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(FILED: NEW YORK COUNTY CLERK 0671972012) INDEX NO. 153814/2012
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/19/2012
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
INDEX NO,
CHERCAL HUDSON, Plaintiff designate
NEW YORK
Plaintiffs,
as the place for trial
‘The basis of venue is
-against- Plaintiff's Residence
4
SUMMONS
JANET CAMARGO-SOTELO AND FRANK SOLER,
Plaintiff’ Residence
230 East 123 Street
Defendants. County of NEW YORK
To The Above Named Defendants
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 Attorneys 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: Bronx, New York LAW FIRM OF NONNA SHIKH, PC
June 19, 2912
Defendants‘ Address: Attorney for Plaintiff
Office & P.O. Box
JANET CAMARGO- SOTELO 400 East Fordham Road, Suite 202
123 East 116" Street, Apt. 2C Bronx, New York 10458
New York, New York 10029 Telephone (718) 295-4000
FRANK SOLER
100 Darrow Place, Apt. #19
Bronx, NY 10475
+
2
YOU SHOULD IMMEDIATELY BRING THESE DOCUMENTS
. TO YOUR ATTORNEY OR INSURANCE COMPANY
t
2
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
CHERCAL HUDSON, INDEX #
Plaintiff,
~against- VERIFIED COMPLAINT
JANET CAMARGO-SOTELO AND FRANK SOLER,
Defendants.
Plaintiffs, complaining of the defendants, by their attorneys LAW FIRM OF
NONNA SHIKH, P.C., respectfully show to this Court and allege:
1. That on December 2, 2011, plaintiff CHERCAL HUDSON was and still is a
resident of the County of New York, City and State of New York.
2, That on December 2, 2011, Park Avenue at or about East 120" Street, New
York, New York was and siill is a public roadway.
3. That on December 2, 2011, upon information and belief, defendant JANET
CAMARGO-SOTELO was the owner ofa 2000 Ford vehicle bearing Illinois State License
Plate No. N1S5566.
4. That on December 2, 2011, upon information and belief, defendant JANET
CAMARGO-SOTELO was the operator of the 2000 Ford vehicie bearing Illinois State
License Plate Na. N155566.
5 That on December 2, 2011, upon information and belief, defendant FRANK
SOLER was the owner of a 2008 Honda vehicle bearing New York State License Plate No.
BRONXS1.
u
6. That on December 2, 2011, upon information and belief, defendant FRANK
SOLER was the operator of the 2008 Honda vehicle bearing New York State License Plate
No. BRONXS1,
7. That on December 2, 2011, plaintiff CHERCAL HUDSON was the operator of a
2003 Nissan vehicle bearing New York State License Plate number MYRASCAL.
8. That on December 2, 2011, defendants as stated herein was negligent in the
ownership, operation, maintenance and control of their motor vehicles in colliding.
9. Plainttt CHIERCAL HUDSON has sustained serious injury as defined in
Subsection (d) of Section 5102 of the Insurance Law of the State of New York.
10. That solely as a result of the negligence of the defendant as stated herein,
plaintiff, CHERCAL HUDSON sustained serious, severe and permanent injuries and
disabilities; pain and suffering and loss of enjoyment of life; was rendered sick, sore, lame
i
and disabled; sustained severe mental anguish, nervous shock and great physical pain; was
compelled to obiain medical treatment and will be compelled to undergo further medical
treatment for an undetermined amount of time, and has been damaged accordingly in the
sum that exceeds the jurisdictional limits of all lower courts.
WHEREFORE, plaintiff, CHERCAL HUDSON, demands judgment against defendant
as stated herein.: in the sum that exceeds the jurisdictional limits of all lower courts such higher
amount as may be determined by a Court and/or jury together with the costs and
disbursements of this action.
Dated: Bronx, New York
June 19, gon
x
LAW FIRM OF NONNA SHIKH, P.C.
Attorneys for Plaintiffs
400 East Fordham Road, Suite 202
Bronx, New York 10458
STATE OFNEW YORK )
COUNTY OF BRONX } ss
INDIVIDUAL VERIPICATION
The onesie ng duly swarr, deposes and says thal the deponent is the
plaintiff in the within action; that deponent hes read the foregoing and knows the contents
thereof; that the same are true to dspanent's own kaowledge, except as to the matters
therein stated 19 be alleged on information and belief, and that 2s to those matters
deponent believes ther lo be ue.
CL Mien
fore this
i
Daye 20 fe.
NOTARW SU LIC
Law Cfficas of Nonna Shikh
Notary Public, State of New Yor,: 400 E.Bronx,
Fordham Rd Sulte 802
NY 10458
Ne lo. O2SH507-
Quat lifted in Broy nx 7877 Tel:(718}295-4000
‘oMmMission Event, Coui ty.
es 5/12) 13
SUPREME COURT OF STATE OF NEW YORK
COUNTY OF NEW YORK.
rn na ne ne eet tree eee meena nee ener ttn net —~
CHERCAL HUDSON,
Plaintiff,
~against-
JANET CAMARGO-SOTELO AND FRANK SOLER
Defendants,
SUMMONS AN RIFIED COMPLAINT
wenn ee tenn nn eens ann nnn ee ee trent
‘A SHIKEY
LAW FL F NONNA SHIKH, P.C.
torneys for Plaintiff
400 East Fordham Road, Suite 202
x, New York 10458
(718) 295-4000
Preview
(FILED: NEW YORK COUNTY CLERK 0671972012) INDEX NO. 153814/2012 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/19/2012 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK INDEX NO, CHERCAL HUDSON, Plaintiff designate NEW YORK Plaintiffs, as the place for trial ‘The basis of venue is -against- Plaintiff's Residence 4 SUMMONS JANET CAMARGO-SOTELO AND FRANK SOLER, Plaintiff’ Residence 230 East 123 Street Defendants. County of NEW YORK To The Above Named Defendants 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 Attorneys 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: Bronx, New York LAW FIRM OF NONNA SHIKH, PC June 19, 2912 Defendants‘ Address: Attorney for Plaintiff Office & P.O. Box JANET CAMARGO- SOTELO 400 East Fordham Road, Suite 202 123 East 116" Street, Apt. 2C Bronx, New York 10458 New York, New York 10029 Telephone (718) 295-4000 FRANK SOLER 100 Darrow Place, Apt. #19 Bronx, NY 10475 + 2 YOU SHOULD IMMEDIATELY BRING THESE DOCUMENTS . TO YOUR ATTORNEY OR INSURANCE COMPANY t 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK CHERCAL HUDSON, INDEX # Plaintiff, ~against- VERIFIED COMPLAINT JANET CAMARGO-SOTELO AND FRANK SOLER, Defendants. Plaintiffs, complaining of the defendants, by their attorneys LAW FIRM OF NONNA SHIKH, P.C., respectfully show to this Court and allege: 1. That on December 2, 2011, plaintiff CHERCAL HUDSON was and still is a resident of the County of New York, City and State of New York. 2, That on December 2, 2011, Park Avenue at or about East 120" Street, New York, New York was and siill is a public roadway. 3. That on December 2, 2011, upon information and belief, defendant JANET CAMARGO-SOTELO was the owner ofa 2000 Ford vehicle bearing Illinois State License Plate No. N1S5566. 4. That on December 2, 2011, upon information and belief, defendant JANET CAMARGO-SOTELO was the operator of the 2000 Ford vehicie bearing Illinois State License Plate Na. N155566. 5 That on December 2, 2011, upon information and belief, defendant FRANK SOLER was the owner of a 2008 Honda vehicle bearing New York State License Plate No. BRONXS1. u 6. That on December 2, 2011, upon information and belief, defendant FRANK SOLER was the operator of the 2008 Honda vehicle bearing New York State License Plate No. BRONXS1, 7. That on December 2, 2011, plaintiff CHERCAL HUDSON was the operator of a 2003 Nissan vehicle bearing New York State License Plate number MYRASCAL. 8. That on December 2, 2011, defendants as stated herein was negligent in the ownership, operation, maintenance and control of their motor vehicles in colliding. 9. Plainttt CHIERCAL HUDSON has sustained serious injury as defined in Subsection (d) of Section 5102 of the Insurance Law of the State of New York. 10. That solely as a result of the negligence of the defendant as stated herein, plaintiff, CHERCAL HUDSON sustained serious, severe and permanent injuries and disabilities; pain and suffering and loss of enjoyment of life; was rendered sick, sore, lame i and disabled; sustained severe mental anguish, nervous shock and great physical pain; was compelled to obiain medical treatment and will be compelled to undergo further medical treatment for an undetermined amount of time, and has been damaged accordingly in the sum that exceeds the jurisdictional limits of all lower courts. WHEREFORE, plaintiff, CHERCAL HUDSON, demands judgment against defendant as stated herein.: in the sum that exceeds the jurisdictional limits of all lower courts such higher amount as may be determined by a Court and/or jury together with the costs and disbursements of this action. Dated: Bronx, New York June 19, gon x LAW FIRM OF NONNA SHIKH, P.C. Attorneys for Plaintiffs 400 East Fordham Road, Suite 202 Bronx, New York 10458 STATE OFNEW YORK ) COUNTY OF BRONX } ss INDIVIDUAL VERIPICATION The onesie ng duly swarr, deposes and says thal the deponent is the plaintiff in the within action; that deponent hes read the foregoing and knows the contents thereof; that the same are true to dspanent's own kaowledge, except as to the matters therein stated 19 be alleged on information and belief, and that 2s to those matters deponent believes ther lo be ue. CL Mien fore this i Daye 20 fe. NOTARW SU LIC Law Cfficas of Nonna Shikh Notary Public, State of New Yor,: 400 E.Bronx, Fordham Rd Sulte 802 NY 10458 Ne lo. O2SH507- Quat lifted in Broy nx 7877 Tel:(718}295-4000 ‘oMmMission Event, Coui ty. es 5/12) 13 SUPREME COURT OF STATE OF NEW YORK COUNTY OF NEW YORK. rn na ne ne eet tree eee meena nee ener ttn net —~ CHERCAL HUDSON, Plaintiff, ~against- JANET CAMARGO-SOTELO AND FRANK SOLER Defendants, SUMMONS AN RIFIED COMPLAINT wenn ee tenn nn eens ann nnn ee ee trent ‘A SHIKEY LAW FL F NONNA SHIKH, P.C. torneys for Plaintiff 400 East Fordham Road, Suite 202 x, New York 10458 (718) 295-4000