Preview
FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No.
-----------------------------------------------------------x
TAREQ RAHMAN and ALIFA RAHMAN,
Plaintiff, Defendant(s)Reside
In Kings County
against
The basis of venue designated is:
ZAIN AHMED, Defendant(s) residence.
Defendant,
__-_______________--____--__--____________________________-____------Ç
To the above named Defendant(s)
ott are IJerelly glittittttotteh to answer the complaint in this action, and to serve a copy
of your answer, of 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 services 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 19, 2024
Harmon, Linder & Rogowsky
Attorneys for Plaintif(s)
3 Park Avenue, Suite 2300
New York, NY 10016
Defendant's Address:
Zain Ahmed
2669 Batchelder Street Apt 1
Brooklyn, NY 11235
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------x
TAREQ RAHMAN and ALIFA RAHMAN
VERIFIED COMPLAINT
INDEX NO:
Plaintiff(s),
-against-
ZAIN AHMED,
Defendant(s).
--------------------------------------x
Plaintiffs, complaining of the defendant herein by their
attorneys, HARMON, LINDER & ROGOWSKY, ESQS., respectfully sets
forth and alleges, as follows:
AS AND FOR A FIRST CAUSE OF ACTION
ON BEHALF OF TAREQ RAHMAN
1. That at the time of the commencement of this action
defendant, ZAIN AHMED, was a resident of the County of KINGS,
State of New York.
2. That at all times herein mentioned defendant, ZAIN AHMED, was
the owner and the operator an automobile bearing registration
number LBL3174, State of New York.
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3. That at all times herein mentioned, plaintiff, TAREQ RAHMAN,
was the owner and the operator of the vehicle, bearing
registration number Y202631C, State of New York.
4. That on the FIFTH Day of JULY 2023, at approximately 12:20
a.m. defendant's vehicle came into contact with plaintiff's
vehicle on 87-25 167 STREET, a public street and thoroughfare,
in the County QUEENS, State of New York.
5. That defendant so carelessly and negligently operated their
aforesaid respective motor vehicle so as to cause the aforesaid
contact.
6. That as a result of the foregoing, this plaintiff was caused
to and did sustain severe and serious personal injuries and was
required to seek and obtain medical care and attention in an
effort to cure and/or alleviate the same and upon information
and belief, will be so compelled to do in future.
7. That the aforesaid occurrence and injuries sustained by this
plaintiff were caused by the negligence of the defendant and not
by any act or omission on the part of this plaintiff
contributing thereto.
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8. That this plaintiff has sustained a serious injury as the
same is defined in Subdivision (d) of Section 5102 of the
Insurance Law of the State of New York.
9. That this action falls within one or more of the exceptions
set forth in Section 1602 of the CPLR.
10. That by reason of the foregoing, plaintiff, TAREQ RAHMAN,
has been damaged in an amount which exceeds the jurisdictional
limits of all lower courts that would otherwise have
jurisdiction.
AS AND FOR THE SECOND CAUSE OF ACTION ON
BEHALF OF PLAINTIFF ALIFA RAHMAN
11. This plaintiff repeats, reiterates and realleges each and
every allegation contained in paragraphs of this complaint
"1"
numbered through "10", inclusive, with the same force and
effect as though the same were more fully set forth at length
herein.
12. That at all times herein mentioned, plaintiff, ALIFA RAHMAN,
was a passenger of the aforesaid the vehicle, bearing
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registration number Y202631C, State of New York.
13. That defendant so carelessly and negligently operated their
aforesaid respective motor vehicle so as to cause the aforesaid
contact.
14. That as a result of the foregoing, this plaintiff was caused
to and did sustain severe and serious personal injuries and was
required to seek and obtain medical care and attention in an
effort to cure and/or alleviate the same and upon information
and belief, will be so compelled to do in future.
15. That the aforesaid occurrence and injuries sustained by this
plaintiff were caused by the negligence of the defendant and not
by any act or omission on the part of this plaintiff
contributing thereto.
16. That this plaintiff has sustained a serious injury as the
same is defined in Subdivision (d) of Section 5102 of the
Insurance Law of the State of New York.
17. That this action falls within one or more of the exceptions
set forth in Section 1602 of the CPLR.
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18. That by reason of the foregoing, plaintiff, ALIFA RAHNAN,
has been damaged in an amount which exceeds the jurisdictional
limits of all lower courts that would otherwise have
jurisdiction.
AS AND FOR A THIRD CAUSE OF ACTION ON
BEHALF OF PLAINTIFF TAREQ RAHMAN
19. This plaintiff repeats, reiterates and realleges each and
every allegation contained in paragraphs of this complaint
"1"
numbered through "18", inclusive, with the same force and
II
effect as though the same were more fully set forth at length
herein.
20. That defendant so carelessly and negligently operated their
aforesaid respective motor vehicle so as to cause the aforesaid
contact.
21. That as a result of the foregoing, this plaintiff's
aforesaid vehicle was caused to and did sustain property damage
and this plaintiff was required to seek and obtain mechanical
attention in an effort to repair the damages.
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22. That the aforesaid occurrence and property damage sustained
by this plaintiff's vehicle was caused by the negligence of the
defendant and not by any act or omission on the part of this
plaintiff contributing thereto.
WHEREFORE, plaintiff, TAREQ RAHMAN, demands judgement
against the defendant in the First Cause of Action in an amount
which exceeds the jurisdictional limits of all lower courts that
would otherwise have jurisdiction; plaintiff, ALIFA RAHMAN,
demands judgement against the defendant in the Second Cause of
Action in an amount which exceeds the jurisdictional limits of
all lower courts that would otherwise have jurisdiction and
plaintiff, TAREQ RAHMAN, demands judgement against the defendant
in the Third Cause of Action all together with the costs and
disbursements of this action.
Dated: New York, NY
April 19, 2024
HARMON, LINDER & ROGOWSKY, ESQS.
Attorney(s) for Plaintiff(s)
3 Park Avenue, Suite 2300
New York, New York 10016
(212) 732-3665
MJL/AS
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ATTORNEY'S VERIFICATION
STATE OF NEW YORK )
) ss:
COUNTY OF NEW YORK)
I, the undersigned, am an attorney admitted to practice in the Courts of New York State,
and say that:
I am the attorney of record or of counsel with the attorney(s) of record for plaintiff.
I have read the annexed SUMMONS AND VERIFIED COMPLAINT and know the
contents thereof and the same are true to my knowledge, except those matters therein which are
stated to be alleged on information and belief. As to those matters, I believe them to be true.
My belief, as to those matters therein not stated upon knowledge is based upon the following:
Interviews and/or discussions with the plaintiff(s) and papers and/or documents in the file.
The reasons I make this affirmation instead of the plaintiff is because said plaintiff
resides outside of the county from where your deponent maintains his office for the practice of
law.
Dated: New York, New York
April 19, 2024
Mark J. Linder Esq.,
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Index No. Year
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
______________________________________-_________________________________________________
TAREQ RAHMAN and AL I FA RAHMAN,
Plaintiff,
-against-
Z AIN AHME D,
Defendant.
_________________________________________________-_____________________
SUMMONS AND VERIFIED COMPLAINT
_______________________________________________________________________________
HARMON, LINDER & ROGOSWKY, ESQS.
Attorney for Plaintiff(s)
3 Park Avenue, Suite 2300
New York, NY 10016
(212) 732-3665 Phone
(212) 732-1462 Facsimile
____________________________-----______________________________________
To:
Attorney(s) for Defendant
______________________________________----------_________
Service of a copy of the within Summons and Complaint is hereby admitted.
Dated:
Attorney(s) for
_______________________________________---------------------------
PLEASE TAKE NOTICE
¡ Notice of Entry that the within is a (certified) true copy of a
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 .
Dated:
Yours, etc.
Harmon, Linder & Rogowsky
Attorneys for
Plaintiff
3 Park Avenue, Suite 2300
New York, NY 10016
(212) 732-3665
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Preview
FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No. -----------------------------------------------------------x TAREQ RAHMAN and ALIFA RAHMAN, Plaintiff, Defendant(s)Reside In Kings County against The basis of venue designated is: ZAIN AHMED, Defendant(s) residence. Defendant, __-_______________--____--__--____________________________-____------Ç To the above named Defendant(s) ott are IJerelly glittittttotteh to answer the complaint in this action, and to serve a copy of your answer, of 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 services 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 19, 2024 Harmon, Linder & Rogowsky Attorneys for Plaintif(s) 3 Park Avenue, Suite 2300 New York, NY 10016 Defendant's Address: Zain Ahmed 2669 Batchelder Street Apt 1 Brooklyn, NY 11235 1 of 9 FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------x TAREQ RAHMAN and ALIFA RAHMAN VERIFIED COMPLAINT INDEX NO: Plaintiff(s), -against- ZAIN AHMED, Defendant(s). --------------------------------------x Plaintiffs, complaining of the defendant herein by their attorneys, HARMON, LINDER & ROGOWSKY, ESQS., respectfully sets forth and alleges, as follows: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF TAREQ RAHMAN 1. That at the time of the commencement of this action defendant, ZAIN AHMED, was a resident of the County of KINGS, State of New York. 2. That at all times herein mentioned defendant, ZAIN AHMED, was the owner and the operator an automobile bearing registration number LBL3174, State of New York. 2 of 9 FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 3. That at all times herein mentioned, plaintiff, TAREQ RAHMAN, was the owner and the operator of the vehicle, bearing registration number Y202631C, State of New York. 4. That on the FIFTH Day of JULY 2023, at approximately 12:20 a.m. defendant's vehicle came into contact with plaintiff's vehicle on 87-25 167 STREET, a public street and thoroughfare, in the County QUEENS, State of New York. 5. That defendant so carelessly and negligently operated their aforesaid respective motor vehicle so as to cause the aforesaid contact. 6. That as a result of the foregoing, this plaintiff was caused to and did sustain severe and serious personal injuries and was required to seek and obtain medical care and attention in an effort to cure and/or alleviate the same and upon information and belief, will be so compelled to do in future. 7. That the aforesaid occurrence and injuries sustained by this plaintiff were caused by the negligence of the defendant and not by any act or omission on the part of this plaintiff contributing thereto. 3 of 9 FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 8. That this plaintiff has sustained a serious injury as the same is defined in Subdivision (d) of Section 5102 of the Insurance Law of the State of New York. 9. That this action falls within one or more of the exceptions set forth in Section 1602 of the CPLR. 10. That by reason of the foregoing, plaintiff, TAREQ RAHMAN, has been damaged in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction. AS AND FOR THE SECOND CAUSE OF ACTION ON BEHALF OF PLAINTIFF ALIFA RAHMAN 11. This plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs of this complaint "1" numbered through "10", inclusive, with the same force and effect as though the same were more fully set forth at length herein. 12. That at all times herein mentioned, plaintiff, ALIFA RAHMAN, was a passenger of the aforesaid the vehicle, bearing 4 of 9 FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 registration number Y202631C, State of New York. 13. That defendant so carelessly and negligently operated their aforesaid respective motor vehicle so as to cause the aforesaid contact. 14. That as a result of the foregoing, this plaintiff was caused to and did sustain severe and serious personal injuries and was required to seek and obtain medical care and attention in an effort to cure and/or alleviate the same and upon information and belief, will be so compelled to do in future. 15. That the aforesaid occurrence and injuries sustained by this plaintiff were caused by the negligence of the defendant and not by any act or omission on the part of this plaintiff contributing thereto. 16. That this plaintiff has sustained a serious injury as the same is defined in Subdivision (d) of Section 5102 of the Insurance Law of the State of New York. 17. That this action falls within one or more of the exceptions set forth in Section 1602 of the CPLR. 5 of 9 FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 18. That by reason of the foregoing, plaintiff, ALIFA RAHNAN, has been damaged in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction. AS AND FOR A THIRD CAUSE OF ACTION ON BEHALF OF PLAINTIFF TAREQ RAHMAN 19. This plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs of this complaint "1" numbered through "18", inclusive, with the same force and II effect as though the same were more fully set forth at length herein. 20. That defendant so carelessly and negligently operated their aforesaid respective motor vehicle so as to cause the aforesaid contact. 21. That as a result of the foregoing, this plaintiff's aforesaid vehicle was caused to and did sustain property damage and this plaintiff was required to seek and obtain mechanical attention in an effort to repair the damages. 6 of 9 FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 22. That the aforesaid occurrence and property damage sustained by this plaintiff's vehicle was caused by the negligence of the defendant and not by any act or omission on the part of this plaintiff contributing thereto. WHEREFORE, plaintiff, TAREQ RAHMAN, demands judgement against the defendant in the First Cause of Action in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction; plaintiff, ALIFA RAHMAN, demands judgement against the defendant in the Second Cause of Action in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction and plaintiff, TAREQ RAHMAN, demands judgement against the defendant in the Third Cause of Action all together with the costs and disbursements of this action. Dated: New York, NY April 19, 2024 HARMON, LINDER & ROGOWSKY, ESQS. Attorney(s) for Plaintiff(s) 3 Park Avenue, Suite 2300 New York, New York 10016 (212) 732-3665 MJL/AS 7 of 9 FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 ATTORNEY'S VERIFICATION STATE OF NEW YORK ) ) ss: COUNTY OF NEW YORK) I, the undersigned, am an attorney admitted to practice in the Courts of New York State, and say that: I am the attorney of record or of counsel with the attorney(s) of record for plaintiff. I have read the annexed SUMMONS AND VERIFIED COMPLAINT and know the contents thereof and the same are true to my knowledge, except those matters therein which are stated to be alleged on information and belief. As to those matters, I believe them to be true. My belief, as to those matters therein not stated upon knowledge is based upon the following: Interviews and/or discussions with the plaintiff(s) and papers and/or documents in the file. The reasons I make this affirmation instead of the plaintiff is because said plaintiff resides outside of the county from where your deponent maintains his office for the practice of law. Dated: New York, New York April 19, 2024 Mark J. Linder Esq., 8 of 9 FILED: KINGS COUNTY CLERK 04/23/2024 03:31 PM INDEX NO. 511606/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2024 Index No. Year SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ______________________________________-_________________________________________________ TAREQ RAHMAN and AL I FA RAHMAN, Plaintiff, -against- Z AIN AHME D, Defendant. _________________________________________________-_____________________ SUMMONS AND VERIFIED COMPLAINT _______________________________________________________________________________ HARMON, LINDER & ROGOSWKY, ESQS. Attorney for Plaintiff(s) 3 Park Avenue, Suite 2300 New York, NY 10016 (212) 732-3665 Phone (212) 732-1462 Facsimile ____________________________-----______________________________________ To: Attorney(s) for Defendant ______________________________________----------_________ Service of a copy of the within Summons and Complaint is hereby admitted. Dated: Attorney(s) for _______________________________________--------------------------- PLEASE TAKE NOTICE ¡ Notice of Entry that the within is a (certified) true copy of a 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 . Dated: Yours, etc. Harmon, Linder & Rogowsky Attorneys for Plaintiff 3 Park Avenue, Suite 2300 New York, NY 10016 (212) 732-3665 9 of 9