INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

SUPREME

COURT

OF THE

COUNTY

OF KINGS

NEW YORK

OF

STATE

Filed:

CHRISTOPHER

INDEX

LYLES,

NO:

Plaintiff

Plaintiff,

designates
as the

County

Kings

place

of

trial.

-against-

THE

OF NEW

CITY

YORK

OF THE

CORRECTIONS

and

THE

OF NEW

CITY

S U

M M O

The

basis

YORK,

of

1352
Far

the

YOU
a copy

of

HEREBY

ARE

your

answer

exclusive

summons,

of

is complete

summons

the

on
the

SUMMONED
attorneys

of

of

service

summons

this

is

Dickens

Street

Rockaway,

NY

11692

Defendant:

to answer

plaintiffs

day

if this

above-named

venue

residence:

PlaintifTs
Defendants.

To

N S

OF

DEPARTMENT

the
20

within

in this

complaint
days

after

the

or within

summons,

is not

personally

delivered

to you

this

summons,

a judgment

by

default

the

costs

after

within

and

of

service
days

30

action

the

to serve

this
service
State

York.
In case
against

Dated:

you

New
August

for

of
the

York,
29,

your
relief

New

failure

to answer

demanded

in the

together

complaint,

with

York

2019

THE

LEVY

A

IRM,

By:
Ja

for

Attorney
233

New
(212)

1 of 14

Broa
York.

Le

iÈ4.

Pla

way,

New

227-1222

y
tiff

Suite
York

2200
10279

P.C.

will
of

this

be taken
action.

of

this

of New

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

THE

RECEIVED NYSCEF: 08/29/2019

CITY

OF NEW

Corporation

Counsel

100

Church

Street

New

York.

New

Church

New

York,

10007

OF CORRECTIONS

DEPARTMENT
100

York

YORK

OF THE

Street

New

York

10007

2 of 14

CITY

OF NEW

YORK

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

SUPREME

COURT

OF THE

COUNTY

OF KINGS

OF NEW

STATE

YORK

INDEX
CHRISTOPHER

NO:

LYLES,

VERIFIED

COMPLAINT

Plaintiff,
-against-

THE

OF NEW

CITY

CORRECTIONS

YORK

OF THE

DEPARTMENT

and

OF NEW

CITY

OF

YORK.

Defendants.

Plaintiff,
Complaint,

his

by

resident

of

the

of

County

Queens

was

and

laws

of

still

Notice

State

3.

Within
prior

of

FOR

commenced

with

the

days

of

action.

YORK

year

information
with

after

all

has
for

the

of the
the

duly

days

said

cause

cause

of

this

action,

ninety

days

and

belief.

that

conditions

such
herein,

served
of

cases
and
and

damages

3 of 14

OF

of

action

accrued

herein,

still

is a

and

more

than

thirty

a Notice

by

of
the

and
days

Claim

plaintiff

than
and

served,

of

this

provided

more

action

this

of

the

thirty

filed
was

a
so

herein.

commencement
of

YORK,

virtue

by

and

and

YORK,

accrued

brining

and

presented,

duly

action

made

sustained

and

OF NEW

CITY
under

OF NEW

to the

filed

was

ACTION

existing

plaintiff

to the

Verified

mentioned

THE

and

said

prior

herein

defendant,

CITY

after

precedent

in

presented,

an adjustment

THE

his

York.

organized

the

and

accrued

the

after

with

New

times

CAUSE

duly

claim

statute

of

mentioned,

commencement

one

provisions

ninety

NEW

(90)

regarding

4. Upon

this

ninety

State

for

belief:

at all

A.FIRST

Corporation,
York.

within

complied

hereinafter

of New

to the

Claim

duly

times

is a Municipal

the

days

(30)

at all

the

as and

P.C..

FIRM,

and

LYLES,

and

AS AND
2. That

information

CHRISTOPHER

plaintiff,

LAW

LEVY

upon

alleges,

respectfully
1. The

THE

attorneys.

this

action,

and

in

a particular,

prior
herein

herein,

plaintiff

action.

to the
with
upon

has

complied
and

within

commencement

THE
which

CITY
this

OF

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

cause

of

days

action

is based,

refused

remains

to and

unpaid

and

that

neglected

and

after

to make

OF NEW

CITY

an adjustment

although

unadjusted,

THE

said

or payment

plaintiff

has

YORK

for

on

claim.

said

demanded

duly

that

more

than

said

the

same

thirty

claim
be paid

and

adjusted.

the

5. That

all

6. That

at all

Brooklyn

and

House

State

New

of

7. That
operated

Kings,

the

and

maintained

Kings,

the

the

Kings,

10.

That
the

managed

times

and

11.

That

That

the

located

times

been

held.

THE

defendant

at 275

Atlantic

Avenue,

CITY

OF NEW

in the

County

CITY

OF NEW

YORK

of

owned

Kings,

City

times

of

Detention

hereinafter

New

York.

times

located

THE

at 275

the

of

County

OF NEW

CITY

Atlantic

THE

defendant

located

at 275

Atlantic

Avenue.

OF

CITY

YORK

in the

of

County

NEW YORK
in

Avenue,

to work

Kings,

City

hereinafter

officers

who

located

mentioned,
at the
and

mentioned,
work

at 275

the

of

County

at the

2

4 of 14

of New
the
Brooklyn

Avenue.

THE

House

of

OF NEW

CITY

Atlantic

defendant,

Brooklyn
State

THE

defendant

mentioned,

Detention

hereinafter

officers
of

in

Avenue,

York.

of

times

Atlantic

defendant

mentioned.

Detention

House

at all

at 275

YORK

York.

New

of

correction

of

House

State

located

mentioned,

hereinafter

times

THE

defendant

York.

New

at all

at all

Detention

House
of

mentioned.

hereinafter

of

County

of

New

of

State

correction
in the

have

mentioned,

hereinafter

House

Brooklyn

City

12.

Detention

Brooklyn
and

employed

Avenue,

State
at all

City

law

by

hereinafter

Brooklyn

and

City

controlled

of

State
at all

9. That
managed

times

Brooklyn

City

required

York.

at all

8. That

Kings,

hearings

CITY

Detention

YORK

in the

OF NEW
located

of

County

YORK

at 275

Atlantic

York.
defendant,
House

THE
of

CITY

Detention

OF NEW
located

YORK
at 275

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

Atlantic

Avenue.

in the

13. That
supervised
275

the

Atlantic

the

at all

15. That

Avenue,

at all

in the

at all

Kings,

times

hereinafter

incarcerated

in the

County

of

controlled

the
in the

at all

times

inmates

of

County

Kings,

set forth

Plaintiff

CHRISTOPHER

without
with

Brooklyn

and

FOR

of

House

or about

February

20,

realleges

at 275

located

OF NEW

CITY

at 275

located

THE

YORK

Atlantic

NEW YORK

OF

CITY

Detention

at 275

located

THE

defendant,
of

Atlantic

OF NEW

CITY

Detention

at 275

located

YORK
Atlantic

York.

paragraphs

and

Detention

YORK

York.

CAUSE

reiterates

of

THE

defendant,

A SECOND

repeats.

OF NEW

CITY

York.

of New

State

at

OF ACTION
"1"

through

as if more

"17",

fully

herein.
19. That

Atlantic

the

located

York.

Detention

House

mentioned,

City

of

Detention

York.

defendant,

of New

State

at the

incarcerated

the

New

of

NEW YORK

OF

CITY

THE

House
of

of New

Brooklyn

and

hereinafter

AS AND
18.

City

defendant,

House

mentioned,
at the

Kings,

the

State

of New

State

State

Brooklyn

and

City

House

Brooklyn

mentioned,

THE

Brooklyn

and

and

York.

defendant.

the

at the

City

at the

inmates

17. That

Avenue,

hereinafter

the

supervised

Avenue,

of

at the

City

work

Kings,

incarcerated

County

16. That

of

the

mentioned,

who

County

times

inmates

Kings,

hereinatter

officers

in the

of

work

of New

State

mentioned,

County

times

correction

Avenue,

the

the

and

City

to who

officers
in

Kings,

hereinafter

correction

That

controlled

managed

times

Avenue.

I4.

Atlantic

at all

of

County

on

LYLES

Avenue

in

20.

or knife
That

like

incarcerated
of

County

cause

justification,
a knife

the

was

2019

Kings,

at the

City

or provocation,

sharp

on or about

at or about
Brooklyn

and

State

negligently

I1:00
House

of

New

assaulted,

a.m.,
of
York,

while

the

Detention
was,

battered.

by

plaintiff,
located

at 275

a fellow

inmate,

lacerated

and/or

cut

object.

February

20,

2019,

3

5 of 14

at or about

11:00

a.m.,

while

the

plaintiff

was

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

incarcerated
of

at the

Kings,

or knife

like

direction

of

the

time

one

of

the

House
of New

State
object

sharp

21.

or more

a result

has

damaged
have

That

of

damage

without
inmate
of

THE

the

has

to their

property
of

and

the

lacerated

battered,

and/or

under

the

were

acting

in the

scope

on
of

Constitutions

OF NEW

in the

County

with

a knife

cut

supervision,

and

control,

of their

aforesaid

employment

at

guard

security

physical

permanent

the jurisdictional

and

limits

of

psychological

all

lower

courts

20,

the

United

in the

the

custody

just

cause

was

and

New

its

or

servants,

of

and/or

just

others
cut

and/or

agents,

without

fact,

or more

on

their

plaintiff,

correction

without

cause,

by

fear
and

property
a fellow

officers

in

the

laws.

statutes.

employ

or notice.

of the

State

herein.

lacerate
one

in

contained

plaintiff,

of New
York,

York,
were

under
the

the
United

violated

States

by

the

cut

while

rules

Government

defendant,

THE

respects:

assaulted,
of

or

rights

and

States

following

Plaintiff

of

allegation

every

or persons

warning

the

York

in law

batter,

without

and

YORK,

property

direction

2019,

of New

City

basis

or the

ACTION

set forth

OF NEW

assault,

all

YORK,

each

fully

without

and

CAUSE_OF

realleges

CITY

plaintiff,

February

YORK
a.

THE

this

of

the

by

serious,

as more

"21",

control,

the

battery

exceeding

or persons,

OF NEW

That

regulations

Avenue,

acting

and

suffered

and

authority,

supervision,

CITY

and

Atlantic

was

FOR A THIRD

reiterates

through

lawful

at the

who

assault

in a sum

defendant.

provocation

24.

CITY

"1"

without

employees,

who

at 275

jurisdiction.

repeats,

number
23.

inmate

foregoing

LYLES,

been

Plaintiff

paragraphs

assaulted,

officers

AS AND
22.

located

was

York

correction

of the

otherwise

would

Detention

incident.

As

and

injuries,

of

a fellow

by

CHRISTOPHER

plaintiff,

that

and

City

Brooklyn

the

defendant,

provocation.

4

6 of 14

lacerated

battered,
its

agents,

and/or
servants

and/or

detained

employees

and
without

in

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

b.

Plaintiff

deprived

was

Constitution
Rights
25.

OF NEW
serious

That

physical
and

26.
costs

That

incurred
27.

of

of

reason

reason

by

a sum

together

jurisdiction,

28.

Plaintiff

paragraphs

"1"

at all

CORRECTIONS

and

30.

thirty

(30)

days

filed

a Notice

THE

CITY

days

after

duly

of

said

complied

Upon

NEW
action

with

all

under

and

fees

of

of

rights

all

and

realleges

as more

his

to

lower

costs

Civil

THE

defendant,

to severe

secured

the

commencement
said
and

accrued

herein.
and

conditions

the

of
claim

this

belief.

of

CITY
and

the

by

that

precedent

5

7 of 14

the

laws

of

this

action,

of

action

to the

to the

has

that

fees

and

been

would

otherwise

in prosecuting

this

action.

ACTION
allegation

contained

DEPARTMENT

still
the

in

State

of

duly

Corporation,

New

herein,

York.

and

presented,

within

one

of this

year

of this

action,

and

than

more

and

served,

OF CORRECTIONS

commencement

brining

OF

is a Municipal

accrued

plaintiff

so commenced

prior

attorney's

LYLES,

every

DEPARTMENT

was

of

herein.

and

cause

with

action

and

defendant,

was

YORK,

after

days

cost

incurred

set forth

fully

virtue

by

full

courts

OF

each

mentioned,

and

YORK,

the

the

by

subject

CHRISTOPHER

limits

OF NEW

regarding

information

was

is entitled

plaintiff,

attorney's

"27",

(90)

the

by

plaintiff

FOR A FOURTH_CAUSE

CITY

to the

Claim

said

hereinafter

ninety

prior

OF

31.

times

rights

deprived

plaintiff

foregoing,

reiterates

existing

Within

employees,

the jurisdictional

OF THE

organized

action.

through

as provided

States

the

by

States.

this

AND

secured

et seq.)
of the

in being

foregoing,

with

United

1983

§§

and/or

the

the

repeats,

number
That

of

exceeding

AS

duly

of

the

violation

harm

United

of

or immunities

privileges

rights,

laws

U.S.C.

servants,

the

the

aforesaid

psychological

laws

by

That

29.

the

in prosecuting

in

damaged
have

and

(42

Act

its agents,

YORK,

Constitution

reason

by

and

of

and

action,
has

OF
ninety

plaintiff
complied

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

with

the

provisions

ninety

days

of

action,

this

of

after

the

has

DEPARTMENT
damages
said

duly

remains

in such

accrued

by

served

presented,

and
and

plaintiff

and

neglected

and

more

than

filed

which

OF THE

and
days

thirty
of

has

prior

Claim

this

of

cause

on

demanded

commencement

is based,
for

and

more
said

claim.

that

within

an adjustment

YORK
said

and

with

for

action

OF NEW

duly

to the

herein

YORK

or payment

plaintiff

in a particular,

OF NEW

CITY

an adjustment

although

provided

a Notice
CITY

upon

herein,

to make

unadjusted.

made

OF THE

OF CORRECTIONS

to and

unpaid

the

cases

herein,

OF CORRECTIONS

sustained

refused

statute

cause

DEPARTMENT

days

the

the

of
that
than

after

thirty

claim

same

be paid

and

adjusted,
32.

That

all

33.

That

at all

CORRECTIONS
located

at 275
34.

That

CORRECTIONS
located

at 275
35.

That

CORRECTIONS
located

at 275
36.

That

CORRECTIONS
located

at 275
37.

That

CORRECTIONS
located

at 275

hearings
times

OF THE
Atlantic
at all

times

at all

OF THE
Atlantic
at all

OF THE
Atlantic
at all

Avenue.
times

OF THE
Atlantic

the

Avenue,

Kings,

of

in the

OF
in the

of

County

City

operated

Kings,

City

defendant

Kings,

City

defendant

NEW YORK

managed

of

OF NEW

Kings,

6

8 of 14

of

City

defendant

YORK

County

Brooklyn

controlled

Kings,

City

State

and

OF

House
of

of

New

DEPARTMENT
the

Brooklyn

and

State

the
and

Brooklyn
State

of

Brooklyn

and

State

and

House

New

of

of

Detention

York.

OF
of

House

Brooklyn
State

York.

OF

New

DEPARTMENT
the

of Detention

New

DEPARTMENT
the

York.

House
of

Detention

OF

DEPARTMENT

maintained

mentioned.

in the

the

mentioned,

County

DEPARTMENT

defendant

NEW YORK

OF

hereinafter
CITY

owned

YORK

County

held.

defendant

mentioned,

hereinafter
CITY

of

County

OF NEW
in

been

mentioned,

hereinafter

Avenue,
times

in the

CITY

have

NEW YORK

hereinafter

CITY

law

mentioned,

OF

CITY

Avenue.
times

by

hereinafter

Avenue,

OF THE
Atlantic

required

Detention

York.

OF
House

of New

York.

of

Detention

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

38.

That

at all

CORRECTIONS
Brooklyn

39.

of

That

Brooklyn

and

State

at all

of New
That

at the

Kings.

and

Detention

times

and

State

of New

41.

That

at all

times

Brooklyn

House

New

of

That

of New

officers

County

of

to work

Kings,

at the
and

City

managed

Atlantic

mentioned,

the

DEPARTMENT

defendant,
the

correction
in

Avenue,

the

OF

officers

who
of

County

work

Kings,

at

City

YORK
located

DEPARTMENT

defendant,

supervised

the

Atlantic

at 275

correction

OF

officers
in the

Avenue,

to who
of

County

York.

mentioned,

OF NEW

Detention

located

YORK
at 275

the

DEPARTMENT

defendant,
the

controlled
Atlantic

correction

officers

in the

Avenue,

OF

County

who
of

work

Kings,

City

at all

times

of

Detention

hereinafter
CITY

mentioned,

OF NEW

located

at 275

YORK

the

managed

Atlantic

DEPARTMENT

defendant,
the

Avenue,

inmates

in the

OF

incarcerated

at the

of

City

County

Kings,

and

York.
at all

times

OF THE

House

44.

in the

Avenue,

at 275

Detention

CITY

OF THE

That

of New

correction

OF

York.

CORRECTIONS
Brooklyn

of

of

hereinafter

OF THE

House

43.

employed

the

YORK

OF NEW

CITY

City

Brooklyn

located

hereinafter

House

State

DEPARTMENT

Atlantic

mentioned,

OF NEW

CITY

OF THE

CORRECTIONS

State

hereinafter

Brooklyn

42.

State

of

at all

CORRECTIONS
at the

defendant,

York.

CORRECTIONS
work

YORK

at 275

located

times

OF THE
House

40.

OF NEW

CITY

Detention

mentioned,

York.

CORRECTIONS
the

hereinafter

OF THE

House

of New

State

times

of

Detention

hereinafter
CITY

mentioned,

OF NEW

located

at 275

YORK

the

supervised

Atlantic

DEPARTMENT

defendant,

Avenue,

the

inmates

in the

County

OF
at the

incarcerated
of

Kings,

York.

That

at all

times

hereinafter

mentioned,

7

9 of 14

the

defendant,

DEPARTMENT

OF

City

and

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

CORRECTIONS
Brooklyn

OF THE

House

of New

State

of

OF NEW

CITY

Detention

set

forth

Atlantic

That

on

reiterates

and

or about

February

20,

in the

a knife

inmates

in the

Avenue,

CAUSE

realleges

incarcerated
of

County

at the

Kings.

City

and

ACTION

OF

"I"

paragraphs

incarcerated

at the

Kings,

and

City

or knife

like

direction

of

time

on

through

as if more

"44",

fully

of
48.

the
As

House
of New

by

and

injuries.
would

50.

a result

has

of

a fellow

York,

was,

by

located

at 275

a fellow

inmate,

lacerated

battered,

assaulted,

inmate

who
who

while

a.m.,
at 275

located

was

officers

the

Plaintiff

and/or

cut

the

Atlantic

was
in the

Avenue,
and/or

lacerated

battered,

plaintiff

was

acting

under

the

were

acting

in the

scope

cut

with

a knife

control.

supervision,
of

County

their

employment

security

guard

and

"1"

and

suffered

battery

serious,

by

aforesaid

the

permanent

the jurisdictional

exceeding

physical
limits

and
of

all

psychological
lower

courts

jurisdiction.

repeats,

the

has

in a sum

damaged
have

assault

foregoing

LYLES,

been

otherwise

That

plaintiff.

Detention

of

assaulted,

the

incident.

number

paragraphs

of New

at or about

2019,

Detention

York

AS AND
49.

while

a.m.,

House

State

negligently

of

correction

CHRISTOPHER

plaintiff.

Brooklyn

and

City

20,

February

Brooklyn

or more

one

Kings,

11:00

object.

sharp

or about

State

at the

or provocation,

object

sharp

of

at or about

2019

incarcerated

County

like

or knife
That

was

cause

justification.

47.

that

FOR A FIFTH

repeats.

LYLES

Avenue

without

the

Atlantic

the

herein.

CHRISTOPHER

of

controlled

York.

Plaintiff

46.

with

at 275

located

AS AND
45.

YORK

reiterates

through

defendant,

FOR

"48",

A SIXTH
and

CAUSE
each

realleges

as more

DEPARTMENT

8

10 of 14

fully

OF
and

set forth

ACTION

every

allegation

contained

in

herein.

OF CORRECTIONS

OF THE

CITY

OF NEW

at

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

its servants,

YORK,
fact,

without

just

persons

of

lacerate

and/or

or more

correction

others

on
cut

51.

regulations

and

the

their

plaintiff,

all

20,

Constitutions

of

the

inmate

York

OF CORRECTIONS

DEPARTMENT

at the

or persons,

property
of

this

plaintiff,

supervision,

basis

law

or the

property

assault,

batter,

and

control,

in

direction

OF CORRECTIONS

or
or

of

one

OF THE

or notice.
rights

and

States

their

without

authority.

DEPARTMENT

of

the

2019,

lawful

provocation

warning

United

to

without

employ

of New

City

damage

a fellow

without

February

of the

of

and

in the

YORK,
on

fear

by

without

employees,

property

officers

That

and

and/or

without

cause,

OF NEW

CITY

agents.

of

State

the

New

and

OF THE

New

of

under

plaintiff,

the

York,
were

York,

States
the

by

YORK

statutes.

laws,

United

violated

OF NEW

CITY

the

rules

Government

defendant,

in the

following

respects:
a.

Plaintiff

b.

was

the

custody

just

cause

Plaintiff

of

Constitution

52.

That

by

DEPARTMENT
and/or

deprived
53.

costs

That

incurred
54.

plaintiff

damaged

the

on

by

her

was

rights

(42

reason

of

by

in a sum

reason

exceeding

of

the

the

U.S.C.

of

and/or

cut

servants

agents,

laws

of

the

while

and/or

detained

and

employees

in

without

by

the

this

action.

the

foregoing,

plaintiff,

the jurisdictional

9

11 of 14

limits

rights

by

OF NEW

secured

as provided

the

the

by

by

the

Civil

and

of

laws

is entitled

all

lower

its agents,

and
the

to full

CHRISTOPHER
of

defendant.

YORK,

physical

serious

Constitution
plaintiff

foregoing,

the

CITY
and

States

immunities

et seq.)
of

to severe

subject

or

United

1983

§§

OF THE

privileges

rights,

violation

aforesaid

secured

in prosecuting
That

and

Act
of

its

defendant,

deprived

OF CORRECTIONS

employees,

being

reason

the

lacerated

battered,

or provocation.
was

Rights

assaulted,

courts

psychological

United

cost

servants,

of

LYLES,
that

harm

in

States.
attorney's

has
would

fees

been
otherwise

and

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

have

together

jurisdiction,

the

WHEREFORE,
Defendant
have
all

lower

sum
on

in a sum

jurisdiction

that

Third

Cause

would

otherwise
limits

Cause

Action;

and

have

jurisdiction

otherwise
disbursements

Dated:

New
August

of

York,
29,

this

of

otherwise

have
of

fees

have

and

in a sum

on

Sixth

that

would

otherwise

the jurisdictional

limits

of

have

limits
together

of

all

with

lower

TH§

the

New
(212)

10

12 of 14

for

Suite

Broadway,
York,

New

227-1222

FIRM,

Plaintiff

York

2200
10279

on

costs

evy

AW

LEVY

Attdrneys
233

B.

all

courts

2019

Ipmil

of

jurisdiction

York

By:

have

P.C.

and

the

otherwise
limits

of Action;

action.

New

would

in a sum

and

Action;

otherwise

Action;

Cause

action.

against

the jurisdictional

exceeding

that

the jurisdictional
of

courts

Second

Cause

would

Cause

lower

this

judgment

the

courts

Fourth

in prosecuting

demands

all

on

exceeding

that

incurred

in a sum

lower

the

courts

exceeding

on the

all

in a sum

jurisdiction
lower

and

of

jurisdiction

of

costs

LYLES,

limits

Action;

limits

all

and

CHRISTOPHER

Cause

Action;

the jurisdictional
of

First

would

of

attorney's

the jurisdictional

the jurisdictional

exceeding
the

that

said

Plaintiff,

exceeding

on the

courts

with

and

in a

jurisdiction
lower

courts

exceeding
the
that

of

Fifth
would

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

SUPREME

COURT

OF THE

COUNTY

OF KINGS

OF NEW

STATE

YORK

INDEX
CHRISTOPHER

NO:

LYLES.
Plaintiff,

ATTORNEY'S
-against-

THE

VERIFICATION

OF NEW

CITY

CORRECTIONS

YORK

OF THE

and

CITY

DEPARTMENT
OF NEW

OF

YORK,

Defendants.

Jamie
makes

the

B.

a member

the

under

of the

admitted

duly

in the

State

of New

York,

of perjury:

penalty

of THE

firm

law

to practice

LAW

LEVY

attorneys

the

P.C.,

FIRM,

of

record

for

plaintiff.

I have

read

my own

knowledge

and

as to those

that

This
of New

which

grounds

correspondence
is in affirmant's

Dated:

New

York,
29,

Complaint

foregoing

except

as to the

matters,

I believe

them

is made
is the

of

County

affirmant's
with

the

possession.

New

therein

where

belief
said

and
your

contents

stated

as to all

other

not

the

thereof;
on

to be alleged

plaintiff

by

affirmant

maintains

matters

not

pertinent

data

York

2019

JAM

13 of 14

stated

contained

information

plaintiff,

and

the

same

is true

information

and

to
belief

to be true.

affimiant

by

know

and

matters

had

which

August

the

verification

York.

The
are

affirmation

following

I am
the

an attorney

Levy,

- B.

LEV

relating

because

he is not

in the

County

offices.

upon

affirmant's

in the
thereto.

said

knowledge
plaintiffs

file,

 INDEX NO. 519146/2019

FILED: KINGS COUNTY CLERK 08/29/2019 10:59 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/29/2019

COURT

SUPREME
COUNTY

OF THE

YORK

OF KINGS
Index

____

OF NFW

STATE

____

__ - - . . . __-

CHRISTOPHER

No:

- - - - - - - - - . - - - . - - - ________

____

_ ___________

______

LYLES.
Plaintiff,

-against-

THE

OF NEW

CITY

NEW

YORK

and

DEPARTMENT

OF CORRECTIONS

OF THE

CITY

OF

YORK.
Defendants.

__ _________

______

____

_ _ __

__ ___

___ __ _-

- - - - - - - - - __ - __ - - - - - . _ _ ______

____

_______________-

SUMMONS
_______________

__

____

and

_

LEVY

THE
233

for

Broadway.
York,
(212)

14 of 14

New

_____

_______

_ _

_ _ ___

P.C.

FIRM,
Plaintiff
Suite

2200

York

10279

227-1222

- - -

______

COMPLAINT

__________

LAW

Attorneys

New

_ _ _

VERIFIED

_____-

_______

_ _ _______