Preview
FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF Kings Date Purchased:
______________________________________________________________________Ç
MOLLIE JACE and JENNA JACE, SUMMONS
Plaintiffs, Plaintiffs designate Kings
County as the place of trial.
vs.
The basis of venue is:
THE HERTZ CORPORATION, HERTZ VEHICLES LLC and Plaintiffs residence
SHAREE COOPER,
Plaintiffs reside at:
Defendants. 371 Van Siclen Avenue
Brooklyn, N.Y., 11207
_________________________________________________________ _____________Ç
County of Kings
To the above named Defendants:
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 t s summons, to serve a notice of
appearance on the Plaintiffs attorney(s) within twenty da after the service of this summons,
exclusive of the day of service, where service is made by delivery upon you personally within
the state, or, within 30 days after completion of service •here service is made in any other
manner. In case of your failure to appear or answer, ju ment will be taken against you by
default for the relief demanded in the complaint.
Dated: New York, New York
March 8, 2022
H. TA NBA
LAW OFFICES OF JAY H. TANENBAUM
Attorney for Plaintiffs
14 Wall Street - Suite 5F
New York, New York 10005
(212) 422-1765
Our File No. 555-20J-0084
TO:
THE HERTZ CORPORATION
28 Liberty Street
New York, New York 10005
HERTZ VEHICLES LLC
28 Liberty Street
New York, New York 10005
SHAREE COOPER
(Unknown)
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF Kings
----------------------------------------------------------------------X Index No.:
MOLLIE JACE and JENNA JACE,
Date Purchased:
Plaintiffs,
VERIFIED COMPLAINT
vs.
THE HERTZ CORPORATION, HERTZ VEHICLES LLC and
SHAREE COOPER,
Defendants.
______________________________________________________________________Ç
Plaintiffs, by their attorneys, Law Offices of Jay H. Tanenbaum, complaining of the
Defendants, respectfully allege, upon information and belief:
AS AND FOR A FIRST CAUSE OF ACTION
ON BEHALF OF THE PLAINTIFF, MOLLIE JACE:
1. At all times herein mentioned, Plaintiffs were, and still are, residents of the
County of Kings, City and State of New York.
2. At all times herein mentioned, Defendant THE HERTZ CORPORATION was, and
still is, a foreign business corporation duly authorized to do business in the State of
New York.
3. At all times herein mentioned, Defendant HERTZ VEHICLES LLC was, and still
is, a foreign business corporation duly authorized to do business in the State of New
York.
4. At all times herein mentioned, Defendant SHAREE COOPER was, and still is, a
resident of the County of Kings, City and State of New York.
5. At all times herein mentioned, Defendant THE HERTZ CORPORATION was the
owner of a 2020 Toyota motor vehicle bearing New York State registration number
JJJ5010.
6. At all times herein mentioned, Defendant HERTZ VEHICLES LLC was the owner
of a 2020 Toyota motor vehicle bearing New York State registration number JJJ5010.
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7. At all times herein mentioned, Defendant SHAREE COOPER operated the
aforementioned motor vehicle motor vehicle.
8. At all times herein mentioned, Defendant SHAREE COOPER operated the motor
vehicle with the permission of Defendant, THE HERTZ CORPORATION.
9. At all times herein mentioned, Defendant SHAREE COOPER operated the
aforementioned motor vehicle with the knowledge of the Defendant, THE HERTZ
CORPORATION.
10. At all times herein mentioned, Defendant SHAREE COOPER operated the
aforementioned motor vehicle with the consent of the Defendant, THE HERTZ
CORPORATION.
11. At all times herein mentioned, Defendant SHAREE COOPER operated the motor
vehicle with the permission of Defendant, HERTZ VEHICLES LLC.
12. At all times herein mentioned, Defendant SHAREE COOPER operated the
aforementioned motor vehicle with the knowledge of the Defendant, HERTZ VEHICLES
LLC.
13. At all times herein mentioned, Defendant SHAREE COOPER operated the
aforementioned motor vehicle with the consent of the Defendant, HERTZ VEHICLES
LLC.
14. At all times herein mentioned, Plaintiff Mollie Jace, was the operator of a 2018
Mitsubishi motor vehicle bearing New York State registration number KDN5780.
15. At all times herein mentioned, Liberty Avenue and Pennsylvania, in the County
of Kings, City and State of New York, were public roadways, streets and/or
thoroughfares.
16. That on December 4, 2020, Defendant SHAREE COOPER was operating the
vehicle owned by Defendant, THE HERTZ CORPORATION at the aforementioned
location.
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17. That on December 4, 2020, Defendant SHAREE COOPER was operating the
vehicle owned by Defendant, HERTZ VEHICLES LLC at the aforementioned location.
18. That on December 4, 2020, Plaintiff, Mollie Jace was operating her motor
vehicle at the aforementioned location.
19. That on December 4, 2020, at the aforementioned location, the motor vehicle
owned by Defendant THE HERTZ CORPORATION and operated by Defendant SHAREE
COOPER, struck the motor vehicle operated by Plaintiff, Mollie Jace.
20. That on December 4, 2020, at the aforementioned location, the motor vehicle
owned by Defendant HERTZ VEHICLES LLC and operated by Defendant SHAREE
COOPER, struck the motor vehicle operated by Plaintiff, Mollie Jace.
21. That as a result of the aforesaid contact, Plaintiff, Mollie Jace, was injured.
22. That the aforesaid occurrence was caused wholly and solely by reason of the
negligence of the Defendants without any fault or negligence on the part of the Plaintiff
contributing thereto.
23. That Defendants were negligent, careless and reckless in the ownership,
operation, management, maintenance, supervision, use and control of the aforesaid
vehicle and the Defendants were otherwise negligent, careless, reckless and grossly
negligent under the circumstances then and there prevailing.
24. That by reason of the foregoing, Plaintiff Mollie Jace, sustained severe and
permanent personal injuries; and Plaintiff, Mollie Jace, was otherwise damaged.
25. That Plaintiff Mollie Jace, sustained serious injuries as defmed by §5102 (d) of
the Insurance Law of the of the State of New York.
26. That Plaintiff Mollie Jace, sustained serious injuries and economic loss greater
than basic economic loss as defined by §5104 of the Insurance Law of the State of New
York.
27. That Plaintiff Mollie Jace, is not seeking to recover any damages for which
Plaintiff has been reimbursed by no-fault insurance and/or for which no-fault
3
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insurance is obligated to reimburse Plaintiff. Plaintiff is seeking to recover only those
damages not recoverable through no-fault insurance under the facts and circumstances
in this action.
28. That by reason of the foregoing, Plaintiff Mollie Jace, has been damaged in a
sum which exceeds the jurisdictional limits of all lower courts which would otherwise
have jurisdiction.
AS AND FOR A SECOND CAUSE OF ACTION
ON BEHALF OF PLAINTIFF, JENNA JACE
29. Plaintiff, repeats, reiterates and realleges each and every allegation contained in
"1" "20"
paragraphs numbered through the same force and effect as though set forth
herein at length.
30. That as a result of the aforesaid contact, Plaintiff, JENNA JACE, was injured.
31. That the aforesaid occurrence was caused wholly and solely by reason of the
negligence of the Defendants without any fault or negligence on the part of the Plaintiff
contributing thereto.
32. That Defendants were negligent, careless and reckless in the ownership,
operation, management, maintenance, supervision, use and control of the aforesaid
vehicle and the Defendants were otherwise negligent, careless, reckless and grossly
negligent under the circumstances then and there prevailing.
33. That by reason of the foregoing, Plaintiff JENNA JACE, sustained severe and
permanent personal injuries; and Plaintiff, JENNA JACE, was otherwise damaged.
34. That Plaintiff JENNA JACE, sustained serious injuries as defined by §5102 (d) of
the Insurance Law of the of the State of New York.
35. That Plaintiff JENNA JACE, sustained serious injuries and economic loss
greater than basic economic loss as defined by §5104 of the Insurance Law of the State
of New York.
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36. That Plaintiff JENNA JACE, is not seeking to recover any damages for which
Plaintiff has been reimbursed by no-fault insurance and/or for which no-fault
insurance is obligated to reimburse Plaintiff. Plaintiff is seeking to recover only those
damages not recoverable through no-fault insurance under the facts and circumstances
in this action.
37. That by reason of the foregoing, Plaintiff JENNA JACE, has been damaged in a
sum which exceeds the jurisdictional limits of all lower courts which would otherwise
have jurisdiction.
WHEREFORE, Plaintiffs demand judgment against the Defendants herein on all causes
of action, in a sum exceeding the jurisdictional limits of 11 lower courts which would otherwise
have jurisdiction, together with the costs and disburse e ts of this action.
Dated: New York, New York
March 8, 2022
JAY H BAUM
L FICE F J H. TANENBAUM
ttorney for Plaintiffs
14 Wall Street - Suite 5F
ewYork, New York 10005
(212) 42fi765
Our File No. 555-20J-0084
5
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ATTORNEY'S·VERIFICATION
The undersigned, an attomey, adaútted to practice in the Courts of the State of New
York,
That deponent is the
attomey of record for the
as read the plaintiff(s)in the within
foregoingcomplaint action; that deponent
billof and knows the
is true particulars, contents
to deponent's own knowledge, thereof; that the same
except as to the matters
intbnnation and belief, therein stated to be aueged
and that as to those upon
further matters, deponent believes that to be true..
says that the reason this Deponent
verification is made by
plaintiff deponent and not by plaintiff
(s) reside (s) in a county other that in which (s) is that
deponent maintains his offices.
The grounds for deponent's belief as to all matters
investigations not stated upon his
which he has made or has caused knowledge are
to be made
action, and statements conceming the subject
of parties and/or matter of this
witnesses made herein.
The undersigned affirms t%at the
foregoing statements are under the penalties of perjury:
Dated: New York, N.Y.
Sgd
JAY H. TANENBAUM
-
.-.
INDIVIDUAL VERIFICÁTION
STATE OF NEW YORK, COUNTY OF
(p o )SS: . . .
p(
. Being duly swom, deposes and says:
That deponent is Ont. of
has read thg pipintiff (s) in the within
the complaint action; that
foregoing deponent
is true b)ACpatticahas,•ndItaoivs the c tents
eDept as to those matters thereof; that the
therein stated to behged sand
upon ormation and
those matters, deponent believes belief, and as to
it to be true.
. SgdJ
Swom to before me this
day of
EUETTE A. ALVAREZ
NotaryPublic, State of New York
No. 01AL472635t7
Qualified in Richmond C
Commission Expires November30,
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Index No.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
MOLLIE JACE and JENNA JACE,
Plaintiff(s),
-against-
THE HERTZ CORPORATION, HERTZ VEHICLES LLC and SHAREE COOPER,
Defendant(s).
SUMMONS AND VERIFIED COMPLAINT
TO:
LAW OFFICES OF JAY H. TANENBAUM
Attorney for Plaintiff
14 Wall Street - Suite 5F
New York, New York 10005
Tel No.: (212) 422-1765
Fax No.: (212) 425-7492
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitt to practice in the
Courts of New York State, certified that, upon information and belief a able inquiry,
the contentions contained in the annexed document are not frivolo .
Dated: Wednesday, March 09, 2022 Signatu
Print Signors Name LAW OFFICES OF J Y . ENBAUM
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Preview
FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF Kings Date Purchased: ______________________________________________________________________Ç MOLLIE JACE and JENNA JACE, SUMMONS Plaintiffs, Plaintiffs designate Kings County as the place of trial. vs. The basis of venue is: THE HERTZ CORPORATION, HERTZ VEHICLES LLC and Plaintiffs residence SHAREE COOPER, Plaintiffs reside at: Defendants. 371 Van Siclen Avenue Brooklyn, N.Y., 11207 _________________________________________________________ _____________Ç County of Kings To the above named Defendants: 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 t s summons, to serve a notice of appearance on the Plaintiffs attorney(s) within twenty da after the service of this summons, exclusive of the day of service, where service is made by delivery upon you personally within the state, or, within 30 days after completion of service •here service is made in any other manner. In case of your failure to appear or answer, ju ment will be taken against you by default for the relief demanded in the complaint. Dated: New York, New York March 8, 2022 H. TA NBA LAW OFFICES OF JAY H. TANENBAUM Attorney for Plaintiffs 14 Wall Street - Suite 5F New York, New York 10005 (212) 422-1765 Our File No. 555-20J-0084 TO: THE HERTZ CORPORATION 28 Liberty Street New York, New York 10005 HERTZ VEHICLES LLC 28 Liberty Street New York, New York 10005 SHAREE COOPER (Unknown) 1 of 8 FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF Kings ----------------------------------------------------------------------X Index No.: MOLLIE JACE and JENNA JACE, Date Purchased: Plaintiffs, VERIFIED COMPLAINT vs. THE HERTZ CORPORATION, HERTZ VEHICLES LLC and SHAREE COOPER, Defendants. ______________________________________________________________________Ç Plaintiffs, by their attorneys, Law Offices of Jay H. Tanenbaum, complaining of the Defendants, respectfully allege, upon information and belief: AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF THE PLAINTIFF, MOLLIE JACE: 1. At all times herein mentioned, Plaintiffs were, and still are, residents of the County of Kings, City and State of New York. 2. At all times herein mentioned, Defendant THE HERTZ CORPORATION was, and still is, a foreign business corporation duly authorized to do business in the State of New York. 3. At all times herein mentioned, Defendant HERTZ VEHICLES LLC was, and still is, a foreign business corporation duly authorized to do business in the State of New York. 4. At all times herein mentioned, Defendant SHAREE COOPER was, and still is, a resident of the County of Kings, City and State of New York. 5. At all times herein mentioned, Defendant THE HERTZ CORPORATION was the owner of a 2020 Toyota motor vehicle bearing New York State registration number JJJ5010. 6. At all times herein mentioned, Defendant HERTZ VEHICLES LLC was the owner of a 2020 Toyota motor vehicle bearing New York State registration number JJJ5010. 2 of 8 FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022 7. At all times herein mentioned, Defendant SHAREE COOPER operated the aforementioned motor vehicle motor vehicle. 8. At all times herein mentioned, Defendant SHAREE COOPER operated the motor vehicle with the permission of Defendant, THE HERTZ CORPORATION. 9. At all times herein mentioned, Defendant SHAREE COOPER operated the aforementioned motor vehicle with the knowledge of the Defendant, THE HERTZ CORPORATION. 10. At all times herein mentioned, Defendant SHAREE COOPER operated the aforementioned motor vehicle with the consent of the Defendant, THE HERTZ CORPORATION. 11. At all times herein mentioned, Defendant SHAREE COOPER operated the motor vehicle with the permission of Defendant, HERTZ VEHICLES LLC. 12. At all times herein mentioned, Defendant SHAREE COOPER operated the aforementioned motor vehicle with the knowledge of the Defendant, HERTZ VEHICLES LLC. 13. At all times herein mentioned, Defendant SHAREE COOPER operated the aforementioned motor vehicle with the consent of the Defendant, HERTZ VEHICLES LLC. 14. At all times herein mentioned, Plaintiff Mollie Jace, was the operator of a 2018 Mitsubishi motor vehicle bearing New York State registration number KDN5780. 15. At all times herein mentioned, Liberty Avenue and Pennsylvania, in the County of Kings, City and State of New York, were public roadways, streets and/or thoroughfares. 16. That on December 4, 2020, Defendant SHAREE COOPER was operating the vehicle owned by Defendant, THE HERTZ CORPORATION at the aforementioned location. 2 3 of 8 FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022 17. That on December 4, 2020, Defendant SHAREE COOPER was operating the vehicle owned by Defendant, HERTZ VEHICLES LLC at the aforementioned location. 18. That on December 4, 2020, Plaintiff, Mollie Jace was operating her motor vehicle at the aforementioned location. 19. That on December 4, 2020, at the aforementioned location, the motor vehicle owned by Defendant THE HERTZ CORPORATION and operated by Defendant SHAREE COOPER, struck the motor vehicle operated by Plaintiff, Mollie Jace. 20. That on December 4, 2020, at the aforementioned location, the motor vehicle owned by Defendant HERTZ VEHICLES LLC and operated by Defendant SHAREE COOPER, struck the motor vehicle operated by Plaintiff, Mollie Jace. 21. That as a result of the aforesaid contact, Plaintiff, Mollie Jace, was injured. 22. That the aforesaid occurrence was caused wholly and solely by reason of the negligence of the Defendants without any fault or negligence on the part of the Plaintiff contributing thereto. 23. That Defendants were negligent, careless and reckless in the ownership, operation, management, maintenance, supervision, use and control of the aforesaid vehicle and the Defendants were otherwise negligent, careless, reckless and grossly negligent under the circumstances then and there prevailing. 24. That by reason of the foregoing, Plaintiff Mollie Jace, sustained severe and permanent personal injuries; and Plaintiff, Mollie Jace, was otherwise damaged. 25. That Plaintiff Mollie Jace, sustained serious injuries as defmed by §5102 (d) of the Insurance Law of the of the State of New York. 26. That Plaintiff Mollie Jace, sustained serious injuries and economic loss greater than basic economic loss as defined by §5104 of the Insurance Law of the State of New York. 27. That Plaintiff Mollie Jace, is not seeking to recover any damages for which Plaintiff has been reimbursed by no-fault insurance and/or for which no-fault 3 4 of 8 FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022 insurance is obligated to reimburse Plaintiff. Plaintiff is seeking to recover only those damages not recoverable through no-fault insurance under the facts and circumstances in this action. 28. That by reason of the foregoing, Plaintiff Mollie Jace, has been damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF PLAINTIFF, JENNA JACE 29. Plaintiff, repeats, reiterates and realleges each and every allegation contained in "1" "20" paragraphs numbered through the same force and effect as though set forth herein at length. 30. That as a result of the aforesaid contact, Plaintiff, JENNA JACE, was injured. 31. That the aforesaid occurrence was caused wholly and solely by reason of the negligence of the Defendants without any fault or negligence on the part of the Plaintiff contributing thereto. 32. That Defendants were negligent, careless and reckless in the ownership, operation, management, maintenance, supervision, use and control of the aforesaid vehicle and the Defendants were otherwise negligent, careless, reckless and grossly negligent under the circumstances then and there prevailing. 33. That by reason of the foregoing, Plaintiff JENNA JACE, sustained severe and permanent personal injuries; and Plaintiff, JENNA JACE, was otherwise damaged. 34. That Plaintiff JENNA JACE, sustained serious injuries as defined by §5102 (d) of the Insurance Law of the of the State of New York. 35. That Plaintiff JENNA JACE, sustained serious injuries and economic loss greater than basic economic loss as defined by §5104 of the Insurance Law of the State of New York. 5 of 8 FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022 36. That Plaintiff JENNA JACE, is not seeking to recover any damages for which Plaintiff has been reimbursed by no-fault insurance and/or for which no-fault insurance is obligated to reimburse Plaintiff. Plaintiff is seeking to recover only those damages not recoverable through no-fault insurance under the facts and circumstances in this action. 37. That by reason of the foregoing, Plaintiff JENNA JACE, has been damaged in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. WHEREFORE, Plaintiffs demand judgment against the Defendants herein on all causes of action, in a sum exceeding the jurisdictional limits of 11 lower courts which would otherwise have jurisdiction, together with the costs and disburse e ts of this action. Dated: New York, New York March 8, 2022 JAY H BAUM L FICE F J H. TANENBAUM ttorney for Plaintiffs 14 Wall Street - Suite 5F ewYork, New York 10005 (212) 42fi765 Our File No. 555-20J-0084 5 6 of 8 FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022 ATTORNEY'S·VERIFICATION The undersigned, an attomey, adaútted to practice in the Courts of the State of New York, That deponent is the attomey of record for the as read the plaintiff(s)in the within foregoingcomplaint action; that deponent billof and knows the is true particulars, contents to deponent's own knowledge, thereof; that the same except as to the matters intbnnation and belief, therein stated to be aueged and that as to those upon further matters, deponent believes that to be true.. says that the reason this Deponent verification is made by plaintiff deponent and not by plaintiff (s) reside (s) in a county other that in which (s) is that deponent maintains his offices. The grounds for deponent's belief as to all matters investigations not stated upon his which he has made or has caused knowledge are to be made action, and statements conceming the subject of parties and/or matter of this witnesses made herein. The undersigned affirms t%at the foregoing statements are under the penalties of perjury: Dated: New York, N.Y. Sgd JAY H. TANENBAUM - .-. INDIVIDUAL VERIFICÁTION STATE OF NEW YORK, COUNTY OF (p o )SS: . . . p( . Being duly swom, deposes and says: That deponent is Ont. of has read thg pipintiff (s) in the within the complaint action; that foregoing deponent is true b)ACpatticahas,•ndItaoivs the c tents eDept as to those matters thereof; that the therein stated to behged sand upon ormation and those matters, deponent believes belief, and as to it to be true. . SgdJ Swom to before me this day of EUETTE A. ALVAREZ NotaryPublic, State of New York No. 01AL472635t7 Qualified in Richmond C Commission Expires November30, 7 of 8 FILED: KINGS COUNTY CLERK 03/09/2022 09:07 AM INDEX NO. 506904/2022 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/09/2022 Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS MOLLIE JACE and JENNA JACE, Plaintiff(s), -against- THE HERTZ CORPORATION, HERTZ VEHICLES LLC and SHAREE COOPER, Defendant(s). SUMMONS AND VERIFIED COMPLAINT TO: LAW OFFICES OF JAY H. TANENBAUM Attorney for Plaintiff 14 Wall Street - Suite 5F New York, New York 10005 Tel No.: (212) 422-1765 Fax No.: (212) 425-7492 Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitt to practice in the Courts of New York State, certified that, upon information and belief a able inquiry, the contentions contained in the annexed document are not frivolo . Dated: Wednesday, March 09, 2022 Signatu Print Signors Name LAW OFFICES OF J Y . ENBAUM 8 of 8