Preview
FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index #
---------------------------------------------------------------------X Date Purchased:
STEPHANIE BOLANOS,
SUMMONS
Plaintiff(s),
Plaintiff designates
Queens County
-against- as place of trial
The basis of the venue
is: Plaintiff’s Residence
HARIS GRACA and SADET GRACA,
Defendant(s).
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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, or, if the complaint is not served with this summons, to serve a notice of
appearance on the Plaintiff's Attorneys within 20 days after the service of this summons exclusive of
the day of service (or within 30 days after the service is complete if this summons is not personally
delivered to you within the State of New York); and in case of your failure to appear or answer,
judgment will be taken against you by default for the relief demanded herein.
Dated: New York, New York
April 12, 2021
Jason L. Paris
____________________________
JASON L. PARIS, ESQ.
THE PARIS LAW GROUP, P.C.
Attorneys for Plaintiff
STEPHANIE BOLANOS
60 East 42nd Street, Suite 4600
New York, NY 10122
212-970-8754
Defendant’s Address:
HARIS GRACA
18 ARGONNE ROAD W
HAMPTON BAYS, NY 11946
SADET GRACA
18 ARGONNE ROAD W
HAMPTON BAYS, NY 11946
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index No.:
---------------------------------------------------------------------X
STEPHANIE BOLANOS,
VERIFIED COMPLAINT
Plaintiff(s),
-against-
HARIS GRACA and SADET GRACA,
Defendant(s).
---------------------------------------------------------------------X
The plaintiff, STEPHANIE BOLANOS, by her attorneys, THE PARIS LAW GROUP,
P.C., complaining of the defendants herein, respectfully shows to the court and alleges as follows:
1. That at all of the times hereinafter alleged, the plaintiff, STEPHANIE
BOLANOS, was and stillis a resident of the Queens County, City and State of State of New
York.
2. That at all of the times hereinafter alleged, the defendant, HARIS GRACA, was
and still is a resident of the Suffolk County, State of New York.
3. That at all times hereinafter alleged, the defendant, SADET GRACA, was and
still is a resident of the Suffolk County, State of New York.
4. That at all times hereinafter alleged, and upon information and belief, the defendant,
SADET GRACA, was the owner of a certain 2014 BMW motor vehicle bearing New York State
registration number, GEK4198.
5. That at all times hereinafter alleged, and upon information and belief, the defendant,
SADET GRACA, was the owner of a certain 2014 BMW motor vehicle bearing a vehicle
registration number, 5UXKR0C50E0K45053.
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6. That at all times hereinafter alleged, and upon information and belief, the defendant,
SADET GRACA, controlled the aforesaid motor vehicle.
7. That at all times hereinafter alleged, and upon information and belief, the defendant,
SADET GRACA, maintained the aforesaid motor vehicle.
8. That at all times hereinafter alleged, and upon information and belief, the defendant,
SADET GRACA, managed the aforesaid motor vehicle.
9. That at all times hereinafter alleged, and upon information and belief, the defendant,
SADET GRACA, repaired the aforesaid motor vehicle.
10. That at all times hereinafter alleged, and upon information and belief, the defendant,
SADET GRACA, supervised the aforesaid motor vehicle.
11. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, operated the aforesaid motor vehicle.
12. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, operated the aforesaid motor vehicle, with the knowledge, permission and
consent of the defendant, SADET GRACA.
13. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, controlled the aforesaid motor vehicle.
14. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, controlled the aforesaid motor vehicle, with the knowledge, permission and
consent of the defendant, SADET GRACA.
15. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, maintained the aforesaid motor vehicle.
16. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, maintained the aforesaid motor vehicle, with the knowledge, permission and
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consent of the defendant, SADET GRACA.
17. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, managed the aforesaid motor vehicle.
18. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, managed the aforesaid motor vehicle, with the knowledge, permission and
consent of the defendant, SADET GRACA.
19. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, repaired the aforesaid motor vehicle.
20. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, repaired the aforesaid motor vehicle, with the knowledge, permission and
consent of the defendant, SADET GRACA.
21. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, supervised the aforesaid motor vehicle.
22. That at all times hereinafter alleged, and upon information and belief, the defendant,
HARIS GRACA, supervised the aforesaid motor vehicle, with the knowledge, permission and
consent of the defendant, SADET GRACA.
23. That at all times hereinafter alleged, and upon information and belief, the plaintiff,
STEPHANIE BOLANOS, operated a certain 2019 Nissan motor vehicle bearing New York
State registration number, JFY1274.
24. That at all of the times hereinafter mentioned Grand Central Parkway at or near
Union Turnpike, in the Queens County, State of New York, were and still are public roadway used
extensively by the public in general.
25. That on May 3, 2020, the aforesaid motor vehicles were in contact at the
aforementioned location.
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26. That on May 3, 2020, the aforesaid motor vehicles were in a collision at the
aforementioned location.
27. That the aforesaid accident and injuries resulting there from were due solely and
wholly as a result of the careless and negligent manner in which the defendants owned, operated,
controlled, maintained, managed, and repaired their motor vehicle without this plaintiff in any way
contributing thereto.
28. That by reason of the foregoing and the negligence of the defendants, the plaintiff,
STEPHANIE BOLANOS, was severely injured, bruised and wounded, suffered, still suffers
and will continue to suffer for some time physical pain and bodily injuries and became sick, sore,
lame and disabled and so remained for a considerable length of time.
29. That by reason of the foregoing, the plaintiff, STEPHANIE BOLANOS, was
compelled to and did necessarily require medical aid and attention, and did necessarily pay and
become liable therefore for medicines and upon information and belief, the plaintiff,
STEPHANIE BOLANOS, will necessarily incur similar expenses.
30. That by reason of the foregoing, the plaintiff, STEPHANIE BOLANOS, has
been unable to attend to her usual occupation in the manner required.
31. That by reason of the wrongful, negligent and unlawful actions of the defendants,
as aforesaid, the plaintiff, STEPHANIE BOLANOS, sustained serious injuries as defined in
Section 5102(d) of the Insurance Law of The State of New York, and has sustained economic
loss greater than basic economic loss as defined in Section 5102 of the said Insurance Law.
32. That one or more of the provisions of §1602 of the Civil Practice Law and Rules
do apply to the within action.
33. That as a result of the foregoing, the plaintiff, STEPHANIE BOLANOS, has been
damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise
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have jurisdiction.
WHEREFORE, the plaintiff, STEPHANIE BOLANOS, demands judgment against the
defendants in the sum exceeding the jurisdictional limits of all lower courts which would otherwise
have jurisdiction, together with the costs and disbursements of her action.
Dated: New York, New York
April 12, 2021
Jason L. Paris
____________________________
JASON L. PARIS, ESQ.
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ATTORNEY'S VERIFICATION
JASON L. PARIS, an attorney duly admitted to practice before the Courts of the State of
New York, affirms the following to be true under the penalties of perjury:
I am a member at THE PARIS LAW GROUP, P.C., attorneys of record for Plaintiff. 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 files.
The reason this verification is made by me and not Plaintiff is that Plaintiff does not reside
in the county wherein the attorneys for the plaintiff maintain their offices.
Dated: New York, New York
April 12, 2021
Jason L. Paris
____________________________
JASON L. PARIS, ESQ.
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Index No.:
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
STEPHANIE BOLANOS,
Plaintiff(s),
-against-
HARIS GRACA and SADET GRACA,
Defendant(s).
SUMMONS and VERIFIED COMPLAINT
THE PARIS LAW GROUP, P.C.
Attorneys for Plaintiff
60 East 42nd Street, Suite 4600
New York, NY 10122
212-970-8754
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Preview
FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index # ---------------------------------------------------------------------X Date Purchased: STEPHANIE BOLANOS, SUMMONS Plaintiff(s), Plaintiff designates Queens County -against- as place of trial The basis of the venue is: Plaintiff’s Residence HARIS GRACA and SADET GRACA, Defendant(s). ---------------------------------------------------------------------X 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, or, if the complaint is not served with this summons, to serve a notice of appearance on the Plaintiff's Attorneys within 20 days after the service of this summons exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein. Dated: New York, New York April 12, 2021 Jason L. Paris ____________________________ JASON L. PARIS, ESQ. THE PARIS LAW GROUP, P.C. Attorneys for Plaintiff STEPHANIE BOLANOS 60 East 42nd Street, Suite 4600 New York, NY 10122 212-970-8754 Defendant’s Address: HARIS GRACA 18 ARGONNE ROAD W HAMPTON BAYS, NY 11946 SADET GRACA 18 ARGONNE ROAD W HAMPTON BAYS, NY 11946 1 of 8 FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No.: ---------------------------------------------------------------------X STEPHANIE BOLANOS, VERIFIED COMPLAINT Plaintiff(s), -against- HARIS GRACA and SADET GRACA, Defendant(s). ---------------------------------------------------------------------X The plaintiff, STEPHANIE BOLANOS, by her attorneys, THE PARIS LAW GROUP, P.C., complaining of the defendants herein, respectfully shows to the court and alleges as follows: 1. That at all of the times hereinafter alleged, the plaintiff, STEPHANIE BOLANOS, was and stillis a resident of the Queens County, City and State of State of New York. 2. That at all of the times hereinafter alleged, the defendant, HARIS GRACA, was and still is a resident of the Suffolk County, State of New York. 3. That at all times hereinafter alleged, the defendant, SADET GRACA, was and still is a resident of the Suffolk County, State of New York. 4. That at all times hereinafter alleged, and upon information and belief, the defendant, SADET GRACA, was the owner of a certain 2014 BMW motor vehicle bearing New York State registration number, GEK4198. 5. That at all times hereinafter alleged, and upon information and belief, the defendant, SADET GRACA, was the owner of a certain 2014 BMW motor vehicle bearing a vehicle registration number, 5UXKR0C50E0K45053. 2 of 8 FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021 6. That at all times hereinafter alleged, and upon information and belief, the defendant, SADET GRACA, controlled the aforesaid motor vehicle. 7. That at all times hereinafter alleged, and upon information and belief, the defendant, SADET GRACA, maintained the aforesaid motor vehicle. 8. That at all times hereinafter alleged, and upon information and belief, the defendant, SADET GRACA, managed the aforesaid motor vehicle. 9. That at all times hereinafter alleged, and upon information and belief, the defendant, SADET GRACA, repaired the aforesaid motor vehicle. 10. That at all times hereinafter alleged, and upon information and belief, the defendant, SADET GRACA, supervised the aforesaid motor vehicle. 11. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, operated the aforesaid motor vehicle. 12. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, operated the aforesaid motor vehicle, with the knowledge, permission and consent of the defendant, SADET GRACA. 13. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, controlled the aforesaid motor vehicle. 14. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, controlled the aforesaid motor vehicle, with the knowledge, permission and consent of the defendant, SADET GRACA. 15. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, maintained the aforesaid motor vehicle. 16. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, maintained the aforesaid motor vehicle, with the knowledge, permission and 3 of 8 FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021 consent of the defendant, SADET GRACA. 17. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, managed the aforesaid motor vehicle. 18. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, managed the aforesaid motor vehicle, with the knowledge, permission and consent of the defendant, SADET GRACA. 19. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, repaired the aforesaid motor vehicle. 20. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, repaired the aforesaid motor vehicle, with the knowledge, permission and consent of the defendant, SADET GRACA. 21. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, supervised the aforesaid motor vehicle. 22. That at all times hereinafter alleged, and upon information and belief, the defendant, HARIS GRACA, supervised the aforesaid motor vehicle, with the knowledge, permission and consent of the defendant, SADET GRACA. 23. That at all times hereinafter alleged, and upon information and belief, the plaintiff, STEPHANIE BOLANOS, operated a certain 2019 Nissan motor vehicle bearing New York State registration number, JFY1274. 24. That at all of the times hereinafter mentioned Grand Central Parkway at or near Union Turnpike, in the Queens County, State of New York, were and still are public roadway used extensively by the public in general. 25. That on May 3, 2020, the aforesaid motor vehicles were in contact at the aforementioned location. 4 of 8 FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021 26. That on May 3, 2020, the aforesaid motor vehicles were in a collision at the aforementioned location. 27. That the aforesaid accident and injuries resulting there from were due solely and wholly as a result of the careless and negligent manner in which the defendants owned, operated, controlled, maintained, managed, and repaired their motor vehicle without this plaintiff in any way contributing thereto. 28. That by reason of the foregoing and the negligence of the defendants, the plaintiff, STEPHANIE BOLANOS, was severely injured, bruised and wounded, suffered, still suffers and will continue to suffer for some time physical pain and bodily injuries and became sick, sore, lame and disabled and so remained for a considerable length of time. 29. That by reason of the foregoing, the plaintiff, STEPHANIE BOLANOS, was compelled to and did necessarily require medical aid and attention, and did necessarily pay and become liable therefore for medicines and upon information and belief, the plaintiff, STEPHANIE BOLANOS, will necessarily incur similar expenses. 30. That by reason of the foregoing, the plaintiff, STEPHANIE BOLANOS, has been unable to attend to her usual occupation in the manner required. 31. That by reason of the wrongful, negligent and unlawful actions of the defendants, as aforesaid, the plaintiff, STEPHANIE BOLANOS, sustained serious injuries as defined in Section 5102(d) of the Insurance Law of The State of New York, and has sustained economic loss greater than basic economic loss as defined in Section 5102 of the said Insurance Law. 32. That one or more of the provisions of §1602 of the Civil Practice Law and Rules do apply to the within action. 33. That as a result of the foregoing, the plaintiff, STEPHANIE BOLANOS, has been damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise 5 of 8 FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021 have jurisdiction. WHEREFORE, the plaintiff, STEPHANIE BOLANOS, demands judgment against the defendants in the sum exceeding the jurisdictional limits of all lower courts which would otherwise have jurisdiction, together with the costs and disbursements of her action. Dated: New York, New York April 12, 2021 Jason L. Paris ____________________________ JASON L. PARIS, ESQ. 6 of 8 FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021 ATTORNEY'S VERIFICATION JASON L. PARIS, an attorney duly admitted to practice before the Courts of the State of New York, affirms the following to be true under the penalties of perjury: I am a member at THE PARIS LAW GROUP, P.C., attorneys of record for Plaintiff. 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 files. The reason this verification is made by me and not Plaintiff is that Plaintiff does not reside in the county wherein the attorneys for the plaintiff maintain their offices. Dated: New York, New York April 12, 2021 Jason L. Paris ____________________________ JASON L. PARIS, ESQ. 7 of 8 FILED: QUEENS COUNTY CLERK 04/12/2021 03:18 PM INDEX NO. 708413/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/12/2021 Index No.: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS STEPHANIE BOLANOS, Plaintiff(s), -against- HARIS GRACA and SADET GRACA, Defendant(s). SUMMONS and VERIFIED COMPLAINT THE PARIS LAW GROUP, P.C. Attorneys for Plaintiff 60 East 42nd Street, Suite 4600 New York, NY 10122 212-970-8754 8 of 8