Preview
FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/18/2024
"C"
Exhibit
FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023
NYSCEF DOC. NO. 11 RECEIVED
INDEX NYSCEF:
NO. 01/18/2024
716946/2023
EŠLED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 Pl!
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 12/13/2023
A
ABRAMS
LAW GROUP
December 13, 2023
VIA USPS CERTIFIED MAIL - RRR
USPS FIRST CLASS MAIL
Dhaneshwar Balkaran
108-52 Liverpool Street
Jamaica, NY 11435
RE: Mukhamedov v. Balkaran - Supreme Queens - Index No.: 716946/2023
To the above named party:
A review of my file indicates that you were served with a Summons and Complaint in connection
with the above action. Your time to answer said Summons and Complaint has now expired and up
to this date, we have received no Answer on your behalf.
I am enclosing a copy of that Summons and Complaint which was served upon you and I strongly
suggest that you retain the services of an attorney to interpose an answer on your behalf.
Your failure to answer, will make you responsible for a default judgment which I can now move
for in Court. I certainly hope your actions will make this unnecessary. I thank you for your
anticipated cooperation.
Very truly yours,
ABRA AW GR P, P.C.
BY: MELANIE ABRAMS, ESQ.
Enc.
cc: All counsel via NYSCEF
104-70 Queens Boulevard, Suite 502 " Forest Hills,NY 11375
Telephone(718)997-9797
Facsimile (718)997-9796
E-mail:abramslawgroup@gmail.com
1 of 10
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NYSCEF:
NO.
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7 1 694 6 2 02 3
FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 /
6 PM
NYSCF;F D0F No 4 RECEI CE 23
FILED QUEENS COUNTY CLERK 08 / 15 / 2023 05 : 07 P
NYSCEF ICC. NO. 1 RECEIVED NYSCEF: 08/1(/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
MARCEL MUKHAMEDOV,
Plaintiff, SUMMONS
-against-
Index No:
DHANESHWAR BALKARAN,
Defendant.
TO THE ABOVE-NAMED DEFENDANT:
YOU ARE HEREBY SUMMONED 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 Attorney within 20 days after the service complete if this Summons,
exclusive of the day of service (or within 30 days after the service is complete if this Summons is
not personally delivered to you within the State of New York) and proper.
PLEASE TAKE NOTICE that the law provides: (a) If this Summons is served by its delivery to
you personally within the State of New York, you must appear and answer within twenty (20) days
after such service; or (b) If this Summons is served by delivery to any person other than you
personally, or is served outside the State of New York, or by publication, or by any means other
than personal delivery to you within the State of New York, you are allowed thirty (30) days after
proof of service thereof is filed with the Clerk of the Court within which to appear and answer.
Plaintiff designates Queens County as the place of trial for this action. The basis of venue is NY
CPLR §503.
Dated: Forest Hills, New York
August 9, 2023
Yours, etc.,
ABRA LA GROUP, P.C.
BY: M LANIE ABRAMS, ESQ.
Attorneys for Plaintiff
104-70 Queens Blvd., Suite 502
Forest Hills, NY 11375
Tel: (718) 997-9797
TO: PLEASE SEE ATTACHED RIDER.
ABRAMS LAW GROUP, P.C.
1 of 8
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NYSCEF:
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01/18/2024
716946/2023
FILED : (.UEENS COUNTY CLERK 12 /13/2023 02:0 6 Pl
RECE .C 023
No
IL D: ÇÙEENS COUNTY CLERK 08/15/2023 05:07 PMl
NYSCEF Dri:. NO. 1 RECEIVED NYSCEF: 08/16.2023
SERVICE RIDER
DEFENDANT SERVE AT
DHANESHWAR BALKARAN 108-52 LIVERPOOL STREET
JAMAICA, NY 11435
ABRAMS LAW GROUP, P.C.
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NYSCEF:
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716946/2023
FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 PNj
NYS FF DDr No 4 RECEIVED N E 023
FILED QUEENS COUNTY CLERK NDEX 6
08 /15/2023 05 : 07 PM|
NYSCEF I(C. NO. 1 RECEIVED NYSCEF: 08/1(/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
MARCEL MUKHAMEDOV,
Plaintiff,
-against- COMPLAINT
DHANESHWAR BALKARAN, Index No:
Defendant.
Plaintiff, Marcel Mukhamedov, ("Plaintiff") by and through attorneys, ABRAMS LAW
GROUP, P.C., complaining of the Defendant, Dhaneshwar Balkaran, ("Defendant"), as and for
the instant Complaint, respectfully alleges, upon information and belief:
1. That Plaintiff, at all times herein mentioned, was and still is a resident of the
County of Queens, in the State ofNew York, and as such, is subject to this Honorable Court.
2. That Defendant, at all times herein mentioned, was and still is a resident of the
County of Queens, in the State of New York, and as such, is subject to this Honorable Court.
AS AND FOR A FIRST CAUSE OF ACTION
(NEGLIGENCE)
3. That on or about August 11, 2021, Defendant was an owner of a certain 2001 Dodge
motor vehicle bearing license plate number JHN4968, as issued by the State of New York ("the
Dodge vehicle").
4. That on or about August 11, 2021, Defendant was the titled owner of the Dodge
vehicle.
ABRAMS LAW GROUP, P.C.
3 of 8
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NYSCEF:
NO.
01/18/2024
71694 6 /2023
FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 PlÈ
NYSCEF DOC NO 4 RECEIVED NYSCE 023
|FILED QUEENS COUNTY CLERK INDEX NO. 16
08 /15/2023 05 : 07 PM|
NYSCEF LCC. NO. 1 RECEIVED NYSCEF: 08/1(/2023
5. That on or about August 11, 2021, Defendant was the registered owner ofthe Dodge
vehicle.
6. That on or about August 11, 2021, Defendant was an operator of the Dodge vehicle
7. That on or about August 11, 2021, Defendant was the lessee of the Dodge vehicle.
8. That on or about August 11, 2021, Defendant was the lessor of the Dodge vehicle.
9. That on or about August 11, 2021, Defendant maintained the Dodge vehicle.
10. That on or about August 11, 2021, Defendant controlled the Dodge vehicle.
11. That on or about August 11, 2021, Defendant owned, operated, maintained, and
controlled the Dodge vehicle.
12. That at all times herein mentioned, the roadway at or in front of the intersection of
101st Avenue and Van Wyck Expressway, in Queens County, New York (the "accident situs"),
was and still remains a roadway used extensively by the public in general.
13. That on August 11, 2021, Plaintiff was a lawful bicyclist at the accident situs.
14. That on August 11, 2021, the Dodge vehicle came into contact with the Plaintiff
bicyclist, at the accident situs.
15. That the subject accident and injuries resulting therefrom, were due solely and
wholly as the result of the careless and negligent manner in which Defendant owned, operated,
maintained and/or controlled the Dodge vehicle, without Plaintiff contributing in any way thereto.
16. That by reason of the foregoing and the negligence of the Defendant, Plaintiff was
severely injured, bruised and wounded, suffered, still suffers, and will continue to suffer for some
time, physical pain and bodily injuries and became sick, sore, lame, and disabled and so remained
for a considerable length of time.
ABRAMS LAW GROUP, P.C.
4 of 8
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NYSCEF DOC. NO. 11 RECEIVED
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NYSCEF:
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01/18/2024
71694 6/2023
EŠLED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 PM1
NYS RF DOF NO 4 RECE CE 023
FILED QUEENS COUNTY CLERK 08 /15 / 2023 05 : 07 PM
NYSCEF ECC. NO. 1 RECEIVED NYSCEF: 08/10/2023
17. That by reason of the foregoing, Plaintiff was compelled to and did necessarily
require medical aid and attention and did necessarily pay and become liable therefor for medicines
and upon information and belief, Plaintiff will necessarily incur similar expenses.
18. That by reason of the foregoing, Plaintiff has been unable to attend to their usual
occupation in the manner required.
19. That by reason of the wrongful, negligent, and unlawful actions of the Defendant,
as aforesaid, Plaintiff sustained serious injuries as defined in Section 5102(d) of the Insurance Law
of the State ofNew York. Plaintiff has further sustained economic loss greater than basic economic
loss as defined in Section 5102 of the said Insurance Law.
20. That one or more of the provisions of §l602 of the Civil Practice Law and Rules
do apply to the within action.
21. That by reason of the foregoing, Plaintiff was damaged in an amount exceeding
seventy-five thousand dollars.
22. That by reason of the foregoing, Plaintiff was damaged in an amount which exceeds
the monetary jurisdictional limits of any and all lower Courts which would otherwise have
jurisdiction herein, in an amount to be determined upon trial of this action.
23. The Plaintiff reserves the rights to amend/supplement the instant Complaint up to and
including through the time of trial.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff demands that the following judgment in Plaintiff's favor, for
Plaintiff's First Cause of Action, awarding damages against Defendant, for an amount which
exceeds the jurisdictional limits of all other Courts which would otherwise have jurisdiction herein,
ABRAMS LAW GROUP, P.C.
5 of 8
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FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023
NYSCEF DOC. NO. 11 RECEIVED
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NYSCEF:
NO.
01/18/2024
716946/2023
FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 PM|
NY.SPEF Don NO 4 RECE CE : / / 023
|FILED QUEENS COUNTY CLERK 08/15/2023 05 : 07 PM
NYSCEF I t C. NO. 1 RECEIVED NYSCEF: 08/1E /2023
in an amount to be determined upon trial of this action, together with costs and disbursements of
this action, and with interest from the date of the accident.
Dated: Forest Hills, New York
August 9, 2023
Yours, etc.,
ABRAMS GROUP, P.C.
BY: MEL EABRAMS, ESQ.
Attorneys for Plaintiff
MARCEL MUKHAMEDOV
104-70 Queens Blvd., Suite 502
Forest Hills, NY 11375
Tel: (718)997-9797
ABRAMS LAW GROUP, P.C.
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NO.
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71694 6/2023
ETLED : ()UEENS COUNTY CLERK 12/13/2023 02 : 0 6 PM
NYSCEF DOC NO. 4 RECEIVED NYSCE : 3/ 023
INDEX NO. 6
|FILED : QUEENS COUNTY CLERK 08 /15/2023 05 : 07 PM|
NYSCEF 90C. NO. 1 RECEIVED NYSCEF: 08/1(/2023
INDIVIDUAL VERIFICATION
STATE OF NEW YORK )
) SS:
COUNTY OF QUEENS )
Marcel Mukhamedov duly sworn, deposes and says:
Deponent is the Plaintiff in the within action.
Deponent has read the foregoing:
COMPLAINT
and knows the contents thereof.
The same is true to deponent knowledge eXcept as matters therein stated to be alleged and
that as to those matters, Deponent believes them to be true.
Makel Mukhamedov
Sworn to before me on
August 9, 2023
i
NotaryPublic, State of NewYork
No.01Ai36340740
Qualified in Queens County
Commission Expires April 25, 20.?ck.
ABRAMS LAW GROUP, P.C.
7 of 8
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NYSCEF:
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FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 71694 6 /2023
PM|
NYSCEF DOC NO 4 RECEIVED NYSCE : 91 / 023
|FILED QUEENS COUNTY CLERK 08/15/2023 INDEX NO. 6
05 : 07 Pl!
NYSCEF T t C. NO. 1 " RECEIVED NYSCEF: 08/1E /2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index No.: __
MARCEL MUKHAMEDOV,
Plaintiff,
-against-
. .
DHANESHWAR BALKARAN,
Defendant.
SUMMONS and VERIFIED COMPLAINT
ABRAMS LAW GROUP, P.C.
By: MELANIE ABRAMS, ESQ.
Attorneys for Plaintiff
MARCEL MUKHAMEDOV
104-70 Queens Boulevard, Suite 502
Forest Hills, NY 11375
Tel: (718) 997-9797
Pursuant to 22NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the
courts of the State of New York, certifies, that, upon information and belief and reasonable
inquiry, the contentions contained in the annexed document are not frivolous.
MELANIE ABRAMS, ESQ.
ABRAMS LAW GROUP, P.C.
8 of 8
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3 3/2023
2
0
2
/
6
4 1
7169
Addressee
Delivery Restricted
Postmark Confirmation" Receipt
NO. 54§2 HBfe Agent Expresse Confirmation
Delivery
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INDEX Mall Retum
RECEIP7 Date
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Signature
C:httfe C. 1? PrIorityDelivery
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Preview
FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/18/2024 "C" Exhibit FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 716946/2023 EŠLED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 Pl! NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 12/13/2023 A ABRAMS LAW GROUP December 13, 2023 VIA USPS CERTIFIED MAIL - RRR USPS FIRST CLASS MAIL Dhaneshwar Balkaran 108-52 Liverpool Street Jamaica, NY 11435 RE: Mukhamedov v. Balkaran - Supreme Queens - Index No.: 716946/2023 To the above named party: A review of my file indicates that you were served with a Summons and Complaint in connection with the above action. Your time to answer said Summons and Complaint has now expired and up to this date, we have received no Answer on your behalf. I am enclosing a copy of that Summons and Complaint which was served upon you and I strongly suggest that you retain the services of an attorney to interpose an answer on your behalf. Your failure to answer, will make you responsible for a default judgment which I can now move for in Court. I certainly hope your actions will make this unnecessary. I thank you for your anticipated cooperation. Very truly yours, ABRA AW GR P, P.C. BY: MELANIE ABRAMS, ESQ. Enc. cc: All counsel via NYSCEF 104-70 Queens Boulevard, Suite 502 " Forest Hills,NY 11375 Telephone(718)997-9797 Facsimile (718)997-9796 E-mail:abramslawgroup@gmail.com 1 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 7 1 694 6 2 02 3 FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 / 6 PM NYSCF;F D0F No 4 RECEI CE 23 FILED QUEENS COUNTY CLERK 08 / 15 / 2023 05 : 07 P NYSCEF ICC. NO. 1 RECEIVED NYSCEF: 08/1(/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS MARCEL MUKHAMEDOV, Plaintiff, SUMMONS -against- Index No: DHANESHWAR BALKARAN, Defendant. TO THE ABOVE-NAMED DEFENDANT: YOU ARE HEREBY SUMMONED 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 Attorney within 20 days after the service complete if this Summons, exclusive of the day of service (or within 30 days after the service is complete if this Summons is not personally delivered to you within the State of New York) and proper. PLEASE TAKE NOTICE that the law provides: (a) If this Summons is served by its delivery to you personally within the State of New York, you must appear and answer within twenty (20) days after such service; or (b) If this Summons is served by delivery to any person other than you personally, or is served outside the State of New York, or by publication, or by any means other than personal delivery to you within the State of New York, you are allowed thirty (30) days after proof of service thereof is filed with the Clerk of the Court within which to appear and answer. Plaintiff designates Queens County as the place of trial for this action. The basis of venue is NY CPLR §503. Dated: Forest Hills, New York August 9, 2023 Yours, etc., ABRA LA GROUP, P.C. BY: M LANIE ABRAMS, ESQ. Attorneys for Plaintiff 104-70 Queens Blvd., Suite 502 Forest Hills, NY 11375 Tel: (718) 997-9797 TO: PLEASE SEE ATTACHED RIDER. ABRAMS LAW GROUP, P.C. 1 of 8 2 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 716946/2023 FILED : (.UEENS COUNTY CLERK 12 /13/2023 02:0 6 Pl RECE .C 023 No IL D: ÇÙEENS COUNTY CLERK 08/15/2023 05:07 PMl NYSCEF Dri:. NO. 1 RECEIVED NYSCEF: 08/16.2023 SERVICE RIDER DEFENDANT SERVE AT DHANESHWAR BALKARAN 108-52 LIVERPOOL STREET JAMAICA, NY 11435 ABRAMS LAW GROUP, P.C. 2 of 8 3 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 716946/2023 FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 PNj NYS FF DDr No 4 RECEIVED N E 023 FILED QUEENS COUNTY CLERK NDEX 6 08 /15/2023 05 : 07 PM| NYSCEF I(C. NO. 1 RECEIVED NYSCEF: 08/1(/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS MARCEL MUKHAMEDOV, Plaintiff, -against- COMPLAINT DHANESHWAR BALKARAN, Index No: Defendant. Plaintiff, Marcel Mukhamedov, ("Plaintiff") by and through attorneys, ABRAMS LAW GROUP, P.C., complaining of the Defendant, Dhaneshwar Balkaran, ("Defendant"), as and for the instant Complaint, respectfully alleges, upon information and belief: 1. That Plaintiff, at all times herein mentioned, was and still is a resident of the County of Queens, in the State ofNew York, and as such, is subject to this Honorable Court. 2. That Defendant, at all times herein mentioned, was and still is a resident of the County of Queens, in the State of New York, and as such, is subject to this Honorable Court. AS AND FOR A FIRST CAUSE OF ACTION (NEGLIGENCE) 3. That on or about August 11, 2021, Defendant was an owner of a certain 2001 Dodge motor vehicle bearing license plate number JHN4968, as issued by the State of New York ("the Dodge vehicle"). 4. That on or about August 11, 2021, Defendant was the titled owner of the Dodge vehicle. ABRAMS LAW GROUP, P.C. 3 of 8 4 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 71694 6 /2023 FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 PlÈ NYSCEF DOC NO 4 RECEIVED NYSCE 023 |FILED QUEENS COUNTY CLERK INDEX NO. 16 08 /15/2023 05 : 07 PM| NYSCEF LCC. NO. 1 RECEIVED NYSCEF: 08/1(/2023 5. That on or about August 11, 2021, Defendant was the registered owner ofthe Dodge vehicle. 6. That on or about August 11, 2021, Defendant was an operator of the Dodge vehicle 7. That on or about August 11, 2021, Defendant was the lessee of the Dodge vehicle. 8. That on or about August 11, 2021, Defendant was the lessor of the Dodge vehicle. 9. That on or about August 11, 2021, Defendant maintained the Dodge vehicle. 10. That on or about August 11, 2021, Defendant controlled the Dodge vehicle. 11. That on or about August 11, 2021, Defendant owned, operated, maintained, and controlled the Dodge vehicle. 12. That at all times herein mentioned, the roadway at or in front of the intersection of 101st Avenue and Van Wyck Expressway, in Queens County, New York (the "accident situs"), was and still remains a roadway used extensively by the public in general. 13. That on August 11, 2021, Plaintiff was a lawful bicyclist at the accident situs. 14. That on August 11, 2021, the Dodge vehicle came into contact with the Plaintiff bicyclist, at the accident situs. 15. That the subject accident and injuries resulting therefrom, were due solely and wholly as the result of the careless and negligent manner in which Defendant owned, operated, maintained and/or controlled the Dodge vehicle, without Plaintiff contributing in any way thereto. 16. That by reason of the foregoing and the negligence of the Defendant, Plaintiff was severely injured, bruised and wounded, suffered, still suffers, and will continue to suffer for some time, physical pain and bodily injuries and became sick, sore, lame, and disabled and so remained for a considerable length of time. ABRAMS LAW GROUP, P.C. 4 of 8 5 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 71694 6/2023 EŠLED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 PM1 NYS RF DOF NO 4 RECE CE 023 FILED QUEENS COUNTY CLERK 08 /15 / 2023 05 : 07 PM NYSCEF ECC. NO. 1 RECEIVED NYSCEF: 08/10/2023 17. That by reason of the foregoing, Plaintiff was compelled to and did necessarily require medical aid and attention and did necessarily pay and become liable therefor for medicines and upon information and belief, Plaintiff will necessarily incur similar expenses. 18. That by reason of the foregoing, Plaintiff has been unable to attend to their usual occupation in the manner required. 19. That by reason of the wrongful, negligent, and unlawful actions of the Defendant, as aforesaid, Plaintiff sustained serious injuries as defined in Section 5102(d) of the Insurance Law of the State ofNew York. Plaintiff has further sustained economic loss greater than basic economic loss as defined in Section 5102 of the said Insurance Law. 20. That one or more of the provisions of §l602 of the Civil Practice Law and Rules do apply to the within action. 21. That by reason of the foregoing, Plaintiff was damaged in an amount exceeding seventy-five thousand dollars. 22. That by reason of the foregoing, Plaintiff was damaged in an amount which exceeds the monetary jurisdictional limits of any and all lower Courts which would otherwise have jurisdiction herein, in an amount to be determined upon trial of this action. 23. The Plaintiff reserves the rights to amend/supplement the instant Complaint up to and including through the time of trial. PRAYER FOR RELIEF WHEREFORE, Plaintiff demands that the following judgment in Plaintiff's favor, for Plaintiff's First Cause of Action, awarding damages against Defendant, for an amount which exceeds the jurisdictional limits of all other Courts which would otherwise have jurisdiction herein, ABRAMS LAW GROUP, P.C. 5 of 8 6 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 716946/2023 FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 PM| NY.SPEF Don NO 4 RECE CE : / / 023 |FILED QUEENS COUNTY CLERK 08/15/2023 05 : 07 PM NYSCEF I t C. NO. 1 RECEIVED NYSCEF: 08/1E /2023 in an amount to be determined upon trial of this action, together with costs and disbursements of this action, and with interest from the date of the accident. Dated: Forest Hills, New York August 9, 2023 Yours, etc., ABRAMS GROUP, P.C. BY: MEL EABRAMS, ESQ. Attorneys for Plaintiff MARCEL MUKHAMEDOV 104-70 Queens Blvd., Suite 502 Forest Hills, NY 11375 Tel: (718)997-9797 ABRAMS LAW GROUP, P.C. 6 of 8 7 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 71694 6/2023 ETLED : ()UEENS COUNTY CLERK 12/13/2023 02 : 0 6 PM NYSCEF DOC NO. 4 RECEIVED NYSCE : 3/ 023 INDEX NO. 6 |FILED : QUEENS COUNTY CLERK 08 /15/2023 05 : 07 PM| NYSCEF 90C. NO. 1 RECEIVED NYSCEF: 08/1(/2023 INDIVIDUAL VERIFICATION STATE OF NEW YORK ) ) SS: COUNTY OF QUEENS ) Marcel Mukhamedov duly sworn, deposes and says: Deponent is the Plaintiff in the within action. Deponent has read the foregoing: COMPLAINT and knows the contents thereof. The same is true to deponent knowledge eXcept as matters therein stated to be alleged and that as to those matters, Deponent believes them to be true. Makel Mukhamedov Sworn to before me on August 9, 2023 i NotaryPublic, State of NewYork No.01Ai36340740 Qualified in Queens County Commission Expires April 25, 20.?ck. ABRAMS LAW GROUP, P.C. 7 of 8 8 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED INDEX NYSCEF: NO. 01/18/2024 FILED : QUEENS COUNTY CLERK 12/13/2023 02:0 6 71694 6 /2023 PM| NYSCEF DOC NO 4 RECEIVED NYSCE : 91 / 023 |FILED QUEENS COUNTY CLERK 08/15/2023 INDEX NO. 6 05 : 07 Pl! NYSCEF T t C. NO. 1 " RECEIVED NYSCEF: 08/1E /2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No.: __ MARCEL MUKHAMEDOV, Plaintiff, -against- . . DHANESHWAR BALKARAN, Defendant. SUMMONS and VERIFIED COMPLAINT ABRAMS LAW GROUP, P.C. By: MELANIE ABRAMS, ESQ. Attorneys for Plaintiff MARCEL MUKHAMEDOV 104-70 Queens Boulevard, Suite 502 Forest Hills, NY 11375 Tel: (718) 997-9797 Pursuant to 22NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of the State of New York, certifies, that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. MELANIE ABRAMS, ESQ. ABRAMS LAW GROUP, P.C. 8 of 8 9 of 10 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/18/2024 3 3/2023 2 0 2 / 6 4 1 7169 Addressee Delivery Restricted Postmark Confirmation" Receipt NO. 54§2 HBfe Agent Expresse Confirmation Delivery Yes No Mailm Mall of QA INDEX Mall Retum RECEIP7 Date O O O O Registered Registered Restricted Signature Signature C:httfe C. 1? PrIorityDelivery below: Domestic item oppropute) - OO O OO . from address Delivery Name) different Delivery MAIL® as