Preview
FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
Index No.
- - - - - --- - - ---------------------------------------x
Plaintiff, Plaintiff's Residence
QUEENS County
against 1685 Norman Street, Apt. 2R
Ridgewood, NY 11385
CARLOS J.ALTAMIRANO,
The basis of venue designated is:
Defendant. residence.
Plaintiff(s)
__________________________________----______-------------------------Ç
To the above named Defendant(s)
Stt Art herebP 5tittittt0tithto answer the complaint in thisaction, 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 ismade in any other manner. In
case of your failure to appear or answer, judgment will be taken against you by default for the
reliefdemanded in the complaint.
DATED: New York, New York
December 16, 2022
Harmon, Linder & Rogowsky, Esqs.
Attorneys for Plaintiff(s)
3 Park Avenue, 23rd Floor
Suite 2300
New York, NY 10016
Carlos J.Altamirano
15 Second Street
Ridgefield Park, NJ 07660
1 of 6
FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------x
JASMINE F. MORAN,
VERIFIED COMPLAINT
Plaintiff,
-against-
CARLOS J. ALTAMIRANO,
Defendant.
--------------------------------------x
Plaintiff, complaining of the defendant herein by her attorneys,
HARMON, LINDER & ROGOWSKY, ESQS., respectfully sets forth and
alleges, as follows:
AS FOR A CAUSE OF ACTION
ON BEHALF OF JASMINE F. MORAN
1. That at the time of the commencement of this action plaintiff
was a resident of the County of QUEENS, State of New York.
2. That at all times herein mentioned defendant, CARLOS J.
ALTAMIRANO, was the owner and operator of a motor vehicle
bearing registration number E69PFX, State of New Jersey.
3. That at all times herein mentioned, plaintiff, JASMINE F.
MORAN, was the operator of a motor vehicle bearing registration
number HYU7856, State of New York.
4. That on the Twenty-Second Day of December 2021, at
approximately 5:38 p.m., the aforesaid vehicles came into
2 of 6
FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022
contact with plaintiff's vehicle at Ocean Avenue, at or near its
intersection Church Street, a public street and thoroughfare, in
the County of Nassau, State of New York.
5. The defendant so carelessly and negligently operated his
aforesaid vehicle so as to cause the aforesaid contact.
6. That as a result of the foregoing, this plaintiff was caused
to and did sustain severe and serious injuries and was required
to seek and obtain medical care and attention in an effort to
cure and alleviate same and, upon information and belief, will
be compelled to do so in the future.
7. That the aforesaid occurrence and the injuries sustained by
this plaintiff were caused by the negligence of the defendant.
8. That this plaintiff has sustained a serious injury as the
"d"
same is defined in Subdivision of Section 5102 of the
Insurance Law of the State of New York.
9. That this action falls within one or more of the exceptions
set forth in Section 1602 of the CPLR.
3 of 6
FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022
10. That by reason of the foregoing, plaintiff, JASMINE F.
MORAN, has been damaged in an amount which exceeds the
jurisdictional limits of all lower courts that would otherwise
have jurisdiction.
WHEREFORE, plaintiff, JASMINE F. MORAN, demands judgment
against the defendants on the Cause of Action in an amount which
exceeds the jurisdictional limits of all lower courts that would
otherwise have jurisdiction; all together with the costs and
disbursements of this action.
Dated: New York, New York
December 16, 2022
HARMON, LINDER & ROGOWSKY, ESQS.
Attorney(s) for Plaintiff(s)
3 Park Avenue, Suite 2300
New York, New York 10016
(212) 732-3665
MJL/mj
4 of 6
FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022
ATTORNEY'S VERIFICATION
STATE OF NEW YORK )
) ss:
COUNTY OF NEW YORK)
I,the undersigned, am an attorney admitted to practice in the Courts of New York State,
and say that:
I am the attomey of record or of counsel with the attomey(s) of record for plaintiff.
I have read the annexed SUMMONS AND VERIFIED COMPLAINT and know the
contents thereof and the same are true to my knowledge, except those matters therein which are
stated to be alleged on information and belief. As to those matters, I believe them to be true.
My belief,as to those matters therein not stated upon knowledge is based upon the following:
Interviews and/or discussions with the plaintiff(s) and papers and/or documents in the file.
The reasons I make this affirmation instead of the plaintiff isbecause said plaintiff
resides outside of the county from where your deponent maintains his office for the practice of
law.
Dated: New York, New York
December 16, 2022
Mark J. Linder, Esq.
5 of 6
FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022
Index No. Year
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
___________________________________________________________________________________________________________________
JASMINE F. MORAN,
Plaintiff,
-against-
CARLOS J. ALTAMIRANO,
Defendant.
____________________________________________________________________________----..__________________________________
SUMMONS AND VERIFIED COMPLAINT
___________________________________________________________________________________________________________________
HARMON, LINDER & ROGOSWKY, ESQS.
Attomey for Plaintiff(s)
3 Park Avenue, 23rd Floor
Suite 2300
New York, NY 10016
(212) 732-3665 Phone
(212) 732-1462 Facsimile
______________________________________________________________________________-------------------------------______
To:
Attorney(s) for Defendant
__________________________________________________________________________________-----------------________________
Service of a copy of the within Summons and Complaint is hereby admitted.
Dated:
Attorney(s) for
___________________________________________________-_______________________________________________________________
PLEASE TAKE NOTICE
¡ Notice of Entry thatthe withinis a (certified)
truecopy of a
entered intheofficeof theclerk ofthe withinnamed Court on
¡ Notice of Settlement
thatan orderof which the withinis a true
copy willbe presented forsettlement tothe
Hon. , oneof the judgesofthe withinnamed Court, at ,
on
Dated:
Yours, etc.
Harmon, Linder & Rogowsky, Esqs.
Attorneysfor Plaintyf
3 Park Avenue, Suite 2300
New York, NY 10016
(212) 732-3665
6 of 6
Preview
FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No. - - - - - --- - - ---------------------------------------x Plaintiff, Plaintiff's Residence QUEENS County against 1685 Norman Street, Apt. 2R Ridgewood, NY 11385 CARLOS J.ALTAMIRANO, The basis of venue designated is: Defendant. residence. Plaintiff(s) __________________________________----______-------------------------Ç To the above named Defendant(s) Stt Art herebP 5tittittt0tithto answer the complaint in thisaction, 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 ismade in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the reliefdemanded in the complaint. DATED: New York, New York December 16, 2022 Harmon, Linder & Rogowsky, Esqs. Attorneys for Plaintiff(s) 3 Park Avenue, 23rd Floor Suite 2300 New York, NY 10016 Carlos J.Altamirano 15 Second Street Ridgefield Park, NJ 07660 1 of 6 FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS --------------------------------------x JASMINE F. MORAN, VERIFIED COMPLAINT Plaintiff, -against- CARLOS J. ALTAMIRANO, Defendant. --------------------------------------x Plaintiff, complaining of the defendant herein by her attorneys, HARMON, LINDER & ROGOWSKY, ESQS., respectfully sets forth and alleges, as follows: AS FOR A CAUSE OF ACTION ON BEHALF OF JASMINE F. MORAN 1. That at the time of the commencement of this action plaintiff was a resident of the County of QUEENS, State of New York. 2. That at all times herein mentioned defendant, CARLOS J. ALTAMIRANO, was the owner and operator of a motor vehicle bearing registration number E69PFX, State of New Jersey. 3. That at all times herein mentioned, plaintiff, JASMINE F. MORAN, was the operator of a motor vehicle bearing registration number HYU7856, State of New York. 4. That on the Twenty-Second Day of December 2021, at approximately 5:38 p.m., the aforesaid vehicles came into 2 of 6 FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022 contact with plaintiff's vehicle at Ocean Avenue, at or near its intersection Church Street, a public street and thoroughfare, in the County of Nassau, State of New York. 5. The defendant so carelessly and negligently operated his aforesaid vehicle so as to cause the aforesaid contact. 6. That as a result of the foregoing, this plaintiff was caused to and did sustain severe and serious injuries and was required to seek and obtain medical care and attention in an effort to cure and alleviate same and, upon information and belief, will be compelled to do so in the future. 7. That the aforesaid occurrence and the injuries sustained by this plaintiff were caused by the negligence of the defendant. 8. That this plaintiff has sustained a serious injury as the "d" same is defined in Subdivision of Section 5102 of the Insurance Law of the State of New York. 9. That this action falls within one or more of the exceptions set forth in Section 1602 of the CPLR. 3 of 6 FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022 10. That by reason of the foregoing, plaintiff, JASMINE F. MORAN, has been damaged in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction. WHEREFORE, plaintiff, JASMINE F. MORAN, demands judgment against the defendants on the Cause of Action in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction; all together with the costs and disbursements of this action. Dated: New York, New York December 16, 2022 HARMON, LINDER & ROGOWSKY, ESQS. Attorney(s) for Plaintiff(s) 3 Park Avenue, Suite 2300 New York, New York 10016 (212) 732-3665 MJL/mj 4 of 6 FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022 ATTORNEY'S VERIFICATION STATE OF NEW YORK ) ) ss: COUNTY OF NEW YORK) I,the undersigned, am an attorney admitted to practice in the Courts of New York State, and say that: I am the attomey of record or of counsel with the attomey(s) of record for plaintiff. I have read the annexed SUMMONS AND VERIFIED COMPLAINT and know the contents thereof and the same are true to my knowledge, except those matters therein which are stated to be alleged on information and belief. As to those matters, I believe them to be true. My belief,as to those matters therein not stated upon knowledge is based upon the following: Interviews and/or discussions with the plaintiff(s) and papers and/or documents in the file. The reasons I make this affirmation instead of the plaintiff isbecause said plaintiff resides outside of the county from where your deponent maintains his office for the practice of law. Dated: New York, New York December 16, 2022 Mark J. Linder, Esq. 5 of 6 FILED: QUEENS COUNTY CLERK 12/16/2022 12:24 PM INDEX NO. 726453/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2022 Index No. Year SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ___________________________________________________________________________________________________________________ JASMINE F. MORAN, Plaintiff, -against- CARLOS J. ALTAMIRANO, Defendant. ____________________________________________________________________________----..__________________________________ SUMMONS AND VERIFIED COMPLAINT ___________________________________________________________________________________________________________________ HARMON, LINDER & ROGOSWKY, ESQS. Attomey for Plaintiff(s) 3 Park Avenue, 23rd Floor Suite 2300 New York, NY 10016 (212) 732-3665 Phone (212) 732-1462 Facsimile ______________________________________________________________________________-------------------------------______ To: Attorney(s) for Defendant __________________________________________________________________________________-----------------________________ Service of a copy of the within Summons and Complaint is hereby admitted. Dated: Attorney(s) for ___________________________________________________-_______________________________________________________________ PLEASE TAKE NOTICE ¡ Notice of Entry thatthe withinis a (certified) truecopy of a entered intheofficeof theclerk ofthe withinnamed Court on ¡ Notice of Settlement thatan orderof which the withinis a true copy willbe presented forsettlement tothe Hon. , oneof the judgesofthe withinnamed Court, at , on Dated: Yours, etc. Harmon, Linder & Rogowsky, Esqs. Attorneysfor Plaintyf 3 Park Avenue, Suite 2300 New York, NY 10016 (212) 732-3665 6 of 6