Preview
FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
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TEKHI TAYLOR, Index No.:
Date Purchased:
Plaintiff, Plaintiff designates QUEENS
County as the place of trial.
-against- The basis of venue is
Defendant’s residence
DECHENG LI, SUMMONS
Defendant’s residence:
13742 Geranium Avenue
Flushing, NY 11355
Defendants.
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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' Attorney within twenty (20) days after service of 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 in case of your failure to appear
or answer, judgment will be taken against you by default for the relief demanded in the complaint.
JURY TRIAL DEMANDED
DATED: Garden City, New York
April 13, 2024
THE LAW OFFICES OF DERELL D. WILSON
Attorneys for Plaintiff
By
Derell D. Wilson
1225 Franklin Avenue, Suite 325
Garden City, New York 11530
(516) 280-2081
THE LAW OFFICES OF DERELL D. WILSON
1225 FRANKLIN AVENUE, SUITE 325
GARDEN CITY, NY 11530
(516) 280-2081
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
Defendant’s Address:
DECHENG LI
13742 Geranium Avenue
Flushing, NY 11355
THE LAW OFFICES OF DERELL D. WILSON
1225 FRANKLIN AVENUE, SUITE 325
GARDEN CITY, NY 11530
(516) 280-2081
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
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TEKHI TAYLOR,
Plaintiff,
-against- VERIFIED COMPLAINT
DECHENG LI,
Defendants.
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Plaintiff, TEKHI TAYLOR, by his attorneys, THE LAW OFFICES OF DERELL D.
WILSON, complains of the defendants, and alleges:
1. On or about December 7, 2022, and at all times relevant to this Complaint, the
Plaintiff, TEKHI TAYLOR, was and is a resident of the County of Nassau, State of New York.
2. On or about December 7, 2022, and at all times relevant to this Complaint,
Defendant, DECHENG LI, was and is a resident of the County of Queens, State of New York.
3. On or about December 7, 2022, and at all times relevant to this complaint
Defendant, DECHENG LI, owned a 2015 TOYOTA SUBN. bearing a New York State License
Plate Number JFW2855, hereinafter referred as “motor vehicle number one”.
4. On or about December 7, 2022, Defendant, DECHENG LI, operated a motor
vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor
vehicle number one, at or near the accident location.
5. On or about December 7, 2022, Defendant, DECHENG LI, controlled a motor
vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor
vehicle number one, at or near the accident location.
THE LAW OFFICES OF DERELL D. WILSON
1225 FRANKLIN AVENUE, SUITE 325
GARDEN CITY, NY 11530
(516) 280-2081
3 of 8
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6. On or about December 7, 2022, Defendant, DECHENG LI, maintained a motor
vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor
vehicle number one, at or near the accident location.
7. On or about December 7, 2022, Defendant, DECHENG LI, inspected a motor
vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor
vehicle number one, at or near the accident location.
8. On or about December 7, 2022, Defendant, DECHENG LI, owned, operated,
controlled, maintained and inspected a motor vehicle bearing a New York State License Plate
Number JFW2855, the aforementioned motor vehicle number one, at or near the accident location.
9. On December 7, 2022, the aforementioned motor vehicle number one was owned
and driven by Defendant, DECHENG LI.
10. On or about December 7, 2022, the Defendant, DECHENG LI, owned and operated
a 2015 TOYOTA SUBN bearing a New York State License Plate Number JFW2855, the
aforementioned motor vehicle number one, while on Fulton Street, Westbury at the intersection of
Drexel Avenue, Westbury in the County of Nassau, New York (referred to as the “accident
location”).
11. On December 7, 2022, the Plaintiff, TEKHI TAYLOR, was lawfully present as a
pedestrian, at or near the accident location.
12. On or about December 7, 2022, motor vehicle number one operated by Defendant,
DECHENG LI, violently struck the Plaintiff, TEKHI TAYLOR, at or near the accident location.
13. As a result of said accident, Plaintiff, TEKHI TAYLOR, was injured.
14. That as a result of the aforesaid violent collision , Plaintiff, TEKHI TAYLOR, was
severely injured.
THE LAW OFFICES OF DERELL D. WILSON
1225 FRANKLIN AVENUE, SUITE 325
GARDEN CITY, NY 11530
(516) 280-2081
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15. Plaintiff, TEKHI TAYLOR, sustained “serios’’ injuries as such term is defined by
Section 5102 of the Insurance of the State of New York and being a covered person claiming
against a covered person, is entitled to recover for non-economic loss, including pain, suffering,
disfigurement and disability. Moreover, the Plaintiff is entitled to recover for such economic losses
that exceed the basic economic loss.
16. That defendants were negligent by reason of the recklessness and carelessness in
the ownership, operation, maintenance, management and control of the aforesaid motor vehicle;
in failing to properly maintain, repair and care for the aforesaid motor vehicle; in failing to have
same under reasonable and proper control; in failing to keep a proper lookout upon the highway;
in failing to give due and proper warning of the movements of the said motor vehicle; in failing to
slow or stop said motor vehicle in order to avoid the accident; in failing to heed traffic controls; in
failing to signal or give signals; in failing to afford the plaintiff a reasonable opportunity to reach
a place of safety; in operating the motor vehicle as to cause the same to come in contact with such
objects and/or persons as were involved in said accident; in so operating the motor vehicle as to
cause the same to be in such a position on the highway as to endanger the safety to others; in
operating said motor vehicle at such speed at said location as to cause the same to be of danger to
others, and in violating that statutes, ordinances and regulations (of which the Court will take
Judicial notice) in such cases made and provided.
WHEREFORE, Plaintiff, TEKHI TAYLOR, demands judgment against the Defendants,
DECHENG LI , in a sum that exceeds the jurisdiction of all other courts lower than the Supreme
Court of the State of New York together with the costs and disbursements and interests of this
action.
THE LAW OFFICES OF DERELL D. WILSON
1225 FRANKLIN AVENUE, SUITE 325
GARDEN CITY, NY 11530
(516) 280-2081
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FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
DATED: Garden City, New York
April 13, 2024
THE LAW OFFICES OF DERELL D. WILSON
Attorneys for Plaintiff
By
Derell D. Wilson
1225 Franklin Avenue, Suite 325
Garden City, New York 11530
(516) 280-2081
THE LAW OFFICES OF DERELL D. WILSON
1225 FRANKLIN AVENUE, SUITE 325
GARDEN CITY, NY 11530
(516) 280-2081
6 of 8
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
VERIFICATION
STATE OF NEW YORK )
) SS.:
COUNTY OF QUEENS )
Derell D. Wilson, Esq., an attorney duly admitted to practice law in
the Courts of this State, affirms the following under penalties of perjury:
I am the attorney for the plaintiff in the above entitled-action. I have read the foregoing
SUMMONS AND VERIFIED COMPLAINT and know the contents thereof, and upon information
and belief, affirmant believes after an inquiry reasonable under the circumstances the matters
alleged herein to be true, and that the contentions herein are not frivolous, as that term is defined in
Part 130.
The reason this verification is made by affirmant and not by plaintiff is that the plaintiff herein
reside in a County other than the County in which we maintain our offices.
The source of affirmant's information and the grounds of her belief are communications,
papers, reports and investigations contained in the file maintained by this office.
Dated: Garden City, New York
April 13, 2024
Derell D. Wilson
THE LAW OFFICES OF DERELL D. WILSON
1225 FRANKLIN AVENUE, SUITE 325
GARDEN CITY, NY 11530
(516) 280-2081
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
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TEKHI TAYLOR,
Plaintiff, Index No.:
-against-
DECHENG LI,
Defendants.
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==========================================================================
SUMMONS AND VERIFIED COMPLAINT
==========================================================================
THE LAW OFFICES OF DERELL D. WILSON
Attorneys for: Plaintiff
1225 Franklin Avenue, Suite 325
Garden City, New York 11530
(516) 280-2081
===========================================================================
The undersigned attorney hereby certifies, pursuant to 22 NYCRR 130-1.1-a that he/she has read the
within papers and that same are not frivolous as that term is defined in 22 NYCRR 130-1.1(c).
DERELL D. WILSON
===========================================================================
Service of a copy of the within is hereby admitted.
Dated, ________________________________
Attorney(s) for
===========================================================================
PLEASE TAKE NOTICE:
NOTICE OF ENTRY
that the within is a (certified) true copy of an duly entered in the
office of the clerk of the within named court on __________________2024.
NOTICE OF SETTLEMENT
that an order of which the within is a true copy
will be presented for settlement to the HON. one of the judges of the
within named Court, at on 2024
at________ O’clock ___.M.
Dated, _________________________
Yours, etc.
THE LAW OFFICES OF DERELL D. WILSON
THE LAW OFFICES OF DERELL D. WILSON
1225 FRANKLIN AVENUE, SUITE 325
GARDEN CITY, NY 11530
(516) 280-2081
8 of 8
Preview
FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS --------------------------------------------------------------------X TEKHI TAYLOR, Index No.: Date Purchased: Plaintiff, Plaintiff designates QUEENS County as the place of trial. -against- The basis of venue is Defendant’s residence DECHENG LI, SUMMONS Defendant’s residence: 13742 Geranium Avenue Flushing, NY 11355 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 Plaintiffs' Attorney within twenty (20) days after service of 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 in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. JURY TRIAL DEMANDED DATED: Garden City, New York April 13, 2024 THE LAW OFFICES OF DERELL D. WILSON Attorneys for Plaintiff By Derell D. Wilson 1225 Franklin Avenue, Suite 325 Garden City, New York 11530 (516) 280-2081 THE LAW OFFICES OF DERELL D. WILSON 1225 FRANKLIN AVENUE, SUITE 325 GARDEN CITY, NY 11530 (516) 280-2081 1 of 8 FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 Defendant’s Address: DECHENG LI 13742 Geranium Avenue Flushing, NY 11355 THE LAW OFFICES OF DERELL D. WILSON 1225 FRANKLIN AVENUE, SUITE 325 GARDEN CITY, NY 11530 (516) 280-2081 2 of 8 FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS -------------------------------------------------------------------x TEKHI TAYLOR, Plaintiff, -against- VERIFIED COMPLAINT DECHENG LI, Defendants. ------------------------------------------------------------------x Plaintiff, TEKHI TAYLOR, by his attorneys, THE LAW OFFICES OF DERELL D. WILSON, complains of the defendants, and alleges: 1. On or about December 7, 2022, and at all times relevant to this Complaint, the Plaintiff, TEKHI TAYLOR, was and is a resident of the County of Nassau, State of New York. 2. On or about December 7, 2022, and at all times relevant to this Complaint, Defendant, DECHENG LI, was and is a resident of the County of Queens, State of New York. 3. On or about December 7, 2022, and at all times relevant to this complaint Defendant, DECHENG LI, owned a 2015 TOYOTA SUBN. bearing a New York State License Plate Number JFW2855, hereinafter referred as “motor vehicle number one”. 4. On or about December 7, 2022, Defendant, DECHENG LI, operated a motor vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor vehicle number one, at or near the accident location. 5. On or about December 7, 2022, Defendant, DECHENG LI, controlled a motor vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor vehicle number one, at or near the accident location. THE LAW OFFICES OF DERELL D. WILSON 1225 FRANKLIN AVENUE, SUITE 325 GARDEN CITY, NY 11530 (516) 280-2081 3 of 8 FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 6. On or about December 7, 2022, Defendant, DECHENG LI, maintained a motor vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor vehicle number one, at or near the accident location. 7. On or about December 7, 2022, Defendant, DECHENG LI, inspected a motor vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor vehicle number one, at or near the accident location. 8. On or about December 7, 2022, Defendant, DECHENG LI, owned, operated, controlled, maintained and inspected a motor vehicle bearing a New York State License Plate Number JFW2855, the aforementioned motor vehicle number one, at or near the accident location. 9. On December 7, 2022, the aforementioned motor vehicle number one was owned and driven by Defendant, DECHENG LI. 10. On or about December 7, 2022, the Defendant, DECHENG LI, owned and operated a 2015 TOYOTA SUBN bearing a New York State License Plate Number JFW2855, the aforementioned motor vehicle number one, while on Fulton Street, Westbury at the intersection of Drexel Avenue, Westbury in the County of Nassau, New York (referred to as the “accident location”). 11. On December 7, 2022, the Plaintiff, TEKHI TAYLOR, was lawfully present as a pedestrian, at or near the accident location. 12. On or about December 7, 2022, motor vehicle number one operated by Defendant, DECHENG LI, violently struck the Plaintiff, TEKHI TAYLOR, at or near the accident location. 13. As a result of said accident, Plaintiff, TEKHI TAYLOR, was injured. 14. That as a result of the aforesaid violent collision , Plaintiff, TEKHI TAYLOR, was severely injured. THE LAW OFFICES OF DERELL D. WILSON 1225 FRANKLIN AVENUE, SUITE 325 GARDEN CITY, NY 11530 (516) 280-2081 4 of 8 FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 15. Plaintiff, TEKHI TAYLOR, sustained “serios’’ injuries as such term is defined by Section 5102 of the Insurance of the State of New York and being a covered person claiming against a covered person, is entitled to recover for non-economic loss, including pain, suffering, disfigurement and disability. Moreover, the Plaintiff is entitled to recover for such economic losses that exceed the basic economic loss. 16. That defendants were negligent by reason of the recklessness and carelessness in the ownership, operation, maintenance, management and control of the aforesaid motor vehicle; in failing to properly maintain, repair and care for the aforesaid motor vehicle; in failing to have same under reasonable and proper control; in failing to keep a proper lookout upon the highway; in failing to give due and proper warning of the movements of the said motor vehicle; in failing to slow or stop said motor vehicle in order to avoid the accident; in failing to heed traffic controls; in failing to signal or give signals; in failing to afford the plaintiff a reasonable opportunity to reach a place of safety; in operating the motor vehicle as to cause the same to come in contact with such objects and/or persons as were involved in said accident; in so operating the motor vehicle as to cause the same to be in such a position on the highway as to endanger the safety to others; in operating said motor vehicle at such speed at said location as to cause the same to be of danger to others, and in violating that statutes, ordinances and regulations (of which the Court will take Judicial notice) in such cases made and provided. WHEREFORE, Plaintiff, TEKHI TAYLOR, demands judgment against the Defendants, DECHENG LI , in a sum that exceeds the jurisdiction of all other courts lower than the Supreme Court of the State of New York together with the costs and disbursements and interests of this action. THE LAW OFFICES OF DERELL D. WILSON 1225 FRANKLIN AVENUE, SUITE 325 GARDEN CITY, NY 11530 (516) 280-2081 5 of 8 FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 DATED: Garden City, New York April 13, 2024 THE LAW OFFICES OF DERELL D. WILSON Attorneys for Plaintiff By Derell D. Wilson 1225 Franklin Avenue, Suite 325 Garden City, New York 11530 (516) 280-2081 THE LAW OFFICES OF DERELL D. WILSON 1225 FRANKLIN AVENUE, SUITE 325 GARDEN CITY, NY 11530 (516) 280-2081 6 of 8 FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 VERIFICATION STATE OF NEW YORK ) ) SS.: COUNTY OF QUEENS ) Derell D. Wilson, Esq., an attorney duly admitted to practice law in the Courts of this State, affirms the following under penalties of perjury: I am the attorney for the plaintiff in the above entitled-action. I have read the foregoing SUMMONS AND VERIFIED COMPLAINT and know the contents thereof, and upon information and belief, affirmant believes after an inquiry reasonable under the circumstances the matters alleged herein to be true, and that the contentions herein are not frivolous, as that term is defined in Part 130. The reason this verification is made by affirmant and not by plaintiff is that the plaintiff herein reside in a County other than the County in which we maintain our offices. The source of affirmant's information and the grounds of her belief are communications, papers, reports and investigations contained in the file maintained by this office. Dated: Garden City, New York April 13, 2024 Derell D. Wilson THE LAW OFFICES OF DERELL D. WILSON 1225 FRANKLIN AVENUE, SUITE 325 GARDEN CITY, NY 11530 (516) 280-2081 7 of 8 FILED: QUEENS COUNTY CLERK 04/16/2024 10:04 AM INDEX NO. 708079/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/16/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS --------------------------------------------------------------------X TEKHI TAYLOR, Plaintiff, Index No.: -against- DECHENG LI, Defendants. --------------------------------------------------------------------X ========================================================================== SUMMONS AND VERIFIED COMPLAINT ========================================================================== THE LAW OFFICES OF DERELL D. WILSON Attorneys for: Plaintiff 1225 Franklin Avenue, Suite 325 Garden City, New York 11530 (516) 280-2081 =========================================================================== The undersigned attorney hereby certifies, pursuant to 22 NYCRR 130-1.1-a that he/she has read the within papers and that same are not frivolous as that term is defined in 22 NYCRR 130-1.1(c). DERELL D. WILSON =========================================================================== Service of a copy of the within is hereby admitted. Dated, ________________________________ Attorney(s) for =========================================================================== PLEASE TAKE NOTICE: NOTICE OF ENTRY that the within is a (certified) true copy of an duly entered in the office of the clerk of the within named court on __________________2024. NOTICE OF SETTLEMENT that an order of which the within is a true copy will be presented for settlement to the HON. one of the judges of the within named Court, at on 2024 at________ O’clock ___.M. Dated, _________________________ Yours, etc. THE LAW OFFICES OF DERELL D. WILSON THE LAW OFFICES OF DERELL D. WILSON 1225 FRANKLIN AVENUE, SUITE 325 GARDEN CITY, NY 11530 (516) 280-2081 8 of 8