On September 10, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Akeya P. Clarke,
and
Francisco Brivard,
Lyft, Inc.,
Vela Brivarderilus,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 07/01/2022 04:52 PM INDEX NO. 523184/2021
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 07/01/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
Index No.: 523184/21
AKEYA P. CLARKE,
Plaintiff, STATEMENT OF
-against- MATERIAL FACTS
FRANCISCO BRIVARD, LYFT, INC. and VELA
BRIVARDERILUS,
Defendants.
Mikhail Yadgarov, an attorney duly admitted to practice law before the Courts of the State of
New York, hereby affirms the truth of the following under penalty of perjury:
1. This is an action for serious personal injuries sustained by plaintiff AKEYA P.
CLARKE, as a result of a motor vehicle collision that occurred on August 17"', 2020, in which a
vehicle owned by defendant VELA BRIVARDERILUS and operated by defendant FRANCISCO
BRIVARD struck the vehicle plaintiff was passenger in from behind while plaintiff's vehicle was
stopped for approximately three to four seconds due to a red light on Flushing Avenue near its
"5"
intersection with Bedford Avenue, in the County of Kings, State of New York. (See Exhibit
Affidavit of the Plaintiff, AKEYA P. CLARKE).
2. As a result of the subject accident, plaintiff sustained severe and permanent personal
injuries to her left shoulder, lumbar spine and cervical spine and was required to undergo a left
shoulder arthroscopy surgery. (A copy of Plaintiff's Bill of Particulars is annexe hereto as Exhibit
"3").
Dated: Brooklyn, New York
July 1, 2022
ail Yadgarov, Esq.
2
1 of 1
Document Filed Date
July 01, 2022
Case Filing Date
September 10, 2021
Category
Torts - Motor Vehicle
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FILED: KINGS COUNTY CLERK 07/01/2022 04:52 PM INDEX NO. 523184/2021 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 07/01/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No.: 523184/21 AKEYA P. CLARKE, Plaintiff, STATEMENT OF -against- MATERIAL FACTS FRANCISCO BRIVARD, LYFT, INC. and VELA BRIVARDERILUS, Defendants. Mikhail Yadgarov, an attorney duly admitted to practice law before the Courts of the State of New York, hereby affirms the truth of the following under penalty of perjury: 1. This is an action for serious personal injuries sustained by plaintiff AKEYA P. CLARKE, as a result of a motor vehicle collision that occurred on August 17"', 2020, in which a vehicle owned by defendant VELA BRIVARDERILUS and operated by defendant FRANCISCO BRIVARD struck the vehicle plaintiff was passenger in from behind while plaintiff's vehicle was stopped for approximately three to four seconds due to a red light on Flushing Avenue near its "5" intersection with Bedford Avenue, in the County of Kings, State of New York. (See Exhibit Affidavit of the Plaintiff, AKEYA P. CLARKE). 2. As a result of the subject accident, plaintiff sustained severe and permanent personal injuries to her left shoulder, lumbar spine and cervical spine and was required to undergo a left shoulder arthroscopy surgery. (A copy of Plaintiff's Bill of Particulars is annexe hereto as Exhibit "3"). Dated: Brooklyn, New York July 1, 2022 ail Yadgarov, Esq. 2 1 of 1