Preview
FILED: KINGS COUNTY CLERK 10/25/2018 02:37 PM INDEX NO. 521543/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
Filed:
PIETRO SCICCHITANO, 1NDEX NO.
Plaintiffs, Plaintiffs designate Kings
County as the place of trial.
-against-
S U M M O N S
MONIRUL ISLAM,
The basis of venue is
Defendant. the Defendant's Residence.
To the above named Defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
plaintiffs'
a copy of your answer on the attorneys within 20 days after the service of this
summons, exclusive of the day of service of this summons, or within 30 days after service of this
summons is complete if this summons is not personally delivered to you within the State of New
York.
In case of your failure to answer this summons, a judgment by default will be taken
against you for the relief demanded in the complaint, together with the costs of this action.
Dated: East Meadow, New York
October 25, 2018
MIROTZNIK & ASSOCIATES, LLC
Attorneys for Plaintiffs
2115 Hempstead Turnpike
East Meadow, New York 11554
(516) 794-8827
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TO:
MONIRUL ISLAM
507 Elderts Lane
Brooklyn, NY 11208
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
INDEX NO.
PIETRO SCICCHITANO,
Plaintiffs, VERIFIED COMPLAINT
-against-
MONIRUL ISLAM,
Defendant.
Plaintiff, by his attorneys, MIROTZNIK & ASSOCIATES, LLC, as and for his Verified
Complaint, respectfully allege, upon information and belief:
1. The plaintiff, PIETRO SCICCHITANO, at all times herein mentioned was and still is
a resident of the County of Nassau and the State of New York.
2. The defendant, MONIRUL ISLAM, at all times herein mentioned was and still is a
resident of the County of Kings and the State of New York.
3. On or about March 27, 2016, BOSCAINO AUTO CN LTD owned a certain
automobile, bearing New York State license plate number 20504TT.
4. On or about March 27, 2016, plaintiff PIETRO SCICCHITANO was the operator of a
certain automobile, bearing New York State license plate number 20504TT.
5. On or about March 27, 2016, plaintiff MONIRUL ISLAM owned a certain
automobile, bearing New York State license plate number T668960C.
6. On or about March 27, 2016, defendant MONIRUL ISLAM was the registered owner
of a certain automobile, bearing New York State license plate number T668960C.
7. On or about March 27, 2016, defendant MONIRUL ISLAM was the titled owner of a
certain automobile, bearing Èew York State license plate number T668960C.
8. On or about March 27, 2016, defendant MONIRUL ISLAM maintained a certain
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FILED: KINGS COUNTY CLERK 10/25/2018 02:37 PM INDEX NO. 521543/2018
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automobile, bearing New York State license plate number T668960C.
9. On or about March 27, 2016, defendant MONIRUL ISLAM controlled a certain
automobile, bearing New York State license plate number T668960C.
10. On or about March 27, 2016, defendant MONIRUL ISLAM was the lessee of a
certain automobile, bearing New York State license plate number T668960C.
11. On or about March 27, 2016, defendant MONIRUL ISLAM was the lessor of a
certain automobile, bearing New York State license plate mimber T668960C.
12. On or about March 27, 2016, defendant MONIRUL ISLAM was the operator of a
certain automobile, bearing New York State license plate number T668960C.
13. On or about March 27, 2016, the vehicle operated by the defendant MONIRUL
ISLAM came in contact with the vehicle operated by the plaintiff PIETRO SCICCHITANO at
105th
Cross Island Parkway at or near Avenue, County of Queens, State of New York.
14. Solely as a result of the defendant's negligence, carelessness and recklessness, the
plaintiff PIETRO SCICCHITANO was caused to suffer severe and serious personal injuries to
mind and body, and further, that the plaintiff was subjected to great physical pain and mental
anguish.
15. As a result of the foregoing, the plaintiff sustained serious personal injuries as
defined in Section 5102(d) of the Insurance Law of the State of New York, and/or economic loss
greater than basic economic loss as defined in Section 5102(a) of the Insurance Law of the State
of New York.
16. This action falls within one or more of the exceptions set forth in Section 1602 of the
Civil Practice Law and Rules.
17. Due to defendant's negligence, plaintiff is entitled to damages.
WHEREFORE, the plaintiff demands judgment awarding damages, in an amount
exceeding the monetary jurisdictional limits of all lower courts which would otherwise have
2
4 of 6
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018
.-
jurisdiction, together with interest and the costs and disbursements of this action, and such other
and further relief as to this Court seems just and proper.
Dated: East Meadow, New York
October 25, 2018
By: tephen . dd o
MIRO & ASSOCIATES, LLC
Attorneys for Plaintiffs
2115 Hempstead Turnpike
East Meadow, New York 11554
(516) 794-8827
3
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
Index No
- -
--------..-----------.----.---------.-----.--.---- - - - - - - . - - - - -
PIETRO SCICCHITANO and MONIRUL ISLAM,
Plaintiffs,
-against-
MONIRUL ISLAM,
Defendants.
- - _ _ _ _ _ _ _--_ _ _-_ _ _ _ _ _-_ _ _....--.--..-.--------...____.__-- - --
____________________________________________
SUMMONS and VERIFIED COMPLAINT
________________---------------________________
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to
practice in the Courts of New York certifies upon
State, that, information
and belief, and reasonable the böntentions coñtained
inquiry, in the
annexed document are not frivolous
By:
Michael B. Mirotznik
MIROTZNIK & ASSOCIATES, LLC
Attorneys for Plaintiffs
2115 Hempstead Turnpike
East Meadow, New York 11554
(516) 794-8827
6 of 6
Preview
FILED: KINGS COUNTY CLERK 10/25/2018 02:37 PM INDEX NO. 521543/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Filed: PIETRO SCICCHITANO, 1NDEX NO. Plaintiffs, Plaintiffs designate Kings County as the place of trial. -against- S U M M O N S MONIRUL ISLAM, The basis of venue is Defendant. the Defendant's Residence. To the above named Defendant: YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve plaintiffs' a copy of your answer on the attorneys within 20 days after the service of this summons, exclusive of the day of service of this summons, or within 30 days after service of this summons is complete if this summons is not personally delivered to you within the State of New York. In case of your failure to answer this summons, a judgment by default will be taken against you for the relief demanded in the complaint, together with the costs of this action. Dated: East Meadow, New York October 25, 2018 MIROTZNIK & ASSOCIATES, LLC Attorneys for Plaintiffs 2115 Hempstead Turnpike East Meadow, New York 11554 (516) 794-8827 1 of 6 FILED: KINGS COUNTY CLERK 10/25/2018 02:37 PM INDEX NO. 521543/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018 TO: MONIRUL ISLAM 507 Elderts Lane Brooklyn, NY 11208 2 of 6 FILED: KINGS COUNTY CLERK 10/25/2018 02:37 PM INDEX NO. 521543/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS INDEX NO. PIETRO SCICCHITANO, Plaintiffs, VERIFIED COMPLAINT -against- MONIRUL ISLAM, Defendant. Plaintiff, by his attorneys, MIROTZNIK & ASSOCIATES, LLC, as and for his Verified Complaint, respectfully allege, upon information and belief: 1. The plaintiff, PIETRO SCICCHITANO, at all times herein mentioned was and still is a resident of the County of Nassau and the State of New York. 2. The defendant, MONIRUL ISLAM, at all times herein mentioned was and still is a resident of the County of Kings and the State of New York. 3. On or about March 27, 2016, BOSCAINO AUTO CN LTD owned a certain automobile, bearing New York State license plate number 20504TT. 4. On or about March 27, 2016, plaintiff PIETRO SCICCHITANO was the operator of a certain automobile, bearing New York State license plate number 20504TT. 5. On or about March 27, 2016, plaintiff MONIRUL ISLAM owned a certain automobile, bearing New York State license plate number T668960C. 6. On or about March 27, 2016, defendant MONIRUL ISLAM was the registered owner of a certain automobile, bearing New York State license plate number T668960C. 7. On or about March 27, 2016, defendant MONIRUL ISLAM was the titled owner of a certain automobile, bearing Èew York State license plate number T668960C. 8. On or about March 27, 2016, defendant MONIRUL ISLAM maintained a certain 3 of 6 FILED: KINGS COUNTY CLERK 10/25/2018 02:37 PM INDEX NO. 521543/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018 automobile, bearing New York State license plate number T668960C. 9. On or about March 27, 2016, defendant MONIRUL ISLAM controlled a certain automobile, bearing New York State license plate number T668960C. 10. On or about March 27, 2016, defendant MONIRUL ISLAM was the lessee of a certain automobile, bearing New York State license plate number T668960C. 11. On or about March 27, 2016, defendant MONIRUL ISLAM was the lessor of a certain automobile, bearing New York State license plate mimber T668960C. 12. On or about March 27, 2016, defendant MONIRUL ISLAM was the operator of a certain automobile, bearing New York State license plate number T668960C. 13. On or about March 27, 2016, the vehicle operated by the defendant MONIRUL ISLAM came in contact with the vehicle operated by the plaintiff PIETRO SCICCHITANO at 105th Cross Island Parkway at or near Avenue, County of Queens, State of New York. 14. Solely as a result of the defendant's negligence, carelessness and recklessness, the plaintiff PIETRO SCICCHITANO was caused to suffer severe and serious personal injuries to mind and body, and further, that the plaintiff was subjected to great physical pain and mental anguish. 15. As a result of the foregoing, the plaintiff sustained serious personal injuries as defined in Section 5102(d) of the Insurance Law of the State of New York, and/or economic loss greater than basic economic loss as defined in Section 5102(a) of the Insurance Law of the State of New York. 16. This action falls within one or more of the exceptions set forth in Section 1602 of the Civil Practice Law and Rules. 17. Due to defendant's negligence, plaintiff is entitled to damages. WHEREFORE, the plaintiff demands judgment awarding damages, in an amount exceeding the monetary jurisdictional limits of all lower courts which would otherwise have 2 4 of 6 FILED: KINGS COUNTY CLERK 10/25/2018 02:37 PM INDEX NO. 521543/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018 .- jurisdiction, together with interest and the costs and disbursements of this action, and such other and further relief as to this Court seems just and proper. Dated: East Meadow, New York October 25, 2018 By: tephen . dd o MIRO & ASSOCIATES, LLC Attorneys for Plaintiffs 2115 Hempstead Turnpike East Meadow, New York 11554 (516) 794-8827 3 5 of 6 FILED: KINGS COUNTY CLERK 10/25/2018 02:37 PM INDEX NO. 521543/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No - - --------..-----------.----.---------.-----.--.---- - - - - - - . - - - - - PIETRO SCICCHITANO and MONIRUL ISLAM, Plaintiffs, -against- MONIRUL ISLAM, Defendants. - - _ _ _ _ _ _ _--_ _ _-_ _ _ _ _ _-_ _ _....--.--..-.--------...____.__-- - -- ____________________________________________ SUMMONS and VERIFIED COMPLAINT ________________---------------________________ Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the Courts of New York certifies upon State, that, information and belief, and reasonable the böntentions coñtained inquiry, in the annexed document are not frivolous By: Michael B. Mirotznik MIROTZNIK & ASSOCIATES, LLC Attorneys for Plaintiffs 2115 Hempstead Turnpike East Meadow, New York 11554 (516) 794-8827 6 of 6