10.24.14 - taxi complaint

LAW OFFICE OF BARD L. SHOBER, ESQ.1021 S. Main StreetPleasantville, NJ 08232609-343-1790Atty. ID: 033341991Attorney for Plaintiffs

TASNEM AFZAL, MOHAMMAD :SUPERIOR COURT OF NEW JERSEYA. KALAM, MUHAMMAD A. :ATLANTIC COUNTYANSARI, AHAMED N, SIKDER, :CHANCERY DIVISIONSHAKHAUTH HOSSAIN, :MOHAMMAD FARUK, ABU :NASOR, MOHAMMAD J. ALAM, :TAPAN DAY, ABUL AZAD, MD :K. ZAMAN, MD ALI, MOHD R. :KARIM, MOHAMMED HOSSAIN, :IQBAL HOSSEN, MOHAMMED :M. HUSSAIN, AHMED H. :MABROUK, ABDULLAH AL- :FAROOQ, SAYAD ALAM, :MUHAMMAD IBRAR, :MOHAMMAD A. WADUD, :MOHAMMED SHAMSUDDIN, :MOHAMMED KARIM, PULAK :BARUA, KHAIRUZZAM :SHEIKH, MUJIBUR RAHMAN, :MOHOMMED A. ESKANDOR, :SURESH LAMBA, MOHAMMED :I. HOSSAIN, MD H. KABIR, :MOHAMMAD R. ISLAM, :MOHOMMED S. CHOWDHURY, :SONY TAYLOR, FAROOQ :CHOUDHRY, MUSHTAQ KHAN :Plaintiffs, :v. :DOCKET NO. :ADEL HALIM, MYRA COHEN :CIVIL ACTIONTRUST, YAFIE S. OSMAN, :VERIFIED COMPLAINTPERLMAN LEASING INC., :JOHNIE R. WHITE, KING CAB :CO., DAT PHAM, MYMCM, :MONIR GAYED, CITY :SERVICE CAB, INC., MARSEIL :SALAMA, MINH V. HOANG, :MARYANN VASSALOTTI, :OCEAN HEIGHTS TAXI :SERVICE, JOSEPH DEWES, :THE LIMO OF AMERICA CO., :TAXI CAB OF AMERICA, INC., :UNITED TAXI CAB, INC., :JOHN DOE TAXI MEDALLION :OWNERS A to Z, JANE DOE :TAXI LEASE AGENCIES/AGENTS:1 20, JACK DOE TAXI CAB :OWNERS 1 10, :Defendants, : :

The Plaintiffs, Tasnem Afzal et als. through their attorney Bard L. Shober, Esq. of the Law Office of Bard L. Shober, Esq., by way of Complaint against the Defendants Adel Halim et als. herein say that:PARTIES1. The Plaintiff TASNEM AFZAL is a citizen of the State of New Jersey having his principle residence at 3015 Howard Avenue, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 001.2. The Plaintiff MOHAMMAD A. KALAM is a citizen of the State of New Jersey having his principle residence at 205 Abbey Lane, Pleasantville, Atlantic County, New Jersey; and is the leasee of taxi medallion 017.3. The Plaintiff MUHAMMAD A. ANSARI is a citizen of the State of New Jersey having his principle residence at 38 S. Trenton Avenue, 2nd Fl., Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 057.4. The Plaintiff AHAMED N. SIKDER is a citizen of the State of New Jersey having his principle residence at 8 N. Newport Avenue, Ventnor, Atlantic County, New Jersey; and is the leasee of taxi medallion 060.5. The Plaintiff SHAKHAUTH HOSSAIN is a citizen of the State of New Jersey having his principle residence at 102 S. Massachussets Avenue, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 063.6. The Plaintiff MOHAMMAD FARUK is a citizen of the State of New Jersey having his principle residence at 615 Jackson Avenue, Northfield, Atlantic County, New Jersey; and is the leasee of taxi medallion 064.7. The Plaintiff ABU NASOR is a citizen of the State of New Jersey having his principle residence at 103 Seagull Drive, Egg Harbor Township, Atlantic County, New Jersey; and is the leasee of taxi medallion 072.8. The Plaintiff MOHAMMAD J. ALAM is a citizen of the State of New Jersey having his principle residence at 2406 Arctic Avenue, 2nd Fl., Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 083.9. The Plaintiff TAPAN K. DAY is a citizen of the State of New Jersey having his principle residence at 120 N. Texas Avenue, Apt. #3, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 085.10. The Plaintiff ABUL K. AZAD is a citizen of the State of New Jersey having his principle residence at 226 Fairbanks Avenue, Northfield, Atlantic County, New Jersey; and is the leasee of taxi medallion 086.11. The Plaintiff MD K. ZAMAN is a citizen of the State of New Jersey having his principle residence at 654 N. Dover Avenue, Apt. A2, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 088.12. The Plaintiff MD Z. ALI is a citizen of the State of New Jersey having his principle residence at 250 Nevada Avenue, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 092.13. The Plaintiff MOHD R. KARIM is a citizen of the State of New Jersey having his principle residence at 3330 Boston Court, E6, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 104.14. The Plaintiff MOHAMMED HOSSAIN is a citizen of the State of New Jersey having his principle residence at 2510 Ivins Avenue, Egg Harbor Township, Atlantic County, New Jersey; and is the leasee of taxi medallion 108.15. The Plaintiff IQBAL HOSSEN is a citizen of the State of New Jersey having his principle residence at 27 C. Baratta Terrace, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 128.16. The Plaintiff MOHAMMED M. HUSSAIN is a citizen of the State of New Jersey having his principle residence at 43 S. Harrisburg Avenue, #B, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 129.17. The Plaintiff AHMED H. MABROUK is a citizen of the State of New Jersey having his principle residence at 2501 Bayshore Road, Villas, Cape May County, New Jersey; and is the leasee of taxi medallion 130.18. The Plaintiff ABDULLAH A. FAROOQ is a citizen of the State of New Jersey having his principle residence at 2717 Fairmount Avenue, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 140.19. The Plaintiff SAYED S. ALAM is a citizen of the State of New Jersey having his principle residence at 3330 Sovereign Court, F3, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 145.20. The Plaintiff MUHAMMAD IBRAR is a citizen of the State of New Jersey having his principle residence at 2403 Pacific Avenue, Apt. 2, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 148.21. The Plaintiff MOHAMMAD A. WADUD is a citizen of the State of New Jersey having his principle residence at 100 N. Laclede Place, Apt. 1, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 157.22. The Plaintiff MOHAMMED SHAMSUDDIN is a citizen of the State of New Jersey having his principle residence at 27 N. Texas Avenue, 1 Fl., Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 160.23. The Plaintiff MOHAMMED A. KARIM is a citizen of the State of New Jersey having his principle residence at 3330 Hartford Court, Apt. B4, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 170.24. The Plaintiff PULAK BARUA is a citizen of the State of New Jersey having his principle residence at 130 N. Maxwell Avenue, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 171.25. The Plaintiff KHAIRUZZA SHEIKH is a citizen of the State of New Jersey having his principle residence at 41 S. Delancey Place, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 175.26. The Plaintiff MUJIBUR RAHMAN is a citizen of the State of New Jersey having his principle residence at 208 N. Texas Avenue, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 180.27. The Plaintiff MOHOMMED A. ESKANDOR is a citizen of the State of New Jersey having his principle residence at 3330 Providence Court, Apt. F3, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 212.28. The Plaintiff SURESH K. LAMBA is a citizen of the State of New Jersey having his principle residence at 3330 Fairmount Avenue, Boston Court, Apt. C3, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 221.29. The Plaintiff MOHAMMED I. HOSSAIN is a citizen of the State of New Jersey having his principle residence at 11 Holden Court, Egg Harbor Township, Atlantic County, New Jersey; and is the leasee of taxi medallion 229.30. The Plaintiff MD H. KABIR is a citizen of the State of New Jersey having his principle residence at 206 N. Texas Avenue, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 242.31. The Plaintiff MOHAMMED R. ISLAM is a citizen of the State of New Jersey having his principle residence at 615 Jackson Avenue, Northfield, Atlantic County, New Jersey; and is the leasee of taxi medallion 245.32. The Plaintiff MOHOMMED S. CHOWDHURY is a citizen of the State of New Jersey having his principle residence at 203 N. Chelsea Avenue, 2nd Floor, Atlantic City, Atlantic County, New Jersey; and is the leasee of taxi medallion 250.33. The Plaintiff SONY TAYLOR is a citizen of the State of New Jersey having his principle residence at 200 Chesterbrook Road, Egg Harbor Township, Atlantic County, New Jersey; and is the leasee of taxi medallion 174.34. The Plaintiff FAROOQ A. CHOUDHRY is a citizen of the State of New Jersey having his principle residence at 4901 Harbour Beach Boulevard, #L-1, Brigantine, Atlantic County, New Jersey; and is the leasee of taxi medallion 010.35. The Plaintiff MUSHTAQ KHAN is a citizen of the State of New Jersey having his principle residence at 2567 Tilton Road, F-4, Egg Harbor Township, Atlantic County, New Jersey; and is the leasee of taxi medallion 121.36. The Defendant ADEL HALIM is a citizen of the State of New Jersey having his principle residence 831 N. Dorset Avenue, Ventnor, Atlantic County, New Jersey, and is the owner of taxi medallions 063, 064, 129, 170, 180, 245, and 250.37. The Defendant MYRA COHEN TRUST is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 403 N. Cornwall Avenue, Ventnor, Atlantic County, New Jersey, and is the owner of taxi medallions 017, 060, 086, 088, 092, and 175.38. The Defendant YAFIE S. OSMAN is a citizen of the State of New Jersey having his principle residence 177 4th Avenue, Estell Manor, Atlantic County, New Jersey and is the owner of taxi medallions 057, and 083.39. The Defendant PERLMAN LEASING, INC. is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 3101 Boardwalk, #710-1 Atlantic County, New Jersey, and is the owner of taxi medallions 072, 171, 221, 229, and 242.40. The Defendant JOHNIE R. WHITE is a citizen of the State of New Jersey having his principle residence 1825 Arkansas Avenue, Atlantic City, Atlantic County, New Jersey, and is the owner of taxi medallion 085.41. The Defendant KING CAB CO. is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 450 Bay Avenue, Somers Point, Atlantic County, New Jersey, and is the owner of taxi medallions 104, and 157.42. The Defendant DAT PHAM is a citizen of the State of New Jersey having his principle residence 3111 Fairmount Avenue, Atlantic City, Atlantic County, New Jersey, and is the owner of taxi medallion 108.43. The Defendant MYMCM. is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 153 Old NY Road, Port Republic, Atlantic County, New Jersey, and is the owner of taxi medallion 128.44. The Defendant MONIR GAYED is a citizen of the State of New Jersey having his principle residence 153 Old NY Road, Port Republic Atlantic County, New Jersey, and is the owner of taxi medallion 160.45. The Defendant CITY SERVICE CAB, INC.. is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 3401 Winchester Avenue, Atlantic City, Atlantic County, New Jersey, and is the owner of taxi medallion 121, and 140.46. The Defendant MARSEIL SALAMA is a citizen of the State of New Jersey having his principle residence 1112 Broad Street, Northfield, Atlantic County, New Jersey, and is the owner of taxi medallion 145.47. The Defendant MINH V. HOANG is a citizen of the State of New Jersey having his principle residence 18 N. Brighton Avenue, Atlantic City, Atlantic County, New Jersey, and is the owner of taxi medallion 148.48. The Defendant MARYANN VASSALOTTI is a citizen of the State of Pennsylvania having her principle residence 407 Westfield Drive, Broomal, Pennsylvania, and is the owner of taxi medallion 212.49. The Defendant OCEAN HEIGHTS TAXI SERVICE, LTD. is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 310 W. Ocean Heights Avenue, Linwood, Atlantic County, New Jersey, and is the owner of taxi medallion 174.50. The Defendant JOSEPH DEWES is a citizen of the State of New Jersey having his principle residence 424 N. Somerset Avenue, Ventnor, Atlantic County, New Jersey, and is the owner of taxi medallion 010.51. The Defendant THE LIMO OF AMERICA CO. is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 831 N. Dorset Avenue, Ventnor, Atlantic County, New Jersey, and is the owner of motor vehicles used as taxi cabs with the following medallions: 017, 057, 060, 086, 088, 092, and 175.52. The Defendant TAXI CAB OF AMERICA, INC. is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 831 N. Dorset Avenue, Ventnor, Atlantic County, New Jersey, and is the owner of motor vehicles used as taxi cabs with the following medallions: 072, 085, 121, 128, 140, 145, 160, 171, 221, and 242.53. The Defendant UNTIED TAXI CAB, INC. is a business and/or financial organization legally organized to do business in the State of New Jersey having its principle place of business at 831 N. Dorset Avenue, Ventnor, Atlantic County, New Jersey, and is the owner of motor vehicles used as taxi cabs with the following medallions: 001, 064, 104, 108, 130, 148, 157, 170, 212, 229, and 245.PLEADINGS COMMON TO ALL COUNTS54. The Plaintiffs are duly licensed taxi cab drivers in the City of Atlantic City, and are the leasees of taxi cab medallions as described above; said leases running from September 1, 2014 to August 31, 2015. The Medallion leases, registered and filed with the City of Atlantic City Department of Licensing and Inspections specify a monthly lease payment from $500 to $850.55. Defendant, ADEL HALIM, upon information and belief, served as an agent for taxi cab medallions owned by other defendants, in essence creating a sub-lease for said medallions in violation of Atlantic City Ordinance 233-11; said medallions being 001, 017, 057, 060, 063, 064, 072, 083, 085, 086, 088, 092, 104, 108, 121, 128, 129, 130, 140, 145, 148, 157, 160, 170, 171, 175, 180, 212, 221, 229, 242, 245, and 250.56. Defendant, ADEL HALIM, through coercion and misrepresentation required the medallion leases to pay him, for the benefit of the use of a taxi medallion, $575 each week. Defendant, HALIM in addition required nearly all of the plaintiffs to transfer ownership of their taxi vehicle to one of the companies owned and/or controlled and/or managed by him, representing falsely that it was required that the medallion owner, through him have ownership of the vehicle. Defendant, HALIM also represented to the affected driver/plaintiffs that insurance would be provided by him at a reduced rate.57. Defendants, OCEAN HEIGHTS TAXI SERVICE and JOSEPH DEWES, likewise, through coercion and misrepresentation required their medallion leases to pay them for the benefit of a taxi medallion $575 each week. Defendants, OCEAN HEIGHTS TAXI SERVICE and JOSEPH DEWES also represented to the affected driver/plaintiffs that insurance would be provided by him at a reduced rate.58. The Plaintiffs paid the demanded $575 each week to Defendants HALIM, OCEAN HEIGHTS TAXI SERVICE and/or JOSEPH DEWES until October 1, 2014 when they learned that the representations made to them by HALIM, OCEAN HEIGHTS TAXI SERVICE and DEWES, were false, and that the duly recorded and filed medallion leases required a monthly payment of $500 to $850 depending on the respective medallion lease.59. Plaintiffs have made all of the required lease payments pursuant to the recorded and filed medallion leases.60. In response to Plaintiffs decision to pay only the required lease payments pursuant to the recorded and filed medallion leases, Defendants HALIM, OCEAN HEIGHTS TAXI SERVICE AND DEWES have cancelled the required automobile taxi insurance and in some cases voided or attempted to void the medallion leases held by plaintiffs.COUNT ONEFRAUD61.Plaintiffs repeat the allegations set forth above in this Complaint as though specifically set forth herein and made a part hereof.62.By virtue of their aforementioned actions and inactions, Defendants, individually and collectively, unlawfully seized, took and converted funds belonging to Plaintiffs.63.These defendants seized, took and converted the funds of Plaintiffs for their own benefit and to the detriment of Plaintiffs.64.As a result of the aforesaid acts of these defendants, Plaintiffs have been, and will continue to be, significantly and irreparably damaged.WHEREFORE, Plaintiffs demands judgment against Defendants, jointly and severally, for: (a) Compensatory damages;(b) Punitive damages;(c) Interest;(d) Attorneys fees;(e) Costs of suit; and(f) Any other relief the Court deems just and equitable.

COUNT TWOCONVERSION65. Plaintiffs repeat and reallege the allegations set forth in all prior paragraphs in the complaint herein as if set forth herein in full.66. The Defendants, Adel Halim, The Limo of America Co., Taxi Cab of America, Inc., and United Taxi Cab, Inc., did take and convert Plaintiffs assets including the taxi cab vehicles, and deprived Plaintiffs from their just and lawful enjoyment thereof. WHEREFORE, Plaintiffs demands judgment against Defendants, jointly and severally, for: (a) Compensatory damages;(b) Punitive damages;(c) Interest;(d) Attorneys fees;(e) Costs of suit; and(f) Any other relief the Court deems just and equitable.

COUNT THREECOMMON LAW FRAUD67. Plaintiffs repeat the allegations that are set forth above in this Verified Complaint as though specifically set forth herein and made a part hereof.68.As described above, Defendants misrepresented material facts to Plaintiffs and failed to disclose material facts to Plaintiffs. Specifically, Defendants falsely represented that the taxi cab vehicles were required to be owned by an agent of the medallion owner, that additional monies were required to be paid to the medallion owners agents for the benefit of use of the medallion, and that automobile liability insurance would be provided at a lower cost..69.Defendants made these false and misleading statements to Plaintiffs knowing that they would be relied upon by Plaintiffs.70.Defendants either knew that their statements were false and that the omitted facts were true, or recklessly disregarded whether their statements were false and the omitted facts were true.71.Plaintiffs justifiably and reasonably relied on the misstatements and omissions by Defendants in not taking action sooner to address the misdeeds and unscrupulous conduct.72.Plaintiffs would have taken action sooner to preserve and protect themselves from the actions and inaction of Defendants had they known the truth concerning the material facts that Defendants misrepresented, concealed or omitted. 73.By making material, false misrepresentations and by concealing or omitting material facts as described above, Defendants intended to, and did, defraud Plaintiffs.74.As a proximate result of Defendants fraudulent conduct, Plaintiffs have sustained significant damages and suffered irreparable harm and will continue to sustain significant damages and suffer irreparable harm. WHEREFORE, Plaintiffs demands judgment against Defendants, jointly and severally, for: (a) Compensatory damages;(b) Punitive damages;(c) Interest;(d) Attorneys fees;(e) Costs of suit; and(f) Any other relief the Court deems just and equitable.

COUNT FOURBREACH OF CONTRACT75. Plaintiffs repeat the allegations that are set forth above in this Verified Complaint as though specifically set forth herein and made a part hereof.76. As described above Plaintiffs and Defendants entered into medallion lease contracts that were duly filed and recorded with the Atlantic City Department of Licensing & Inspections.77. Plaintiffs breached the contract by voiding and/or attmepting to void the medallion leases despite plaintiffs proper and complete performance of said contracts.

78. As a direct and proximate result of Defendants breach of the lease contracts, Plaintiffs have been harmed and caused to suffer damages.WHEREFORE, Plaintiffs demands judgment against Defendants, jointly and severally, for: (a) Compensatory damages;(b) Punitive damages;(c) Interest;(d) Attorneys fees;(e) Costs of suit; and(f) Any other relief the Court deems just and equitable.COUNT FIVEFICTITIOUS PARTIES

79. Plaintiffs repeat the allegations that are set forth above in this Verified Complaint as though specifically set forth herein and made a part hereof.79. Plaintiffs allege that an insufficient amount of time has passed within which to determine the identity of any other individuals or business entities who may be responsible for the causation of the injuries aforesaid. 3. Plaintiffs allege for the purposes of the within Complaint, said individuals and/or business entities have been nominated as JOHN DOE TAXI MEDALLION OWNERS A to Z, JANE DOE TAXI LEASE AGENCIES/AGENTS 1-20, and JACK DOE TAXI CAB OWNERS 1-10. 4. Plaintiffs, pursuant to the Rules of the Court for the State of New Jersey, reserve the right to amend the within Complaint to add additional Defendants when and if the identity of said individuals and/or business entities becomes known. WHEREFORE, Third-Party Plaintiffs demand judgment of this Count against Defendants John Doe Taxi Medallion Owners A to Z, Jane Doe Taxi Lease Agencies 1 20, and Jack Doe Taxi Cab Owners 1 10 (multiple alternative fictitious entities) for damages together with pre and post judgment interest, costs, counsel fees and expenses, and such other relief as the Court deems just and equitable.

CERTIFICATION PURSUANT TO RULE 4:51 I hereby certify that the matter in controversy, herein is not the subject of any other action pending in any other Court or arbitration process of which the undersigned is aware. Further, I hereby certify that it is not contemplated that any other party should be jointed in this action.I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.

____________________________________Bard L. Shober, Esq.DATED: ______________________

VERIFICATION MAHABUBUR RAHMAN, of full age, hereby certifies:I am the Plaintiff in the foregoing Verified Complaint. The allegations of the Complaint are true to the best of my knowledge, information and belief and the Complaint is made in truth and good faith, for the causes set forth in it. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.

___________________________________TASNAM AFZALDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMAD A. KALAMDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MUHAMMAD A. ANSARIDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________AHAMED N. SIKDERDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________SHAKHAUTH HOSSAINDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMAD FARUKDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________ABU NASSORDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMAD J. ALAMDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________TAPAN DAYDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________ABUL AZADDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MD K. ZAMANDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MD ALIDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHD R. KARIMDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMED HOSSAINDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________IQBAL HOSSENDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMED M. HUSSAINDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________AHMED H. MARBROUKDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________ABDULLAH AL-FAROOQDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________SAYAD ALAMDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MUHAMMAD IBRARDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMAD A. WADUDDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMAD SHAMSUDDINDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMED KARIMDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________PULAK BARUADATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________KHAIRUZZAM SHEIKHDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MUJIBAR RAHMANDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMED A. ESKANDORDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________SURESH LAMBADATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMED I. HOSSAINDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MD H. KABIRDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMAD R. ISLAMDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________MOHAMMED S. CHOWDHURYDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________SONY TAYLORDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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___________________________________FAROOQ CHOUDHRYDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2012

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VERIFICATION MUSHTAQ KHAN, of full age, hereby certifies:I am the Plaintiff in the foregoing Verified Complaint. The allegations of the Complaint are true to the best of my knowledge, information and belief and the Complaint is made in truth and good faith, for the causes set forth in it. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.

___________________________________MUSHTAQ KHANDATED: _________________________Sworn and Subscribed before meThis ______day of _______, 2014

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10.24.14 - taxi complaint

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