Preview
FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
-----------------------------------------------------------------x Index No.
BIBI A. SHAFIEK,
Date Filed:
Plaintiff,
Plaintiff designates: QUEENS
-against- County as the place of trial
The basis of venue is:
GREEN ACRES ADJACENT LLC, Plaintiff’s residence
Defendant. SUMMONS
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Plaintiff’s address:
132-47 114th Street
South Ozone Park, New York 11420
To the above named Defendant(s):
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, within 20 days after the 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.
Dated: New York, New York
April 29, 2024
REDMOND LAW FIRM, PLLC
By:
Cornelius Redmond, Esq.
Attorneys for Plaintiff
80 Broad Street, Suite 1202
New York, New York 10004
(212) 799-8989
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Defendant’s Address:
GREEN ACRES ADJACENT LLC
c/o C T Corporation System
28 Liberty Street
New York, New York 10005
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
-----------------------------------------------------------------x Index No.
BIBI A. SHAFIEK,
VERIFIED COMPLAINT
Plaintiff,
-against-
GREEN ACRES ADJACENT LLC,
Defendant.
-----------------------------------------------------------------x
Plaintiff, by her attorneys, REDMOND LAW FIRM, PLLC complaining of the
Defendant, all upon information and belief, respectfully states and alleges as follows:
1. That at all times herein mentioned, the plaintiff BIBI A. SHAFIEK was a resident
of the County of Queens, City of South Ozone Park and State of New York.
2. That at all times herein mentioned, the occurrence that gave rise to this action
occurred in the County of Nassau, City of Valley Stream and State of New York.
3. That upon information and belief, at all times herein mentioned, the defendant
GREEN ACRES ADJACENT LLC (said defendant hereinafter referred to as “GREEN
ACRES”) was a foreign limited liability company duly authorized to do business within the State
of New York.
4. That upon information and belief, at all times herein mentioned, the defendant
GREEN ACRES was a partnership transacting business in the State of New York.
5. That upon information and belief, at all times herein mentioned, the defendant
GREEN ACRES was a business entity doing business within the State of New York.
6. That on or about February 1, 2022, the defendant, GREEN ACRES, owned the
premises located at 5 Green Acres Rd S, Valley Stream, New York 11581.
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7. That on or about said date, the defendant, GREEN ACRES, was a lessor of the
subject premises.
8. That on or about said date, the defendant, GREEN ACRES, was a lessee of the
subject premises.
9. That on or about said date, the defendant, GREEN ACRES, occupied the subject
premises.
10. That on or about said date, the defendant, GREEN ACRES, managed the subject
premises.
11. That on or about said date, the defendant, GREEN ACRES, acted as the managing
agent of the subject premises.
12. That on or about said date, the defendant, GREEN ACRES, controlled the subject
premises.
13. That on or about February 1, 2022, the defendant, GREEN ACRES, maintained
the subject premises, and more particularly the parking lot located on the subject premises.
14. That on or about said date, the defendant, GREEN ACRES, was responsible for
maintaining the subject parking lot.
15. That on or about said date the defendant, GREEN ACRES, inspected the subject
parking lot.
16. That on or about said date the defendant, GREEN ACRES, was responsible for
inspecting the subject parking lot.
17. That on or about said date the defendant, GREEN ACRES, repaired the subject
parking lot.
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18. That on or about said date the defendant, GREEN ACRES, was responsible for
repairing the subject parking lot.
19. That the Defendant, its agents, servants and/or employees operated, supervised,
managed, maintained and were in sole charge and control of all portions of the aforesaid
premises available to and used by the various persons in common and all other persons lawfully
on the premises.
20. That the Defendant reserved to itself, its agents, servants and/or employees, the
right to come onto the aforesaid premises for the purpose of inspection, repair and maintaining
those parts used by or available to all of the persons in common, in a reasonably safe condition.
21. That the plaintiff was lawfully on the Defendant’s subject premises.
22. That on said date and place, the Defendant had charge of the subject location, and
it was the duty of said Defendant, its agents, servants and/or employees to use reasonable care
and diligence in the maintenance, operation, and care of the subject parking lot and to maintain
same, for the purpose of keeping same in a reasonably safe condition for users thereof.
23. That on said date while the plaintiff was lawfully on said premises, she was
caused to slip and fall on black ice in parking lot and to be injured due to the slippery, wet, icy,
defective, hazardous, unsafe, dangerous condition thereat, causing plaintiff to sustain severe and
serious personal injuries with attendant special damages.
24. That on said date the Defendant, its agents, servants and/or employees, reserved
to itself the right and duty of general supervision, maintenance, operation and control, at the
aforesaid location and premises, and did in fact exercise such right of supervision, maintenance,
operation and control.
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25. That on said date and place, the Defendant had charge of the subject premises,
and it was the duty of said Defendant, its agents, servants and/or employees to use reasonable
care and diligence in the management, operation, care and maintenance of the subject premises
and to make any and all necessary markings, warning, repairs thereto, for the purpose of keeping
the same in a reasonably safe condition for travelers traversing thereat.
26. That the said occurrence and the injuries resulting therefrom were caused and/or
precipitated by reason of the negligence and carelessness of the Defendant, its agents, servants,
independent contractors and/or employees, in that it negligently caused, allowed and permitted
the subject dangerous and defective premises to be, become and remain in a defective and
dangerous condition so that a trap existed on the aforesaid premises; there being a great
impediment on said premises, endangering persons lawfully traversing thereat.
27. That upon information and belief at all times herein mentioned the Defendant, its
agents, servants, independent contractors and/or employees had actual and/or constructive notice
of the aforesaid dangerous and defective condition and/or created the dangerous condition.
28. That on or about said date and at all times mentioned herein, the plaintiff would
not have been caused to be injured on the subject premises in the absence of negligence on the
part of the Defendant.
29. That on or about said date and at all times mentioned herein, the subject premises
was within the exclusive control of the Defendant.
30. That the said occurrence and the injuries resulting therefrom were caused and/or
precipitated by reason of the negligence and carelessness of the Defendant, its agents, servants,
independent contractors and/or employees solely and wholly as a result of the negligence of the
Defendant herein and without any negligence on the part of the plaintiff contributing thereto.
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31. That at no time between its receipt of the notice of said dangerous condition
complained of and February 1, 2022, did the Defendant, its agents, servants and/or employees
ever cure, correct or in any way repair the dangerous premises condition complained of.
32. That on or about said date and at all times mentioned herein, the plaintiff was
caused to be injured on the subject premises due to the doctrine of res ipsa loquitur.
33. That on or about said date and at all times mentioned herein, the plaintiff was
caused to be injured on the subject premises due to a recurring condition.
34. That on or about said date and at all times mentioned herein, the plaintiff would
not have slipped and due to slippery, icy, wet, defective, hazardous, unsafe, dangerous condition
on the premises in the absence of negligence on the part of the Defendant.
35. The Defendant, GREEN ACRES, its agents, servants and/or employees and/or
contractors were negligent and careless in the ownership, operation, maintenance, supervision,
repair, care and control of the aforesaid premises; in creating, continuing, causing, acquiescing
in, permitting, maintaining and allowing the aforesaid premises to be, become and remain in an
unsafe, dangerous and hazardous condition and failing to provide a safe means of egress and
ingress from the subject premises.
36. The Defendant, GREEN ACRES, was negligent and careless in the ownership,
operation, maintenance, supervision, inspection, repair, care, and control of the aforesaid
premises in creating, continuing, causing, acquiescing in, permitting, maintaining and allowing
the aforesaid premises to be, become and remain in a unsafe, dangerous and hazardous condition
all of which constituted a nuisance and impediment and a grave danger and hazard, endangering
the persons lawfully traversing there over.
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37. The Defendant, GREEN ACRES, its agents, servants and/or employees and/or
contractors were negligent in disregarding its duty to maintain the premises in their exclusive
control in a reasonably safe condition and in a condition of good repair and maintenance; in
failing to properly remedy the aforesaid dangerous condition and in allowing it to exist; in
causing, allowing and permitting an inherently dangerous condition and trap to be, become and
remain on the said premises.
38. That the said occurrence and the injuries resulting therefrom were caused and/or
precipitated by reason of the negligence and carelessness of the Defendant, its agents, servants,
independent contractors and/or employees solely and wholly as a result of the negligence of the
Defendant herein and without any negligence on the part of the plaintiff contributing thereto.
39. That upon information and belief at all times herein mentioned the Defendant, its
agents, servants, independent contractors and/or employees had actual and/or constructive notice
of the aforesaid dangerous and defective condition and/or created the dangerous condition.
40. That on or about said date and at all times mentioned herein, the plaintiff would
not have been caused to be injured on the subject premises in the absence of negligence on the
part of the Defendant.
41. That on or about said date and at all times mentioned herein, the subject premises
was within the exclusive control of the Defendant.
42. That this action falls within one or more of the exceptions contained in CPLR §
1602.
43. That by reason of the foregoing the plaintiff sustained severe injuries to various
parts of plaintiff’s body specially neck, shoulder, back, chest, stomach and tail bone; that
plaintiff suffered and will continue to suffer for some time to come great pain and anguish in
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body and mind; that plaintiff received necessary hospital care and attention for a long period of
time; that plaintiff necessarily received and will continue to receive medical treatment and
medicines for which expenses have, are and will continue to be incurred; that as a result of the
injuries sustained by plaintiff, plaintiff may, in the future, require further hospital and medical
care and attention; that plaintiff has been unable to return to plaintiff’s usual duties and
occupation as plaintiff had theretofore done and, upon information and belief, plaintiff’s injuries
are permanent, protracted and disabling in nature all to plaintiff’s damage as against the
Defendant in a sum which exceeds the jurisdictional limits of all lower courts of the State of
New York.
WHEREFORE, plaintiff demands judgment against the Defendant in an amount which
exceeds the jurisdictional limits of the lower courts of the State of New York, together with the
costs and disbursements of this action.
Dated: New York, New York
April 29, 2024
REDMOND LAW FIRM, PLLC
By:
Cornelius Redmond, Esq.
Attorneys for Plaintiff
80 Broad Street, Suite 1202
New York, New York 10004
(212) 799-8989
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VERIFICATION
STATE OF NEW YORK }
} ss:
COUNTY OF NEW YORK }
I, the undersigned, an attorney duly admitted to practice law in the State of New York,
state that I am a member of the firm REDMOND LAW FIRM, PLLC, attorneys of record for the
plaintiff in the within action; I have read the foregoing
COMPLAINT
and know the contents thereof; the same is true to my own knowledge except as to those matters
therein stated to be alleged upon information and belief, and as to those matters, I believe to be
true. The reason this verification is made by me and not by the plaintiff is that deponent
maintains offices outside the County in which plaintiff resides.
The grounds of my belief as to all matters not stated upon my knowledge, are as follows:
entire file maintained in your deponent’s offices, investigations, etc.
I affirm that the foregoing statements are true, under the penalties of perjury.
Dated: New York, New York
April 29, 2024
By:
Cornelius Redmond, Esq.
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SUPREME COURT OF THE STATE OF NEW YORK INDEX NO.
COUNTY OF QUEENS
BIBI A. SHAFIEK,
Plaintiff,
-against-
GREEN ACRES ADJACENT LLC,
Defendant.
SUMMONS AND VERIFIED COMPLAINT
REDMOND LAW FIRM, PLLC
Attorneys for Plaintiff
80 Broad Street, Suite 1202
New York, New York 10004
(212) 799-8989
Pursuant to 22NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the
Courts of New York State, certifies that, upon information and belief and reasonable inquiry,
the contentions contained in the annexed document are not frivolous
CORNELIUS REDMOND, ESQ.
REDMOND LAW FIRM, PLLC
_________________________________________________________________________________
[ ] Notice of Entry
that the within is a (certified) true copy of a
duly entered in the Office of the Clerk of the within named court on 20
[ ] Notice of Settlement
that an order of which the within is a true copy
will be presented to the Hon. one of the judges of the within court at
on 20 at M.
Dated: Yours, etc.
REDMOND LAW FIRM, PLLC
80 Broad Street, Suite 1202
New York, New York 10004
(212) 799-8989
11 of 11
Preview
FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS -----------------------------------------------------------------x Index No. BIBI A. SHAFIEK, Date Filed: Plaintiff, Plaintiff designates: QUEENS -against- County as the place of trial The basis of venue is: GREEN ACRES ADJACENT LLC, Plaintiff’s residence Defendant. SUMMONS -----------------------------------------------------------------x Plaintiff’s address: 132-47 114th Street South Ozone Park, New York 11420 To the above named Defendant(s): 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, within 20 days after the 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. Dated: New York, New York April 29, 2024 REDMOND LAW FIRM, PLLC By: Cornelius Redmond, Esq. Attorneys for Plaintiff 80 Broad Street, Suite 1202 New York, New York 10004 (212) 799-8989 1 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 Defendant’s Address: GREEN ACRES ADJACENT LLC c/o C T Corporation System 28 Liberty Street New York, New York 10005 2 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS -----------------------------------------------------------------x Index No. BIBI A. SHAFIEK, VERIFIED COMPLAINT Plaintiff, -against- GREEN ACRES ADJACENT LLC, Defendant. -----------------------------------------------------------------x Plaintiff, by her attorneys, REDMOND LAW FIRM, PLLC complaining of the Defendant, all upon information and belief, respectfully states and alleges as follows: 1. That at all times herein mentioned, the plaintiff BIBI A. SHAFIEK was a resident of the County of Queens, City of South Ozone Park and State of New York. 2. That at all times herein mentioned, the occurrence that gave rise to this action occurred in the County of Nassau, City of Valley Stream and State of New York. 3. That upon information and belief, at all times herein mentioned, the defendant GREEN ACRES ADJACENT LLC (said defendant hereinafter referred to as “GREEN ACRES”) was a foreign limited liability company duly authorized to do business within the State of New York. 4. That upon information and belief, at all times herein mentioned, the defendant GREEN ACRES was a partnership transacting business in the State of New York. 5. That upon information and belief, at all times herein mentioned, the defendant GREEN ACRES was a business entity doing business within the State of New York. 6. That on or about February 1, 2022, the defendant, GREEN ACRES, owned the premises located at 5 Green Acres Rd S, Valley Stream, New York 11581. 3 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 7. That on or about said date, the defendant, GREEN ACRES, was a lessor of the subject premises. 8. That on or about said date, the defendant, GREEN ACRES, was a lessee of the subject premises. 9. That on or about said date, the defendant, GREEN ACRES, occupied the subject premises. 10. That on or about said date, the defendant, GREEN ACRES, managed the subject premises. 11. That on or about said date, the defendant, GREEN ACRES, acted as the managing agent of the subject premises. 12. That on or about said date, the defendant, GREEN ACRES, controlled the subject premises. 13. That on or about February 1, 2022, the defendant, GREEN ACRES, maintained the subject premises, and more particularly the parking lot located on the subject premises. 14. That on or about said date, the defendant, GREEN ACRES, was responsible for maintaining the subject parking lot. 15. That on or about said date the defendant, GREEN ACRES, inspected the subject parking lot. 16. That on or about said date the defendant, GREEN ACRES, was responsible for inspecting the subject parking lot. 17. That on or about said date the defendant, GREEN ACRES, repaired the subject parking lot. 4 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 18. That on or about said date the defendant, GREEN ACRES, was responsible for repairing the subject parking lot. 19. That the Defendant, its agents, servants and/or employees operated, supervised, managed, maintained and were in sole charge and control of all portions of the aforesaid premises available to and used by the various persons in common and all other persons lawfully on the premises. 20. That the Defendant reserved to itself, its agents, servants and/or employees, the right to come onto the aforesaid premises for the purpose of inspection, repair and maintaining those parts used by or available to all of the persons in common, in a reasonably safe condition. 21. That the plaintiff was lawfully on the Defendant’s subject premises. 22. That on said date and place, the Defendant had charge of the subject location, and it was the duty of said Defendant, its agents, servants and/or employees to use reasonable care and diligence in the maintenance, operation, and care of the subject parking lot and to maintain same, for the purpose of keeping same in a reasonably safe condition for users thereof. 23. That on said date while the plaintiff was lawfully on said premises, she was caused to slip and fall on black ice in parking lot and to be injured due to the slippery, wet, icy, defective, hazardous, unsafe, dangerous condition thereat, causing plaintiff to sustain severe and serious personal injuries with attendant special damages. 24. That on said date the Defendant, its agents, servants and/or employees, reserved to itself the right and duty of general supervision, maintenance, operation and control, at the aforesaid location and premises, and did in fact exercise such right of supervision, maintenance, operation and control. 5 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 25. That on said date and place, the Defendant had charge of the subject premises, and it was the duty of said Defendant, its agents, servants and/or employees to use reasonable care and diligence in the management, operation, care and maintenance of the subject premises and to make any and all necessary markings, warning, repairs thereto, for the purpose of keeping the same in a reasonably safe condition for travelers traversing thereat. 26. That the said occurrence and the injuries resulting therefrom were caused and/or precipitated by reason of the negligence and carelessness of the Defendant, its agents, servants, independent contractors and/or employees, in that it negligently caused, allowed and permitted the subject dangerous and defective premises to be, become and remain in a defective and dangerous condition so that a trap existed on the aforesaid premises; there being a great impediment on said premises, endangering persons lawfully traversing thereat. 27. That upon information and belief at all times herein mentioned the Defendant, its agents, servants, independent contractors and/or employees had actual and/or constructive notice of the aforesaid dangerous and defective condition and/or created the dangerous condition. 28. That on or about said date and at all times mentioned herein, the plaintiff would not have been caused to be injured on the subject premises in the absence of negligence on the part of the Defendant. 29. That on or about said date and at all times mentioned herein, the subject premises was within the exclusive control of the Defendant. 30. That the said occurrence and the injuries resulting therefrom were caused and/or precipitated by reason of the negligence and carelessness of the Defendant, its agents, servants, independent contractors and/or employees solely and wholly as a result of the negligence of the Defendant herein and without any negligence on the part of the plaintiff contributing thereto. 6 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 31. That at no time between its receipt of the notice of said dangerous condition complained of and February 1, 2022, did the Defendant, its agents, servants and/or employees ever cure, correct or in any way repair the dangerous premises condition complained of. 32. That on or about said date and at all times mentioned herein, the plaintiff was caused to be injured on the subject premises due to the doctrine of res ipsa loquitur. 33. That on or about said date and at all times mentioned herein, the plaintiff was caused to be injured on the subject premises due to a recurring condition. 34. That on or about said date and at all times mentioned herein, the plaintiff would not have slipped and due to slippery, icy, wet, defective, hazardous, unsafe, dangerous condition on the premises in the absence of negligence on the part of the Defendant. 35. The Defendant, GREEN ACRES, its agents, servants and/or employees and/or contractors were negligent and careless in the ownership, operation, maintenance, supervision, repair, care and control of the aforesaid premises; in creating, continuing, causing, acquiescing in, permitting, maintaining and allowing the aforesaid premises to be, become and remain in an unsafe, dangerous and hazardous condition and failing to provide a safe means of egress and ingress from the subject premises. 36. The Defendant, GREEN ACRES, was negligent and careless in the ownership, operation, maintenance, supervision, inspection, repair, care, and control of the aforesaid premises in creating, continuing, causing, acquiescing in, permitting, maintaining and allowing the aforesaid premises to be, become and remain in a unsafe, dangerous and hazardous condition all of which constituted a nuisance and impediment and a grave danger and hazard, endangering the persons lawfully traversing there over. 7 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 37. The Defendant, GREEN ACRES, its agents, servants and/or employees and/or contractors were negligent in disregarding its duty to maintain the premises in their exclusive control in a reasonably safe condition and in a condition of good repair and maintenance; in failing to properly remedy the aforesaid dangerous condition and in allowing it to exist; in causing, allowing and permitting an inherently dangerous condition and trap to be, become and remain on the said premises. 38. That the said occurrence and the injuries resulting therefrom were caused and/or precipitated by reason of the negligence and carelessness of the Defendant, its agents, servants, independent contractors and/or employees solely and wholly as a result of the negligence of the Defendant herein and without any negligence on the part of the plaintiff contributing thereto. 39. That upon information and belief at all times herein mentioned the Defendant, its agents, servants, independent contractors and/or employees had actual and/or constructive notice of the aforesaid dangerous and defective condition and/or created the dangerous condition. 40. That on or about said date and at all times mentioned herein, the plaintiff would not have been caused to be injured on the subject premises in the absence of negligence on the part of the Defendant. 41. That on or about said date and at all times mentioned herein, the subject premises was within the exclusive control of the Defendant. 42. That this action falls within one or more of the exceptions contained in CPLR § 1602. 43. That by reason of the foregoing the plaintiff sustained severe injuries to various parts of plaintiff’s body specially neck, shoulder, back, chest, stomach and tail bone; that plaintiff suffered and will continue to suffer for some time to come great pain and anguish in 8 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 body and mind; that plaintiff received necessary hospital care and attention for a long period of time; that plaintiff necessarily received and will continue to receive medical treatment and medicines for which expenses have, are and will continue to be incurred; that as a result of the injuries sustained by plaintiff, plaintiff may, in the future, require further hospital and medical care and attention; that plaintiff has been unable to return to plaintiff’s usual duties and occupation as plaintiff had theretofore done and, upon information and belief, plaintiff’s injuries are permanent, protracted and disabling in nature all to plaintiff’s damage as against the Defendant in a sum which exceeds the jurisdictional limits of all lower courts of the State of New York. WHEREFORE, plaintiff demands judgment against the Defendant in an amount which exceeds the jurisdictional limits of the lower courts of the State of New York, together with the costs and disbursements of this action. Dated: New York, New York April 29, 2024 REDMOND LAW FIRM, PLLC By: Cornelius Redmond, Esq. Attorneys for Plaintiff 80 Broad Street, Suite 1202 New York, New York 10004 (212) 799-8989 9 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 VERIFICATION STATE OF NEW YORK } } ss: COUNTY OF NEW YORK } I, the undersigned, an attorney duly admitted to practice law in the State of New York, state that I am a member of the firm REDMOND LAW FIRM, PLLC, attorneys of record for the plaintiff in the within action; I have read the foregoing COMPLAINT and know the contents thereof; the same is true to my own knowledge except as to those matters therein stated to be alleged upon information and belief, and as to those matters, I believe to be true. The reason this verification is made by me and not by the plaintiff is that deponent maintains offices outside the County in which plaintiff resides. The grounds of my belief as to all matters not stated upon my knowledge, are as follows: entire file maintained in your deponent’s offices, investigations, etc. I affirm that the foregoing statements are true, under the penalties of perjury. Dated: New York, New York April 29, 2024 By: Cornelius Redmond, Esq. 10 of 11 FILED: QUEENS COUNTY CLERK 04/29/2024 01:21 AM INDEX NO. 709020/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX NO. COUNTY OF QUEENS BIBI A. SHAFIEK, Plaintiff, -against- GREEN ACRES ADJACENT LLC, Defendant. SUMMONS AND VERIFIED COMPLAINT REDMOND LAW FIRM, PLLC Attorneys for Plaintiff 80 Broad Street, Suite 1202 New York, New York 10004 (212) 799-8989 Pursuant to 22NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the Courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous CORNELIUS REDMOND, ESQ. REDMOND LAW FIRM, PLLC _________________________________________________________________________________ [ ] Notice of Entry that the within is a (certified) true copy of a duly entered in the Office of the Clerk of the within named court on 20 [ ] Notice of Settlement that an order of which the within is a true copy will be presented to the Hon. one of the judges of the within court at on 20 at M. Dated: Yours, etc. REDMOND LAW FIRM, PLLC 80 Broad Street, Suite 1202 New York, New York 10004 (212) 799-8989 11 of 11