Preview
FILED: KINGS COUNTY CLERK 04/19/2022 02:19 PM INDEX NO. 514198/2021
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 04/19/2022
EXHIBIT A
FILED: KINGS COUNTY CLERK 11/29/2018
04/19/2022 02:11
02:19 PM INDEX NO. 523984/2018
514198/2021
NYSCEF DOC. NO. 1
15 RECEIVED NYSCEF: 11/29/2018
04/19/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------X
JUDY PFEFFER, SUMMONS
Plaintiff, Index No.:
Date Filed:
-against-
RONAH HARRIS,
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, of if the complaint is not served with this summons, to serve a notice of
appearance on the plaintiffs' attorney(s) within twenty days after the services of this summons
exclusive of the day of service, where service is made by delivery upon you personally within the
state, or within 30 days after completion of service where service is made in any other manner. In
case of your failure to appear or answer, judgment will be taken against you by default for the relief
demanded in the complaint.
Plaintiff designates Kings County as the venue pursuant to CPLR 503(a), in that a
substantial part of the events or omissions giving rise to the claim occurred therein.
Dated: New York, New York
November 29, 2018
______________________________
WEISS & AKERMAN
Attorneys for Plaintiff
JUDY PFEFFER
52 Duane Street
7th Floor
New York, New York 10007
(212) 233-0800
TO:
RONAH HARRIS
20234 Heather Dr
West Windsor Township, NJ 08550
1
1 of 5
FILED: KINGS COUNTY CLERK 11/29/2018
04/19/2022 02:11
02:19 PM INDEX NO. 523984/2018
514198/2021
NYSCEF DOC. NO. 1
15 RECEIVED NYSCEF: 11/29/2018
04/19/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------X Index No.:
JUDY PFEFFER,
Plaintiff, COMPLAINT
-against-
RONAH HARRIS,
Defendants,
--------------------------------------------------------------------X
Plaintiff, by her attorneys, WEISS & AKERMAN, complaining of the defendant, allege, upon
information and belief as follows:
1. At all times relevant hereto, herein mentioned, plaintiff was and still is a resident of
the County of Kings, State of New York.
2. At all times relevant hereto, defendant RONAH HARRIS was and still is a resident
of the State of New York.
3. At all times relevant hereto, defendant, RONAH HARRIS was and still is a resident
of a foreign state.
4. That on or about August 28, 2018, defendant RONAH HARRIS owned a Toyota
motor vehicle bearing New Jersey license plate X48FSF.
5. That on or about August 28, 2018, defendant RONAH HARRIS operated the
aforesaid motor vehicle.
6. That on or about August 28, 2018, defendant RONAH HARRIS managed the
aforesaid motor vehicle.
2
2 of 5
FILED: KINGS COUNTY CLERK 11/29/2018
04/19/2022 02:11
02:19 PM INDEX NO. 523984/2018
514198/2021
NYSCEF DOC. NO. 1
15 RECEIVED NYSCEF: 11/29/2018
04/19/2022
7. That on or about August 28, 2018, defendant RONAH HARRIS controlled the
aforesaid motor vehicle.
8. That on or about August 28, 2018, plaintiff JUDY PFEFFER was a passenger in a
second motor vehicle.
9. That on or about August 28, 2018, Avenue S and Batchelder Street, in the County of
Kings, State of New York, were public roadways and/or thoroughfares.
10. That on or about August 28, 2018, in the vicinity of the aforesaid roadways, the
aforementioned vehicle and operated by defendant RONAH HARRIS was in contact with the motor
vehicle in which the plaintiff JUDY PFEFFER was a passenger.
11. That as a result of the aforesaid contact, the plaintiff was injured.
12. That the aforesaid occurrence was cause wholly and solely by reason of the
negligence of the defendant, without any fault or negligence on the part of the plaintiff contributing
thereto.
13. That the negligence of the defendant consisted of operating the aforesaid motor
vehicle in a negligent, reckless, and careless; in failing to keep the aforesaid motor vehicles under
reasonable and proper control; in failing to operate the aforesaid motor vehicles with due regard for
the safety of the public and others; in failing to keep a proper lookout; in failing to observe what was
available to be observed; in failing to observe each other; in failing to avoid contact with and yield
the right of way; im operating the aforesaid motor vehicle in a manner contrary to and in violation of
the statutes, ordinances, rules and regulations in such cases made and provided; in failing to provide
and/or make prompt and timely use of adequate and efficient brakes and steering mechanisms; in
operating the aforesaid motor vehicles in such a negligent, careless, reckless wanton and grossly
3
3 of 5
FILED: KINGS COUNTY CLERK 11/29/2018
04/19/2022 02:11
02:19 PM INDEX NO. 523984/2018
514198/2021
NYSCEF DOC. NO. 1
15 RECEIVED NYSCEF: 11/29/2018
04/19/2022
negligent manner as to precipitate the aforesaid accident; in failing to take defensive action; in
failing to warn of the approach of the aforesaid motor vehicles and the defendants was otherwise
careless, reckless and negligent.
14. That by reason of the foregoing, plaintiff sustained severe and permanent personal
injuries, and plaintiff was otherwise damaged.
15. That plaintiff sustained serious injuries as defined in Article 51 of the Insurance Law
of the State of New York.
16. That plaintiff sustained serious injuries and economic loss greater than basic
economic loss as to satisfy the exceptions of Article 51 of the Insurance Law of the State of New
York.
17. That this action falls within one or more of the exceptions as set forth in CPLR
Article 16 in that Plaintiff seeks to hold one or more persons liable as a result of the use, ownership
and possession of a motor vehicle.
18. That as a result of the foregoing, Plaintiff was damaged in an amount exceeding the
jurisdiction of all lower courts.
WHEREFORE, Plaintiff demands judgment against the Defendant in an amount to be
4
4 of 5
FILED: KINGS COUNTY CLERK 11/29/2018
04/19/2022 02:11
02:19 PM INDEX NO. 523984/2018
514198/2021
NYSCEF DOC. NO. 1
15 RECEIVED NYSCEF: 11/29/2018
04/19/2022
determined at the trial of this action, which amount exceeds the jurisdiction of all lower courts,
together with the costs and disbursements of this action.
Dated: New York, New York
November 29, 2018
Yours, etc,
______________________________
WEISS & AKERMAN
Attorneys for Plaintiff
JUDY PFEFFER
52 Duane Street
7th Floor
New York, New York 10007
(212) 233-0800
5
5 of 5
Preview
FILED: KINGS COUNTY CLERK 04/19/2022 02:19 PM INDEX NO. 514198/2021 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 04/19/2022 EXHIBIT A FILED: KINGS COUNTY CLERK 11/29/2018 04/19/2022 02:11 02:19 PM INDEX NO. 523984/2018 514198/2021 NYSCEF DOC. NO. 1 15 RECEIVED NYSCEF: 11/29/2018 04/19/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X JUDY PFEFFER, SUMMONS Plaintiff, Index No.: Date Filed: -against- RONAH HARRIS, 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, of if the complaint is not served with this summons, to serve a notice of appearance on the plaintiffs' attorney(s) within twenty days after the services of this summons exclusive of the day of service, where service is made by delivery upon you personally within the state, or within 30 days after completion of service where service is made in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Plaintiff designates Kings County as the venue pursuant to CPLR 503(a), in that a substantial part of the events or omissions giving rise to the claim occurred therein. Dated: New York, New York November 29, 2018 ______________________________ WEISS & AKERMAN Attorneys for Plaintiff JUDY PFEFFER 52 Duane Street 7th Floor New York, New York 10007 (212) 233-0800 TO: RONAH HARRIS 20234 Heather Dr West Windsor Township, NJ 08550 1 1 of 5 FILED: KINGS COUNTY CLERK 11/29/2018 04/19/2022 02:11 02:19 PM INDEX NO. 523984/2018 514198/2021 NYSCEF DOC. NO. 1 15 RECEIVED NYSCEF: 11/29/2018 04/19/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X Index No.: JUDY PFEFFER, Plaintiff, COMPLAINT -against- RONAH HARRIS, Defendants, --------------------------------------------------------------------X Plaintiff, by her attorneys, WEISS & AKERMAN, complaining of the defendant, allege, upon information and belief as follows: 1. At all times relevant hereto, herein mentioned, plaintiff was and still is a resident of the County of Kings, State of New York. 2. At all times relevant hereto, defendant RONAH HARRIS was and still is a resident of the State of New York. 3. At all times relevant hereto, defendant, RONAH HARRIS was and still is a resident of a foreign state. 4. That on or about August 28, 2018, defendant RONAH HARRIS owned a Toyota motor vehicle bearing New Jersey license plate X48FSF. 5. That on or about August 28, 2018, defendant RONAH HARRIS operated the aforesaid motor vehicle. 6. That on or about August 28, 2018, defendant RONAH HARRIS managed the aforesaid motor vehicle. 2 2 of 5 FILED: KINGS COUNTY CLERK 11/29/2018 04/19/2022 02:11 02:19 PM INDEX NO. 523984/2018 514198/2021 NYSCEF DOC. NO. 1 15 RECEIVED NYSCEF: 11/29/2018 04/19/2022 7. That on or about August 28, 2018, defendant RONAH HARRIS controlled the aforesaid motor vehicle. 8. That on or about August 28, 2018, plaintiff JUDY PFEFFER was a passenger in a second motor vehicle. 9. That on or about August 28, 2018, Avenue S and Batchelder Street, in the County of Kings, State of New York, were public roadways and/or thoroughfares. 10. That on or about August 28, 2018, in the vicinity of the aforesaid roadways, the aforementioned vehicle and operated by defendant RONAH HARRIS was in contact with the motor vehicle in which the plaintiff JUDY PFEFFER was a passenger. 11. That as a result of the aforesaid contact, the plaintiff was injured. 12. That the aforesaid occurrence was cause wholly and solely by reason of the negligence of the defendant, without any fault or negligence on the part of the plaintiff contributing thereto. 13. That the negligence of the defendant consisted of operating the aforesaid motor vehicle in a negligent, reckless, and careless; in failing to keep the aforesaid motor vehicles under reasonable and proper control; in failing to operate the aforesaid motor vehicles with due regard for the safety of the public and others; in failing to keep a proper lookout; in failing to observe what was available to be observed; in failing to observe each other; in failing to avoid contact with and yield the right of way; im operating the aforesaid motor vehicle in a manner contrary to and in violation of the statutes, ordinances, rules and regulations in such cases made and provided; in failing to provide and/or make prompt and timely use of adequate and efficient brakes and steering mechanisms; in operating the aforesaid motor vehicles in such a negligent, careless, reckless wanton and grossly 3 3 of 5 FILED: KINGS COUNTY CLERK 11/29/2018 04/19/2022 02:11 02:19 PM INDEX NO. 523984/2018 514198/2021 NYSCEF DOC. NO. 1 15 RECEIVED NYSCEF: 11/29/2018 04/19/2022 negligent manner as to precipitate the aforesaid accident; in failing to take defensive action; in failing to warn of the approach of the aforesaid motor vehicles and the defendants was otherwise careless, reckless and negligent. 14. That by reason of the foregoing, plaintiff sustained severe and permanent personal injuries, and plaintiff was otherwise damaged. 15. That plaintiff sustained serious injuries as defined in Article 51 of the Insurance Law of the State of New York. 16. That plaintiff sustained serious injuries and economic loss greater than basic economic loss as to satisfy the exceptions of Article 51 of the Insurance Law of the State of New York. 17. That this action falls within one or more of the exceptions as set forth in CPLR Article 16 in that Plaintiff seeks to hold one or more persons liable as a result of the use, ownership and possession of a motor vehicle. 18. That as a result of the foregoing, Plaintiff was damaged in an amount exceeding the jurisdiction of all lower courts. WHEREFORE, Plaintiff demands judgment against the Defendant in an amount to be 4 4 of 5 FILED: KINGS COUNTY CLERK 11/29/2018 04/19/2022 02:11 02:19 PM INDEX NO. 523984/2018 514198/2021 NYSCEF DOC. NO. 1 15 RECEIVED NYSCEF: 11/29/2018 04/19/2022 determined at the trial of this action, which amount exceeds the jurisdiction of all lower courts, together with the costs and disbursements of this action. Dated: New York, New York November 29, 2018 Yours, etc, ______________________________ WEISS & AKERMAN Attorneys for Plaintiff JUDY PFEFFER 52 Duane Street 7th Floor New York, New York 10007 (212) 233-0800 5 5 of 5