Preview
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
_______________________________________________ Index No.
MARIA LOURDES ARIAS,
Plaintiff designates Queens
Plaintiff, County as the place of trial.
-against- The basis of venue is Place of
Occurrence
NEW YORK CITY TRANSIT AUTHORITY and
METROPOLITAN TRANSPORTATION AUTHORITY, SUMMONS
Defendants.
________________________________________________
COUNTY OF QUEENS
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 this summons, to serve a notice of appearance
on the plaintiff's attorneys within twenty (20) days after the service of this summons, exclusive of
the day of service (or within thirty (30) days after the service is complete if this 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.
Dated: May 6, 2024
NEWMAN, ANZALONE & NEWMAN, LLP
Attorneys for the Plaintiff
Office and Post Office Address
95-25 Queens Boulevard, 11th Floor
DEFENDANTS’ ADDRESSES: Rego Park, NY 11374
NEW YORK CITY TRANSIT AUTHORITY
130 Livingston Street
Brooklyn, NY 11201
METROPOLITAN TRANSPORTATION AUTHORITY
2 Broadway
New York, NY 10004
1 of 8
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
_________________________________________________
MARIA LOURDES ARIAS,
Plaintiff, Index No.:
-against-
NEW YORK CITY TRANSIT AUTHORITY and COMPLAINT
METROPOLITAN TRANSPORTATION AUTHORITY,
Defendants.
________________________________________________
Plaintiff, by her attorneys, NEWMAN, ANZALONE & NEWMAN, LLP, complaining of
the Defendants, states to the Court and alleges as follows upon information and belief:
1. That at all times herein mentioned, the occurrence complained of occurred in the
County of Queens, City and State of New York.
2. That at all times herein mentioned, the Defendant, NEW YORK CITY TRANSIT
AUTHORITY, was and still is a public benefit corporation organized and existing under and by
virtue of the Public Authorities Laws of the State of New York.
3. That a Notice of Claim was duly and timely served upon the Defendant, NEW
YORK CITY TRANSIT AUTHORITY, within the time prescribed by law.
4. That the statutory 50-H Hearing in this matter was held on January 12, 2024.
5. That more than thirty (30) days have elapsed since the service and filing of the
aforesaid Notice of Claim upon the Defendant, who has not, to this date, adjusted any of the claims
asserted in any of the aforesaid Notices of Claim and herein pleaded.
6. That this action is being commenced within one year and ninety days of its accrual.
7. That upon information and belief, at all times mentioned herein, the Defendant,
NEW YORK CITY TRANSIT AUTHORITY, was the owner of a certain train station known as
the 103 St-Corona Plaza Station, in the County of Queens, City and State of New York.
8. That upon information and belief, at all times mentioned herein, the Defendant,
2 of 8
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
NEW YORK CITY TRANSIT AUTHORITY, operated the aforesaid train station including the
exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and
more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the
County of Queens, City and State of New York.
9. That upon information and belief, at all times mentioned herein, the Defendant,
NEW YORK CITY TRANSIT AUTHORITY, managed the aforesaid train station including the
exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and
more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the
County of Queens, City and State of New York.
10. That upon information and belief, at all times mentioned herein, the Defendant,
NEW YORK CITY TRANSIT AUTHORITY, possessed the aforesaid train station including the
exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and
more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the
County of Queens, City and State of New York.
11. That upon information and belief, at all times mentioned herein, the Defendant,
NEW YORK CITY TRANSIT AUTHORITY, maintained the aforesaid train station including
the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and
more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the
County of Queens, City and State of New York.
12. That upon information and belief, at all times mentioned herein, the Defendant,
NEW YORK CITY TRANSIT AUTHORITY, controlled the aforesaid train station including the
exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and
more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the
County of Queens, City and State of New York.
13. That at all times herein mentioned, the Defendant, METROPOLITAN
TRANSPORTATION AUTHORITY, was and still is a public benefit corporation organized and
existing under and by virtue of the Public Authorities Laws of the State of New York, and has
3 of 8
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
offices at 2 Broadway, New York, NY 10004.
14. That a Notice of Claim was duly and timely served upon the Defendant,
METROPOLITAN TRANSPORTATION AUTHORITY, within the time prescribed by law.
15. That more than thirty (30) days has elapsed since the service and filing of the
aforesaid Notice of Claim upon the Defendant, who has not, to this date, adjusted any of the claims
asserted in any of the aforesaid Notice of Claim and herein pleaded.
16. That this action is being commenced within one year and ninety days of its accrual.
17. That upon information and belief, at all times mentioned herein, the Defendant,
METROPOLITAN TRANSPORTATION AUTHORITY, was the owner of a certain train
station known as the 103 St-Corona Plaza Station, in the County of Queens, City and State of New
York,
18. That upon information and belief, at all times mentioned herein, the Defendant,
METROPOLITAN TRANSPORTATION AUTHORITY, operated the aforesaid train station
including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza
Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt
Avenue, in the County of Queens, City and State of New York.
19. That upon information and belief, at all times mentioned herein, the Defendant,
METROPOLITAN TRANSPORTATION AUTHORITY, managed the aforesaid train station
including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza
Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt
Avenue, in the County of Queens, City and State of New York.
20. That upon information and belief, at all times mentioned herein, the Defendant,
METROPOLITAN TRANSPORTATION AUTHORITY, maintained the aforesaid train station
including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza
Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt
Avenue, in the County of Queens, City and State of New York
21. That upon information and belief, at all times mentioned herein, the Defendant,
4 of 8
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
METROPOLITAN TRANSPORTATION AUTHORITY, possessed the aforesaid train station
including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza
Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt
Avenue, in the County of Queens, City and State of New York.
22. That upon information and belief, at all times mentioned herein, the Defendant,
METROPOLITAN TRANSPORTATION AUTHORITY, the aforesaid train station including
the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and
more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the
County of Queens, City and State of New York.
23. That upon information and belief, at all times mentioned herein, the Defendant,
METROPOLITAN TRANSPORTATION AUTHORITY, controlled the aforesaid train station
including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza
Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt
Avenue, in the County of Queens, City and State of New York.
24. That at all times herein mentioned, the train station known as the 103 St-Corona
Plaza Station, in the County of Queens, City and State of New York, was and still is a train station
open to the public and in common use by the residents of said city and others.
25. That at all times herein mentioned, there was a duty imposed upon the Defendants to
keep the aforementioned exterior staircase/landing area, in a safe and proper condition for those
individuals lawfully utilizing the same.
26. That on the 27th day of June, 2023, while the Plaintiff, MARIA LOURDES
ARIAS, was lawfully traversing upon the aforesaid exterior staircase/landing area of the #7 train
located at the train station known as the 103 St-Corona Plaza Station, and more particularly in
front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens,
City and State of New York, she was caused to trip/slip and fall due breaks, cracks, raises and/or
depression upon said staircase/landing area, causing her to be violently precipitated to the ground,
thus sustaining the injuries as herein alleged.
5 of 8
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
27. That on the 27th day of June, 2023, and for a long period of time prior thereto, the
Defendants held out to the public that the exterior staircase/landing area of the #7 train located at
the train station known as the 103 St-Corona Plaza Station, and more particularly in front
of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City
and State of New York, could be used safely by persons lawfully thereon, including the Plaintiff
herein.
28. That for a long period of time prior to the 27th day of June, 2023, in derogation of
their respective duties, the Defendants caused, permitted, and allowed the aforesaid dangerous and
defective conditions to exist, so that it was dangerous to the lives and limbs of those lawfully using
same.
29. That upon information and belief, prior to the 27th day of June, 2023, the Defendants
had actual knowledge of the unsafe and dangerous condition of the aforesaid exterior
staircase/landing area, or that same had existed for so long a period of time that said Defendants
should have known of said condition in time to have made said area safe before the occurrence of
the accident herein alleged.
30. That the accident and the injuries resulting to the Plaintiff therefrom were caused
solely and wholly by reason of the negligence of the Defendants without any negligence on the part
of the Plaintiff contributing thereto.
31. By reason of the foregoing, Plaintiff, MARIA LOURDES ARIAS, was rendered
sick, sore, lame and disabled, and suffered severe, painful and permanent injuries including
fractures to various parts of Plaintiff's person with accompanying pain; that Plaintiff continues to be
sick, sore, lame and disabled, she has been incapacitated and has expended and become obligated to
expend sums of money for medical care and attention in an effort to cure herself of her injuries and
to alleviate her pain and suffering. She was unable and continues to be unable for some time to
come, to pursue her usual daily occupation, duties and daily activities, all to her damage.
WHEREFORE, Plaintiff, MARIA LOURDES ARIAS, has sustained injuries and
damages in a sum greater than the jurisdictional limits of any lower court and as such, demands
6 of 8
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
judgment on all causes of action stated herein against the Defendants.
Dated: Rego Park, New York
May 6, 2024
Yours, etc.
NEWMAN, ANZALONE & NEWMAN, LLP
By: LUCILLE A. ANZALONE, ESQ.
Attorneys for Plaintiff
95-25 Queens Boulevard, 11th Floor
Rego Park, NY 11374
(718) 896-2700
File No.: 00385-23
7 of 8
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
Index No.:
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
MARIA LOURDES ARIAS,
Plaintiff,
-against-
NEW YORK CITY TRANSIT AUTHORITY and METROPOLITAN TRANSPORTATION
AUTHORITY,
Defendants.
SUMMONS AND COMPLAINT
NEWMAN, ANZALONE & NEWMAN LLP
Attorneys for Plaintiff
95-25 Queens Boulevard, 11th Floor
Rego Park, New York 11374
Telephone: (718) 896-2700
Facsimile: (718) 896-2560
Pursuant to 22 NYCRR 130.1-1, the undersigned, an attorney admitted to practice in the Courts of New York
State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the
annexed document are not frivolous.
05/06/2024
Dated: _______________________ Signed: ___________________________________
Service of a copy of the within
Dated: _______________________ Signed: ___________________________________
8 of 8
Preview
FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS _______________________________________________ Index No. MARIA LOURDES ARIAS, Plaintiff designates Queens Plaintiff, County as the place of trial. -against- The basis of venue is Place of Occurrence NEW YORK CITY TRANSIT AUTHORITY and METROPOLITAN TRANSPORTATION AUTHORITY, SUMMONS Defendants. ________________________________________________ COUNTY OF QUEENS 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 this summons, to serve a notice of appearance on the plaintiff's attorneys within twenty (20) days after the service of this summons, exclusive of the day of service (or within thirty (30) days after the service is complete if this 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. Dated: May 6, 2024 NEWMAN, ANZALONE & NEWMAN, LLP Attorneys for the Plaintiff Office and Post Office Address 95-25 Queens Boulevard, 11th Floor DEFENDANTS’ ADDRESSES: Rego Park, NY 11374 NEW YORK CITY TRANSIT AUTHORITY 130 Livingston Street Brooklyn, NY 11201 METROPOLITAN TRANSPORTATION AUTHORITY 2 Broadway New York, NY 10004 1 of 8 FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS _________________________________________________ MARIA LOURDES ARIAS, Plaintiff, Index No.: -against- NEW YORK CITY TRANSIT AUTHORITY and COMPLAINT METROPOLITAN TRANSPORTATION AUTHORITY, Defendants. ________________________________________________ Plaintiff, by her attorneys, NEWMAN, ANZALONE & NEWMAN, LLP, complaining of the Defendants, states to the Court and alleges as follows upon information and belief: 1. That at all times herein mentioned, the occurrence complained of occurred in the County of Queens, City and State of New York. 2. That at all times herein mentioned, the Defendant, NEW YORK CITY TRANSIT AUTHORITY, was and still is a public benefit corporation organized and existing under and by virtue of the Public Authorities Laws of the State of New York. 3. That a Notice of Claim was duly and timely served upon the Defendant, NEW YORK CITY TRANSIT AUTHORITY, within the time prescribed by law. 4. That the statutory 50-H Hearing in this matter was held on January 12, 2024. 5. That more than thirty (30) days have elapsed since the service and filing of the aforesaid Notice of Claim upon the Defendant, who has not, to this date, adjusted any of the claims asserted in any of the aforesaid Notices of Claim and herein pleaded. 6. That this action is being commenced within one year and ninety days of its accrual. 7. That upon information and belief, at all times mentioned herein, the Defendant, NEW YORK CITY TRANSIT AUTHORITY, was the owner of a certain train station known as the 103 St-Corona Plaza Station, in the County of Queens, City and State of New York. 8. That upon information and belief, at all times mentioned herein, the Defendant, 2 of 8 FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 NEW YORK CITY TRANSIT AUTHORITY, operated the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 9. That upon information and belief, at all times mentioned herein, the Defendant, NEW YORK CITY TRANSIT AUTHORITY, managed the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 10. That upon information and belief, at all times mentioned herein, the Defendant, NEW YORK CITY TRANSIT AUTHORITY, possessed the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 11. That upon information and belief, at all times mentioned herein, the Defendant, NEW YORK CITY TRANSIT AUTHORITY, maintained the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 12. That upon information and belief, at all times mentioned herein, the Defendant, NEW YORK CITY TRANSIT AUTHORITY, controlled the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 13. That at all times herein mentioned, the Defendant, METROPOLITAN TRANSPORTATION AUTHORITY, was and still is a public benefit corporation organized and existing under and by virtue of the Public Authorities Laws of the State of New York, and has 3 of 8 FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 offices at 2 Broadway, New York, NY 10004. 14. That a Notice of Claim was duly and timely served upon the Defendant, METROPOLITAN TRANSPORTATION AUTHORITY, within the time prescribed by law. 15. That more than thirty (30) days has elapsed since the service and filing of the aforesaid Notice of Claim upon the Defendant, who has not, to this date, adjusted any of the claims asserted in any of the aforesaid Notice of Claim and herein pleaded. 16. That this action is being commenced within one year and ninety days of its accrual. 17. That upon information and belief, at all times mentioned herein, the Defendant, METROPOLITAN TRANSPORTATION AUTHORITY, was the owner of a certain train station known as the 103 St-Corona Plaza Station, in the County of Queens, City and State of New York, 18. That upon information and belief, at all times mentioned herein, the Defendant, METROPOLITAN TRANSPORTATION AUTHORITY, operated the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 19. That upon information and belief, at all times mentioned herein, the Defendant, METROPOLITAN TRANSPORTATION AUTHORITY, managed the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 20. That upon information and belief, at all times mentioned herein, the Defendant, METROPOLITAN TRANSPORTATION AUTHORITY, maintained the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York 21. That upon information and belief, at all times mentioned herein, the Defendant, 4 of 8 FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 METROPOLITAN TRANSPORTATION AUTHORITY, possessed the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 22. That upon information and belief, at all times mentioned herein, the Defendant, METROPOLITAN TRANSPORTATION AUTHORITY, the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 23. That upon information and belief, at all times mentioned herein, the Defendant, METROPOLITAN TRANSPORTATION AUTHORITY, controlled the aforesaid train station including the exterior staircase/landing area of the #7 train located at the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York. 24. That at all times herein mentioned, the train station known as the 103 St-Corona Plaza Station, in the County of Queens, City and State of New York, was and still is a train station open to the public and in common use by the residents of said city and others. 25. That at all times herein mentioned, there was a duty imposed upon the Defendants to keep the aforementioned exterior staircase/landing area, in a safe and proper condition for those individuals lawfully utilizing the same. 26. That on the 27th day of June, 2023, while the Plaintiff, MARIA LOURDES ARIAS, was lawfully traversing upon the aforesaid exterior staircase/landing area of the #7 train located at the train station known as the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York, she was caused to trip/slip and fall due breaks, cracks, raises and/or depression upon said staircase/landing area, causing her to be violently precipitated to the ground, thus sustaining the injuries as herein alleged. 5 of 8 FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 27. That on the 27th day of June, 2023, and for a long period of time prior thereto, the Defendants held out to the public that the exterior staircase/landing area of the #7 train located at the train station known as the 103 St-Corona Plaza Station, and more particularly in front of/adjacent to the premises known as 103-07 Roosevelt Avenue, in the County of Queens, City and State of New York, could be used safely by persons lawfully thereon, including the Plaintiff herein. 28. That for a long period of time prior to the 27th day of June, 2023, in derogation of their respective duties, the Defendants caused, permitted, and allowed the aforesaid dangerous and defective conditions to exist, so that it was dangerous to the lives and limbs of those lawfully using same. 29. That upon information and belief, prior to the 27th day of June, 2023, the Defendants had actual knowledge of the unsafe and dangerous condition of the aforesaid exterior staircase/landing area, or that same had existed for so long a period of time that said Defendants should have known of said condition in time to have made said area safe before the occurrence of the accident herein alleged. 30. That the accident and the injuries resulting to the Plaintiff therefrom were caused solely and wholly by reason of the negligence of the Defendants without any negligence on the part of the Plaintiff contributing thereto. 31. By reason of the foregoing, Plaintiff, MARIA LOURDES ARIAS, was rendered sick, sore, lame and disabled, and suffered severe, painful and permanent injuries including fractures to various parts of Plaintiff's person with accompanying pain; that Plaintiff continues to be sick, sore, lame and disabled, she has been incapacitated and has expended and become obligated to expend sums of money for medical care and attention in an effort to cure herself of her injuries and to alleviate her pain and suffering. She was unable and continues to be unable for some time to come, to pursue her usual daily occupation, duties and daily activities, all to her damage. WHEREFORE, Plaintiff, MARIA LOURDES ARIAS, has sustained injuries and damages in a sum greater than the jurisdictional limits of any lower court and as such, demands 6 of 8 FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 judgment on all causes of action stated herein against the Defendants. Dated: Rego Park, New York May 6, 2024 Yours, etc. NEWMAN, ANZALONE & NEWMAN, LLP By: LUCILLE A. ANZALONE, ESQ. Attorneys for Plaintiff 95-25 Queens Boulevard, 11th Floor Rego Park, NY 11374 (718) 896-2700 File No.: 00385-23 7 of 8 FILED: QUEENS COUNTY CLERK 05/06/2024 05:38 PM INDEX NO. 709652/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 Index No.: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS MARIA LOURDES ARIAS, Plaintiff, -against- NEW YORK CITY TRANSIT AUTHORITY and METROPOLITAN TRANSPORTATION AUTHORITY, Defendants. SUMMONS AND COMPLAINT NEWMAN, ANZALONE & NEWMAN LLP Attorneys for Plaintiff 95-25 Queens Boulevard, 11th Floor Rego Park, New York 11374 Telephone: (718) 896-2700 Facsimile: (718) 896-2560 Pursuant to 22 NYCRR 130.1-1, the undersigned, an attorney admitted to practice in the Courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. 05/06/2024 Dated: _______________________ Signed: ___________________________________ Service of a copy of the within Dated: _______________________ Signed: ___________________________________ 8 of 8