SUMMONS
SERVICE
LAW OFFICES OF
RAFFI T. KHOROZIAN, PC
1073 Palisade Avenue
Fort Lee, New Jersey 07024
Tel No.: (201) 969-4800
Fax No.: (201) 969-2800
Attorney for Plaintiff, Rolland Butler
____________________________
ROLLAND BUTLER, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION: MORRIS COUNTY
Plaintiff, : DOCKET NO.: MRS-L-2066-24
vs. :
: CIVIL ACTION
:
TOWNSHIP OF PARSIPPANY-TROY :
HILLS, ABC MAINTENANCE CO 1-10, :
LITTLE MASON PROPERTIES, LLC, :
JOHN DOE 1-10, ABC CORP 1-10, :
XYZ, INC. 1-10, (said names being :
fictitious for persons and entities :
unknown at this time) :
: SUMMONS
:
Defendant(s). :
:
____________________________
From The State of New Jersey
To the Defendant Named Above: LITTLE MASON PROPERTIES, LLC
The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The Complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days from the date you received this summons, not counting the date you received it. (The address of each deputy clerk of the Superior Court is provided.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the Superior Court, Hughes Justice Complex, CN-971, Trenton, NJ 08625. A filing fee payable to the Clerk of the Superior Court and a completed Case Information Statement (available from the deputy clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer or motion to plaintiff=s attorney whose name and address appear above, or to plaintiff, if no attorney is named above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with a fee of $135.00 for Law Division and $105.00 for Chancery Division and a completed Case Information Statement) if you want the court to hear your defense.
If you do not file and serve a written answer or motion within 35 days, the court may enter a judgement against you for the relief plaintiff demands, plus interest and cost of suit. If judgment is entered against you, the Sheriff may seize your money, wages or property to pay all part of the judgment.
If you cannot afford an attorney, you may call the Legal Services office in the county where you live. A list of these offices is provided. If you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services. A list of these numbers is also provided.
DATED: June 8, 2026
/s/ Michelle M. Smith
Acting Clerk of the Superior Court
Name of defendant to be served: LITTLE MASON PROPERTIES, LLC
Address for service: 1138-1154 KNOLL ROAD, BOONTON, NJ 07005
LAW OFFICES OF
RAFFI T. KHOROZIAN, PC
1073 Palisade Avenue
Fort Lee, New Jersey 07024
Tel No.: (201) 969-4800
Fax No.: (201) 969-2800
Attorney for Plaintiff, Rolland Butler
____________________________
ROLLAND BUTLER, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION: MORRIS COUNTY
Plaintiff, : DOCKET NO.: MRS-L-2066-24
vs. :
: CIVIL ACTION
:
TOWNSHIP OF PARSIPPANY-TROY :
HILLS, ABC MAINTENANCE CO 1-10, :
LITTLE MASON PROPERTIES, LLC, :
JOHN DOE 1-10, ABC CORP 1-10, :
XYZ, INC. 1-10, (said names being :
fictitious for persons and entities :
unknown at this time) :
: SUMMONS
:
Defendant(s). :
:
____________________________
From The State of New Jersey
To the Defendant Named Above: LITTLE MASON PROPERTIES, LLC
The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The Complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days from the date you received this summons, not counting the date you received it. (The address of each deputy clerk of the Superior Court is provided.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the Superior Court, Hughes Justice Complex, CN-971, Trenton, NJ 08625. A filing fee payable to the Clerk of the Superior Court and a completed Case Information Statement (available from the deputy clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer or motion to plaintiff=s attorney whose name and address appear above, or to plaintiff, if no attorney is named above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with a fee of $135.00 for Law Division and $105.00 for Chancery Division and a completed Case Information Statement) if you want the court to hear your defense.
If you do not file and serve a written answer or motion within 35 days, the court may enter a judgement against you for the relief plaintiff demands, plus interest and cost of suit. If judgment is entered against you, the Sheriff may seize your money, wages or property to pay all part of the judgment.
If you cannot afford an attorney, you may call the Legal Services office in the county where you live. A list of these offices is provided. If you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services. A list of these numbers is also provided.
DATED: June 8, 2026
/s/ Michelle M. Smith
Acting Clerk of the Superior Court
Name of defendant to be served: LITTLE MASON PROPERTIES, LLC
Address for service: 1138-1154 KNOLL ROAD, PARSIPPANY-TROY HILLS, NJ 07005
LAW OFFICES OF
RAFFI T. KHOROZIAN, PC
1073 Palisade Avenue
Fort Lee, New Jersey 07024
Tel No.: (201) 969-4800
Fax No.: (201) 969-2800
Attorney for Plaintiff, Rolland Butler
____________________________
ROLLAND BUTLER, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION: MORRIS COUNTY
Plaintiff, : DOCKET NO.: MRS-L-2066-24
vs. :
: CIVIL ACTION
:
TOWNSHIP OF PARSIPPANY-TROY :
HILLS, ABC MAINTENANCE CO 1-10, :
LITTLE MASON PROPERTIES, LLC, :
JOHN DOE 1-10, ABC CORP 1-10, :
XYZ, INC. 1-10, (said names being :
fictitious for persons and entities :
unknown at this time) :
: SUMMONS
:
Defendant(s). :
:
____________________________
From The State of New Jersey
To the Defendant Named Above: LITTLE MASON PROPERTIES, LLC
Registered Agent: IFRAN HASSAN
The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The Complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days from the date you received this summons, not counting the date you received it. (The address of each deputy clerk of the Superior Court is provided.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the Superior Court, Hughes Justice Complex, CN-971, Trenton, NJ 08625. A filing fee payable to the Clerk of the Superior Court and a completed Case Information Statement (available from the deputy clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer or motion to plaintiff=s attorney whose name and address appear above, or to plaintiff, if no attorney is named above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with a fee of $135.00 for Law Division and $105.00 for Chancery Division and a completed Case Information Statement) if you want the court to hear your defense.
If you do not file and serve a written answer or motion within 35 days, the court may enter a judgement against you for the relief plaintiff demands, plus interest and cost of suit. If judgment is entered against you, the Sheriff may seize your money, wages or property to pay all part of the judgment.
If you cannot afford an attorney, you may call the Legal Services office in the county where you live. A list of these offices is provided. If you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services. A list of these numbers is also provided.
DATED: June 8, 2026
/s/ Michelle M. Smith
Acting Clerk of the Superior Court
Name of defendant to be served: LITTLE MASON PROPERTIES, LLC
Registered Agent: IFRAN HASSAN
Address for service: 17-25 CHURCH STREET #12, SOUTH ORANGE, NEW JERSEY 07079
LAW OFFICES OF
RAFFI T. KHOROZIAN, PC
1073 Palisade Avenue
Fort Lee, New Jersey 07024
Tel No.: (201) 969-4800
Fax No.: (201) 969-2800
Attorney for Plaintiff, Rolland Butler
____________________________
ROLLAND BUTLER, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION: MORRIS COUNTY
Plaintiff, : DOCKET NO.: MRS-L-2066-24
vs. :
: CIVIL ACTION
:
TOWNSHIP OF PARSIPPANY-TROY :
HILLS, ABC MAINTENANCE CO 1-10, :
LITTLE MASON PROPERTIES, LLC, :
JOHN DOE 1-10, ABC CORP 1-10, :
XYZ, INC. 1-10, (said names being :
fictitious for persons and entities :
unknown at this time) :
: SUMMONS
:
Defendant(s). :
:
____________________________
From The State of New Jersey
To the Defendant Named Above: LITTLE MASON PROPERTIES, LLC
Registered Agent: IFRAN HASSAN
The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The Complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days from the date you received this summons, not counting the date you received it. (The address of each deputy clerk of the Superior Court is provided.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the Superior Court, Hughes Justice Complex, CN-971, Trenton, NJ 08625. A filing fee payable to the Clerk of the Superior Court and a completed Case Information Statement (available from the deputy clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer or motion to plaintiff=s attorney whose name and address appear above, or to plaintiff, if no attorney is named above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with a fee of $135.00 for Law Division and $105.00 for Chancery Division and a completed Case Information Statement) if you want the court to hear your defense.
If you do not file and serve a written answer or motion within 35 days, the court may enter a judgement against you for the relief plaintiff demands, plus interest and cost of suit. If judgment is entered against you, the Sheriff may seize your money, wages or property to pay all part of the judgment.
If you cannot afford an attorney, you may call the Legal Services office in the county where you live. A list of these offices is provided. If you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services. A list of these numbers is also provided.
DATED: June 8, 2026
/s/ Michelle M. Smith
Acting Clerk of the Superior Court
Name of defendant to be served: LITTLE MASON PROPERTIES, LLC
Registered Agent: IFRAN HASSAN
Address for service: 70 CREST DRIVE, SOUTH ORANGE, NEW JERSEY 07079
LAW OFFICES OF
RAFFI T. KHOROZIAN, PC
1073 Palisade Avenue
Fort Lee, New Jersey 07024
Tel No.: (201) 969-4800
Fax No.: (201) 969-2800
Attorney for Plaintiff, Rolland Butler
____________________________
ROLLAND BUTLER, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION: MORRIS COUNTY
Plaintiff, : DOCKET NO.: MRS-L-2066-24
vs. :
: CIVIL ACTION
:
TOWNSHIP OF PARSIPPANY-TROY :
HILLS, ABC MAINTENANCE CO 1-10, :
LITTLE MASON PROPERTIES, LLC, :
JOHN DOE 1-10, ABC CORP 1-10, :
XYZ, INC. 1-10, (said names being :
fictitious for persons and entities :
unknown at this time) :
: SECOND AMENDED COMPLAINT
:
Defendant(s). :
:
____________________________
Plaintiff, ROLLAND BUTLER, residing in the Township of Parsippany-Troy Hills, County of Morris, and State of New Jersey, by way of Complaint against the Defendants herein, say:
FIRST COUNT
1. On or about July 15, 2024, Plaintiff, ROLLAND BUTLER, was the owner and operator of a motor vehicle which was traveling at or near 1138-1154 Knoll Road, in the Township of Parsippany-Troy Hills, County of Morris, and State of New Jersey as a result of a caved in storm drain, the plaintiff was involved a vehicle motor vehicle accident thus sustaining personal injuries.
2. At all times relevant hereto, defendants TOWNSHIP OF PARSIPPANY-TROY HILLS, ABC MAINTENANCE CO 1-10, LITTLE MASON PROPERTIES, LLC, JOHN DOE 1-10, ABC CORP 1-10 and/or XYZ, INC. 1-10, owned, supervised, controlled, operated, maintained, leased, repaired and/or inspected the aforesaid streets and/or roads thereto where plaintiff ROLLAND BUTLER was lawfully traveling on.
3. At the aforesaid time and place, the said defendants, jointly, severally, and/or individually, and/or their servants, agents, and/or employees, so negligently, carelessly and recklessly maintained, owned, operated, controlled, supervised, repaired, and/or inspected said streets and/or roads thereto so as to cause, create and/or allow a hazardous and dangerous condition to exist and a nuisance to exist whereby plaintiff's vehicle struck a caved in storm drain thus causing the plaintiff to sustain severe and permanent injuries.
4. Defendants jointly, severally and/or individually and/or their agents, servants and/or employees were negligent in failing to maintain, supervise, illuminate, control and/or provide warnings or barriers relative to a dangerous condition on the aforesaid streets and/or roads thereto, and/or allowed, created and/or failed to repair a dangerous condition, and/or failed to provide a reasonably safe means of access and/or egress for persons lawfully on its premises, any and all of which proximately caused plaintiff ROLLAND BUTLER to sustain severe and permanent injuries.
5. As a direct and proximate result of the negligence of the defendants as aforesaid, jointly, severally and/or individually, plaintiff ROLLAND BUTLER sustained severe and permanent injuries; suffered and will in the future suffer great pain and anguish; was and will be required to seek medical and hospital care and attention; and/or will cause plaintiff to sustain economic losses and damages and was and will in the future be unable to engage in his pursuits and occupations.
WHEREFORE, plaintiff ROLLAND BUTLER hereby demands judgment against the defendants either jointly, severally and/or in the alternative, for compensatory damages, together with interest, costs of suit and attorneys' fees.
SECOND COUNT
1. Plaintiff repeats each an every allegation of the prior Count as though fully set forth at length herein.
2. Defendants, ABC MAINTENANCE CO. 1-10, JOHN DOE 1-10, ABC CORP 1-10, XYZ, INC. 1-10 fictitious corporations,companies, individuals and/or contractors were responsible to the premises and/or streets and/or roads thereto and/or repaired, supervised and/or performed work upon at the aforesaid location. These defendants were negligent, careless and/or reckless in failing to maintain, supervise, illuminate, control and/or provide warnings or barriers relative to a dangerous condition on the aforesaid premises and/or streets and/or roads thereto so as to provide a reasonably safe street and/or road therereof at the subject premises.
3. As a direct and proximate result of the negligence of the defendants as aforesaid, jointly, severally and/or individually, plaintiff ROLLAND BUTLER sustained severe and permanent injuries; suffered and will in the future suffer great pain and anguish; was and will be required to seek medical and hospital care and attention; did and will in the future cause plaintiff to sustain economic losses and damages, and was and will in the future be unable to engage in his pursuits and occupations.
WHEREFORE, plaintiff ROLLAND BUTLER hereby demands judgment against the defendants either jointly, severally and/or in the alternative, for compensatory damages, together with interest, costs of suit and attorneys' fees.
THIRD COUNT
1. Plaintiff repeat and re-allege each and every allegation of the prior Counts as set forth herein.
2. The defendants, JOHN DOE 1-10 (a fictitious named), ABC MAINTENANCE CO 1-10 (fictitious corporations) ABC CORP. 1-10 and XYZ, INC. 1-10 (fictitious corporations), are named herein as representing any unknown potential defendants in this lawsuit, whose identity might be revealed to the plaintiff during the course of this lawsuit and so as to halt the running to the Statute of Limitations as to the said presently unknown and unidentified defendants.
WHEREFORE, plaintiff ROLLAND BUTLER hereby demands judgment against the defendants either jointly, severally and/or in the alternative, for compensatory damages, together with interest, costs of suit and attorneys' fees.
FOURTH COUNT
1. Plaintiff hereby repeats, reiterates and realleges each and every allegation contained in the prior counts and sets them forth as if at length herein.
2. On or about July 15, 2024 the Plaintiff was caused to sustain personal injuries.
3. As a direct and proximate result of the aforesaid negligence of the Defendants, the Plaintiff ROLLAND BUTLER was required to obtain medical attention and treatment.
4. Plaintiff was forced to incur medical bills as a result of this incident and will be required to obtain medical treatment in the future and incur bills.
WHEREFORE, the plaintiff demands judgment against the Defendants for payment of all related hospital, medical bills, payment of all costs of suit, payment of all attorney's fees as permitted by the Court including interest, cost and any other expenses incurred as a result of any other lawsuits brought against the Plaintiff for payment of said medical bills.
FIFTH COUNT 1. Plaintiff hereby repeats, reiterates and realleges each and every allegation contained in the prior counts and sets them forth as if at length herein.
2. As a result of the accident that occurred on July 15, 2024, plaintiff incurred out-of-pocket expenses including but not limited to medical bills.
WHEREFORE, plaintiff, ROLLAND BUTLER, demands judgement against the
defendants, together with interest and costs of the suit.
LAW OFFICES OF RAFFI T. KHOROZIAN
Raffi T. Khorozian
Raffi T. Khorozian, Esq.
Dated: February 11, 2026
JURY DEMAND
Plaintiff hereby demands a trial by jury as to all issues so triable.
LAW OFFICES OF RAFFI T. KHOROZIAN
Raffi T. Khorozian
Raffi T. Khorozian, Esq.
Dated: February 11, 2026
DEMAND FOR INTERROGATORY ANSWERS
Pursuant to R. 4:17-1 (b) (ii), the plaintiff(s) hereby demand that all defendant(s)answer the uniform interrogatories listed in Form C of Appendix II of the Rules of Court.
LAW OFFICES OF RAFFI T. KHOROZIAN
Raffi T. Khorozian
Raffi T. Khorozian, Esq.
Dated: February 11, 2026
NOTICE IN LIEU OF SUBPOENA
Pursuant to R.1:9-1 plaintiff hereby demands the appearance of each and every named defendant for the purpose of giving testimony in the above referenced action at the time of trial.
LAW OFFICES OF RAFFI T. KHOROZIAN
Raffi T. Khorozian
Raffi T. Khorozian, Esq.
Dated: February 11, 2026
DESIGNATION OF TRIAL COUNSEL
Pursuant to R.4:25-4, attorney Raffi T. Khorozian, Esq. is hereby designated as trial counsel.
LAW OFFICES OF RAFFI T. KHOROZIAN
Raffi T. Khorozian
Raffi T. Khorozian, Esq.
Dated: February 11, 2026
CERTIFICATION
Pursuant to R. 4:5-1, I certify that to the best of my knowledge the matter in controversy is not the subject of any other action pending in any court or pending arbitration proceeding, nor is any other action or arbitration proceeding contemplated.
LAW OFFICES OF RAFFI T. KHOROZIAN
Raffi T. Khorozian
Raffi T. Khorozian, Esq.
Dated: February 11, 2026
June 11 2026
LNYS0535322
$351.78