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INDEX NO. 154026/2012
NYSCEF DOC. NOJ 1 RECEIVED NYSCEF: ,06/26/2012
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Moo a +--+ eee eee
TAKISHA BLAIR, Index #:
Date filed:
Plaintiff(s),
Plaintiff's designate
NEW YORK
County as place of trial
-against -
The basis of the venue is:
Plaintiffs Residence
CAROLYN CRUMES and ALBERT GRUMES,
SUMMONS
Defendant(s) . Plaintiff resides at:
250 West 131* Street
++-- ee eee x County of NEW YORK
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 attorney for the plaintiff(s) within twenty (20) days
after service of this Summons, exclusive of the day of service [or within thirty (30) days
after 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 for the relief demanded in the complaint.
DATED: New York, New York
May 30, 2012
Yours, etc.,
ais)
ETH D, ZUKO! SQ
‘Attorney for Plaintiff(s) ‘
275 Madison Avenue, Suite 705
New York, N.Y. 10016
(212)732-0040
DEFENDANT(S) ADDRESS(ES):
CAROLYN CRUMES
209 West 119" Street, Apt. 3L or Apt. 4
New York, New York 10026
ALBERT CRUMES.
209 West 119" Street, Apt. 3L
New York, New York 10026
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
aon eee eee ee
TAKISHA BLAIR, Index #:
Plaintiff(s), VERIFIED
COMPLAINT
-against-
CAROLYN CRUMES and ALBERT CRUMES,
Defendant(s).
meee eee ne ------
Plaintiff, by her attorney, SETH D. ZUKOFF, upon information and belief, at all
times hereinafter mentioned, alleges:
’ AS AND FOR THE FIRST CAUSE OF ACTION
1 Plaintiff, TAKISHA BLAIR resided and still resides at 250 West 131%
Street, in the County, City and State of New York.
2 Defendant, CAROLYN CRUMES resided and still resides at 209 West
131* Street, Apt. 3L, in the County, City and State of New York.
3 On or about the 11" day of June, 2010, defendant CAROLYN CRUMES
owned a 2000 Mercedes Benz motor vehicle bearing New York State license plate
number ETK3418.
4 Defendant, ALBERT CRUMES resided and still resides at 209 West
131" Street, Apt. 3L, in the County, City and State of New York.
5. On or about the 11" day of June 2010, defendant ALBERT CRUMES
operated the aforesaid motor vehicle.
6 On or about the 11" day of June 2010, defendant ALBERT CRUMES
controlled the aforesaid motor vehicle.
7 On or about the 11" day of June 2010, defendant ALBERT CRUMES
operated and controlled the aforesaid motor vehicle with the permission and consent
of the owner, defendant CAROLYN CRUMES
8 That on or about the 11" day of June 2010, West 118" Street at the
intersection St. Nicholas Avenue, was and stiil is a public thoroughfare in the County,
City and State of New York.
9 That on or about the 11" day of June 2010, while the plaintiff, TAKISHA
BLAIR was lawfully and properly operating a motor vehicle on West 118" Street at the
intersection of St. Nicholas Avenue, in the County, City and State of New York, the
defendants' motor vehicle struck plaintiff.
10. Plaintiff, TAKISHA BLAIR was injured.
11. Plaintiff, TAKISHA BLAIR was seriously injured.
12. The aforesaid occurrence and resulting injuries to plaintiff, TAKISHA
BLAIR was due solely to the carelessness, recklessness and negligence of the
defendants without any fault or wrongdoing on the part of the plaintiff contributing
thereto.
13. Plaintiff, TAKISHA BLAIR has sustained a serious injury as defined as
subdivision (d) of Section 5102 of the insurance Law, or economic loss greater than
economic loss as defined in subdivision (a) of Section 5102 of the Insurance Law.
14. This action falis within one or more of the exceptions set forth in CPLR
1602.
15. By reason of the foregoing, plaintiff has been damaged.
WHEREFORE, plaintiff demands judgment against the defendants in the First
Cause of Action in the amount which exceeds the jurisdictional limits of all lower courts
in which this matter may have been brought, with interest from the date of occurrence,
together with the costs and disbursements of this action.
Dated: New York, New York
May 30, 2012
Yours, tc.
THT
ETH ZUKOFF, E:
Attorney for Plaintiff
275 Madison Avenue
Suite 705
New York, N.Y. 10016
(212) 732-0040
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INDEX NO. 154026/2012 NYSCEF DOC. NOJ 1 RECEIVED NYSCEF: ,06/26/2012 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Moo a +--+ eee eee TAKISHA BLAIR, Index #: Date filed: Plaintiff(s), Plaintiff's designate NEW YORK County as place of trial -against - The basis of the venue is: Plaintiffs Residence CAROLYN CRUMES and ALBERT GRUMES, SUMMONS Defendant(s) . Plaintiff resides at: 250 West 131* Street ++-- ee eee x County of NEW YORK 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 attorney for the plaintiff(s) within twenty (20) days after service of this Summons, exclusive of the day of service [or within thirty (30) days after 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 for the relief demanded in the complaint. DATED: New York, New York May 30, 2012 Yours, etc., ais) ETH D, ZUKO! SQ ‘Attorney for Plaintiff(s) ‘ 275 Madison Avenue, Suite 705 New York, N.Y. 10016 (212)732-0040 DEFENDANT(S) ADDRESS(ES): CAROLYN CRUMES 209 West 119" Street, Apt. 3L or Apt. 4 New York, New York 10026 ALBERT CRUMES. 209 West 119" Street, Apt. 3L New York, New York 10026 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK aon eee eee ee TAKISHA BLAIR, Index #: Plaintiff(s), VERIFIED COMPLAINT -against- CAROLYN CRUMES and ALBERT CRUMES, Defendant(s). meee eee ne ------ Plaintiff, by her attorney, SETH D. ZUKOFF, upon information and belief, at all times hereinafter mentioned, alleges: ’ AS AND FOR THE FIRST CAUSE OF ACTION 1 Plaintiff, TAKISHA BLAIR resided and still resides at 250 West 131% Street, in the County, City and State of New York. 2 Defendant, CAROLYN CRUMES resided and still resides at 209 West 131* Street, Apt. 3L, in the County, City and State of New York. 3 On or about the 11" day of June, 2010, defendant CAROLYN CRUMES owned a 2000 Mercedes Benz motor vehicle bearing New York State license plate number ETK3418. 4 Defendant, ALBERT CRUMES resided and still resides at 209 West 131" Street, Apt. 3L, in the County, City and State of New York. 5. On or about the 11" day of June 2010, defendant ALBERT CRUMES operated the aforesaid motor vehicle. 6 On or about the 11" day of June 2010, defendant ALBERT CRUMES controlled the aforesaid motor vehicle. 7 On or about the 11" day of June 2010, defendant ALBERT CRUMES operated and controlled the aforesaid motor vehicle with the permission and consent of the owner, defendant CAROLYN CRUMES 8 That on or about the 11" day of June 2010, West 118" Street at the intersection St. Nicholas Avenue, was and stiil is a public thoroughfare in the County, City and State of New York. 9 That on or about the 11" day of June 2010, while the plaintiff, TAKISHA BLAIR was lawfully and properly operating a motor vehicle on West 118" Street at the intersection of St. Nicholas Avenue, in the County, City and State of New York, the defendants' motor vehicle struck plaintiff. 10. Plaintiff, TAKISHA BLAIR was injured. 11. Plaintiff, TAKISHA BLAIR was seriously injured. 12. The aforesaid occurrence and resulting injuries to plaintiff, TAKISHA BLAIR was due solely to the carelessness, recklessness and negligence of the defendants without any fault or wrongdoing on the part of the plaintiff contributing thereto. 13. Plaintiff, TAKISHA BLAIR has sustained a serious injury as defined as subdivision (d) of Section 5102 of the insurance Law, or economic loss greater than economic loss as defined in subdivision (a) of Section 5102 of the Insurance Law. 14. This action falis within one or more of the exceptions set forth in CPLR 1602. 15. By reason of the foregoing, plaintiff has been damaged. WHEREFORE, plaintiff demands judgment against the defendants in the First Cause of Action in the amount which exceeds the jurisdictional limits of all lower courts in which this matter may have been brought, with interest from the date of occurrence, together with the costs and disbursements of this action. Dated: New York, New York May 30, 2012 Yours, tc. THT ETH ZUKOFF, E: Attorney for Plaintiff 275 Madison Avenue Suite 705 New York, N.Y. 10016 (212) 732-0040