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INDEX NO. 2013EF385
(FILED: ONONDAGA COUNTY CLERK 1272372013)
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/23/2013
STATE OF NEW YORK
SUPREME COURT __COUNTY OF ONONDAGA
JOSHUA R. BOLICK,
SUMMONS
Plaintiff,
Index No.
vs.
AZEEZ ENTERPRISES and
AZEEZ EL-HAGE,
Defendants,
To the above-named Defendants:
You are hereby summoned and required to serve upon Plaintiff's attorneys an answer to the
Complaint in this action within twenty (20) days after the service of the 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. 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 the venue designated is the resi mee of the Plaintiff, which is the County of
Onondaga, State of New York.
Dated: Decerbor A2___, 2013
& CATALANO, LLC
Ti Mandronics Esq.
Atte eyes for Pl.
m Street, Suite 120
che: t, New York 14614
elephone: (585) 232-6874
To Defendants:
Azeez Enterprises Azeez El-Hage
511 Wolf Street 511 Wolf Street
Syracuse, NY 13208 Syracuse, NY 13208
STATE OF NEW YORK
SUPREME COURT__COUNTY OF ONONDAGA
JOSHUA R. BOLICK, COMPLAINT
Plaintiff,
Index No.
VS.
AZEEZ ENTERPRISES and
AZEEZ EL-HAGE,
Defendants.
Plaintiff, Joshua R. Bolick, by and through his attorneys, ALEXANDER & CATALANO,
LLC, as and for his Complaint, upon information and belief, states:
1 That Plaintiff, Joshua R. Bolick, is an individual who resides the County of
Onondaga, and State of New York.
2 That Defendant, Azeez Enterprises, is a domestic corporation who maintains a
principal place of business at 511 Wolf Street, Syracuse, NY 13208.
3 That at all times relevant hereto, Defendant Azeez Enterprises was duly organized and
existing under and by virtue of the laws of the State of New York and authorized to do business in
the State of New York.
4 That upon information and belief, that on June 19, 2012, Defendant, Azeez
Enterprises, is and/or was responsible for the management, maintenance, supervision and/or control
of certain real property known as 511 Wolf Street, in City of Syracuse, County of Onondaga, and
State of New York.
5 That Defendant, Azeez El-Hage, was and still is a resident of the County of
Onondaga, and State of New York.
6 That upon information and belief, that on June 19, 2012, Defendant, Azeez El-Hage,
is and/or was responsible for the management, maintenance, supervision and/or control of certain
real property known as 511 Wolf Street, in City of Syracuse, County of Onondaga, and State of New
York.
7 That on June 19, 2012, the Plaintiff, Joshua R. Bolick, was lawfully present on the
said premises located at 511 Wolf Street, in City of Syracuse, County of Onondaga, and State of New
York.
8 That on June 19, 2012, the Defendants owed a duty to the Plaintiff to maintain the
aforementioned premises in a reasonable and safe condition, and breached that duty.
9 That on June 19, 2012, Azeez Enterprises and Azeez El-Hage were actively and/or
vicariously responsible for causing and creating a dangerous condition at the aforementioned
premises.
10. That the defendants and each of them were negligent in causing the aforesaid
dangerous condition.
11. That on June 19, 2012, the Plaintiff was injured as part of a wall in the garage area
collapsed onto plaintiff, who sustained injuries as the result of the dangerous and defective condition
present on the premises.
12. That as a result of the culpable conduct, negligence and ‘carelessness of the
Defendants, the Plaintiff was caused to suffer severe and painful personal injuries.
13. That the Plaintiff's resulting personal injuries sustained by the Plaintiff were due
solely to the negligence and carelessness of the Defendants and without any negligence of the
Plaintiff.
14, That the Plaintiff's cause of action falls within the exceptions set forth in Article 16 of
the CPLR.
WHEREFORE, the Plaintiff demands judgment in an amount which exceeds the
jurisdictional limits of all lower courts, which would otherwise have jurisdiction, together with the
costs and disbursements of this action, and for such other and further relief as this Court may deem
just and proper.
DATED: _ December 22 » 2013
ALE fife carsiano Luc
Th thy R. Mandronico, Esq.
Aftorneys for Plaintiff
S. Washington Street, Suite 120
Rochester, New York 14614
Telephone: (585) 232-6874
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INDEX NO. 2013EF385 (FILED: ONONDAGA COUNTY CLERK 1272372013) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/23/2013 STATE OF NEW YORK SUPREME COURT __COUNTY OF ONONDAGA JOSHUA R. BOLICK, SUMMONS Plaintiff, Index No. vs. AZEEZ ENTERPRISES and AZEEZ EL-HAGE, Defendants, To the above-named Defendants: You are hereby summoned and required to serve upon Plaintiff's attorneys an answer to the Complaint in this action within twenty (20) days after the service of the 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. 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 the venue designated is the resi mee of the Plaintiff, which is the County of Onondaga, State of New York. Dated: Decerbor A2___, 2013 & CATALANO, LLC Ti Mandronics Esq. Atte eyes for Pl. m Street, Suite 120 che: t, New York 14614 elephone: (585) 232-6874 To Defendants: Azeez Enterprises Azeez El-Hage 511 Wolf Street 511 Wolf Street Syracuse, NY 13208 Syracuse, NY 13208 STATE OF NEW YORK SUPREME COURT__COUNTY OF ONONDAGA JOSHUA R. BOLICK, COMPLAINT Plaintiff, Index No. VS. AZEEZ ENTERPRISES and AZEEZ EL-HAGE, Defendants. Plaintiff, Joshua R. Bolick, by and through his attorneys, ALEXANDER & CATALANO, LLC, as and for his Complaint, upon information and belief, states: 1 That Plaintiff, Joshua R. Bolick, is an individual who resides the County of Onondaga, and State of New York. 2 That Defendant, Azeez Enterprises, is a domestic corporation who maintains a principal place of business at 511 Wolf Street, Syracuse, NY 13208. 3 That at all times relevant hereto, Defendant Azeez Enterprises was duly organized and existing under and by virtue of the laws of the State of New York and authorized to do business in the State of New York. 4 That upon information and belief, that on June 19, 2012, Defendant, Azeez Enterprises, is and/or was responsible for the management, maintenance, supervision and/or control of certain real property known as 511 Wolf Street, in City of Syracuse, County of Onondaga, and State of New York. 5 That Defendant, Azeez El-Hage, was and still is a resident of the County of Onondaga, and State of New York. 6 That upon information and belief, that on June 19, 2012, Defendant, Azeez El-Hage, is and/or was responsible for the management, maintenance, supervision and/or control of certain real property known as 511 Wolf Street, in City of Syracuse, County of Onondaga, and State of New York. 7 That on June 19, 2012, the Plaintiff, Joshua R. Bolick, was lawfully present on the said premises located at 511 Wolf Street, in City of Syracuse, County of Onondaga, and State of New York. 8 That on June 19, 2012, the Defendants owed a duty to the Plaintiff to maintain the aforementioned premises in a reasonable and safe condition, and breached that duty. 9 That on June 19, 2012, Azeez Enterprises and Azeez El-Hage were actively and/or vicariously responsible for causing and creating a dangerous condition at the aforementioned premises. 10. That the defendants and each of them were negligent in causing the aforesaid dangerous condition. 11. That on June 19, 2012, the Plaintiff was injured as part of a wall in the garage area collapsed onto plaintiff, who sustained injuries as the result of the dangerous and defective condition present on the premises. 12. That as a result of the culpable conduct, negligence and ‘carelessness of the Defendants, the Plaintiff was caused to suffer severe and painful personal injuries. 13. That the Plaintiff's resulting personal injuries sustained by the Plaintiff were due solely to the negligence and carelessness of the Defendants and without any negligence of the Plaintiff. 14, That the Plaintiff's cause of action falls within the exceptions set forth in Article 16 of the CPLR. WHEREFORE, the Plaintiff demands judgment in an amount which exceeds the jurisdictional limits of all lower courts, which would otherwise have jurisdiction, together with the costs and disbursements of this action, and for such other and further relief as this Court may deem just and proper. DATED: _ December 22 » 2013 ALE fife carsiano Luc Th thy R. Mandronico, Esq. Aftorneys for Plaintiff S. Washington Street, Suite 120 Rochester, New York 14614 Telephone: (585) 232-6874