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Jong M. Lee v. Sameh T. Ahmed

Docket 512161/2023, New York State, Kings County, Supreme Court (Apr. 25, 2023)
Case TypeTorts - Motor Vehicle
TagsTort, Civil, Vehicle
Plaintiff - Petitioner Jong M. Lee
Defendant - Respondent Sameh T. Ahmed
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COMPLAINT

Document Jong M. Lee v. Sameh T. Ahmed, 512161/2023, 2 (N.Y. Sup. Ct., Kings County Apr. 25, 2023)
was severely injured and damaged, rendered sick, sore, lame, and disabled, sustained severe nervous shock and mental anguish, great physical pain and emotional upset, some of which injuries are permanent in nature and duration, and Plaintiff will be permanently caused to suffer pain, inconvenience, and other effects of such injuries; Plaintiff incurred in the past and in the future will necessarily incur further hospital and/or medical expenses in an effort to be cured of said injuries; and Plaintiff has suffered and/or in the future will necessarily suffer additional loss of time and earnings from employment; and Plaintiff will be unable to pursue the usual duties with the same degree of efficiency as prior to this accident, all to Plaintiff s great damage.
That as a result of the foregoing, this Plaintiff suffered a serious injury as defined by §5102(d) of the Insurance Law of the State of New York.
That reason of Plaintiff JONG M. LEE has been damaged in an amount by the foregoing, which exceeds the jurisdictional limitations of any and all lower courts.
was caused to sustain great pain and suffering from the onset of this accident until the present.
upon information and belief, based upon review of the records maintained in the office of our law firm.
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STATEMENT OF AUTHORIZATION FOR ELECTRONIC FILING

Document Jong M. Lee v. Sameh T. Ahmed, 512161/2023, 4 (N.Y. Sup. Ct., Kings County May. 2, 2023)
documents through ("the filing ( ye, and at my direction on my behalf the New York State Courts Electronic Uniform Rules for agent") has registered ).
Further as a filing authorize I hereby in any e-filed matter in which as provided the Trial Courts.
This authorization extends in which any matter I may authorize to any matter agent the filing in which I have previously to record my consent consented to e-filing in the NYSCEF system.
thorization ljyeryd4o r pres regarding this filing Resource Center.
thef.-Filing agent shall continue until I revoke it in writing on a gna t /e 7 enrd) Laats|æ Print Name TÁg Lamol&W hrm!Department Giu Dated SS 8% m -aM M
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document Jong M. Lee v. Sameh T. Ahmed, 512161/2023, 3 (N.Y. Sup. Ct., Kings County May. 2, 2023)
as the CO-TENANT Said premises of the is Deponent further states that he describes the person actually served as follows: Sex
of same in a postpaid wrapper a true copy/copies Deponent enclosed last known at the defendant's/respondenes residence properly addressed to the defendant/respondent at
under exclusive in a post office or official said wrapper and deposited the United States of care and custody depository FIRST CLASS MAIL in an envelope marked Postal Service within New York State on May 2, 2023 by REGULAR
and not envelope or otherwise by return address thereof, indicating the party to be served.
that the The Summons Served had endorsed thereon the Index number and date of filing.
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SUMMONS

Document Jong M. Lee v. Sameh T. Ahmed, 512161/2023, 1 (N.Y. Sup. Ct., Kings County Apr. 25, 2023)
basis The occurrence of venue: Place of You are your answer, the Plaintiff's where of judgment service, completion answer, summoned to serve complaint the a copy and to answer hereby on a notice of appearance this with served if the complaint is not summons, or, of the day of of the service exclusive this after attorneys within days summons, twenty or, within after you within 30 days the upon service is made state, personally by delivery in any other manner.
the relief against will for by default demanded in the be taken you in this action, to serve of Dated: New York Brooklyn, April 25, 2023 Yours, etc., Esq. Aleksandr Vakarey,
was and still is a domestic limited liability company duly organized and existing under and by virtue of the laws of the State of New York.
was and is a business entity duly organized and existing pursuant to the laws of the State of New York.
She has been compelled to undergo medical aid, treatment and attention and expand money and incur obligations physicians' for services, medical and hospital expenses for the care and treatment of her injuries; and upon information and belief, she will be compelled to expend additional sums of money and incur further obligations in the future for additional physicians' medical hospital expenses for services, and the further care and treatment of her injuries.
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