Preview
FILED: QUEENS COUNTY CLERK 03/12/2024 09:33 AM INDEX NO. 705373/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/12/2024
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF QUEENS
Plaintiff designates Queens
County as the place of trial.
JORGE X. ALULEMA,
Plaintiff, S U M M O N S
-against- The basis of venue is
Plaintiffs residence:
SUSAN D. SANCHEZ, 22-18 92nd Street
2nd Floor
Defendant.
East Elmhurst, NY 11369
To the above named Defendants:
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a
of your answer on the plaintiffs attorneys within 20 days after the service of this summons,
copy
exclusive of the day of service of this summons, or within 30 days after service of this summons is
complete if this summons is not personally delivered to you within the State of New York.
In case of your failure to answer this summons, a judgment by default will be taken against
you for the relief demanded in the complaint, togetperwith sts of this action.
Dated: Astoria, New York
March 11, 202
`A O & FILLAs, LLP
: Dominick Rendina, Esq.
Attorneys for Plaintiff
31-19 Newtown Avenue
Seventh Floor
Astoria, New York 11102
(718) 746 3440
Our File No.: 31726-24
DEFENDANTS:
SUSAN D. SANCHEZ
64-53 84th Street
Middle Village, NY 11379
FORWARD THIS IMMEDIATELY TO YOUR ATTORNEY OR INSURANCE COMPANY
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index No.:
VERIFIED COMPLAINT
JORGE X. ALULEMA,
Plaintiff,
-against-
SUSAN D. SANCHEZ,
Defendant.
Plaintiff, by his attorneys, SACCO & FILLAS, LLP, as and for his Verified Complaint,
respectfully alleges, upon information and belief:
AS AND FOR A FIRST CAUSE OF ACTION
1. The plaintiff, JORGE X. ALULEMA, at all times herein mentioned was and still is a
resident of the County of Queens and the State of New York.
2. The defendant, SUSAN D. SANCHEZ, at all times herein mentioned was and still is a
resident of the County of Queens and the State of New York.
3. On or about August 04, 2023, plaintiff JORGE X. ALULEMA was the registered owner of
a certain 2013 motor vehicle, bearing NY license plate number HAL2787.
4. On or about August 04, 2023, plaintiff JORGE X. ALULEMA was the operator of a certain
2013 Ford Motor vehicle, bearing NY license plate number HAL2787.
5. On or about August 04, 2023, Woodhaven Boulevard & 62nd Road, Rego Park, New York,
in the County of Queens, was and still a public roadway in common use by the general public
6. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the registered owner of
a certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243.
7. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the titled owner of a
certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243.
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8. On or about August 04, 2023, defendant SUSAN D. SANCHEZ maintained a certain 2010
Nissan motor vehicle, bearing New York license plate number JEC7243.
9. On or about August 04, 2023, defendant SUSAN D. SANCHEZ controlled a certain 2010
Nissan motor vehicle, bearing New York license plate number JEC7243.
10. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the lessee of a certain
2010 Nissan motor vehicle, bearing New York license plate number JEC7243.
11. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the lessor of a certain
2010 Nissan motor vehicle, bearing New York license plate number JEC7243.
12. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the operator of a
certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243.
13. On or about August 04, 2023, at approximately 1:00AM, the vehicle owned and operated by
the defendant SUSAN D. SANCHEZ came in contact with the vehicle owned and operated
by the plaintiff JORGE X. ALULEMA, at or near Woodhaven Boulevard & 62nd Road,
Rego Park, New York, in the County of Queens, State of New York.
14. Solely as a result of the defendant's negligence and carelessness the plaintiff was caused to
suffer severe and serious personal injuries to mind and body, and further, that the plaintiff
was subjected to great physical pain and mental anguish.
15. The aforesaid occurrence was caused by the negligence of the defendant, without any
culpable conduct on the part of the plaintiff.
16. As a result of the foregoing, the plaintiff sustained serious personal injuries as defined in
Section 5102(d) of the Insurance Law of the State of New York, and/or economic loss greater
than basic economic loss as defined in Section 5102(a) of the Insurance Law of the State of
New York.
17. This action falls within one or more of the exceptions set forth in Section 1602 of the Civil
Practice Law and Rules.
defendants'
18. Due to negligence, plaintiff JORGE X. ALULEMA is entitled to damages in a
sum which exceeds the jurisdictional limit of all lower Courts which would otherwise have
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jurisdiction.
AS AND FOR A SECOND CAUSE OF ACTION
19. Plaintiff JORGE X. ALULEMA incorporates by reference the allegations contained in the
preceding paragraphs as though fully set forth herein.
20. By reason of the foregoing, the plaintiff JORGE X. ALULEMA 's vehicle was damaged,
thereby necessitating repairs and/or the replacement thereof.
21. Due to defendant's negligence, plaintiff JORGE X. ALULEMA is entitled to damages.
WHEREFORE, the plaintiff demands:
a. judgment awarding damages on the first cause of action, in an amount exceeding
the monetary jurisdictional limits of all lower courts which would otherwise have jurisdiction;
b. judgment awarding damages on the second cause of action, in an amount
exceeding the monetary jurisdictional limits of all lower courts which would otherwise have
jurisdiction;
c. interest, the costs and disbursements of this action, together with such other and
further relief as to this Court seems just and proper.
Dated: Astoria, New York
March 11, 2024
Hy: ommick Rendtna, Esq.
CCO & FILLAS, LLP
Attorneys for Plaintiff
31-19 Newtown Avenue
Seventh Floor
Astoria, New York 11102
(718) 746-3440
Our File No.: 31726-24
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
Index No.:
JORGE X. ALULEMA, ATTORNEY'S
Plaintiff, VERIFICATION
-against-
SUSAN D. SANCHEZ,
Defendant.
Dominick Rendina, Esq., an attorney duly admitted to practice law in the State of New York,
makes the following affirmation under the penalty of perjury:
I am of the firm of SACCO & FILLAS, LLP, the attorneys of record for the plaintiff.
I have read the foregoing COMPLAINT and know the contents thereof; the same is true to
my own knowledge except as to the matters therein stated to be alleged on information and belief
and that as to those matters, I believe them to be true.
This verification is made by affinnant and not by plaintiff because she is not in the County of
Queens, which is the County where your affirmant maintains offices.
The grounds of affirmant's belief as to all matters not stated upon affirmant's knowledge are
correspondence had with the said plaintiff, information contained in the said plaintiffs file, which is
in affirmant's possession, and other pertinent data relating thereto.
Dated: Queens, New York
March 11, 2024
D inick Rendina sq.
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index No.:
JORGE X. ALULEMA,
Plaintiff,
-against-
SUSAN D. SANCHEZ,
Defendant.
SUMMONS and VERIFIED COMPLAINT
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts
of New York State, certifies that, upon information and belief and reasonable inquiry, the
contentions contained in the annexed documents are not frivolous.
Dated: Astoria, New York
March 11, 2024
Signature:
4'bominick Readina, Esq.
SACCO & FILLAS, LLP
Attorneys for Plaintiff
31-19 Newtown Avenue
Seventh Floor
Astoria, New York 11102
(718) 746-3440
Our File No.: 31726-24
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Preview
FILED: QUEENS COUNTY CLERK 03/12/2024 09:33 AM INDEX NO. 705373/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/12/2024 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF QUEENS Plaintiff designates Queens County as the place of trial. JORGE X. ALULEMA, Plaintiff, S U M M O N S -against- The basis of venue is Plaintiffs residence: SUSAN D. SANCHEZ, 22-18 92nd Street 2nd Floor Defendant. East Elmhurst, NY 11369 To the above named Defendants: YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a of your answer on the plaintiffs attorneys within 20 days after the service of this summons, copy exclusive of the day of service of this summons, or within 30 days after service of this summons is complete if this summons is not personally delivered to you within the State of New York. In case of your failure to answer this summons, a judgment by default will be taken against you for the relief demanded in the complaint, togetperwith sts of this action. Dated: Astoria, New York March 11, 202 `A O & FILLAs, LLP : Dominick Rendina, Esq. Attorneys for Plaintiff 31-19 Newtown Avenue Seventh Floor Astoria, New York 11102 (718) 746 3440 Our File No.: 31726-24 DEFENDANTS: SUSAN D. SANCHEZ 64-53 84th Street Middle Village, NY 11379 FORWARD THIS IMMEDIATELY TO YOUR ATTORNEY OR INSURANCE COMPANY SACCO& FILLAS,LLP 1 of 6 FILED: QUEENS COUNTY CLERK 03/12/2024 09:33 AM INDEX NO. 705373/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/12/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No.: VERIFIED COMPLAINT JORGE X. ALULEMA, Plaintiff, -against- SUSAN D. SANCHEZ, Defendant. Plaintiff, by his attorneys, SACCO & FILLAS, LLP, as and for his Verified Complaint, respectfully alleges, upon information and belief: AS AND FOR A FIRST CAUSE OF ACTION 1. The plaintiff, JORGE X. ALULEMA, at all times herein mentioned was and still is a resident of the County of Queens and the State of New York. 2. The defendant, SUSAN D. SANCHEZ, at all times herein mentioned was and still is a resident of the County of Queens and the State of New York. 3. On or about August 04, 2023, plaintiff JORGE X. ALULEMA was the registered owner of a certain 2013 motor vehicle, bearing NY license plate number HAL2787. 4. On or about August 04, 2023, plaintiff JORGE X. ALULEMA was the operator of a certain 2013 Ford Motor vehicle, bearing NY license plate number HAL2787. 5. On or about August 04, 2023, Woodhaven Boulevard & 62nd Road, Rego Park, New York, in the County of Queens, was and still a public roadway in common use by the general public 6. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the registered owner of a certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243. 7. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the titled owner of a certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243. SACCO& NLLAS, LLP 2 of 6 FILED: QUEENS COUNTY CLERK 03/12/2024 09:33 AM INDEX NO. 705373/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/12/2024 8. On or about August 04, 2023, defendant SUSAN D. SANCHEZ maintained a certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243. 9. On or about August 04, 2023, defendant SUSAN D. SANCHEZ controlled a certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243. 10. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the lessee of a certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243. 11. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the lessor of a certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243. 12. On or about August 04, 2023, defendant SUSAN D. SANCHEZ was the operator of a certain 2010 Nissan motor vehicle, bearing New York license plate number JEC7243. 13. On or about August 04, 2023, at approximately 1:00AM, the vehicle owned and operated by the defendant SUSAN D. SANCHEZ came in contact with the vehicle owned and operated by the plaintiff JORGE X. ALULEMA, at or near Woodhaven Boulevard & 62nd Road, Rego Park, New York, in the County of Queens, State of New York. 14. Solely as a result of the defendant's negligence and carelessness the plaintiff was caused to suffer severe and serious personal injuries to mind and body, and further, that the plaintiff was subjected to great physical pain and mental anguish. 15. The aforesaid occurrence was caused by the negligence of the defendant, without any culpable conduct on the part of the plaintiff. 16. As a result of the foregoing, the plaintiff sustained serious personal injuries as defined in Section 5102(d) of the Insurance Law of the State of New York, and/or economic loss greater than basic economic loss as defined in Section 5102(a) of the Insurance Law of the State of New York. 17. This action falls within one or more of the exceptions set forth in Section 1602 of the Civil Practice Law and Rules. defendants' 18. Due to negligence, plaintiff JORGE X. ALULEMA is entitled to damages in a sum which exceeds the jurisdictional limit of all lower Courts which would otherwise have SACCO& MLLAS,LLP 3 of 6 FILED: QUEENS COUNTY CLERK 03/12/2024 09:33 AM INDEX NO. 705373/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/12/2024 jurisdiction. AS AND FOR A SECOND CAUSE OF ACTION 19. Plaintiff JORGE X. ALULEMA incorporates by reference the allegations contained in the preceding paragraphs as though fully set forth herein. 20. By reason of the foregoing, the plaintiff JORGE X. ALULEMA 's vehicle was damaged, thereby necessitating repairs and/or the replacement thereof. 21. Due to defendant's negligence, plaintiff JORGE X. ALULEMA is entitled to damages. WHEREFORE, the plaintiff demands: a. judgment awarding damages on the first cause of action, in an amount exceeding the monetary jurisdictional limits of all lower courts which would otherwise have jurisdiction; b. judgment awarding damages on the second cause of action, in an amount exceeding the monetary jurisdictional limits of all lower courts which would otherwise have jurisdiction; c. interest, the costs and disbursements of this action, together with such other and further relief as to this Court seems just and proper. Dated: Astoria, New York March 11, 2024 Hy: ommick Rendtna, Esq. CCO & FILLAS, LLP Attorneys for Plaintiff 31-19 Newtown Avenue Seventh Floor Astoria, New York 11102 (718) 746-3440 Our File No.: 31726-24 SACCO& FILLAS,LLP 4 of 6 FILED: QUEENS COUNTY CLERK 03/12/2024 09:33 AM INDEX NO. 705373/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/12/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No.: JORGE X. ALULEMA, ATTORNEY'S Plaintiff, VERIFICATION -against- SUSAN D. SANCHEZ, Defendant. Dominick Rendina, Esq., an attorney duly admitted to practice law in the State of New York, makes the following affirmation under the penalty of perjury: I am of the firm of SACCO & FILLAS, LLP, the attorneys of record for the plaintiff. I have read the foregoing COMPLAINT and know the contents thereof; the same is true to my own knowledge except as to the matters therein stated to be alleged on information and belief and that as to those matters, I believe them to be true. This verification is made by affinnant and not by plaintiff because she is not in the County of Queens, which is the County where your affirmant maintains offices. The grounds of affirmant's belief as to all matters not stated upon affirmant's knowledge are correspondence had with the said plaintiff, information contained in the said plaintiffs file, which is in affirmant's possession, and other pertinent data relating thereto. Dated: Queens, New York March 11, 2024 D inick Rendina sq. SACCOa FILLAS,LLP 5 of 6 FILED: QUEENS COUNTY CLERK 03/12/2024 09:33 AM INDEX NO. 705373/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/12/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No.: JORGE X. ALULEMA, Plaintiff, -against- SUSAN D. SANCHEZ, Defendant. SUMMONS and VERIFIED COMPLAINT Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed documents are not frivolous. Dated: Astoria, New York March 11, 2024 Signature: 4'bominick Readina, Esq. SACCO & FILLAS, LLP Attorneys for Plaintiff 31-19 Newtown Avenue Seventh Floor Astoria, New York 11102 (718) 746-3440 Our File No.: 31726-24 SACCO& FILLAS,LLP 6 of 6