Preview
FILED: KINGS COUNTY CLERK 04/29/2024 12:09 PM INDEX NO. 512027/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
Index No.
--- - -- -- - - -- - ---------------------------------------x
Plaintiff, Plaintiff's Residence in
KINGS County
against 461 Crescent Apt. 2F
Street,
Brooklyn, NY 11208
BORIS SACHAKOV,
The basis of venue designated is:
Defendant. residence.
Plaintiff(s)
--_____________________-------______-----------------_________-------Ç
To the above named Defendant(s)
On Art IJerebP 5tittitttotteb 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 plaintiffs 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 28, 2024
Harmon, Linder & Rogowsky, Esqs.
Attorneys for Plaintiff(s)
3 Park Avenue, 23rd Floor
Suite 2300
New York, NY 10016
Boris Sachakov
64-20 Saunders Street, Apt. C1
Flushing, NY 11374
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
______________________________________x
NASIR UDDIN RAJU,
Plaintiff(s), VERIFIED COMPLAINT
Index No.
-against-
BORIS SACHAKOV,
Defendant (s).
______________________________________Ç
Plaintiff, complaining of the defendant herein by his
attorneys, HARMON, LINDER & ROGOWSKY, ESQS., respectfully
set forth and alleges, as follows:
AS AND FOR A FIRST CAUSE OF ACTION
ON BEHALF OF PLAINTIFF NASIR UDDIN RAJU
1.That at the time of the commencement of this action
plaintiff, NASIR UDDIN RAJU, was a resident of the County of
KINGS, State of New York.
2. That at all times herein mentioned, defendant BORIS
SACHAKOV, was the owner and operator of a motor vehicle
bearing registration number ERB1833, State of New York.
3. That at all times mentioned plaintiff, NASIR UDDIN RAJU,
was a bicyclist lawfully traversing on 79 Avenue A, a
public street and thoroughfare County of New York, State of
New York.
4. That on the Eleventh Day of March 2024 at approximately
8:15 p.m. the aforesaid vehicle came into contact with
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plaintiff on 79 Avenue A, a public street and thoroughfare
County of New York, State of New York.
5. That the defendant so carelessly and negligently
operated their aforesaid vehicles 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 injuries
and was required to seek and obtain medical care and
attention in an effort to cure and alleviated same and
upon information and belief, will be compelled to do so in
the future,
7. That the aforesaid occurrences and the injuries
sustained by this plaintiff were caused by the negligence
of the defendant.
8. That this plaintiff has sustained a serious injury as
"d"
the same is defined in Subdivision of Section 5102
of the Insurance Law.
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, NASIR UDDIN
RAJU, has been damaged in an amount which exceeds the
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jurisdictional limits of all lower courts that would
otherwise jurisdiction.
AS AND FOR A SECOND CAUSE OF ACTION ON
BEHALF OF PLAINTIFF NASIR UDDIN RAJU
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 defendant so carelessly and negligently operated their
aforesaid respective motor vehicle so as to cause the aforesaid
contact.
13. 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.
14. 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.
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WHEREFORE, plaintiff, NASIR UDDIN RAJU, 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 and
plaintiff, NASIR UDDIN RAJU, demands judgement against the
defendant in the Second Cause of Action; all together with
the costs and disbursements of this action.
Dated: New York, NY
April 28, 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 28, 2024
Mark J. Linder, Esq.
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Index No. Year
SUPREME COURT OF THE STATE OF NEW Y ORK
COUNTY OF KINGS
____----_______-__________--__________________________________----------------_________________________________----
NASIR UDDIN RAJU,
Plaintiff,
-against-
BORIS SACHAKOV,
Defendant.
___-----------------_______________________________________--_____________________________------___________________
SUMMONS AND VERIFIED COMPLAINT
_______________-_______-_________________________________________________________-_________________________________
HARMON, LINDER & ROGOSWKY, ESQS.
Attorney for Plaintiff(s)
3 Park Avenue, 23rd Floor
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
O 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
O 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, Esqs.
Attorneys for
Plaintiff
3 Park Avenue, Suite 2300
New York, NY 10016
(212) 732-3665
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Preview
FILED: KINGS COUNTY CLERK 04/29/2024 12:09 PM INDEX NO. 512027/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No. --- - -- -- - - -- - ---------------------------------------x Plaintiff, Plaintiff's Residence in KINGS County against 461 Crescent Apt. 2F Street, Brooklyn, NY 11208 BORIS SACHAKOV, The basis of venue designated is: Defendant. residence. Plaintiff(s) --_____________________-------______-----------------_________-------Ç To the above named Defendant(s) On Art IJerebP 5tittitttotteb 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 plaintiffs 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 28, 2024 Harmon, Linder & Rogowsky, Esqs. Attorneys for Plaintiff(s) 3 Park Avenue, 23rd Floor Suite 2300 New York, NY 10016 Boris Sachakov 64-20 Saunders Street, Apt. C1 Flushing, NY 11374 1 of 7 FILED: KINGS COUNTY CLERK 04/29/2024 12:09 PM INDEX NO. 512027/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ______________________________________x NASIR UDDIN RAJU, Plaintiff(s), VERIFIED COMPLAINT Index No. -against- BORIS SACHAKOV, Defendant (s). ______________________________________Ç Plaintiff, complaining of the defendant herein by his attorneys, HARMON, LINDER & ROGOWSKY, ESQS., respectfully set forth and alleges, as follows: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF PLAINTIFF NASIR UDDIN RAJU 1.That at the time of the commencement of this action plaintiff, NASIR UDDIN RAJU, was a resident of the County of KINGS, State of New York. 2. That at all times herein mentioned, defendant BORIS SACHAKOV, was the owner and operator of a motor vehicle bearing registration number ERB1833, State of New York. 3. That at all times mentioned plaintiff, NASIR UDDIN RAJU, was a bicyclist lawfully traversing on 79 Avenue A, a public street and thoroughfare County of New York, State of New York. 4. That on the Eleventh Day of March 2024 at approximately 8:15 p.m. the aforesaid vehicle came into contact with 2 of 7 FILED: KINGS COUNTY CLERK 04/29/2024 12:09 PM INDEX NO. 512027/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 plaintiff on 79 Avenue A, a public street and thoroughfare County of New York, State of New York. 5. That the defendant so carelessly and negligently operated their aforesaid vehicles 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 injuries and was required to seek and obtain medical care and attention in an effort to cure and alleviated same and upon information and belief, will be compelled to do so in the future, 7. That the aforesaid occurrences and the injuries sustained by this plaintiff were caused by the negligence of the defendant. 8. That this plaintiff has sustained a serious injury as "d" the same is defined in Subdivision of Section 5102 of the Insurance Law. 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, NASIR UDDIN RAJU, has been damaged in an amount which exceeds the 3 of 7 FILED: KINGS COUNTY CLERK 04/29/2024 12:09 PM INDEX NO. 512027/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 jurisdictional limits of all lower courts that would otherwise jurisdiction. AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF PLAINTIFF NASIR UDDIN RAJU 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 defendant so carelessly and negligently operated their aforesaid respective motor vehicle so as to cause the aforesaid contact. 13. 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. 14. 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. 4 of 7 FILED: KINGS COUNTY CLERK 04/29/2024 12:09 PM INDEX NO. 512027/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 WHEREFORE, plaintiff, NASIR UDDIN RAJU, 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 and plaintiff, NASIR UDDIN RAJU, demands judgement against the defendant in the Second Cause of Action; all together with the costs and disbursements of this action. Dated: New York, NY April 28, 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 5 of 7 FILED: KINGS COUNTY CLERK 04/29/2024 12:09 PM INDEX NO. 512027/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 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 28, 2024 Mark J. Linder, Esq. 6 of 7 FILED: KINGS COUNTY CLERK 04/29/2024 12:09 PM INDEX NO. 512027/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 Index No. Year SUPREME COURT OF THE STATE OF NEW Y ORK COUNTY OF KINGS ____----_______-__________--__________________________________----------------_________________________________---- NASIR UDDIN RAJU, Plaintiff, -against- BORIS SACHAKOV, Defendant. ___-----------------_______________________________________--_____________________________------___________________ SUMMONS AND VERIFIED COMPLAINT _______________-_______-_________________________________________________________-_________________________________ HARMON, LINDER & ROGOSWKY, ESQS. Attorney for Plaintiff(s) 3 Park Avenue, 23rd Floor 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 O 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 O 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, Esqs. Attorneys for Plaintiff 3 Park Avenue, Suite 2300 New York, NY 10016 (212) 732-3665 7 of 7