Preview
FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
Index No.
------ ---------------------------- x
Plaintiff, Plaintiff designates
QUEENS County as the place of
against trialof this action.
CHRISTOPHER DANIEL AROCHO, NASEEM ROBIN The basis venuedesignated is:
of
and BASIL SAFDAR, The in which the subject
County
accident occurred.
Defendant,
-----------------------------------------------------------x
To the above named Defendant(s)
att are IJereby sttmmonth 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, judgmcat will be taken against you by default for the
relief demanded in the complaint.
DATED: New York, New York
April 7, 2021
Harmon, Linder & Rogowsky
Attorneys for Plaints)f(s)
3 Park Avenue, Suite 2300
New York, NY 10016
Christopher Daniel Arocho
7 Deibler Drive
Freeville, NY 13068
Naseem Robin
7729 Castor Ave
Philadelphia, PA 19152
Basil Safdar
94-12 134 Street
Queens, NY 11419
1 of 7
FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
-------------------------------------------x
EJONA BANUSHI,
VERIFIED COMPLAINT
Plaintiff,
-against-
CHRISTOPHER DANIEL AROCHO, NASEEM ROBIN
and BASIL SAFDAR,
Defendants.
--------------------------------------------x
Plaintiff, complaining of the defendants herein by her attorneys,
HARMON, LINDER & ROGOWSKY, ESQS., respectfully sets forth and
alleges, as follows:
AS AND FOR A CAUSE OF ACTION
ON BEHALF OF EJONA BANUSHI
1. That the accident herein complained of occurred within the County
of QUEENS, State of New York.
2. That at all times herein mentioned defendant, CHRISTOPHER DANIEL
AROCHO, was the owner and the operator of an automobile bearing
registration number HGH7826, State of New York.
3. That at all times herein mentioned NACTTV was
defendant, ROBIN,
the owner of an automobile bearing registration number KDX7739,
State of Pennsylvania.
2 of 7
FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021
4. That at all times herein mentioned defendant, BASIL SAFDAR, was
the operator of an automobile bearing registration number KDX7739,
State of Pennsylvania.
5. That at all times herein mentioned defendant, BASIL SAFDAR, was
in physical charge, operation, management and control of the
aforesaid vehicle owned by the defendant, NASEEM ROBIN, with the
knowledge, consent, and permission, either express or implied of the
defendant owner thereof.
6. That at all times herein mentioned plaintiff, EJONA BANUSHI, was
a passenger of the aforesaid motor vehicle bearing registration
number KDX7739, State of Pennsylvania.
7. That on the Ninth day of August 2019, at approximately 3:09 p.m.,
the aforesaid vehicles came into contact with each other on Lefferts
Boulevard, at or near its intersection with 103rd Avenue, a public
street and thoroughfare, in the County of Queens, State of New York.
8. The defendants so carelessly and negligently operated their
aforesaid respective vehicles so as to cause the aforesaid contact.
3 of 7
FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021
9. That as a result of the foregoing, this plaintiff was caused to
and did sustain severe and serious injuries and was required to seek
and obtain medical care and attention in an effort to cure and
alleviate same and, upon information and belief, will be compelled
to do so in the future.
10. That the aforesaid occurrence and the injuries sustained by this
plaintiff were caused by the negligence of the defendants.
11. That this plaintiff has sustained a serious injury as the same
"d"
is defined in Subdivision of Section 5102 of the Insurance Law
of the State of New York.
12. This action falls within one or more of the exceptions set
forth in CPLR section 1602.
13. That by reason of the foregoing, plaintiff, EJONA BANUSHI, has
been damaged in an amount which exceeds the jurisdictional limits of
all lower courts that would otherwise have jurisdiction.
WHEREFORE, plaintiff, EJONA BANUSHI, demands judgement against
the defendants in the Cause of Action in an amount which exceeds the
jurisdictional limits of all lower courts that would otherwise have
4 of 7
FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021
jurisdiction; all together with the costs and disbursements of this
action.
Dated: New York, NY
April 7, 2021
HARMON, LINDER & ROGOWSKY, ESQS.
Attorney(s) for Plaintiff(s)
3 Park Avenue, Suite 2300
New York, New York 10016
(212) 732-3665
MJL/mj
5 of 7
FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021
ATTORNEY'S VERIFICATION
STATE OF NEW YORK )
) ss:
COUNTY OF NEW YORK)
I,the undersigned, am an attorney admitted to practice in the Courts of New York State,
and say that:
I am the attorney of record or of counsel with the attorney(s) of record for plaintiff.
I have read the annexed SUMMONS AND VERIFIED COMPLAINT and know the
contents thereof and the same are true to my knowledge, except those matters therein which are
stated to be alleged on information and belief. As to those matters, I believe them to be true.
My belief, as to those matters therein not stated upon knowledge is based upon the following:
Interviews and/or discussions with the plaintiff(s) and papers and/or documents in the file.
The reasons I make this affirmation instead of the plaintiff is because said plaintiff
resides outside of the county from where your deponent maintains his office for the practice of
law.
Dated: New York, New York
April 7, 2021
Mark J. Linder Esq.,
6 of 7
FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021
Index No. Year
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
E JONA BANUSH I,
Plaintiff,
-against-
CHRISTO PHER DAN IEL AROCHO, NASEEM ROBIN
and BASIL SAFDAR,
Defendant.
SUMMONS AND VERIFIED COMPLAINT
__,........____ _______ ._____ ___
HARMON, LINDER & ROGOSWKY, ESQS.
Attorney for Plaintiff(s)
3 Park Avenue, Suite 2300
New York, NY 10016
(212) 732-3665 Phone
(212) 732-1462 Facsimile
________ ___ __________________________ ______________________________________
To:
Attorney(s) for Defendant
Service of a copy of the within Summons and Complaint is hereby admitted.
Dated:
Attorney(s) for
---________________________________.. - - - -- - -- _________________
PLEASE TAKE NOTICE
O Notice of Entry thatthe within isa (certified)truecopy ofa
entered inthe office ofthe clerk ofthe within named Court on
Notice of Settlement
thatan order of which the within isa true copy willbe presented forsettlement to the
Hon. , oneof the judges ofthe within named Court, at
on
Dated:
Yours, etc.
Harmon, Linder & Rogowsky
Attorneys for Plaintiff
3 Park Avenue, Suite 2300
New York, NY 10016
(212) 732-3665
7 of 7
Preview
FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No. ------ ---------------------------- x Plaintiff, Plaintiff designates QUEENS County as the place of against trialof this action. CHRISTOPHER DANIEL AROCHO, NASEEM ROBIN The basis venuedesignated is: of and BASIL SAFDAR, The in which the subject County accident occurred. Defendant, -----------------------------------------------------------x To the above named Defendant(s) att are IJereby sttmmonth 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, judgmcat will be taken against you by default for the relief demanded in the complaint. DATED: New York, New York April 7, 2021 Harmon, Linder & Rogowsky Attorneys for Plaints)f(s) 3 Park Avenue, Suite 2300 New York, NY 10016 Christopher Daniel Arocho 7 Deibler Drive Freeville, NY 13068 Naseem Robin 7729 Castor Ave Philadelphia, PA 19152 Basil Safdar 94-12 134 Street Queens, NY 11419 1 of 7 FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS -------------------------------------------x EJONA BANUSHI, VERIFIED COMPLAINT Plaintiff, -against- CHRISTOPHER DANIEL AROCHO, NASEEM ROBIN and BASIL SAFDAR, Defendants. --------------------------------------------x Plaintiff, complaining of the defendants herein by her attorneys, HARMON, LINDER & ROGOWSKY, ESQS., respectfully sets forth and alleges, as follows: AS AND FOR A CAUSE OF ACTION ON BEHALF OF EJONA BANUSHI 1. That the accident herein complained of occurred within the County of QUEENS, State of New York. 2. That at all times herein mentioned defendant, CHRISTOPHER DANIEL AROCHO, was the owner and the operator of an automobile bearing registration number HGH7826, State of New York. 3. That at all times herein mentioned NACTTV was defendant, ROBIN, the owner of an automobile bearing registration number KDX7739, State of Pennsylvania. 2 of 7 FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021 4. That at all times herein mentioned defendant, BASIL SAFDAR, was the operator of an automobile bearing registration number KDX7739, State of Pennsylvania. 5. That at all times herein mentioned defendant, BASIL SAFDAR, was in physical charge, operation, management and control of the aforesaid vehicle owned by the defendant, NASEEM ROBIN, with the knowledge, consent, and permission, either express or implied of the defendant owner thereof. 6. That at all times herein mentioned plaintiff, EJONA BANUSHI, was a passenger of the aforesaid motor vehicle bearing registration number KDX7739, State of Pennsylvania. 7. That on the Ninth day of August 2019, at approximately 3:09 p.m., the aforesaid vehicles came into contact with each other on Lefferts Boulevard, at or near its intersection with 103rd Avenue, a public street and thoroughfare, in the County of Queens, State of New York. 8. The defendants so carelessly and negligently operated their aforesaid respective vehicles so as to cause the aforesaid contact. 3 of 7 FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021 9. That as a result of the foregoing, this plaintiff was caused to and did sustain severe and serious injuries and was required to seek and obtain medical care and attention in an effort to cure and alleviate same and, upon information and belief, will be compelled to do so in the future. 10. That the aforesaid occurrence and the injuries sustained by this plaintiff were caused by the negligence of the defendants. 11. That this plaintiff has sustained a serious injury as the same "d" is defined in Subdivision of Section 5102 of the Insurance Law of the State of New York. 12. This action falls within one or more of the exceptions set forth in CPLR section 1602. 13. That by reason of the foregoing, plaintiff, EJONA BANUSHI, has been damaged in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction. WHEREFORE, plaintiff, EJONA BANUSHI, demands judgement against the defendants in the Cause of Action in an amount which exceeds the jurisdictional limits of all lower courts that would otherwise have 4 of 7 FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021 jurisdiction; all together with the costs and disbursements of this action. Dated: New York, NY April 7, 2021 HARMON, LINDER & ROGOWSKY, ESQS. Attorney(s) for Plaintiff(s) 3 Park Avenue, Suite 2300 New York, New York 10016 (212) 732-3665 MJL/mj 5 of 7 FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021 ATTORNEY'S VERIFICATION STATE OF NEW YORK ) ) ss: COUNTY OF NEW YORK) I,the undersigned, am an attorney admitted to practice in the Courts of New York State, and say that: I am the attorney of record or of counsel with the attorney(s) of record for plaintiff. I have read the annexed SUMMONS AND VERIFIED COMPLAINT and know the contents thereof and the same are true to my knowledge, except those matters therein which are stated to be alleged on information and belief. As to those matters, I believe them to be true. My belief, as to those matters therein not stated upon knowledge is based upon the following: Interviews and/or discussions with the plaintiff(s) and papers and/or documents in the file. The reasons I make this affirmation instead of the plaintiff is because said plaintiff resides outside of the county from where your deponent maintains his office for the practice of law. Dated: New York, New York April 7, 2021 Mark J. Linder Esq., 6 of 7 FILED: QUEENS COUNTY CLERK 04/09/2021 03:56 PM INDEX NO. 708300/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/09/2021 Index No. Year SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS E JONA BANUSH I, Plaintiff, -against- CHRISTO PHER DAN IEL AROCHO, NASEEM ROBIN and BASIL SAFDAR, Defendant. SUMMONS AND VERIFIED COMPLAINT __,........____ _______ ._____ ___ HARMON, LINDER & ROGOSWKY, ESQS. Attorney for Plaintiff(s) 3 Park Avenue, Suite 2300 New York, NY 10016 (212) 732-3665 Phone (212) 732-1462 Facsimile ________ ___ __________________________ ______________________________________ To: Attorney(s) for Defendant Service of a copy of the within Summons and Complaint is hereby admitted. Dated: Attorney(s) for ---________________________________.. - - - -- - -- _________________ PLEASE TAKE NOTICE O Notice of Entry thatthe within isa (certified)truecopy ofa entered inthe office ofthe clerk ofthe within named Court on Notice of Settlement thatan order of which the within isa true copy willbe presented forsettlement to the Hon. , oneof the judges ofthe within named Court, at on Dated: Yours, etc. Harmon, Linder & Rogowsky Attorneys for Plaintiff 3 Park Avenue, Suite 2300 New York, NY 10016 (212) 732-3665 7 of 7