FILED: BRONX COUNTY CLERK 09/15/2016 12:36 PM INDEX NO. 23444/2016E NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 09/15/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX ----------------------------------------------------------------------------X MOHAMED SAAD, SOPHIA MARRERO and CORY MARRERO infant by m\l\g SOPHIA MARRERO, -against- Plaintiff (s), BERNARDO E. HIDALGO and SANDRA LIMO, LLC a/k/a SANDRA LIMOUSINE, LLC Defendant (s), ----------------------------------------------------------------------------X SECOND AMENDED SUM M ONS Index No 23444/2016E Plaintiff(s) designates BRONX County as the place of trial The basis of venue is PLAINTIFF S RESIDENCE PLAINTIFF resides at 1224 Walton Avenue Apt. 3F Bronx, New York 10452 County of BRONX To the above named Defendant(s) 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 Attorney(s) within 20 days after the service of this summons, exclusive of the day of service (or within 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 herein. Dated: SEPTEMBER 15, 2016 /s/ Alexander Roytblat BY: ALEXANDER ROYTBLAT, ESQ. This SUMMONS AND COMPLAINT and the papers on which it is based, are certified pursuant to Section 130-1.1-a of the rules of the Chief Administrator (22NYCRR) KALANT & ROYTBLAT, PLLC Attorney(s) for Plaintiff(s) Office and Post Office Address Notice: The object of this action is to recover for personal injury 91-31 Queens Blvd. Ste. 313 due to defendant(s) negligence Elmhurst, New York 11373 T: (718) 872-6374 The relief sought is Monetary Damages Upon your failure to appear, judgment will be taken against you by default with interest from October 31, 2015and the costs of this action. DEFENDANT(S) ADDRESS(ES) Bernardo E. Hidalgo 111-29 44 th Avenue Corona, New York Sandra Limo, LLC 97-19 95 St. Ozone Park, New York 11416 1 of 17
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX ----------------------------------------------------------------------------X MOHAMED SAAD, SOPHIA MARRERO and CORY MARRERO infant by m\l\g SOPHIA MARRERO, SECOND AMENDED VERIFIED COMPLAINT -against- Plaintiff (s), Index # 23444/2016E BERNARDO E. HIDALGO and SANDRA LIMO, LLC a/k/a SANDRA LIMOUSINE, LLC Defendant (s), ----------------------------------------------------------------------------X Plaintiff(s), complaining of the defendants by her attorney upon information and belief, respectfully allege(s): AS AND FOR A FIRST CAUSE OF ACTION ON BEHALF OF PLAINTIFF MOHAMED SAAD 1. That at all the times herein mentioned, the defendant BERNARDO E. HIDALGO, was and still is a resident of the County of Queens the State of New York, residing at 111-29 44 Ave. Corona, New York 11416. 2. That at all the times herein mentioned, the defendant SANDRA LIMO, LLC a/k/a SANDRA LIMOUSINE, LLC (thereafter SANDRA LIMO, LLC ) was and still is a domestic business corporation duly organized and existing under and by virtue of the laws of State of New York and doing business in the State of New York. 3. That at all the times herein mentioned, the plaintiff MOHAMED SAAD, was and still is a resident of the County of BRONX the State of New York, residing at 1224 Walton Ave. 3F Bronx, NY 10452 4. That on or about October 31, 2015 on a public highway called Atlantic Ave. at or near its 2 of 17
intersection with Woodhaven Blvd. Queens, New York, a motor vehicle bearing Registration #: T510516C, NY State came into contact with a motor vehicle bearing Registration #: U45EPP, NY State. 5. That on or about October 31, 2015on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, a motor vehicle bearing Registration #: T510516C, NY State came into contact with a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 6. That on or about October 31, 2015 on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO E. HIDALGO was the operator of the motor vehicle owned by SANDRA LIMO, LLC bearing Registration #: T510516C, NY State which came into contact with a motor vehicle bearing Registration #: U45EPP, NY State in which plaintiff was lawfully seated. 7. That on or about October 31, 2015 on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO E. HIDALGO operated a motor vehicle bearing Registration #: T510516C, NY State, which came into contact with a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 8. That on or about October 31, 2015on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO E. HIDALGO negligently drove a motor vehicle bearing Registration #: T510516C, NY State into a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 9. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned by defendant, SANDRA LIMO, LLC and controlled and maintained 3 of 17
by defendant BERNARDO E. HIDALGO. 10. That at all times relevant to this action, Motor vehicle bearing Registration #: T510516C, NY State was operated by defendant BERNARDO E. HIDALGO with the permission and consent of the owner. 11. That at all times relevant to this action, motor vehicle bearing Registration # T510516C, NY State was operated by defendant BERNARDO E. HIDALGO within the scope of that permission and consent. 12. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned, controlled and maintained by defendant SANDRA LIMO, LLC 13. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned, controlled and maintained by defendant BERNADO E. HIDALGO 14. That at all times relevant to this action and prior thereto, defendant, BERNARDO E. HIDALGO, was an employee of the defendant SANDRA LIMO, LLC 15. That at all times relevant to this action, motor vehicle bearing New York State license plate T510516C, NY State was operated by the defendant BERNARDO E. HIDALGO within the scope of his employment. 16. At all relevant times, it was the duty of defendants, to operate, keep and maintain said motor vehicle in a reasonable state of repair and in good and safe condition, and not to suffer and permit said motor vehicle become dangerous to plaintiff. 17. That the liability of defendants arise from the use, operation or ownership of a motor vehicle within the meaning of CPLR 1602; a non-delegable duty; the doctrine of respondeat superior; and reckless disregard of defendant for the safety of others within the meaning of CPLR 1602; and accordingly to the extent that limited liability would impair, modify, abrogate or 4 of 17
restrict the right of plaintiff as against said defendants, defendants are not entitled to invoke the limited liability provisions of Article 16 of the CPLR and to the extent, if any, that any defendants in this action contend that any of the employers of plaintiff bears any culpability: with respect to the injuries of plaintiff, the benefits of CPLR 1602 are claimed by plaintiff. 18. That the defendant, his agents, servants and/or employees acted with reckless disregard for the well-being of the plaintiff, were negligent, careless, willful and wanton in ownership, control, maintenance and operation their vehicle at a rapid and excessive rate of speed under the circumstances then existing; in failing to obey traffic signals; in operating their vehicle with ineffectual brakes, appliances and other devices; in failing to have their vehicle under proper control; in causing and permitting their vehicle to collide with and strike plaintiff vehicle, and/or plaintiff, and/or vehicle in which plaintiff was seated; in failing to give any notice or warning of their vehicle's approach; in failing to exercise that degree of care required of a prudent person operating a motor vehicle on a public highway; in failing to give plaintiff's vehicle or each other the right of way; in failing to keep a proper look out; in operating a motor vehicle violation of the statutes, ordinances, rules and regulations made and provided therefore including but not limited to violation of New York State Vehicle and Traffic Law Sections 116, 375, 600, 1100, 1101, 1110, 1111, 1112, 1113, 1120, 1127, 1128, 1129, 1141, 1142, 1143, 1146, 1151, 1160, 1163, 1172, 1180, 1180(e), and 1213; being liable under the doctrine of res ipsa loquitor, and, in otherwise causing the damages sustained by plaintiff; all in violation of the statutes, ordinances, rules and regulations made and provided therefore. 19. That this action falls within one or more of the exceptions set forth in CPLR 1602. 20. That plaintiff sustained serious injuries and economic loss greater than basic economic loss as defined by 5104 of the Insurance Law of the State of New York. 5 of 17
21. Solely as a result of the defendant s negligence, willful, wanton and gross negligence as aforesaid, plaintiff has sustained a serious personal injury and/or impairment which resulted in dismemberment; significant disfigurement; fracture; permanent loss of a body organ, or member; permanent consequential limitation of use of a body organ or member; significant limitation of use of a body function or system; loss of normal pursuits and pleasures of life; and/or a medically determined injury or impairment which prevents plaintiff from performing substantially all of the material acts which constituted plaintiff's usual and customary activities for such period of time all as specified by Section 5102 of the Insurance Law, Subsection (d); in all to their damages both compensatory and exemplary in an amount, which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction and which warrants the jurisdiction of this Court. AS AND FOR A SECOND CAUSE OF ACTION ON BEHALF OF PLAINTIFF SOPHIA MARRERO 22. Plaintiff hereby repeats, reiterates, and re-alleges each and every allegation in paragraphs 1 through 21 with the same force and effect as if more fully and at length set forth herein. 23. That at all the times herein mentioned, the defendant BERNARDO E. HIDALGO, was and still is a resident of the County of Queens the State of New York, residing at 111-29 44 Ave. Corona, New York 11416. 24. That at all the times herein mentioned, the defendant SANDRA LIMO, LLC was and still is a domestic business corporation duly organized and existing under and by virtue of the laws of State of New York and doing business in the State of New York. 25. That at all the times herein mentioned, the plaintiff SOPHIA MARRERO, was and 6 of 17
still is a resident of the County of QUEENS the State of New York, residing at 97-20 Van Wyck apt. D3 South Richmond Hill, New York 11419 26. That on or about October 31, 2015on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, a motor vehicle bearing Registration #: T510516C, NY State came into contact with a motor vehicle bearing Registration #: U45EPP, NY State. 27. That on or about October 31, 2015on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, a motor vehicle bearing Registration #: T510516C, NY State came into contact with a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 28. That on or about October 31, 2015 on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO E. HIDALGO was the operator of the motor vehicle owned by SANDRA LIMO, LLC bearing Registration #: T510516C, NY State which came into contact with a motor vehicle bearing Registration #: U45EPP, NY State in which plaintiff was lawfully seated. 29. That on or about October 31, 2015 on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO E. HIDALGO operated a motor vehicle bearing Registration #: T510516C, NY State, which came into contact with a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 30. That on or about October 31, 2015on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO 7 of 17
E. HIDALGO negligently drove a motor vehicle bearing Registration #: T510516C, NY State into a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 31. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned by defendant, SANDRA LIMO, LLC., and controlled and maintained by defendant BERNARDO E. HIDALGO. 32. That at all times relevant to this action, Motor vehicle bearing Registration #: T510516C, NY State was operated by defendant BERNARDO E. HIDALGO with the permission and consent of the owner. 33. That at all times relevant to this action, motor vehicle bearing Registration # T510516C, NY State was operated by defendant BERNARDO E. HIDALGO within the scope of that permission and consent. 34. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned, controlled and maintained by defendant SANDRA LIMO, LLC 35. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned, controlled and maintained by defendant BERNADO E. HIDALGO 36. That at all times relevant to this action and prior thereto, defendant, BERNARDO E. HIDALGO, was an employee of the defendant SANDRA LIMO, LLC 37. That at all times relevant to this action, motor vehicle bearing New York State license plate T510516C, NY State was operated by the defendant BERNARDO E. HIDALGO within the scope of his employment. 8 of 17
38. At all relevant times, it was the duty of defendants, to operate, keep and maintain said motor vehicle in a reasonable state of repair and in good and safe condition, and not to suffer and permit said motor vehicle become dangerous to plaintiff. 39. That the liability of defendants arise from the use, operation or ownership of a motor vehicle within the meaning of CPLR 1602; a non-delegable duty; the doctrine of respondeat superior; and reckless disregard of defendant for the safety of others within the meaning of CPLR 1602; and accordingly to the extent that limited liability would impair, modify, abrogate or restrict the right of plaintiff as against said defendants, defendants are not entitled to invoke the limited liability provisions of Article 16 of the CPLR and to the extent, if any, that any defendants in this action contend that any of the employers of plaintiff bears any culpability: with respect to the injuries of plaintiff, the benefits of CPLR 1602 are claimed by plaintiff. 40. That the defendant, his agents, servants and/or employees acted with reckless disregard for the well-being of the plaintiff, were negligent, careless, willful and wanton in ownership, control, maintenance and operation their vehicle at a rapid and excessive rate of speed under the circumstances then existing; in failing to obey traffic signals; in operating their vehicle with ineffectual brakes, appliances and other devices; in failing to have their vehicle under proper control; in causing and permitting their vehicle to collide with and strike plaintiff vehicle, and/or plaintiff, and/or vehicle in which plaintiff was seated; in failing to give any notice or warning of their vehicle's approach; in failing to exercise that degree of care required of a prudent person operating a motor vehicle on a public highway; in failing to give plaintiff's vehicle or each other the right of way; in failing to keep a proper look out; in operating a motor vehicle violation of 9 of 17
the statutes, ordinances, rules and regulations made and provided therefore including but not limited to violation of New York State Vehicle and Traffic Law Sections 116, 375, 600, 1100, 1101, 1110, 1111, 1112, 1113, 1120, 1127, 1128, 1129, 1141, 1142, 1143, 1146, 1151, 1160, 1163, 1172, 1180, 1180(e), and 1213; being liable under the doctrine of res ipsa loquitor, and, in otherwise causing the damages sustained by plaintiff; all in violation of the statutes, ordinances, rules and regulations made and provided therefore. 41. That this action falls within one or more of the exceptions set forth in CPLR 1602. 42. That plaintiff sustained serious injuries and economic loss greater than basic economic loss as defined by 5104 of the Insurance Law of the State of New York. 43. Solely as a result of the defendant s negligence, willful, wanton and gross negligence as aforesaid, plaintiff has sustained a serious personal injury and/or impairment which resulted in dismemberment; significant disfigurement; fracture; permanent loss of a body organ, or member; permanent consequential limitation of use of a body organ or member; significant limitation of use of a body function or system; loss of normal pursuits and pleasures of life; and/or a medically determined injury or impairment which prevents plaintiff from performing substantially all of the material acts which constituted plaintiff's usual and customary activities for such period of time all as specified by Section 5102 of the Insurance Law, Subsection (d); in all to their damages both compensatory and exemplary in an amount, which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction and which warrants the jurisdiction of this Court AS AND FOR A THIRD CAUSE OF ACTION ON BEHALF 10 of 17
OF PLAINTIFF CORY MARRERO infant by m\l\g SOPHIA MARRERO 44. Plaintiff hereby repeats, reiterates, and re-alleges each and every allegation in paragraphs 1 through 42 with the same force and effect as if more fully and at length set forth herein. 45. That at all the times herein mentioned, the defendant BERNARDO E. HIDALGO, was and still is a resident of the County of Queens the State of New York, residing at 111-29 44 Ave. Corona, New York 11416. 46. That at all the times herein mentioned, the defendant SANDRA LIMO, LLC was and still is a domestic business corporation duly organized and existing under and by virtue of the laws of State of New York and doing business in the State of New York. 47. That at all the times herein mentioned, the plaintiff CORY MARRERO, was and still is a resident of the County of QUEENS the State of New York, residing at 97-20 Van Wyck apt. 3D South Richmond Hill, New York 11419 48. That on or about October 31, 2015on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, a motor vehicle bearing Registration #: T510516C, NY State came into contact with a motor vehicle bearing Registration #: U45EPP, NY State. 49. That on or about October 31, 2015on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, a motor vehicle bearing Registration #: T510516C, NY State came into contact with a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 50. That on or about October 31, 2015 on a public highway called Atlantic Ave. at or near 11 of 17
its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO E. HIDALGO was the operator of the motor vehicle owned by SANDRA LIMO, LLC bearing Registration #: T510516C, NY State which came into contact with a motor vehicle bearing Registration #: U45EPP, NY State in which plaintiff was lawfully seated. 51. That on or about October 31, 2015 on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO E. HIDALGO operated a motor vehicle bearing Registration #: T510516C, NY State, which came into contact with a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 52. That on or about October 31, 2015on a public highway called Atlantic Ave. at or near its intersection with Woodhaven Blvd. Queens, New York, the defendant BERNARDO E. HIDALGO negligently drove a motor vehicle bearing Registration #: T510516C, NY State into a motor vehicle bearing Registration#: U45EPP, NY State in which plaintiff was lawfully seated. 53. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned by defendant, SANDRA LIMO, LLC, and controlled and maintained by defendant BERNARDO E. HIDALGO. 54. That at all times relevant to this action, Motor vehicle bearing Registration #: T510516C, NY State was operated by defendant BERNARDO E. HIDALGO with the permission and consent of the owner. 55. That at all times relevant to this action, motor vehicle bearing Registration # T510516C, NY State was operated by defendant BERNARDO E. HIDALGO within the scope of 12 of 17
that permission and consent. 56. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned, controlled and maintained by defendant SANDRA LIMO, LLC 57. That at all times relevant to this action, motor vehicle bearing Registration #: T510516C, NY State was then owned, controlled and maintained by defendant BERNADO E. HIDALGO 58. That at all times relevant to this action and prior thereto, defendant, BERNARDO E. HIDALGO, was an employee of the defendant SANDRA LIMO, LLC 59. That at all times relevant to this action, motor vehicle bearing New York State license plate T510516C, NY State was operated by the defendant BERNARDO E. HIDALGO within the scope of his employment. 60. At all relevant times, it was the duty of defendants, to operate, keep and maintain said motor vehicle in a reasonable state of repair and in good and safe condition, and not to suffer and permit said motor vehicle become dangerous to plaintiff. 61. That the liability of defendants arise from the use, operation or ownership of a motor vehicle within the meaning of CPLR 1602; a non-delegable duty; the doctrine of respondeat superior; and reckless disregard of defendant for the safety of others within the meaning of CPLR 1602; and accordingly to the extent that limited liability would impair, modify, abrogate or restrict the right of plaintiff as against said defendants, defendants are not entitled to invoke the limited liability provisions of Article 16 of the CPLR and to the extent, if any, that any defendants in this action contend that any of the employers of plaintiff bears any culpability: with respect to the injuries of plaintiff, 13 of 17
the benefits of CPLR 1602 are claimed by plaintiff. 62. That the defendant, his agents, servants and/or employees acted with reckless disregard for the well-being of the plaintiff, were negligent, careless, willful and wanton in ownership, control, maintenance and operation their vehicle at a rapid and excessive rate of speed under the circumstances then existing; in failing to obey traffic signals; in operating their vehicle with ineffectual brakes, appliances and other devices; in failing to have their vehicle under proper control; in causing and permitting their vehicle to collide with and strike plaintiff vehicle, and/or plaintiff, and/or vehicle in which plaintiff was seated; in failing to give any notice or warning of their vehicle's approach; in failing to exercise that degree of care required of a prudent person operating a motor vehicle on a public highway; in failing to give plaintiff's vehicle or each other the right of way; in failing to keep a proper look out; in operating a motor vehicle violation of the statutes, ordinances, rules and regulations made and provided therefore including but not limited to violation of New York State Vehicle and Traffic Law Sections 116, 375, 600, 1100, 1101, 1110, 1111, 1112, 1113, 1120, 1127, 1128, 1129, 1141, 1142, 1143, 1146, 1151, 1160, 1163, 1172, 1180, 1180(e), and 1213; being liable under the doctrine of res ipsa loquitor, and, in otherwise causing the damages sustained by plaintiff; all in violation of the statutes, ordinances, rules and regulations made and provided therefore. 63. That this action falls within one or more of the exceptions set forth in CPLR 1602. 64. That plaintiff sustained serious injuries and economic loss greater than basic economic loss as defined by 5104 of the Insurance Law of the State of New York. 65. Solely as a result of the defendant s negligence, willful, wanton and gross negligence 14 of 17
as aforesaid, plaintiff has sustained a serious personal injury and/or impairment which resulted in dismemberment; significant disfigurement; fracture; permanent loss of a body organ, or member; permanent consequential limitation of use of a body organ or member; significant limitation of use of a body function or system; loss of normal pursuits and pleasures of life; and/or a medically determined injury or impairment which prevents plaintiff from performing substantially all of the material acts which constituted plaintiff's usual and customary activities for such period of time all as specified by Section 5102 of the Insurance Law, Subsection (d); in all to their damages both compensatory and exemplary in an amount, which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction and which warrants the jurisdiction of this Court WHEREFORE, the plaintiff demands judgment both compensatory and exemplary against the defendant in the FIRST, SECOND and THIRD causes of action in an amount which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction and which warrants the jurisdiction of this Court; together with the costs and disbursements of each cause of action. Yours, etc. /S/Alexander Roytblat Alexander Roytblat, Esq. Attorneys for Plaintiff 15 of 17
STATE OF NEW YORK) COUNTY OF QUEENS) The undersigned, an attorney admitted to practice in the Courts of the State of New York, states that affirmant is a member of the firm of KALANT & ROYTBLAT, PLLC, the attorneys for the plaintiff(s) that affirmant(s) has read the foregoing SECOND AMENDED SUMMONS AND COMPLAINT and know(s) the contents thereof, and that same is true to the affirmant s knowledge, except as to the matters therein stated to be alleged upon information and belief, and that as to those matters affirmant believes to be true. That reason this verification is made by affirmant and not by the plaintiff(s), plaintiff(s) reside outside of the county where the affirmant s office is located. The source of affirmant s knowledge and the grounds of belief as to those matters therein stated to be alleged on information and belief are correspondence and investigations which have been made concerning the subject matter in this action, and which are in possession of the said attorneys. The undersigned affirms that foregoing statements are true, under the penalties of perjury. DATE: ELMHURST, NEW YORK SEPTEMBER 15, 2016 /S/Alexander Roytblat ALEXANDER ROYTBLAT, ESQ. 16 of 17
Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX ----------------------------------------------------------------------------------------------------------------X MOHAMED SAAD, SOPHIA MARRERO and CORY MARRERO infant by m\l\g SOPHIA MARRERO, Plaintiff (s), -against- BERNARDO E. HIDALGO and SANDRA LIMO, LLC a/k/a SANDRA LIMOUSINE, LLC Defendant (s), ------------------------------------------------------------------------------------------------------------X SUMMONS and COMPLAINT Attorney(s) for KALANT & ROYTBLAT, PLLC Attorney for Plaintiff Office and Post Office Address, Telephone 91-31 Queens Blvd. Ste. 313 TELEPHONE (718) 872-6374 "WE DO NOT ACCEPT SERVI CE BY ELECTRONI C TRANSM I SSI ON (FAX)" Service of a copy of the within Dated:, is hereby admitted... Attorney(s) for KALANT & ROYTBLAT, PLLC Attorney for Plaintiff 91-31 Queens Blvd. Ste. 313 Elmhurst, Queens 1137 718-872-6374 17 of 17