Complaint

 SUPREME COURT OF THE STATE OF XXX

COUNTY OF XXX

 

(Insert Plaintiff’s Name)

          Plaintiff,

    vs.

New York City Department of Transportation

          Defendant.

 

TO THE SUPREME COURT OF THE STATE OF XXX

The complaint of the Plaintiff, (Insert Plaintiff’s Name), respectfully shows and alleges as follows:

  1. The Plaintiff herein, (Insert Plaintiff’s Name), is a resident of the State of XXX.PERSON 1 resides at (Insert Plaintiff’s Address).
  2. The Defendant herein, XXX  Department of Transportation, is tasked with ensuring the safe, efficient, and environmentally responsible movement of people and goods in the City of XXX and to maintain and enhance the transportation infrastructure crucial to the economic vitality and quality of life of city residents.
  3. The Plaintiff requested for a speed hump on 71st Avenue between 110th and 112th Streets.
  4. In a letter dated XXX, the Defendant informed the Plaintiff that the location met the criteria for a speed hump. The Defendant only required approval from Community Board 6. The Defendant promised to install speed humps when Community Board 6 approved the request.
  5. In a letter dated XXX, Community Board 6 approved the installation of speed humps on 71st Avenue between 110th and 112th Streets.
  6. Up to date, the Defendant has not built speed humps on 71st Avenue between 110th and 112th Streets despite meeting the criteria for installation and approval from Community Board 6.
  7. The lack of installation of speed humps in the streets puts residents at risk of speeding vehicles. Installation of speed humps will increase the safety of residents.

WHEREFORE, the Plaintiff demands judgment against the Defendant, an order of specific performance compelling the Defendant to install speed humps on 71st Avenue between 110th and 112th Streets, costs and disbursements, together with any other relief the Court finds to be just and proper. 

Dated: (Enter Date)

(Plaintiff’s Signature)

(Plaintiff’s Full Name)

(Plaintiff’s Address)

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