Preview
FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024
SUPREME COURT OF THE STATE OF NEW YORK Index No.
COUNTY OF QUEENS
-------------------------------------------------------------------X SUMMONS
JAMIL AHMED and SAIMA RASOOL
Plaintiff designates Queens
Plaintiffs, County as the place of trial.
-against- The basis of venue is:
Plaintiffs’ Residence
MELISSA LUCAS and IMANI LUCAS,
Defendants,
-------------------------------------------------------------------X
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 Plaintiff's attorney(s) 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: New York, New York
April 10, 2024
Yours, etc.,
_______________________________________
SAGAR CHADHA, ESQ.,
THE PERECMAN FIRM, P.L.L.C.
Attorneys for Plaintiffs,
JAMIL AHMED and SAIMA RASOOL
250 West 57th Street, Suite 401
New York, New York 10107
(212) 977-7033
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TO:
MELISSA LUCAS
43 Roanoke Road
Belle Mead, NJ 08502
IMANI LUCAS
43 Roanoke Road
Belle Mead, NJ 08502
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
-------------------------------------------------------------------X Index No.
JAMIL AHMED and SAIMA RASOOL
Plaintiffs, VERIFIED COMPLAINT
-against-
MELISSA LUCAS and IMANI LUCAS,
Defendants,
-------------------------------------------------------------------X
Plaintiffs, by their attorneys, THE PERECMAN FIRM, P.L.L.C., complaining of the
Defendants, respectfully alleges, upon information and belief as follows:
1. That on August 21, 2023 (hereinafter, “the date of the incident,”) and at all times
hereinafter mentioned, Plaintiffs were, and still are, residents of the County of Queens, State of
New York.
2. That on the date of the incident and at all times hereinafter mentioned Defendant
MELISSA LUCAS was, and still is, the owner of a 2013 Honda motor vehicle bearing New Jersey
State license plate number K92KYU (hereinafter, “the LUCAS vehicle”).
3. That on the date of the incident and at all times hereinafter mentioned, the
Defendant MELISSA LUCAS, operated the LUCAS vehicle.
4. That on the date of the incident and at all times hereinafter mentioned, the
Defendant MELISSA LUCAS, managed the LUCAS vehicle.
5. That on the date of the incident and at all times hereinafter mentioned, the
Defendant MELISSA LUCAS, possessed the LUCAS vehicle.
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6. That on the date of the incident and at all times hereinafter mentioned, the
Defendant MELISSA LUCAS, controlled the LUCAS vehicle.
7. That on the date of the incident and at all times hereinafter mentioned, the
Defendant MELISSA LUCAS, maintained the LUCAS vehicle.
8. That on the date of the incident and at all times hereinafter mentioned the Defendant
IMANI LUCAS, operated the LUCAS vehicle.
9. That on the date of the incident and at all times hereinafter mentioned the Defendant
IMANI LUCAS operated the LUCAS vehicle with the permission of Defendant MELISSA
LUCAS.
10. That on the date of the incident and at all times hereinafter mentioned the Defendant
IMANI LUCAS operated the LUCAS vehicle with the consent of Defendant MELISSA LUCAS.
11. That on the date of the incident and at all times hereinafter mentioned the Defendant
IMANI LUCAS was in possession of the LUCAS vehicle.
12. That on the date of the incident and at all times hereinafter mentioned the Defendant
IMANI LUCAS, managed the LUCAS vehicle.
13. That on the date of the incident and at all times hereinafter mentioned the Defendant
IMANI LUCAS, controlled the LUCAS vehicle.
14. That on the date of the incident and at all times hereinafter mentioned the Defendant
IMANI LUCAS, maintained the LUCAS vehicle.
15. That on the date of the incident and at all times hereinafter mentioned the LUCAS
vehicle was not reported lost.
16. That on the date of the incident and at all times hereinafter mentioned the LUCAS
vehicle was not reported stolen.
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17. That on the date of the incident and at all times hereinafter mentioned, Plaintiff
JAMIL AHMED was the operator of a 2021 Lexus motor vehicle bearing New York State license
plate number KUH2240 (hereinafter, “the AHMED vehicle”).
18. That on the date of the incident and at all times hereinafter mentioned, Plaintiff
SAIMA RASOOL was a passenger in the AHMED vehicle.
19. That on the date of the incident and at all times hereinafter mentioned, the Interstate
495 (hereinafter "LIE"), at or within the vicinity of Peck Avenue, in the County of Queens, State
of New York (hereinafter, “the location of the incident,”) was, and still is, a public roadway and/or
thoroughfare upon which motor vehicles did customarily travel and traverse.
20. That on the date of the incident and at all times hereinafter mentioned, the location
of the incident was a two-way roadway with lanes for vehicular traffic travelling both in an
eastbound and westbound direction.
21. That on the date of the incident and at all times hereinafter mentioned, the
eastbound lanes designated for vehicular traffic at the location of the incident were separated from
the westbound lanes designated for vehicular traffic by a barrier on the roadway.
22. That on the date of the incident and at all times hereinafter mentioned, the AHMED
vehicle was lawfully travelling at the location of the incident.
23. That on the date of the incident and at all times hereinafter mentioned, the AHMED
vehicle was lawfully travelling in an eastbound direction at the location of the incident.
24. That on the date of the incident, Plaintiff JAMIL AHMED was the operator of the
AHMED vehicle as it was travelling and present at the location of the incident, as aforesaid.
25. That on the date of the incident, Plaintiff SAIMA RASOOL was a passenger in the
AHMED vehicle as it was travelling and present at the location of the incident, as aforesaid.
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26. That on the date of the incident, the LUCAS vehicle was travelling in an eastbound
direction at the location of the incident.
27. That on the date of the incident, as the LUCAS vehicle was travelling in an
eastbound direction at the location of the incident, the LUCAS vehicle came into contact with the
AHMED vehicle.
28. That on the date of the incident, the front of the LUCAS vehicle came into contact with
the rear of the AHMED vehicle.
29. That on the date of the incident, when the LUCAS vehicle came into contact with
the AHMED vehicle, as aforesaid, Defendant IMANI LUCAS was operating the LUCAS vehicle.
30. That on the date of the incident, Defendant IMANI LUCAS, was operating the
LUCAS vehicle at the location of the incident, when it was caused to come into contact with the
rear of the AHMED vehicle at the location of the incident.
31. That Defendant IMANI LUCAS observed, viewed, and saw traffic present, located
and travelling in a eastbound direction at the location of the incident, including the AHMED
vehicle, and yet Defendant IMANI LUCAS, continued to operate the LUCAS vehicle into traffic,
thereby coming into contact with the AHMED vehicle.
32. That as a consequence of the aforementioned contact and/or collision between the
LUCAS vehicle and the AHMED vehicle, Plaintiff JAMIL AHMED was injured.
33. That as a consequence of the aforementioned contact and/or collision between the
LUCAS vehicle and the AHMED vehicle, Plaintiff SAIMA RASOOL was injured.
34. That the aforesaid occurrence was caused wholly and solely by reason of the
negligence of the Defendants without any fault or negligence on the part of the Plaintiffs
contributing thereto.
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35. That the aforesaid occurrence was caused solely by reason of the negligence,
carelessness, and recklessness of the Defendants in the ownership, operation, possession,
management, maintenance, use, and control of the LUCAS vehicle; in failing to keep the LUCAS
vehicle under proper, prudent, and reasonable control; in operating the LUCAS vehicle at an
excessive and unlawful rate of speed under the conditions and circumstances prevailing at or prior
to the said occurrence; in failing to give the AHMED vehicle the right of way; in failing to keep a
proper lookout; in negligently, carelessly and recklessly failing to stop thereby causing the contact
between the LUCAS vehicle and AHMED vehicle at the location of the incident; in failing to see;
in failing to observe the roadway; in failing to observe the AHMED vehicle; in failing to timely
stop; in failing to apply the brakes; in failing to give any sign, signal, or warning of the approach
of the LUCAS vehicle; in causing the LUCAS vehicle to come into contact with the AHMED
vehicle; in failing to obey the traffic signs and/or signals at the location of the incident; in failing
to slow down as may be necessary for safe operation of the LUCAS vehicle; in exceeding the
maximum speed limits for vehicular traffic at the location of the incident, thereby endangering life
and property located thereat; in failing to see that which there was to be seen; in failing to observe
or see the presence of the AHMED vehicle at the location of the incident at the time that the
LUCAS vehicle proceeded into the location of the incident; in failing to stop for vehicles present
within the location of the incident, and more particularly, the AHMED vehicle; in failing to yield
the right of way to vehicles in the location of the incident and more particularly, the AHMED
vehicle; in causing the LUCAS vehicle to come into contact with the AHMED vehicle; in failing
to adequately and properly supervise the operator of the LUCAS vehicle; in negligently, carelessly
and recklessly failing to properly supervise Defendant IMANI LUCAS in the use, management,
maintenance and operation of the LUCAS vehicle; in failing to properly and adequately instruct
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the driver of the LUCAS vehicle; in failing to properly and adequately instruct and/or train
Defendant IMANI LUCAS in the use, managements maintenance and operation of the LUCAS
vehicle; in failing to keep the LUCAS vehicle in proper and operable condition; in failing to
properly maintain the LUCAS vehicle; in failing to comply with the Statutes and Ordinances
pertaining to vehicular traffic on the highways and/or roadways of the City and State of New York;
and in otherwise failing to avoid this collision, although the Defendants had a full opportunity to
avoid same.
36. That by reason of the foregoing, the Plaintiff, JAMIL AHMED, was caused to
sustain serious, severe and permanent personal injuries and was otherwise damaged.
37. That by reason of the foregoing, the Plaintiff, SAIMA RASOOL, was caused to
sustain serious, severe and permanent personal injuries and was otherwise damaged.
39. That by reason of the foregoing, the Plaintiff JAMIL AHMED sustained serious
injuries as defined by section 5102(d) of the Insurance Law of the State of New York.
40. That by reason of the foregoing, the Plaintiff SAIMA RASOOL sustained serious
injuries as defined by section 5102(d) of the Insurance Law of the State of New York.
41. That by reason of the foregoing, the Plaintiffs have sustained economic loss greater
than "basic economic loss" as defined by section 5104 of the Insurance Law of the State of New
York.
42. That Plaintiffs are not seeking to recover any damages for which Plaintiffs have
been reimbursed by no-fault insurance and/or for which no-fault insurance is obligated to
reimburse Plaintiffs. Plaintiffs are seeking to recover only those damages not recoverable through
no-fault insurance under the facts and circumstances in this action.
43. That solely by reason of the aforementioned incident, Plaintiff JAMIL AHMED
sustained great bodily injuries with accompanying pain and suffering; he became and continues to
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be sick, sore, lame and disabled; some of his injuries will be permanent; he was and will be
compelled to seek medical attention for these injuries; and has been and will be unable to attend
to his usual business and occupation.
44. That solely by reason of the aforementioned incident, Plaintiff SAIMA RASOOL
sustained great bodily injuries with accompanying pain and suffering; she became and continues
to be sick, sore, lame and disabled; some of her injuries will be permanent; she was and will be
compelled to seek medical attention for these injuries; and has been and will be unable to attend
to her usual business and occupation.
45. That this action falls within one or more of the exceptions set forth in CPLR §1602
46. That by reason of the foregoing, the Plaintiffs have been damaged in an amount in
excess of the monetary limits of all lower courts which would otherwise have jurisdiction, plus
interest, costs, and disbursements.
47. WHEREFORE, Plaintiffs demand judgment against the Defendants herein, in a
sum exceeding the jurisdictional limits of all lower courts which would otherwise have
jurisdiction, together with the costs and disbursements of this action.
Dated: New York, New York
April 10, 2024
Yours, etc.
SAGAR CHADHA, ESQ.
THE PERECMAN FIRM, P.L.L.C.
Attorneys for Plaintiffs,
JAMIL AHMED and SAIMA RASOOL
250 West 57th Street, Suite 401
New York, New York 10107
(212) 977-7033
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ATTORNEY’S VERIFICATION
STATE OF NEW YORK )
) ss.:
COUNTY OF NEW YORK )
The undersigned, an attorney admitted to practice law in the Courts of New York State,
affirms under penalty of perjury that I am one of the attorneys for the plaintiff in the within action;
I have read the foregoing VERIFIED COMPLAINT and know the contents thereof; the same is
true to my own knowledge, except as to the matters I believe to be true. The reason this verification
is made by me and not by my clients, is that my clients are not presently in the County where I
maintain my offices. The grounds of my belief as to all matters not stated upon my own knowledge
are the materials in my file and the investigation conducted by my office.
Dated: New York, New York
April 10, 2024
________________________________
Sagar Chadha, Esq.
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index No.
JAMIL AHMED and SAIMA RASOOL,
Plaintiffs,
-against-
MELISSA LUCAS and IMANI LUCAS,
Defendants,
SUMMONS & VERIFIED COMPLAINT
THE PERECMAN FIRM, P.L.L.C.
Attorneys for Plaintiffs
250 West 57th Street, Suite 401
New York, New York 10107
Tel. (212) 977-7033
Fax (212) 977-7035
To: Service of a copy of the within is hereby admitted.
_________________________________________________________________________
CERTIFICATION BY ATTORNEY
STATE OF NEW YORK )
) ss.:
COUNTY OF NEW YORK )
I, the undersigned, an attorney duly admitted to practice in the Courts of the State of New York, certify
that, upon information and belief, formed after an inquiry reasonable under the circumstances, the
presentation of the attached SUMMONS & VERIFIED COMPLAINT and the contentions contained
therein are not frivolous, as that term is defined in Section 130.1.1(c) of the rules of the Chief
Administrator.
Dated: New York, New York
April 10, 2024 __________________________
Sagar Chadha, Esq.
PLEASE TAKE NOTICE:
____ Notice of Entry
____ Notice of Settlement Yours, etc.,
The Perecman Firm, P.L.L.C.
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Preview
FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 SUPREME COURT OF THE STATE OF NEW YORK Index No. COUNTY OF QUEENS -------------------------------------------------------------------X SUMMONS JAMIL AHMED and SAIMA RASOOL Plaintiff designates Queens Plaintiffs, County as the place of trial. -against- The basis of venue is: Plaintiffs’ Residence MELISSA LUCAS and IMANI LUCAS, Defendants, -------------------------------------------------------------------X 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 Plaintiff's attorney(s) 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: New York, New York April 10, 2024 Yours, etc., _______________________________________ SAGAR CHADHA, ESQ., THE PERECMAN FIRM, P.L.L.C. Attorneys for Plaintiffs, JAMIL AHMED and SAIMA RASOOL 250 West 57th Street, Suite 401 New York, New York 10107 (212) 977-7033 1 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 TO: MELISSA LUCAS 43 Roanoke Road Belle Mead, NJ 08502 IMANI LUCAS 43 Roanoke Road Belle Mead, NJ 08502 2 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS -------------------------------------------------------------------X Index No. JAMIL AHMED and SAIMA RASOOL Plaintiffs, VERIFIED COMPLAINT -against- MELISSA LUCAS and IMANI LUCAS, Defendants, -------------------------------------------------------------------X Plaintiffs, by their attorneys, THE PERECMAN FIRM, P.L.L.C., complaining of the Defendants, respectfully alleges, upon information and belief as follows: 1. That on August 21, 2023 (hereinafter, “the date of the incident,”) and at all times hereinafter mentioned, Plaintiffs were, and still are, residents of the County of Queens, State of New York. 2. That on the date of the incident and at all times hereinafter mentioned Defendant MELISSA LUCAS was, and still is, the owner of a 2013 Honda motor vehicle bearing New Jersey State license plate number K92KYU (hereinafter, “the LUCAS vehicle”). 3. That on the date of the incident and at all times hereinafter mentioned, the Defendant MELISSA LUCAS, operated the LUCAS vehicle. 4. That on the date of the incident and at all times hereinafter mentioned, the Defendant MELISSA LUCAS, managed the LUCAS vehicle. 5. That on the date of the incident and at all times hereinafter mentioned, the Defendant MELISSA LUCAS, possessed the LUCAS vehicle. 3 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 6. That on the date of the incident and at all times hereinafter mentioned, the Defendant MELISSA LUCAS, controlled the LUCAS vehicle. 7. That on the date of the incident and at all times hereinafter mentioned, the Defendant MELISSA LUCAS, maintained the LUCAS vehicle. 8. That on the date of the incident and at all times hereinafter mentioned the Defendant IMANI LUCAS, operated the LUCAS vehicle. 9. That on the date of the incident and at all times hereinafter mentioned the Defendant IMANI LUCAS operated the LUCAS vehicle with the permission of Defendant MELISSA LUCAS. 10. That on the date of the incident and at all times hereinafter mentioned the Defendant IMANI LUCAS operated the LUCAS vehicle with the consent of Defendant MELISSA LUCAS. 11. That on the date of the incident and at all times hereinafter mentioned the Defendant IMANI LUCAS was in possession of the LUCAS vehicle. 12. That on the date of the incident and at all times hereinafter mentioned the Defendant IMANI LUCAS, managed the LUCAS vehicle. 13. That on the date of the incident and at all times hereinafter mentioned the Defendant IMANI LUCAS, controlled the LUCAS vehicle. 14. That on the date of the incident and at all times hereinafter mentioned the Defendant IMANI LUCAS, maintained the LUCAS vehicle. 15. That on the date of the incident and at all times hereinafter mentioned the LUCAS vehicle was not reported lost. 16. That on the date of the incident and at all times hereinafter mentioned the LUCAS vehicle was not reported stolen. 4 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 17. That on the date of the incident and at all times hereinafter mentioned, Plaintiff JAMIL AHMED was the operator of a 2021 Lexus motor vehicle bearing New York State license plate number KUH2240 (hereinafter, “the AHMED vehicle”). 18. That on the date of the incident and at all times hereinafter mentioned, Plaintiff SAIMA RASOOL was a passenger in the AHMED vehicle. 19. That on the date of the incident and at all times hereinafter mentioned, the Interstate 495 (hereinafter "LIE"), at or within the vicinity of Peck Avenue, in the County of Queens, State of New York (hereinafter, “the location of the incident,”) was, and still is, a public roadway and/or thoroughfare upon which motor vehicles did customarily travel and traverse. 20. That on the date of the incident and at all times hereinafter mentioned, the location of the incident was a two-way roadway with lanes for vehicular traffic travelling both in an eastbound and westbound direction. 21. That on the date of the incident and at all times hereinafter mentioned, the eastbound lanes designated for vehicular traffic at the location of the incident were separated from the westbound lanes designated for vehicular traffic by a barrier on the roadway. 22. That on the date of the incident and at all times hereinafter mentioned, the AHMED vehicle was lawfully travelling at the location of the incident. 23. That on the date of the incident and at all times hereinafter mentioned, the AHMED vehicle was lawfully travelling in an eastbound direction at the location of the incident. 24. That on the date of the incident, Plaintiff JAMIL AHMED was the operator of the AHMED vehicle as it was travelling and present at the location of the incident, as aforesaid. 25. That on the date of the incident, Plaintiff SAIMA RASOOL was a passenger in the AHMED vehicle as it was travelling and present at the location of the incident, as aforesaid. 5 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 26. That on the date of the incident, the LUCAS vehicle was travelling in an eastbound direction at the location of the incident. 27. That on the date of the incident, as the LUCAS vehicle was travelling in an eastbound direction at the location of the incident, the LUCAS vehicle came into contact with the AHMED vehicle. 28. That on the date of the incident, the front of the LUCAS vehicle came into contact with the rear of the AHMED vehicle. 29. That on the date of the incident, when the LUCAS vehicle came into contact with the AHMED vehicle, as aforesaid, Defendant IMANI LUCAS was operating the LUCAS vehicle. 30. That on the date of the incident, Defendant IMANI LUCAS, was operating the LUCAS vehicle at the location of the incident, when it was caused to come into contact with the rear of the AHMED vehicle at the location of the incident. 31. That Defendant IMANI LUCAS observed, viewed, and saw traffic present, located and travelling in a eastbound direction at the location of the incident, including the AHMED vehicle, and yet Defendant IMANI LUCAS, continued to operate the LUCAS vehicle into traffic, thereby coming into contact with the AHMED vehicle. 32. That as a consequence of the aforementioned contact and/or collision between the LUCAS vehicle and the AHMED vehicle, Plaintiff JAMIL AHMED was injured. 33. That as a consequence of the aforementioned contact and/or collision between the LUCAS vehicle and the AHMED vehicle, Plaintiff SAIMA RASOOL was injured. 34. That the aforesaid occurrence was caused wholly and solely by reason of the negligence of the Defendants without any fault or negligence on the part of the Plaintiffs contributing thereto. 6 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 35. That the aforesaid occurrence was caused solely by reason of the negligence, carelessness, and recklessness of the Defendants in the ownership, operation, possession, management, maintenance, use, and control of the LUCAS vehicle; in failing to keep the LUCAS vehicle under proper, prudent, and reasonable control; in operating the LUCAS vehicle at an excessive and unlawful rate of speed under the conditions and circumstances prevailing at or prior to the said occurrence; in failing to give the AHMED vehicle the right of way; in failing to keep a proper lookout; in negligently, carelessly and recklessly failing to stop thereby causing the contact between the LUCAS vehicle and AHMED vehicle at the location of the incident; in failing to see; in failing to observe the roadway; in failing to observe the AHMED vehicle; in failing to timely stop; in failing to apply the brakes; in failing to give any sign, signal, or warning of the approach of the LUCAS vehicle; in causing the LUCAS vehicle to come into contact with the AHMED vehicle; in failing to obey the traffic signs and/or signals at the location of the incident; in failing to slow down as may be necessary for safe operation of the LUCAS vehicle; in exceeding the maximum speed limits for vehicular traffic at the location of the incident, thereby endangering life and property located thereat; in failing to see that which there was to be seen; in failing to observe or see the presence of the AHMED vehicle at the location of the incident at the time that the LUCAS vehicle proceeded into the location of the incident; in failing to stop for vehicles present within the location of the incident, and more particularly, the AHMED vehicle; in failing to yield the right of way to vehicles in the location of the incident and more particularly, the AHMED vehicle; in causing the LUCAS vehicle to come into contact with the AHMED vehicle; in failing to adequately and properly supervise the operator of the LUCAS vehicle; in negligently, carelessly and recklessly failing to properly supervise Defendant IMANI LUCAS in the use, management, maintenance and operation of the LUCAS vehicle; in failing to properly and adequately instruct 7 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 the driver of the LUCAS vehicle; in failing to properly and adequately instruct and/or train Defendant IMANI LUCAS in the use, managements maintenance and operation of the LUCAS vehicle; in failing to keep the LUCAS vehicle in proper and operable condition; in failing to properly maintain the LUCAS vehicle; in failing to comply with the Statutes and Ordinances pertaining to vehicular traffic on the highways and/or roadways of the City and State of New York; and in otherwise failing to avoid this collision, although the Defendants had a full opportunity to avoid same. 36. That by reason of the foregoing, the Plaintiff, JAMIL AHMED, was caused to sustain serious, severe and permanent personal injuries and was otherwise damaged. 37. That by reason of the foregoing, the Plaintiff, SAIMA RASOOL, was caused to sustain serious, severe and permanent personal injuries and was otherwise damaged. 39. That by reason of the foregoing, the Plaintiff JAMIL AHMED sustained serious injuries as defined by section 5102(d) of the Insurance Law of the State of New York. 40. That by reason of the foregoing, the Plaintiff SAIMA RASOOL sustained serious injuries as defined by section 5102(d) of the Insurance Law of the State of New York. 41. That by reason of the foregoing, the Plaintiffs have sustained economic loss greater than "basic economic loss" as defined by section 5104 of the Insurance Law of the State of New York. 42. That Plaintiffs are not seeking to recover any damages for which Plaintiffs have been reimbursed by no-fault insurance and/or for which no-fault insurance is obligated to reimburse Plaintiffs. Plaintiffs are seeking to recover only those damages not recoverable through no-fault insurance under the facts and circumstances in this action. 43. That solely by reason of the aforementioned incident, Plaintiff JAMIL AHMED sustained great bodily injuries with accompanying pain and suffering; he became and continues to 8 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 be sick, sore, lame and disabled; some of his injuries will be permanent; he was and will be compelled to seek medical attention for these injuries; and has been and will be unable to attend to his usual business and occupation. 44. That solely by reason of the aforementioned incident, Plaintiff SAIMA RASOOL sustained great bodily injuries with accompanying pain and suffering; she became and continues to be sick, sore, lame and disabled; some of her injuries will be permanent; she was and will be compelled to seek medical attention for these injuries; and has been and will be unable to attend to her usual business and occupation. 45. That this action falls within one or more of the exceptions set forth in CPLR §1602 46. That by reason of the foregoing, the Plaintiffs have been damaged in an amount in excess of the monetary limits of all lower courts which would otherwise have jurisdiction, plus interest, costs, and disbursements. 47. WHEREFORE, Plaintiffs demand judgment against the Defendants herein, in a sum exceeding the jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with the costs and disbursements of this action. Dated: New York, New York April 10, 2024 Yours, etc. SAGAR CHADHA, ESQ. THE PERECMAN FIRM, P.L.L.C. Attorneys for Plaintiffs, JAMIL AHMED and SAIMA RASOOL 250 West 57th Street, Suite 401 New York, New York 10107 (212) 977-7033 9 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 ATTORNEY’S VERIFICATION STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) The undersigned, an attorney admitted to practice law in the Courts of New York State, affirms under penalty of perjury that I am one of the attorneys for the plaintiff in the within action; I have read the foregoing VERIFIED COMPLAINT and know the contents thereof; the same is true to my own knowledge, except as to the matters I believe to be true. The reason this verification is made by me and not by my clients, is that my clients are not presently in the County where I maintain my offices. The grounds of my belief as to all matters not stated upon my own knowledge are the materials in my file and the investigation conducted by my office. Dated: New York, New York April 10, 2024 ________________________________ Sagar Chadha, Esq. 10 of 11 FILED: QUEENS COUNTY CLERK 04/10/2024 10:24 AM INDEX NO. 707656/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/10/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No. JAMIL AHMED and SAIMA RASOOL, Plaintiffs, -against- MELISSA LUCAS and IMANI LUCAS, Defendants, SUMMONS & VERIFIED COMPLAINT THE PERECMAN FIRM, P.L.L.C. Attorneys for Plaintiffs 250 West 57th Street, Suite 401 New York, New York 10107 Tel. (212) 977-7033 Fax (212) 977-7035 To: Service of a copy of the within is hereby admitted. _________________________________________________________________________ CERTIFICATION BY ATTORNEY STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) I, the undersigned, an attorney duly admitted to practice in the Courts of the State of New York, certify that, upon information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the attached SUMMONS & VERIFIED COMPLAINT and the contentions contained therein are not frivolous, as that term is defined in Section 130.1.1(c) of the rules of the Chief Administrator. Dated: New York, New York April 10, 2024 __________________________ Sagar Chadha, Esq. PLEASE TAKE NOTICE: ____ Notice of Entry ____ Notice of Settlement Yours, etc., The Perecman Firm, P.L.L.C. 11 of 11