Preview
FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------- ¬--------------X Index No.
ALEXANDER RAGOLSKY,
Plaintiff(s)
Plaintiff, Kings County
as the place
-against-
The basis of
MIN AUNG WONG. Defendant(s)
SUMMONS
Defendant. Defendant(s)
22nd
47 Bay
--------------------- ------------------------X Brooklyn, N
To the above named Defendant(s)
YOU ARE HEREBY SUMMONED to Answer the Complaint in this action
copy of your Answer, or, if the Complaint is not served with this Summons, to
Appearance, on the Plaintiffs attorney(s) within twenty (20) days after the
Summons, exclusive of the day of service (or within thirty (30) days after the s
if this Summons is not personally
delivered to you within the State of New York)
your failure to appear or answer, Judgment will be taken against you y Defau
demanded in the Complaint.
Dated: Garden City, New York
October 17, 2018
J H D. SULLIVAN
L VAN & SULLIVAN
Attorneys for Plaintiff
1225 Franklin Avenue, Suite
Garden City, New York 1
Defendant(s) address(es):
1 of 7
FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------------X Index No.
ALEXANDER RAGOLSKY,
Plaintiff,
yERIFIED
C_OMPLAINT
-against-
MIN AUNG WONG,
Defendant.
--------------------------------------------------------------------X
On behalf of the Plaintiff, ALEXANDER RAGOLSKY, by and throu
Joseph D. Sullivan, Esq. as and for his complaint of the Defendant herein states
1. That at all times hereinafter mentioned the Defendant, MIN AU
and still is a resident of the County of Kings, State of New York.
2. That all times hereinafter mentioned Plaintiff, ALEXANDER RA
resident of New Jersey.
3. Upon information and belief at all times hereinafter mentioned
Battery Tunnel, was a public street and roadway traveled upon by motor vehicles.
4. Upon information and belief, at all times hereinafter mentioned,
MIN AUNG WONG, was the owner of a 2017 Mercedes-Benz motor vehicle w
plate and registration number HNH 7884, New York, 2017.
5. Upon information 2 of and
7 belief, at all times hereinafter mentioned,
FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018
the Brooklyn Battery Tunnel in the County of Brooklyn, State of New York.
AS AND FOR A FIRST CAUSE OF ACTION
8. That the negligence of the Defendant consisted of owning and op
vehicle in a dangerous manner; failing to keep a proper lookout ahead; in causing
permitting
the motor vehicle to be operated at an excessive, dangerous and
speed under the circumstances then and there prevailing; in failing to have an
vehicle under reasonable and proper control; failing to obey and heed the
conditions then and there existing; in
failing
to take the necessary and p
precautions to guard against and prevent the occurrence of the accident; in failing
and prudence in the circumstances then and there prevailing; in failing and omitting
motor vehicle under control in time to avoid the occurrence of the accident;
omitting to have adequate sufficient braking and/or other safety devices; in
faili
to make timely and adequate use of such brakes or braking devices as were there
make proper use of the steering mechanism; in operating and controlling
without regards to the rights of other persons in and to the use of the roadway;
what was there to be seen; in
permitting themselves to be distracted; in failing
accident; in failing to observe the flow of traffic; in failing to avoid contact; in
safe passage to the Plaintiff; in
operating the motor vehicle in such negligent,
wanton and grossly negligent 3manner
of 7 as to precipitate the aforesaid accident;
FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018
attentive; in operating the motor vehicle in a manner contrary to and in violation
ordinances, rules and regulations in such cases made and provided; in causing,
permitting the motor vehicle in which Plaintiff, was driving to collide; and the
otherwise careless, reckless, culpable and negligent in the premises, all in violation
and regulations.
9. The aforesaid occurrence and the injuries resulting to the Plaintiff
RAGOLSKY, therefrom, were caused solely
and wholly as a result of the
Defendant without any negligence on the part of the Plaintiff
contributing
the
left the scene of the accident and upon information and belief was issued a ticke
the VTL of the State of New York.
10. As a result of the aforesaid, the Plaintiff ALEXANDER R
sustained a serious injury as defined in §5102(d) of the Insurance Law of the S
and an economic loss greater than basic economic loss as defined in §5102(a)
Law of the State of New York.
11. By reason of the aforesaid, the Plaintiff ALEXANDER RAGO
sore and disabled; the Plaintiff ALEXANDER RAGOLSKY, suffered and c
from great physical pain and mental anguish; Plaintiff has been informed an
future suffering will exist and will be permanent with permanent pain, discomfort,
movement, disfigurement, and 4 disability.
of 7
FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018
14. That as a result of the foregoing, Plaintiff ALEXANDER RAGO
damaged in the amount of One Million ($1,000,000.00) Dollars.
WHEREFORE, Plaintiff, ALEXANDER RAGOLSKY, demands judgm
Defendant on the first cause of action for money damages in the amount
($1,000,000.00) Dollars, together with the costs and disbursements of this action.
Yours, etc.
S LLIVAN & S L I N
O D. SUL IVAN
Sul i & Sullivan
rneys for Plaintiff
1225 Franklin Avenue, Suite
Garden City, New York 115
(516) 248-7777
Josephd.sullivan@att.net
5 of 7
FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018
VERIFICATION
STATE OF NEW JERSEY
COUNTY OF Af O
I, Alexander Ragolsky, being duly sworn according to law, depose and say:
1. I am the person named in the foregoing Complaint.
2. The statements in the Complaint are true and to the best of knowledge and
belief.
ALE ER RAGOLS
Sworn bef
L
and ubscribed e
me this day of , 2018
N YÂRY PÙBLI
6 of 7
FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018
SUPREME COURT OF THE STATE OF NEW YORK Index #
COUNTY OF KINGS
------------------------------------------------- ------X
ALEXANDER RAGOLSKY,
Plaintiff,
-against-
MIN AUNG WONG,
Defendant.
---------------- ----------------------------------------X
VERIFIED COMPLAINT
SULLIVAN & SULLIVAN
Attorney for Plaintiff
1225 Franklin Avenue, Suite 325
Garden City, New York 11530
(516) 248-7777
(516) 746-6170 (Fax)
Pursuant to 22 NYCRR 130-1.1., the undersigned, an attorney admitted to practice in the courts of New York State,
certified
that, upon information and belief and reasonable inquiry, the contentions contained in the annexed
document are not frivolous.
Dated.. Signature............................................................
Print Signer's Name JOSEPH D. SULLIVAN
Service of a copy of the within is hereby admitted
Dated, ...................................................................
Attorney(s) for
SIR: PLEASE TAKE NOTICE
NOTICE OF that the within is a (certified) true copy of a entered in the office of the clerk of the within
ENTRY named Court on
NOTICE OF that an Order of which the within is a true copy will be presented for settlement to the Hon.
SETTLEMENT one of the judges of the within named Court, at on , at
M.
To:
MIN AUNG WONG
Defendant
7 of 7
Preview
FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------- ¬--------------X Index No. ALEXANDER RAGOLSKY, Plaintiff(s) Plaintiff, Kings County as the place -against- The basis of MIN AUNG WONG. Defendant(s) SUMMONS Defendant. Defendant(s) 22nd 47 Bay --------------------- ------------------------X Brooklyn, N To the above named Defendant(s) YOU ARE HEREBY SUMMONED to Answer the Complaint in this action copy of your Answer, or, if the Complaint is not served with this Summons, to Appearance, on the Plaintiffs attorney(s) within twenty (20) days after the Summons, exclusive of the day of service (or within thirty (30) days after the s if this Summons is not personally delivered to you within the State of New York) your failure to appear or answer, Judgment will be taken against you y Defau demanded in the Complaint. Dated: Garden City, New York October 17, 2018 J H D. SULLIVAN L VAN & SULLIVAN Attorneys for Plaintiff 1225 Franklin Avenue, Suite Garden City, New York 1 Defendant(s) address(es): 1 of 7 FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X Index No. ALEXANDER RAGOLSKY, Plaintiff, yERIFIED C_OMPLAINT -against- MIN AUNG WONG, Defendant. --------------------------------------------------------------------X On behalf of the Plaintiff, ALEXANDER RAGOLSKY, by and throu Joseph D. Sullivan, Esq. as and for his complaint of the Defendant herein states 1. That at all times hereinafter mentioned the Defendant, MIN AU and still is a resident of the County of Kings, State of New York. 2. That all times hereinafter mentioned Plaintiff, ALEXANDER RA resident of New Jersey. 3. Upon information and belief at all times hereinafter mentioned Battery Tunnel, was a public street and roadway traveled upon by motor vehicles. 4. Upon information and belief, at all times hereinafter mentioned, MIN AUNG WONG, was the owner of a 2017 Mercedes-Benz motor vehicle w plate and registration number HNH 7884, New York, 2017. 5. Upon information 2 of and 7 belief, at all times hereinafter mentioned, FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018 the Brooklyn Battery Tunnel in the County of Brooklyn, State of New York. AS AND FOR A FIRST CAUSE OF ACTION 8. That the negligence of the Defendant consisted of owning and op vehicle in a dangerous manner; failing to keep a proper lookout ahead; in causing permitting the motor vehicle to be operated at an excessive, dangerous and speed under the circumstances then and there prevailing; in failing to have an vehicle under reasonable and proper control; failing to obey and heed the conditions then and there existing; in failing to take the necessary and p precautions to guard against and prevent the occurrence of the accident; in failing and prudence in the circumstances then and there prevailing; in failing and omitting motor vehicle under control in time to avoid the occurrence of the accident; omitting to have adequate sufficient braking and/or other safety devices; in faili to make timely and adequate use of such brakes or braking devices as were there make proper use of the steering mechanism; in operating and controlling without regards to the rights of other persons in and to the use of the roadway; what was there to be seen; in permitting themselves to be distracted; in failing accident; in failing to observe the flow of traffic; in failing to avoid contact; in safe passage to the Plaintiff; in operating the motor vehicle in such negligent, wanton and grossly negligent 3manner of 7 as to precipitate the aforesaid accident; FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018 attentive; in operating the motor vehicle in a manner contrary to and in violation ordinances, rules and regulations in such cases made and provided; in causing, permitting the motor vehicle in which Plaintiff, was driving to collide; and the otherwise careless, reckless, culpable and negligent in the premises, all in violation and regulations. 9. The aforesaid occurrence and the injuries resulting to the Plaintiff RAGOLSKY, therefrom, were caused solely and wholly as a result of the Defendant without any negligence on the part of the Plaintiff contributing the left the scene of the accident and upon information and belief was issued a ticke the VTL of the State of New York. 10. As a result of the aforesaid, the Plaintiff ALEXANDER R sustained a serious injury as defined in §5102(d) of the Insurance Law of the S and an economic loss greater than basic economic loss as defined in §5102(a) Law of the State of New York. 11. By reason of the aforesaid, the Plaintiff ALEXANDER RAGO sore and disabled; the Plaintiff ALEXANDER RAGOLSKY, suffered and c from great physical pain and mental anguish; Plaintiff has been informed an future suffering will exist and will be permanent with permanent pain, discomfort, movement, disfigurement, and 4 disability. of 7 FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018 14. That as a result of the foregoing, Plaintiff ALEXANDER RAGO damaged in the amount of One Million ($1,000,000.00) Dollars. WHEREFORE, Plaintiff, ALEXANDER RAGOLSKY, demands judgm Defendant on the first cause of action for money damages in the amount ($1,000,000.00) Dollars, together with the costs and disbursements of this action. Yours, etc. S LLIVAN & S L I N O D. SUL IVAN Sul i & Sullivan rneys for Plaintiff 1225 Franklin Avenue, Suite Garden City, New York 115 (516) 248-7777 Josephd.sullivan@att.net 5 of 7 FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018 VERIFICATION STATE OF NEW JERSEY COUNTY OF Af O I, Alexander Ragolsky, being duly sworn according to law, depose and say: 1. I am the person named in the foregoing Complaint. 2. The statements in the Complaint are true and to the best of knowledge and belief. ALE ER RAGOLS Sworn bef L and ubscribed e me this day of , 2018 N YÂRY PÙBLI 6 of 7 FILED: KINGS COUNTY CLERK 10/26/2018 10:58 AM INDEX NO. 521608/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/26/2018 SUPREME COURT OF THE STATE OF NEW YORK Index # COUNTY OF KINGS ------------------------------------------------- ------X ALEXANDER RAGOLSKY, Plaintiff, -against- MIN AUNG WONG, Defendant. ---------------- ----------------------------------------X VERIFIED COMPLAINT SULLIVAN & SULLIVAN Attorney for Plaintiff 1225 Franklin Avenue, Suite 325 Garden City, New York 11530 (516) 248-7777 (516) 746-6170 (Fax) Pursuant to 22 NYCRR 130-1.1., the undersigned, an attorney admitted to practice in the courts of New York State, certified that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated.. Signature............................................................ Print Signer's Name JOSEPH D. SULLIVAN Service of a copy of the within is hereby admitted Dated, ................................................................... Attorney(s) for SIR: PLEASE TAKE NOTICE NOTICE OF that the within is a (certified) true copy of a entered in the office of the clerk of the within ENTRY named Court on NOTICE OF that an Order of which the within is a true copy will be presented for settlement to the Hon. SETTLEMENT one of the judges of the within named Court, at on , at M. To: MIN AUNG WONG Defendant 7 of 7