARAN1)O JOHN DOE
11* 2"d
264 Bay Street, Floor c/o ANTHONY MARANDO
11228. 11* 25d
Brooklyn, NY 264 Bay Street, Floor
....
----........ Brooldyn, NY 11228
k-
2 of 8
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
MILDRED J. FANA,
Plaintiff, VERIFIED COMPLAINT
-against- . Index No.
ANTRONY MARANDO and JOHN DOE, name ficd6=S
and unknown to the.plaintiff
at this
time,
Defendants.
------------------------- ¬-- ------X
Plaintiff, MILDRED L FANA, by her attorneys, CHERNY & PODOLSKY, PLLC,
'-
cariq A g of the defcñdañts herein, respectfully alleges upon information and belief as
follows:
1) Plaintiff,MILDRED 1 FANA, was and stillisa resident of the County of Kings, ¡
City and State of New York..
2). Defendat, ANTHONY MARANDO, was and stillisa resident of the County of
Kings, City and State of New York.
3) On orabout May 8, 2018, defendant, ANTHONY MARANDO, was theowner of a
2005 Jeep motor vehicle bearing State ofNew York registcaden number QVK3664.
4) On or about May 8, 2018, defendant, ANTHONY MARANDO, ed a
2005 Jeep motor vehicle bearing State·ofNew tork registrationnumber G.VK3664.
5) On orabout May 8, 2018,defendant, ANTHONY MARANDO, was controllinga
2005 Jeep motor vehicle bearing State ofNew York registration ilumberrGVK3664.
6) On or about May 8, 2018, defe~Þmt, ANTHONY MARANDO, was theoperator
of a 2005 motor vehicle bearing State ofNew York registr-atiGn
number GVK3664.
Jeep
On or about d ANTHONY MARANDO, was a
7) . May 8,.2018, =t, operating
3 af 8
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2005 Jeep motor vehicle bearing State of New York regiatration number GVK3664 on Bay
at or near itsintersection 865 in the 8tateof
Parkway, with Street, County of Kings, City and
New York.
8) That at alltimes hereinaftermentioned, Bay Parkway, at ornear itsintersection with
86th
Street, in theCounty of Kings, City and State of New York, are and were a.public roadways,
streets,highways arid/orthoroughfares used extensively by the public in general.
9) On or about May 8, 2018, defendant, ANTHONY MARANDO, was operating a
2005 Jeep niotor vehicle bearing State of New York registrationnumber GVK3664 within the
scope of his employment.
10) Orr or about May 8, 2018 defendarG‡, JOHN DOE, was the opmeter of a 2005
motor vehicle bearing State ofNew York registratiortnumber GVK3664.
Jeep
11) On or about May 8, 2018, defendant, JOHN DOE, was controlling a 2005 Jeep
motor vehicle bearing State ofNew York registration number GVK3664
12) On or about May 8, 2018, defendant, JOHN DQE, was operating a 2005 Jeep
motor vehicle bearing State ofNew York registraticñ number GVK3664 with the knowledge of .
the defendant owner.
13) On or about May 8, 2018, defendant, JOHN DOE, was operating a 2005 Jeep
motor vehicle bearing State ofNew York registrationnumber GVK3664 with the permission of
the defendant owner.
14) On or about May 8 2018, defends.at,JOHN DOE, was operating a 2005 Jeep
motor vehicle bearing State of New York registration number GVIO664 with the express
consent of the defendant owner,
On or about dehdan+ IOHN was a 2005
15) May 8, 2018, DOE, qperating Jeep
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motor vehicle bearing State of New York registrationnumber GVK3664 with the implied
consent of thedefendant owner.
16) On or about May 8, 2018, defendant, JOHN DOE, was operating a 2005 Jeep
motor vehicle bearing State of New York registrationnumber GVK3664 within the scope of
his/her employment.
17) On or about May 8, 2018, defendarlt, JOHN DOE, was operating a 2005 Jeep
motor vehicle bearing State of New York registratics number GVK3664 on Bay Parkway
865
Avenue, at ornear itsintersection with Street, in theCounty of Kings, City and State ofNew
York.
18) On or about May 8, 2018,plaintiff,MILDRED L FANA, was operating a 2017
Toyota motor vehicle beating State of New York registration number T708958C on Bay
86*
Parkway, at or near itsintersectionwith Street, 111the County of Kings, City and State of
New York.
defendants'
20) At the aforesaid time and place, the motor vehicle came into contact
with the motor vehicle of theplaintiff.
21) That said contactwas due solely to theñégligence of the defendants, without any
negligence on the partof theplaintiffcontributing thereto.
22) That as a result of the aforesaid contact, plaintig MILDRED J. FANA, was
severely and permanently injured.
23) Plaintiff,MILDRED J. FANA, was seriously injured.
24) PlaintiR MILDRED J..FANA, has. sustained a serious injury as defined by
Article 51 of the Insurance Law, or economic loss greaterthan basic econbmic loss as definedby
Article 51.of the Insurance Law.
5 of B
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25) This action fallswithin one ormore of the exceptions set forthin CPLR Section
1602.
26) The aforesaid occurrence and resn'ting injuries to the plaintiff
were due solely to
the carelessness, recklessness and ne.gligence of the defendents in the awaciship, operation,
management, inspection, maintenance,. supervision, repair and controlof the above mcationed
motor vehicle,without any negligence on the part ofthe plaintiffcontributing thereto
27) That by reason of the forcgcing, MILDRED
the plaintifÇ J. FANA has been
darnaged in excess of thejurisdictional limitsof allthe lower Courts that would othcrwise have
jurisilictinnin thisstateand by reason of the fõregüIng, the plaintiffhas suffered damages in an
amount to be determined at trial
WHEREFORE, MILDRED
plaintiff, J, FANA, demands iudgaicat inthe
plaintiff's
favor and against the defendants in an amount to be determined at which
trial, isin
excess of thejurisdicticnal limitsof alllower courts,together with costs
interest, and
disbursements of thisaction.
I
Dated: Brooklyn, New York
October 30, 2018
Yours, etc.,
Mari Milorava-Kelman, Esq.
CHERNY & PODOLSKY, PLLC
Attorneys for Plaintiff
MILDRED J. FANA
125 4*
1723 East Street, Floor
Brooklyn, NY 11.229
(718) 449-5100
File No.: 8959
u a
6 of 8
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018
Index No.:
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-.--.._____-___.____ -------- X
MILDRED J. FANA,
Plaintiff,
-against-
ANTHONY MARANDO and JOHN DOE, name fictitious
andunknown to theplaintiffat thistime,
Defendants..
_______..__.--..--____ ___----..-.-X
SUMMONS AND VERIFIED COMPLAINT
CHERNY & PODOLSKY, PLLC
1723 EAST
12™ 4™ FLOOR -
STREET,
BROOKLYN, NEW YORK 11229
(718) 449-5100
Pursuant to 22 NYCRR 130-1,1,the undersigñed the sitorney admitted to practicein thecourts
of New York State,certifiesthat,upon information and belief and reasonable inquiry, the
contentiom cantained inthe anne.xed document arenot frivolous.
Service of a copy of the withinishereby admitted.
Dated
..........................................
Attorney(s) for
Dated: Brooklyn, New York
October 30, 2018
CHERNY & PODOLSKY, PLLC
1723 EAST
12™ 4m ELOOR
STREET,
BROOKLYN, NEW YORK 11229
(718) 449-5100
8 of 8
Preview
FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 03/19/2020 a FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 NYSCEF (Page 1 DOC. ofNO.10)30 RECEIVED NYSCEF: 03/19/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --.---------..--___---------.-------x MILDRED J. FANA .10 O Plalntiff/Petitioner' 521793/2018 -against- Index No. ANTHONY MARANDO, JOHN DOE Defendant/Respondent. --------------------------------x NOTICE OF ELECTRONIC FILING You have received this Notice because: • The Plaintiff/Petitioner, whose name is listed above, has filed this case the using New York State Courts e-fillngsystem, and • You are a Defendant/Respondent (a party) inthis case. (CPLR § 2111, Uniform Rule § 202.5-bb) Ifyou are represented by an attorney: give this Notice to your attorney. (Attornevs: see Attorneys" "Information for pg. 2), If you are not represented by an attorney: you are not required to e-file. You may serve and file documents in paper form and you must be served with documants in paper form. as a without an you participate in e- However, pad·y attorney, may filing. . Benefits of E-Filing You can: • serve and fileyour documents electronically • view your case file on-line • limityour number of trips to the courthouse • court fees on-line. pay any There are no additional fees to e-file,view, or print your case records. To sign up fore-filing or for rnore information about how e-filingworks, you may: • visit:www.nvcourts,qov/efile-unrepresented or • go to the Center or Clerk's Office at the court where the case was filed. To find Help legal information to help you represent yourself visit www.nvcourthelp.aov Page 1 of 2 EFM-1 FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 NYSCEF (Page 2 DOC. ofNO. 10)30 . RECEIVED NYSCEF: 03/19/2020 Information for Attorneys An attorney representing a party-who is served with this notice must either: 1) immediately record his orher representation within-the e-filed matter on the NYSCEF site https://iapps.courts.state.ny,us/nvscef/HomePage: or 2) filethe Notice of Opt-Out form with the clerk of the court where this action is pending. Exemptions from mandatory e-filing are Ilmited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with allemployees subject to their direction) the operational knowledge to comply with e-filingrequirements. [5ection 202.5-bb(e)] For additional information about electronic filing and to create a NYSCEF account, visitthe NYSCEF website at www.nvcourts.cov/efile or.contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: efileanvcourts.oovi Dated: 10/30/2018 1723 East 12th 4th Street, Floor ALEKSANDR SIMON CHERNY Name Address CHERNY & PODOLSKY, PLLC Brooklyn,NY 11229 Firm Name .. 718-449-5100 Phone alekcherny gmnitcom E-Mail . . --o ANTHONY MARANDO 264 Bay 11thStreet,2nd Floor Brooklyn, NY 11228 JOHN DOE c/o ANTHONY MARANDO . 11/20/17 Index No. Page 2 of 2 EFM-1 FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 (Page of NYSCEF } DOC. NO.10)30 RECEIVED NYSCEF: 03/19/2020 - INDEX NO. 521793/2018 JFÊLED: KINGS COUNTY . ERK 10 / 3 0 / 2 018 0 1: 2 2 PM| 'NYSCEF DOC. NO. 1 RECEIVED NYSCEF: -10/30/2018 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF KINGS Date Filed: --___.....-a________-_________ .--.-----X MILDRED J. FANA, SUMMONS .. Plaintiff, Plaintiffdesignates KINGS County as theplace of Trial. -against- The basis of venue is The Plaintiff'sresidence, ANTHONY MARANDO and JOHN DOE, namefictiticas Plaintiffresidesat: . - 6th an2l)MREown to theplaintiff at this time, 5314 Avenue Brooklyn, NY 11220 Defendants, County of KINGS. ---- -------- -- ----X TO THE ABOVE NAMED DEFENDANTS: YOU ARE REREBY SUMMONED toanswer the complaint in thisaction and.to serve a copy of your ariswer,or, ifthe complaint isnot served with the summons, to serve a notice of appearance on plaintiff'sattorneys within twenty (20) days after service of thissummehs, exclusive of the day of service, or within thirty (30) days afterservice is complete ifthis summcas is not personally delivered to you within the State of New Yo1t In case of your failureto answer, Judgment will be taken.against you by default forthe reliefdemanded in the Complaint. DATED: Brooklyn, New York October.30, 2018 Yours, etc., By: Mari Milorava Kelman, Esq CHERNY & PODOLSKY, PLLC Attorneys forPlaintiff MILDRED J. FANA 126 45 .1723 East Street, Floor Brooklyn, NY 11229 (718) 449-5100 FileNo.: 8959 1 of 8 FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 NYSCEF(Page 4 DOC. of NO.10)30 RECEIVED NYSCEF: 03/19/2020 FILED: MGS COUNTY sRK 10 /3 O/ 2 0 18 0 1: 2 2 PM| . INDEX No. 521793/201B NYSCEF DOC . NO. 1 • * . RECEIVED NYSCEF: 10/30/2018 . . . . .DEVENDXNTS' ADDRESSES: ANTHONY MARAN1)O JOHN DOE 11* 2"d 264 Bay Street, Floor c/o ANTHONY MARANDO 11228. 11* 25d Brooklyn, NY 264 Bay Street, Floor .... ----........ Brooldyn, NY 11228 k- 2 of 8 FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 NYSCEF (Page 5 DOC. ofNO. 10)30 RECEIVED NYSCEF: 03/19/2020 JFILED: KINGS COUNTY RK 10 2018 01: 22 P INDEX NO. 521793/2018 /30/ NYSCEF DOC. NO. 1 RECEIVED NYSCE F: 10/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS MILDRED J. FANA, Plaintiff, VERIFIED COMPLAINT -against- . Index No. ANTRONY MARANDO and JOHN DOE, name ficd6=S and unknown to the.plaintiff at this time, Defendants. ------------------------- ¬-- ------X Plaintiff, MILDRED L FANA, by her attorneys, CHERNY & PODOLSKY, PLLC, '- cariq A g of the defcñdañts herein, respectfully alleges upon information and belief as follows: 1) Plaintiff,MILDRED 1 FANA, was and stillisa resident of the County of Kings, ¡ City and State of New York.. 2). Defendat, ANTHONY MARANDO, was and stillisa resident of the County of Kings, City and State of New York. 3) On orabout May 8, 2018, defendant, ANTHONY MARANDO, was theowner of a 2005 Jeep motor vehicle bearing State ofNew York registcaden number QVK3664. 4) On or about May 8, 2018, defendant, ANTHONY MARANDO, ed a 2005 Jeep motor vehicle bearing State·ofNew tork registrationnumber G.VK3664. 5) On orabout May 8, 2018,defendant, ANTHONY MARANDO, was controllinga 2005 Jeep motor vehicle bearing State ofNew York registration ilumberrGVK3664. 6) On or about May 8, 2018, defe~Þmt, ANTHONY MARANDO, was theoperator of a 2005 motor vehicle bearing State ofNew York registr-atiGn number GVK3664. Jeep On or about d ANTHONY MARANDO, was a 7) . May 8,.2018, =t, operating 3 af 8 FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 (Page ,6 of 10) NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 03/19/2020 FILED : KINGS COUNTY l JRK 10 /30 /2018 01: 22 PM INDEX NO. 521793/2018 NYSCEF DoC. No. 1 RECEIVED NYSCEF: 10/30/2018 2005 Jeep motor vehicle bearing State of New York regiatration number GVK3664 on Bay at or near itsintersection 865 in the 8tateof Parkway, with Street, County of Kings, City and New York. 8) That at alltimes hereinaftermentioned, Bay Parkway, at ornear itsintersection with 86th Street, in theCounty of Kings, City and State of New York, are and were a.public roadways, streets,highways arid/orthoroughfares used extensively by the public in general. 9) On or about May 8, 2018, defendant, ANTHONY MARANDO, was operating a 2005 Jeep niotor vehicle bearing State of New York registrationnumber GVK3664 within the scope of his employment. 10) Orr or about May 8, 2018 defendarG‡, JOHN DOE, was the opmeter of a 2005 motor vehicle bearing State ofNew York registratiortnumber GVK3664. Jeep 11) On or about May 8, 2018, defendant, JOHN DOE, was controlling a 2005 Jeep motor vehicle bearing State ofNew York registration number GVK3664 12) On or about May 8, 2018, defendant, JOHN DQE, was operating a 2005 Jeep motor vehicle bearing State ofNew York registraticñ number GVK3664 with the knowledge of . the defendant owner. 13) On or about May 8, 2018, defendant, JOHN DOE, was operating a 2005 Jeep motor vehicle bearing State ofNew York registrationnumber GVK3664 with the permission of the defendant owner. 14) On or about May 8 2018, defends.at,JOHN DOE, was operating a 2005 Jeep motor vehicle bearing State of New York registration number GVIO664 with the express consent of the defendant owner, On or about dehdan+ IOHN was a 2005 15) May 8, 2018, DOE, qperating Jeep 4 of 8 FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 ( Page'7 of 10) NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 03/19/2020 JF ILED : KINGS COUNTY JRK 10 3 0 /2 0 18 O 1: 2 2 PM INDEX No. 521793/2018 / NYSCEF^DOC. NO. 1 RECEIVED NYS CEF: 10/30/2018 motor vehicle bearing State of New York registrationnumber GVK3664 with the implied consent of thedefendant owner. 16) On or about May 8, 2018, defendant, JOHN DOE, was operating a 2005 Jeep motor vehicle bearing State of New York registrationnumber GVK3664 within the scope of his/her employment. 17) On or about May 8, 2018, defendarlt, JOHN DOE, was operating a 2005 Jeep motor vehicle bearing State of New York registratics number GVK3664 on Bay Parkway 865 Avenue, at ornear itsintersection with Street, in theCounty of Kings, City and State ofNew York. 18) On or about May 8, 2018,plaintiff,MILDRED L FANA, was operating a 2017 Toyota motor vehicle beating State of New York registration number T708958C on Bay 86* Parkway, at or near itsintersectionwith Street, 111the County of Kings, City and State of New York. defendants' 20) At the aforesaid time and place, the motor vehicle came into contact with the motor vehicle of theplaintiff. 21) That said contactwas due solely to theñégligence of the defendants, without any negligence on the partof theplaintiffcontributing thereto. 22) That as a result of the aforesaid contact, plaintig MILDRED J. FANA, was severely and permanently injured. 23) Plaintiff,MILDRED J. FANA, was seriously injured. 24) PlaintiR MILDRED J..FANA, has. sustained a serious injury as defined by Article 51 of the Insurance Law, or economic loss greaterthan basic econbmic loss as definedby Article 51.of the Insurance Law. 5 of B FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 NYSCEF (Page 8 DOC. ofNO. 10) 30 RECEIVED NYSCEF: 03/19/2020 : KINGS COUNTY Ji:RK /3 0 /2 018 01: 2 2 PM INDEX NO. 521793/2015 . IFTlaED 10 NYSCBP DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018 25) This action fallswithin one ormore of the exceptions set forthin CPLR Section 1602. 26) The aforesaid occurrence and resn'ting injuries to the plaintiff were due solely to the carelessness, recklessness and ne.gligence of the defendents in the awaciship, operation, management, inspection, maintenance,. supervision, repair and controlof the above mcationed motor vehicle,without any negligence on the part ofthe plaintiffcontributing thereto 27) That by reason of the forcgcing, MILDRED the plaintifÇ J. FANA has been darnaged in excess of thejurisdictional limitsof allthe lower Courts that would othcrwise have jurisilictinnin thisstateand by reason of the fõregüIng, the plaintiffhas suffered damages in an amount to be determined at trial WHEREFORE, MILDRED plaintiff, J, FANA, demands iudgaicat inthe plaintiff's favor and against the defendants in an amount to be determined at which trial, isin excess of thejurisdicticnal limitsof alllower courts,together with costs interest, and disbursements of thisaction. I Dated: Brooklyn, New York October 30, 2018 Yours, etc., Mari Milorava-Kelman, Esq. CHERNY & PODOLSKY, PLLC Attorneys for Plaintiff MILDRED J. FANA 125 4* 1723 East Street, Floor Brooklyn, NY 11.229 (718) 449-5100 File No.: 8959 u a 6 of 8 FILED: KINGS COUNTY CLERK 03/19/2020 02:27 PM INDEX NO. 521793/2018 (Page 10 . of 10) NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 03/19/2020 .(F1LED : KINGS COUNTY t JRK 10 3 0 /2 010 01: 2 2 ( INDEX NO. 521793/2018 / PMj NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/30/2018 Index No.: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -.--.._____-___.____ -------- X MILDRED J. FANA, Plaintiff, -against- ANTHONY MARANDO and JOHN DOE, name fictitious andunknown to theplaintiffat thistime, Defendants.. _______..__.--..--____ ___----..-.-X SUMMONS AND VERIFIED COMPLAINT CHERNY & PODOLSKY, PLLC 1723 EAST 12™ 4™ FLOOR - STREET, BROOKLYN, NEW YORK 11229 (718) 449-5100 Pursuant to 22 NYCRR 130-1,1,the undersigñed the sitorney admitted to practicein thecourts of New York State,certifiesthat,upon information and belief and reasonable inquiry, the contentiom cantained inthe anne.xed document arenot frivolous. Service of a copy of the withinishereby admitted. Dated .......................................... Attorney(s) for Dated: Brooklyn, New York October 30, 2018 CHERNY & PODOLSKY, PLLC 1723 EAST 12™ 4m ELOOR STREET, BROOKLYN, NEW YORK 11229 (718) 449-5100 8 of 8