Preview
FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK Ind
---------------------------------------------------------------------------X
LEANDER KNUST, SU
Plaintiff, Pla
YO
-against- trial
AMRITPAL SINGH and MDAMRIT TAXI INC, The
Pla
Defendant.
---------------------------------------------------------------------------X Pla
237
Ne
Cou
You are hereby suns:::d to answer the complaint in this
copy of your answer or, if the complaint is not served with this summon
appearance on the plaintiffs attorney(s) within twenty days after the
exclusive of the day of service where service is made by delivery upon
the state, or within 30 days after completion of service where service
manner. In case of your failure to appear or answer, judgment will
default for the relief demanded in the complaint
DATED: Brooklyn, New York
July 15, 2019
GEORGAKLIS & MALL
By:
Kostantinos Mallas
Attorneys for Plaintiff
Office and P.O. Address
9118 Fifth Avenue
1 of 6
Brooklyn, NY 1 1209
FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019
SUPREME COURT OF THE STATE OF NEW Y ORK
COUNTY OF NEW YORK
-------------------------------------------------- ---------X
LEANDER KNUST,
CO
Plaintiff,
Ind
-against-
AMRITPAL SINGH AND MDAMRIT TAXI INC,
Defendants.
--------------------------------------------------------------------X
Plaintiff, by his attorneys, GEORGAKLIS & MALLAS PLL
defendants, at all times hereinaaer mentioned, upon information and
AS AND FOR A FIRST CAUSE OF ACTION
1. On October 22, 2018, defendant MDAMRIT TAXI INC
vehicle bearing New York State license plate number 8H30J.
2. On October 22, 2018, defendant MDAMRIT TAXI INC lea
vehicle.
3. On October 22, 2018, defendant MDAMRIT TAXI
aforementioned motor vehicle.
4. On October 22, 2018, defendant MDAMRIT TAXI
aforementioned motor vehicle.
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FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019
7. On October 22, 2018, defendant AMRITPAL SINGH operate
vehicle.
8. On October 22, 2018, defendant AMRITPAL SINGH
MDAMRIT TAXI INC.
9. On October 22, 2018, defendant AMRITPAL SINGH operate
vehicle with the pennission and consent of MDAMRIT TAX INC.
10. On October 22, 2018, defendant AMRITPAL SINGH operate
vehicle while in the scope of his employment with defendant MDAMRIT
1 1. On October 22, 2018, defendant AMRITPAL SINGH leas
vehicle.
12. On October 22, 2018, defendant AMRITPAL SINGH maintained
motor vehicle.
13. On October 22, 2018, defendant AMRITPAL SINGH controlled
motor vehicle.
14. On October 22, 2018, defendant AMRITPAL SINGH repaire
motor vehicle.
15. On October 22, 2018, plaintiff LEANDER KNUST was
aforesaid location while riding a bicycle.
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FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019
18. On October 22, 2018, at approximately 1:00 am, plaintiff LEANDER KNUST was a
bicyclist at or about the aforesaid location.
19. On October 22, 2018, the motor vehicle owned by defendant, and operated by
defendant AMRITPAL SINGH, came into contact with the bicycle operated by plaintiff
LEANDER KNUST.
20. The aforementioned contact was caused by reason ofthenegligence, carelessness and
recklessness ofthe defendants in his ownership, operation, maintenance, management, repair and
control of the aforesaid motor vehicle.
21. That defendants were negligent and indulged in culpable conduct by reason of the
recklessness and carelessness in the ownership, operation, maintenance, management and
control of their aforesaid motor vehicles; in failing to properly maintain, repair and care for the
aforesaid motor vehicle; in failing to have same under reasonable and proper control; in failing
to keep a proper lookout upon a highway; in failing to give due and proper warning of the
movements of said motor vehicle; in failing to heed traffic controls; in failing to signal or give
signals; in failing to afford the plaintiff a reasonable opportunity to reach a place of safety; in
operating the motor vehicle as to cause the same to come into contact with such objects and/or
such persons as involved in said accident; in so operating the motor vehicle as to cause the
same to be in such a position on the roadway as to endanger the safety to others; in failing to
see; in failing to see that which was there to be seen; in operating said motor vehicle at such
speeds at said location as to cause the same to be of danger to others, and in violating the
statues, ordinances and regulations, of which the Court will take Judicial notice, in such cases
made and provided.
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FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019
22. By reason of the foregoing, plaintiff LEANDER KNUST was injured.
23. By reason of the foregoing, plaintiff LEANDER KNUST was seriously injured.
24. The exemptions set forth in CPLR §l 601 do not apply by reason of one or more of
the exemptions set forth in CPLR §l 602.
25. The exemptions set forth in CPLR §l 601 do not apply by reason of one or more
of the exemptions set forth in CPLR §l 602 includiñg but not limited to § 1602(6).
26. reason of the plaintiff LEANDER KNUST s=*ained a serious
By foregoiñg,
injury as defined in §5 102(d) of the Insurance Law of the State of New York and/or
economic losses defmed by §5102(a) of the Insurance Law of the State of New York.
27. By reason of the foregoing, plaintiff LEANDER KNUST has sustained damages,
both general and special, in an amount that exceeds the jurisdictional limits of all lower
Courts to be decided by a jury at the time of trial.
WHEREFORE, plaintiff LEANDER KNUST demands judgment against the defendants
in thiscause of action in an amount that exceeds the jurisdictional limits of alllower Courts to
be decided by a jury at the time of trial together with the costs and disbursements of this
action.
Dated: Brooklyn, New York
July 15, 2019
GEORGAKLIS & MALLAS, PLLC
By: stantinos Mallas Esq.
Attorneys for Plaintiff
9118 Fifth Avenue
Brooklyn, New York 1 1209
(718) 238-2400
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FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019
VERIFICATION
Kostantinos Mallas, an attorney duly admitted to practice in
affinns the following under penalties of perjury:
I am a member of Georgaklis & Mallas, PLLC, attomeys for the
action. I have read the foregoing and know the contents thereof. Upon
believe the matters alleged therein to be true.
The reason this Verification is made by me and not by plaintiff
attorneys'
in a
county other than the one in which the plaintiff's maintain
The source of my information and the grounds for my beliefs
papers, reports and investigations contained in the litigation file.
Dated: Brooklyn, New York
July 15, 2019
KOSTANTINOS MALL
6 of 6
Preview
FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Ind ---------------------------------------------------------------------------X LEANDER KNUST, SU Plaintiff, Pla YO -against- trial AMRITPAL SINGH and MDAMRIT TAXI INC, The Pla Defendant. ---------------------------------------------------------------------------X Pla 237 Ne Cou You are hereby suns:::d to answer the complaint in this copy of your answer or, if the complaint is not served with this summon appearance on the plaintiffs attorney(s) within twenty days after the exclusive of the day of service where service is made by delivery upon the state, or within 30 days after completion of service where service manner. In case of your failure to appear or answer, judgment will default for the relief demanded in the complaint DATED: Brooklyn, New York July 15, 2019 GEORGAKLIS & MALL By: Kostantinos Mallas Attorneys for Plaintiff Office and P.O. Address 9118 Fifth Avenue 1 of 6 Brooklyn, NY 1 1209 FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019 SUPREME COURT OF THE STATE OF NEW Y ORK COUNTY OF NEW YORK -------------------------------------------------- ---------X LEANDER KNUST, CO Plaintiff, Ind -against- AMRITPAL SINGH AND MDAMRIT TAXI INC, Defendants. --------------------------------------------------------------------X Plaintiff, by his attorneys, GEORGAKLIS & MALLAS PLL defendants, at all times hereinaaer mentioned, upon information and AS AND FOR A FIRST CAUSE OF ACTION 1. On October 22, 2018, defendant MDAMRIT TAXI INC vehicle bearing New York State license plate number 8H30J. 2. On October 22, 2018, defendant MDAMRIT TAXI INC lea vehicle. 3. On October 22, 2018, defendant MDAMRIT TAXI aforementioned motor vehicle. 4. On October 22, 2018, defendant MDAMRIT TAXI aforementioned motor vehicle. 2 of 6 FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019 7. On October 22, 2018, defendant AMRITPAL SINGH operate vehicle. 8. On October 22, 2018, defendant AMRITPAL SINGH MDAMRIT TAXI INC. 9. On October 22, 2018, defendant AMRITPAL SINGH operate vehicle with the pennission and consent of MDAMRIT TAX INC. 10. On October 22, 2018, defendant AMRITPAL SINGH operate vehicle while in the scope of his employment with defendant MDAMRIT 1 1. On October 22, 2018, defendant AMRITPAL SINGH leas vehicle. 12. On October 22, 2018, defendant AMRITPAL SINGH maintained motor vehicle. 13. On October 22, 2018, defendant AMRITPAL SINGH controlled motor vehicle. 14. On October 22, 2018, defendant AMRITPAL SINGH repaire motor vehicle. 15. On October 22, 2018, plaintiff LEANDER KNUST was aforesaid location while riding a bicycle. 3 of 6 FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019 18. On October 22, 2018, at approximately 1:00 am, plaintiff LEANDER KNUST was a bicyclist at or about the aforesaid location. 19. On October 22, 2018, the motor vehicle owned by defendant, and operated by defendant AMRITPAL SINGH, came into contact with the bicycle operated by plaintiff LEANDER KNUST. 20. The aforementioned contact was caused by reason ofthenegligence, carelessness and recklessness ofthe defendants in his ownership, operation, maintenance, management, repair and control of the aforesaid motor vehicle. 21. That defendants were negligent and indulged in culpable conduct by reason of the recklessness and carelessness in the ownership, operation, maintenance, management and control of their aforesaid motor vehicles; in failing to properly maintain, repair and care for the aforesaid motor vehicle; in failing to have same under reasonable and proper control; in failing to keep a proper lookout upon a highway; in failing to give due and proper warning of the movements of said motor vehicle; in failing to heed traffic controls; in failing to signal or give signals; in failing to afford the plaintiff a reasonable opportunity to reach a place of safety; in operating the motor vehicle as to cause the same to come into contact with such objects and/or such persons as involved in said accident; in so operating the motor vehicle as to cause the same to be in such a position on the roadway as to endanger the safety to others; in failing to see; in failing to see that which was there to be seen; in operating said motor vehicle at such speeds at said location as to cause the same to be of danger to others, and in violating the statues, ordinances and regulations, of which the Court will take Judicial notice, in such cases made and provided. - 3 - 4 of 6 FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019 22. By reason of the foregoing, plaintiff LEANDER KNUST was injured. 23. By reason of the foregoing, plaintiff LEANDER KNUST was seriously injured. 24. The exemptions set forth in CPLR §l 601 do not apply by reason of one or more of the exemptions set forth in CPLR §l 602. 25. The exemptions set forth in CPLR §l 601 do not apply by reason of one or more of the exemptions set forth in CPLR §l 602 includiñg but not limited to § 1602(6). 26. reason of the plaintiff LEANDER KNUST s=*ained a serious By foregoiñg, injury as defined in §5 102(d) of the Insurance Law of the State of New York and/or economic losses defmed by §5102(a) of the Insurance Law of the State of New York. 27. By reason of the foregoing, plaintiff LEANDER KNUST has sustained damages, both general and special, in an amount that exceeds the jurisdictional limits of all lower Courts to be decided by a jury at the time of trial. WHEREFORE, plaintiff LEANDER KNUST demands judgment against the defendants in thiscause of action in an amount that exceeds the jurisdictional limits of alllower Courts to be decided by a jury at the time of trial together with the costs and disbursements of this action. Dated: Brooklyn, New York July 15, 2019 GEORGAKLIS & MALLAS, PLLC By: stantinos Mallas Esq. Attorneys for Plaintiff 9118 Fifth Avenue Brooklyn, New York 1 1209 (718) 238-2400 - 4 - 5 of 6 FILED: NEW YORK COUNTY CLERK 07/17/2019 10:53 AM INDEX NO. 156977/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2019 VERIFICATION Kostantinos Mallas, an attorney duly admitted to practice in affinns the following under penalties of perjury: I am a member of Georgaklis & Mallas, PLLC, attomeys for the action. I have read the foregoing and know the contents thereof. Upon believe the matters alleged therein to be true. The reason this Verification is made by me and not by plaintiff attorneys' in a county other than the one in which the plaintiff's maintain The source of my information and the grounds for my beliefs papers, reports and investigations contained in the litigation file. Dated: Brooklyn, New York July 15, 2019 KOSTANTINOS MALL 6 of 6