Preview
(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 03/30/2022
From: Bazerman, Morgan S
To: "patrice.lynott@erieinsurance.com"
Subject: Glick, Jeremy & Rebecca PDF copy: Subro Notice of Claim Letter to Chefalo Carprentry POLICY 1464353903
DATE OF LOSS 08/28/2019 Claims Ref 040519043246
Date: Thursday, September 5, 2019 11:08:00 AM
Attachments: 9770212.PDF
Good Morning,
Please review attached document regarding the above claim.
Thank you.
Morgan §. Bazerman
Paralegal, Subrogation
Eustace, Prezioso & Yapchanyk
55 Water Street - 28th Floor
New York, New York 10041, USA
Office: (212)612-4380
Fax: (212)612-4284
Information contained in this electronic communication and any attachments transmitted within is CONFIDENTIAL
and may contain information that is LEGALLY PRIVILEGED. It is only for the use of the individual or entity
named above. If you are not the intended recipient, you are hereby notified that any review, release, retransmission,
copying, dissemination or other use of, or taking any action in reliance upon this communication, is strictly
prohibited. If you have received this communication in error, please destroy any printed copies. Receipt by anyone
other than the intended recipient is not a waiver of any attorney-client, attorney work product or other privileges.
000465(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM
NYSCEF DOC. NO. 21
EUSTACE, PREZIOSO & yapchanyk
ATTORNEYS AT LAW
55Water Street e28'r Fl.
INDEX NO. 500661/2021
RECEIVED NYSCEF: 03/30/2022
EDWARD M. EUSTACE
RICHARD C. PREZIOSO
CHRISTOPHER M. YAPCHANYK
Craig j.billeci
PAUL A. TUMBLESON
REGINE DELY-LAZARD
LAUREN S. YANG
MAUREEN E. PEKNIC.
TIMOTHY S.CARR
ANTHONY J. TOMARI
Nathaliec.Hackett
THOMAS B. FERRIS
TERENCE H. DeMARZO
New York,NY 10041
(212) 612-4200
(212) 612-4284
Not a Partner shipor Professional
Cor poration Bhavleen k.sabhar wal
ROBERT M. MAZZEI
Robert M.Michell
MILES A. LINEFSKY
DANIEL P. ROCCO
Michael s.munger
Hillary A.fraenkel
PETER T.mensching
Justin v.buscher
OF COUNSEL
Alanj.harris
Brendan Hennessy
Jonathan E.hill
MICHELLE GRAMLICH
September 5, 2019
Chefalo Carpentry and Construction
Evan Chefalo
P.O. Box 70
Pleasant Valley, New York
Re: NOTICE OF CLAIM
Glick, Jeremy & Rebecca
Our File Number: 040519043246
Date of Loss: August 28, 2019
Dear Sir:
Our firm represents the subrogated interests of Executive Risk Indemnity Inc., a/s/o Glick,
Jeremy & Rebecca (“Executive”) with respect to property damage that occurred on August 28",
2019 at 11 Forest Lane, Cold Spring, New York. Based on our preliminary investigation, it
appears that this loss stems from a fire caused by improperly discarded varnish rags (ZAR
Amber Varnish) that was being used on site. As such, your company, employees and/ or agents
may be responsible for all related damages. Executive expects to pay its Insureds for the
damages an amount exceeding Four Hundred Thousand Dollars ($400,000.00), and Executive
may seek to hold your company responsible for these damages.
As such, this correspondence is to serve as notice of the subrogated rights of Executive for any
and all damages stemming from the possible negligence of your company, employees, and
agents relative to the above-referenced loss.
Accordingly, you should also preserve all records, notes, account information, service tickets,
invoices and other information that relates to the work your company, agents, employees and
contractors performed relative to the above-referenced incident. It is your responsibility to
preserve all evidence and material related to the design, manufacturing and distribution, as well
as, any warnings, as potential litigation may ensue.
000466(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 03/30/2022
We request that you contact your insurance company and/ or your attorney immediately upon
receipt of this correspondence to advise them of our involvement so that they can communicate
with us about any questions they may have and/or to participate in an inspection. The site cannot
be held indefinitely so time is of the essence.
We appreciate your time and attention for this important matter.
Please do not hesitate to contact the undersigned with any questions.
Very truly yours,
Vb
if z
[ /
Michael S. Munger
Cie:
Erie Insurance Company
Attention: Patrice Lynott
Claim #A400002086212
patrice.lynott@erieinsurance.com
000467(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 03/30/2022
Chefalo Carpentry and Construction
Evan Chefalo
P.O. Box 70
Pleasant Valley, New York 12569
000468(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM
INDEX NO. 500661/2021
NYSCEF DOC. NO. 21
EUSTACE
Al
N
Stephen R. Conklin
2240 Salt Point Turnpike
Clinton Corners, NY 12514
Dear Sir:
55 WATER STREET e 28™ FL,
RECEIVED NYSCEF: 03/30/2022
» PREZIOSO & YAPCHANYK
TTORNEYS AT LAW
NEW YORK, NY 10041
TEL 2) 612-4200
FAX 2
OT AP.
ARWAL
NG
GRAMLICH
September 9, 2019
Re: NOTICE OF CLAIM
Executive Risk Indemnity Inc. a/s/o
Glick, Jeremy & Rebecca
Our File Number: 040519043246
Date of Loss: August 28, 2019
Our firm represents the subrogated interests of Executive Risk Indemnity Inc., a/s/o Glick,
Jeremy & Rebecca (“Executive”) with respect to property damage that occurred on August 28",
2019 at 11 Forest Lane, Cold Spri
ng, New York. Based on our preliminary investigation, it
appears that this loss stems from a fire caused by improperly discarded varnish rags (ZAR
Amber Varnish) that was being used on site. As such, your company, employees and/ or agents
may be responsible for all relate
damages an amount exceeding Fou
damages. Executive expects to pay its Insureds for the
x Hundred Thousand Dollars ($400,000.00), and Executive
may seek to hold your company responsible for these damages.
As such, this correspondence is to s
and all damages stemming from t
agents relative to the above-referenc
Accordingly, you should also prese
invoices and other information that
erve as notice of the subrogated rights of Executive for any
e possible negligence of your company, employees, and
ed loss.
rve all records, notes, account information, service tickets,
relates to the work your company, agents, employees and
contractors performed relative to t!
above-referenced incident. It is your responsibility to
preserve all evidence and material related to the design, manufacturing and distribution, as well
as, any warnings, as potential litigati
ion may ensue.
000469(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 03/30/2022
We request that you contact your insurance company and/ or your attorney immediately upon
receipt of this correspondence to advise them of our involvement so that they can communicate
with us about any questions they may have and/or to participate in an inspection. The site cannot
be held indefinitely so time is of the essence.
We appreciate your time and attention for this important matter.
Please do not hesitate to contact the undersigned with any questions.
Very truly yours,
fbi
Michael S. Munger
000470(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM
NYSCEF DOC. NO. 21
Stephen R. Conklin
2240 Salt Point Turnpike
Clinton Corners, NY 12514
000471
INDEX NO. 500661/2021
RECEIVED NYSCEF: 03/30/2022
Preview
(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 03/30/2022 From: Bazerman, Morgan S To: "patrice.lynott@erieinsurance.com" Subject: Glick, Jeremy & Rebecca PDF copy: Subro Notice of Claim Letter to Chefalo Carprentry POLICY 1464353903 DATE OF LOSS 08/28/2019 Claims Ref 040519043246 Date: Thursday, September 5, 2019 11:08:00 AM Attachments: 9770212.PDF Good Morning, Please review attached document regarding the above claim. Thank you. Morgan §. Bazerman Paralegal, Subrogation Eustace, Prezioso & Yapchanyk 55 Water Street - 28th Floor New York, New York 10041, USA Office: (212)612-4380 Fax: (212)612-4284 Information contained in this electronic communication and any attachments transmitted within is CONFIDENTIAL and may contain information that is LEGALLY PRIVILEGED. It is only for the use of the individual or entity named above. If you are not the intended recipient, you are hereby notified that any review, release, retransmission, copying, dissemination or other use of, or taking any action in reliance upon this communication, is strictly prohibited. If you have received this communication in error, please destroy any printed copies. Receipt by anyone other than the intended recipient is not a waiver of any attorney-client, attorney work product or other privileges. 000465(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM NYSCEF DOC. NO. 21 EUSTACE, PREZIOSO & yapchanyk ATTORNEYS AT LAW 55Water Street e28'r Fl. INDEX NO. 500661/2021 RECEIVED NYSCEF: 03/30/2022 EDWARD M. EUSTACE RICHARD C. PREZIOSO CHRISTOPHER M. YAPCHANYK Craig j.billeci PAUL A. TUMBLESON REGINE DELY-LAZARD LAUREN S. YANG MAUREEN E. PEKNIC. TIMOTHY S.CARR ANTHONY J. TOMARI Nathaliec.Hackett THOMAS B. FERRIS TERENCE H. DeMARZO New York,NY 10041 (212) 612-4200 (212) 612-4284 Not a Partner shipor Professional Cor poration Bhavleen k.sabhar wal ROBERT M. MAZZEI Robert M.Michell MILES A. LINEFSKY DANIEL P. ROCCO Michael s.munger Hillary A.fraenkel PETER T.mensching Justin v.buscher OF COUNSEL Alanj.harris Brendan Hennessy Jonathan E.hill MICHELLE GRAMLICH September 5, 2019 Chefalo Carpentry and Construction Evan Chefalo P.O. Box 70 Pleasant Valley, New York Re: NOTICE OF CLAIM Glick, Jeremy & Rebecca Our File Number: 040519043246 Date of Loss: August 28, 2019 Dear Sir: Our firm represents the subrogated interests of Executive Risk Indemnity Inc., a/s/o Glick, Jeremy & Rebecca (“Executive”) with respect to property damage that occurred on August 28", 2019 at 11 Forest Lane, Cold Spring, New York. Based on our preliminary investigation, it appears that this loss stems from a fire caused by improperly discarded varnish rags (ZAR Amber Varnish) that was being used on site. As such, your company, employees and/ or agents may be responsible for all related damages. Executive expects to pay its Insureds for the damages an amount exceeding Four Hundred Thousand Dollars ($400,000.00), and Executive may seek to hold your company responsible for these damages. As such, this correspondence is to serve as notice of the subrogated rights of Executive for any and all damages stemming from the possible negligence of your company, employees, and agents relative to the above-referenced loss. Accordingly, you should also preserve all records, notes, account information, service tickets, invoices and other information that relates to the work your company, agents, employees and contractors performed relative to the above-referenced incident. It is your responsibility to preserve all evidence and material related to the design, manufacturing and distribution, as well as, any warnings, as potential litigation may ensue. 000466(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 03/30/2022 We request that you contact your insurance company and/ or your attorney immediately upon receipt of this correspondence to advise them of our involvement so that they can communicate with us about any questions they may have and/or to participate in an inspection. The site cannot be held indefinitely so time is of the essence. We appreciate your time and attention for this important matter. Please do not hesitate to contact the undersigned with any questions. Very truly yours, Vb if z [ / Michael S. Munger Cie: Erie Insurance Company Attention: Patrice Lynott Claim #A400002086212 patrice.lynott@erieinsurance.com 000467(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 03/30/2022 Chefalo Carpentry and Construction Evan Chefalo P.O. Box 70 Pleasant Valley, New York 12569 000468(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021 NYSCEF DOC. NO. 21 EUSTACE Al N Stephen R. Conklin 2240 Salt Point Turnpike Clinton Corners, NY 12514 Dear Sir: 55 WATER STREET e 28™ FL, RECEIVED NYSCEF: 03/30/2022 » PREZIOSO & YAPCHANYK TTORNEYS AT LAW NEW YORK, NY 10041 TEL 2) 612-4200 FAX 2 OT AP. ARWAL NG GRAMLICH September 9, 2019 Re: NOTICE OF CLAIM Executive Risk Indemnity Inc. a/s/o Glick, Jeremy & Rebecca Our File Number: 040519043246 Date of Loss: August 28, 2019 Our firm represents the subrogated interests of Executive Risk Indemnity Inc., a/s/o Glick, Jeremy & Rebecca (“Executive”) with respect to property damage that occurred on August 28", 2019 at 11 Forest Lane, Cold Spri ng, New York. Based on our preliminary investigation, it appears that this loss stems from a fire caused by improperly discarded varnish rags (ZAR Amber Varnish) that was being used on site. As such, your company, employees and/ or agents may be responsible for all relate damages an amount exceeding Fou damages. Executive expects to pay its Insureds for the x Hundred Thousand Dollars ($400,000.00), and Executive may seek to hold your company responsible for these damages. As such, this correspondence is to s and all damages stemming from t agents relative to the above-referenc Accordingly, you should also prese invoices and other information that erve as notice of the subrogated rights of Executive for any e possible negligence of your company, employees, and ed loss. rve all records, notes, account information, service tickets, relates to the work your company, agents, employees and contractors performed relative to t! above-referenced incident. It is your responsibility to preserve all evidence and material related to the design, manufacturing and distribution, as well as, any warnings, as potential litigati ion may ensue. 000469(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM INDEX NO. 500661/2021 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 03/30/2022 We request that you contact your insurance company and/ or your attorney immediately upon receipt of this correspondence to advise them of our involvement so that they can communicate with us about any questions they may have and/or to participate in an inspection. The site cannot be held indefinitely so time is of the essence. We appreciate your time and attention for this important matter. Please do not hesitate to contact the undersigned with any questions. Very truly yours, fbi Michael S. Munger 000470(FILED: PUTNAM COUNTY CLERK 0373072022 01:22 PM NYSCEF DOC. NO. 21 Stephen R. Conklin 2240 Salt Point Turnpike Clinton Corners, NY 12514 000471 INDEX NO. 500661/2021 RECEIVED NYSCEF: 03/30/2022