Preview
FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023
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SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF KINGS Date Purchased
---------------- ---------------------------x SUMMONS
IRVING J. WELLS, JACOB WELLS and
SHAKEESHA ANN WELLS, Plaintiffs designate Kings County
as the place of trial.
Plaintiffs,
The basis of venue is:
-against- Plaintiffs'
residence
Plaintiffs reside at
BERTINA A. LOUISAIRE and PETER CONDE, 205 Avenue
Albany
Brooklyn, New York 11213
Defendants.
-----------------------------------X
To the above-named Defendants:
You are hereby sun1moned to answer the complaint in this action, and 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 attomeys within twenty days after the service 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.
Dated: Bronx, New York
July 26, 2023
Yours etc.,
NO A S , ESQ.
THE W OF NONNA SHIKH, P.C.
Attomeys or tiffs
400 East For am Road, Suite 202
Bronx, New Y k 10458
(718) 295-4000
DEFENDANTS'
ADDRESSES:
BERTINA A. LOUISAIRE
95*
78-01 Avenue, #1
Queens, NY 11416
PETER CONDE
95*
78-01 Avenue, #1
Queens, NY 11416
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
____________-------------------X
IRVING J. WELLS, JACOB WEIlS and
SHAKEESHA ANN WELLS,
VERIFIED
Plaintiffs, COMPLAINT
-against-
BERTINA A. LOUISAIRE and PETER CONDE,
Defendants.
________________________________..X
Plaintiffs, complaining of the defendant, by their attomeys LAW FIRM OF NONNA
allege·
SHIKH, P.C., respectfully show to this Court and
.
AS FOR THE FIRST CAUSE OF ACTION ON BEHALF OF PLAINTIFF
IRVING J. WELLS
1. At all times herein mentioned, Plaintiff IRVING J. WELLS was, and still is a resident
of the County of Kings, State of New York.
2. At all times herein mentioned, Plaintiff JACOB WELLS was, and still is a resident of
the County of Kings, State of New York.
3. At all times herein mentioned, Plaintiff SHAKEESHA ANN WELLS was, and still
is a resident of the County of Kings, State of New York.
4. At all times herein mentioned, Defendant BERTINA A. LOUISAIRE was, and still
is a resident of the County of Queens, State of New York.
5. At all emes herein mentioned, Defendant PETER CONDE was, and still is a resident
of the County of Queens, State of New York.
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6. At all times herein mentioned, on July 2, 2020, Defendant BERTINA A.
LOUISAIRE owned a 2002 Honda motor vehicle bearing New York State license plate number
HUG6653.
7. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A.
.
LOUISAIRE managed the aforementioned 2002 Honda motor vehicle bearing New York State
license plate number HUG6653.
8. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A.
LOUISAIRE maintained the aforementioned 2002 Honda motor vehicle bearing New York State
license plate number HUG6653.
9. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A.
LOUISAIRE controlled the aforementioned 2002 Honda motor vehicle bearing New York State
license plate number HUG6653.
10. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A.
LOUISAIRE repaired the aforementioned 2002 Honda motor vehicle bearing New York State
license plate number HUG6653.
11. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A.
LOUISAIRE operated the aforementioned 2002 Honda motor vehicle bearing New York State
license plate number HUG6653.
12. That on July 2, 2020, Defendant BERTINA A. LOUISAIRE operated said 2002
Honda motor vehicle New York State license plate number HUG6653 at or about the above-
bearing
mentioned location with the express and implied permission of Defendant PETER CONDE.
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13. At all times herein mentioned, on July 2, 2020, Defendant PETER CONDE owned
a 2002 Honda motor vehicle bearing New York State license plate number HUG6653.
14. At all times herein mentioned, and on July 2, 2020, Defendant PETER CONDE
managed the aforementioned 2002 Honda motor vehicle bearing New York State license plate number
HUG6653.
15. At all times herein mentioned, and on July 2, 2020, Defendant PETER CONDE
maintained the aforementioned 2002 Honda motor vehicle bearing New York State license plate
number HUG6653.
16. At all times herein mentioned, and on July 2, 2020, Defendant PETER CONDE
controlled the aforementioned 2002 Honda motor vehicle bearing New York State license plate
number HUG6653.
17. At all times herein mentioned, and on July 2, 2020, Defendant PETER CONDE
repaired the aforementioned 2002 Honda motor vehicle bearing New York State license plate number
HUG6653.
18. That on July 2, 2020, Plaintiff IRVING J. WELLS was the lawful operator of a 2011
GMC motor vehicle bearing New York State license plate number JBB1398.
19. That on July 2, 2020, Jackie Robinson Expressway at or near its intersection/exit with
Metropolitan Avenue, in the County of Queens, State of New York was a legal public thoroughfare.
20. That on July 2, 2020, the aforesaid motor vehicle owned by Defendant PETER
CONDE and operated and controlled by Defendant BERTINA A. LOUISAIRE came into contact
with the aforesaid motor vehicle operated by the Plaintiff IRVING J. WELLS at the aforementioned
location.
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21. That as a result of the aforesaid collision, Plaintiff IRVING J. WELLS was seriously
injured.
22. That the above-stated occurrence and the results thereof were in no way due to any
negligence on the part of this Plaintiff contributing thereto, but were caused by the joint, several
Defendants'
and/or concurrent negligence of the Defendants and/or said agents, servants, employees
and/or licensees in the ownership, operation, management, maintenance and control of their said
motor vehicle.
23. Defendants were negligent, careless and reckless in the ownership, management,
maintenance, supervision and control of their aforesaid vehicle and Defendants were otherwise
negligent, careless and reckless under the circumstances then and there prevailing.
24. That Plaintiff IRVING J. WELLS sustained serious injuries as defined by §5102(d)
of the Insurance Law of the State of New York and loss greater than basic economic loss as defined
by §5104 of the Insurance Law of the State of New York.
25. That by reason of the foregoing, Plaintiff IRVING J. WELLS was damaged in a sum
which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction.
AS FOR THE SECOND CAUSE OF ACTION ON BEHALF OF PLAINTIFF
JACOB WELLS
26. Plaintiffs reiterate, re-state and re-allege every single allegation made in paragraphs
" 1" "25"
to as if fully and at length set forth herein.
26. That on July 2, 2020, Plaintiff JACOB WELLS was a passenger of the
aforementioned 2002 Honda motor vehicle operated by Plaintiff IRVING J. WELLS bearing New
York State license plate number HUG6653.
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27. That on July 17, 2022, the aforesaid motor vehicle owned by Defendant PETER .
CONDE and operated and controlled by Defendant BERTINA A. LOUISAIRE came into contact
with the aforesaid motor vehicle occupied by Plaintiff JACOB WELLS at the aforementioned
location.
28. That as a result of the aforesaid collision, Plaintiff JACOB WELLS was seriously
injured.
29. That the above-stated occurrence and the results thereof were in no way due to any
negligence on the part of this Plaintiff contributing thereto, but were caused by the joint, several
and/or concurrent negligence of the Defendant and/or said Defendant's agents, servants, employees
and/or licensees in the ownership, operation, management, maintenance and control of their said
motor vehicle.
30. Defendants were negligent, careless and recldess in the ownership, management,
maintenance, supervision and control of their aforesaid vehicle and Defendants were otherwise
negligent, careless and reckless under the circumstances then and there prevailing.
31. That Plaintiff JACOB WELLS sustained serious injuries as defined by §5102(d) of
the Insurance Law of the State of New York and loss greater than basic economic loss as defined by
§5104 of the Insurance Law of the State of New York.
32. That by reason of the foregoing, Plaintiff JACOB WELLS was damaged in a sum
which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction.
AS FOR THE THIRD CAUSE OF ACTION ON BEHALF OF PLAINTIFF
SHAKEESHA ANN WELLS
33. Plaintiffs reiterate, re-state and re-allege every single allegation made in in paragraphs
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"1" "32"
to as if fully and at length set forth herein.
34. That on July 2, 2020, Plaintiff SHAKEESHA ANN WELLS was a passenger of the
aforementioned 2002 Honda motor vehicle operated by Plaintiff IRVING J. WELLS bearing New
York State license plate number HUG6653.
35. That on July 2, 2020, the aforesaid motor vehicle owned by Defendant PETER
CONDE and operated and controlled by Defendant BERTINA A. LOUISAIRE came into contact
with the aforesaid motor vehicle occupied by Plaintiff SHAKEESHA ANN WELLS at the
aforementioned location.
36. That as a result of the aforesaid collision, Plaintiff SHAKEESHA ANN WELLS was
seriously injured.
37. That the above-stated occurrence and the results thereof were in no way due to any
negligence on the part of this Plaintiff contributing thereto, but were caused by the joint, several
Defendants'
and/or concurrent negligence of the Defendants and/or said agents, servants, employees
and/or licensees in the ownership, operation, management, maintenance and control of their said
motor vehicle.
38. Defendants were negligent, careless and reckless in the ownership, management,
maintenance, supervision and control of their aforesaid vehicle and Defendants were otherwise
negligent, careless and recldess under the circumstances then and there prevailing.
39. That Plaintiff SHAKEESHA ANN WELLS sustained serious injuries as defined by
§5102(d) of the Insurance Law of the State of New York and loss greater than basic economic loss as
defined by §5104 of the Insurance Law of the State of New York.
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40. That by reason of the foregoing, Plaintiff SHAKEESHA ANN WELLS was
damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise
have jurisdiction.
WHEREFORE, plaintiffs demand judgment against the defendant in the FIRST, SECOND
and THIRD Causes of action herein, in a sum exceeding the jurisdictional limits of all lower courts
which would otherwise have jurisdiction, together with the costs and disbursements of this action.
Dated: Bronx, New York
July 26, 2023
Yours etc.,
NONN S , ESQ.
THE LAW F OF NONNA SHIKH, P.C.
Attomeys for P tiffs
400 East For Road, Suite 202
Bronx, New Yo 0458
(718) 295-4000
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ATTORNEY'S VERIFICATION
The undersigned, an attorney admitted to practice in the State of New York, affirms:
That the undersigned is associated with THE LAW FIRM OF NONNA SHIKH, P.C., the
attorneys of record for the plaintiffs in the within action; that the undersigned has read the foregoing
and knows the contents thereof; that the same are true to the affirmant's own knowledge, except as
to the matters therein stated to b alleged on information and belief; and as to those matters affirmant
believes them to be true.
The undersigned further states that the reason this affirmation is made by the undersigned and
within where your affirmant
not by our clients is that the plaintiffs are presently not the county
maintains her office.
The grounds of the affirmants belief as to all matters not stated to be upon affirmants
knowledge are as follows:
Materials contained in the office file.
The undersigned affirms that the foregoing statements are true, under penalty of perjury.
Dated: Bronx, New York
July 26, 2023
SHIKH, ESQ.
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
IRVING J. WELLS, JACOB WELLS and SHAKEESHA ANN WEIlS,
Plaintiffs,
-against-
.
BERTINA A. LOUISAIRE and PETER CONDE,
Defendants.
SUMMONS AND VERIFIED COMPLAINT
NONNA SHIKH, ESQ.
THE LAW FIRM OF NONNA SHIKH, P.C.
Attorngs for Plaintifs
400 East Fordham Road, Suite 202
Bronx, New York10458
(718) 295-4000
10 of 10
Preview
FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 . SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF KINGS Date Purchased ---------------- ---------------------------x SUMMONS IRVING J. WELLS, JACOB WELLS and SHAKEESHA ANN WELLS, Plaintiffs designate Kings County as the place of trial. Plaintiffs, The basis of venue is: -against- Plaintiffs' residence Plaintiffs reside at BERTINA A. LOUISAIRE and PETER CONDE, 205 Avenue Albany Brooklyn, New York 11213 Defendants. -----------------------------------X To the above-named Defendants: You are hereby sun1moned to answer the complaint in this action, and 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 attomeys within twenty days after the service 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. Dated: Bronx, New York July 26, 2023 Yours etc., NO A S , ESQ. THE W OF NONNA SHIKH, P.C. Attomeys or tiffs 400 East For am Road, Suite 202 Bronx, New Y k 10458 (718) 295-4000 DEFENDANTS' ADDRESSES: BERTINA A. LOUISAIRE 95* 78-01 Avenue, #1 Queens, NY 11416 PETER CONDE 95* 78-01 Avenue, #1 Queens, NY 11416 1 of 10 FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 . SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ____________-------------------X IRVING J. WELLS, JACOB WEIlS and SHAKEESHA ANN WELLS, VERIFIED Plaintiffs, COMPLAINT -against- BERTINA A. LOUISAIRE and PETER CONDE, Defendants. ________________________________..X Plaintiffs, complaining of the defendant, by their attomeys LAW FIRM OF NONNA allege· SHIKH, P.C., respectfully show to this Court and . AS FOR THE FIRST CAUSE OF ACTION ON BEHALF OF PLAINTIFF IRVING J. WELLS 1. At all times herein mentioned, Plaintiff IRVING J. WELLS was, and still is a resident of the County of Kings, State of New York. 2. At all times herein mentioned, Plaintiff JACOB WELLS was, and still is a resident of the County of Kings, State of New York. 3. At all times herein mentioned, Plaintiff SHAKEESHA ANN WELLS was, and still is a resident of the County of Kings, State of New York. 4. At all times herein mentioned, Defendant BERTINA A. LOUISAIRE was, and still is a resident of the County of Queens, State of New York. 5. At all emes herein mentioned, Defendant PETER CONDE was, and still is a resident of the County of Queens, State of New York. 2 of 10 FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 . 6. At all times herein mentioned, on July 2, 2020, Defendant BERTINA A. LOUISAIRE owned a 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 7. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A. . LOUISAIRE managed the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 8. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A. LOUISAIRE maintained the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 9. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A. LOUISAIRE controlled the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 10. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A. LOUISAIRE repaired the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 11. At all times herein mentioned, and on July 2, 2020, Defendant BERTINA A. LOUISAIRE operated the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 12. That on July 2, 2020, Defendant BERTINA A. LOUISAIRE operated said 2002 Honda motor vehicle New York State license plate number HUG6653 at or about the above- bearing mentioned location with the express and implied permission of Defendant PETER CONDE. 3 of 10 FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 . 13. At all times herein mentioned, on July 2, 2020, Defendant PETER CONDE owned a 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 14. At all times herein mentioned, and on July 2, 2020, Defendant PETER CONDE managed the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 15. At all times herein mentioned, and on July 2, 2020, Defendant PETER CONDE maintained the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 16. At all times herein mentioned, and on July 2, 2020, Defendant PETER CONDE controlled the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 17. At all times herein mentioned, and on July 2, 2020, Defendant PETER CONDE repaired the aforementioned 2002 Honda motor vehicle bearing New York State license plate number HUG6653. 18. That on July 2, 2020, Plaintiff IRVING J. WELLS was the lawful operator of a 2011 GMC motor vehicle bearing New York State license plate number JBB1398. 19. That on July 2, 2020, Jackie Robinson Expressway at or near its intersection/exit with Metropolitan Avenue, in the County of Queens, State of New York was a legal public thoroughfare. 20. That on July 2, 2020, the aforesaid motor vehicle owned by Defendant PETER CONDE and operated and controlled by Defendant BERTINA A. LOUISAIRE came into contact with the aforesaid motor vehicle operated by the Plaintiff IRVING J. WELLS at the aforementioned location. 4 of 10 FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 21. That as a result of the aforesaid collision, Plaintiff IRVING J. WELLS was seriously injured. 22. That the above-stated occurrence and the results thereof were in no way due to any negligence on the part of this Plaintiff contributing thereto, but were caused by the joint, several Defendants' and/or concurrent negligence of the Defendants and/or said agents, servants, employees and/or licensees in the ownership, operation, management, maintenance and control of their said motor vehicle. 23. Defendants were negligent, careless and reckless in the ownership, management, maintenance, supervision and control of their aforesaid vehicle and Defendants were otherwise negligent, careless and reckless under the circumstances then and there prevailing. 24. That Plaintiff IRVING J. WELLS sustained serious injuries as defined by §5102(d) of the Insurance Law of the State of New York and loss greater than basic economic loss as defined by §5104 of the Insurance Law of the State of New York. 25. That by reason of the foregoing, Plaintiff IRVING J. WELLS was damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. AS FOR THE SECOND CAUSE OF ACTION ON BEHALF OF PLAINTIFF JACOB WELLS 26. Plaintiffs reiterate, re-state and re-allege every single allegation made in paragraphs " 1" "25" to as if fully and at length set forth herein. 26. That on July 2, 2020, Plaintiff JACOB WELLS was a passenger of the aforementioned 2002 Honda motor vehicle operated by Plaintiff IRVING J. WELLS bearing New York State license plate number HUG6653. 5 of 10 FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 27. That on July 17, 2022, the aforesaid motor vehicle owned by Defendant PETER . CONDE and operated and controlled by Defendant BERTINA A. LOUISAIRE came into contact with the aforesaid motor vehicle occupied by Plaintiff JACOB WELLS at the aforementioned location. 28. That as a result of the aforesaid collision, Plaintiff JACOB WELLS was seriously injured. 29. That the above-stated occurrence and the results thereof were in no way due to any negligence on the part of this Plaintiff contributing thereto, but were caused by the joint, several and/or concurrent negligence of the Defendant and/or said Defendant's agents, servants, employees and/or licensees in the ownership, operation, management, maintenance and control of their said motor vehicle. 30. Defendants were negligent, careless and recldess in the ownership, management, maintenance, supervision and control of their aforesaid vehicle and Defendants were otherwise negligent, careless and reckless under the circumstances then and there prevailing. 31. That Plaintiff JACOB WELLS sustained serious injuries as defined by §5102(d) of the Insurance Law of the State of New York and loss greater than basic economic loss as defined by §5104 of the Insurance Law of the State of New York. 32. That by reason of the foregoing, Plaintiff JACOB WELLS was damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. AS FOR THE THIRD CAUSE OF ACTION ON BEHALF OF PLAINTIFF SHAKEESHA ANN WELLS 33. Plaintiffs reiterate, re-state and re-allege every single allegation made in in paragraphs 6 of 10 FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 "1" "32" to as if fully and at length set forth herein. 34. That on July 2, 2020, Plaintiff SHAKEESHA ANN WELLS was a passenger of the aforementioned 2002 Honda motor vehicle operated by Plaintiff IRVING J. WELLS bearing New York State license plate number HUG6653. 35. That on July 2, 2020, the aforesaid motor vehicle owned by Defendant PETER CONDE and operated and controlled by Defendant BERTINA A. LOUISAIRE came into contact with the aforesaid motor vehicle occupied by Plaintiff SHAKEESHA ANN WELLS at the aforementioned location. 36. That as a result of the aforesaid collision, Plaintiff SHAKEESHA ANN WELLS was seriously injured. 37. That the above-stated occurrence and the results thereof were in no way due to any negligence on the part of this Plaintiff contributing thereto, but were caused by the joint, several Defendants' and/or concurrent negligence of the Defendants and/or said agents, servants, employees and/or licensees in the ownership, operation, management, maintenance and control of their said motor vehicle. 38. Defendants were negligent, careless and reckless in the ownership, management, maintenance, supervision and control of their aforesaid vehicle and Defendants were otherwise negligent, careless and recldess under the circumstances then and there prevailing. 39. That Plaintiff SHAKEESHA ANN WELLS sustained serious injuries as defined by §5102(d) of the Insurance Law of the State of New York and loss greater than basic economic loss as defined by §5104 of the Insurance Law of the State of New York. 7 of 10 FILED: KINGS COUNTY CLERK . 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 40. That by reason of the foregoing, Plaintiff SHAKEESHA ANN WELLS was damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. WHEREFORE, plaintiffs demand judgment against the defendant in the FIRST, SECOND and THIRD Causes of action herein, in a sum exceeding the jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with the costs and disbursements of this action. Dated: Bronx, New York July 26, 2023 Yours etc., NONN S , ESQ. THE LAW F OF NONNA SHIKH, P.C. Attomeys for P tiffs 400 East For Road, Suite 202 Bronx, New Yo 0458 (718) 295-4000 8 of 10 FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 ATTORNEY'S VERIFICATION The undersigned, an attorney admitted to practice in the State of New York, affirms: That the undersigned is associated with THE LAW FIRM OF NONNA SHIKH, P.C., the attorneys of record for the plaintiffs in the within action; that the undersigned has read the foregoing and knows the contents thereof; that the same are true to the affirmant's own knowledge, except as to the matters therein stated to b alleged on information and belief; and as to those matters affirmant believes them to be true. The undersigned further states that the reason this affirmation is made by the undersigned and within where your affirmant not by our clients is that the plaintiffs are presently not the county maintains her office. The grounds of the affirmants belief as to all matters not stated to be upon affirmants knowledge are as follows: Materials contained in the office file. The undersigned affirms that the foregoing statements are true, under penalty of perjury. Dated: Bronx, New York July 26, 2023 SHIKH, ESQ. 9 of 10 FILED: KINGS COUNTY CLERK 07/26/2023 04:35 PM INDEX NO. 521560/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS IRVING J. WELLS, JACOB WELLS and SHAKEESHA ANN WEIlS, Plaintiffs, -against- . BERTINA A. LOUISAIRE and PETER CONDE, Defendants. SUMMONS AND VERIFIED COMPLAINT NONNA SHIKH, ESQ. THE LAW FIRM OF NONNA SHIKH, P.C. Attorngs for Plaintifs 400 East Fordham Road, Suite 202 Bronx, New York10458 (718) 295-4000 10 of 10