LAW OFFICE OF BARD L. SHOBER, ESQ.

1021 S. Main Street

Pleasantville, NJ 08232
609-343-1790
Atty. ID: 033341991
Attorney for Plaintiffs

TASNEM AFZAL, MOHAMMAD

A. KALAM, MUHAMMAD A.
ANSARI, AHAMED N, SIKDER,
SHAKHAUTH 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 ALFAROOQ, 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.
ADEL HALIM, MYRA COHEN
TRUST, YAFIE S. OSMAN,
PERLMAN LEASING INC.,
JOHNIE R. WHITE, KING CAB
CO., DAT PHAM, MYMCM,
MONIR GAYED, CITY

:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:

SUPERIOR COURT OF NEW JERSEY

ATLANTIC COUNTY
CHANCERY DIVISION

DOCKET NO.
CIVIL ACTION
VERIFIED COMPLAINT

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:
PARTIES
1. 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 COUNTS
54. 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 ONE
FRAUD
61.

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 TWO
CONVERSION
65. 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 THREE
COMMON LAW FRAUD
67.

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 FOUR
BREACH OF CONTRACT
75. 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 FIVE
FICTITIOUS 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 AFZAL
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMAD A. KALAM
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MUHAMMAD A. ANSARI
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
AHAMED N. SIKDER
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
SHAKHAUTH HOSSAIN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMAD FARUK
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
ABU NASSOR
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMAD J. ALAM
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
TAPAN DAY
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
ABUL AZAD
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MD K. ZAMAN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MD ALI
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHD R. KARIM
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMED HOSSAIN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
IQBAL HOSSEN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMED M. HUSSAIN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
AHMED H. MARBROUK
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
ABDULLAH AL-FAROOQ
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
SAYAD ALAM
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MUHAMMAD IBRAR
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMAD A. WADUD
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMAD SHAMSUDDIN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMED KARIM
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
PULAK BARUA
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
KHAIRUZZAM SHEIKH
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MUJIBAR RAHMAN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMED A. ESKANDOR
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
SURESH LAMBA
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMED I. HOSSAIN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MD H. KABIR
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMAD R. ISLAM
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
MOHAMMED S. CHOWDHURY
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
SONY TAYLOR
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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.

___________________________________
FAROOQ CHOUDHRY
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2012

__________________________________

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 KHAN
DATED: _________________________
Sworn and Subscribed before me
This ______day of _______, 2014

__________________________________