Preview
FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTV OF NEW YORK
—
-------------------------------------------------------------X X SUMMONS
AMY LEE,
Plaintiff designates NEW
Plaintiff, YORK County as the place of
trial.
-against-
The basis of venue is:
KENNETH EGRI, JR., Accident Location
Defendant. Accident occurred on Canal
————— —
-------------------------------------------------------------X — Street at or near its
intersection with Mott Street,
New York, New York
County ofNEW 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, of if the complaint is not served with this summons, to serve a notice of appearance on
the plaintiffs attorney(s) within twenty days after the services 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: Lake Success, New York
May 29, 2018
Respectfully yours,
y: AITifÑforcNAUGHTON, ESQ.
LAW OFFICE OF COHEN & JAFFE, LLP
Attorneys for the Plaintif
2001 Marcus Avenue - Suite W295
Lake Success, New York 11042
(516) 358-6900
www.CohenJaffe.com
TO: KENNETH EGRI, JR.
144 Cross Street
Kenilworth, New Jersey 07033
carrier**"'**
"'***Please submit these papers to your insurance
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------X Plaintiff Demands Trial
AMY LEE, By Jury
Plaintiff,
VERIFIED COMPLAINT
-against-
Index No.:
KENNETH EGRI, JR.,
Defendant.
---------------------------------------------X ----- â€
Plaintiff, AMY LEE, by her attorneys, Law Office of Cohen & Jaffe, LLP, as and for her
Complaint alleges against Defendant upon information and belief as follows:
THE PARTIES
1. At alltimes herein mentioned, Plaintiff AMY LEE was, and stillis a resident of
the County of NASSAU, State of New York.
2. At alltimes herein mentioned, Defendant KENNETH EGRI, JR. was and stillis
a resident of the County of UNION, State of New Jersey.
3. This action falls within one or more of the exceptions set forth in CPLR 1602.
AS AND FOR A FIRST CAUSE OF ACTION
ON BEHALF OF PLAINTIFF AMY LEE
4. Plaintiff, AMY LEE, respectfully repeats, reiterates and realleges each and every
"1"
paragraph numbered through "3", inclusive, with the same force and effect as if said
paragraphs were more fully set forth at length herein.
5. At alltimes herein mentioned, Defendant KENNETH EGRI, JR. was the owner of a
2015 Nissan motor vehicle bearing New Jersey State license plate number A56FYH.
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FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018
6. At all times herein mentioned, Defendant KENNETH EGRI, JR. was the operator of
a 2015 Nissan motor vehicle bearing New Jersey State license plate number A56FYH.
7. At alltimes herein mentioned, Defendant KENNETH EGRI, JR. maintained the
aforementioned motor vehicle.
8. At alltimes herein mentioned, Defendant KENNETH EGRI, JR. controlled the
aforementioned motor vehicle.
9. At alltimes herein mentioned, Canal Street at or near itsintersection with Mott
Street, in the County of New York, City and State of New York, was and still is a public
roadway over and along which motor vehicles were accustomed to and did travel.
10. On August 4, 2017, Defendant KENNETH EGRI, JR. was operating a 2015
Nissan motor vehicle bearing New Jersey State license plate number A56FYH at the
aforementioned location.
11. On August 4, 2017, the Plaintiff AMY LEE was a pedestrian traveling at and/or
about the aforementioned location with care, caution and attentiveness.
12. On August 4, 2017, the aforesaid 2015 Nissan motor vehicle owned and operated by
Defendant KENNETH EGRI, JR. negligently came into contact with the Plaintiff.
13. As a result of the aforesaid contact, Plaintiff, AMY LEE was injured.
14. The aforesaid occurrence was cause wholly and solely by reason of the negligence
of the Defendant in his ownership, operation, maintenance and control of his motor vehicle and
without any fault or negligence on the part of the Plaintiff contributing thereto.
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018
15. As a result of the aforesaid contact, Plaintiff AMY LEE sustained severe and serious
injuries as defined in Section 5102(d) of the Insurance Law of the State of New York and an
economic loss greater than basic economic loss as defined in Section 5102(a) of the Insurance Law
of the State of New York.
16. By reason of the foregoing, Plaintiff AMY LEE has been damaged in a sum that
exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction over
this matter.
WHEREFORE, itis respectfully requested that this Court grant judgment against the
defendant in an amount which exceeds the jurisdictional limit of all lower courts which might
otherwise have jurisdiction over this matter, together with costs and disbursements, and interest,
and for such other, further and different relief as to this Court may seem just and proper.
Dated: May 29, 2018
Lake Success, New York
Respectfully yours,
lif.yŒATTL e UGHT , ESQ.
LAW OFFICE OF COHE JAFFE, LLP
Attorneys for the Plaintiff
2001 Marcus Avenue - S ite W295
Lake Success, New York 11042
(516) 358-6900
www.Cohen Jaffe.com
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018
ATTORNEY'S VERIFICATION
I, the undersigned, an attorney admitted to practice in the courts of New York State, state:
I am an associate with the LAW OFFICE OF COHEN 2 JAFFE, LLP, attorneys of record for
the Plaintiff in the within action; I have read the foregoing COMPLAINT and know the contents
thereof; and the same is true to my own knowledge, except as to the matters therein stated to be
alleged upon information and belief, and as to those matters I believe it to be true. The reason
this verification is made by me and not by the Plaintiff is that the Plaintiff resides outside the
county wherein this firm maintains itsoffice.
The grounds of my belief as to all matters stated upon my own knowledge are as follows:
conversations with my client and information gathered in my file.
Dated: Lake Success, New York
May 29, 2018
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FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK Index No.:
-------------------------------------------------------------------X D/Purchased:
AMY LEE,
Plaintiff,
-against-
KENNETH EGRI, JR.,
Defendant.
X
---------------------------------------------------------------------X
SUMMONS AND VERIFIED COMPLAINT
LAW OFFICE OF COHEN & JAFFE, LLP
Attorneys for Plaintiff
2001 Marcus Avenue
Lake Success, NY 11042
(516) 358-6900
www. Cohen Jaffe.com
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Preview
FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTV OF NEW YORK — -------------------------------------------------------------X X SUMMONS AMY LEE, Plaintiff designates NEW Plaintiff, YORK County as the place of trial. -against- The basis of venue is: KENNETH EGRI, JR., Accident Location Defendant. Accident occurred on Canal ————— — -------------------------------------------------------------X — Street at or near its intersection with Mott Street, New York, New York County ofNEW 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, of if the complaint is not served with this summons, to serve a notice of appearance on the plaintiffs attorney(s) within twenty days after the services 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: Lake Success, New York May 29, 2018 Respectfully yours, y: AITifÑforcNAUGHTON, ESQ. LAW OFFICE OF COHEN & JAFFE, LLP Attorneys for the Plaintif 2001 Marcus Avenue - Suite W295 Lake Success, New York 11042 (516) 358-6900 www.CohenJaffe.com TO: KENNETH EGRI, JR. 144 Cross Street Kenilworth, New Jersey 07033 carrier**"'** "'***Please submit these papers to your insurance 1 of 6 FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------X Plaintiff Demands Trial AMY LEE, By Jury Plaintiff, VERIFIED COMPLAINT -against- Index No.: KENNETH EGRI, JR., Defendant. ---------------------------------------------X ----- †Plaintiff, AMY LEE, by her attorneys, Law Office of Cohen & Jaffe, LLP, as and for her Complaint alleges against Defendant upon information and belief as follows: THE PARTIES 1. At alltimes herein mentioned, Plaintiff AMY LEE was, and stillis a resident of the County of NASSAU, State of New York. 2. At alltimes herein mentioned, Defendant KENNETH EGRI, JR. was and stillis a resident of the County of UNION, State of New Jersey. 3. This action falls within one or more of the exceptions set forth in CPLR 1602. AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF PLAINTIFF AMY LEE 4. Plaintiff, AMY LEE, respectfully repeats, reiterates and realleges each and every "1" paragraph numbered through "3", inclusive, with the same force and effect as if said paragraphs were more fully set forth at length herein. 5. At alltimes herein mentioned, Defendant KENNETH EGRI, JR. was the owner of a 2015 Nissan motor vehicle bearing New Jersey State license plate number A56FYH. 2 of 6 FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018 6. At all times herein mentioned, Defendant KENNETH EGRI, JR. was the operator of a 2015 Nissan motor vehicle bearing New Jersey State license plate number A56FYH. 7. At alltimes herein mentioned, Defendant KENNETH EGRI, JR. maintained the aforementioned motor vehicle. 8. At alltimes herein mentioned, Defendant KENNETH EGRI, JR. controlled the aforementioned motor vehicle. 9. At alltimes herein mentioned, Canal Street at or near itsintersection with Mott Street, in the County of New York, City and State of New York, was and still is a public roadway over and along which motor vehicles were accustomed to and did travel. 10. On August 4, 2017, Defendant KENNETH EGRI, JR. was operating a 2015 Nissan motor vehicle bearing New Jersey State license plate number A56FYH at the aforementioned location. 11. On August 4, 2017, the Plaintiff AMY LEE was a pedestrian traveling at and/or about the aforementioned location with care, caution and attentiveness. 12. On August 4, 2017, the aforesaid 2015 Nissan motor vehicle owned and operated by Defendant KENNETH EGRI, JR. negligently came into contact with the Plaintiff. 13. As a result of the aforesaid contact, Plaintiff, AMY LEE was injured. 14. The aforesaid occurrence was cause wholly and solely by reason of the negligence of the Defendant in his ownership, operation, maintenance and control of his motor vehicle and without any fault or negligence on the part of the Plaintiff contributing thereto. 3 of 6 FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018 15. As a result of the aforesaid contact, Plaintiff AMY LEE sustained severe and serious injuries as defined in Section 5102(d) of the Insurance Law of the State of New York and an economic loss greater than basic economic loss as defined in Section 5102(a) of the Insurance Law of the State of New York. 16. By reason of the foregoing, Plaintiff AMY LEE has been damaged in a sum that exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction over this matter. WHEREFORE, itis respectfully requested that this Court grant judgment against the defendant in an amount which exceeds the jurisdictional limit of all lower courts which might otherwise have jurisdiction over this matter, together with costs and disbursements, and interest, and for such other, further and different relief as to this Court may seem just and proper. Dated: May 29, 2018 Lake Success, New York Respectfully yours, lif.yŒATTL e UGHT , ESQ. LAW OFFICE OF COHE JAFFE, LLP Attorneys for the Plaintiff 2001 Marcus Avenue - S ite W295 Lake Success, New York 11042 (516) 358-6900 www.Cohen Jaffe.com 4 of 6 FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018 ATTORNEY'S VERIFICATION I, the undersigned, an attorney admitted to practice in the courts of New York State, state: I am an associate with the LAW OFFICE OF COHEN 2 JAFFE, LLP, attorneys of record for the Plaintiff in the within action; I have read the foregoing COMPLAINT and know the contents thereof; and the same is true to my own knowledge, except as to the matters therein stated to be alleged upon information and belief, and as to those matters I believe it to be true. The reason this verification is made by me and not by the Plaintiff is that the Plaintiff resides outside the county wherein this firm maintains itsoffice. The grounds of my belief as to all matters stated upon my own knowledge are as follows: conversations with my client and information gathered in my file. Dated: Lake Success, New York May 29, 2018 5 of 6 FILED: NEW YORK COUNTY CLERK 05/30/2018 10:06 AM INDEX NO. 155000/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No.: -------------------------------------------------------------------X D/Purchased: AMY LEE, Plaintiff, -against- KENNETH EGRI, JR., Defendant. X ---------------------------------------------------------------------X SUMMONS AND VERIFIED COMPLAINT LAW OFFICE OF COHEN & JAFFE, LLP Attorneys for Plaintiff 2001 Marcus Avenue Lake Success, NY 11042 (516) 358-6900 www. Cohen Jaffe.com 6 of 6