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FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 12/16/2022
EXHIBIT 18
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 12/16/2022
CCOAMINI SUPREMECOURT - STATE OF NEW YORK DATE: 10/05/2021
INDEX NO: 107453 2002 NEW YORK COUNTY CLERK TIME: 11:46:37
PURCHASE: 04112002 CIVIL INDEX MINUTE BOOK INQUIRY
PLAINTIFF NAME: PIERSON CHERI DEFENDANTNAME: FARRIOR GORDONS
ATTORNEY: KENNETH J. GELLERMA ATTORNEY: UNKNOWN
26 COURT ST., STE.
BROOKLYN, NY
718-797-3737
SEQ DATE MINUTES
0001 04112002 SUMMONSAND COMPLAINT
PAGE - 1
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 12/16/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK .
---------------------------------------------------------X
CHERI PIERSON, $
Index No.
Plaintiff, Date purchased:
-against-
Plaintiff(s)designate(s)
NEW YORK
County as the Place of trial
GORDON S. FARRIOR,
Defendant. SUMMONS
The basis of venue is
Place of occurrence
Plaintiff resides at
2307 Cmssing Way, Wayne
State of New Jersey
___________________---________________________________Ç
To the above named Defendant(s)
YOU ARE HEREBY SUMMONED to answer the complaint in this
action 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 Attorneys(s) within
days after the service of this summons, exclusive of the date of service r within 30
days after the service is complete ifthis#siammons is not personally deh d to yo
within the State of New York); and in case of your failure to appe r an r, d ent
will be taken against you by default for the relief demanded e co pl
NNETH ELLE
Dated: Brooklyn,
April 11, 2002. . Attorney(s) or Plaintiff
Office and Post Office Address
Defendant's address: 26 Court Street, Suite 1401
Brooklyn, NY 11242
(718) 797-3737
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 12/16/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-----------------------------------------------X Index No.
CHERI PEIRSON,
VERIFIED COMPLAINT
Plaintiff,
-against-
GORDON S. FARRIOR,
'
Defendant. o2107453
___________________________________________Ç
Plaintiff, by her attorney, Kenneth J. Gellerman, complaining of the
defendant allege at all times hereinafter mentioned and upon
information and belief:
1. Plaintiff is a resident of the town of Wayne, State of New Jersey.
2. Defendant is a resident of the County, City, and State of New
York.
3. On April 23, 2000, defendant owned and operated a motor
vehicle, to wit a 1987 Hyundi, bearing New York State registration number
N798KE.
4. On April 23, 2000, defendant operated, managed and
controlled the aforesaid vehicle.
5. On April 23, 2000, plaintiff operated a motor vehicle.
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 12/16/2022
6. Third Avenue at the intersection with East 40th Street is a public
thoroughfare located in the County, City and State of New York.
7. That on April 23, 2000, the motor vehicle owned and operated
by defendant and the motor vehicle operated by plaintiff were in
contact with each other.
8. That said contact took place on Third Avenue at the intersection
of East 40thStreet in the County, City and State of New York.
9. That the defendant was careless, negligent, and reckless in the
ownership, operation, management and control of their motor vehicle.
10. That by reason of said occurrence, plaintiff was injured.
11. That by reason of said occurrence, plaintiff was seriously injured.
12. That plaintiff sustained a serious injury, and/or economic loss
greater than basic economic loss, as defined in Article 51 of the Insurance
Law.
13. That the injuries to plaintiff were caused wholly and solely
through the carelessness, negligence, and recklessness of the defendant
without any fault on plaintiff's part contributing thereto.
14. That this action falls within one or more of the exceptions
contained in CPLR Section 1602.
15. That as a result of the foregoing, plaintiff has been damaged in
the sum of $1,000,000.00.
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 12/16/2022
WHEREFORE, plaintiff demands judgment against the defendant in
the sum of $1,000,000.00; together with the costs and disbursement of this
action.
Dated: Brooklyn, NY
April 11, 2002.
ENNETH J. ERM
Attorney for la tiff
Office an P. O. Address
26 Court Street
Suite 1401
Brooklyn, NY 11242
(718) 797-3737