Preview
FILED: KINGS COUNTY CLERK 06/12/2018 01:05 PM INDEX NO. 518485/2017
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/12/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X Index No.: 518485/2017
ROBERT MOORE, (ECF)
Plaintiff,
RESPONSE TO
v. PRELIMINARY
CONFERENCE ORDER
STARRETT CITY, INC.,
Defendant.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE, that Defendant, Starrett City, Inc., by itsattorneys, Eustace,
Marquez, Epstein, Prezioso & Yapchanyk, hereby responds to this Court's Preliminary
Conference Order dated April 11, 2018, as follows:
INSURANCE INFORMATION
Please be advised that we have been informed by the Chubb Group of Insurance
Companies, a division of Federal Insurance Company, that there isprimary coverage in the
amount of $1,000,000 issued by Great Northern Insurance Company, bearing policy number
73564355, applicable to this litigation.
WITNESSES
Upon information and belief, the individual identified in the incident report may be a
witness in this matter.
STATEMENTS OF OPPOSING PARTIES
Defendant, Starrett City, Inc. herein is not in possession of any adverse party statements,
at this time.
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FILED: KINGS COUNTY CLERK 06/12/2018 01:05 PM INDEX NO. 518485/2017
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/12/2018
PHOTOGRAPHS
Color copies of the photographs were previously provided in Defendant's Response to
Notice for Discovery and Inspection dated June 6, 2018.
ACCIDENT REPORT
Copies of the accident reports were previously provided in Defendant's Response to
Notice for Discovery and Inspection dated June 6, 2018.
EXPERT WITNESSES
Defendant, Starrett City, Inc. herein hsd not yet decided whom they will call as expert
witnesses to testify at the time of trial of this action, but hereby reserve(s) all such rights pursuant
to CPLR § 3101 (d)(1).
Defendant hereby reserves the right to amend and/or supplement this response up to and
including the time of trial.
DATED: June 12, 2018
New York, New York
Yours, etc.,
Eustace, Marquez, Epstein, Prezioso 4
Yapchanyk
Attorneys for Defendant
STARRETT CITY, INC.
Office and Post Ofñce 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 Plaintiff, Robert Moore
488 Madison Avenue, Suite 1100
New York, New York 10022
(212) 308-3456
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FILED: KINGS COUNTY CLERK 06/12/2018 01:05 PM INDEX NO. 518485/2017
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/12/2018
Index No.: 518485/2017 (ECF)
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ROBERT MOORE,
Plaintiff,
-against-
STARRETT CITY, INC.,
Defendant.
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 06/12/2018 01:05 PM INDEX NO. 518485/2017 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/12/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------------X Index No.: 518485/2017 ROBERT MOORE, (ECF) Plaintiff, RESPONSE TO v. PRELIMINARY CONFERENCE ORDER STARRETT CITY, INC., Defendant. ----------------------------------------------------------------------X PLEASE TAKE NOTICE, that Defendant, Starrett City, Inc., by itsattorneys, Eustace, Marquez, Epstein, Prezioso & Yapchanyk, hereby responds to this Court's Preliminary Conference Order dated April 11, 2018, as follows: INSURANCE INFORMATION Please be advised that we have been informed by the Chubb Group of Insurance Companies, a division of Federal Insurance Company, that there isprimary coverage in the amount of $1,000,000 issued by Great Northern Insurance Company, bearing policy number 73564355, applicable to this litigation. WITNESSES Upon information and belief, the individual identified in the incident report may be a witness in this matter. STATEMENTS OF OPPOSING PARTIES Defendant, Starrett City, Inc. herein is not in possession of any adverse party statements, at this time. 1 of 3 FILED: KINGS COUNTY CLERK 06/12/2018 01:05 PM INDEX NO. 518485/2017 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/12/2018 PHOTOGRAPHS Color copies of the photographs were previously provided in Defendant's Response to Notice for Discovery and Inspection dated June 6, 2018. ACCIDENT REPORT Copies of the accident reports were previously provided in Defendant's Response to Notice for Discovery and Inspection dated June 6, 2018. EXPERT WITNESSES Defendant, Starrett City, Inc. herein hsd not yet decided whom they will call as expert witnesses to testify at the time of trial of this action, but hereby reserve(s) all such rights pursuant to CPLR § 3101 (d)(1). Defendant hereby reserves the right to amend and/or supplement this response up to and including the time of trial. DATED: June 12, 2018 New York, New York Yours, etc., Eustace, Marquez, Epstein, Prezioso 4 Yapchanyk Attorneys for Defendant STARRETT CITY, INC. Office and Post Ofñce 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 Plaintiff, Robert Moore 488 Madison Avenue, Suite 1100 New York, New York 10022 (212) 308-3456 2 of 3 FILED: KINGS COUNTY CLERK 06/12/2018 01:05 PM INDEX NO. 518485/2017 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/12/2018 Index No.: 518485/2017 (ECF) SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ROBERT MOORE, Plaintiff, -against- STARRETT CITY, INC., Defendant. 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