Preview
FILED: KINGS COUNTY CLERK 08/11/2015 09:42 AM INDEX NO. 504203/2013
NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 08/11/2015
SUPREME COURT OF THE STATE OF NEW YORK Index No: 504203/2013
COUNTY OF KINGS Date purchased: 7/24/2013
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AYSE BALANTEKIN as the mother and natural guardian Plaintiff designates:
of infants BUSE BALANTEKIN and FURKAN KINGS COUNTY as
BALANTEKIN and AYSE BALANTEKIN Individually, the place of trial
Plaintiffs,
-against- AMENDED SUMMONS
CHRIS E. GLANVILL and TAMARA GLANVILL, The basis of the venue is
Plaintiff’s Residence
Defendant.
Plaintiff resides at
-------------------------------------------------------------------X 2200 Ocean Avenue
Brooklyn, New York 11229
To the above named Defendants: County of Kings
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
February 17, 2015
AKIN LAW GROUP PLLC
Attorneys for Plaintiff(s)
/ s / Gulsah Senol
_______________________
By: Gulsah Senol, Esq.
45 Broadway, Suite 1420
New York, New York 10006
(212) 825-1400
Defendants' Addresses:
CHRIS E. GLANVILL
570 N Wellwood Avenue
Lindenhurst, New York 11757
TAMARA GLANVILL
570 N Wellwood Avenue
Lindenhurst, New York 11757
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No: 504203/2013
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AYSE BALANTEKIN as the mother and natural guardian
of infants BUSE BALANTEKIN and FURKAN
BALANTEKIN and AYSE BALANTEKIN Individually,
AMENDED
Plaintiffs, VERIFIED COMPLAINT
- against -
CHRIS E. GLANVILL and TAMARA GLANVILL,
Defendant.
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Plaintiffs, by their attorneys, AKIN LAW GROUP PLLC upon information and belief,
complain of the Defendants herein as follows:
AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF
OF THE PLAINTIFF, AYSE BALANTEKIN
1. That at all times hereinafter mentioned, plaintiff, AYSE BALANTEKIN, was and
still is a resident of the State of New York county of Kings.
2. That at all times hereinafter mentioned, plaintiff, Infant BUSE BALANTEKIN, was
and still is a resident of the State of New York county of Kings.
3. That at all times hereinafter mentioned, plaintiff, Infant FURKAN BALANTEKIN,
was and still is a resident of the State of New York county of Kings.
4. That at all times hereinafter mentioned, defendant, CHRIS E. GLANVILL, was and
still is a resident of the State of New York.
5. That at all times hereinafter mentioned, Defendant, CHRIS E. GLANVILL, was and
still is an individual residing at 570 N. Wellwood Avenue, Lindenhurst, New York
11757.
6. That at all times hereinafter mentioned, defendant TAMARA GLANVILL, was and
still is a resident of the State of New York.
7. That at all times hereinafter mentioned, Defendant, TAMARA GLANVILL, was and
still is an individual residing at 570 N. Wellwood Avenue, Lindenhurst, New York
11757.
8. That at all times hereinafter mentioned, Defendant, CHRIS E. GLANVILL, owned a
2005 Jeep vehicle.
9. That at all times hereinafter mentioned, Defendant, CHRIS E. GLANVILL, owned a
2005 Jeep vehicle bearing State of New York license plate DHU4440.
10. That at all times hereinafter mentioned, Defendant, CHRIS E. GLANVILL, owned a
2005 Jeep vehicle bearing vehicle identification number 1J4GL48K15W616226.
11. On or about November 22, 2012, the defendant CHRIS E. GLANVILL, gave consent
to defendant TAMARA GLANVILL to operate the aforesaid 2005 Jeep vehicle.
12. On or about November 22, 2012, the defendant CHRIS E. GLANVILL, had
knowledge that another individual was operating the aforesaid 2005 Jeep vehicle.
13. On or about November 22, 2012, the defendant CHRIS E. GLANVILL, had
knowledge that defendant TAMARA GLANVILL was operating the aforesaid 2005
Jeep vehicle.
14. On or about November 22, 2012, the defendant TAMARA GLANVILL, operated the
aforesaid 2005 Jeep vehicle.
15. That at all times hereinafter mentioned, the defendant CHRIS E. GLANVILL,
maintained the aforesaid 2005 Jeep vehicle.
16. That at all times hereinafter mentioned, the defendant, CHRIS E. GLANVILL,
inspected the aforesaid 2005 Jeep vehicle.
17. That at all times hereinafter mentioned, the defendant, CHRIS E. GLANVILL,
repaired the aforesaid 200 Jeep vehicle.
18. That at all times hereinafter mentioned, the defendant, CHRIS E. GLANVILL,
controlled the aforesaid 2005 Jeep vehicle.
19. That at all times hereinafter mentioned, the defendant TAMARA GLANVILL,
maintained the aforesaid 2005 Jeep vehicle.
20. That at all times hereinafter mentioned, the defendant, TAMARA GLANVILL,
inspected the aforesaid 2005 Jeep vehicle.
21. That at all times hereinafter mentioned, the defendant, TAMARA GLANVILL,
repaired the aforesaid 200 Jeep vehicle.
22. That at all times hereinafter mentioned, the defendant, TAMARA GLANVILL,
controlled the aforesaid 2005 Jeep vehicle.
23. That at all times hereinafter mentioned, Avenue W at or near its intersection with
Ocean Avenue in the County of Kings, City and State of New York was and is a
public roadway, over, along and upon which motor vehicles did and do travel.
24. That on or about November 22, 2012 the Plaintiff AYSE BALANTEKIN was
situated within a 2002 Toyota vehicle bearing State of New York license plate
FPT1202.
25. That at the aforementioned time and place, the aforesaid 2005 Jeep vehicle and the
aforesaid 2002 Toyota vehicle came into contact.
26. That at the aforementioned time and place, the aforesaid 2005 Jeep vehicle struck the
aforesaid 2002 Toyota vehicle.
27. That at the aforementioned time and place, the aforesaid 2005 Jeep vehicle struck the
aforesaid 2002 Toyota vehicle from the rear.
28. That at the aforementioned time and place, the aforesaid 2005 Jeep vehicle struck the
aforesaid 2002 Toyota vehicle from the rear while the aforesaid 2002 Toyota vehicle
was at a complete stop.
29. That the aforementioned contact was caused as a direct result of the negligence of the
Defendant(s) and without any negligence on the part of the Plaintiff contributing
thereto.
30. That the Defendants were negligent in the ownership, operation, maintenance and
control of the aforesaid 2005 Jeep vehicle.
31. That this action falls within one or more of the exception set forth in Article 16 of the
CPLR.
32. That by reason of the foregoing, the Plaintiff, AYSE BALANTEKIN, was severely
bruised, wounded and injured, suffered internal and external injuries, some of which
are believed to be of a permanent nature, and was confined to her home and bed, was
compelled to undergo extensive medical aid, attention and treatment in an effort to
cure herself of the injuries sustained, and since some of the injuries are believed to be
of a permanent and lasting nature, she will continue to suffer similar damages in the
future.
33. That as a result of the foregoing, the plaintiff, AYSE BALANTEKIN, sustained a
serious injury as defined in Section 5102(d) of the Insurance Law and an economic
loss greater than basic economic loss as defined in Section 5102(a) of the Insurance
Law.
34. That as a direct result of the foregoing the plaintiff, AYSE BALANTEKIN, has been
damaged in an amount that exceeds the jurisdictional limits of all lower courts.
AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF
OF THE INFANT PLAINTIFF, BUSE BALANTEKIN
35. The infant plaintiff, BUSE BALANTEKIN, repeats, reiterates, and realleges each and
every allegation contained in paragraphs of the Verified Complaint designated "1"
through "34" inclusive with the same force and effect as though said paragraphs were
more fully set forth herein at length.
36. That at the aforementioned time and place the infant plaintiff, BUSE BALANTEKIN,
was a passenger in the aforesaid 2002 Toyota vehicle.
37. That by reason of the foregoing, the infant plaintiff, BUSE BALANTEKIN, sustained
great bodily injury.
38. That by reason of the foregoing, the infant plaintiff, BUSE BALANTEKIN, was
severely bruised, wounded and injured, suffered internal and external injuries, some of
which are believed to be of a permanent nature, and was confined to her home and bed,
was compelled to undergo extensive medical aid, attention and treatment in an effort to
cure herself of the injuries sustained, and since some of the injuries are believed to be of
a permanent and lasting nature, she will continue to suffer similar damages in the future.
39. That as a result of the foregoing, the infant plaintiff, BUSE BALANTEKIN, sustained
a serious injury as defined in Section 5102(d) of the Insurance Law and an economic
loss greater than basic economic loss as defined in Section 5102(a) of the Insurance
Law.
40. That as a result of the foregoing, the infant plaintiff, BUSE BALANTEKIN, has been
damaged in an amount that exceeds the jurisdictional limits of all lower Courts.
AS AND FOR A THIRD CAUSE OF ACTION ON BEHALF
OF THE INFANT PLAINTIFF, FURKAN BALANTEKIN
41. The infant plaintiff, FURKAN BALANTEKIN, repeats, reiterates, and realleges each
and every allegation contained in paragraphs of the Verified Complaint designated "1"
through "40" inclusive with the same force and effect as though said paragraphs were
more fully set forth herein at length.
42. That at the aforementioned time and place the infant plaintiff, FURKAN
BALANTEKIN, was a passenger in the aforesaid 2002 Toyota vehicle.
43. That by reason of the foregoing, the infant plaintiff, FURKAN BALANTEKIN,
sustained great bodily injury.
44. That by reason of the foregoing, the infant plaintiff, FURKAN BALANTEKIN, was
severely bruised, wounded and injured, suffered internal and external injuries, some of
which are believed to be of a permanent nature, and was confined to his home and bed,
was compelled to undergo extensive medical aid, attention and treatment in an effort to
cure himself of the injuries sustained, and since some of the injuries are believed to be of
a permanent and lasting nature, he will continue to suffer similar damages in the future.
45. That as a result of the foregoing, the infant plaintiff, FURKAN BALANTEKIN,
sustained a serious injury as defined in Section 5102(d) of the Insurance Law and an
economic loss greater than basic economic loss as defined in Section 5102(a) of the
Insurance Law.
46. That as a result of the foregoing, the infant plaintiff, FURKAN BALANTEKIN, has
been damaged in an amount that exceeds the jurisdictional limits of all lower Courts.
WHEREFORE, the plaintiffs demands judgment against the defendants in an amount which
exceeds the jurisdictional limits of all lower Courts on the First Cause of Action, the plaintiffs
demands judgment against the defendants in an amount which exceeds the jurisdictional limits
of all lower Courts on the Second Cause of Action, and the plaintiffs demands judgment
against the defendants in an amount which exceeds the jurisdictional limits of all lower Courts
on the Third Cause of Action, together with costs, disbursements and such other or further
relief which this Court deems is just and proper.
DATED: New York, New York
February 17, 2015
Respectfully submitted
AKIN LAW GROUP PLLC
Attorneys for the Plaintiff
/ s / Gulsah Senol
________________________
By: Gulsah Senol Esq.
45 Broadway, Suite 1420
New York, New York 10006
(212) 825-1400
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No: 504203/2013
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AYSE BALANTEKIN as the mother and natural guardian
of infants BUSE BALANTEKIN and FURKAN
BALANTEKIN and AYSE BALANTEKIN Individually,
Plaintiffs, ATTORNEY'S VERIFICATION
- against -
CHRIS E. GLANVILL and TAMARA GLANVILL,
Defendant.
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I, Gulsah Senol, being duly sworn deposes and state under the penalties of perjury that: I
am an attorney duly admitted to practice law in the courts of New York State and am an
associate at AKIN LAW GROUP PLLC, the attorneys of record for the plaintiffs in the within
action.
I have read the foregoing, AMENDED VERIFIED COMPLAINT, and know the contents
thereof; the same is true to my own knowledge, except as to the matters therein alleged to be on
information and belief, and as to those matters I believe them to be true.
The reason this verification is made by me and not by the Plaintiffs is that the Plaintiffs
resides in a county other than where we maintain our office.
The grounds of my belief as to all matters not stated upon my own knowledge are as
follows: Conversations with the plaintiffs, review of our file and all the pleadings and
proceedings heretofore had herein.
Dated: New York, New York
February 17, 2015
/ s / Gulsah Senol
______________________
Gulsah Senol, Esq.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No: 504203/2013
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AYSE BALANTEKIN as the mother and natural guardian
of infants BUSE BALANTEKIN and FURKAN
BALANTEKIN and AYSE BALANTEKIN Individually,
Plaintiffs,
- against -
CHRIS E. GLANVILL and TAMARA GLANVILL,
Defendant.
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______________________________________________________________________________
AMENDED SUMMONS AND
AMENDED VERIFIED COMPLAINT
______________________________________________________________________________
AKIN LAW GROUP PLLC
Attorneys for Plaintiff
45 Broadway, Suite 1420
New York, New York 10006
Tel. (212) 825-1400
Fax. (212) 825-1440
Preview
FILED: KINGS COUNTY CLERK 08/11/2015 09:42 AM INDEX NO. 504203/2013 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 08/11/2015 SUPREME COURT OF THE STATE OF NEW YORK Index No: 504203/2013 COUNTY OF KINGS Date purchased: 7/24/2013 --------------------------------------------------------------------X AYSE BALANTEKIN as the mother and natural guardian Plaintiff designates: of infants BUSE BALANTEKIN and FURKAN KINGS COUNTY as BALANTEKIN and AYSE BALANTEKIN Individually, the place of trial Plaintiffs, -against- AMENDED SUMMONS CHRIS E. GLANVILL and TAMARA GLANVILL, The basis of the venue is Plaintiff’s Residence Defendant. Plaintiff resides at -------------------------------------------------------------------X 2200 Ocean Avenue Brooklyn, New York 11229 To the above named Defendants: County of Kings 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 February 17, 2015 AKIN LAW GROUP PLLC Attorneys for Plaintiff(s) / s / Gulsah Senol _______________________ By: Gulsah Senol, Esq. 45 Broadway, Suite 1420 New York, New York 10006 (212) 825-1400 Defendants' Addresses: CHRIS E. GLANVILL 570 N Wellwood Avenue Lindenhurst, New York 11757 TAMARA GLANVILL 570 N Wellwood Avenue Lindenhurst, New York 11757 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No: 504203/2013 --------------------------------------------------------------X AYSE BALANTEKIN as the mother and natural guardian of infants BUSE BALANTEKIN and FURKAN BALANTEKIN and AYSE BALANTEKIN Individually, AMENDED Plaintiffs, VERIFIED COMPLAINT - against - CHRIS E. GLANVILL and TAMARA GLANVILL, Defendant. --------------------------------------------------------------X Plaintiffs, by their attorneys, AKIN LAW GROUP PLLC upon information and belief, complain of the Defendants herein as follows: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF THE PLAINTIFF, AYSE BALANTEKIN 1. That at all times hereinafter mentioned, plaintiff, AYSE BALANTEKIN, was and still is a resident of the State of New York county of Kings. 2. That at all times hereinafter mentioned, plaintiff, Infant BUSE BALANTEKIN, was and still is a resident of the State of New York county of Kings. 3. That at all times hereinafter mentioned, plaintiff, Infant FURKAN BALANTEKIN, was and still is a resident of the State of New York county of Kings. 4. That at all times hereinafter mentioned, defendant, CHRIS E. GLANVILL, was and still is a resident of the State of New York. 5. That at all times hereinafter mentioned, Defendant, CHRIS E. GLANVILL, was and still is an individual residing at 570 N. Wellwood Avenue, Lindenhurst, New York 11757. 6. That at all times hereinafter mentioned, defendant TAMARA GLANVILL, was and still is a resident of the State of New York. 7. That at all times hereinafter mentioned, Defendant, TAMARA GLANVILL, was and still is an individual residing at 570 N. Wellwood Avenue, Lindenhurst, New York 11757. 8. That at all times hereinafter mentioned, Defendant, CHRIS E. GLANVILL, owned a 2005 Jeep vehicle. 9. That at all times hereinafter mentioned, Defendant, CHRIS E. GLANVILL, owned a 2005 Jeep vehicle bearing State of New York license plate DHU4440. 10. That at all times hereinafter mentioned, Defendant, CHRIS E. GLANVILL, owned a 2005 Jeep vehicle bearing vehicle identification number 1J4GL48K15W616226. 11. On or about November 22, 2012, the defendant CHRIS E. GLANVILL, gave consent to defendant TAMARA GLANVILL to operate the aforesaid 2005 Jeep vehicle. 12. On or about November 22, 2012, the defendant CHRIS E. GLANVILL, had knowledge that another individual was operating the aforesaid 2005 Jeep vehicle. 13. On or about November 22, 2012, the defendant CHRIS E. GLANVILL, had knowledge that defendant TAMARA GLANVILL was operating the aforesaid 2005 Jeep vehicle. 14. On or about November 22, 2012, the defendant TAMARA GLANVILL, operated the aforesaid 2005 Jeep vehicle. 15. That at all times hereinafter mentioned, the defendant CHRIS E. GLANVILL, maintained the aforesaid 2005 Jeep vehicle. 16. That at all times hereinafter mentioned, the defendant, CHRIS E. GLANVILL, inspected the aforesaid 2005 Jeep vehicle. 17. That at all times hereinafter mentioned, the defendant, CHRIS E. GLANVILL, repaired the aforesaid 200 Jeep vehicle. 18. That at all times hereinafter mentioned, the defendant, CHRIS E. GLANVILL, controlled the aforesaid 2005 Jeep vehicle. 19. That at all times hereinafter mentioned, the defendant TAMARA GLANVILL, maintained the aforesaid 2005 Jeep vehicle. 20. That at all times hereinafter mentioned, the defendant, TAMARA GLANVILL, inspected the aforesaid 2005 Jeep vehicle. 21. That at all times hereinafter mentioned, the defendant, TAMARA GLANVILL, repaired the aforesaid 200 Jeep vehicle. 22. That at all times hereinafter mentioned, the defendant, TAMARA GLANVILL, controlled the aforesaid 2005 Jeep vehicle. 23. That at all times hereinafter mentioned, Avenue W at or near its intersection with Ocean Avenue in the County of Kings, City and State of New York was and is a public roadway, over, along and upon which motor vehicles did and do travel. 24. That on or about November 22, 2012 the Plaintiff AYSE BALANTEKIN was situated within a 2002 Toyota vehicle bearing State of New York license plate FPT1202. 25. That at the aforementioned time and place, the aforesaid 2005 Jeep vehicle and the aforesaid 2002 Toyota vehicle came into contact. 26. That at the aforementioned time and place, the aforesaid 2005 Jeep vehicle struck the aforesaid 2002 Toyota vehicle. 27. That at the aforementioned time and place, the aforesaid 2005 Jeep vehicle struck the aforesaid 2002 Toyota vehicle from the rear. 28. That at the aforementioned time and place, the aforesaid 2005 Jeep vehicle struck the aforesaid 2002 Toyota vehicle from the rear while the aforesaid 2002 Toyota vehicle was at a complete stop. 29. That the aforementioned contact was caused as a direct result of the negligence of the Defendant(s) and without any negligence on the part of the Plaintiff contributing thereto. 30. That the Defendants were negligent in the ownership, operation, maintenance and control of the aforesaid 2005 Jeep vehicle. 31. That this action falls within one or more of the exception set forth in Article 16 of the CPLR. 32. That by reason of the foregoing, the Plaintiff, AYSE BALANTEKIN, was severely bruised, wounded and injured, suffered internal and external injuries, some of which are believed to be of a permanent nature, and was confined to her home and bed, was compelled to undergo extensive medical aid, attention and treatment in an effort to cure herself of the injuries sustained, and since some of the injuries are believed to be of a permanent and lasting nature, she will continue to suffer similar damages in the future. 33. That as a result of the foregoing, the plaintiff, AYSE BALANTEKIN, sustained a serious injury as defined in Section 5102(d) of the Insurance Law and an economic loss greater than basic economic loss as defined in Section 5102(a) of the Insurance Law. 34. That as a direct result of the foregoing the plaintiff, AYSE BALANTEKIN, has been damaged in an amount that exceeds the jurisdictional limits of all lower courts. AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF THE INFANT PLAINTIFF, BUSE BALANTEKIN 35. The infant plaintiff, BUSE BALANTEKIN, repeats, reiterates, and realleges each and every allegation contained in paragraphs of the Verified Complaint designated "1" through "34" inclusive with the same force and effect as though said paragraphs were more fully set forth herein at length. 36. That at the aforementioned time and place the infant plaintiff, BUSE BALANTEKIN, was a passenger in the aforesaid 2002 Toyota vehicle. 37. That by reason of the foregoing, the infant plaintiff, BUSE BALANTEKIN, sustained great bodily injury. 38. That by reason of the foregoing, the infant plaintiff, BUSE BALANTEKIN, was severely bruised, wounded and injured, suffered internal and external injuries, some of which are believed to be of a permanent nature, and was confined to her home and bed, was compelled to undergo extensive medical aid, attention and treatment in an effort to cure herself of the injuries sustained, and since some of the injuries are believed to be of a permanent and lasting nature, she will continue to suffer similar damages in the future. 39. That as a result of the foregoing, the infant plaintiff, BUSE BALANTEKIN, sustained a serious injury as defined in Section 5102(d) of the Insurance Law and an economic loss greater than basic economic loss as defined in Section 5102(a) of the Insurance Law. 40. That as a result of the foregoing, the infant plaintiff, BUSE BALANTEKIN, has been damaged in an amount that exceeds the jurisdictional limits of all lower Courts. AS AND FOR A THIRD CAUSE OF ACTION ON BEHALF OF THE INFANT PLAINTIFF, FURKAN BALANTEKIN 41. The infant plaintiff, FURKAN BALANTEKIN, repeats, reiterates, and realleges each and every allegation contained in paragraphs of the Verified Complaint designated "1" through "40" inclusive with the same force and effect as though said paragraphs were more fully set forth herein at length. 42. That at the aforementioned time and place the infant plaintiff, FURKAN BALANTEKIN, was a passenger in the aforesaid 2002 Toyota vehicle. 43. That by reason of the foregoing, the infant plaintiff, FURKAN BALANTEKIN, sustained great bodily injury. 44. That by reason of the foregoing, the infant plaintiff, FURKAN BALANTEKIN, was severely bruised, wounded and injured, suffered internal and external injuries, some of which are believed to be of a permanent nature, and was confined to his home and bed, was compelled to undergo extensive medical aid, attention and treatment in an effort to cure himself of the injuries sustained, and since some of the injuries are believed to be of a permanent and lasting nature, he will continue to suffer similar damages in the future. 45. That as a result of the foregoing, the infant plaintiff, FURKAN BALANTEKIN, sustained a serious injury as defined in Section 5102(d) of the Insurance Law and an economic loss greater than basic economic loss as defined in Section 5102(a) of the Insurance Law. 46. That as a result of the foregoing, the infant plaintiff, FURKAN BALANTEKIN, has been damaged in an amount that exceeds the jurisdictional limits of all lower Courts. WHEREFORE, the plaintiffs demands judgment against the defendants in an amount which exceeds the jurisdictional limits of all lower Courts on the First Cause of Action, the plaintiffs demands judgment against the defendants in an amount which exceeds the jurisdictional limits of all lower Courts on the Second Cause of Action, and the plaintiffs demands judgment against the defendants in an amount which exceeds the jurisdictional limits of all lower Courts on the Third Cause of Action, together with costs, disbursements and such other or further relief which this Court deems is just and proper. DATED: New York, New York February 17, 2015 Respectfully submitted AKIN LAW GROUP PLLC Attorneys for the Plaintiff / s / Gulsah Senol ________________________ By: Gulsah Senol Esq. 45 Broadway, Suite 1420 New York, New York 10006 (212) 825-1400 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No: 504203/2013 -------------------------------------------------------------------X AYSE BALANTEKIN as the mother and natural guardian of infants BUSE BALANTEKIN and FURKAN BALANTEKIN and AYSE BALANTEKIN Individually, Plaintiffs, ATTORNEY'S VERIFICATION - against - CHRIS E. GLANVILL and TAMARA GLANVILL, Defendant. -------------------------------------------------------------------X I, Gulsah Senol, being duly sworn deposes and state under the penalties of perjury that: I am an attorney duly admitted to practice law in the courts of New York State and am an associate at AKIN LAW GROUP PLLC, the attorneys of record for the plaintiffs in the within action. I have read the foregoing, AMENDED VERIFIED COMPLAINT, and know the contents thereof; the same is true to my own knowledge, except as to the matters therein alleged to be on information and belief, and as to those matters I believe them to be true. The reason this verification is made by me and not by the Plaintiffs is that the Plaintiffs resides in a county other than where we maintain our office. The grounds of my belief as to all matters not stated upon my own knowledge are as follows: Conversations with the plaintiffs, review of our file and all the pleadings and proceedings heretofore had herein. Dated: New York, New York February 17, 2015 / s / Gulsah Senol ______________________ Gulsah Senol, Esq. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No: 504203/2013 -------------------------------------------------------------------X AYSE BALANTEKIN as the mother and natural guardian of infants BUSE BALANTEKIN and FURKAN BALANTEKIN and AYSE BALANTEKIN Individually, Plaintiffs, - against - CHRIS E. GLANVILL and TAMARA GLANVILL, Defendant. -------------------------------------------------------------------X ______________________________________________________________________________ AMENDED SUMMONS AND AMENDED VERIFIED COMPLAINT ______________________________________________________________________________ AKIN LAW GROUP PLLC Attorneys for Plaintiff 45 Broadway, Suite 1420 New York, New York 10006 Tel. (212) 825-1400 Fax. (212) 825-1440