Preview
FILED: NASSAU COUNTY CLERK 04/19/2024 11:40 AM INDEX NO. 606821/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/19/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTYOF NASSAU
ic************************************************************
KERRY R. MEYERS
Plaintiff, COMPLAINT
V.
Index No.
TIMOTE LOUISSIANT,
Defendant.
*************************************************************
Plaintiff, KERRY R. MEYERS by her attorneys. CELLING LAW LLP for
her complaint against defendant, TIMOTE LOUISSIANT, alleges upon information and
belief:
1. At all times herein relevant plaintiff KERRY R. MEYERS, has been
a resident of the County of Nassau and State of New York.
2. At all times herein relevant defendant TIMOTE LOUISSIANT, has
been a resident of the County of Queens and State of New York.
3. On or about July 25. 2021, plaintiff KERRY R. MEYERS, was the
operator of a certain 2019 Honda bearing New York State License Plate No. HCS3687.
4. On or about July 25, 2021, defendant TIMOTE LOUISSIANT, was
the owner of a certain 2018 Toyota bearing New York State License Plate No.
KHF7948.
5. On or about July 25, 2021, at approximately 1:57 p.m., plaintiff
KERRY R. MEYERS, operated the vehicle described in Paragraph 3 above on East
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FILED: NASSAU COUNTY CLERK 04/19/2024 11:40 AM INDEX NO. 606821/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/19/2024
Broadway at or near its intersection with Neptune Boulevard in the City of Long Beach
County of Nassau, State of New York.
6. On or about July 25, 2021, at approximately 1:57 p.m., defendant
TIMOTE LOUISSIANT, operated the vehicle described in Paragraph 4 above on East
Broadway at or near its intersection with Neptune Boulevard in the City of Long Beach
County of Nassau, State of New York.
7. On or about July 25, 2021, at approximately 1:57 p.m., the vehicle
being operated by defendant TIMOTE LOUISSIANT, came in to contact with the vehicle
being operated by plaintiff KERRY R. MEYERS, on East Broadway at or near its
intersection with Neptune Boulevard in the City of Long Beach, County of Nassau, State
of New York.
8. As a result of the above referenced incident, plaintiff KERRY R.
MEYERS was injured.
9. The incident described in Paragraph 7 above occurred as a result
of defendant TIMOTE LOUISSIANT’s negligence and/or recklessness, without any
negligence attributable in any measure to plaintiff.
10. Plaintiff KERRY R. MEYERS, has sustained a serious injury as
defined in subsection (d) of section five thousand one hundred two of the New York
State Insurance Law.
11. Plaintiff KERRY R. MEYERS, has sustained economic loss greater
than basic economic loss, as defined in subsection (a) of section five thousand one
hundred two of the New York State Insurance Law.
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FILED: NASSAU COUNTY CLERK 04/19/2024 11:40 AM INDEX NO. 606821/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/19/2024
12. The limitations on liability set forth in CPLR Article 16 do not apply
herein: one or more of the exemptions set forth in CPLR Section 1602 applies
13. As a result of the negligence and/or recklessness of defendant
TIMOTE LOUISSIANT, as alleged above, plaintiff KERRY R. MEYERS, was injured and
has suffered damages in an amount which exceeds the monetary jurisdictional limits of
all lower New York State Courts.
WHEREFORE, Plaintiff KERRY R. MEYERS, demands judgment against
defendant TIMOTE LOUISSIANT in an amount which exceeds the monetary
jurisdictional limits of all lower New York State Courts and plaintiff KERRY R. MEYERS
demands such other, further and different relief as the Court may deem just and proper
together with the costs and disbursements of this action.
DATED: Melville, New York
April 18, 2024
Yours, etc.
CELLING LAV/LLP
By:
Abraham J. Meir, Esq.
Attorn^s for Plaintiff
401 Broadhollow Road, Suite 302
Melv/e, NY 11747
(888) 888-8888
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FILED: NASSAU COUNTY CLERK 04/19/2024 11:40 AM INDEX NO. 606821/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/19/2024
Index No;
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF
Kerry R. Meyers
Plaintiff(s)
V
Timote Louissiant
Defendant(s)
SUMMONS AND COMPLAINT
CELLINO LAW LLP
Attorneys for Plaintiff
Office & Post Office Address, Telephone
401 Broadhollow Road, Suite 302
Melville, New York 11747
(800) 555-5555
Service of a copy of the within is hereby admitted.
Dated: Melville, New York
, 2024
PLEASE TAKE NOTICE:
NOTICE OF ENTRY
that the within is a (certified) true copy of an Order
duly entered in the office of the clerk of the within named court on
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 at
Dated
Yours, etc.
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Preview
FILED: NASSAU COUNTY CLERK 04/19/2024 11:40 AM INDEX NO. 606821/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/19/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTYOF NASSAU ic************************************************************ KERRY R. MEYERS Plaintiff, COMPLAINT V. Index No. TIMOTE LOUISSIANT, Defendant. ************************************************************* Plaintiff, KERRY R. MEYERS by her attorneys. CELLING LAW LLP for her complaint against defendant, TIMOTE LOUISSIANT, alleges upon information and belief: 1. At all times herein relevant plaintiff KERRY R. MEYERS, has been a resident of the County of Nassau and State of New York. 2. At all times herein relevant defendant TIMOTE LOUISSIANT, has been a resident of the County of Queens and State of New York. 3. On or about July 25. 2021, plaintiff KERRY R. MEYERS, was the operator of a certain 2019 Honda bearing New York State License Plate No. HCS3687. 4. On or about July 25, 2021, defendant TIMOTE LOUISSIANT, was the owner of a certain 2018 Toyota bearing New York State License Plate No. KHF7948. 5. On or about July 25, 2021, at approximately 1:57 p.m., plaintiff KERRY R. MEYERS, operated the vehicle described in Paragraph 3 above on East 1 of 4 FILED: NASSAU COUNTY CLERK 04/19/2024 11:40 AM INDEX NO. 606821/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/19/2024 Broadway at or near its intersection with Neptune Boulevard in the City of Long Beach County of Nassau, State of New York. 6. On or about July 25, 2021, at approximately 1:57 p.m., defendant TIMOTE LOUISSIANT, operated the vehicle described in Paragraph 4 above on East Broadway at or near its intersection with Neptune Boulevard in the City of Long Beach County of Nassau, State of New York. 7. On or about July 25, 2021, at approximately 1:57 p.m., the vehicle being operated by defendant TIMOTE LOUISSIANT, came in to contact with the vehicle being operated by plaintiff KERRY R. MEYERS, on East Broadway at or near its intersection with Neptune Boulevard in the City of Long Beach, County of Nassau, State of New York. 8. As a result of the above referenced incident, plaintiff KERRY R. MEYERS was injured. 9. The incident described in Paragraph 7 above occurred as a result of defendant TIMOTE LOUISSIANT’s negligence and/or recklessness, without any negligence attributable in any measure to plaintiff. 10. Plaintiff KERRY R. MEYERS, has sustained a serious injury as defined in subsection (d) of section five thousand one hundred two of the New York State Insurance Law. 11. Plaintiff KERRY R. MEYERS, has sustained economic loss greater than basic economic loss, as defined in subsection (a) of section five thousand one hundred two of the New York State Insurance Law. 2 2 of 4 FILED: NASSAU COUNTY CLERK 04/19/2024 11:40 AM INDEX NO. 606821/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/19/2024 12. The limitations on liability set forth in CPLR Article 16 do not apply herein: one or more of the exemptions set forth in CPLR Section 1602 applies 13. As a result of the negligence and/or recklessness of defendant TIMOTE LOUISSIANT, as alleged above, plaintiff KERRY R. MEYERS, was injured and has suffered damages in an amount which exceeds the monetary jurisdictional limits of all lower New York State Courts. WHEREFORE, Plaintiff KERRY R. MEYERS, demands judgment against defendant TIMOTE LOUISSIANT in an amount which exceeds the monetary jurisdictional limits of all lower New York State Courts and plaintiff KERRY R. MEYERS demands such other, further and different relief as the Court may deem just and proper together with the costs and disbursements of this action. DATED: Melville, New York April 18, 2024 Yours, etc. CELLING LAV/LLP By: Abraham J. Meir, Esq. Attorn^s for Plaintiff 401 Broadhollow Road, Suite 302 Melv/e, NY 11747 (888) 888-8888 3 3 of 4 FILED: NASSAU COUNTY CLERK 04/19/2024 11:40 AM INDEX NO. 606821/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/19/2024 Index No; SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF Kerry R. Meyers Plaintiff(s) V Timote Louissiant Defendant(s) SUMMONS AND COMPLAINT CELLINO LAW LLP Attorneys for Plaintiff Office & Post Office Address, Telephone 401 Broadhollow Road, Suite 302 Melville, New York 11747 (800) 555-5555 Service of a copy of the within is hereby admitted. Dated: Melville, New York , 2024 PLEASE TAKE NOTICE: NOTICE OF ENTRY that the within is a (certified) true copy of an Order duly entered in the office of the clerk of the within named court on 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 at Dated Yours, etc. 4 of 4