Plaintiff, by his attorneys, AJLOUNYINJURY LAW, complaining alleges, upon information and belief, as follows: above named, respectfully of the defendant
That all times hereinafter CORP., maintained a principal place of business mentioned, Defendant, MARIONCONSTRUCTION in the City, County and State of NewYork.
That upon information and belief, at all times herein mentioned, the Defendant had or should have had actual and constructive notice of said dangerous condition.
That as a result of said incident, and the Defendants' negligence, carelessness, and recklessness as described herein, Plaintiff sustained serious, protracted and permanent personal injuries, was rendered sick, sore, lame and disabled; was confined to bed and home; has been and will be prevented from attending his usual duties, did seek and still seeks medical attention and aid, has incurred and will incur great expense for medical care and attention, and sustained other injuries and damages.
WHEREFORE,Plaintiff respectfully demands judgment in an amount that exceeds the jurisdiction of the lower courts, together with costs and disbursements of this action.