ARIEL LEVY et al v. CITY OF NEW YORK et al Document 1

Filed March 16, 2022

BackBack to ARIEL LEVY et al v. CITY OF NEW YORK et al, Supreme Court of the State of New York, Kings County Case No. 507804/2022

SUMMONS + COMPLAINT

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Page 1 INDEX NO. 507804/2022
FILED: KINGS COUNTY CLERK 03/16/2022 04:03 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 03/16/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ARIEL LEVY as proposed administrator of the
estate of JACK LEVY, ARIEL LEVY, and
DAWN LEVY individually,
SUMMONS
Plaintiffs,
-againstCITY OF NEW YORK, NEW YORK CITY
DEPARTMENT OF TRANSPORTATION and
NEW YORK CITY DEPARTMENT OF
DESIGN AND CONSTRUCTION, and
TESLA, INC.
Defendants.
To the above-named Defendant(s):
YOU ARE HEREBY SUMMONED to answer the complaint in their action and
to serve a copy of your answer, or, if the complaint is not served with their summons, to serve a
notice of appearance, on the Plaintiff's Attorney(s) within 20 days after the service of the
summons, 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.
The basis of venue is Plaintiff’s residence at the time of the incident. At the time
of the incident, plaintiff resided at 59 Gaylord Drive South Brooklyn, New York 11234.
Dated: New York, New York
March 16, 2022
Yours, etc.,
NAPOLI SHKOLNIK, PLLC
_________________________
By: Joseph P. Napoli, Esq.
Attorneys for Plaintiffs Lexington Avenue – 11th Floor
New York, New York 10017-6502
(212) 397-1000
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To:
Via Secretary of State
CITY OF NEW YORK CHURCH STREET
NEW YORK, NY 10007
NEW YORK CITY DEPARTMENT OF TRANSPORTATION
MUNICIPAL BUILDING CENTRE STREET, 12th FLOOR
NEW YORK, NY 10007
NEW YORK CITY DEPARTMENT OF DESIGN AND CONSTRUCTION-30 THOMSON AVENUE,
LONG ISLAND CITY, NEW YORK, 10001
Via Service of Process
TESLA, INC. TESLA ROAD
AUSTIN, TEXAS 78725
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ARIEL LEVY as proposed administrator of the
estate of JACK LEVY, ARIEL LEVY, and
DAWN LEVY individually,
Plaintiffs,
VERIFIED COMPLAINT
-againstCITY OF NEW YORK, NEW YORK CITY
DEPARTMENT OF TRANSPORTATION and
NEW YORK CITY DEPARTMENT OF
DESIGN AND CONSTRUCTION, and
TESLA. INC.,
Defendants.
PLAINTIFFS, JACK LEVY and ARIEL LEVY, complaining of defendants, upon
information and belief, shows.
That on June 10, 2021, Plaintiffs, JACK LEVY and ARIEL LEVY, were and
are residents of the State of New York, County of Kings..
That the cause of action alleged herein arose in the County of Kings, City
and State of New York.
AS AND FOR A FIRST CAUSE OF ACTION:
NEGLIGENCE AND GROSS NEGLIGENCE
.
That at all times herein mentioned, the defendant, the CITY OF NEW
YORK, was and still is a municipal corporation, duly organized and existing under and by virtue
of the laws of the State of New York..
That at all times herein mentioned, the defendant, NEW YORK CITY
DEPARTMENT OF TRANSPORTATION, was and still is a municipal corporation, duly
organized and existing under and by virtue of the laws of the State of New York.
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.
That at all times herein mentioned, the defendant, NEW YORK CITY
DEPARTMENT OF DESIGN AND CONSTRUCTION, was and still is a municipal corporation,
duly organized and existing under and by virtue of the laws of the State of New York..
That prior hereto on August 25, 2021 within the time prescribed by law, a
sworn Notice of Claim stating, among other things, the time, date and place where the injuries and
damages were sustained, together with Plaintiff's demands for adjustment thereof was duly served
on the plaintiffs’ behalf on the CITY OF NEW YORK and that thereafter said the CITY OF NEW
YORK refused or neglected for more than thirty (30) days and up to the commencement of this
action to make any adjustment or payment thereof, and that thereafter, and within the time provided
by law, this action was commenced..
That prior hereto on August 25, 2021, and within the time prescribed by
law, a sworn Notice of Claim stating, among other things, the time, date and place where the
injuries and damages were sustained, together with Plaintiff's demands for adjustment thereof was
duly served on the plaintiffs’ behalf on NEW YORK CITY DEPARTMENT OF
TRANSPORTATION and that thereafter said NEW YORK CITY DEPARTMENT OF
TRANSPORTATION refused or neglected for more than thirty (30) days and up to the
commencement of this action to make any adjustment or payment thereof, and that thereafter, and
within the time provided by law, this action was commenced..
That prior hereto on August 25, 2021, and within the time prescribed by
law, a sworn Notice of Claim stating, among other things, the time, date and place where the
injuries and damages were sustained, together with Plaintiff's demands for adjustment thereof
was duly served on the plaintiffs’ behalf on NEW YORK CITY DEPARTMENT OF DESIGN
AND CONSTRUCTION and that thereafter said NEW YORK CITY DEPARTMENT OF
DESIGN AND CONSTRUCTION refused or neglected for more than thirty (30) days and up to
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the commencement of this action to make any adjustment or payment thereof, and that thereafter,
and within the time provided by law, this action was commenced..
That on November 3, 2021, a hearing was held by defendants, the CITY OF
NEW YORK pursuant to Section 50H of the General Municipal Law..
That on November 3, 2021, a hearing was held by defendants, NEW YORK
CITY DEPARTMENT OF TRANSPORTATION pursuant to Section 50H of the General
Municipal Law..
That on November 3, 2021, a hearing was held by defendants NEW YORK
CITY DEPARTMENT OF DESIGN AND CONSTRUCTION pursuant to Section 50H of the
General Municipal Law..
That this action is being commenced within one year and ninety days after
accrual of this cause of action or within the time allowed by law..
That on June 10, 2021, and at all times herein mentioned, the public
roadways, more specifically the roadway at the intersection of National Drive and Strickland Avenue
in the County of New York, City and State of New York was owned by the defendant, the CITY
OF NEW YORK..
That on June 10, 2021, and at all times herein mentioned, the public
roadways, more specifically the roadway at the intersection of National Drive and Strickland Avenue
in the County of New York, City and State of New York was owned by the defendant NEW YORK
CITY DEPARTMENT OF TRANSPORTATION..
That on June 10, 2021, and at all times herein mentioned, the public
roadways, more specifically the roadway at the intersection of National Drive and Strickland Avenue
in the County of New York, City and State of New York was owned by the defendant NEW YORK
CITY DEPARTMENT OF DESIGN AND CONSTRUCTION.
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.
That on June 10, 2021, and at all times herein mentioned, it was the duty
of defendant the CITY OF NEW YORK to maintain the public roadways, more specifically the
roadway at the intersection of National Drive and Strickland Avenue, in the County of Kings, State
of New York, in a reasonably safe condition..
That on June 10, 2021, and at all times herein mentioned, it was the duty
of defendant NEW YORK CITY DEPARTMENT OF TRANSPORTATION to maintain the
public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue, in the County of Kings, State of New York, in a reasonably safe condition..
That on June 10, 2021, and at all times herein mentioned, it was the duty
of defendant NEW YORK CITY DEPARTMENT OF DESIGN AND CONSTRUCTION to
maintain the public roadways, more specifically the roadway at the intersection of National Drive
and Strickland Avenue, in a reasonably safe condition..
That on June 10, 2021, and at all times herein mentioned, the aforesaid
public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York was managed by the defendants
the CITY OF NEW YORK, its agents, servants and/or employees..
That on June 10, 2021, and at all times herein mentioned, the aforesaid
public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York was managed by the defendants
NEW YORK CITY DEPARTMENT OF TRANSPORTATION, its agents, servants and/or
employees..
That on June 10, 2021, and at all times herein mentioned, the aforesaid
public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York was managed by the defendants
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NEW YORK CITY DEPARTMENT OF DESIGN AND CONSTRUCTION, its agents, servants
and/or employees..
That on June 10, 2021, and at all times herein mentioned, the aforesaid
public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York, was controlled by the defendants
the CITY OF NEW YORK, its agents, servants and/or employees..
That on June 10, 2021, and at all times herein mentioned, the aforesaid
public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York, was controlled by the defendants
NEW YORK CITY DEPARTMENT OF TRANSPORTATION, its agents, servants and/or
employees..
That on June 10, 2021, and at all times herein mentioned, the aforesaid
public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York, was controlled by the defendants
NEW YORK CITY DEPARTMENT OF DESIGN AND CONSTRUCTION, its agents, servants
and/or employees..
That on June 10, 2021, and at all times herein mentioned, the aforesaid he
aforesaid public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York was repaired by the defendants THE
CITY OF NEW YORK, its agents, servants and/or employees..
That on June 10, 2021, and at all times herein mentioned, the aforesaid he
aforesaid public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York was repaired by the defendants
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NEW YORK CITY DEPARTMENT OF TRANSPORTATION, its agents, servants and/or
employees..
That on June 10, 2021, and at all times herein mentioned, the aforesaid he
aforesaid public roadways, more specifically the roadway at the intersection of National Drive and
Strickland Avenue in the County of Kings, State of New York was repaired by the defendants
NEW YORK CITY DEPARTMENT OF DESIGN AND CONSTRUCTION, its agents, servants
and/or employees..
That on June 10, 2021, Plaintiff JACK LEVY, deceased, was a lawful
passenger was a lawful passenger in a vehicle bearing New York License Plate KLG513, when
said vehicle experienced a deadly collision at the intersection of National Drive and Strickland
Avenue, County of Kings, State of New York..
That the absence of proper signage, painted roadway lines, speed bumps, stop
signs, adequate street lighting and general defective roadway design caused and contributed to the
subject collision by the creation of the defective, dangerous, unreasonably dark condition and
dangerous intersection of National Drive and Strickland Avenue, County of Kings, State of New
York..
The defendants the CITY OF NEW YORK, NEW YORK CITY
DEPARTMENT OF TRANSPORTATION, and NEW YORK CITY DEPARTMENT OF
DESIGN AND CONSTRUCTION created the aforementioned defective, dangerous, and
unreasonable dark conditions in the subject intersection due to the absence of proper signage,
painted roadway lines, speed bumps, stop signs, adequate street lighting and general defective
roadway design.
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.
That the above mentioned occurrence and the results thereof were caused by
the negligence , recklessness, carelessness, wanton and willful acts and/or omissions of the CITY OF
NEW YORK, NEW YORK CITY DEPARTMENT OF TRANSPORTATION and NEW YORK
CITY DEPARTMENT OF DESIGN AND CONSTRUCTION, their agents, servants, employees
and/or licensees in the design, construction, ownership, operation, control, supervision, creation and
maintenance of the aforesaid intersection of
National Drive and Strickland Avenue, and the
appurtenances adjacent and located thereat including but not limited to roadway geometry, signage,
traffic flow, lane usage, lane demarcation, driver visibility, street lighting and traffic and safety and
controls; in carelessly, negligently and recklessly causing, permitting and/or allowing said intersection
of National Drive and Strickland Avenue, to be, become and remain in a dangerous and hazardous
condition, constituting a trap, nuisance and hazard to those on said roadway and specifically the
claimant, JACK LEVY, deceased, in that Respondents, the CITY OF NEW YORK, NEW YORK
CITY DEPARTMENT OF TRANSPORTATION and NEW YORK CITY DEPARTMENT OF
DESIGN AND CONSTRUCTION, carelessly, negligently and with gross negligence and utter
disregard for the safety of persons traversing thereat, failed to design, construct, own, operate, control,
supervise, create and maintain the aforesaid roads, intersections and appurtenances in a reasonably
safe condition thereby creating dangerous and hazardous conditions at the said intersection; in
failing to have and install speed bumps, speed humps, speed cushions, speed tables, gateways, raised
intersections, median barriers, traffic diverters, and/or other traffic control measures to control and
prevent vehicles from traveling at unsafe and/or excessive rates of speed; in having an inadequate,
improper and insufficient roadway and intersection, design and plan; in having an inadequate,
improper and insufficient lighting at said intersection; in failing to review the existing roadway design
and plan in light of its actual operation; in actually creating the aforesaid dangerous and hazardous
conditions complained of herein; in failing and refusing to enact, commence and take the necessary
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and proper remedial measures to correct, remove, repair, reduce and otherwise eliminate the
dangerous and hazardous conditions complained of herein despite having the required permits,
approvals, plans, means and methods to do so; in failing to take the necessary steps to alleviate said
dangerous and hazardous conditions before authorizing the use and access to vehicular traffic; in
failing to erect barricades, or otherwise restrict use of aforesaid area to prevent hazards, traps and
nuisances from endangering the general public and, more particularly, claimant herein; in failing to
warn the general public and, more particularly, claimant herein, of the subject hazards, traps and
nuisances; in permitting and allowing the aforesaid conditions to exist at the aforesaid intersection
and roadways; in failing to undertake proper and/or adequate safety studies and/or surveys; in failing
to heed the recommendations and suggestions for roadway and signage, traffic and control redesigns
and reconfiguration from previously conducted studies and surveys of the vehicular traffic and traffic
patterns in the aforesaid intersection and roadways; and in failing to take the necessary steps, measures
and actions which would have prevented the aforesaid accident which was foreseeable..
That no negligence on the part of the plaintiff JACK LEVY, deceased,
caused or contributed to the occurrence alleged herein..
That on June 10, 2021, and at all times herein mentioned, defendants the
CITY OF NEW YORK, NEW YORK CITY DEPARTMENT OF TRANSPORTATION and the
NEW YORK CITY DEPARTMENT OF DESIGN AND CONSTRUCTION, its agents, servants
and/or employees were negligent in that they breached their duty to keep the aforementioned
sidewalk and the area immediately adjacent thereto in a safe, proper and secure manner, in good
repair and free from obstruction, defect, hazardous and dangerous conditions..
That defendants, the CITY OF NEW YORK, NEW YORK CITY
DEPARTMENT OF TRANSPORTATION, and NEW YORK CITY DEPARTMENT OF
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DESIGN AND CONSTRUCTION, its agents, servants and/or employees had actual and/or
constructive notice of the defect, dangerous and hazardous conditions.
AS AND FOR A SECOND CAUSE OF ACTION:
CONCIOUS PAIN AND SUFFERING.
Plaintiffs and the decedent’s distributees repeats, reiterates and realleges
each and every allegation contained in the paragraphs of this complaint above with the same
force and effect as though more fully set forth at length herein.
.
That by reason of the foregoing, culpable conduct and the negligence of
defendants, the CITY OF NEW YORK, NEW YORK CITY DEPARTMENT OF
TRANSPORTATION, and NEW YORK CITY DEPARTMENT OF DESIGN AND
CONSTRUCTION, the Plaintiff sustained serious, severe, and permanent injuries and ultimately
was caused to expire.
.
That as a result of the aforesaid conduct, Plaintiff was severely injured.
.
That as a result of the aforesaid conduct, Plaintiff was seriously injured.
.
That as a result of the aforesaid conduct, Plaintiff was gravely injured.
.
That as a result of all of the foregoing, Plaintiff was caused to and did suffer
and sustain economic and pecuniary losses..
That by reason of the wrongful, negligent, and unlawful actions and conduct
of the Defendants, as aforesaid, the Plaintiff sustained serious injuries as defined in §5102(d) of
the Insurance Law of the State of New York and has sustained economic loss greater than basic
economic loss as defined in said Insurance Law.
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.
That this action falls within one or more of the exceptions set forth in CPLR
.
That as a result of the foregoing, Plaintiff has been damaged in a sum that
§1602.
exceeds the jurisdictional limits of all the lower courts which would otherwise have jurisdiction.
.
That pursuant to CPLR § 1602(2)(iv), Defendants, are jointly and severally
liable for all of Plaintiff’s damages, including but not limited to Plaintiff’s non-economic losses,
irrespective of the provisions of CPLR § 1601, by reason of the fact Defendant owed the Plaintiff
a non-delegable duty of care.
.
That Plaintiff’s damages, including but not limited to Plaintiff’s non-
economic losses, irrespective of the provisions of CPLR § 1601, by reason of the fact that
answering defendants, the CITY OF NEW YORK, NEW YORK CITY DEPARTMENT OF
TRANSPORTATION, and NEW YORK CITY DEPARTMENT OF DESIGN AND
CONSTRUCTION., are vicariously liable for the negligent acts and omissions of its agents,
servants, and/or employees.
.
That pursuant to CPLR §1602(5), Defendants, are jointly and severally
liable for all of Plaintiff’s damages, including but not limited to Plaintiff’s non-economic losses,
irrespective of the provisions of CPLR §1601, by reason of the fact that Defendants’ wrongful
conduct was intentional.
.
That pursuant to CPLR § 1602(7), Defendants are jointly and severally
liable for all of Plaintiff’s damages, including but not limited to Plaintiff’s non-economic losses,
irrespective of the provisions of CPLR §1601 by reason of the fact that Defendants acted with
reckless disregard for the safety of others.
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.
That pursuant to CPLR §1602(11), Defendants are jointly and severally
liable for all of Plaintiff’s damages, including but not limited to Plaintiff’s non-economic losses,
irrespective of the provisions of CPLR §1601 by reason of the fact that Defendants acted
knowingly or intentionally, and in concert, to cause the acts or failures which are a proximate cause
of Plaintiff’s injuries..
By reason of the wrongful, negligent, and unlawful actions of the
Defendants, as aforesaid, the Plaintiff, JACK LEVY, sustained serious injuries as defined in
§5102(d) of the Insurance Law of the State of New York.
.
By reason of the foregoing, the deceased, JACK LEVY was compelled and
did necessarily require medical aid and attention and did necessarily pay and become liable
therefore, medical expenses.
.
That solely by reason of the foregoing, the decedent, JACK LEVY,
Plaintiffs ARIEL LEVY, and DAWN LEVY have been damaged in a sum which exceeds the
jurisdictional limits of all lower courts which would otherwise have jurisdiction.
AS AND FOR A THIRD CAUSE OF ACTION:
WRONGFUL DEATH.
Plaintiffs and the decedent’s distributees repeats, reiterates and realleges
each and every allegation contained in the paragraphs of this complaint above with the same
force and effect as though more fully set forth at length herein.
.
That by virtue of the wrongful death of decedent, JACK LEVY, his
distributees have been permanently deprived of his services, society, and companionship.
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.
That solely by reason of the foregoing, plaintiff JACK LEVY and the
decedent's distributees were obliged to incur expense and become obligated for medical aid and
attention in an effort to cure decedent JACK LEVY.
.
That by reason of the foregoing, Plaintiffs ARIEL LEVY, DAWN LEVY,
and the decedent's distributees have been severely and permanently damaged and, accordingly, are
entitled to appropriate compensation.
.
That as a result of the foregoing, Plaintiffs ARIEL LEVY, DAWN LEVY and
the decedent's distributees have been damaged in a sum in excess of the jurisdictional limit of all
lower Courts of the State of New York.
AS AND FOR A FOURTH CAUSE OF ACTION
LOSS OF SOCIETY AND SERVICES
.
Plaintiffs and the decedent’s distributees repeats, reiterates and realleges
each and every allegation contained in the paragraphs of this complaint above with the same force
and effect as though more fully set forth at length herein..
That at all times hereinafter mentioned, plaintiffs ARIEL LEVY and
DAWN LEVY were the parents of the decedent, JACK LEVY, and as such were entitled to the
services, society, comfort, and companionship of their son.
.
That as a result of the foregoing occurrence, and resulting serious personal
injuries, plaintiffs ARIEL LEVY and DAWN LEVY have been deprived of the services, society,
comfort, companionship of their son JACK LEVY.
.
That the damages in this action exceed the jurisdiction of the lower courts
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which would otherwise have jurisdiction over the subject matter.
.
That due to the aforesaid, plaintiffs suffered damages in an amount to be
determined by the Court.
AS AND FOR A FIFTH CAUSE OF ACTION
DESIGN DEFECT
(Against Tesla, Inc.).
Tesla was founded in July 2003 and is headquartered in Palo Alto, California. Tesla
claims to use proprietary technology and state-of-the-art manufacturing processes. Tesla designs,
develops, manufactures, and sells electric vehicles and electric vehicle powertrain components.
The company also provides services for developing and selling electric powertrain systems and
components to other automotive manufacturers. It markets and sells its vehicles through Tesla
stores and the Internet..
In 2008, Tesla first entered the vehicle market with the production of the Tesla
Roadster, an all-electric sports car. In 2012, it began selling the Model S, an all-electric luxury
sedan. Following a series of delays, Tesla began selling the Model X, an all-electric luxury
crossover sports utility vehicle, in the fourth quarter of 2015..
In 2021, Tesla started selling the Model Y – a battery electric compact crossover.
.
Tesla’s strategy in selling the Models S and X was to sell expensive sports vehicles
to high-income consumers, promising the power of a sports car but in an eco-friendly, all-electric
package. Tesla’s package of features was meant to distinguish it from other automobile companies
offering electric vehicles that the public perceived as lacking in power and performance. To
capture public interest, Tesla’s early models relied heavily on performance factors such as
acceleration from 0 to 60 mph, which Tesla automobiles could generally perform under 4 seconds,
with a top speed of 155 miles per hour. Since those early days, Tesla has continually pushed the
envelope on quick acceleration, reaching 0-to-60 rates comparable to sports cars.
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.
Even the model Y, which is a less expensive SUV crossover, features a
“performance” edition that is capable of accelerating from 0-to-60 in 3.5 seconds..
The Model Y is described as being designed to “exceed safety standards.”
.
Consistent with Tesla’s representations, it has designed and manufactured other
putative safety features into the Model Y. For example, the Model Y includes a feature called
“Lane Departure Avoidance,” which Tesla explains is used when a driver starts departing from a
lane without his or her turn signal on. In such cases, the automobile checks to see whether a driver’s
hands are on the wheel and, if not, the driver will receive a series of reminders and alerts. In cases
of emergency, the vehicle will even steer the automobile back into the correct driving lane when
it detects that it is drifting out of its lane and a collision may occur. Tesla further advertises
Obstacle Aware Acceleration, which automatically reduces acceleration and can also apply the
brakes when an obstacle is detected in front of your car while driving at low speeds..
Despite all of the purported safety features described above, the Model Y suffers
from one or more dangerous defects causing it to accelerate without a command from the driver
to do so. Whether the SUA Defect is caused by mechanical issues with the accelerator pedal, an
unknown failure in the electronic motor control system, or some other failure in the various
electrical, mechanical, or computer systems in the vehicle, the SUA Defect not only causes the
Model Y to lose control, but it overrides various of the purported “safety” features Tesla has
installed in the Model Y to prevent accidents from occurring, rendering the SUA Defect even more
dangerous than it might be otherwise..
Compounding this issue is that Tesla refuses to share vehicle data with its owners.
Tesla will only issue what it terms a “summary” of the relevant data but will not give Plaintiff—
or any owner for that matter— access to the data he or she generates by driving the vehicle.
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.
Members of the general public report that Sudden Unintended Acceleration
(“SUA”) has been and remains a problem with Tesla vehicles. The most important sources of field
data regarding this issue is the National Highway Traffic Safety Administration’s Consumer
Complaint Database. This publicly available database contains all motor vehicle-related consumer
complaints submitted to NHTSA since January 2000. Consumers submit what is called a “Vehicle
Owner Questionnaire” in which they are asked to provide information that includes, the make,
model, and model year of the vehicle, the approximate incident date, the mileage at which the
incident occurred, whether the incident involved a crash or a fire, whether any persons were injured
or killed in the incident, the speed of the vehicle at the time of the incident, and a description of
the incident along with a description of the vehicle components they believe were involved in the
incident..
The majority of consumer complaints are submitted online at www.safercar.gov
where consumers can input this information directly into the database through their computer.
They can also submit complaints by telephone through the Auto Safety Hotline, through
submitting a paper Vehicle Owner Questionnaire form, and by submitting consumer letters to
NHTSA by mail. This information is then entered into NHTSA’s ARTEMIS database where it can
be searched and reviewed by the general public and vehicle manufacturers alike, by make, model,
model year, and component. this database is promoted by NHTSA as a valuable consumer
information tool. Just in the past three years, dozens of complaints have been submitted to NHTSA
describing Tesla drivers’ experience with uncommanded acceleration.
B. Tesla Withholds Data Generated by the Owner of the Vehicle.
Tesla has evaded its warranty obligations by failing to tell consumers that their
vehicles are not reasonably safe and by representing that the cause of the unsafe SUA condition is
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driver error or negligence. Tesla refuses to repair the unsafe SUA condition and, in fact, denies
that SUA is even a problem on any of its automobiles. Tesla collects a wide range of telematics
data regarding the performance, usage, operation, and condition of each Tesla vehicle. Some of
the data categories regularly captured by Tesla include the “vehicle identification number; speed
information; odometer readings; battery use management information; battery charging history;
electrical system functions; software version information; infotainment system data; safety-related
data and camera images (including information regarding the vehicle’s SRS systems, braking and
acceleration, security, e-brake, and accidents); short video clips of accidents; information
regarding the use and operation of Autopilot, Summon, and other features; and other data to assist
in identifying issues and analyzing the performance of the vehicle.”.
Tesla also collects “data about accidents involving your Tesla vehicle (e.g., air bag
deployment and other recent sensor data); data about remote services (e.g., remote lock/unlock,
start/stop charge, and honk-the-horn commands); a data report to confirm that your vehicle is
online together with information about the current software version and certain telematics data;
vehicle connectivity information; data about any issues that could materially impair operation of
your vehicle; data about any safety-critical issues; and data about each software and firmware
update.”.
But Tesla will not give the data to the owner of the vehicle. As Tesla states in the
owner’s manual, “In addition, and subject to local law, Tesla does not disclose the data recorded
to an owner unless it pertains to a non-warranty repair service and in this case, will disclose only
the data that is related to the repair.”.
At all times herein mentioned, Tesla designed, manufactured, assembled,
distributed, fabricated, constructed, marketed, promoted, advertised, sold, supplied, inspected,
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tested, and provided for use the subject Tesla vehicle and its component parts for use by members
of the general public..
Plaintiff’s use of the Subject Vehicle was at all times foreseeable and foreseen by
Defendants and each of them, as it was used by Plaintiff in the manner intended by Defendants..
The Subject Vehicle was defective in its design in that it failed to perform as safely
as a reasonable consumer would expect when used in an intended or reasonably foreseeable
manner..
The Subject Vehicle is further defective in that the risks of danger inherent in its
design outweigh the benefits, in that the gravity of danger posed by the design was great, the
likelihood that such danger would cause injury was substantial, there were feasible, safer
alternative designs known to Defendants at the time of manufacture, the financial costs of an
improved design was minor and there were likely no adverse consequences to the product, or to
the user, that would result from an alternative design..
Tesla designed, engineered, developed, manufactured, fabricated, assembled,
equipped, tested or failed to test, inspected or failed to inspect, repaired, retrofitted or failed to
retrofit, failed to recall, labeled, advertised, promoted, marketed, supplied, distributed, wholesaled,
and sold the subject vehicle and its component parts and constituents, which was intended by Tesla
to be used for the purpose of use as a passenger vehicle, and other related activities..
The subject vehicle was not reasonably safe as designed and manufactured because,
at the time of its manufacture, the likelihood that the product would cause the claimant's harm or
similar harms, and the seriousness of those harms, outweighed the burden on Tesla to design a
vehicle that would have prevented those harms and the adverse effect that an alternative design
that was practical and feasible would have on the usefulness of the product, but rather, instead
exposed the users of said product, and others, to serious injuries because of the failure of Tesla to
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properly guard and protect the users of the subject vehicle, and others, from the not reasonably
safe design of said product..
The Subject Vehicle manufactured and supplied by Defendants was defective and
unsafe for its intended purpose in that the subject vehicle was prone to unintended acceleration
and general malfunction. Said products did, in fact, cause personal injuries and death as described
herein while being used in a reasonably foreseeable manner, thereby rendering the same defective,
unsafe, and dangerous for use..
The Subject Vehicle manufactured and supplied by Defendants was placed into the
stream of commerce by the Defendants in a defective and unreasonably dangerous condition in
which the foreseeable risks exceeded the benefits associated with the design or formulation..
The Subject Vehicle that the Defendants designed, manufactured, assembled,
tested, distributed and sold was, at the time it left the Defendant’s control, defective and
unreasonably dangerous for its ordinary and expected use because it contained the defective and
unsafe conditions as alleged above..
Further, the Subject Vehicle that Defendants manufactured, designed, assembled,
inspected, tested, distributed and sold was delivered to the Plaintiff without any change in its
defective condition. Said products were intended to reach the ultimate consumer in the same
condition as it left Defendants..
Plaintiff did not know of the substantial danger of using the Subject Vehicle. Said
dangers were not readily recognizable by users, including Plaintiff. Defendants further failed to
warn and/or adequately warn of the risks to which Plaintiff and other similarly situated were
exposed or provide adequate use instructions.
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.
Tesla knew or should have known that the Subject Vehicle was defectively
designed and/or manufactured and was therefore prone to failure under normal driving conditions,
potentially causing injuries or death..
The aforementioned negligent acts and omissions of Defendants were the direct and
proximate cause of Plaintiff’s damages..
That solely by reason of the foregoing, plaintiff JACK LEVY and the decedent's
distributees were obliged to incur expense and become obligated for medical aid and attention in an
effort to cure decedent JACK LEVY..
That by reason of the foregoing, Plaintiffs ARIEL LEVY, DAWN LEVY, and the
decedent's distributees have been severely and permanently damaged and, accordingly, are entitled to
appropriate compensation..
That as a result of the foregoing, Plaintiffs ARIEL LEVY, DAWN LEVY and the
decedent's distributees have been damaged in a sum in excess of the jurisdictional limit of all lower
Courts of the State of New York.
SIXTH CAUSE OF ACTION
FAILURE TO WARN
(Against Tesla, Inc.).
Plaintiff hereby incorporates by reference all previous paragraphs of this Complaint
as if fully set forth herein and further alleges as to Defendants, and each of them, as follows:.
Defendants, and each of them, knew that the subject vehicle, and its component
parts, would be purchased and used without inspection for defects in the design of the vehicle..
The subject vehicle or the component parts were defective when it left the control
of each of these Defendants..
At the time of the subject vehicle’s design, manufacture, and sale, and continuing
up to the time of Plaintiff’s injuries and death, Defendants knew or should have known of the
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substantial dangers involved in the reasonably foreseeable use of these vehicles, whose defective
design, manufacturing, and lack of sufficient warnings caused them to have an unreasonably
dangerous propensity to suffer from brake system or brake rotor failures and thereby cause injuries
or death..
Specifically, the Defendants offered no warning of the vehicle’s brake system’s
increased risk of failure or of the incapacity of B-Pillar’s carbon fiber design to withstand
foreseeable impact forces..
Defendants knew that these substantial dangers are not readily recognizable to an
ordinary consumer and that consumers would purchase and use these products without inspection..
At all relevant times, Defendants failed to provide adequate warnings, instructions,
guidelines or admonitions to members of the consuming public, including Plaintiff, of the defects,
which Defendants knew, or in the exercise of reasonable care should have known, to have existed
in the subject vehicle, and its component parts..
At the time of Plaintiff’s injuries, the subject vehicle was being used in the manner
intended by Defendants, and in a manner that was reasonably foreseeable by Defendants as
involving substantial danger that was not readily apparent to its users..
Plaintiff’s damages were the legal and proximate result of Defendants’ failure to
provide adequate warnings. Defendants owed Plaintiff a duty in designing, manufacturing,
warning about, and distributing the subject vehicle..
That solely by reason of the foregoing, plaintiff JACK LEVY and the decedent's
distributees were obliged to incur expense and become obligated for medical aid and attention in an
effort to cure decedent JACK LEVY.
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.
That by reason of the foregoing, Plaintiffs ARIEL LEVY, DAWN LEVY, and the
decedent's distributees have been severely and permanently damaged and, accordingly, are entitled to
appropriate compensation..
That as a result of the foregoing, Plaintiffs ARIEL LEVY, DAWN LEVY and the
decedent's distributees have been damaged in a sum in excess of the jurisdictional limit of all lower
Courts of the State of New York.
WHEREFORE, Plaintiff prays judgment against Defendants as hereinafter set forth.
SEVENTH CAUSE OF ACTION
MANUFACTURING DEFECT
(Against Tesla, Inc.).
Plaintiff hereby incorporates by reference all previous paragraphs of this
Complaint as if fully set forth herein and further alleges as to the Tesla Defendant, and each of
them, as follows:.
At all times herein mentioned, the Subject Vehicle was used in the manner
expected and intended by the Tesla Defendant..
The Subject Vehicle was defective at the time of its manufacture, development,
production, testing, inspection, endorsement, sale, and distribution, and at the time they left the
possession of the Defendants, in that, and not by way of limitation, the products differed from the
Defendants’ intended result and intended design and specifications, and from other ostensibly
identical units of the same product line..
Tesla Defendant, and each of them, knew or should have known of the defective
nature of the Subject Vehicle, including among other things, that the Brake Rotors were prone to
detachment, breakage, separation, disintegration, and general malfunction and created an
unreasonably high risk while in use, and would foreseeably result in injury or death to the public,
purchasers, and/or consumers.
of 30
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.
The Tesla Defendant knew or should have known of the defective nature of the
Subject Vehicle, including among other things, that the subject Model Y was prone to sudden
unintended acceleration, and created an unreasonably high risk while in use, and would
foreseeably result in injury or death to the public, purchasers, and/or consumers..
Specifically, the Tesla Defendant failed to:
a. Manufacture the braking/acceleration system with software that would not cause
unintended acceleration;
b. Manufacture the subject vehicle with a braking system that would not fail during
foreseeable use;
c. Utilize an appropriate quality assurance process to ensure that the subject vehicle
was equipped with an appropriate and functional braking system;
d. Utilize an appropriate quality assurance process to ensure that the subject vehicle
was equipped with an appropriate and functional acceleration system;.
That solely by reason of the foregoing, plaintiff JACK LEVY and the decedent's
distributees were obliged to incur expense and become obligated for medical aid and attention in an
effort to cure decedent JACK LEVY..
That by reason of the foregoing, Plaintiffs ARIEL LEVY, DAWN LEVY, and the
decedent's distributees have been severely and permanently damaged and, accordingly, are entitled
to appropriate compensation..
That as a result of the foregoing, Plaintiffs ARIEL LEVY, DAWN LEVY and the
decedent's distributees have been damaged in a sum in excess of the jurisdictional limit of all lower
Courts of the State of New York.
WHEREFORE, Plaintiff prays for judgment against Defendants as hereinafter set forth.
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ELEVENTH CAUSE OF ACTION
BREACH OF IMPLIED WARRANTY
(Against Tesla, Inc.). Plaintiff hereby incorporates by reference all previous paragraphs of this
Complaint as if fully set forth herein and further alleges as to Defendants, and each of them, as
follows:.
The Tesla Defendant placed the Subject Vehicle into the stream of commerce for
sale and recommended its use to consumers without adequately warning consumers and the
public, including Plaintiff, of the risks associated with the use of the Subject Vehicle..
Tesla had a duty to exercise reasonable care in the research, development, design,
testing, manufacture, inspection, labeling, distribution, marketing, promotion, sale, and release of
the Subject Vehicle, including the duty to:
a. Ensure that an appropriate quality assurance process to ensure that the subject
vehicle was equipped with an appropriate and functional braking system;
b. Ensure an appropriate quality assurance process to ensure that the subject vehicle
was equipped with an appropriate and functional acceleration system;.
The Plaintiff justifiably and detrimentally relied on the warranties and
representations of Defendants in the purchase and use of the Subject Vehicle..
Tesla was under a duty to disclose the defective and unsafe nature of the Subject
Vehicle to consumers and users, such as Plaintiff..
Tesla had sole access to material facts concerning the defects, and Defendants
knew that consumers and users, such as Plaintiff, could not have reasonably discovered such
defects..
By the conduct alleged, Tesla, its agents and employees, warranted to Plaintiff that
the products were merchantable and fit for the purpose intended.
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RECEIVED NYSCEF: 03/16/2022
.
This warranty was breached because the Subject Vehicle was not safe and effective
as Tesla had represented and Plaintiff suffered death as a result..
As a direct and proximate, and legal result of Tesla’s negligence, carelessness,
recklessness, wantonness, and other wrongdoing, Plaintiff suffered injuries as described above.
WHEREFORE, Plaintiff prays for judgment against Defendants as hereinafter set forth.
TWELVTH CAUSE OF ACTION
BREACH OF EXPRESS WARRANTY
(Against Tesla, Inc.).
Plaintiff hereby incorporates by reference all previous paragraphs of this
Complaint as if fully set forth herein and further alleges as to Defendants, and each of them, as
follows:.
The aforementioned manufacturing, designing, distributing, testing, constructing,
recommending, merchandizing, advertising, promoting, supplying and selling of the Subject
Vehicle were expressly warranted to be safe for use by Plaintiff and other members of the general
public..
At the time of the making of the express warranties, Defendants had knowledge of
the purpose for which Defendants’ Subject Vehicle was to be used and warranted the same to be
in all respects, fit, safe, and effective and proper for such purpose..
Specifically, it was warranted that the Model Y Vehicle was capable of protecting
passengers, as follows::
a.
“Autopilot's advanced safety and convenience features are designed to
assist you with the most burdensome parts of driving.”
b.
“360°Rear, side and forward-facing cameras provide maximum visibility”;
“250m Powerful visual processing at up to 250 meters of range,” and “12 Ultrasonic
sensors” to “Detect Nearby Cars, Prevent Collisions and assist with parking.”
of 30
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.
Plaintiff reasonably relied upon the skill and judgment of Tesla, and upon said
express warranty above, in using the Subject Vehicle. The warranty and representations were
untrue in that the product was unsafe and, therefore, unsuitable for the use for which it was
intended. The Subject Vehicle could and did thereby cause Plaintiff to suffer the herein described
injuries, damages, and death..
As a direct and proximate, and legal result of Tesla’s negligence, carelessness,
recklessness, wantonness, and other wrongdoing, Plaintiff suffered injuries as described above.
WHEREFORE, Plaintiff prays for judgment against Defendants as hereinafter set forth.
Dated: New York, New York
March 16, 2022
Yours, etc.,
NAPOLI SHKOLNIK, PLLC
_________________________
By: Joseph P. Napoli, Esq.
Attorneys for Plaintiffs Lexington Avenue – 11th Floor
New York, New York 10017-6502
(212) 397-1000
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To:
Via Secretary of State
CITY OF NEW YORK CHURCH STREET
NEW YORK, NY 10007
NEW YORK CITY DEPARTMENT OF TRANSPORTATION
MUNICIPAL BUILDING CENTRE STREET, 12th FLOOR
NEW YORK, NY 10007
NEW YORK CITY DEPARTMENT OF DESIGN AND CONSTRUCTION-30 THOMSON AVENUE,
LONG ISLAND CITY, NEW YORK, 10001
Via Service of Process
TESLA, INC. TESLA ROAD
AUSTIN, TEXAS 78725
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Page 29 INDEX NO. 507804/2022
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ARIEL LEVY as proposed administrator of the
estate of JACK LEVY, ARIEL LEVY, and
DAWN LEVY individually
Index No.:
Plaintiffs,
-against-
VERIFICATION
CITY OF NEW YORK, NEW YORK CITY
DEPARTMENT OF TRANSPORTATION and
NEW YORK CITY DEPARTMENT OF
DESIGN AND CONSTRUCTION, and
TESLA, Inc.
Defendants.
STATE OF NEW YORK }
COUNTY OF NEW YORK } ss:
JOSEPH P. NAPOLI, ESQ., an attorney admitted to practice in the Courts of New
York State, states:.
Affirmant is a senior partner of the law firm of NAPOLI SHKOLNIK, PLLC,
attorneys of record for the plaintiff in the within action. Affirmant has read the foregoing
SUMMONS & COMPLAINT and knows the contents thereof; the same is true to affirmant's own
knowledge, except as to the matters therein stated to be alleged on information and belief, and that
as to those matters, affirmant believes it to be true..
This verification is made by affirmant and not by plaintiff, for the reason
that plaintiff’s residence is not in the county where affirmant maintains his office..
The ground of affirmant's belief as to all matters not stated upon affirmant's
knowledge are as follows: information furnished by plaintiff and counsel's investigation. The
undersigned affirms that the foregoing statements are true, under the penalties of perjury.
Dated: New York, New York
March 16, 2022
_________________________
By: Joseph P. Napoli, Esq.
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NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 03/16/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ARIEL LEVY as proposed administrator of the estate of JACK LEVY, ARIEL LEVY, and
DAWN LEVY individually,
Plaintiffs,
-againstCITY OF NEW YORK, NEW YORK CITY DEPARTMENT OF TRANSPORTATION and
NEW YORK CITY DEPARTMENT OF DESIGN AND CONSTRUCTION, and TESLA,
INC.,
Defendants.
SUMMONS & COMPLAINT
NAPOLI SHKOLNIK, PLLC
Attorneys for Plaintiff(s) Lexington Avenue – 11th Floor
New York, New York 10017-6502
(212) 397-1000
CERTIFICATION PURSUANT TO 22 N.Y.C.R.R. §130-1.1a
JOSEPH P. NAPOLI, ESQ., hereby certifies that, pursuant to 22 N.Y.C.R.R. §130-1.1a, the
foregoing is not frivolous as nor frivolously presented.
_______________________
Dated: New York, New York
March 16, 2022
To
Attorney(s) for Plaintiff
Joseph P. Napoli, Esq.
Service of a copy of the within
Dated:
Attorney(s) for Plaintiff
is hereby admitted.
□ Please take notice that the within is a (certified) true copy of a
duly entered in the Office of the Clerk of the within named Court on
□ Please take Please take notice that an Order of
which the within is a true copy will be presented for settlement to the Hon.
one of the Judges of the within named Court, at
on
at
:
□ a.m./ □ p.m.
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