Preview
FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No.
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NATALIA §pummong
HENRY,
Plaintiff,
Plaintiff designates KINGS
against County as the place of trial.
THE NEW YORK CITY TRANSIT AUTHORITY, MTA, Basis of Venue:
THE MTA BUS COMAPNY and SAMUEL SARDHAN, C. P. L. R. 505(a)
Defendants.
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To the above named Defendant(s)
ott Art IJBT2bP sttmmotteb to answer the complaint in this action, 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 attomey(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 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: New York, New York
November 29, 2023
Harmon, Linder & Rogowsky, Esqs.
Attorneys for Plaintiff(s)
3 Park Avenue, Suite 2300
New York, NY 10016
The New York City Transit Authority
130 Livingston Street, Eleventh Floor
Brooklyn, NY 11201
MTA
347 Madison Avenue
New York, NY 10017
The MTA Bus Company
2 Broadway
New York, NY 10004
Samuel Sardhan
249-15 Mayda Road
Rosedale, NY 11422
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_______________________________________________________________Ç
NATALIA HENRY,
Plaintiff, VERIFIED COMPLAINT
-against-
Index No.:
THE NEW YORK CITY TRANSIT AUTHORITY,
MTA, THE MTA BUS COMAPNY and SAMUEL
SARDHAN,
Defendants.
_____________________________________________Ç
Plaintiff NATALIA HENRY, complaining of the defendants herein by her attorneys,
HARMON, LINDER and ROGOWSKY, ESQS., respectfully sets forth and allege, as follows:
AS AND FOR A FIRST CAUSE OF ACTION
ON BEHALF OF PLAINTIFF NATALIA HENRY,
1. The basis for venue is that the accident herein complained of occurred within the County
of KINGS, City and State of New York.
2. Upon information and belief, that at all times herein mentioned defendant, THE NEW
YORK CITY TRANSIT AUTHORITY was and still is a municipal corporation
organized and existing under and by virtue of the laws of the State of New York.
3. That at all times herein mentioned, the plaintiff duly served a Notice of Claim and
Intention to sue thereupon on the defendant, THE NEW YORK CITY TRANSIT
AUTHORITY, within the time prescribed by law.
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4. That defendant, THE NEW YORK CITY TRANSIT AUTHORITY, has neglected and refused
to make an adjustment in payment thereof within more than thirty (30) days after service of said
Notice of Claim and Intention to Sue.
5. Upon information and belief, that at all times herein mentioned defendant, MTA was and
still is a municipal corporation organized and existing under and by virtue of the laws of
the State of New York.
6. That at all times herein mentioned, the plaintiff duly served a Notice of Claim and
Intention to sue thereupon on the defendant, MTA, within the time prescribed by law.
7. That defendant, MTA, has neglected and refused to make an adjustment in payment
thereof within more than thirty (30) days after service of said Notice of Claim and
Intention to Sue.
8. Upon information and belief, that at all times herein mentioned defendant, THE MTA
BUS COMPANY, was and still is a municipal corporation organized and existing under
and by virtue of the laws of the State of New York.
9. That at all times herein mentioned, the plaintiff duly served a Notice of Claim and
Intention to sue thereupon on the defendant, THE MTA BUS COMPANY, within the
time prescribed by law.
10. That defendant, THE MTA BUS COMPANY, has neglected and refused to make an
adjustment in payment thereof within more than thirty (30) days after service of said
Notice of Claim and Intention to Sue.
11. That the plaintiff has duly complied with all statutes and laws applicable to the
defendants, precedent to the making of this claim and bringing this action.
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12. Upon information and belief, that at all times herein mentioned, defendant THE NEW
YORK CITY TRANSIT AUTHORITY, was the owner of a vehicle bearing registration
number AV8223, New York.
13. Upon information and belief, that at all times herein mentioned, defendant MABSTOA,
was the owner of a vehicle bearing registration number AV8223, New York.
14. Upon information and belief, that at all times herein mentioned, defendant MTA, was
the owner of a vehicle bearing registration number AV8223, New York.
15. Upon information and belief, that at all times herein mentioned, defendant THE MTA
BUS COMPANY, was the owner of a vehicle bearing registration number AV8223, New
York. Upon information and belief, that at all times herein mentioned, defendant
SAMUEL SARDHAN, was an employee of defendant, THE NEW YORK CITY
TRANSIT AUTHORITY.
16. Upon information and belief, that at all times herein mentioned, defendant SAMUEL
SARDHAN, was an employee of defendant, MTA.
17. Upon information and belief, that at all times herein mentioned, defendant SAMUEL
SARDHAN, was an employee of defendant, THE MTA BUS COMPANY.
18. Upon information and belief, that at all times herein mentioned, defendant SAMUEL
SARDHAN, was acting within the scope of his employment with THE NEW YORK
CITY TRANSIT AUTHORITY.
19. Upon information and belief, that at all times herein mentioned, defendant SAMUEL
SARDHAN, was acting within the scope of his employment with MTA.
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20. Upon information and belief, that at all times herein mentioned, defendant SAMUEL
SARDHAN, was acting within the scope of his employment with THE MTA BUS
COMPANY.
21. Upon information and belief, that at all times herein mentioned, defendant SAMUEL
SARDHAN, was the operator of vehicle bearing number AV8223, New York.
22. Upon information and belief, that at all times herein mentioned, defendant, SAMUEL
SARDHAN, was in physical charge, operation, management and control of the aforesaid
motor vehicle owned by defendant THE NEW YORK CITY TRANSIT AUTHORITY,
with the knowledge, consent and permission, whether express or implied, of the
defendant owner thereof.
23. Upon information and belief, that at all times herein mentioned, defendant, SAMUEL
SARDHAN, was in physical charge, operation, management and control of the aforesaid
motor vehicle owned by defendant MTA, with the knowledge, consent and permission,
whether express or implied, of the defendant owner thereof.
24. Upon information and belief, that at all times herein mentioned, defendant, SAMUEL
SARDHAN, was in physical charge, operation, management and control of the aforesaid
motor vehicle owned by defendant THE MTA BUS COMPANY, with the knowledge,
consent and permission, whether express or implied, of the defendant owner thereof.
25. That at all times herein mentioned, Plaintiff, NATALIA HENRY, was the owner and
operator of a motor vehicle bearing number KPM2165, New York.
26. That on the OCTOBER 21, 2022 at approximately 6:15 P.M., the aforesaid vehicle came
into contact with plaintiff's vehicle on BUSHWICK AVENUE at or near the intersection
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with DEKALB AVENUE, a public street and thoroughfare, in the County of KINGS,
City and State of New York.
27. That defendant so carelessly and negligently operated the aforesaid vehicle so as to cause
the aforesaid contact.
28. That as a result of the foregoing, this plaintiff was caused to and did sustain severe and
serious personal injuries and was required to seek and obtain medical care and attention
in an effort to cure and/or alleviate the same and upon information and belief, will be so
compelled to do in future.
29. That the aforesaid occurrence and injuries sustained by this plaintiff were caused by the
negligence of the defendant and not by any act or omission on the part of this plaintiff
contributing thereto.
30. That this plaintiff has sustained a serious injury as the same is defined in Subdivision (d)
of Section 5102 of the Insurance Law of the State of New York.
31. That this action falls within one or more of the exceptions set forth in section 1602 of the
CPLR.
32. That by reason of the foregoing, plaintiff has been damaged in an amount that exceeds
the jurisdictional limits of all lower courts that otherwise have jurisdiction.
AS AND FOR A SECOND CAUSE OF ACTION
ON BEHALF OF PLAINTIFF NATALIA HENRY
33. This plaintiff repeats, reiterates and realleges each and every allegation contained in
"1" "32"
paragraphs of this complaint numbered through inclusive, with the same force
and effect as though the same were more fully set forth at length herein.
34. That defendant so carelessly and negligently operated their aforesaid respective motor
vehicle so as to cause the aforesaid contact.
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35. That as a result of the foregoing, this plaintiffs aforesaid vehicle was caused to and did
sustain property damage and this plaintiff was required to seek and obtain mechanical
attention in an effort to repair the damages.
36. That the aforesaid occurrence and property damage sustained by this plaintiffs vehicle
was caused wholly and solely by the negligence of the defendants and not by any act or
omission on the part of this plaintiff contributing there to.
37. That by reason of the foregoing, plaintiff has been damaged in an amount that exceeds
the jurisdictional limits of all lower courts that otherwise have jurisdiction.
WHEREFORE, plaintiff NATALIA HENRY, demands judgment against the Defendants
in the First and Second Cause of Actions 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
November 29, 2023
HARMON, LINDER & ROGOWSKY
Attorneys for Plaintiff
3 Park Avenue Suite 2300
New York, NY 10016
Phone (212) 732-3665
Fax (212) 732-1462
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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 attorney(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 is because said plaintiff
resides outside of the county from where your deponent maintains his office for the practice of
law.
Dated: New York, New York
November 29, 2023
Mark J. Linder, Esq.
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Index No. Year
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_____________________________________________________________________________________
NATALIA HENRY,
Plaintiff,
-against-
THE NEW YORK CITY TRANSIT AUTHORITY, MTA, THE MTA BUS COMAPNY and
SAMUEL SARDHAN,
Defendants.
_____________________________________________________________________
SUMMONS AND VERIFIED COMPLAINT
___________________________________________________________________________________
HARMON, LINDER & ROGOSWKY, ESQS.
Attorney for Plaintiff(s)
3 Park Avenue, 23rd Floor
Suite 2300
New York, NY 10016
(212) 732-3665 Phone
(212) 732-1462 Facsimile
___________________________________________________________________________
To:
Attomey(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 that the within is a (certified) true copy of a
entered in the office of the clerk of the within named Court on
O Notice of Settlement
that an order of which the within is a true copy will be presented for settlement to the
Hon. , one of the judges of the within named Court, at ,
on
Dated:
Yours, etc.
Harmon, Linder & Rogowsky, Esqs.
Attorneys for Plaintiff
3 Park Avenue, Suite 2300
New York, NY 10016
(212) 732-3665
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Preview
FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No. --------------------------------------------------------------------X NATALIA §pummong HENRY, Plaintiff, Plaintiff designates KINGS against County as the place of trial. THE NEW YORK CITY TRANSIT AUTHORITY, MTA, Basis of Venue: THE MTA BUS COMAPNY and SAMUEL SARDHAN, C. P. L. R. 505(a) Defendants. ---------------------------------------------------------------------X To the above named Defendant(s) ott Art IJBT2bP sttmmotteb to answer the complaint in this action, 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 attomey(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 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: New York, New York November 29, 2023 Harmon, Linder & Rogowsky, Esqs. Attorneys for Plaintiff(s) 3 Park Avenue, Suite 2300 New York, NY 10016 The New York City Transit Authority 130 Livingston Street, Eleventh Floor Brooklyn, NY 11201 MTA 347 Madison Avenue New York, NY 10017 The MTA Bus Company 2 Broadway New York, NY 10004 Samuel Sardhan 249-15 Mayda Road Rosedale, NY 11422 1 of 9 FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS _______________________________________________________________Ç NATALIA HENRY, Plaintiff, VERIFIED COMPLAINT -against- Index No.: THE NEW YORK CITY TRANSIT AUTHORITY, MTA, THE MTA BUS COMAPNY and SAMUEL SARDHAN, Defendants. _____________________________________________Ç Plaintiff NATALIA HENRY, complaining of the defendants herein by her attorneys, HARMON, LINDER and ROGOWSKY, ESQS., respectfully sets forth and allege, as follows: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF PLAINTIFF NATALIA HENRY, 1. The basis for venue is that the accident herein complained of occurred within the County of KINGS, City and State of New York. 2. Upon information and belief, that at all times herein mentioned defendant, THE NEW YORK CITY TRANSIT AUTHORITY was and still is a municipal corporation organized and existing under and by virtue of the laws of the State of New York. 3. That at all times herein mentioned, the plaintiff duly served a Notice of Claim and Intention to sue thereupon on the defendant, THE NEW YORK CITY TRANSIT AUTHORITY, within the time prescribed by law. 2 of 9 FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 4. That defendant, THE NEW YORK CITY TRANSIT AUTHORITY, has neglected and refused to make an adjustment in payment thereof within more than thirty (30) days after service of said Notice of Claim and Intention to Sue. 5. Upon information and belief, that at all times herein mentioned defendant, MTA was and still is a municipal corporation organized and existing under and by virtue of the laws of the State of New York. 6. That at all times herein mentioned, the plaintiff duly served a Notice of Claim and Intention to sue thereupon on the defendant, MTA, within the time prescribed by law. 7. That defendant, MTA, has neglected and refused to make an adjustment in payment thereof within more than thirty (30) days after service of said Notice of Claim and Intention to Sue. 8. Upon information and belief, that at all times herein mentioned defendant, THE MTA BUS COMPANY, was and still is a municipal corporation organized and existing under and by virtue of the laws of the State of New York. 9. That at all times herein mentioned, the plaintiff duly served a Notice of Claim and Intention to sue thereupon on the defendant, THE MTA BUS COMPANY, within the time prescribed by law. 10. That defendant, THE MTA BUS COMPANY, has neglected and refused to make an adjustment in payment thereof within more than thirty (30) days after service of said Notice of Claim and Intention to Sue. 11. That the plaintiff has duly complied with all statutes and laws applicable to the defendants, precedent to the making of this claim and bringing this action. 3 of 9 FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 12. Upon information and belief, that at all times herein mentioned, defendant THE NEW YORK CITY TRANSIT AUTHORITY, was the owner of a vehicle bearing registration number AV8223, New York. 13. Upon information and belief, that at all times herein mentioned, defendant MABSTOA, was the owner of a vehicle bearing registration number AV8223, New York. 14. Upon information and belief, that at all times herein mentioned, defendant MTA, was the owner of a vehicle bearing registration number AV8223, New York. 15. Upon information and belief, that at all times herein mentioned, defendant THE MTA BUS COMPANY, was the owner of a vehicle bearing registration number AV8223, New York. Upon information and belief, that at all times herein mentioned, defendant SAMUEL SARDHAN, was an employee of defendant, THE NEW YORK CITY TRANSIT AUTHORITY. 16. Upon information and belief, that at all times herein mentioned, defendant SAMUEL SARDHAN, was an employee of defendant, MTA. 17. Upon information and belief, that at all times herein mentioned, defendant SAMUEL SARDHAN, was an employee of defendant, THE MTA BUS COMPANY. 18. Upon information and belief, that at all times herein mentioned, defendant SAMUEL SARDHAN, was acting within the scope of his employment with THE NEW YORK CITY TRANSIT AUTHORITY. 19. Upon information and belief, that at all times herein mentioned, defendant SAMUEL SARDHAN, was acting within the scope of his employment with MTA. 4 of 9 FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 20. Upon information and belief, that at all times herein mentioned, defendant SAMUEL SARDHAN, was acting within the scope of his employment with THE MTA BUS COMPANY. 21. Upon information and belief, that at all times herein mentioned, defendant SAMUEL SARDHAN, was the operator of vehicle bearing number AV8223, New York. 22. Upon information and belief, that at all times herein mentioned, defendant, SAMUEL SARDHAN, was in physical charge, operation, management and control of the aforesaid motor vehicle owned by defendant THE NEW YORK CITY TRANSIT AUTHORITY, with the knowledge, consent and permission, whether express or implied, of the defendant owner thereof. 23. Upon information and belief, that at all times herein mentioned, defendant, SAMUEL SARDHAN, was in physical charge, operation, management and control of the aforesaid motor vehicle owned by defendant MTA, with the knowledge, consent and permission, whether express or implied, of the defendant owner thereof. 24. Upon information and belief, that at all times herein mentioned, defendant, SAMUEL SARDHAN, was in physical charge, operation, management and control of the aforesaid motor vehicle owned by defendant THE MTA BUS COMPANY, with the knowledge, consent and permission, whether express or implied, of the defendant owner thereof. 25. That at all times herein mentioned, Plaintiff, NATALIA HENRY, was the owner and operator of a motor vehicle bearing number KPM2165, New York. 26. That on the OCTOBER 21, 2022 at approximately 6:15 P.M., the aforesaid vehicle came into contact with plaintiff's vehicle on BUSHWICK AVENUE at or near the intersection 5 of 9 FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 with DEKALB AVENUE, a public street and thoroughfare, in the County of KINGS, City and State of New York. 27. That defendant so carelessly and negligently operated the aforesaid vehicle so as to cause the aforesaid contact. 28. That as a result of the foregoing, this plaintiff was caused to and did sustain severe and serious personal injuries and was required to seek and obtain medical care and attention in an effort to cure and/or alleviate the same and upon information and belief, will be so compelled to do in future. 29. That the aforesaid occurrence and injuries sustained by this plaintiff were caused by the negligence of the defendant and not by any act or omission on the part of this plaintiff contributing thereto. 30. That this plaintiff has sustained a serious injury as the same is defined in Subdivision (d) of Section 5102 of the Insurance Law of the State of New York. 31. That this action falls within one or more of the exceptions set forth in section 1602 of the CPLR. 32. That by reason of the foregoing, plaintiff has been damaged in an amount that exceeds the jurisdictional limits of all lower courts that otherwise have jurisdiction. AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF PLAINTIFF NATALIA HENRY 33. This plaintiff repeats, reiterates and realleges each and every allegation contained in "1" "32" paragraphs of this complaint numbered through inclusive, with the same force and effect as though the same were more fully set forth at length herein. 34. That defendant so carelessly and negligently operated their aforesaid respective motor vehicle so as to cause the aforesaid contact. 6 of 9 FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 35. That as a result of the foregoing, this plaintiffs aforesaid vehicle was caused to and did sustain property damage and this plaintiff was required to seek and obtain mechanical attention in an effort to repair the damages. 36. That the aforesaid occurrence and property damage sustained by this plaintiffs vehicle was caused wholly and solely by the negligence of the defendants and not by any act or omission on the part of this plaintiff contributing there to. 37. That by reason of the foregoing, plaintiff has been damaged in an amount that exceeds the jurisdictional limits of all lower courts that otherwise have jurisdiction. WHEREFORE, plaintiff NATALIA HENRY, demands judgment against the Defendants in the First and Second Cause of Actions 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 November 29, 2023 HARMON, LINDER & ROGOWSKY Attorneys for Plaintiff 3 Park Avenue Suite 2300 New York, NY 10016 Phone (212) 732-3665 Fax (212) 732-1462 7 of 9 FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 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 attorney(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 is because said plaintiff resides outside of the county from where your deponent maintains his office for the practice of law. Dated: New York, New York November 29, 2023 Mark J. Linder, Esq. 8 of 9 FILED: KINGS COUNTY CLERK 11/29/2023 05:34 PM INDEX NO. 534935/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/29/2023 Index No. Year SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS _____________________________________________________________________________________ NATALIA HENRY, Plaintiff, -against- THE NEW YORK CITY TRANSIT AUTHORITY, MTA, THE MTA BUS COMAPNY and SAMUEL SARDHAN, Defendants. _____________________________________________________________________ SUMMONS AND VERIFIED COMPLAINT ___________________________________________________________________________________ HARMON, LINDER & ROGOSWKY, ESQS. Attorney for Plaintiff(s) 3 Park Avenue, 23rd Floor Suite 2300 New York, NY 10016 (212) 732-3665 Phone (212) 732-1462 Facsimile ___________________________________________________________________________ To: Attomey(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 that the within is a (certified) true copy of a entered in the office of the clerk of the within named Court on O Notice of Settlement that an order of which the within is a true copy will be presented for settlement to the Hon. , one of the judges of the within named Court, at , on Dated: Yours, etc. Harmon, Linder & Rogowsky, Esqs. Attorneys for Plaintiff 3 Park Avenue, Suite 2300 New York, NY 10016 (212) 732-3665 9 of 9