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INDEX NO. 161002/2014
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/05/2014
SUPREME COURT OF THE STATE OF NEW YORK Index No.
COUNTY OF NEW YORK Date Purchased:
sacra crete tice aenanaainbaniainieem cue neseemamapeccned! SUMMONS
JAHRIEL BROWNE, Plaintiff designates New York
County as the place of trial.
Plaintiff,
The basis of venue is:
-against- Plaintiff's Residence
Plaintiff resides at: 251 West 135"
THE NEW YORK CITY SOCIETY OF THE
Street, New York, N.Y 10030
METHODIST CHURCH, SALEM METH CHURCH,
RENEE DOE and DOUG DOE, New York County
Defendants.
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 days after the service of this summons, exclusive of the day of
service, where service is made by delivery upon you personally within the state, or, within 30 days
after completion of service where service is made in any other manner. In case of your failure to
appear or answer, judgment will be taken against you by default for the relief demanded in the
complaint.
yt
Dated: New York, NY
November5 , 2014
Gary N. Rawlins, Esq.
The Rawlins Law Firm, PLLC
Attorneys for Plaintiff
JAHRIEL BROWNE
80 Broad Street, 5 Floor
New York, NY 10004
Phone: 212-926-0050
Fax: 212-926-0059
TO:
NYC Society Methodist Church
475 Riverside DR STE 1922
New York NY 10115-0028
Salem Meth Church
211 West 129" Street
New York New York 10030
Renee Doe
Doug Doe
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
ase ea ae eco ar re aaae Be Index No.:
JAHRIEL BROWNE, Date Purchased:
Plaintiff, VERIFIED COMPLAINT
-against-
THE NEW YORK CITY SOCIETY OF THE
METHODIST CHURCH, SALEM METH CHURCH,
RENEE DOE and DOUG DOE,
Defendants
--
Plaintiff, by his attorney THE RAWLINS LAW FIRM, PLLC complaining of the
Defendants respectfully alleges, upon information and belief:
1 That at the time of the commencement of this action, Plaintiff JAHRIEL
BROWNE resided in the County of New York , City and State of New York.
2. That the cause of action alleged herein arose in the County of New York,
City and State of New York.
3 That on or about January 12, 2012, and at all times herein mentioned,
Defendants NEW YORK SOCIETY METHODIST CHURCH was the owner, operator,
manager, and superintendents of the building located at 211 West 129" Street and is a
resident of New York County.
4 That on or about January 12, 2012, and at all times herein mentioned,
Defendants NEW YORK SOCIETY METHODIST CHURCH was and still a public
corporation duly licensed to conduct business in the State of New York and is the owner of
the property located at 211 West 129" Street, New York NY, 10030.
5 That on or about January 12, 2012, and at all times herein mentioned, a
public church existed in the County of New York, City and State of New York, located at
211 West 129" Street.
AS AND FOR A FIRST CAUSE OF ACTION
6 Plaintiff repeats and reiterates each and every one of the above
allegations.
7. That on or about January 12, 2012, and at all times herein mentioned, the
SALEM METH CHURCH at said location were owned, maintained, controlled, and
managed by Defendants NEW YORK SOCIETY METHODIST CHURCH.
8 That on January 12, 2012 and at all times herein mentioned, it was the duty
of Defendant to maintain the public church, more specifically doors, roof and stairwell, in a
reasonably safe condition.
9. That on or about January 12, 2012, Plaintiff JAHRIEL BROWNE was
lawfully a guest at the SALEM METH CHURCH.
10. That on or about January 12, 2012, while Plaintiff was lawfully walking
down the stairs of the aforesaid location, he was caused to slip, trip and/or fall and sustain
severe and permanent injuries.
li. That, upon information and belief, Defendants employed personal to
maintain, repair; and manage the doors, roof and stairwell and to were employed to keep a
clean and safe environment for all guests. Defendants negligently trained, managed and
supervised their employees and caused, permitted and allowed water to accumulate on
the stairway. Plaintiff was caused, permitted and allowed to slip and fall and sustain
serious injury.
12. That no negligence on the part of the Plaintiff contributed to the occurrence
PLAINTIFF'S VERIFICATION
STATE OF NEW YORK, COUNTY OF KINGS, ss:
qq alte L(tonne , being duly sworn, says:
Tam a Plaintiff in the action herein: I have read the annexed
COMPLAINT
and know the contents thereof, and the same are true to my knowledge, except those
matters therein which are stated to be alleged upon information and belief, and as to those
matters I believe them to be true. My belief as to those matters therein not stated upon
knowledge, is based upon facts, records, and other pertinent information contained in my
personal files.
DATED: New York, NY
No 5doit
x Solnitt Geourt
Sworn to before me this day
of Mtuenber _, 2014
singe
No fblic
GARY RAWLINS
NOTARY PUBLIC, State Of New York
No. G2R 6041 445
Qualified In Jew lor Ky Count
Commissiun Expites wiay 8, 20 as ig
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
i i x Index No.
JAHRIEL BROWNE,
Plaintiffs,
SUMMONS AND COMPLAINT
-against-
THE NEW YORK CITY SOCIETY OF THE METHODIST
CHURCH, SALEM METH CHURCH, RENEE DOE and
DOUG DOE,
Defendani
RA /LINY LAW FIRM, PLLC
v Attgrney for Plaintiff
80. road Street 5" FL
New York, NY 10004
P:(212) 926-0050
F:(212) 926-0059
To:
NYC Society Methodist Church
475 Riverside DR ST 1922
New York NY 10115-0028
Salem Meth Church
211 West 129" Street
New York New York 10030
Renee Doe
Doug Doe
Service of a copy of the within is hereby admitted
Dated:
Attorney(s) for Defendant(s)
PLEASE TAKE NOTICE
1 That the within is a (certified) true copy ofa
Entered in the office of the clerk of the within named court on
NOTICE OF ENTRY
ti 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.
NOTICE OF SETTLEMENT
Dated:
STATE OF NEW YORK, COUNTY OF NEW YORK
‘The undersigned, an attorney admitted to practice on the courts of New York State
Certification Certifies that the within
By Attorney
Preview
INDEX NO. 161002/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/05/2014 SUPREME COURT OF THE STATE OF NEW YORK Index No. COUNTY OF NEW YORK Date Purchased: sacra crete tice aenanaainbaniainieem cue neseemamapeccned! SUMMONS JAHRIEL BROWNE, Plaintiff designates New York County as the place of trial. Plaintiff, The basis of venue is: -against- Plaintiff's Residence Plaintiff resides at: 251 West 135" THE NEW YORK CITY SOCIETY OF THE Street, New York, N.Y 10030 METHODIST CHURCH, SALEM METH CHURCH, RENEE DOE and DOUG DOE, New York County Defendants. 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 days after the service of this summons, exclusive of the day of service, where service is made by delivery upon you personally within the state, or, within 30 days after completion of service where service is made in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. yt Dated: New York, NY November5 , 2014 Gary N. Rawlins, Esq. The Rawlins Law Firm, PLLC Attorneys for Plaintiff JAHRIEL BROWNE 80 Broad Street, 5 Floor New York, NY 10004 Phone: 212-926-0050 Fax: 212-926-0059 TO: NYC Society Methodist Church 475 Riverside DR STE 1922 New York NY 10115-0028 Salem Meth Church 211 West 129" Street New York New York 10030 Renee Doe Doug Doe SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ase ea ae eco ar re aaae Be Index No.: JAHRIEL BROWNE, Date Purchased: Plaintiff, VERIFIED COMPLAINT -against- THE NEW YORK CITY SOCIETY OF THE METHODIST CHURCH, SALEM METH CHURCH, RENEE DOE and DOUG DOE, Defendants -- Plaintiff, by his attorney THE RAWLINS LAW FIRM, PLLC complaining of the Defendants respectfully alleges, upon information and belief: 1 That at the time of the commencement of this action, Plaintiff JAHRIEL BROWNE resided in the County of New York , City and State of New York. 2. That the cause of action alleged herein arose in the County of New York, City and State of New York. 3 That on or about January 12, 2012, and at all times herein mentioned, Defendants NEW YORK SOCIETY METHODIST CHURCH was the owner, operator, manager, and superintendents of the building located at 211 West 129" Street and is a resident of New York County. 4 That on or about January 12, 2012, and at all times herein mentioned, Defendants NEW YORK SOCIETY METHODIST CHURCH was and still a public corporation duly licensed to conduct business in the State of New York and is the owner of the property located at 211 West 129" Street, New York NY, 10030. 5 That on or about January 12, 2012, and at all times herein mentioned, a public church existed in the County of New York, City and State of New York, located at 211 West 129" Street. AS AND FOR A FIRST CAUSE OF ACTION 6 Plaintiff repeats and reiterates each and every one of the above allegations. 7. That on or about January 12, 2012, and at all times herein mentioned, the SALEM METH CHURCH at said location were owned, maintained, controlled, and managed by Defendants NEW YORK SOCIETY METHODIST CHURCH. 8 That on January 12, 2012 and at all times herein mentioned, it was the duty of Defendant to maintain the public church, more specifically doors, roof and stairwell, in a reasonably safe condition. 9. That on or about January 12, 2012, Plaintiff JAHRIEL BROWNE was lawfully a guest at the SALEM METH CHURCH. 10. That on or about January 12, 2012, while Plaintiff was lawfully walking down the stairs of the aforesaid location, he was caused to slip, trip and/or fall and sustain severe and permanent injuries. li. That, upon information and belief, Defendants employed personal to maintain, repair; and manage the doors, roof and stairwell and to were employed to keep a clean and safe environment for all guests. Defendants negligently trained, managed and supervised their employees and caused, permitted and allowed water to accumulate on the stairway. Plaintiff was caused, permitted and allowed to slip and fall and sustain serious injury. 12. That no negligence on the part of the Plaintiff contributed to the occurrence PLAINTIFF'S VERIFICATION STATE OF NEW YORK, COUNTY OF KINGS, ss: qq alte L(tonne , being duly sworn, says: Tam a Plaintiff in the action herein: I have read the annexed COMPLAINT and know the contents thereof, and the same are true to my knowledge, except those matters therein which are stated to be alleged upon information and belief, and as to those matters I believe them to be true. My belief as to those matters therein not stated upon knowledge, is based upon facts, records, and other pertinent information contained in my personal files. DATED: New York, NY No 5doit x Solnitt Geourt Sworn to before me this day of Mtuenber _, 2014 singe No fblic GARY RAWLINS NOTARY PUBLIC, State Of New York No. G2R 6041 445 Qualified In Jew lor Ky Count Commissiun Expites wiay 8, 20 as ig SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK i i x Index No. JAHRIEL BROWNE, Plaintiffs, SUMMONS AND COMPLAINT -against- THE NEW YORK CITY SOCIETY OF THE METHODIST CHURCH, SALEM METH CHURCH, RENEE DOE and DOUG DOE, Defendani RA /LINY LAW FIRM, PLLC v Attgrney for Plaintiff 80. road Street 5" FL New York, NY 10004 P:(212) 926-0050 F:(212) 926-0059 To: NYC Society Methodist Church 475 Riverside DR ST 1922 New York NY 10115-0028 Salem Meth Church 211 West 129" Street New York New York 10030 Renee Doe Doug Doe Service of a copy of the within is hereby admitted Dated: Attorney(s) for Defendant(s) PLEASE TAKE NOTICE 1 That the within is a (certified) true copy ofa Entered in the office of the clerk of the within named court on NOTICE OF ENTRY ti 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. NOTICE OF SETTLEMENT Dated: STATE OF NEW YORK, COUNTY OF NEW YORK ‘The undersigned, an attorney admitted to practice on the courts of New York State Certification Certifies that the within By Attorney