Preview
FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024
OFTHESTATEOFNEW
SUPREMECOURT YORK Index No.:
COUNTYOFNEWYORK Date Purchased:
________________________________________________Ç
JOHANNA
PEREZ,
SUMMONS
Plaintiff,
Plaintiff designates NewYork
County as the place of trial.
-against-
The basis of venue is:
SANGREALLLC ANDTHESANGREAL Defendant's residence
APARTMENTS,
Defendant resides at:
Defendants,
49 W. 33rd Street
__________________________________________Ç NewYork, NY 10001
To the above named Defendants:
You are hereby summonedto 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 attorneys within twenty days after the service 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 demandedin the complaint.
Dated: Bronx, New York
June 10, 2024
Jaso S lapir
SHAPIROLAWOFFICES, PLLC
Attorney for Plaintiff(s) Johanna Perez
3205 Grand Concourse, Suite 1
Bronx, NewYork 10468
718-295-7000
TO:
Sangreal LLC
Paul W. Siegett, Esq
49 West 33rd St, 3rd F1
NewYork, NY 10001
The Sangreal Apa1tments
401 Warburton Avenue
Yonkers, NY 10701
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FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024
SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOFNEWYORK Index No.:
----------------------------------------------------------------X Date Purchased:
JOHANNA
PEREZ,
COMPLAINT
Plaintiff,
-against-
SANGREALLLC ANDTHE SANGREALAPARTMENTS,
Defendants.
________-___________________________________________Ç
Plaintiff by her attorneys, SHAPIRO LAW OFFICES, PLLC complaining of the
Defendants, respectfully alleges, upon information and belief:
1. That at all times herein mentioned, the Plaintiff was, and still is a resident of the
County of Westchester, State of NewYork.
2. That at all times herein mentioned, the Defendant SANGREALLLC was and
still is a domestic corporation, duly organized and existing under and by virtue of the laws of the
State of NewYork.
3. That at all times herein mentioned, the Defendant SANGREALLLC was and
still is a foreign corporation duly authorized to do business in the State of NewYork.
4. That at all times herein mentioned, the Defendant SANGREALLLC, maintained
a principal place of business in the County of New York, State of NewYork.
5. That at all times herein mentioned, the Defendant THE SANGREAL
APARTMENTS
was and still is a domestic corporation duly organized and existing under and
by virtue of the laws of the State of NewYork.
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FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024
6. That at all times herein mentioned, the Defendant THE SANGREAL
APARTMENTS
was and still is a foreign corporation duly authorized to do business in the
State of NewYork.
7. That at all times herein mentioned, the Defendant THE SANGREAL
APARTMENTS
maintained a principal place of business in the County of State of NewYork.
8. That at all times herein mentioned, the Defendant SANGREALLLC owned the
premises and appurtenances and fixtures thereto, located at 401 Warburton Avenue, Yonkers,
NY 10701.
9. That at all times herein mentioned, and upon information and belief, the
Defendant SANGREAL
LLC managedthe aforesaid premises.
10. That at all times herein mentioned, and upon information and belief, the
Defendant SANGREALLLC controlled the aforesaid premises.
11. That at all times herein mentioned, and upon infonnation and belief, the
Defendant SANGREAL
LLC maintained the aforesaid premises.
12. That at all times herein mentioned, and upon information and belief, the
Defendant SANGREAL
LLC repaired the aforesaid premises.
13. That at all times herein mentioned, and upon information and belief, the
Defendant APARTMENTS
THESANGREAL managedthe aforesaid premises.
14. That at all times herein mentioned, and upon infonnation and belief, the
Defendant APARTMENTS
THESANGREAL controlled the aforesaid premises.
15. That at all times herein mentioned, and upon information and belief, the
Defendant THESANGREALAPARTMENTS
maintained the aforesaid premises.
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FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024
16. That at all times herein mentioned, and upon infonnation and belief, the
Defendant APARTMENTS
THESANGREAL repaired the aforesaid premises.
17. On September 30, 2023, Plaintiff JOHANNAPEREZwas lawfully on the
aforesaid premises.
18. On September 30, 2023, while Plaintiff JOHANNAPEREZwas lawfully about
the aforesaid premises she was caused to sustain serious and pennanent injuries.
19. The above mentioned occurrence, and the results thereof, were caused by the
Defendants'
joint, several and concurrent negligence of the Defendants and/or said agents,
selmants, employees and/or licensees in the ownership, operation, management, supervision,
maintenance and control of the aforesaid premises.
20. That no negligence on the part of the Plaintiff contributed to the occmrence
alleged herein in any manner whatsoever.
21. That by reason of the foregoing, Plaintiff JOHANNA
PEREZwas caused to
sustain serious injuries and to have suffered pain, shock and mental anguish; that these injuries
and their effects will be permanent; and as a result of said injuries Plaintiff has been caused to
incur, and will continue to incur, expenses for medical care and attention; and, as a further result,
Plaintiff was, and will continue to be, rendered unable to perform Plaintiff s normal activities and
duties and has sustained a resultant loss therefrom.
22. That as a result of the foregoing, Plaintiff was damagedin a sum which exceeds
the jurisdictional limits of all lower courts which would otherwise have jurisdiction.
WHEREFORE,Plaintiff demands judgment against the Defendants herein, in a
sum exceeding the jurisdictional limits of all lower courts which would otherwise have
jurisdiction, together with the costs and disbursements of this action.
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FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024
Dated: Bronx, NewYork
June 10, 2024
Your , etc.
Jaso Tapifo
SHAPIROLAWOFFICES, PLLC
Attorney for Plaintiff(s) Johanna Perez
3205 Grand Concourse, Suite 1
Bronx, NewYork 10468
718-295-7000
5 of 6
FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024
Index No.
OFTHESTATEOFNEW
SUPREMECOURT YORK
COUNTYOFWESTCHESTER
JOHANNA
PEREZ,
Plaintiff,
-against-
SANGREALLLC and THESANGREALAPARTMENTS
Defendants.
ANDCOMPLAINT
SUMMONS
SHAPIROLAWOFFICES, PLLC
Attorneys for Plaintiff
3205 Grand Concourse, Suite 1
Bronx, NY 10468
718-295-7000
ATTORNEY
CERTIFICATION
The undersigned, an Attorney admitted to
practice in the Courts of NewYork State,
certifies that, upon information, belief
and reasonable inquity, the contentions
contained in the above-referenced document(s)
are not frivolous.
JASONSHAPIRO, ESQ.
To:
Attorney(s) for
Service of a copy of the within is hereby admitted.
Dated:
...............................
Attorney(s) for
6 of 6
Preview
FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024 OFTHESTATEOFNEW SUPREMECOURT YORK Index No.: COUNTYOFNEWYORK Date Purchased: ________________________________________________Ç JOHANNA PEREZ, SUMMONS Plaintiff, Plaintiff designates NewYork County as the place of trial. -against- The basis of venue is: SANGREALLLC ANDTHESANGREAL Defendant's residence APARTMENTS, Defendant resides at: Defendants, 49 W. 33rd Street __________________________________________Ç NewYork, NY 10001 To the above named Defendants: You are hereby summonedto 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 attorneys within twenty days after the service 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 demandedin the complaint. Dated: Bronx, New York June 10, 2024 Jaso S lapir SHAPIROLAWOFFICES, PLLC Attorney for Plaintiff(s) Johanna Perez 3205 Grand Concourse, Suite 1 Bronx, NewYork 10468 718-295-7000 TO: Sangreal LLC Paul W. Siegett, Esq 49 West 33rd St, 3rd F1 NewYork, NY 10001 The Sangreal Apa1tments 401 Warburton Avenue Yonkers, NY 10701 1 of 6 FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024 SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFNEWYORK Index No.: ----------------------------------------------------------------X Date Purchased: JOHANNA PEREZ, COMPLAINT Plaintiff, -against- SANGREALLLC ANDTHE SANGREALAPARTMENTS, Defendants. ________-___________________________________________Ç Plaintiff by her attorneys, SHAPIRO LAW OFFICES, PLLC complaining of the Defendants, respectfully alleges, upon information and belief: 1. That at all times herein mentioned, the Plaintiff was, and still is a resident of the County of Westchester, State of NewYork. 2. That at all times herein mentioned, the Defendant SANGREALLLC was and still is a domestic corporation, duly organized and existing under and by virtue of the laws of the State of NewYork. 3. That at all times herein mentioned, the Defendant SANGREALLLC was and still is a foreign corporation duly authorized to do business in the State of NewYork. 4. That at all times herein mentioned, the Defendant SANGREALLLC, maintained a principal place of business in the County of New York, State of NewYork. 5. That at all times herein mentioned, the Defendant THE SANGREAL APARTMENTS was and still is a domestic corporation duly organized and existing under and by virtue of the laws of the State of NewYork. 2 of 6 FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024 6. That at all times herein mentioned, the Defendant THE SANGREAL APARTMENTS was and still is a foreign corporation duly authorized to do business in the State of NewYork. 7. That at all times herein mentioned, the Defendant THE SANGREAL APARTMENTS maintained a principal place of business in the County of State of NewYork. 8. That at all times herein mentioned, the Defendant SANGREALLLC owned the premises and appurtenances and fixtures thereto, located at 401 Warburton Avenue, Yonkers, NY 10701. 9. That at all times herein mentioned, and upon information and belief, the Defendant SANGREAL LLC managedthe aforesaid premises. 10. That at all times herein mentioned, and upon information and belief, the Defendant SANGREALLLC controlled the aforesaid premises. 11. That at all times herein mentioned, and upon infonnation and belief, the Defendant SANGREAL LLC maintained the aforesaid premises. 12. That at all times herein mentioned, and upon information and belief, the Defendant SANGREAL LLC repaired the aforesaid premises. 13. That at all times herein mentioned, and upon information and belief, the Defendant APARTMENTS THESANGREAL managedthe aforesaid premises. 14. That at all times herein mentioned, and upon infonnation and belief, the Defendant APARTMENTS THESANGREAL controlled the aforesaid premises. 15. That at all times herein mentioned, and upon information and belief, the Defendant THESANGREALAPARTMENTS maintained the aforesaid premises. 3 of 6 FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024 16. That at all times herein mentioned, and upon infonnation and belief, the Defendant APARTMENTS THESANGREAL repaired the aforesaid premises. 17. On September 30, 2023, Plaintiff JOHANNAPEREZwas lawfully on the aforesaid premises. 18. On September 30, 2023, while Plaintiff JOHANNAPEREZwas lawfully about the aforesaid premises she was caused to sustain serious and pennanent injuries. 19. The above mentioned occurrence, and the results thereof, were caused by the Defendants' joint, several and concurrent negligence of the Defendants and/or said agents, selmants, employees and/or licensees in the ownership, operation, management, supervision, maintenance and control of the aforesaid premises. 20. That no negligence on the part of the Plaintiff contributed to the occmrence alleged herein in any manner whatsoever. 21. That by reason of the foregoing, Plaintiff JOHANNA PEREZwas caused to sustain serious injuries and to have suffered pain, shock and mental anguish; that these injuries and their effects will be permanent; and as a result of said injuries Plaintiff has been caused to incur, and will continue to incur, expenses for medical care and attention; and, as a further result, Plaintiff was, and will continue to be, rendered unable to perform Plaintiff s normal activities and duties and has sustained a resultant loss therefrom. 22. That as a result of the foregoing, Plaintiff was damagedin a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. WHEREFORE,Plaintiff demands judgment against the Defendants herein, in a sum exceeding the jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with the costs and disbursements of this action. 4 of 6 FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024 Dated: Bronx, NewYork June 10, 2024 Your , etc. Jaso Tapifo SHAPIROLAWOFFICES, PLLC Attorney for Plaintiff(s) Johanna Perez 3205 Grand Concourse, Suite 1 Bronx, NewYork 10468 718-295-7000 5 of 6 FILED: NEW YORK COUNTY CLERK 06/13/2024 03:14 PM INDEX NO. 155449/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/13/2024 Index No. OFTHESTATEOFNEW SUPREMECOURT YORK COUNTYOFWESTCHESTER JOHANNA PEREZ, Plaintiff, -against- SANGREALLLC and THESANGREALAPARTMENTS Defendants. ANDCOMPLAINT SUMMONS SHAPIROLAWOFFICES, PLLC Attorneys for Plaintiff 3205 Grand Concourse, Suite 1 Bronx, NY 10468 718-295-7000 ATTORNEY CERTIFICATION The undersigned, an Attorney admitted to practice in the Courts of NewYork State, certifies that, upon information, belief and reasonable inquity, the contentions contained in the above-referenced document(s) are not frivolous. JASONSHAPIRO, ESQ. To: Attorney(s) for Service of a copy of the within is hereby admitted. Dated: ............................... Attorney(s) for 6 of 6