Motion to Amend in Rafik Arabov v. The City Of New York, New York City Police Department, Patrick Lacruz| Trellis.Law

On March 29, 2019 a Exhibit,Appendix was filed involving a dispute between Rafik Arabov, and New York City Police Department, Patrick Lacruz, The City Of New York, for Torts - Motor Vehicle in the District Court of Queens County.

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FILED: QUEENS COUNTY CLERK 06/01/2021 03:10 PM INDEX NO. 705559/2019
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 06/01/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS

RAFIK AROBOV,
AMENDED ANSWER
Plaintiff(s),

-against- Index #: 70555912019

THE CITY OF NEW YORK, NEW YORK CITY POLICE Law Dept. #: 2018-092777
DEPARTMENT AND PATRICK LACRUZ,
Your File #:180497
Defendant(s).

Defendants THE CITY OF NEW YORK, THE CITY OF NEW YORK S/H/A

NEW YORK CITY POLICE DEPARTMENT , PATRICK LACRUZ, by upon JAMES E.

JOHNSON, Corporation Counsel, answering the complaint, allege information and belief:

1. Deny each allegation set forth in paragraph( s) 7, 40-49, inclusive.

2. Deny knowledge or information sufficient to form a belief with respect to

the truth of the allegations set forth in paragraph(s) 1, 1I,39, inclusive.

3. Deny the allegations set forth in paragraph(s) 12-15, inclusive, except that

a notice of a claim was presented, that more than thirty days have elapsed without adjustment

thereof.

4. Deny each allegation set forth in paragraph(s) 37, inclusive, except that

with respect to those portions of the street(s), sidewalks and appurtenances referred to in the

complaint which were or may have been owned by the City of New York, defendant(s) had such

duties as were imposed by law.
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5. Deny each allegation set forth in paragraph(s) 16-36, 38, inclusive, except

that THE CITY OF NEW YORK owned, and PATRICK LACRUZ, who was acting within the

scope of his employment operated the vehicle identified in the complaint.

6. Deny each allegation set forth in paragraph(s) 2-6,8, 10, inclusive, except

that the City of New York is a municipal corporation which employed PATRICK LACRUZ and

maintains a Police Department pursuant to law.

AFFIRMATIVE DEFENSE(S)

7. Plaintif(s)' culpable conduct caused or contributed, in whole or in part, to

hislher/their injuries and or damages.

8. At all times mentioned in the complaint, plaintiff(s) knew or should have

known in the exercise of due/reasonable care of the risks and dangers incident to engaging in the

activity alleged. Plaintif(s) voluntarily performed and engaged in the alleged activity and

assumed the risk of the injuries and/or damages claimed. Plaintiff(s) failed to use all required,

proper, appropriate and reasonable safety devices andlor equipment and failed to take all proper,

appropriate and reasonable steps to assure his/herltheir safety. Plaintif(s)' primary assumption

of risk solely caused his/herltheir injuries andlor damage and defendant(s) owed no duty to the

plaintif(s) with respect to the risk assumed. Plaintiff(s)' express assumption of risk solely

caused hislher/their injuries andlor damage and defendant(s) owed no duty to the plaintiff(s) with

respect to the risk assumed. Plaintiff(s)' implied assumption of risk caused or contributed, in

whole or in part to his/trer/their injuries. In any action for injuries arising from the use of a

vehicle in, or upon which plaintiff(s) were riding; it will be claimed that the injuries andlor

damages sustained were caused by the failure of the plaintif(s) to use available seat-belts andlor

other safety devices.
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9. Defendants are immune from suit for their exercise of discretion in the

performance of a governmental function andlor their exercise of professional judgment.

10. The amounts recoverable by plaintiff(s) are subject to limitation pursuant

to Section 1601 of the Civil Practice Law and Rules, by reason of the culpable conduct of other

person(s) who are, or with reasonable diligence could have been made party iefendant(s) to this

action, or pursuant to Section 15-108 of the General Obligations Law, by reason of a prior

settlement between plaintiff(s) and said person(s), or pursuant to Section 4545 of the Civil

Practice Law and Rules are subject to reduction by collateral sources received by plaintif(s), or

by reason of the fact that punitive damages are not recoverable against municipal defendant(s).

11. In cases involving authorized emergency vehicle(s) engaged in an

emergency operation, or persons, teams, motor vehicles, and other equipment, while actually

engaged in work on a highway, or hazard vehicles while actually engaged in hazardous

operations on or adjacent to a highway, defendant(s) were not reckless in the manner in which

they acted, and are entitled to the benefits of VTL sec. 1103 and/or VTL sec. 1104.

WHEREFORE, defendant(s) demand judgment dismissing the complaint and all

cross-claims against them, or, in the event that they are adjudged liable, granting judgment over,

or apportioning such liability in accordance with their equitable shares of responsibility, and

awarding the costs of this action, together with such other and further relief as to the court may

seem just.

JAMES E. JOHNSON
Corporation Counsel
100 Church Street
New York, New York 10007
FILED: QUEENS COUNTY CLERK 06/01/2021 03:10 PM INDEX NO. 705559/2019
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 06/01/2021

Index #: 70555912019

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS

RAFIK AROBOV,

Plaintiff(s),
- against -

THE CITY OF NEW YORK, NEW YORK CITY POLICE DEPARTMENT
AND PATRICK LACRUZ,

Defendant(s)

COMBINED DEMAIID FOR
BILL OF'PARTICT]LARS & DISCOVERY

JAMES E. JOHNSON
Corporation Counsel
Attomey for Defendants THE CITY OF NEW YORK, THE CITY OF NEW
YORK S/TVA NEW YORK CITY POLICE DEPARTMENT , PATRICK
LACRUZ, 100 Church Street
New York, New York 10007
Telephone Numbers:

Early Intervention Unit (settlements - all Boroughs)
(2r2) 3s6-r66s
Pleadings Unit (212) 356-3235 (pleadings matters only)

All Other Matters (lnquire by county of venue)
Bronx Office: (718) 503-5030 (EBT's - 5045)
Brooklyn Office: (718) 724-5200 (EBT's-5226)
Manhattan Office : (2I2) 3 5 6 -272 5 (EBT's -27 9 I)
Queens Office: (718) 558-2100 (EBT's - 2105)
Staten Island Office: (718) 876-3600 (EBT's-3603)

Please refer to the following Law Dept. #:2018-092777

and indicate the County in which the action is pending in all papers,
correspondence and other communications with respect thereto.
FILED: QUEENS COUNTY CLERK 06/01/2021 03:10 PM INDEX NO. 705559/2019
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 06/01/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS

RAFIK AROBOV,
COMBINED DEMAI\D FOR
Plaintiff(s), VERIFIED BILL OF
PARTICT]LARS & DISCOVERY
-against-

THE CITY OF NEW YORK, NEW YORK CITY POLICE
DEPARTMENT AND PATRICK LACRUZ,

Defendan(s)

DEMAI\D FOR VERIFMD BILL OF'PARTICULARS

PLEASE TAKE NOTICE that pursuant to CPLR 3041, plaintiff(s) is required within 30
days following service of this demand to serve upon JAMES E. JOHNSON, Corporation Counsel, a verified
bill ofparticulars setting forth in reasonable detaila statement of the following:

l. The exact date and time of the act or occurrence.
2. The specific location of the act or occuffence with reference to addresses, landmarks, or
other identifying points of reference, including the direction and distance therefrom. If the occurrence took
place inside a premise, state specifically the location within the premise and also include the block and lot of
the premises.
3. State the injuries claimed, if any.
4. State those injuries claimed to be permanent.
5. If applicable, set forth the length of time it is alleged the plaintif(s) was confined to:
(a) Hospital(s);
(b) Bed;
(c) House.
6. If applicable, set forth the amount claimed as special damages for:
(a) Physician(s) services;
(b) Nurses services;
(c) Hospital expenses;
(d) Drugs and medical supplies;
(e) X-rays and diagnostic tests.
For each of the foregoing elements of damages please state the name and address(es) of the
provider(s) and the dates of treatment. If any of the foregoing elements of damages have been repaid to the
plaintiff(s) or otherwise paid for by other sources, identi$' each type of service recompensed, the source or
sources of such recompense, the amount so paid and the net amount of out of pocket expenses sustained by
the plaintiff(s).
7. If applicable, state the total amount of all other special damages not specified in items
above; and please state the
(a) name and address of each service provider;
(b) each date ofthe service;
(c) amount ofthe expense for eachprovider;
(d) amount of any expense paid by a third-party (including any payment made to
reimburse plaintiff);
(e) name and address of the third-party paying any expense; and
(f) amount of any unreimbursed expense paid by plaintiff(s) personally to each
provider.
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8. State the occupation of plaintiff(s) at the time of the incident; and please state the:
(a) name and address of any employer for 5 years prior to alleged incident and up to
the time of trial;
(b) length of time totally disabled from work;
(c) length of time partially disabled from work;
(d) amount claimed for lost eamings, if any;
i. if a loss of earnings claim is alleged, please state the yearly gross eamings for
each year during 5 years prior to alleged incident and up to the time of trial;
and
(e) number of days absent from work as a result of injuries sustained from the
incident.
9. State the (a) name and address of any school attended by plaintiff(s) for 5 years prior to
alleged incident and up to the time of trial; and (b) the number of days lost from school as a resultof injuries
sustained from incident.
1 0. State the home address of plaintiff(s) for a period of 5 years prior to the alleged incident
to the present.
I 1. State any other name used by plaintiff(s) and the time period when the name was used.
12. State the date of birth and social security number of plaintiff(s) (disclosure of social
security number is voluntary). If a social security number is disclosed, it willbe used by defendant(s) to
determine whether plaintif(s) is (are)Medicaid recipient(s) for purposes of determining whether a Medicaid
lien may attachto any judgment or settlement obtained against the defendant(s).
13. State whether plaintif(s) is (are) Medicare recipient(s). If plaintiffis or was a Medicare
recipient please provide their Medicare identification number and social security number (disclosure of
social security number is voluntary). If a social security number is disclosed, it will be used by
defendant(s) to verify that plaintiff(s)is (are) Medicare recipient(s) for purposes of defendant(s) meeting its
(their) Medicare reporting obligations.
14. If plaintiff(s) has ever been convicted of a crime (including any guilty plea), please state
(a) the NYSID number of plaintiff; (b) the dates of every conviction; (c) whether the conviction was state or
federal; and (d) the county where each conviction occurred.
15.If the complaint alleges loss of services, set forth the pecuniary loss, if any, alleged in
the complaint. Enumerate the damages for:
(a) Loss ofservices;
(b) Consortium;
(c) Other expenses.
16. State those injuries arising from the use or operation of a motor vehicle which are
claimed to be serious, as defined in Insurance Law $ 5102 (d), ifany.
17. If property damage is claimed, please state (a) all property damaged; (b) the fair market
value of each item at the time it was damaged; (c) the cost of repairing each item; (d) the cost of replacing
each item; (e) the date each item was acquired; (f) the purchase cost of each item; (g) the amount(s) provided
by a third-party to reimburse damage; (h) the name and address of any third-party which reimbursed damage;
and (i)amount of any unreirnbursed payment made by plaintiff(s) to replace or repair adamaged item.
18. State the manner in which it is claimed the accident occurred.
I 9. State separately the acts or omissions constituting the alleged negligence of each of the
answering defendant(s), ifany.
20. State separately the acts of each of the answering defendant(s) constituting the
intentional wrongs claimed, if any.
21. State the names of the employee(s) or agents of the answering defendant(s) who are
alleged to have committed the acts set forth in the items above.
22.Descibe any alleged dangerous and defective condition and or the object or
instrumentality complained of, as well as the nature of the condition alleged.
23. State whether any repairs were made prior to the happening of the alleged accident.
24.\f it is alleged that repairs were made prior to the happening of the accident, state when,
where, and by whom, the repairs were made.
25. State whether actual or constructive notice is claimed or whether it is alleged that
defendant created the condition complained of.
26.If acfinl notice is claimed, then set forth the following:
FILED: QUEENS COUNTY CLERK 06/01/2021 03:10 PM INDEX NO. 705559/2019
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 06/01/2021

(a) The names of the employees, agents and/or servants of the defendant(s) to
whom it will be alleged said actual notice was given;
(b) BV whom will it be claimed that said actual notice was given on each occasion
aforesaid;
(c) The date or dates of each said notice;
(d) The place said actual notice was given.
27.If constructive notice is claimed, state the length of time said condition is alleged to have
existed prior to the happening of the alleged occulrence.
28. If prior written notice is claimed, specify the nature of such notice.
29.If prior written notice is claimed, then set forth the following:
(a) The name(s) of the entity, agency, employees, agents andlor servants of the
defendant(s) towhom itwill be alleged said prior written notice was given;
(b) BV whom will it be claimed that said prior written notice was given on each
occasion aforesaid;
(c) The date or dates of each said notice;
(d) The place said notice was given.
30. In any action where plaintiff(s) claim the violation of any statute, ordinance, rule, order,
requirement or regulation, state separately and specifically all such statutes, ordinances, rules or regulations
alleged to have been violated by the answering defendant(s).
31. If applicable, describe in what respects defendant(s) failed to provide plaintif(s) with a
safe place to work.
32. If applicable, state whether plaintif(s) will allege that this defendant(s) was a party to a
contract. Ifyes;
(a) State the parties to the contract;
(b) State the contract nurnber.
33. If applicable, set forth each and every item of construction, excavation or demolition
work which the plaintiff(s) will allege was not so constructed, shored, equipped, guarded, arranged, operated
and conducted as to provide reasonable and adequate safety; setting forth the manner in which the
construction, shoring, equipping, guarding, arranging, operating and/or conducting of the construction,
excavating, or demolition work is alleged to have caused the plaintiff(s) alleged injury.
34.1f applicable, state whether the plaintiff(s) will allege that this defendant(s) exercised
control over the work being performed at the job site. If yes, state the nature and extent of the control
allegedly exercised and the exact manner in which said control was exercised.
35. If applicable, state those injuries claimed to be "grave", as defined in the Workers'
Compensation Law $ 11.

ALLEGED DEF'AMATION
Where applicable, in addition to the foregoing, if plaintiff(s) alleges defamation, the
following items are additionally demanded:
36. Whether the alleged defamatory statement was communicated orally or in a writing.
37. With respect to each of the answering defendant(s), the particular words complained of
and allegedly communicated.
38. The name(s) and address(es) of any person(s) it is alleged heard or received the
defamatory statement(s).
39. If itis alleged that the defamatory statement(s) were communicated in a writing, set
forth the date(s), nature, and content of the writing.
40. If it is alleged that any defamatory statement was published, set forth the date(s), nature
and name of the media or publication and each republication of the alleged defamatory statement.
41. The circumstances, acts, and/or omissions which evince defendant(s) knowledge of the
falsity, or reckless disregard of the truth, or malice, with respect to the statement(s) allegedly made.
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ALLEGED POLICE MISCONDUCT
Where applicable, in addition to the foregoing, if plaintiff(s) alleges police misconduct,
the following items are additionally demanded:
42. State the criminal court file and docket number of the criminal proceeding.
43. State the (a) the specific charges; (b) the disposition ofeach charge; and (c) the date of
said disposition.
44. State the date and time taken into custody.
45. State the date of arraignment.
46. State the date and time released from incarceration.
47. State the name, address, and phone nurnber of attorney(s) who represented plaintiff(s) in
the criminal proceedings.
48. State the amount claimed for legal fees, if any.
49. State the NYSID number of plaintiff(s).
50. For each criminal proceeding, including arraignment, please state the (a) the type of
proceeding; (b) the date(s) of the proceeding; (c) the name of reporter who transcribed the proceeding; and
(d) the name of Judge who presided over the proceeding.

ALLEGED EXPOST'RE TO LEAD-BASED PAINT
Where applicable, in addition to the foregoing, if plaintif(s) allege damages as a result
of exposure to lead-based paint, the following items are additionally demanded:
51. The day, month, and year of initial exposure;
52. The day, month and year when exposure terminated;
53. The address(es), including apartment. numbers, of every premises where it is alleged that
plaintiff(s) were exposed to lead-based paint;
54. The highest recorded blood lead level for plaintiff(s) and the date of the diagnosis;
55. The date of the initial diagnosis;
56. Whether it is claimed that plaintiff(s) sustained any cognitive injuries or leaming
disabilities as a result of any alleged exposure and if so, state the nature of the disability, when any such
disability was diagnosed, the school and current grade level of plaintiff(s) and whether plaintiff(s) have been
placed in any special classes.

ALLEGED ACTION FOR WRONGFT]L DEATH
Where applicable, in addition to the foregoing, if plaintiff(s) allege wrongful death, the
following items are additionally demanded:
57. State the amount claimed as pecuniary loss, specifying the loss of parental guidance by
each person dependant upoq support ofthe decedent.
58. State the names, addresses, ages, and relationships to the decedent of all persons to
whose support it is claimed the decedent contributed.
59. State the nature and purpose of the support contributed as to each person supported,
including how and when support was given.
60. State the date, place and cause of death.
61. State the length of time the decedent remained conscious of the injuries sustained.
62. State the total amounts claimed as special damages for:
(a) Funeral andburial expenses;
(b) Administration expenses;
(c) Any other damages claimed.

ALLEGED NEGLIGENT EMERGENCY MEDICAL RESPONSE
Where applicable, in addition to the foregoing, if plaintiff(s) allege negligent emergency
medical response, the following items are additionally demanded:
63 . The exact dates and times of the claimed acts or occurrences.
64. .The specific locations of the claimed acts and/or occurrences with reference to
addresses, landmarks, or other identifying points of reference. If the claimed acts and/or occurrences took
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NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 06/01/2021

place inside a premise, state specifically the location within the premise andlor the department(s), as
applicable, of said premises.
65. The specific time when the need for medical attention was first noticed by the plaintiff in
distress, or by another person.
66.lf a call for emergency assistance was made, indicate:
(a) the time at which the call was placed.
(b) the person who placed the call and, if other than the patient, his or her
relationship to the patient.
(c) the description or report of injury or emergency given.
(d) if more than one call was made to 91 1.
(e) what the caller was told by the operator.
67 .If more than one call was made to 9 1 I , indicate:
(a) the total number of calls made to 911.
(b) the time of each respective subsequent call,
(c) the person or people who made each respective subsequent call (if different from
the first call).
(d) if the description of the injury or emergency changed after the first call to 911,
indicate what the change was, why the description changed, when the change in condition was first noticed
prior to it being reported to 911, and when the change was reported to 911
(e) what the caller was told by the operator during each respective call.
68. Indicate if 91 t had been contacted earlier in the day of the incident for the same or
similar condition. If so, indicate the person or persons who made the call, and when
they made it. Describe what the person or persons were told by the operator.

69 Indicate what time emergency personnel first arrived. Also indicate, if known, the
respective names and ranks of emergency personnel who arrived on the scene. If
known, indicate if the personnel were from the FDNY or the NYPD. If the
personnel were not from either of those two agencies, identify, if known, the agency
or hospital the personnel were from.

70 Indicate, if known, what time any additional and/or subsequent emergency personnel
arrived after the initial emergency personnel. Indicate if such additional personnel
were from the FDNY or the NYPD. If the additional personnel were not from those
two agencies, identiS' the agency or agencies the personnel were from. Indicate the
names and ranks of any additional emergency personnel who arrived. Describe any
actions taken, and treatment provided by additional emergency persorurel on-scene,
or, if applicable, en route to a hospital.

7I State whether a claim is made that the answering defendant ignored or misdiagnosed
complaints, signs, or symptoms of the patient plaintiff.

(a) Ifsuch a claim is made, state specifically by name or description all
complaints, signs, and symptoms that the answering defendan(s)
ignored or misdiagnosed.

(b) State what injury is claimed as the result of the answering defendant
ignoring or misdiagnosing the complaints, signs, and symptoms.

(d) State what the misdiagnosis of the complaints, signs, and symptoms
was.

72 Describe the treatment, if any, provided by each of the arriving emergency
personnel. Indicate, with specific time(s) and location(s):

(a) if the patient was intubated.
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(i) If it is claimed that intubation was improper, describe how
and why the intubation was improper, and the affect such
alleged improper intubation had on the patient's condition,
illness, or injury.

(ii) If it is claimed that the patient should have been, but was
not intubated, describe the affect such alleged lack of
intubation had on the patient's condition, illness, or injury.

(iii) If it is claimed that there was a delay in the patient being
intubated, state the length of the delay, and explain the
affect such alleged delay had on the patient's condition,
illness, or injury.

(b) ifan intravenous line was started.

(i) If it is claimed that an intravenous line was improper,
describe how and why the intravenous line was improper,
and the affect such alleged improper use had on the
patient's condition, illness, or injury.

(i) If it is claimed that a defibrillator was improperly used,
describe how and why the use was improper, and the affect
such alleged improper use had on the patient's condition,
illness, or injury.

(iD If it is claimed that a defibrillator should have been, but was
not used, explain the affect such alleged lack ofuse had on
the patient's condition, illness, or injury.

(iii) If it is claimed that there was a delay in using a defibrillator,
state the length ofdelay, and explain the affect such alleged
delay had on the patient's condition, illness, or injury.

(d) if oxygen was required or given.

(i) if it is claimed that oxygen should have been given and was
not, explain why oxygenation was required, as well as the
affect that the alleged lack of oxygenation had on the
patient's condition, illness, or injury.

(iD if it is claimed that oxygenation was improper, explain how
it was improper, and the affect that such alleged improper
oxygenation had on the patient's condition, illness, or
injury.

(iii) if it is claimed that there was a delay in oxygenation of the
patient, state the length ofdelay, and the affect such alleged
delay had on the patient's condition, illness, or injury.

(e) if any medication was improperly administered, contraindicated,
administered in an improper dosage or improper manner.

(i) State the name and description of each drug or
medication improperly administered. Describe the
manner in which the drug or medication was
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improperly administered. State the injury claimed
as a result of the improperly administered drug or
medication. State specifically at what point the
drugs were administered improperly.

(ii) State the name and description of each drug or
medication administered iri an improper dosage.
Indicate what the improper dosage was. State the
injury claimed as a result of the improper dosage.
State specifically at what point during treatment the
drugs were administered in an improper dosage.

(iii) State the name and description of each drug or
medication claimed to be contraindicated. State in
what way it is claimed that each such drug or
medication was contraindicated. State the injuries
claimed as a result of the administering of the
contraindicated drug or medication. State
specifically at what point during treatment the
contraindicated drug or medication was
administered.

73 Indicate if the plaintiff was transported to a hospital. Specifu who transported the
plaintiff to the hospital. Indicate if the plaintiff requested to be taken to a specific
hospital. Identify the hospital to which the plaintiff was taken. lndicate what time
the plaintiff was transported from the scene t

Case Info

Judge

Tracy A Track Judge’s New Case

Case No.

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Document Filed Date

June 01, 2021

Case Filing Date

March 29, 2019

County

Parties

BRADLEY, AMANDA L. Attorney for the Defendant
Counsel, Corporation Attorney for the Defendant
Counsel, Corporation Attorney for the Defendants
LEVY, DAVID SHIMON Attorney for the Plaintiff
New York City Police Department Defendant
Patrick Lacruz Defendant
Rafik Arabov Plaintiff
The City of New York Defendant
DAVID LEE Attorneys for Plaintiffs
JAMES JOHNSON Attorneys for Defendants
LEAH FRANKEL Attorney
AMANDA KURTTI Attorney
TERRENCE KOSSEGI Attorneys for Defendants
ZACHARY CARTER Attorneys for Defendants
ALEXIS DUNCAN Attorneys for Defendants

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Exhibit,Appendix: Rafik Arabov v. The City Of New York, New York City Police Department, Patrick Lacruz

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Case Info

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