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FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX
INDEX
NO. 703719/2018
NO.
703719/2018
v.-u. yeamma uv um s x GinatiME U4/.5U / Z U19 11: 20
NYSCEF
NYSCEF
DOC.
DOC.
NO.NO.
4011 RECEIVED
RECEIVED
NYSCEF: 04/30/2019
NYSCEF:
07/07/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
INDEX NO. 703719/2018
G.B., an infant his mother and natural guardian RAYNA
by
DOUOLAS and RAYNA DOUOLAS, Individual,
AFFIDAVIT IN
SUPPORT
Plaintiffs,
-against-
JEVAN SIMPSON, KAYDE PALMER AND FAST LANE
MOTORS, LLC,
Defendants.
STATE OF NEW YORK ss.:
------COUNT-Y-0F-QUEENS- -------------- -
RMY A
l½YN·A E. DOUGLAS, being duly sworn, deposes and says:
1. That I am the plaintiff in the within action.
2. I incorporate and support allthe statemcats made in my attorney's accompsayiñg
Affirmation as if stated in full herein.
3. I make this af fidavit in support of this motion for default judgment against the
Defendants, JEVAN SIMPSON, KAYDE PALMER and FAST LANE MOTORS, LLC.
4. This is an action for personal injuries occurring from an incident on November
19, 2017, whereby my vehicia was struck by the vehicle owned by Defendans, KAYDE
PALMER and FAST LANE MOTORS, LLC, and operated by Defendant, JEVAN SIMPSON.
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FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX
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703719/2018
703719/2018
e...--. yumano vvvaia ©Aram Uef3U(ZU19 11 : 20
NYSCEF
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DOC.
DOC.
NO.NO.
4011 RECEIVED
RECEIVED
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07/07/2021
04/30/2019
5. A Summons and Verified complaint was served upon Defendant JEVAN
SIMPSON and KAYDE PALMER on May 3, 2018, and on FAST LANE MOTORS, LLC on
May 9, 2018. To date, no answer has been interposed on behalf of any defendent. A copy of the
Summons and Verified Cemp!±t is annexed hereto as Exhibit "A". The affidavit of service is
annexed hereto as Exhibit "B".
6. reason of the occurrence, I sustained injuries to my Spine and Shoulder which
By
are permanent in nature:
7. Based upon the foregoing, my attomeys advise me that I have a meritorious cause
Defendants'
of action since I was caused to be injured by the negligence.
8. The defendant was careless, reckless and negligent in the ownership, operation,
management, control, leasing, supervision, inspection, maintenance and repair of their motor
vehicle; in the said vehicle at a rate of speed greater than was reasonable and proper at
operating
the time and place of the accident; in failing to yield the right of way; in losing control of the said
motor vehicle; in failing to keep a proper lookout the roadway; in failing to avoid the
along
accident complained of although there was a reasonable opportunity to do so; infailing to observe
trafficconditions and driving and there existing at theplace and time of the accident complained
of5,in failing to see what there was to be seen; in failing to operate the motor vehicle with that
degree of care and caution necessary under said traffic and driving conditions; in failing to
properly steer, guide, and manage and control of said motor vehicle; in failing to properly sound
the horn or otherwise warn Plaintiff of impending danger; in failing to have adequate and timely
signal, notice or warning; in operating the said motor vehicle without due regard to the rights and
safety of other persons, and especially for the for the safety of Plaintiff herein; in failing to stop,
steer or otherwise avoid the subject accident; in failing to timely apply the brakes or slow down
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FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX NO. 703719/2018
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or stop in such manner so as to avoid said accident; in failing to properly operate the steering
mech-aism of the said motor vehicle so as to avoid said accident; in failing to have made
a quare and timely observations of and response to conditicñs; in failing to observe signs and
signals prevailing the time and place of accident; in failing to keep an adequate, proper and safe
dist£üce betwcca their motor vehicles, and the Plaintiff's vehicic; in failing to keep from striking
Plaintiff's vehicle; in causing injury to the Plaintiff herein; in failing to keep Plaintiff herein free
from injury; in failing to keep the said motor vehicle in proper operating condition; in failing to
inspect said vehicle in proper operating conditions; in failing to inspect said vehicle for defects
deficiencies; in failing to provide said vehicle and Edeqüste and efficient brakes and/or steering
mech=ism and/or signaling devices, and/or tires and/or trâñsmission system; in failing to
observe the rules of the road and in violation all applicable laws, statutes, rules, regü!stions and
ordinances then and therein effect and existing at the place and time of the accident complained
of; and in otherwise being careless, reckless and negligent in the ownership, operation, control,
:;n:g:ment, leasing, supervision, inspection, maiñtenance and repair of the said motor vehicle.
Ranya E. Douglas
Sworn to before me this
l't day of, f
NOTARY PUBLIC
MarioGarcia
Notary Public,Stateof NewYork
No.01GA6289787
GuaMied in Bronx
County
Cammission Ex pires
September 30, 20 ....
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W FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX INDEX NO. 703719/2018 NO. 703719/2018 v.-u. yeamma uv um s x GinatiME U4/.5U / Z U19 11: 20 NYSCEF NYSCEF DOC. DOC. NO.NO. 4011 RECEIVED RECEIVED NYSCEF: 04/30/2019 NYSCEF: 07/07/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS INDEX NO. 703719/2018 G.B., an infant his mother and natural guardian RAYNA by DOUOLAS and RAYNA DOUOLAS, Individual, AFFIDAVIT IN SUPPORT Plaintiffs, -against- JEVAN SIMPSON, KAYDE PALMER AND FAST LANE MOTORS, LLC, Defendants. STATE OF NEW YORK ss.: ------COUNT-Y-0F-QUEENS- -------------- - RMY A l½YN·A E. DOUGLAS, being duly sworn, deposes and says: 1. That I am the plaintiff in the within action. 2. I incorporate and support allthe statemcats made in my attorney's accompsayiñg Affirmation as if stated in full herein. 3. I make this af fidavit in support of this motion for default judgment against the Defendants, JEVAN SIMPSON, KAYDE PALMER and FAST LANE MOTORS, LLC. 4. This is an action for personal injuries occurring from an incident on November 19, 2017, whereby my vehicia was struck by the vehicle owned by Defendans, KAYDE PALMER and FAST LANE MOTORS, LLC, and operated by Defendant, JEVAN SIMPSON. 1 of 3 1 of 3 M FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX iNDEX NO. NO. 703719/2018 703719/2018 e...--. yumano vvvaia ©Aram Uef3U(ZU19 11 : 20 NYSCEF NYSCEF DOC. DOC. NO.NO. 4011 RECEIVED RECEIVED NYSCEF: NrSCEF: 07/07/2021 04/30/2019 5. A Summons and Verified complaint was served upon Defendant JEVAN SIMPSON and KAYDE PALMER on May 3, 2018, and on FAST LANE MOTORS, LLC on May 9, 2018. To date, no answer has been interposed on behalf of any defendent. A copy of the Summons and Verified Cemp!±t is annexed hereto as Exhibit "A". The affidavit of service is annexed hereto as Exhibit "B". 6. reason of the occurrence, I sustained injuries to my Spine and Shoulder which By are permanent in nature: 7. Based upon the foregoing, my attomeys advise me that I have a meritorious cause Defendants' of action since I was caused to be injured by the negligence. 8. The defendant was careless, reckless and negligent in the ownership, operation, management, control, leasing, supervision, inspection, maintenance and repair of their motor vehicle; in the said vehicle at a rate of speed greater than was reasonable and proper at operating the time and place of the accident; in failing to yield the right of way; in losing control of the said motor vehicle; in failing to keep a proper lookout the roadway; in failing to avoid the along accident complained of although there was a reasonable opportunity to do so; infailing to observe trafficconditions and driving and there existing at theplace and time of the accident complained of5,in failing to see what there was to be seen; in failing to operate the motor vehicle with that degree of care and caution necessary under said traffic and driving conditions; in failing to properly steer, guide, and manage and control of said motor vehicle; in failing to properly sound the horn or otherwise warn Plaintiff of impending danger; in failing to have adequate and timely signal, notice or warning; in operating the said motor vehicle without due regard to the rights and safety of other persons, and especially for the for the safety of Plaintiff herein; in failing to stop, steer or otherwise avoid the subject accident; in failing to timely apply the brakes or slow down 2 2 of 3 2 of 3 FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX NO. 703719/2018 NYSCEF NYSCE DOC. F DOC.NO.NO. 4011 RECEIVED RECEIVED NYSCEF: 0407/07/2021 NYSCEF: /30/2019 or stop in such manner so as to avoid said accident; in failing to properly operate the steering mech-aism of the said motor vehicle so as to avoid said accident; in failing to have made a quare and timely observations of and response to conditicñs; in failing to observe signs and signals prevailing the time and place of accident; in failing to keep an adequate, proper and safe dist£üce betwcca their motor vehicles, and the Plaintiff's vehicic; in failing to keep from striking Plaintiff's vehicle; in causing injury to the Plaintiff herein; in failing to keep Plaintiff herein free from injury; in failing to keep the said motor vehicle in proper operating condition; in failing to inspect said vehicle in proper operating conditions; in failing to inspect said vehicle for defects deficiencies; in failing to provide said vehicle and Edeqüste and efficient brakes and/or steering mech=ism and/or signaling devices, and/or tires and/or trâñsmission system; in failing to observe the rules of the road and in violation all applicable laws, statutes, rules, regü!stions and ordinances then and therein effect and existing at the place and time of the accident complained of; and in otherwise being careless, reckless and negligent in the ownership, operation, control, :;n:g:ment, leasing, supervision, inspection, maiñtenance and repair of the said motor vehicle. Ranya E. Douglas Sworn to before me this l't day of, f NOTARY PUBLIC MarioGarcia Notary Public,Stateof NewYork No.01GA6289787 GuaMied in Bronx County Cammission Ex pires September 30, 20 .... 3 3 of 3 3 of 3