Preview
FILED: NASSAU COUNTY CLERK 09/23/2022
11/10/2022 10:39
03:16 AM
PM INDEX NO. 612706/2022
NYSCEF DOC. NO. 1
10 RECEIVED NYSCEF: 09/23/2022
11/10/2022
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF NASSAU Date Filed:
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MARIA TORRES, Plaintiff designates
Nassau County as the
Plaintiff, place of trial
-against- SUMMONS
MOLLY AMELIA SAFAR and JAY SAFAR, The basis of venue is
Plaintiff’s residence.
Defendants.
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TO THE ABOVE NAMED DEFENDANTS:
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 the plaintiff's attorney within twenty (20) days after the service of this Summons,
exclusive of the day of service (or within thirty (30) days after service is complete if this Summons
is not personally delivered to you within the State of New York); and 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: Carle Place, New York
September 23, 2022
Yours, etc.
LAW OFFICE OF ALAN M. SANDERS, LLC
Brian Sanders
BRIAN M. SANDERS, ESQ.
Attorneys for Plaintiff
MARIA TORRES
One Old Country Road - Suite 320
Carle Place, New York 11514
516-742-6400
DEFENDANTS’ ADDRESSES:
MOLLY AMELIA SAFAR JAY SAFAR
58 Barbara Ct 267 Carleton Ave, Apt. 301
Amityville, New York 11701 Central Islip, New York 11722
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FILED: NASSAU COUNTY CLERK 09/23/2022
11/10/2022 10:39
03:16 AM
PM INDEX NO. 612706/2022
NYSCEF DOC. NO. 1
10 RECEIVED NYSCEF: 09/23/2022
11/10/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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MARIA TORRES,
Plaintiff, Index No.
-against- VERIFIED
COMPLAINT
MOLLY AMELIA SAFAR and JAY SAFAR,
Defendants.
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Plaintiff, MARIA TORRES, by and through her attorneys, LAW OFFICE OF ALAN M.
SANDERS, LLC, complaining of defendants MOLLY AMELIA SAFAR and JAY SAFAR,
respectfully shows to the Court and alleges:
1. At all times hereinafter mentioned, plaintiff MARIA TORRES was and still is a
resident of the County of Nassau, State of New York.
2. At all times hereinafter mentioned and upon information and belief, defendant
MOLLY AMELIA SAFAR was and still is a resident of the County of Suffolk, State of New York.
3. At all times hereinafter mentioned and upon information and belief, defendant JAY
SAFAR was and still is a resident of the County of Suffolk, State of New York.
4. At all times hereinafter mentioned, plaintiff MARIA TORRES was the owner and
passenger of a motor vehicle bearing State of New York license plate number KWJ4149.
5. At all times hereinafter mentioned and upon information and belief, defendant
MOLLY AMELIA SAFAR was the operator of a motor vehicle bearing State of New York license
plate number GTX5091.
6. At all times hereinafter mentioned and upon information and belief, defendant JAY
SAFAR was the owner of a motor vehicle bearing State of New York license plate number
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FILED: NASSAU COUNTY CLERK 09/23/2022
11/10/2022 10:39
03:16 AM
PM INDEX NO. 612706/2022
NYSCEF DOC. NO. 1
10 RECEIVED NYSCEF: 09/23/2022
11/10/2022
GTX5091.
7. At all times hereinafter mentioned, Broadway, 75 feet South of Louden Avenue,
Amityville, New York, was and still is a public roadway.
8. On or about the 21st day of March 2022, Broadway, 75 feet South of Louden
Avenue, Amityville, New York, the motor vehicle owned by defendant JAY SAFAR and operated
by defendant MOLLY AMELIA SAFAR came into contact with the motor vehicle owned by
plaintiff MARIA TORRES, in which she was a passenger.
9. There was no culpable conduct on the part of plaintiff MARIA TORRES.
10. Said accident and injuries to plaintiff MARIA TORRES were due to the
carelessness and negligence of defendants.
11. Plaintiff MARIA TORRES sustained serious injuries as defined in Section 5102(d)
of the Insurance law of the State of New York and economic loss greater than basic economic loss
as defined in Section 5102(a) of the Insurance Law of New York State.
12. This action falls within one or more of the exceptions set forth in Civil Practice
Laws §1602.
13. By reason of the foregoing, plaintiff MARIA TORRES was rendered sick, sore,
lame and disabled, and her injuries, upon information and belief, will be of a permanent nature,
and that by reason thereof, she has been and will be prevented in the future from following her
usual vocation, and has been and will be obligated in the future to incur and expend monies for
medical care, medicines and treatment, all to her damage in the sum of ONE MILLION
($1,000,000.00) DOLLARS.
WHEREFORE, plaintiff MARIA TORRES demands judgment against defendant MOLLY
AMELIA SAFAR and defendant JAY SAFAR in the sum of ONE MILLION ($1,000,000.00)
3 of 5
FILED: NASSAU COUNTY CLERK 09/23/2022
11/10/2022 10:39
03:16 AM
PM INDEX NO. 612706/2022
NYSCEF DOC. NO. 1
10 RECEIVED NYSCEF: 09/23/2022
11/10/2022
DOLLARS; together with the costs and disbursements of this action and for such other and further
relief as this Court may deem just and proper.
Dated: Carle Place, New York
September 23, 2022
Yours, etc.
LAW OFFICES OF ALAN M. SANDERS, LLC
Brian Sanders
BRIAN M. SANDERS, ESQ.
Attorneys for Plaintiff
MARIA TORRES
One Old Country Road - Suite 320
Carle Place, New York 11514
516-742-6400
4 of 5
FILED: NASSAU COUNTY CLERK 09/23/2022
11/10/2022 10:39
03:16 AM
PM INDEX NO. 612706/2022
NYSCEF DOC. NO. 1
10 RECEIVED NYSCEF: 09/23/2022
11/10/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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MARIA TORRES,
Index No.:
Plaintiff,
-against-
MOLLY AMELIA SAFAR and JAY SAFAR,
Defendants.
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SUMMONS AND VERIFIED COMPLAINT
=====================================================================
CERTIFICATION PURSUANT TO RULE 130-1.1a
I, the undersigned, am an attorney admitted to practice in the Courts of the State of
New York, and say that my signature below is in lieu of my signature on each of the papers
contained herein.
Brian Sanders
BRIAN M. SANDERS
LAW OFFICES OF ALAN M. SANDERS, LLC
ATTORNEYS FOR PLAINTIFF(S)
MARIA TORRES
ONE OLD COUNTRY ROAD - SUITE 320
CARLE PLACE, NEW YORK 11514
----------------
TEL. NO.: 516-742-6400
FAX. NO.: 516-719-7280
5 of 5
Preview
FILED: NASSAU COUNTY CLERK 09/23/2022 11/10/2022 10:39 03:16 AM PM INDEX NO. 612706/2022 NYSCEF DOC. NO. 1 10 RECEIVED NYSCEF: 09/23/2022 11/10/2022 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF NASSAU Date Filed: ------------------------------------------------------------------------------X MARIA TORRES, Plaintiff designates Nassau County as the Plaintiff, place of trial -against- SUMMONS MOLLY AMELIA SAFAR and JAY SAFAR, The basis of venue is Plaintiff’s residence. Defendants. ------------------------------------------------------------------------------X TO THE ABOVE NAMED DEFENDANTS: 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 the plaintiff's attorney within twenty (20) days after the service of this Summons, exclusive of the day of service (or within thirty (30) days after service is complete if this Summons is not personally delivered to you within the State of New York); and 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: Carle Place, New York September 23, 2022 Yours, etc. LAW OFFICE OF ALAN M. SANDERS, LLC Brian Sanders BRIAN M. SANDERS, ESQ. Attorneys for Plaintiff MARIA TORRES One Old Country Road - Suite 320 Carle Place, New York 11514 516-742-6400 DEFENDANTS’ ADDRESSES: MOLLY AMELIA SAFAR JAY SAFAR 58 Barbara Ct 267 Carleton Ave, Apt. 301 Amityville, New York 11701 Central Islip, New York 11722 1 of 5 FILED: NASSAU COUNTY CLERK 09/23/2022 11/10/2022 10:39 03:16 AM PM INDEX NO. 612706/2022 NYSCEF DOC. NO. 1 10 RECEIVED NYSCEF: 09/23/2022 11/10/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ------------------------------------------------------------------------------X MARIA TORRES, Plaintiff, Index No. -against- VERIFIED COMPLAINT MOLLY AMELIA SAFAR and JAY SAFAR, Defendants. ------------------------------------------------------------------------------X Plaintiff, MARIA TORRES, by and through her attorneys, LAW OFFICE OF ALAN M. SANDERS, LLC, complaining of defendants MOLLY AMELIA SAFAR and JAY SAFAR, respectfully shows to the Court and alleges: 1. At all times hereinafter mentioned, plaintiff MARIA TORRES was and still is a resident of the County of Nassau, State of New York. 2. At all times hereinafter mentioned and upon information and belief, defendant MOLLY AMELIA SAFAR was and still is a resident of the County of Suffolk, State of New York. 3. At all times hereinafter mentioned and upon information and belief, defendant JAY SAFAR was and still is a resident of the County of Suffolk, State of New York. 4. At all times hereinafter mentioned, plaintiff MARIA TORRES was the owner and passenger of a motor vehicle bearing State of New York license plate number KWJ4149. 5. At all times hereinafter mentioned and upon information and belief, defendant MOLLY AMELIA SAFAR was the operator of a motor vehicle bearing State of New York license plate number GTX5091. 6. At all times hereinafter mentioned and upon information and belief, defendant JAY SAFAR was the owner of a motor vehicle bearing State of New York license plate number 2 of 5 FILED: NASSAU COUNTY CLERK 09/23/2022 11/10/2022 10:39 03:16 AM PM INDEX NO. 612706/2022 NYSCEF DOC. NO. 1 10 RECEIVED NYSCEF: 09/23/2022 11/10/2022 GTX5091. 7. At all times hereinafter mentioned, Broadway, 75 feet South of Louden Avenue, Amityville, New York, was and still is a public roadway. 8. On or about the 21st day of March 2022, Broadway, 75 feet South of Louden Avenue, Amityville, New York, the motor vehicle owned by defendant JAY SAFAR and operated by defendant MOLLY AMELIA SAFAR came into contact with the motor vehicle owned by plaintiff MARIA TORRES, in which she was a passenger. 9. There was no culpable conduct on the part of plaintiff MARIA TORRES. 10. Said accident and injuries to plaintiff MARIA TORRES were due to the carelessness and negligence of defendants. 11. Plaintiff MARIA TORRES sustained serious injuries as defined in Section 5102(d) of the Insurance law of the State of New York and economic loss greater than basic economic loss as defined in Section 5102(a) of the Insurance Law of New York State. 12. This action falls within one or more of the exceptions set forth in Civil Practice Laws §1602. 13. By reason of the foregoing, plaintiff MARIA TORRES was rendered sick, sore, lame and disabled, and her injuries, upon information and belief, will be of a permanent nature, and that by reason thereof, she has been and will be prevented in the future from following her usual vocation, and has been and will be obligated in the future to incur and expend monies for medical care, medicines and treatment, all to her damage in the sum of ONE MILLION ($1,000,000.00) DOLLARS. WHEREFORE, plaintiff MARIA TORRES demands judgment against defendant MOLLY AMELIA SAFAR and defendant JAY SAFAR in the sum of ONE MILLION ($1,000,000.00) 3 of 5 FILED: NASSAU COUNTY CLERK 09/23/2022 11/10/2022 10:39 03:16 AM PM INDEX NO. 612706/2022 NYSCEF DOC. NO. 1 10 RECEIVED NYSCEF: 09/23/2022 11/10/2022 DOLLARS; together with the costs and disbursements of this action and for such other and further relief as this Court may deem just and proper. Dated: Carle Place, New York September 23, 2022 Yours, etc. LAW OFFICES OF ALAN M. SANDERS, LLC Brian Sanders BRIAN M. SANDERS, ESQ. Attorneys for Plaintiff MARIA TORRES One Old Country Road - Suite 320 Carle Place, New York 11514 516-742-6400 4 of 5 FILED: NASSAU COUNTY CLERK 09/23/2022 11/10/2022 10:39 03:16 AM PM INDEX NO. 612706/2022 NYSCEF DOC. NO. 1 10 RECEIVED NYSCEF: 09/23/2022 11/10/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ------------------------------------------------------------------------------X MARIA TORRES, Index No.: Plaintiff, -against- MOLLY AMELIA SAFAR and JAY SAFAR, Defendants. ------------------------------------------------------------------------------X ===================================================================== SUMMONS AND VERIFIED COMPLAINT ===================================================================== CERTIFICATION PURSUANT TO RULE 130-1.1a I, the undersigned, am an attorney admitted to practice in the Courts of the State of New York, and say that my signature below is in lieu of my signature on each of the papers contained herein. Brian Sanders BRIAN M. SANDERS LAW OFFICES OF ALAN M. SANDERS, LLC ATTORNEYS FOR PLAINTIFF(S) MARIA TORRES ONE OLD COUNTRY ROAD - SUITE 320 CARLE PLACE, NEW YORK 11514 ---------------- TEL. NO.: 516-742-6400 FAX. NO.: 516-719-7280 5 of 5