Page 1 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
Supreme
Court
County
the
of
State
New
of
York
Kings
of
---------------------------------------------------------X
of
Date
Plaintiff
Plaintiff,
designates
as
Country
trial.
Filing:
NO.:
INDEX
HANON,
ISAC
-against.
TESLA,
place
of
venue
of
residence:
East
8th
NY
INC.,
the
basis
The
plaintiff's
Kings
Street,
is
Brooklyn,
Summons
Defendant.
______________________________________________Ç
To
the
above-named
Defendant(s):
You
and
action
this
to
are
a copy
serve
to
summons,
summoned
hereby
of
your
a Notice
serve
of
days
after
the
service
of
days
after
the
service
is complete
you
within
judgment
the
State
will
be
New
of
and
you
answer
if the
the
of
exclusive
in
summons
by
of
case
is not
Plaintiffs
the
is not
your
default
complaint
the
complaint
on
Appearance
if this
York);
against
taken
or
answer,
summons,
this
to
for
the
with
(or
or
demanded
relief
within
delivered
appear
to
this
within
service
personally
failure
served
Attorneys
of
day
in
to
answer,
in
the
complaint.
Dated:
New
Hempstead,
September
D/A:
York
21,
Yours,
etc.,
LAW
OFFICES
06/08/
ZEMSKY
for
Attorneys
& P.O.
Office
Front
Street,
Hempstead,
(516)
DEFENDANT'S
TESLA,
INC.,
and
OF
& SALOMON,
P.C.
Plaintiff(s)
Address
Suite
New
York
485-
ADDRESS:
S.O.S
Van
Brunt
pursuant
St,
to
Brooklyn,
BCL.
1 of
NY
and
1 Tesla
Road,
Austin,
TexasPage 2 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
Supreme
Court
State
New
of
York
Kings
of
County
the
of
-------------------------------------------------------------------X
Date
HANON,
ISAC
of
INDEX
Plaintiff
Plaintiff,
designates
as
Country
trial.
Filing:
NO.:
The
-against-
TESLA,
the
basis
plaintiff's
Kings
of
place
venue
of
residence:
East
8th
NY
Street,
is
Brooklyn,
INC.,
Defendant.
_____________________________________Ç
To
the
above-named
Defendant(s):
You
and
action
this
to
are
a copy
serve
summons,
to
summoned
hereby
of
your
a Notice
serve
of
days
after
the
service
of
days
after
the
service
is complete
you
within
judgment
the
State
will
be
this
New
of
taken
Appearance
against
you
in
the
by
of
summons
of
case
the
your
is not
Plaintiff's
the
is not
default
complaint
complaint
on
exclusive
if this
and
answer
if the
or
answer,
summons,
York);
to
for
within
delivered
or
demanded
relief
the
with
(or
appear
to
this
within
service
personally
failure
served
Attorneys
of
day
in
to
answer,
in
the
complaint.
Dated:
New
Hempstead,
September
D/A:
York
21,
Yours,
etc.,
LAW
OFFICES
06/08/
ZEMSKY
for
Attorneys
& P.O.
Office
Front
Street,
Hempstead,
(516)
DEFENDANT'S
TESLA,
INC.,
and
OF
& SALOMON,
P.C.
Plaintiff(s)
Address
Suite
New
York
485-
ADDRESS:
S.O.S
Van
Brunt
pursuant
St,
to
Brooklyn,
BCL.
2 of
NY
and
1 Tesla
Road,
Austin,
TexasPage 3 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
SUPREME
COURT
COUNTY
OF
OF THE
STATE
NEW YORK
OF
KINGS
--------------------------------------------------X
ISAC
Index
#:
HANON,
Plaintiff,
-against-
COMPLAINT
TESLA,
INC.,
Defendant.
_______________________________________Ç
Plaintiff,
his
by
of
complaining
the
LAW
attorneys,
defendant(s),
ON
OF ACTION
resident
of
the
County
SECOND:
That,
mentioned,
Kings,
at
That,
all
defendant,
State
of
mentioned,
to
upon
mentioned,
to
FIFTH:
upon
That,
transact
That,
New
P.C.,
follows:
HANON
ISAC
was
plaintiff
and
still
and
belief
principal
in
the
State
place
TESLA,
information
and
of
the
State
and
3 of
New
belief
was
INC.,
in
belief
and
information
business
upon
was
INC.,
is
a
York.
and
and
information
business
defendant,
authorized
INC.,
TESLA,
transact
FOURTH:
of
SALOMON,
at
all
times
business
of
is the
hereinafter
County
York.
defendant,
authorized
PLAINTIFF
mentioned,
information
TESLA,
New
THIRD:That,
State
as
&
CAUSE
FIRST
OF
BEHALF
Kings,
upon
A
hereinafter
times
of
FOR
ZEMSKY
alleges
respectfully
AS AND
FIRST:
OF
OFFICES
and
of
New
belief
and
still
at
is
all
times
domestic
a
hereinafter
corporation
York.
and
still
at
is
a
all
times
foreign
hereinafter
corporation
York.
and
at
all
times
hereinafter
ofPage 4 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
mentioned,
the
defendant,
transaction
of
SIXTH:
of
mentioned,
mentioned,
State
New
of
of
New
mentioned,
and
York
is a
State
of
is a
INC.,
and
maintains
and
belief
all
times
hereinafter
a
place
for
the
at
all
times
a
maintaining
hereinafter
place
for
the
York.
and
TESLA,
at
maintaining
partnership
New
information
for
place
York.
and
INC.,
and
company
New
a
maintaining
York.
belief
is a
of
State
the
proprietorship
New
information
upon
That,
NINTH:
business
a
and
belief
at
all
organization
place
for
the
times
hereinafter
business
transacting
transaction
of
business
in
York.
upon
That,
defendant,
and
information
TESLA,
INC.,
and
belief
at
transacted
actually
all
times
hereinafter
in
business
the
State
of
York.
TENTH:
mentioned,
Van
in
a
of
INC.,
TESLA,
defendant,
State
the
upon
business
EIGHTH:
New
in
That,
of
State
TESLA,
defendant,
transaction
the
information
business
SEVENTH:
the
upon
was
INC.,
in
defendant,
transaction
the
business
That,
mentioned,
in
TESLA,
defendant,
Brunt
Street,
ELEVENTH:
mentioned,
dealership
upon
That,
TESLA,
County
That,
defendant,
facility
located
and
information
of
Kings,
upon
was
INC.,
at
INC.,
Van
New
of
and
information
TESLA,
owner
the
State
was
Brunt
York.
4 of
and
belief
of
at
the
all
times
premises
hereinafter
at
located
York.
and
belief
the
Street,
owner
County
at
of
all
a
of
times
certain
Kings,
hereinafter
automotive
State
of
NewPage 5 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
TWELFTH:
mentioned,
defendant,
operated
a certain
of
County
mentioned,
mentioned,
maintained
a
Street,
of
County
FIFTEENTH:
mentioned,
defendant,
controlled
a
Street,
of
mentioned,
managed
a
of
SEVENTEENTH:
servants
and/or
proper
of
to
employees,
condition
EIGHTEENTH:That,
for
or
Van
at
all
times
Brunt
Street,
New
the
at
servants
premises.
all
times
and/or
located
hereinafter
employees,
at
and
all
at
servants
agents,
times
and/or
located
facility
and
its
Van
Brunt
hereinafter
employees,
at
Van
Brunt
and
belief
at
all
and/or
servants
agents,
located
facility
times
hereinafter
employees,
Van
INC.,
its
at
Brunt
York.
duty
prepare
of
the
the
5 of
the
defendant,
of
delivery
7th
day
TESLA,
Tesla
automobiles
agents,
in
a
automobiles.
Tesla
acquiring
about
aforesaid
hereinafter
York.
INC,
persons
on
hereinafter
employees
at
and
belief
belief
dealership
it was
That,
its
information
State
the
facility
and
New
automotive
Kings,
times
York.
INC.,
TESLA,
certain
County
of
upon
defendant,
of
agents,
dealership
State
That,
its
information
automotive
Kings,
SIXTEENTH:
New
TESLA,
certain
County
of
upon
lessee
dealership
State
That,
a
and
belief
and
INC.,
automotive
Kings,
and
information
TESLA,
certain
all
and/or
located
facility
was
INC.,
upon
defendant,
at
servants
agents,
information
TESLA,
That,
and
belief
York.
upon
defendant,
its
INC.,
dealership
New
of
That,
FOURTEENTH:
and
TESLA,
State
Kings,
and
information
automotive
THIRTEENTH:
Street,
upon
That,
of
June,
2022,
plaintiff
purchased
safePage 6 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
a
Model
INC.
TESLA,
State
Y
from
New
of
Tesla
their
A.M.
was
cut
the
for
was
or
control
of
and
dangerous
the
serious
Brunt
Street,
June,
the
defendant,
of
County
negligence
of
above
the
Kings,
the
of
left
finger
ring
installed
defendant
in
and
the
approximately
his
improperly
dealership
condition
defective
at
when
injuries
been
had
that
of
day
sustain
trim
to
8th
the
to
door
due
and
about
caused
driver's
delivery
maintenance
on
That,
plaintiff
by
otherwise
Van
from
York.
the
prepared
at
located
dealership
NINETEENTH:
8:
7SAYGDEF1NF
VIN#
bearing
its
and/or
operation,
and
premises,
and
then
premises
the
there
existing.
TWENTIETH:
condition
itself
of
said
had
existed
for
so
in
to
have
same
for
such
condition
of
occurrence
the
accident
TWENTY-FIRST:
condition
as
its
servants
agents,
agents,
Model
defendant
dangerous
Tesla
made
the
had
defendant
created
disregarding
employees,
VIN#
time
said
it could
hazardous
have
safe
premise
such
knowledge
of
informed
before
the
through
condition
on
its
said
the
aforesaid
6 of
and
allowed
caused,
hazardous
the
duty,
7SAYGDEF1NF
a
creating
That,
of
period
the
the
hazardous
the
actions
of
employees.
That,
bearing
a
long
of
alleged.
actually
and/or
condition
TWENTY-THIRD:
said
and/or
servants,
Y
herein
That,
TWENTY-SECOND:
its
defendant
time
knowledge
had
That,
to
condition
date,
to
at
the
be
permitted
and
those
through
defendant,
to
lawfully
aforesaid
the
remain
in
a
thereat.
location,
thisPage 7 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
was
plaintiff
caused
aforementioned
were
solely
without
any
TWENTY-FIFTH:
servants
caused
and/or
of
the
to
its
to
the
the
part
injuries
of
the
by
this
sustained
as
defendant,
of
this
plaintiff
hereinbefore
in
to
any
and/or
employees
to
proper
this
further
manner
to
in
that
and
TWENTY-SIXTH:
otherwise
precautions
within
the
in
and
the
to
avoid
jurisdictional
7 of
limits
any
notice
exercise
through
their
said
this
the
in
Tesla
of
its
automobile
or
due
exercise
careless
of
Tesla
the
agents,
delivery
the
had
plaintiff,
foregoing
the
which
the
their
warning
due
that
the
and
care
existed
for
an
servants
agents,
and
failing
and
care
in
prevailing;
to
failing
defendant,
negligent
of
then
condition
the
to
of
maintain
in
give
failed
they
negligent
and
reason
to
conditions
dangerous
suitable
By
sum
and
time;
were
that
to
inspect
failed
they
in
through
condition
properly
sustained
reason
by
defendant
neglecting
safe
neglecting
careless
of
and
reasonably
plaintiff;
the
and
the
a
the
injuries
and
through
of
failing
circumstances
length
unreasonable
in
and
remedy
in
negligence
in
and
occurrence
wholly
apprehended;
the
was
caution
be
to
under
defendant
and
and
failing
delivery
danger
caution
aforesaid
solely
premises
in
automobiles;
damaged
on
employees;
and
dealership
take
negligence
the
recklessness
carelessness,
the
negligence
That,
were
therefrom
of
and
accident
the
by
reason
by
thereto.
contributing
prior
said
the
That,
injured
severely
thereat.
existing
caused
and
alleged,
and
seriously
conditions
TWENTY-FOURTH:
plaintiff
be
to
omitting
occurrence.
ISAC
Court
HANON,
and
for
has
an
been
amountPage 8 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
in
RECEIVED NYSCEF: 10/14/
excess
of
the
jurisdictional
within
the
jurisdictional
costs
Court
Dated:
and
jurisdictional
limits
of
disbursements
deems
just
and
Hempstead,
September
limits
the
of
lower
of
this
of
Courts
lower
the
demands
plaintiff
WHEREFORE,
sum
limits
judgment
this
and
the
State
and
action
the
against
Court
of
of
Courts
for
such
the
an
of
New
in
York
and
other
21,
further
York
Yours,
LAW
etc.,
S OF
OFFIC
ZEMSKY
N
& SAL
.
.
By:
Mich
el
for
Attorneys
L. Salbfhc>n,
Front
Street,
Hempstead,
(516)
8 of
485-
Esq.
Plaintiff
Suite
New
York
excess
together
proper.
New
York.
defendant(s)
amount
for
New
of
State
in
the
of
the
with
relief
as
the
thisPage 9 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
Supreme
Court
of
County
of
the
State
of
New
York
Kings
---------------------------------------------X
ISAC
Index
No.:
HANON,
CERTIFICATION
Plaintiff,
PURSUANT
-against-
TESLA,
TO SECTION
130-1.1-A
INC.,
Defendant.
_________________________________Ç
SI R S :
PLEASE
pursuant
SUMMONS
Dated:
to
TAKE
section
AND
Hempstead,
September
NOTICE,
that
130-1.1-a
of
the
the
papers
accompanying
Rules
of
the
Chief
are
Administrator
(
COMPLAINT
New
21,
York
Yours,
etc.,
LAW
OFFICES
OF
AND
ZEMSKY
SALOMON,
P.C.
BY:
MICHAEL
L. SALOMON,
for
Attorney(s)
& P.O.
Office
Front
Street
Hempstead,
(516)
9 of
485-
ESQ.
Plaintiff(s)
Address
Suite
New
York
being
served
NYCRR):Page 10 INDEX NO. 529844/
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO.
RECEIVED NYSCEF: 10/14/
SUPREME
COURT
OF
COUNTY
OF THE
OF NEW YORK
STATE
KINGS
HANON
ISAC
Index
,
No.
(
, J.)
Plaintiffs,
- against
-
INC.
TESLA,
,
Defendants.
REDACTION
CHECK
ALL THAT APPLY:
The document filed contains no confidential
The document
filed is REDACTED
The document
filed is UN-REDACTED
COVER
PAGE
personal information,
as defined in 22 NYCRR
in accordance with 22 NYCRR
202.5(e).
in accordance with 22 NYCRR
(a) The document filed contains SSN (as authorized
202..5(e).
202.5(e).
by the order specified
below).
(b) The document filed contains confidential personal information as defined
under 22 NYCRR 202.5(e) (as authorized by the order specified below).
This document
Date:
was previously
filed REDACTED.
This document was previously
Date:
filed UN-REDACTED.
The document
filed seeks a remedy under 22 NYCRR
202.5(e)(2).
The document
filed seeks a remedy under 22 NYCRR
202.5(e)(3).
Additional
There
Q
information:
is a previously
yes /
no
filed order
of the Court
regarding
this document:
Date of order:
Date order filed:
Other identifying
The order
information
of the Court
for such order:
is being filed with
the redacted
/ un-redacted
document:
Date of order:
Other
identifying
Signature of filer:
Print Name:
Counsel appearing
Filer
Date:
information
ivn
i int..L
for: ISAC
is Unrepresented
for such order:
ont.
iviviv
(name of party)
HANON
/ Pro se:
O
yes /
®
no
09/21/
10 of
Q
yes /
Q
no
PDF Page 1
PlainSite Cover Page
PDF Page 2
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
Supreme
Court
County
the
of
State
New
of
York
Kings
of
---------------------------------------------------------X
of
Date
Plaintiff
Plaintiff,
designates
as
Country
trial.
Filing:
NO.:
INDEX
HANON,
ISAC
-against.
TESLA,
place
of
venue
of
residence:
East
8th
NY
11230
INC.,
the
basis
The
plaintiff's
Kings
Street,
is
871
Brooklyn,
Summons
Defendant.
______________________________________________Ç
To
the
above-named
Defendant(s):
You
and
action
this
to
are
a copy
serve
to
summons,
summoned
hereby
of
your
a Notice
serve
of
20
days
after
the
service
of
30
days
after
the
service
is complete
you
within
judgment
the
State
will
be
New
of
and
you
answer
if the
the
of
exclusive
in
summons
by
of
case
is not
Plaintiffs
the
is not
your
default
complaint
the
complaint
on
Appearance
if this
York);
against
taken
or
answer,
summons,
this
to
for
the
with
(or
or
demanded
relief
within
delivered
appear
to
this
within
service
personally
failure
served
Attorneys
of
day
in
to
answer,
in
the
complaint.
Dated:
New
Hempstead,
September
D/A:
York
2022
21,
Yours,
etc.,
LAW
OFFICES
06/08/2022
ZEMSKY
for
Attorneys
& P.O.
Office
33
Front
Street,
Hempstead,
(516)
DEFENDANT'S
TESLA,
78725
INC.,
and
OF
& SALOMON,
P.C.
Plaintiff(s)
Address
Suite
New
207
York
11550
485-3800
ADDRESS:
160
S.O.S
Van
Brunt
pursuant
St,
to
Brooklyn,
BCL.
1 of 10
NY
11231
and
1 Tesla
Road,
Austin,
Texas
PDF Page 3
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
Supreme
Court
State
New
of
York
Kings
of
County
the
of
-------------------------------------------------------------------X
Date
HANON,
ISAC
of
INDEX
Plaintiff
Plaintiff,
designates
as
Country
trial.
Filing:
NO.:
The
-against-
TESLA,
the
basis
plaintiff's
Kings
of
place
venue
of
residence:
East
8th
NY
11230
Street,
is
871
Brooklyn,
INC.,
Defendant.
_____________________________________Ç
To
the
above-named
Defendant(s):
You
and
action
this
to
are
a copy
serve
summons,
to
summoned
hereby
of
your
a Notice
serve
of
20
days
after
the
service
of
30
days
after
the
service
is complete
you
within
judgment
the
State
will
be
this
New
of
taken
Appearance
against
you
in
the
by
of
summons
of
case
the
your
is not
Plaintiff's
the
is not
default
complaint
complaint
on
exclusive
if this
and
answer
if the
or
answer,
summons,
York);
to
for
within
delivered
or
demanded
relief
the
with
(or
appear
to
this
within
service
personally
failure
served
Attorneys
of
day
in
to
answer,
in
the
complaint.
Dated:
New
Hempstead,
September
D/A:
York
2022
21,
Yours,
etc.,
LAW
OFFICES
06/08/2022
ZEMSKY
for
Attorneys
& P.O.
Office
33
Front
Street,
Hempstead,
(516)
DEFENDANT'S
TESLA,
78725
INC.,
and
OF
& SALOMON,
P.C.
Plaintiff(s)
Address
Suite
New
207
York
11550
485-3800
ADDRESS:
160
S.O.S
Van
Brunt
pursuant
St,
to
Brooklyn,
BCL.
2 of 10
NY
11231
and
1 Tesla
Road,
Austin,
Texas
PDF Page 4
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
SUPREME
COURT
COUNTY
OF
OF THE
STATE
NEW YORK
OF
KINGS
--------------------------------------------------X
ISAC
Index
#:
HANON,
Plaintiff,
-against-
COMPLAINT
TESLA,
INC.,
Defendant.
_______________________________________Ç
Plaintiff,
his
by
of
complaining
the
LAW
attorneys,
defendant(s),
ON
OF ACTION
resident
of
the
County
SECOND:
That,
mentioned,
Kings,
at
That,
all
defendant,
State
of
mentioned,
to
upon
mentioned,
to
FIFTH:
upon
That,
transact
That,
New
P.C.,
follows:
HANON
ISAC
was
plaintiff
and
still
and
belief
principal
in
the
State
place
TESLA,
information
and
of
the
State
and
3 of 10
New
belief
was
INC.,
in
belief
and
information
business
upon
was
INC.,
is
a
York.
and
and
information
business
defendant,
authorized
INC.,
TESLA,
transact
FOURTH:
of
SALOMON,
at
all
times
business
of
is the
hereinafter
County
York.
defendant,
authorized
PLAINTIFF
mentioned,
information
TESLA,
New
THIRD:That,
State
as
&
CAUSE
FIRST
OF
BEHALF
Kings,
upon
A
hereinafter
times
of
FOR
ZEMSKY
alleges
respectfully
AS AND
FIRST:
OF
OFFICES
and
of
New
belief
and
still
at
is
all
times
domestic
a
hereinafter
corporation
York.
and
still
at
is
a
all
times
foreign
hereinafter
corporation
York.
and
at
all
times
hereinafter
of
PDF Page 5
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
mentioned,
the
defendant,
transaction
of
SIXTH:
of
mentioned,
mentioned,
State
New
of
of
New
mentioned,
and
York
is a
State
of
is a
INC.,
and
maintains
and
belief
all
times
hereinafter
a
place
for
the
at
all
times
a
maintaining
hereinafter
place
for
the
York.
and
TESLA,
at
maintaining
partnership
New
information
for
place
York.
and
INC.,
and
company
New
a
maintaining
York.
belief
is a
of
State
the
proprietorship
New
information
upon
That,
NINTH:
business
a
and
belief
at
all
organization
place
for
the
times
hereinafter
business
transacting
transaction
of
business
in
York.
upon
That,
defendant,
and
information
TESLA,
INC.,
and
belief
at
transacted
actually
all
times
hereinafter
in
business
the
State
of
York.
TENTH:
mentioned,
Van
in
a
of
INC.,
TESLA,
defendant,
State
the
upon
business
EIGHTH:
New
in
That,
of
State
TESLA,
defendant,
transaction
the
information
business
SEVENTH:
the
upon
was
INC.,
in
defendant,
transaction
the
business
That,
mentioned,
in
TESLA,
defendant,
Brunt
Street,
ELEVENTH:
mentioned,
dealership
upon
That,
TESLA,
County
That,
defendant,
facility
located
and
information
of
Kings,
upon
was
INC.,
at
INC.,
160
Van
New
of
and
information
TESLA,
owner
the
State
was
Brunt
York.
4 of 10
and
belief
of
at
the
all
times
premises
hereinafter
at
located
160
York.
and
belief
the
Street,
owner
County
at
of
all
a
of
times
certain
Kings,
hereinafter
automotive
State
of
New
PDF Page 6
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
TWELFTH:
mentioned,
defendant,
operated
a certain
of
County
mentioned,
mentioned,
maintained
a
Street,
of
County
FIFTEENTH:
mentioned,
defendant,
controlled
a
Street,
of
mentioned,
managed
a
of
SEVENTEENTH:
servants
and/or
proper
of
to
employees,
condition
EIGHTEENTH:That,
for
or
160
Van
at
all
times
Brunt
Street,
New
the
at
servants
premises.
all
times
and/or
located
hereinafter
employees,
at
and
all
at
servants
agents,
160
times
and/or
located
facility
and
its
Van
Brunt
hereinafter
employees,
at
160
Van
Brunt
and
belief
at
all
and/or
servants
agents,
located
facility
times
hereinafter
employees,
160
Van
INC.,
its
at
Brunt
York.
duty
prepare
of
the
the
5 of 10
the
defendant,
of
delivery
7th
day
TESLA,
Tesla
automobiles
agents,
in
a
automobiles.
Tesla
acquiring
about
aforesaid
hereinafter
York.
INC,
persons
on
hereinafter
employees
at
and
belief
belief
dealership
it was
That,
its
information
State
the
facility
and
New
automotive
Kings,
times
York.
INC.,
TESLA,
certain
County
of
upon
defendant,
of
agents,
dealership
State
That,
its
information
automotive
Kings,
SIXTEENTH:
New
TESLA,
certain
County
of
upon
lessee
dealership
State
That,
a
and
belief
and
INC.,
automotive
Kings,
and
information
TESLA,
certain
all
and/or
located
facility
was
INC.,
upon
defendant,
at
servants
agents,
information
TESLA,
That,
and
belief
York.
upon
defendant,
its
INC.,
dealership
New
of
That,
FOURTEENTH:
and
TESLA,
State
Kings,
and
information
automotive
THIRTEENTH:
Street,
upon
That,
of
June,
2022,
plaintiff
purchased
safe
PDF Page 7
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
a
Model
2022
INC.
TESLA,
State
Y
from
New
of
Tesla
their
A.M.
was
cut
the
for
was
or
control
of
and
dangerous
the
serious
Brunt
Street,
June,
2022
the
defendant,
of
County
negligence
of
above
the
Kings,
the
of
left
finger
ring
installed
defendant
in
and
the
approximately
his
improperly
dealership
condition
defective
at
when
injuries
been
had
that
of
day
sustain
trim
to
8th
the
to
door
due
and
about
caused
driver's
delivery
maintenance
on
That,
plaintiff
by
otherwise
Van
160
from
York.
the
prepared
at
located
dealership
NINETEENTH:
8:30
7SAYGDEF1NF447614
VIN#
bearing
its
and/or
operation,
and
premises,
and
then
premises
the
there
existing.
TWENTIETH:
condition
itself
of
said
had
existed
for
so
in
to
have
same
for
such
condition
of
occurrence
the
accident
TWENTY-FIRST:
condition
as
its
servants
agents,
agents,
Model
defendant
dangerous
Tesla
made
the
had
defendant
created
disregarding
employees,
VIN#
time
said
it could
hazardous
have
safe
premise
such
knowledge
of
informed
before
the
through
condition
on
its
said
the
aforesaid
6 of 10
and
allowed
caused,
hazardous
the
duty,
7SAYGDEF1NF447614
a
creating
That,
of
period
the
the
hazardous
the
actions
of
employees.
That,
bearing
a
long
of
alleged.
actually
and/or
condition
TWENTY-THIRD:
said
and/or
servants,
Y
herein
That,
TWENTY-SECOND:
its
defendant
time
knowledge
had
That,
to
condition
date,
to
at
the
be
permitted
and
those
through
defendant,
to
lawfully
aforesaid
the
remain
2022
in
a
thereat.
location,
this
PDF Page 8
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
was
plaintiff
caused
aforementioned
were
solely
without
any
TWENTY-FIFTH:
servants
caused
and/or
of
the
to
its
to
the
the
part
injuries
of
the
by
this
sustained
as
defendant,
of
this
plaintiff
hereinbefore
in
to
any
and/or
employees
to
proper
this
further
manner
to
in
that
and
TWENTY-SIXTH:
otherwise
precautions
within
the
in
and
the
to
avoid
jurisdictional
7 of 10
limits
any
notice
exercise
through
their
said
this
the
in
Tesla
of
its
automobile
or
due
exercise
careless
of
Tesla
the
agents,
delivery
the
had
plaintiff,
foregoing
the
which
the
their
warning
due
that
the
and
care
existed
for
an
servants
agents,
and
failing
and
care
in
prevailing;
to
failing
defendant,
negligent
of
then
condition
the
to
of
maintain
in
give
failed
they
negligent
and
reason
to
conditions
dangerous
suitable
By
sum
and
time;
were
that
to
inspect
failed
they
in
through
condition
properly
sustained
reason
by
defendant
neglecting
safe
neglecting
careless
of
and
reasonably
plaintiff;
the
and
the
a
the
injuries
and
through
of
failing
circumstances
length
unreasonable
in
and
remedy
in
negligence
in
and
occurrence
wholly
apprehended;
the
was
caution
be
to
under
defendant
and
and
failing
delivery
danger
caution
aforesaid
solely
premises
in
automobiles;
damaged
on
employees;
and
dealership
take
negligence
the
recklessness
carelessness,
the
negligence
That,
were
therefrom
of
and
accident
the
by
reason
by
thereto.
contributing
prior
said
the
That,
injured
severely
thereat.
existing
caused
and
alleged,
and
seriously
conditions
TWENTY-FOURTH:
plaintiff
be
to
omitting
occurrence.
ISAC
Court
HANON,
and
for
has
an
been
amount
PDF Page 9
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
in
RECEIVED NYSCEF: 10/14/2022
excess
of
the
jurisdictional
within
the
jurisdictional
costs
Court
Dated:
and
jurisdictional
limits
of
disbursements
deems
just
and
Hempstead,
September
limits
the
of
lower
of
this
of
Courts
lower
the
demands
plaintiff
WHEREFORE,
sum
limits
judgment
this
and
the
State
and
action
the
against
Court
of
of
Courts
for
such
the
an
of
New
in
York
and
other
21,
further
York
2022
Yours,
LAW
etc.,
S OF
OFFIC
ZEMSKY
N
& SAL
.
.
By:
Mich
el
for
Attorneys
33
L. Salbfhc>n,
Front
Street,
Hempstead,
(516)
8 of 10
485-3800
Esq.
Plaintiff
Suite
New
207
York
excess
together
proper.
New
York.
defendant(s)
amount
for
New
of
State
11550
in
the
of
the
with
relief
as
the
this
PDF Page 10
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
Supreme
Court
of
County
of
the
State
of
New
York
Kings
---------------------------------------------X
ISAC
Index
No.:
HANON,
CERTIFICATION
Plaintiff,
PURSUANT
-against-
TESLA,
TO SECTION
130-1.1-A
INC.,
Defendant.
_________________________________Ç
SI R S :
PLEASE
pursuant
SUMMONS
Dated:
to
TAKE
section
AND
Hempstead,
September
NOTICE,
that
130-1.1-a
of
the
the
papers
accompanying
Rules
of
the
Chief
are
Administrator
(22
COMPLAINT
New
21,
York
2022
Yours,
etc.,
LAW
OFFICES
OF
AND
ZEMSKY
SALOMON,
P.C.
BY:
MICHAEL
L. SALOMON,
for
Attorney(s)
& P.O.
Office
33
Front
Street
Hempstead,
(516)
9 of 10
485-3800
ESQ.
Plaintiff(s)
Address
Suite
New
207
York
being
11550
served
NYCRR):
PDF Page 11
INDEX NO. 529844/2022
FILED: KINGS COUNTY CLERK 10/14/2022 12:23 PM
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 10/14/2022
SUPREME
COURT
OF
COUNTY
OF THE
OF NEW YORK
STATE
KINGS
HANON
ISAC
Index
,
No.
(
, J.)
Plaintiffs,
- against
-
INC.
TESLA,
,
Defendants.
REDACTION
CHECK
ALL THAT APPLY:
The document filed contains no confidential
The document
filed is REDACTED
The document
filed is UN-REDACTED
COVER
PAGE
personal information,
as defined in 22 NYCRR
in accordance with 22 NYCRR
202.5(e).
in accordance with 22 NYCRR
(a) The document filed contains SSN (as authorized
202..5(e).
202.5(e).
by the order specified
below).
(b) The document filed contains confidential personal information as defined
under 22 NYCRR 202.5(e) (as authorized by the order specified below).
This document
Date:
was previously
filed REDACTED.
This document was previously
Date:
filed UN-REDACTED.
The document
filed seeks a remedy under 22 NYCRR
202.5(e)(2).
The document
filed seeks a remedy under 22 NYCRR
202.5(e)(3).
Additional
There
Q
information:
is a previously
yes /
no
filed order
of the Court
regarding
this document:
Date of order:
Date order filed:
Other identifying
The order
information
of the Court
for such order:
is being filed with
the redacted
/ un-redacted
document:
Date of order:
Other
identifying
Signature of filer:
Print Name:
Counsel appearing
Filer
Date:
information
ivn
i int..L
for: ISAC
is Unrepresented
for such order:
ont.
iviviv
(name of party)
HANON
/ Pro se:
O
yes /
®
no
09/21/2022
10 of 10
Q
yes /
Q
no