Preview
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 12/16/2022
EXHIBIT 17
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 12/16/2022
CCOAMINI SUPREMECOURT - STATE OF NEW YORK DATE: 10/05/2021
INDEX NO: 107432 2003 NEW YORK COUNTY CLERK TIME: 11:47:00
PURCHASE: 04222003 CIVIL INDEX MINUTE BOOK INQUIRY
PLAINTIFF NAME: PIERSON CHERI DEFENDANT NAME: FARRIOR GORDONS
ATTORNEY: KENNETH J. GELLERMA ATTORNEY: UNKNOWN
26 COURT ST., STE.
BROOKLYN, NY
718-797-3737
SEQ DATE MINUTES
0001 04222003 SUMMONSAND COMPLAINT
PAGE - 1
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 12/16/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
.......................-----.......................................--.x
CHERI PIERSON,
03107432
Index No.
Plaintiff, Date purchased:
-against-
Plaintiff(s)designate(s)
County as the Placeof frial
GORDON S. FARRIOR,
SUMMONS
The basis of venue is
Plaintiff'sresidence and
Defen t. . Place of Occurrence
Plaintiffresides at
Ogunty of New York
To the above named Defendant(s)
YOU ARE HEREBY SUMM answer the complaint in this action
to serve a copy of your answer, or, ifthe compla t served with thissummons, to
serve a notice of appearance, on the Plaintiff'sAttorn (s) within days after the
service of this summons, exclusive of the date of service (or within 30 days after the
service is complete ifthissummons isnot personally delivered to you thin the S te of
New York); and in case of your failure to appear or answer, g nt be t n
against you by default for the reliefdemanded in the co laint.
ENNET . GEL RI4AN
Dated: Brooklyn, NY
April 11, 2003. . Attorney for Plaintiff
Office nd 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. 29 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.
03107432
FARRIOR,
Defendant.
X
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. 29 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 40m Street in the County, and State of New York.
City
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. 29 RECEIVED NYSCEF: 12/16/2022
WHEREFORE, plaintiff demands judgment against the defendant in
together with the costs and disbursement of this
the sum of $1,000,000.00;
action.
.L
Dated: Brooklyn, NY
April 11, 2003.
ENN H EL MAN
Attor ey fo la ti
Offi e and P. O Address
26 ourt Street
Suite 1401
Brooklyn, NY 11242
(718) 797-3737
Preview
FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 12/16/2022 EXHIBIT 17 FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 12/16/2022 CCOAMINI SUPREMECOURT - STATE OF NEW YORK DATE: 10/05/2021 INDEX NO: 107432 2003 NEW YORK COUNTY CLERK TIME: 11:47:00 PURCHASE: 04222003 CIVIL INDEX MINUTE BOOK INQUIRY PLAINTIFF NAME: PIERSON CHERI DEFENDANT NAME: FARRIOR GORDONS ATTORNEY: KENNETH J. GELLERMA ATTORNEY: UNKNOWN 26 COURT ST., STE. BROOKLYN, NY 718-797-3737 SEQ DATE MINUTES 0001 04222003 SUMMONSAND COMPLAINT PAGE - 1 FILED: NEW YORK COUNTY CLERK 12/16/2022 12:00 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 12/16/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK .......................-----.......................................--.x CHERI PIERSON, 03107432 Index No. Plaintiff, Date purchased: -against- Plaintiff(s)designate(s) County as the Placeof frial GORDON S. FARRIOR, SUMMONS The basis of venue is Plaintiff'sresidence and Defen t. . Place of Occurrence Plaintiffresides at Ogunty of New York To the above named Defendant(s) YOU ARE HEREBY SUMM answer the complaint in this action to serve a copy of your answer, or, ifthe compla t served with thissummons, to serve a notice of appearance, on the Plaintiff'sAttorn (s) within days after the service of this summons, exclusive of the date of service (or within 30 days after the service is complete ifthissummons isnot personally delivered to you thin the S te of New York); and in case of your failure to appear or answer, g nt be t n against you by default for the reliefdemanded in the co laint. ENNET . GEL RI4AN Dated: Brooklyn, NY April 11, 2003. . Attorney for Plaintiff Office nd 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. 29 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. 03107432 FARRIOR, Defendant. X 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. 29 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 40m Street in the County, and State of New York. City 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. 29 RECEIVED NYSCEF: 12/16/2022 WHEREFORE, plaintiff demands judgment against the defendant in together with the costs and disbursement of this the sum of $1,000,000.00; action. .L Dated: Brooklyn, NY April 11, 2003. ENN H EL MAN Attor ey fo la ti Offi e and P. O Address 26 ourt Street Suite 1401 Brooklyn, NY 11242 (718) 797-3737