Preview
FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
SUMMONS
---------------------------------- ---------------X
Plaintiff designates New York
CARMEN ROMERO,
County as the place of trial.
Plaintiff,
-against- The basis of venue is:
Plaintiff's Residence and the
of Occurrence
THE CITY OF NEW YORK, THE NEW YORK CITY County
DEPARTMENT OF TRANSPORTATION and THE NEW
Plaintiff resides at:
YORK CITY DEPARTMENT OF EDUCATION,
1 Sickles Street
Defendants.
-------------------- New York, NY 10040
X
County of New York
To the above named Defendant:
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 Plaintiffs 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 demanded in the complaint.
Dated: New York, New York
January 10, 2019 .
S-TE9EN ADAM RUB , .
STEVEN ADAM RUBIN & AS TES, PLLC
23rd
71 West Street'Suite 1623
New York, New York 10010
(212)-643-5402
TO: THE CITY OF NEW YORK
The City of New York/Law Department .
Corporation Counsel
100 Church Street
New York, NY 10007
THE NEW YORK CITY
DEPARTMENT OF EDUCATION
Corporation Counsel
100 Church Street
New York, NY 10007
THE NEW YORK CITY
DEPARTMENT OF TRANSPORTATION
Corporation Counsel
100 Church Street
New York,.NY 10007
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK SUMMONS
______--------_______________________ -----X
Plaintiff designates New York
CARMEN ROMERO,,
County as the place of trial.
Plaintiff,
-against- The basis of venue is:
Plaintiff's Residence and the
of Occurrence
THE CITY OF NEW YORK, THE NEW YORK CITY County
DEPARTMENT OF TRANSPORTATION and THE NEW
Plaintiff resides at:
YORK CITY DEPARTMENT OF EDUCATION,
1 Sickles Street
Defendants.
----------------------- -- X New York, NY 10040
County of New York
To the above named Defendant:
You are hereby summoned to answer the complaint in this action, and to serve a
copy of your answer, or, ifthe complaint is not served with this summons, to serve a notice of
appearance on the Plaintiffs 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 demanded in the complaint.
Dated: New York, New York
January 10, 2019
VEN ADAM R ESQ
STEVEN ADAM RUBIN SOCIATES, PLLC
23rd
71 West Street Suite 1623
New York, New York 10010
(212)-643-5402
TO: THE CITY OF NEW YORK
The City of New York/Law Department
Corporation Counsel
100 Church Street
New York, NY 10007
THE NEW YORK CITY
DEPARTMENT OF EDUCATION
Corporation Counsel
100 Church Street
New York, NY 10007
THE NEW YORK CITY
DEPARTMENT OF TRANSPORTATION
Corporation Counsel
100 Church Street
New York, NY 10007
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
____-._.-_____________------------------------------------X
CARMEN ROMERO,
VERIFIED COMPLAINT
Plaintiff,
-against-
THE CITY OF NEW YORK, THE NEW YORK CITY
DEPARTMENT OF TRANSPORTATION and THE NEW
YORK CITY DEPARTMENT OF EDUCATION,
Defendants.
-----------------------------------------------------X
Plaintiff CARMEN ROMERO, by her attorneys, STEVEN ADAM RUBIN &
ASSOCIATES, PLLC, complaining of the Defendants THE CITY OF NEW YORK, THE
NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK
CITY DEPARTMENT OF EDUCATION, respectfully alleges, upon information and belief:
1. That at the time of the commencement of this action, Plaintiff CARMEN
ROMERO resided in the County, City and State of New York.
2. That the cause of action alleged herein arose in the County, City and State of New
York.
3. That this action falls within one or more of the exceptions set forth in CPLR
§1602.
4. That on August 24, 2018, and within the time prescribed by law, a sworn Notice
of Claim stating, among other things, the time when and place where the injuries
and damages were sustained, together with Plaintiffs demands for adjustment
thereof was duly served on the claimant's/Plaintiff's behalf on Defendants THE
CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF
3
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TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF
EDUCATION and that thereafter they have refused or neglected for more than
thirty (30) days, and up to the commeñcemêñt of this action, to make any
adjustment or payment thereof, and that thereafter, and within the time provided
by law, this action was commenced.
5. That on October 17, 2018, a hearing, on behalf of Plaintiff against THE CITY
OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF
TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF
EDUCATION, and pursuant to General Municipal Law Section 50-H, was held.
6. That on July 25, 2018, and at all times herein mentioned, Defendant THE CITY
OF NEW YORK, was and stillis, a municipal corporations.
7. That on July 25, 2018, and at all times herein mentioned, Defendant THE CITY
OF NEW YORK, by its agents, servants and/or employees operated and
maintained defendants THE NEW YORK CITY DEPARTMENT OF
TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF
EDUCATION.
8. That this action is being commeñced within one year and ninety days after accrual
of this cause of action, or within the time allowed by law.
9. That on July 25, 2018, and at all times herein mentioned, a public thoroughfare
and sidewalk portions thereto existed in the County, City and State of New York,
in front of The Professor Juan Bosch School, PS 178, located at 12-18 Ellwood
Street.
4
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10. That on July 25, 2018, and at all times herein mentioned a premises existed
adjacent to the above noted address, owned and operated by Defendants THE
CITY OF NEW YORK and THE NEW YORK CITY DEPARTMENT OF
EDUCATION.
11. That on July 25, 2018, and at all times herein mentioned, the aforesaid
thoroughfare and the sidewalk portions in front of and adjacent to the above-
mentioned premises were owned by Defendants THE CITY OF NEW YORK,
and THE NEW YORK CITY DEPARTMENT OF EDUCATION.
12. That on July 25, 2018, and at all times herein mentioned, the aforesaid
thoroughfare and the sidewalk portions in front of and adjacent to the above-
mentioned premises were operated and managed by Defendants THE CITY OF
NEW YORK, THE NEW YORK CITY DEPARTMENT OF
TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF
EDUCATION.
13. That on July 25, 2018, and at all times herein mentioned, the aforesaid
thoroughfare and the sidewalk portions in front of and adjacent to the above-
mentioned premises were maintained by Defendants THE CITY OF NEW
YORK,,THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION
and THE NEW YORK CITY DEPARTMENT OF EDUCATION.
. .
14. That on July 25, 2018, and at all times herein mentioned, it was the duty of
Defendants THE CITY OF NEW YORK, THE NEW YORK CITY
DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY
DEPARTMENT OF EDUCATION to maintain the public thoroughfares, more
. .
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specifically the thoroughfare and the sidewalk portions in front of and adjacent to
The Professor Juan Bosch School, PS 178, located at 12-18 Ellwood Street, in the
County, City and State of New York, in a reasonably safe condition.
15. That on July 25, 2018, Plaintiff CARMEN ROMERO was a lawful pedestrian at
the above-mentioned location.
16. That on July 25, 2018, while Plaintiff was lawfully walking at the aforesaid
location, she was caused to trip and fall and sustain severe and permanent injuries.
17. The above mentioned occurrence, and the results thereof, were caused wholly and
solely by the negligence of Defendants THE CITY OF NEW YORK, THE
NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE
NEW YORK CITY DEPARTMENT OF EDUCATION and/or said
Defendants'
agents, servants, employees and/or licensees in the ownership,
operation, management, maintenance, repair and control of the aforesaid
thoroughfares and the sidewalk portions in front of and adjacent thereto; and
Defendants were otherwise negligent, careless and reckless.
18. That, upon information and belief, Defendants THE CITY OF NEW YORK,
THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and
THE NEW YORK CITY DEPARTMENT OF EDUCATION had actual
notice of this defective condition for at least fifteen (15) days prior to July 25,
2018.
19. That no negligence on the part of the Plaintiff contributed to the occurrence
alleged herein in any manner whatsoever.
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20. That as a result of the foregoing, Plaintiff CARMEN ROMERO was 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 Plaintiffs normal activities and duties and has
sustained a resultant loss therefrom.
21. That as a result of the foregoing, Plaintiff CARMEN ROMERO was damaged in
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.
Dated: New York, New York
January 10, 2019
Yours, etc.
,AfEVEN ADAM RUBIN, .
STEVEN ADAM RUBIN & ASSOC S, PLLC
23"1
71 West Street Suite 1623
New York, NY 10010
(212) 643-5402
7
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VERIFICATION
STATE OF NEW YORK
as:
COUNTY OF NEW YORK
Carmen Romero, being duly sworn, says:
I am a Plaintiff in the action herein: I have read the
annexed SUMMONS AND COMPLAINT and know the contents thereof, and
the same are true to my knowledge, except those matters therein
which are stated to be alleged upon information and belief, and
as to those matters I believe them to be true. My belief as to
those matters therein not stated upon knowledge, is based upon
facts, records, and other pertinent information contained in my
personal files.
DATED: New York, New York
Carmen Romero
Sworn to before me this
/fGday of ,
140 ary Public
MOJDEH RUBIN
Commissioner of Deeds,City of New York
. No. 1-7048
Cert. Filedin New York County
Commission Expires n h /1er . .
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Preview
FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK SUMMONS ---------------------------------- ---------------X Plaintiff designates New York CARMEN ROMERO, County as the place of trial. Plaintiff, -against- The basis of venue is: Plaintiff's Residence and the of Occurrence THE CITY OF NEW YORK, THE NEW YORK CITY County DEPARTMENT OF TRANSPORTATION and THE NEW Plaintiff resides at: YORK CITY DEPARTMENT OF EDUCATION, 1 Sickles Street Defendants. -------------------- New York, NY 10040 X County of New York To the above named Defendant: 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 Plaintiffs 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 demanded in the complaint. Dated: New York, New York January 10, 2019 . S-TE9EN ADAM RUB , . STEVEN ADAM RUBIN & AS TES, PLLC 23rd 71 West Street'Suite 1623 New York, New York 10010 (212)-643-5402 TO: THE CITY OF NEW YORK The City of New York/Law Department . Corporation Counsel 100 Church Street New York, NY 10007 THE NEW YORK CITY DEPARTMENT OF EDUCATION Corporation Counsel 100 Church Street New York, NY 10007 THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION Corporation Counsel 100 Church Street New York,.NY 10007 1 of 8 FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK SUMMONS ______--------_______________________ -----X Plaintiff designates New York CARMEN ROMERO,, County as the place of trial. Plaintiff, -against- The basis of venue is: Plaintiff's Residence and the of Occurrence THE CITY OF NEW YORK, THE NEW YORK CITY County DEPARTMENT OF TRANSPORTATION and THE NEW Plaintiff resides at: YORK CITY DEPARTMENT OF EDUCATION, 1 Sickles Street Defendants. ----------------------- -- X New York, NY 10040 County of New York To the above named Defendant: You are hereby summoned to answer the complaint in this action, and to serve a copy of your answer, or, ifthe complaint is not served with this summons, to serve a notice of appearance on the Plaintiffs 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 demanded in the complaint. Dated: New York, New York January 10, 2019 VEN ADAM R ESQ STEVEN ADAM RUBIN SOCIATES, PLLC 23rd 71 West Street Suite 1623 New York, New York 10010 (212)-643-5402 TO: THE CITY OF NEW YORK The City of New York/Law Department Corporation Counsel 100 Church Street New York, NY 10007 THE NEW YORK CITY DEPARTMENT OF EDUCATION Corporation Counsel 100 Church Street New York, NY 10007 THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION Corporation Counsel 100 Church Street New York, NY 10007 2 of 8 FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ____-._.-_____________------------------------------------X CARMEN ROMERO, VERIFIED COMPLAINT Plaintiff, -against- THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION, Defendants. -----------------------------------------------------X Plaintiff CARMEN ROMERO, by her attorneys, STEVEN ADAM RUBIN & ASSOCIATES, PLLC, complaining of the Defendants THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION, respectfully alleges, upon information and belief: 1. That at the time of the commencement of this action, Plaintiff CARMEN ROMERO resided in the County, City and State of New York. 2. That the cause of action alleged herein arose in the County, City and State of New York. 3. That this action falls within one or more of the exceptions set forth in CPLR §1602. 4. That on August 24, 2018, and within the time prescribed by law, a sworn Notice of Claim stating, among other things, the time when and place where the injuries and damages were sustained, together with Plaintiffs demands for adjustment thereof was duly served on the claimant's/Plaintiff's behalf on Defendants THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF 3 3 of 8 FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019 TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION and that thereafter they have refused or neglected for more than thirty (30) days, and up to the commeñcemêñt of this action, to make any adjustment or payment thereof, and that thereafter, and within the time provided by law, this action was commenced. 5. That on October 17, 2018, a hearing, on behalf of Plaintiff against THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION, and pursuant to General Municipal Law Section 50-H, was held. 6. That on July 25, 2018, and at all times herein mentioned, Defendant THE CITY OF NEW YORK, was and stillis, a municipal corporations. 7. That on July 25, 2018, and at all times herein mentioned, Defendant THE CITY OF NEW YORK, by its agents, servants and/or employees operated and maintained defendants THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION. 8. That this action is being commeñced within one year and ninety days after accrual of this cause of action, or within the time allowed by law. 9. That on July 25, 2018, and at all times herein mentioned, a public thoroughfare and sidewalk portions thereto existed in the County, City and State of New York, in front of The Professor Juan Bosch School, PS 178, located at 12-18 Ellwood Street. 4 4 of 8 FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019 10. That on July 25, 2018, and at all times herein mentioned a premises existed adjacent to the above noted address, owned and operated by Defendants THE CITY OF NEW YORK and THE NEW YORK CITY DEPARTMENT OF EDUCATION. 11. That on July 25, 2018, and at all times herein mentioned, the aforesaid thoroughfare and the sidewalk portions in front of and adjacent to the above- mentioned premises were owned by Defendants THE CITY OF NEW YORK, and THE NEW YORK CITY DEPARTMENT OF EDUCATION. 12. That on July 25, 2018, and at all times herein mentioned, the aforesaid thoroughfare and the sidewalk portions in front of and adjacent to the above- mentioned premises were operated and managed by Defendants THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION. 13. That on July 25, 2018, and at all times herein mentioned, the aforesaid thoroughfare and the sidewalk portions in front of and adjacent to the above- mentioned premises were maintained by Defendants THE CITY OF NEW YORK,,THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION. . . 14. That on July 25, 2018, and at all times herein mentioned, it was the duty of Defendants THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION to maintain the public thoroughfares, more . . 5 5 of 8 FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019 specifically the thoroughfare and the sidewalk portions in front of and adjacent to The Professor Juan Bosch School, PS 178, located at 12-18 Ellwood Street, in the County, City and State of New York, in a reasonably safe condition. 15. That on July 25, 2018, Plaintiff CARMEN ROMERO was a lawful pedestrian at the above-mentioned location. 16. That on July 25, 2018, while Plaintiff was lawfully walking at the aforesaid location, she was caused to trip and fall and sustain severe and permanent injuries. 17. The above mentioned occurrence, and the results thereof, were caused wholly and solely by the negligence of Defendants THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION and/or said Defendants' agents, servants, employees and/or licensees in the ownership, operation, management, maintenance, repair and control of the aforesaid thoroughfares and the sidewalk portions in front of and adjacent thereto; and Defendants were otherwise negligent, careless and reckless. 18. That, upon information and belief, Defendants THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION and THE NEW YORK CITY DEPARTMENT OF EDUCATION had actual notice of this defective condition for at least fifteen (15) days prior to July 25, 2018. 19. That no negligence on the part of the Plaintiff contributed to the occurrence alleged herein in any manner whatsoever. 6 of 8 FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019 20. That as a result of the foregoing, Plaintiff CARMEN ROMERO was 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 Plaintiffs normal activities and duties and has sustained a resultant loss therefrom. 21. That as a result of the foregoing, Plaintiff CARMEN ROMERO was damaged in 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. Dated: New York, New York January 10, 2019 Yours, etc. ,AfEVEN ADAM RUBIN, . STEVEN ADAM RUBIN & ASSOC S, PLLC 23"1 71 West Street Suite 1623 New York, NY 10010 (212) 643-5402 7 7 of 8 FILED: NEW YORK COUNTY CLERK 01/16/2019 01:48 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2019 VERIFICATION STATE OF NEW YORK as: COUNTY OF NEW YORK Carmen Romero, being duly sworn, says: I am a Plaintiff in the action herein: I have read the annexed SUMMONS AND COMPLAINT and know the contents thereof, and the same are true to my knowledge, except those matters therein which are stated to be alleged upon information and belief, and as to those matters I believe them to be true. My belief as to those matters therein not stated upon knowledge, is based upon facts, records, and other pertinent information contained in my personal files. DATED: New York, New York Carmen Romero Sworn to before me this /fGday of , 140 ary Public MOJDEH RUBIN Commissioner of Deeds,City of New York . No. 1-7048 Cert. Filedin New York County Commission Expires n h /1er . . 8 of 8