Preview
FILED: KINGS COUNTY CLERK 07/31/2018 10:47 AM INDEX NO. 518485/2017
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 07/31/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------x Index No.: 518485/2017
ROBERT MOORE, (ECF)
Plaintiff,
SUPPLEMENTAL
v. RESPONSE TO
PRELIMINARY
CONFERENCE ORDER
STARRETT CITY, INC.,
Defendant.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE, that Defendant, Starrett City, Inc., by its attorneys, Eustace,
Marquez, Epstein, Prezioso & Yapchanyk, hereby supplements their response to this Court's
Preliminary Conference Order dated April 11, 2018, as follows:
1. Please be advised that we have been informed by the Chubb Group of Insurance
Companies, a division of Federal Insurance Company, that there is primary coverage in
the amount of $1,000,000 issued by Great Northern Insurance Company, bearing policy
number 73564355, applicable to this litigation. Please be further advised that we have
also been informed of the following excess coverage written by National Union Fire
Insurance Company of Pittsburgh, Pa. bearing policy number 020760759, with a limit of
$24,000,000 applicable to this litigation.
"A"
2. Annexed herein as Exhibit is a copy of the Defensive Driving Attendance Sheet
showing that Margarita Santiago took the Defensive Driving Course on September 12,
2014.
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FILED: KINGS COUNTY CLERK 07/31/2018 10:47 AM INDEX NO. 518485/2017
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 07/31/2018
Defendant hereby reserves the right to amend and/or supplement this response up to and
including the time of trial.
DATED: July 31, 2018
New York, New York
Yours, etc.,
Eustace, Marquez, Epstein, Prezioso 4
Yapchanyk
Attorneys for Defendant
STARRETT CITY, INC.
Office and Post Office Address
55 Water Street, 28th Floor
New York, New York 10041
(212) 612-4200
By:
Richard C. Prezioso
TO:
The Nolan Law Firm
Attorneys for Plaintif Robert Moore
488 Madison Avenue, Suite 1100
New York, New York 10022
(212) 308-3456
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FILED: KINGS COUNTY CLERK 07/31/2018 10:47 AM INDEX NO. 518485/2017
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 07/31/2018
Index No.: 518485/2017 (ECF)
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ROBERT MOORE,
Plaintiff,
-against-
STARRETT CITY, INC.,
Defendant.
SUPPLEMENTAL RESPONSE TO PRELIMINARY CONFERENCE ORDER
EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK
Attorneys for Defendant
Starrett City, Inc.
Office and Post Office Address
55 Water Street, 28th Floor
New York, New York 10041
(212) 612-4200
3 of 3
Preview
FILED: KINGS COUNTY CLERK 07/31/2018 10:47 AM INDEX NO. 518485/2017 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 07/31/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------------x Index No.: 518485/2017 ROBERT MOORE, (ECF) Plaintiff, SUPPLEMENTAL v. RESPONSE TO PRELIMINARY CONFERENCE ORDER STARRETT CITY, INC., Defendant. ----------------------------------------------------------------------X PLEASE TAKE NOTICE, that Defendant, Starrett City, Inc., by its attorneys, Eustace, Marquez, Epstein, Prezioso & Yapchanyk, hereby supplements their response to this Court's Preliminary Conference Order dated April 11, 2018, as follows: 1. Please be advised that we have been informed by the Chubb Group of Insurance Companies, a division of Federal Insurance Company, that there is primary coverage in the amount of $1,000,000 issued by Great Northern Insurance Company, bearing policy number 73564355, applicable to this litigation. Please be further advised that we have also been informed of the following excess coverage written by National Union Fire Insurance Company of Pittsburgh, Pa. bearing policy number 020760759, with a limit of $24,000,000 applicable to this litigation. "A" 2. Annexed herein as Exhibit is a copy of the Defensive Driving Attendance Sheet showing that Margarita Santiago took the Defensive Driving Course on September 12, 2014. 1 of 3 FILED: KINGS COUNTY CLERK 07/31/2018 10:47 AM INDEX NO. 518485/2017 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 07/31/2018 Defendant hereby reserves the right to amend and/or supplement this response up to and including the time of trial. DATED: July 31, 2018 New York, New York Yours, etc., Eustace, Marquez, Epstein, Prezioso 4 Yapchanyk Attorneys for Defendant STARRETT CITY, INC. Office and Post Office Address 55 Water Street, 28th Floor New York, New York 10041 (212) 612-4200 By: Richard C. Prezioso TO: The Nolan Law Firm Attorneys for Plaintif Robert Moore 488 Madison Avenue, Suite 1100 New York, New York 10022 (212) 308-3456 2 of 3 FILED: KINGS COUNTY CLERK 07/31/2018 10:47 AM INDEX NO. 518485/2017 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 07/31/2018 Index No.: 518485/2017 (ECF) SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ROBERT MOORE, Plaintiff, -against- STARRETT CITY, INC., Defendant. SUPPLEMENTAL RESPONSE TO PRELIMINARY CONFERENCE ORDER EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK Attorneys for Defendant Starrett City, Inc. Office and Post Office Address 55 Water Street, 28th Floor New York, New York 10041 (212) 612-4200 3 of 3