Preview
FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018
SUPREME COURT OF THE STATE OF NEW YORK Index No:
COUNTY OF KINGS
----------
-----------------------------------X Date Purchased:
REGINA M. SACOTO ROMERO,
SUMMONS
Plaintiff,
-against- Plaintiff designates:
KINGS COUNTY
as the place of trial.
JOSEPH F. RAMOS and J & S SUPPLY CORP The basis of venue is
Plaintiff's residence:
Defendants. 417 Baltic Street, Apt 8 A
---------- ---X New York 11217
Brooklyn,
To the above named Defendant(s):
YOU ARE HEREBY SUMMONED to answer the
ceraplairit 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 Attorney within 20 days after the service of
this suiñiñóñs, exclusive of the day of service (or within 30 days after the service is complete if the 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 in the complaint.
Dated October 4, 2018
Yours, etc..
MICHA EVITZ, E
SHULMAN & HILL, PLLC
Attorneys for Plaintiff
REGINA M. SACOTO ROMERO
26 Court Street, Suite 2100
Brooklyn, NY 11242
Defendants addresses:
JOSEPH F. RAMOS
41st
2223 Street
Queens, New York 11105
J &S SUPPLY CORP
. . . .
53-02 37 Street
Queens, New York 11101
State-
-Via Secretary of
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------------------X Index:
REGINA M. SACOTO ROMERO,
Plaintiff,
-against- VERIFIED
COMPLAINT
JOSEPH F. RAMOS and J & S SUPPLY CORP
Defendants.
---------------------------------------------------- ----X
Plaintiff, by her attorneys, SHULMAN & HILL, PLLC, complaining of the
defendants, respectfully alleges the following, upon information and belief:
AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF
OF PLAINTIFF REGINA M. SACOTO ROMERO
1. That at all times hereinafter mentioned, and prior thereto, plaintiff, REGINA
M. SACOTO ROMERO, was and still is a resident of the County of Kings, City
and
State of New York.
2. That at all times hereinafter mentioned, the defendant, JOSEPH F.
RAMOS, was and still is a resident of the County of Queens, City and State of New
York.
3. That at all times hereinafter mentioned, and prior thereto, defendant, J & S
SUPPLY CORP., was and still is in a domestic corporation duly organized by and existing
under and by virtue of the laws of the State of New York.
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4. That at all times hereinafter mentioned, and prior thereto, defendant, J & S
SUPPLY CORP., was still is a domestic corporation duly organized by and existing
under
and by virtue of the laws of the State of New York with their principal place of business in
the State of New York.
5. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was and still is a foreign corporation.
6. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was and still is a foreign corporation duly licensed to conduct business in
the State of New York.
7. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was and still is a foreign corporation not duly licensed to conduct business
in the State of New York.
8. That all times hereinafter mentioned, and prior thereto, defendant, J & S
SUPPLY CORP., was the owner of a motor vehicle.
9. That all times hereinafter mentioned, and prior thereto, defendant, J & S
SUPPLY CORP., was the owner of a Kenworth motor vehicle.
10. That at all times hereinafter mentioned, and prior thereto, defendant, J & S
SUPPLY CORP., was the owner of a vehicle bearing New York license plate number
23572PC.
11. That all times hereinafter mentioned, and prior thereto, defendant, J & S
SUPPLY CORP., was the owner of a Kenworth motor vehicle bearing New York license
plate number 23572PC.
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12. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was the lessor of a motor vehicle.
13. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was the lessor of a Kenworth motor vehicle.
14. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was the lessor of a motor vehicle bearing New York license plate
number 23572PC.
15. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was the lessor of a Kenworth motor vehicle bearing New York license
plate number 23572PC.
16. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was the lessee of a motor vehicle.
17. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was the lessee of a Kenworth motor vehicle.
18. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was the lessee of a motor vehicle bearing New York license plate
number 23572PC.
19. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., was the lessee of a Kenworth motor vehicle bearing New York license
plate number 23572PC.
20. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., maintained the aforesaid motor vehicle.
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21. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., maintained the aforesaid Kenworth motor vehicle.
22. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., maintained the aforesaid motor vehicle bearing New York license plate
number 23572PC.
23. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., maintained the aforesaid Kenworth motor vehicle bearing New York
license plate number 23572PC.
24. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., managed the aforesaid motor vehicle.
25. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., managed the aforesaid Kenworth motor vehicle.
26. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., managed the aforesaid motor vehicle bearing New York license plate
number 23572PC.
27. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., managed the aforesaid Kenworth motor vehicle bearing New York
license plate number 23572PC.
28. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP.,·controlled the aforesaid motor vehicle.
29. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., controlled the aforesaid Kenworth motor vehicle.
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30. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., controlled the aforesaid motor vehicle bearing New York license plate
number 23572PC.
31. That at all times hereinafter mentioned and prior thereto, defendant, J & S
SUPPLY CORP., controlled the aforesaid Kenworth motor vehicle bearing New York
license plate number 23572PC.
32. That all times hereinafter mentioned, and prior thereto, defendant, JOSEPH
F. RAMOS, was the owner of a motor vehicle.
33. That all times hereinafter mentioned, and prior thereto, defendant, JOSEPH
F. RAMOS, was the owner of a Kenworth motor vehicle.
34. That at all times hereinafter mentioned, and prior thereto, defendant,
JOSEPH F. RAMOS, was the owner of a vehicle bearing New York license plate
number 23572PC.
35. That all times hereinafter mentioned, and prior thereto, defendant, JOSEPH
F. RAMOS, was the owner of a Kenworth motor vehicle bearing New York license plate
number 23572PC.
36. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the lessor of a motor vehicle.
37. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the· lessor of a Kenworth motor vehicle.
38. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the lessor of a motor vehicle bearing New York license plate
number 23572PC.
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39. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the lessor of a Kenworth motor vehicle bearing New York
license plate number 23572PC.
40. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the lessee of a motor vehicle.
41. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the lessee of a Kenworth motor vehicle.
42. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the lessee of a motor vehicle bearing New York license plate
number 23572PC.
43. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the lessee of a Kenworth motor vehicle bearing New York
license plate number 23572PC.
44. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the operator of a motor vehicle.
45. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the operator of a Kenworth motor vehicle.
46. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the operator of a motor vehicle bearing New York license
plate number 23572PC.
47. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, was the operator of a Kenworth motor vehicle bearing New York
license plate number 23572PC.
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48. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH F. RAMOS, was the operator of the aforesaid motor vehicle with the
knowledge, permission and consent, expressed or implied, of the owner of said vehicle.
49. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH F. RAMOS, was the operator of the aforesaid Kenworth motor vehicle
bearing New York license plate number 23572PC with the knowledge, permission and
consent, expressed or implied, of the owner, J & S SUPPLY CORP., of said vehicle.
50. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH F. RAMOS, was employed by J & S SUPPLY CORP.
51. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH F. RAMOS, was operating the aforementioned Kenworth motor vehicle while in
the scope of his employment.
52. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH F. RAMOS, was operating the aforementioned Kenworth motor vehicle bearing
New York license plate number 23572PC, while in the scope of his employment.
53. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH F. RAMOS, was operating the aforementioned 2013 Kenworth motor vehicle
bearing New York license plate number 23572PC, while in the scope of his employment.
54. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH-F. RAMOS, was operating the aforementioned Kenworth motor vehicle while in
the scope of his employment for the defendant, J & S SUPPLY CORP.
55. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH F. RAMOS, was operating the aforementioned Kenworth motor vehicle, bearing
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New York license plate number 23572PC, while in the scope of his employment for the
defendant, J & S SUPPLY CORP.
56. That at all times hereinafter mentioned, and prior thereto, the defendant,
JOSEPH F. RAMOS, was operating the aforementioned 2013 Kenworth motor vehicle,
bearing New York license plate number 23572PC, while in the scope of his employment
for the defendant, J & S SUPPLY CORP.
57. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, maintained the aforesaid motor vehicle.
58. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, maintained the aforesaid Kenworth motor vehicle.
59. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, maintained the aforesaid motor vehicle bearing New York license
plate number 23572PC.
60. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, maintained the aforesaid Kenworth motor vehicle bearing New
York license plate number 23572PC.
61. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, managed the aforesaid motor vehicle.
62. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, managed the aforesaidKënworth motor vehicle.
63. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, managed the aforesaid motor vehicle bearing New York license
plate number 23572PC.
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64. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, managed the aforesaid Kenworth motor vehicle bearing New
York license plate number 23572PC.
65. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, controlled the aforesaid motor vehicle.
66. That at all times hereinafter mentioned and prior thereto, defendant,
JOSEPH F. RAMOS, controlled the aforesaid Kenworth motor vehicle.
Preview
FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 SUPREME COURT OF THE STATE OF NEW YORK Index No: COUNTY OF KINGS ---------- -----------------------------------X Date Purchased: REGINA M. SACOTO ROMERO, SUMMONS Plaintiff, -against- Plaintiff designates: KINGS COUNTY as the place of trial. JOSEPH F. RAMOS and J & S SUPPLY CORP The basis of venue is Plaintiff's residence: Defendants. 417 Baltic Street, Apt 8 A ---------- ---X New York 11217 Brooklyn, To the above named Defendant(s): YOU ARE HEREBY SUMMONED to answer the ceraplairit 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 Attorney within 20 days after the service of this suiñiñóñs, exclusive of the day of service (or within 30 days after the service is complete if the 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 in the complaint. Dated October 4, 2018 Yours, etc.. MICHA EVITZ, E SHULMAN & HILL, PLLC Attorneys for Plaintiff REGINA M. SACOTO ROMERO 26 Court Street, Suite 2100 Brooklyn, NY 11242 Defendants addresses: JOSEPH F. RAMOS 41st 2223 Street Queens, New York 11105 J &S SUPPLY CORP . . . . 53-02 37 Street Queens, New York 11101 State- -Via Secretary of 1 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------------X Index: REGINA M. SACOTO ROMERO, Plaintiff, -against- VERIFIED COMPLAINT JOSEPH F. RAMOS and J & S SUPPLY CORP Defendants. ---------------------------------------------------- ----X Plaintiff, by her attorneys, SHULMAN & HILL, PLLC, complaining of the defendants, respectfully alleges the following, upon information and belief: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF PLAINTIFF REGINA M. SACOTO ROMERO 1. That at all times hereinafter mentioned, and prior thereto, plaintiff, REGINA M. SACOTO ROMERO, was and still is a resident of the County of Kings, City and State of New York. 2. That at all times hereinafter mentioned, the defendant, JOSEPH F. RAMOS, was and still is a resident of the County of Queens, City and State of New York. 3. That at all times hereinafter mentioned, and prior thereto, defendant, J & S SUPPLY CORP., was and still is in a domestic corporation duly organized by and existing under and by virtue of the laws of the State of New York. 2 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 4. That at all times hereinafter mentioned, and prior thereto, defendant, J & S SUPPLY CORP., was still is a domestic corporation duly organized by and existing under and by virtue of the laws of the State of New York with their principal place of business in the State of New York. 5. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was and still is a foreign corporation. 6. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was and still is a foreign corporation duly licensed to conduct business in the State of New York. 7. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was and still is a foreign corporation not duly licensed to conduct business in the State of New York. 8. That all times hereinafter mentioned, and prior thereto, defendant, J & S SUPPLY CORP., was the owner of a motor vehicle. 9. That all times hereinafter mentioned, and prior thereto, defendant, J & S SUPPLY CORP., was the owner of a Kenworth motor vehicle. 10. That at all times hereinafter mentioned, and prior thereto, defendant, J & S SUPPLY CORP., was the owner of a vehicle bearing New York license plate number 23572PC. 11. That all times hereinafter mentioned, and prior thereto, defendant, J & S SUPPLY CORP., was the owner of a Kenworth motor vehicle bearing New York license plate number 23572PC. 3 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 12. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was the lessor of a motor vehicle. 13. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was the lessor of a Kenworth motor vehicle. 14. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was the lessor of a motor vehicle bearing New York license plate number 23572PC. 15. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was the lessor of a Kenworth motor vehicle bearing New York license plate number 23572PC. 16. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was the lessee of a motor vehicle. 17. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was the lessee of a Kenworth motor vehicle. 18. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was the lessee of a motor vehicle bearing New York license plate number 23572PC. 19. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., was the lessee of a Kenworth motor vehicle bearing New York license plate number 23572PC. 20. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., maintained the aforesaid motor vehicle. 4 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 21. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., maintained the aforesaid Kenworth motor vehicle. 22. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., maintained the aforesaid motor vehicle bearing New York license plate number 23572PC. 23. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., maintained the aforesaid Kenworth motor vehicle bearing New York license plate number 23572PC. 24. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., managed the aforesaid motor vehicle. 25. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., managed the aforesaid Kenworth motor vehicle. 26. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., managed the aforesaid motor vehicle bearing New York license plate number 23572PC. 27. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., managed the aforesaid Kenworth motor vehicle bearing New York license plate number 23572PC. 28. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP.,·controlled the aforesaid motor vehicle. 29. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., controlled the aforesaid Kenworth motor vehicle. 5 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 30. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., controlled the aforesaid motor vehicle bearing New York license plate number 23572PC. 31. That at all times hereinafter mentioned and prior thereto, defendant, J & S SUPPLY CORP., controlled the aforesaid Kenworth motor vehicle bearing New York license plate number 23572PC. 32. That all times hereinafter mentioned, and prior thereto, defendant, JOSEPH F. RAMOS, was the owner of a motor vehicle. 33. That all times hereinafter mentioned, and prior thereto, defendant, JOSEPH F. RAMOS, was the owner of a Kenworth motor vehicle. 34. That at all times hereinafter mentioned, and prior thereto, defendant, JOSEPH F. RAMOS, was the owner of a vehicle bearing New York license plate number 23572PC. 35. That all times hereinafter mentioned, and prior thereto, defendant, JOSEPH F. RAMOS, was the owner of a Kenworth motor vehicle bearing New York license plate number 23572PC. 36. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the lessor of a motor vehicle. 37. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the· lessor of a Kenworth motor vehicle. 38. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the lessor of a motor vehicle bearing New York license plate number 23572PC. 6 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 39. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the lessor of a Kenworth motor vehicle bearing New York license plate number 23572PC. 40. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the lessee of a motor vehicle. 41. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the lessee of a Kenworth motor vehicle. 42. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the lessee of a motor vehicle bearing New York license plate number 23572PC. 43. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the lessee of a Kenworth motor vehicle bearing New York license plate number 23572PC. 44. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the operator of a motor vehicle. 45. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the operator of a Kenworth motor vehicle. 46. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the operator of a motor vehicle bearing New York license plate number 23572PC. 47. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, was the operator of a Kenworth motor vehicle bearing New York license plate number 23572PC. 7 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 48. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH F. RAMOS, was the operator of the aforesaid motor vehicle with the knowledge, permission and consent, expressed or implied, of the owner of said vehicle. 49. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH F. RAMOS, was the operator of the aforesaid Kenworth motor vehicle bearing New York license plate number 23572PC with the knowledge, permission and consent, expressed or implied, of the owner, J & S SUPPLY CORP., of said vehicle. 50. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH F. RAMOS, was employed by J & S SUPPLY CORP. 51. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH F. RAMOS, was operating the aforementioned Kenworth motor vehicle while in the scope of his employment. 52. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH F. RAMOS, was operating the aforementioned Kenworth motor vehicle bearing New York license plate number 23572PC, while in the scope of his employment. 53. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH F. RAMOS, was operating the aforementioned 2013 Kenworth motor vehicle bearing New York license plate number 23572PC, while in the scope of his employment. 54. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH-F. RAMOS, was operating the aforementioned Kenworth motor vehicle while in the scope of his employment for the defendant, J & S SUPPLY CORP. 55. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH F. RAMOS, was operating the aforementioned Kenworth motor vehicle, bearing 8 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 New York license plate number 23572PC, while in the scope of his employment for the defendant, J & S SUPPLY CORP. 56. That at all times hereinafter mentioned, and prior thereto, the defendant, JOSEPH F. RAMOS, was operating the aforementioned 2013 Kenworth motor vehicle, bearing New York license plate number 23572PC, while in the scope of his employment for the defendant, J & S SUPPLY CORP. 57. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, maintained the aforesaid motor vehicle. 58. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, maintained the aforesaid Kenworth motor vehicle. 59. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, maintained the aforesaid motor vehicle bearing New York license plate number 23572PC. 60. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, maintained the aforesaid Kenworth motor vehicle bearing New York license plate number 23572PC. 61. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, managed the aforesaid motor vehicle. 62. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, managed the aforesaidKënworth motor vehicle. 63. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, managed the aforesaid motor vehicle bearing New York license plate number 23572PC. 9 of 15 FILED: KINGS COUNTY CLERK 10/04/2018 04:41 PM INDEX NO. 519974/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2018 64. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, managed the aforesaid Kenworth motor vehicle bearing New York license plate number 23572PC. 65. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, controlled the aforesaid motor vehicle. 66. That at all times hereinafter mentioned and prior thereto, defendant, JOSEPH F. RAMOS, controlled the aforesaid Kenworth motor vehicle.