Preview
FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024
SUPREME COURT OF THE STATE OF NEW YORK
Index No.:
COUNTY OF KINGS
Date Purchased:
____________________-_________________________________----____________Ç
ADOLFO PASTRANA PLIEGO
SUMMONS
Plaintiff,
Plaintiff designates Kings
-against- County as the place of trial.
The basis of venue is:
FOR SOCCER VENTURES LLC, ALIANZA DE FUTBOL
KNOWN" CPLR 503
AND "XYZ COMPANY IDENTITY NOT
County of Kings
Defendants.
______________________________________________________________________Ç
To the above named Defendants:
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 plaintiffs attorneys 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: BROOKLYN, NEW YORK
April 10, 2024
Law Offic f William Pager
Attorneye Plaintiff
ADOLFC TRANA PLIEGO
205 Kings Hi hway
Brooklyn, New York 11223
718-998-1010
Our File No. 4921EL
TO: FORSOCCERVENTURESLLC
C/O C T Corporation System
28 Liberty Street
New York, NY 10005
ALIANZA DE FUTBOL
224 County Line Road
Wayne, PA 19087
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
______________________________________________________________________Ç
ADOLFO PASTRANA PLIEGO
Index No.:
Date Purchased:
Plaintiff,
-against-
VERIFIED COMPLAINT
FOR SOCCER VENTURES LLC, ALIANZA DE FUTBOL
KNOWN"
AND "XYZ COMPANY IDENTITY NOT
Defendants.
-_____________------_________________________________________..________Ç
Plaintiff, ADOLFO PASTRANA PLIEGO by his attorneys, LAW OFFICES OF
WILLIAM PAGER, complaining of the Defendants, respectfully alleges, upon information and
belief:
1. That at all times hereinafter mentioned, Plaintiff ADOLFO PASTRANA PLIEGO
was, and still is, a resident of the County of Kings and State of New York.
2. That cause of action alleged herein arose in the County of New York, City and State
of New York.
3. That this action falls within one or more of the exceptions set forth in CPLR §1602.
4. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC was and still is a foreign limited liability corporation, duly organized and existing under
and by virtue of the laws of the State of Delaware.
5. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC was and still is a foreign entity, duly organized and existing under and by virtue of the laws
of the State of Delaware.
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6. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC was and still is a foreign corporation, duly authorized to do business in the State of New
York.
7. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC was and still is a foreign corporation, doing business in the State of New York.
8. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was
and still is a foreign limited liability corporation, duly organized and existing under and by virtue
of the laws of the State of Pennsylvania.
9. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was
and still is a foreign entity, duly organized and existing under and by virtue of the laws of the
State of Pennsylvania.
10. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was
and still is a foreign corporation, duly authorized to do business in the State of New York.
11. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was
and still is a foreign corporation, doing business in the State of New York.
12. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL
maintained a principle place of business State of Pennsylvania located at 224 County Line Road,
Wayne, PA 19087.
13. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" and still
was is a foreign corporation, duly organized and existing under and by
virtue of the laws of the State of New York.
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14. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" was and still is a foreign organized and under and
entity, duly existing by
virtue of the laws of the State of New York.
15. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" was and still is a foreign authorized to do business in the
corporation, duly
State of New York.
16. At all times herein mentioned, the defendants, FOR SOCCER VENTURES LLC
defendant's servants, agents and/or employees caused and allowed a soccer league/club to be
organized with games being played at the sports field located at the premises
17. At all times herein mentioned, the defendants, ALIANZA DE FUTBOL defendant's
servants, agents and/or employees caused and allowed a soccer league/club to be organized with
games being played at the sports field located at the premises
18. At all times herein mentioned, the defendants, "XYZ COMPANY IDENTITY NOT
KNOWN" defendant's agents and/or employees caused and allowed a soccer
servants,
league/club to be organized with games being played at the sports field located at the premises
19. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC was the owner of the premises located at 65 Charles Gay Loop, Field #85, New York, NY
10035.
20. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was the
owner of the premises located at 65 Charles Gay Loop, Field #85, New York, NY 10035.
21. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" was the owner of the premises located at 65 Charles Field New
Gay Loop, #85,
York, NY 10035.
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22. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC was the owner of the premises and/or soccer field, located at 65 Charles Gay Loop, Field
#85, New York, NY 10035.
23. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was the
owner of the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York,
NY 10035.
24. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" was the owner of the premises and/or soccer located at 65 Charles
field, Gay
Loop, Field #85, New York, NY 10035.
25. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC operated the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
26. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL
operated the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York,
NY 10035.
27. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" operated the premises and/or soccer located at 65 Charles
field, Gay Loop,
Field #85, New York, NY 10035.
28. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC managed the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
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29. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL
managed the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
30. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" managed and/or
the premises soccer field, located at 65 Charles Gay Loop,
Field #85, New York, NY 10035.
31. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC maintained the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85,
New York, NY 10035.
32. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL
maintained the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
33. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" maintained the premises and/or soccer located at 65 Charles
field, Gay Loop,
Field #85, New York, NY 10035.
34. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC controlled the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85,
New York, NY 10035.
35. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL
controlled the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
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36. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN"
controlled the premises and/or soccer field, located at 65 Charles Gay Loop,
Field #85, New York, NY 10035.
37. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC supervised the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85,
New York, NY 10035.
38. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL
supervised the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
39. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" supervised the premises and/or soccer located at 65 Charles
field, Gay Loop,
Field #85, New York, NY 10035.
40. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC inspected the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
41. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL
inspected the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
42. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" inspected the and/or
premises soccer field, located at 65 Charles Gay Loop,
Field #85, New York, NY 10035.
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43. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC repaired the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New
York, NY 10035.
44. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL
repaired the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York,
NY 10035.
45. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" repaired the premises and/or soccer located at 65 Charles
field, Gay Loop,
Field #85, New York, NY 10035.
46. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES
LLC had the duty to provide a reasonably secure environment at the premises and/or soccer
field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035.
47. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL had the
duty to provide a reasonably secure environment at premises and/or soccer field, located at 65
Charles Gay Loop, Field #85, New York, NY 10035.
48. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY
NOT KNOWN" had the environment at the premises and/or
duty to provide a reasonably secure
soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035.
49. That at all times herein mentioned, the named defendants had been involved in the
Program Development, Sponsorship and Brand Integration, On-Site Activations, Youth Clinics,
Coaching Clinics, ID Camps and Scouting Programs, as well as with Leagues and Tournaments.
50. At all times herein mentioned, it was the duty of the defendant, FOR SOCCER
VENTURES LLC, defendant's servants, agents and/or employees to prevent fighting and/or
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riots from occurring at the sports field located at the premises described above, 65 Charles Gay
Loop, Field #85, New York, NY 10035, to prevent unlawful attacks, assaults and/or injuries.
51. At all times herein mentioned, it was the duty of the defendant, ALIANZA DE
FUTBOL, defendant's servants, agents and/or employees to prevent fighting and/or riots from
occurring at the sports field located at the premises described above, 65 Charles Gay Loop, Field
#85, New York, NY 10035, to prevent unlawful attacks, assaults and/or injuries.
52. At all times herein mentioned, it was the duty of the defendant, XYZ COMPANY
IDENTITY NOT KNOWN", defendant's servants, agents and/or employees to prevent fighting
and/or riots from occurring at the sports field located at the premises described above, 65 Charles
Gay Loop, Field #85, New York, NY 10035, to prevent unlawful attacks, assaults and/or injuries.
53. That the Defendants, their agents, servants, and/or employees actively patrolled,
occupied, controlled, inspected, supervised and/or derived special use of the premises and the
soccer field described above.
54. That the Defendants, their agents, servants and/or employees has and assumed a duty
to keep the above described premises and the soccer field reasonably safe for visitors and the
members of the general public.
55. That the Defendants, their agents, servants and/or employees undertook the
responsibility of providing security and a secured environment for the general public and/or
visitors to the premises and the soccer field.
56. That the Defendants, their agents, servants and employees, were charged with and
obligated to fulfill the duty, safety, supervision, care, custody and control of all the soccer games
under their auspices, including the game complained of, herein.
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57. That the Defendants, their agents, servants and/or employees had a duty to reasonably
control the improper actions of those participating in the soccer games, as well as the patrons and
spectators at the premises and the soccer field on the premises.
58. That the Defendants, their agents, servants and/or employees had a duty to reasonably
control the improper actions of those on the premises and the soccer field on the premises.
59. That the Defendants, their agents, servants and/or employees had a duty to reasonably
control the improper actions of those on the premises and the soccer field on the premises.
60. That the Defendants, their agents, servants and/or employees had a duty to reasonably
protect members of the general public and/or visitors to the premises and the soccer field from
the misconduct and improper actions of those on the premises.
61. That the Defendants, their agents, servants and/or employees had a duty to reasonably
protect members of the general public and/or visitors to the premises from the misconduct and
improper actions of those on the premises, including the agents, servants and/or employees of the
Defendant ALIANZA DE FUTBOL.
62. That the Defendants, their agents, servants and/or employees had a duty to reasonably
protect members of the general public and/or visitors to the premises from the misconduct and
improper actions of those on the premises, including the agents, servants and/or employees of the
Defendant "XYZ COMPANY IDENTITY NOT KNOWN".
63. That on August 5, 2023, Plaintiff ADOLFO PASTRANA PLIEGO was lawfully on
the aforementioned premises and the soccer field at 65 Charles Gay Loop, Field #85, New York,
NY 10035.
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64. At all times herein mentioned, on or about August 5, 2023, there was a soccer game
being held on the sports field located at the premises known as the 65 Charles Gay Loop, Field
#85, New York, NY 10035,
65. At all times herein mentioned, on or about August 5, 2023, during the course of the
soccer game being held on the sports field located at the premises known as the 65 Charles Gay
Loop, Field #85, New York, NY 10035, a fight started in which the plaintiff, was severely
injured.
66. At all times herein mentioned, on or about August 5, 2023, during the course of the
soccer game being held on the sports field located at the premises known as the 65 Charles Gay
Loop, Field #85, New York, NY 10035, a riot started in which the plaintiff, was severely injured.
67. At all times herein mentioned, on or about August 5, 2023 during the course of the
soccer game being held on the sports field located at the premises known 65 Charles Gay Loop,
Field #85, New York, NY 10035, a fight started in which the plaintiff, was assaulted and battered
and left severely injured.
68. At all times
Preview
FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF KINGS Date Purchased: ____________________-_________________________________----____________Ç ADOLFO PASTRANA PLIEGO SUMMONS Plaintiff, Plaintiff designates Kings -against- County as the place of trial. The basis of venue is: FOR SOCCER VENTURES LLC, ALIANZA DE FUTBOL KNOWN" CPLR 503 AND "XYZ COMPANY IDENTITY NOT County of Kings Defendants. ______________________________________________________________________Ç To the above named Defendants: 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 plaintiffs attorneys 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: BROOKLYN, NEW YORK April 10, 2024 Law Offic f William Pager Attorneye Plaintiff ADOLFC TRANA PLIEGO 205 Kings Hi hway Brooklyn, New York 11223 718-998-1010 Our File No. 4921EL TO: FORSOCCERVENTURESLLC C/O C T Corporation System 28 Liberty Street New York, NY 10005 ALIANZA DE FUTBOL 224 County Line Road Wayne, PA 19087 1 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ______________________________________________________________________Ç ADOLFO PASTRANA PLIEGO Index No.: Date Purchased: Plaintiff, -against- VERIFIED COMPLAINT FOR SOCCER VENTURES LLC, ALIANZA DE FUTBOL KNOWN" AND "XYZ COMPANY IDENTITY NOT Defendants. -_____________------_________________________________________..________Ç Plaintiff, ADOLFO PASTRANA PLIEGO by his attorneys, LAW OFFICES OF WILLIAM PAGER, complaining of the Defendants, respectfully alleges, upon information and belief: 1. That at all times hereinafter mentioned, Plaintiff ADOLFO PASTRANA PLIEGO was, and still is, a resident of the County of Kings and State of New York. 2. That cause of action alleged herein arose in the County of New York, City and State of New York. 3. That this action falls within one or more of the exceptions set forth in CPLR §1602. 4. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC was and still is a foreign limited liability corporation, duly organized and existing under and by virtue of the laws of the State of Delaware. 5. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC was and still is a foreign entity, duly organized and existing under and by virtue of the laws of the State of Delaware. 2 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 6. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC was and still is a foreign corporation, duly authorized to do business in the State of New York. 7. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC was and still is a foreign corporation, doing business in the State of New York. 8. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was and still is a foreign limited liability corporation, duly organized and existing under and by virtue of the laws of the State of Pennsylvania. 9. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was and still is a foreign entity, duly organized and existing under and by virtue of the laws of the State of Pennsylvania. 10. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was and still is a foreign corporation, duly authorized to do business in the State of New York. 11. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was and still is a foreign corporation, doing business in the State of New York. 12. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL maintained a principle place of business State of Pennsylvania located at 224 County Line Road, Wayne, PA 19087. 13. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" and still was is a foreign corporation, duly organized and existing under and by virtue of the laws of the State of New York. 3 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 14. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" was and still is a foreign organized and under and entity, duly existing by virtue of the laws of the State of New York. 15. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" was and still is a foreign authorized to do business in the corporation, duly State of New York. 16. At all times herein mentioned, the defendants, FOR SOCCER VENTURES LLC defendant's servants, agents and/or employees caused and allowed a soccer league/club to be organized with games being played at the sports field located at the premises 17. At all times herein mentioned, the defendants, ALIANZA DE FUTBOL defendant's servants, agents and/or employees caused and allowed a soccer league/club to be organized with games being played at the sports field located at the premises 18. At all times herein mentioned, the defendants, "XYZ COMPANY IDENTITY NOT KNOWN" defendant's agents and/or employees caused and allowed a soccer servants, league/club to be organized with games being played at the sports field located at the premises 19. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC was the owner of the premises located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 20. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was the owner of the premises located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 21. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" was the owner of the premises located at 65 Charles Field New Gay Loop, #85, York, NY 10035. 4 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 22. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC was the owner of the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 23. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL was the owner of the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 24. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" was the owner of the premises and/or soccer located at 65 Charles field, Gay Loop, Field #85, New York, NY 10035. 25. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC operated the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 26. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL operated the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 27. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" operated the premises and/or soccer located at 65 Charles field, Gay Loop, Field #85, New York, NY 10035. 28. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC managed the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 5 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 29. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL managed the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 30. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" managed and/or the premises soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 31. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC maintained the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 32. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL maintained the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 33. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" maintained the premises and/or soccer located at 65 Charles field, Gay Loop, Field #85, New York, NY 10035. 34. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC controlled the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 35. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL controlled the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 6 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 36. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" controlled the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 37. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC supervised the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 38. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL supervised the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 39. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" supervised the premises and/or soccer located at 65 Charles field, Gay Loop, Field #85, New York, NY 10035. 40. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC inspected the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 41. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL inspected the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 42. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" inspected the and/or premises soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 7 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 43. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC repaired the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 44. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL repaired the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 45. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" repaired the premises and/or soccer located at 65 Charles field, Gay Loop, Field #85, New York, NY 10035. 46. That at all times hereinafter mentioned, Defendant FOR SOCCER VENTURES LLC had the duty to provide a reasonably secure environment at the premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 47. That at all times hereinafter mentioned, Defendant ALIANZA DE FUTBOL had the duty to provide a reasonably secure environment at premises and/or soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 48. That at all times hereinafter mentioned, Defendant "XYZ COMPANY IDENTITY NOT KNOWN" had the environment at the premises and/or duty to provide a reasonably secure soccer field, located at 65 Charles Gay Loop, Field #85, New York, NY 10035. 49. That at all times herein mentioned, the named defendants had been involved in the Program Development, Sponsorship and Brand Integration, On-Site Activations, Youth Clinics, Coaching Clinics, ID Camps and Scouting Programs, as well as with Leagues and Tournaments. 50. At all times herein mentioned, it was the duty of the defendant, FOR SOCCER VENTURES LLC, defendant's servants, agents and/or employees to prevent fighting and/or 8 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 riots from occurring at the sports field located at the premises described above, 65 Charles Gay Loop, Field #85, New York, NY 10035, to prevent unlawful attacks, assaults and/or injuries. 51. At all times herein mentioned, it was the duty of the defendant, ALIANZA DE FUTBOL, defendant's servants, agents and/or employees to prevent fighting and/or riots from occurring at the sports field located at the premises described above, 65 Charles Gay Loop, Field #85, New York, NY 10035, to prevent unlawful attacks, assaults and/or injuries. 52. At all times herein mentioned, it was the duty of the defendant, XYZ COMPANY IDENTITY NOT KNOWN", defendant's servants, agents and/or employees to prevent fighting and/or riots from occurring at the sports field located at the premises described above, 65 Charles Gay Loop, Field #85, New York, NY 10035, to prevent unlawful attacks, assaults and/or injuries. 53. That the Defendants, their agents, servants, and/or employees actively patrolled, occupied, controlled, inspected, supervised and/or derived special use of the premises and the soccer field described above. 54. That the Defendants, their agents, servants and/or employees has and assumed a duty to keep the above described premises and the soccer field reasonably safe for visitors and the members of the general public. 55. That the Defendants, their agents, servants and/or employees undertook the responsibility of providing security and a secured environment for the general public and/or visitors to the premises and the soccer field. 56. That the Defendants, their agents, servants and employees, were charged with and obligated to fulfill the duty, safety, supervision, care, custody and control of all the soccer games under their auspices, including the game complained of, herein. 9 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 57. That the Defendants, their agents, servants and/or employees had a duty to reasonably control the improper actions of those participating in the soccer games, as well as the patrons and spectators at the premises and the soccer field on the premises. 58. That the Defendants, their agents, servants and/or employees had a duty to reasonably control the improper actions of those on the premises and the soccer field on the premises. 59. That the Defendants, their agents, servants and/or employees had a duty to reasonably control the improper actions of those on the premises and the soccer field on the premises. 60. That the Defendants, their agents, servants and/or employees had a duty to reasonably protect members of the general public and/or visitors to the premises and the soccer field from the misconduct and improper actions of those on the premises. 61. That the Defendants, their agents, servants and/or employees had a duty to reasonably protect members of the general public and/or visitors to the premises from the misconduct and improper actions of those on the premises, including the agents, servants and/or employees of the Defendant ALIANZA DE FUTBOL. 62. That the Defendants, their agents, servants and/or employees had a duty to reasonably protect members of the general public and/or visitors to the premises from the misconduct and improper actions of those on the premises, including the agents, servants and/or employees of the Defendant "XYZ COMPANY IDENTITY NOT KNOWN". 63. That on August 5, 2023, Plaintiff ADOLFO PASTRANA PLIEGO was lawfully on the aforementioned premises and the soccer field at 65 Charles Gay Loop, Field #85, New York, NY 10035. 10 of 23 FILED: KINGS COUNTY CLERK 04/11/2024 11:44 AM INDEX NO. 510375/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/11/2024 64. At all times herein mentioned, on or about August 5, 2023, there was a soccer game being held on the sports field located at the premises known as the 65 Charles Gay Loop, Field #85, New York, NY 10035, 65. At all times herein mentioned, on or about August 5, 2023, during the course of the soccer game being held on the sports field located at the premises known as the 65 Charles Gay Loop, Field #85, New York, NY 10035, a fight started in which the plaintiff, was severely injured. 66. At all times herein mentioned, on or about August 5, 2023, during the course of the soccer game being held on the sports field located at the premises known as the 65 Charles Gay Loop, Field #85, New York, NY 10035, a riot started in which the plaintiff, was severely injured. 67. At all times herein mentioned, on or about August 5, 2023 during the course of the soccer game being held on the sports field located at the premises known 65 Charles Gay Loop, Field #85, New York, NY 10035, a fight started in which the plaintiff, was assaulted and battered and left severely injured. 68. At all times