Preview
FILED: SUFFOLK COUNTY CLERK 06/06/2024 08:35 AM INDEX NO. 613911/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
SUPREMECOURTOFTHESTATEOFNEWYORK Date filed with Court: / /24
COUNTYOFSUFFOLK
-------------------------------------------------------------------X Index No.:
MARYAMS. RAHMAN,
Plaintiff, SUMMONS
-against- Plaintiff designates Suffolk
County as the place of trial
AKHTARMAHMOOD, herein.
The basis of venue is Plaintiff's
Defendant. residence in Suffolk County,
------------------------------------------------------------------------X NY.
TOTHEABOVE-NAMED
DEFENDANT:
YOUAREHEREBYSUMMONED
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 attomey within twenty (20) days after the service of this summons,
exclusive of the day of service or within thirty (30) days after the service is complete if this summons
is not personally delivered toyou within the State of NewYork; 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: June 3, 2024
Merrick, New York
KA LA IGHT
ROB T K. O & ASSOCIATES,P.C.
Atto eys for Plai f
22 Babylon T pike
Merrick, New York 11566
(516) 826-8938
DEFENDANT'SADDRESS:
AKHTARMAHMOOD:
2290 Feuereisen Avenue, Ronkonkoma, New York 11779.
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FILED: SUFFOLK COUNTY CLERK 06/06/2024 08:35 AM INDEX NO. 613911/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOFSUFFOLK
-__-____________________________.___________Ç
MARYAM
S. RAHMAN, Index No.:
Plaintiff, VERIFIED COMPLAINT
-against-
AKHTARMAHMOOD,
Defendant.
___________.._____________.._____________Ç
Plaintiff, MARYAM
S. RAHMAN,
by and through his attorneys, &
K. YOUNG
ROBERT
ASSOCIATES,P.C., as and for his VERIFIED COMPLAINT, alleges the following:
1. At all times herein mentioned Plaintiff, MARYAM
S. RAHMAN,
was and still is a
resident and domiciliary of Suffolk County, New York.
2. At all times herein mentioned Plaintiff operated, maintained and controlled a certain
2006 Ford motor vehicle bearing New York license plate number KEJ8971 for the year 2024.
3. At all times herein mentioned Defendant, AKHTARMAHMOOD,
owned, operated,
maintained and controlled a certain 2015 Toyota motor vehicle bearing New York license plate
number LAH4651 for the year 2024.
4. That on or about February 5, 2024 on Montauk Highway, five (5) feet south of 579
Montauk Highway, Town of Brookhaven, Suffolk County, New York, Defendant's aforesaid motor
vehicle was operated, maintained, inspected and/or controlled in such a negligent, reckless and
careless manner and in such a way so as to cause it to improperly come into contact and violently
collide with Plaintiff thereby causing Plaintiff to sustain severe and serious permanent personal
injuries as hereinafter set forth and which required the aid of medical attention and assistance and
which incapacitated her.
5. At all times herein mentioned, upon information and belief, Defendant was in the
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course of his employment and/or furthering the interests of another person and/or entity when the
vehicle he was operating was involved in a motor vehicle accident with the Plaintiff on February 5,
2024.
6. That the aforesaid occurrence was due solely to the negligence of the Defendant and
without any contributory negligence on the part of the Plaintiff.
7. That Plaintiff sustained severe and serious personal injuries and economic loss as
defined in Article 51 of the Insurance Law of the State of NewYork and particularly Subdivision (d)
of § 5102 thereof.
8. That Plaintiff is a covered person as defined by the Insurance Law of the State of New
York.
9. That upon information and belief, Plaintiff has sustained economic loss greater than
basic economic loss as defined in Subdivision (a) of § 5102 of the Insurance Law of the State of New
York and, that by reason thereof, said Plaintiff is entitled to recover for noneconomic loss and for
loss"
such economic losses as are not included within the definition of "basic economic as set forth
in the Insurance Law of the State of NewYork.
10. That this action falls within one or more of the exceptions set forth in CPLR1602.
11. That as a consequence of the foregoing, Plaintiff was internally, externally and
permanently injured and has been prevented from pursuing and/or tending to her usual occupation
and duties and that the same may continue for the remainder of her natural life.
12. That this Plaintiff sustained severe and serious personal injuries and economic loss as
defined in § 5102 of the Insurance Law of the State of New York; that upon information and belief,
she will continue to suffer from the aforesaid serious and permanent personal injuries for the
remainder of her natural life and from the concomitant effects and sequelae thereof and therefrom.
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13. That Plaintiff has been obliged to seek and obtain medical attention and may for the
remainder of her natural life require medical consultations and attentions solely as a result of the
Defendant's aforesaid negligence.
14. That solely as a result of the foregoing, Plaintiff has been damaged in an amount
exceeding the statutory limits of any lower court having jurisdiction over this matter and in an amount
that shall be determined at the time of trial herein.
WHEREFORE,
Plaintiff, MARYAM
S. RAHMAN,
demandsjudgment herein against the
Defendant, AKHTAR
MAHMOOD,
in an amount exceeding the statutory limits of any lower court
having jurisdiction over this matter and in an amount to be determined at the time of trial herein; all
together with the costs and disbursements incurred herein.
Dated: June 3, 2024
Merrick, New York
L , Q.
RO . O & ASSOCIATES,P.C.
Atto eys for Pl tiff
22 Babylon Turnpike
Merrick, New York 11566
(516) 826-8938
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ATTORNEY
VERIFICATION
STATEOFNEWYORK)
) : ss.:
COUNTYOFNASSAU)
KAYLAL. KNIGHT, an attorney duly admitted to practice law in the courts of the State of
NewYork, affirms under penalty of perjury the truth of the following:
1. That she is associated with Robert K. Young & Associates, the attorneys of record
for the Plaintiff in the within action; that she has read the foregoing SUMMONS
WITH VERIFIED
COMPLAINTand knows the contents thereof; that the same is true to affirmant's knowledge,
except as to the matters therein stated to be alleged on information and belief, and as to those
matters, affirmant believes it to be true; and that the source of affirmants knowledge and the
grounds of belief as to those matters therein stated to be alleged on information and belief are
correspondence, investigations and reports caused to be made by affirmant and submitted to her as
attorney for the Plaintiff which she verily believes to be true.
2. That the reason this Verification is made by affirmant and not by the Plaintiff is
because the Plaintiff does not reside within the County of Nassau where affirmant maintains her
principal office.
3. I, Kayla L. Knight, affirm this day of o , 2024 under the
penalties of perjury under the law of the State of New York, which may include a fine or
imprisonment, that the foregoing is true, and I understand that this document may be filed in an
action or proceeding in a court of law pursuant to CPLR§ 2106
Dated: June 3, 2024
Merrick, New York
KA IGHT //
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024
Index No.: Year:
SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOFSUFFOLK
MARYAM
S. RAHMAN
Plaintiff,
-against-
AKHTARMAHMOOD
Defendant.
ROBERTK. YOUNG& ASSOCIATES,P.C.
Attorney(s) for PLAINTIFF
Office and Post Office Address, Telephone
2284 BABYLON TURNPIKE
MERRICK, NEWYORK11566
826-8938
(516)
(516) 826-4456
FAX: (516) 826-8932
SUMMONS
ANDVERIFIED COMPLAINT
To
Attorney(s) for
Service of a copy of the within is hereby admitted.
Dated,
Attorney(s) for .......................................
Sir: Please take notice
o NOTICEOFENTRY
that within is a (certified) true copy of a
duly entered in the office of the clerk of the within named court on
o NOTICEOFSETTLEMENT
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 the day of 20 at M.
Dated:
TO 22 NYCRR
COMPLIANCEPURSUANT § 130-1.1-a
To the best of the undersigned's knowledge, information and belief formed Yours, etc.
after an inquiry reasonable under the circumstances, the within document(s) Robert Young & Associates
and contentions contained herein are not fri olous as defined in 22 N CRR Attorney(s) for
§ 130-1.1-a. Office and Post Address
2284 BABYLON
TURNPIKE
MERRICK, NY 11566
AN ONY ADARO,ESQ. (516) 826-8938
ROBERTK. OUNG& ASSOCIATES,P.C. (516) 826-4456
To
Attorney(s) for
6 of 6
Preview
FILED: SUFFOLK COUNTY CLERK 06/06/2024 08:35 AM INDEX NO. 613911/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 SUPREMECOURTOFTHESTATEOFNEWYORK Date filed with Court: / /24 COUNTYOFSUFFOLK -------------------------------------------------------------------X Index No.: MARYAMS. RAHMAN, Plaintiff, SUMMONS -against- Plaintiff designates Suffolk County as the place of trial AKHTARMAHMOOD, herein. The basis of venue is Plaintiff's Defendant. residence in Suffolk County, ------------------------------------------------------------------------X NY. TOTHEABOVE-NAMED DEFENDANT: YOUAREHEREBYSUMMONED 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 attomey within twenty (20) days after the service of this summons, exclusive of the day of service or within thirty (30) days after the service is complete if this summons is not personally delivered toyou within the State of NewYork; 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: June 3, 2024 Merrick, New York KA LA IGHT ROB T K. O & ASSOCIATES,P.C. Atto eys for Plai f 22 Babylon T pike Merrick, New York 11566 (516) 826-8938 DEFENDANT'SADDRESS: AKHTARMAHMOOD: 2290 Feuereisen Avenue, Ronkonkoma, New York 11779. 1 of 6 FILED: SUFFOLK COUNTY CLERK 06/06/2024 08:35 AM INDEX NO. 613911/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFSUFFOLK -__-____________________________.___________Ç MARYAM S. RAHMAN, Index No.: Plaintiff, VERIFIED COMPLAINT -against- AKHTARMAHMOOD, Defendant. ___________.._____________.._____________Ç Plaintiff, MARYAM S. RAHMAN, by and through his attorneys, & K. YOUNG ROBERT ASSOCIATES,P.C., as and for his VERIFIED COMPLAINT, alleges the following: 1. At all times herein mentioned Plaintiff, MARYAM S. RAHMAN, was and still is a resident and domiciliary of Suffolk County, New York. 2. At all times herein mentioned Plaintiff operated, maintained and controlled a certain 2006 Ford motor vehicle bearing New York license plate number KEJ8971 for the year 2024. 3. At all times herein mentioned Defendant, AKHTARMAHMOOD, owned, operated, maintained and controlled a certain 2015 Toyota motor vehicle bearing New York license plate number LAH4651 for the year 2024. 4. That on or about February 5, 2024 on Montauk Highway, five (5) feet south of 579 Montauk Highway, Town of Brookhaven, Suffolk County, New York, Defendant's aforesaid motor vehicle was operated, maintained, inspected and/or controlled in such a negligent, reckless and careless manner and in such a way so as to cause it to improperly come into contact and violently collide with Plaintiff thereby causing Plaintiff to sustain severe and serious permanent personal injuries as hereinafter set forth and which required the aid of medical attention and assistance and which incapacitated her. 5. At all times herein mentioned, upon information and belief, Defendant was in the 2 of 6 FILED: SUFFOLK COUNTY CLERK 06/06/2024 08:35 AM INDEX NO. 613911/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 course of his employment and/or furthering the interests of another person and/or entity when the vehicle he was operating was involved in a motor vehicle accident with the Plaintiff on February 5, 2024. 6. That the aforesaid occurrence was due solely to the negligence of the Defendant and without any contributory negligence on the part of the Plaintiff. 7. That Plaintiff sustained severe and serious personal injuries and economic loss as defined in Article 51 of the Insurance Law of the State of NewYork and particularly Subdivision (d) of § 5102 thereof. 8. That Plaintiff is a covered person as defined by the Insurance Law of the State of New York. 9. That upon information and belief, Plaintiff has sustained economic loss greater than basic economic loss as defined in Subdivision (a) of § 5102 of the Insurance Law of the State of New York and, that by reason thereof, said Plaintiff is entitled to recover for noneconomic loss and for loss" such economic losses as are not included within the definition of "basic economic as set forth in the Insurance Law of the State of NewYork. 10. That this action falls within one or more of the exceptions set forth in CPLR1602. 11. That as a consequence of the foregoing, Plaintiff was internally, externally and permanently injured and has been prevented from pursuing and/or tending to her usual occupation and duties and that the same may continue for the remainder of her natural life. 12. That this Plaintiff sustained severe and serious personal injuries and economic loss as defined in § 5102 of the Insurance Law of the State of New York; that upon information and belief, she will continue to suffer from the aforesaid serious and permanent personal injuries for the remainder of her natural life and from the concomitant effects and sequelae thereof and therefrom. 3 of 6 FILED: SUFFOLK COUNTY CLERK 06/06/2024 08:35 AM INDEX NO. 613911/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 13. That Plaintiff has been obliged to seek and obtain medical attention and may for the remainder of her natural life require medical consultations and attentions solely as a result of the Defendant's aforesaid negligence. 14. That solely as a result of the foregoing, Plaintiff has been damaged in an amount exceeding the statutory limits of any lower court having jurisdiction over this matter and in an amount that shall be determined at the time of trial herein. WHEREFORE, Plaintiff, MARYAM S. RAHMAN, demandsjudgment herein against the Defendant, AKHTAR MAHMOOD, in an amount exceeding the statutory limits of any lower court having jurisdiction over this matter and in an amount to be determined at the time of trial herein; all together with the costs and disbursements incurred herein. Dated: June 3, 2024 Merrick, New York L , Q. RO . O & ASSOCIATES,P.C. Atto eys for Pl tiff 22 Babylon Turnpike Merrick, New York 11566 (516) 826-8938 4 of 6 FILED: SUFFOLK COUNTY CLERK 06/06/2024 08:35 AM INDEX NO. 613911/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 ATTORNEY VERIFICATION STATEOFNEWYORK) ) : ss.: COUNTYOFNASSAU) KAYLAL. KNIGHT, an attorney duly admitted to practice law in the courts of the State of NewYork, affirms under penalty of perjury the truth of the following: 1. That she is associated with Robert K. Young & Associates, the attorneys of record for the Plaintiff in the within action; that she has read the foregoing SUMMONS WITH VERIFIED COMPLAINTand knows the contents thereof; that the same is true to affirmant's knowledge, except as to the matters therein stated to be alleged on information and belief, and as to those matters, affirmant believes it to be true; and that the source of affirmants knowledge and the grounds of belief as to those matters therein stated to be alleged on information and belief are correspondence, investigations and reports caused to be made by affirmant and submitted to her as attorney for the Plaintiff which she verily believes to be true. 2. That the reason this Verification is made by affirmant and not by the Plaintiff is because the Plaintiff does not reside within the County of Nassau where affirmant maintains her principal office. 3. I, Kayla L. Knight, affirm this day of o , 2024 under the penalties of perjury under the law of the State of New York, which may include a fine or imprisonment, that the foregoing is true, and I understand that this document may be filed in an action or proceeding in a court of law pursuant to CPLR§ 2106 Dated: June 3, 2024 Merrick, New York KA IGHT // 5 of 6 FILED: SUFFOLK COUNTY CLERK 06/06/2024 08:35 AM INDEX NO. 613911/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/06/2024 Index No.: Year: SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFSUFFOLK MARYAM S. RAHMAN Plaintiff, -against- AKHTARMAHMOOD Defendant. ROBERTK. YOUNG& ASSOCIATES,P.C. Attorney(s) for PLAINTIFF Office and Post Office Address, Telephone 2284 BABYLON TURNPIKE MERRICK, NEWYORK11566 826-8938 (516) (516) 826-4456 FAX: (516) 826-8932 SUMMONS ANDVERIFIED COMPLAINT To Attorney(s) for Service of a copy of the within is hereby admitted. Dated, Attorney(s) for ....................................... Sir: Please take notice o NOTICEOFENTRY that within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on o NOTICEOFSETTLEMENT 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 the day of 20 at M. Dated: TO 22 NYCRR COMPLIANCEPURSUANT § 130-1.1-a To the best of the undersigned's knowledge, information and belief formed Yours, etc. after an inquiry reasonable under the circumstances, the within document(s) Robert Young & Associates and contentions contained herein are not fri olous as defined in 22 N CRR Attorney(s) for § 130-1.1-a. Office and Post Address 2284 BABYLON TURNPIKE MERRICK, NY 11566 AN ONY ADARO,ESQ. (516) 826-8938 ROBERTK. OUNG& ASSOCIATES,P.C. (516) 826-4456 To Attorney(s) for 6 of 6