Preview
FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/13/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
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ANATOLIY BENYAMINOV, SUMMONS
Plaintiff,
-against-
YULIA PINKHASOV, a/k/a JULIA PINKHASOV,
Defendant.
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TO THE ABOVE NAMED DEFENDANT:
YOU ARE HEREBY SUMMONED to appear in this action by serving a notice of
appearance on plaintiff's attorneys within 20 days after service of this summons, exclusive
of the day of service, or within 30 days after service is complete if this summons is not
personally delivered to you within the State of New York. In case of your failure to answer,
Judgment will be taken against you by default for the relief demanded in the Complaint.
The basis of venue is Plaintiff's residence. Plaintiff resides at 105-36 62nd Drive,
Forest Hills, New York 11375, in the County of Queens.
Dated : Forest Hills, New York
October 12, 2020
Yours, etc.,
Regis A. Gallet, Esq.
Law Offices of Regis A. Gallet, LLC.
Attorney for Plaintiff
118-21 Queens Boulevard, Suite 616
Forest Hills, NY 11375
(718)896-2000
File # 19M028
DEFENDANT'S ADDRESS:
JULIA PINKHASOV a/k/a
YULIA PINKHASOV
9 Vanad Drive
Roslyn, NY 11756
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FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
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ANATOLIY BENYAMINOV,
Plaintiff, COMPLAINT
-against-
YULIA PINKHASOV, a/k/a JULIA PINKHASOV,
Defendant.
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Plaintiff, by his attorneys, Law Offices of Regis A. Gallet, LLC., complaining
of the Defendant herein, respectfully shows to this Court, and alleges upon information and
belief as follows:
1. At all times hereinafter mentioned, ANATOLIY BENYAMINOV (“Plaintiff”) was
and still is a resident of the County of Queens, City and State of New York.
2. A all times hereinafter mentioned, YULIA PINKHASOV a/k/a JULIA
PINKHASOV (“Defendant”) was and still is a resident of the State of New York.
3. At all times hereinafter mentioned, Defendant was the owner of a certain
2017 Lexus motor vehicle bearing the New York State registration number EYB3951.
4. At all times hereinafter mentioned, Defendant operated and controlled the
aforesaid 2017 Lexus motor vehicle.
5. At all times hereinafter mentioned, Plaintiff was the owner of a certain 2019
Lexus motor vehicle bearing the New York State registration number CPJ2023.
6. At all times hereinafter mentioned, Plaintiff operated and controlled the
aforesaid 2019 Lexus motor vehicle.
7. At all times hereinafter mentioned, Jewel Avenue, at or near its intersection
with 137th Street, in the County of Queens, City and State of New York, were and still are
public highways, roadways and thoroughfares for the use of motor vehicles.
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FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/13/2020
8. On or about May 20, 2019, the aforesaid motor vehicles came into contact
at the aforesaid public thoroughfares.
9. The aforesaid collision and injuries resulting therefrom, were due solely and
wholly as a result of the culpable conduct and the careless and negligent manner in which
the Defendant maintained, operated and controlled her motor vehicle; in being liable under
the doctrine of res ipsa loquitur; and in otherwise causing the damages sustained by the
Plaintiff without this Plaintiff in any way contributing thereto.
10. By reason of the foregoing, the negligence and culpable conduct of said
Defendant, Plaintiff sustained serious, severe, and permanent injuries to his head, limbs
and body; still suffers and will continue to suffer for some time, great physical and mental
pain and serious bodily injury; became sick, sore, lame and disabled and so remained for
a considerable length of time.
11. By reason of the culpable conduct, wrongful, negligent and unlawful actions
of the Defendant, as aforesaid, Plaintiff sustained serious injuries as defined in Subsection
(d) of Section 5102 of the Insurance Law, or economic loss greater than basic economic
loss, as defined in Subsection (a) of Section 5102 of the Insurance Law.
12. By reason of the foregoing, the negligence and culpable conduct of said
Defendant, Plaintiff is informed and verily believes the aforesaid injuries are permanent
and that he will permanently suffer from the effects of his aforesaid injuries and that he will
be caused to suffer permanent embarrassment and continuous pain and inconvenience.
13. By reason of the foregoing, Plaintiff was compelled and did necessarily
require medical aid and attention and did necessarily pay and become liable therefore for
medicines, and upon information and belief, Plaintiff will necessarily incur similar expenses.
14. By reason of the foregoing, Plaintiff has been unable to attend to his usual
occupation and avocation in the manner required.
15. As a result of the Defendant’s negligence as aforesaid, Plaintiff has been
damaged in a sum exceeding the jurisdictional limits of all lower Courts of this State.
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FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020
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WHEREFORE, Plaintiff demands judgment against the Defendant in a sum
exceeding the jurisdictional limits of all lower Courts of this State; together with attorney's
fees and the costs and disbursements of this action.
Dated: Forest Hills, New York
October 12, 2020
Yours, etc.,
Regis A. Gallet, Esq.
Law Offices of Regis A. Gallet, LLC.
Attorney for Plaintiff
118-21 Queens Boulevard, Suite 616
Forest Hills, NY 11375
(718)896-2000
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Index No.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
ANATOLIY BENYAMINOV,
Plaintiff,
-against-
YULIA PINKHASOV, a/k/a JULIA PINKHASOV,
Defendant.
SUMMONS AND COMPLAINT
Regis A. Gallet, Esq.
Law Offices of Regis A. Gallet, LLC.
Attorneys for Plaintiff
118-21 Queens Boulevard, Suite 616
Forest Hills, NY 11375
(718)896-2000
TO:
YULIA PINKHASOV a/k/a
JULIA PINKHASOV
9 Vanad Drive
Roslyn, NY 11756
5 of 5
Preview
FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/13/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ---------------------------------------------------------------------X ANATOLIY BENYAMINOV, SUMMONS Plaintiff, -against- YULIA PINKHASOV, a/k/a JULIA PINKHASOV, Defendant. --------------------------------------------------------------------X TO THE ABOVE NAMED DEFENDANT: YOU ARE HEREBY SUMMONED to appear in this action by serving a notice of appearance on plaintiff's attorneys within 20 days after service of this summons, exclusive of the day of service, or within 30 days after service is complete if this summons is not personally delivered to you within the State of New York. In case of your failure to answer, Judgment will be taken against you by default for the relief demanded in the Complaint. The basis of venue is Plaintiff's residence. Plaintiff resides at 105-36 62nd Drive, Forest Hills, New York 11375, in the County of Queens. Dated : Forest Hills, New York October 12, 2020 Yours, etc., Regis A. Gallet, Esq. Law Offices of Regis A. Gallet, LLC. Attorney for Plaintiff 118-21 Queens Boulevard, Suite 616 Forest Hills, NY 11375 (718)896-2000 File # 19M028 DEFENDANT'S ADDRESS: JULIA PINKHASOV a/k/a YULIA PINKHASOV 9 Vanad Drive Roslyn, NY 11756 1 of 5 FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/13/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ----------------------------------------------------------------------X ANATOLIY BENYAMINOV, Plaintiff, COMPLAINT -against- YULIA PINKHASOV, a/k/a JULIA PINKHASOV, Defendant. ----------------------------------------------------------------------X Plaintiff, by his attorneys, Law Offices of Regis A. Gallet, LLC., complaining of the Defendant herein, respectfully shows to this Court, and alleges upon information and belief as follows: 1. At all times hereinafter mentioned, ANATOLIY BENYAMINOV (“Plaintiff”) was and still is a resident of the County of Queens, City and State of New York. 2. A all times hereinafter mentioned, YULIA PINKHASOV a/k/a JULIA PINKHASOV (“Defendant”) was and still is a resident of the State of New York. 3. At all times hereinafter mentioned, Defendant was the owner of a certain 2017 Lexus motor vehicle bearing the New York State registration number EYB3951. 4. At all times hereinafter mentioned, Defendant operated and controlled the aforesaid 2017 Lexus motor vehicle. 5. At all times hereinafter mentioned, Plaintiff was the owner of a certain 2019 Lexus motor vehicle bearing the New York State registration number CPJ2023. 6. At all times hereinafter mentioned, Plaintiff operated and controlled the aforesaid 2019 Lexus motor vehicle. 7. At all times hereinafter mentioned, Jewel Avenue, at or near its intersection with 137th Street, in the County of Queens, City and State of New York, were and still are public highways, roadways and thoroughfares for the use of motor vehicles. 2 of 5 FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/13/2020 8. On or about May 20, 2019, the aforesaid motor vehicles came into contact at the aforesaid public thoroughfares. 9. The aforesaid collision and injuries resulting therefrom, were due solely and wholly as a result of the culpable conduct and the careless and negligent manner in which the Defendant maintained, operated and controlled her motor vehicle; in being liable under the doctrine of res ipsa loquitur; and in otherwise causing the damages sustained by the Plaintiff without this Plaintiff in any way contributing thereto. 10. By reason of the foregoing, the negligence and culpable conduct of said Defendant, Plaintiff sustained serious, severe, and permanent injuries to his head, limbs and body; still suffers and will continue to suffer for some time, great physical and mental pain and serious bodily injury; became sick, sore, lame and disabled and so remained for a considerable length of time. 11. By reason of the culpable conduct, wrongful, negligent and unlawful actions of the Defendant, as aforesaid, Plaintiff sustained serious injuries as defined in Subsection (d) of Section 5102 of the Insurance Law, or economic loss greater than basic economic loss, as defined in Subsection (a) of Section 5102 of the Insurance Law. 12. By reason of the foregoing, the negligence and culpable conduct of said Defendant, Plaintiff is informed and verily believes the aforesaid injuries are permanent and that he will permanently suffer from the effects of his aforesaid injuries and that he will be caused to suffer permanent embarrassment and continuous pain and inconvenience. 13. By reason of the foregoing, Plaintiff was compelled and did necessarily require medical aid and attention and did necessarily pay and become liable therefore for medicines, and upon information and belief, Plaintiff will necessarily incur similar expenses. 14. By reason of the foregoing, Plaintiff has been unable to attend to his usual occupation and avocation in the manner required. 15. As a result of the Defendant’s negligence as aforesaid, Plaintiff has been damaged in a sum exceeding the jurisdictional limits of all lower Courts of this State. 3 of 5 FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/13/2020 WHEREFORE, Plaintiff demands judgment against the Defendant in a sum exceeding the jurisdictional limits of all lower Courts of this State; together with attorney's fees and the costs and disbursements of this action. Dated: Forest Hills, New York October 12, 2020 Yours, etc., Regis A. Gallet, Esq. Law Offices of Regis A. Gallet, LLC. Attorney for Plaintiff 118-21 Queens Boulevard, Suite 616 Forest Hills, NY 11375 (718)896-2000 4 of 5 FILED: QUEENS COUNTY CLERK 10/13/2020 06:50 AM INDEX NO. 718432/2020 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/13/2020 Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ANATOLIY BENYAMINOV, Plaintiff, -against- YULIA PINKHASOV, a/k/a JULIA PINKHASOV, Defendant. SUMMONS AND COMPLAINT Regis A. Gallet, Esq. Law Offices of Regis A. Gallet, LLC. Attorneys for Plaintiff 118-21 Queens Boulevard, Suite 616 Forest Hills, NY 11375 (718)896-2000 TO: YULIA PINKHASOV a/k/a JULIA PINKHASOV 9 Vanad Drive Roslyn, NY 11756 5 of 5