On December 20, 2019 a
Motion-Secondary
was filed
involving a dispute between
Jose Gomez,
and
91-93 Franklin Llc,
Alpine Ready Mix Inc.,
Y.N.H. Construction Inc.,
for Torts - Other (Labor Law)
in the District Court of Kings County.
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FILED: KINGS COUNTY CLERK 10/25/2021 05:33 PM INDEX NO. 527680/2019
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------X
JOSE GOMEZ, Index No.: 527680/2019
Plaintiff,
RESPONSE TO
-against- PLAINTIFF’S
COMBINED DEMANDS
91-93 FRANKLIN LLC,
Y.N.H. CONSTRUCTION INC. and
ALPINE READY MIX INC.,
Defendants.
------------------------------------------------------------------X
PLEASE TAKE NOTICE that Defendants, 91-93 FRANKLIN LLC and Y.N.H.
CONSTRUCTION INC., by and through their attorneys RYAN & CONLON, LLP, 2 Wall
Street, Suite 710, New York, New York, hereby respond to the plaintiff’s Combined Demands
dated May 29, 2020, as follows:
1. Witnesses: The responding defendants are unaware of the existence of any witness to
the accident or witness statements.
2. Statement of Plaintiff: The responding defendants are not in possession of any other
party statements at this time. If any become available, said statements will be
provided.
3. Insurance Coverage: The responding defendants are covered through a policy of
insurance with United Specialty Insurance Company under policy number
PSS1800529 and a policy limit of $1,000,000 per occurrence.
4. Accident Reports: Attached hereto as Exhibit “A”.
5. Photographs: The responding defendants are not in possession of any photographs
responsive to this demand.
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FILED: KINGS COUNTY CLERK 10/25/2021 05:33 PM INDEX NO. 527680/2019
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2021
6. Maintenance, Repair and Inspection: The responding defendants are not in possession
of any documents/information responsive to this demand.
7. Contracts: Refer to Exhibit “A” of the responding defendants’ Response to Plaintiff’s
Notice for Discovery and Inspection, dated October 25, 2021.
8. Expert Witness: The responding defendants have yet to designate an expert witness.
All parties will be notified pursuant to the CPLR if and when an expert is retained.
9. Visual Reproductions: The responding defendants are not in possession of any
documents/information responsive to this demand.
The responding defendants reserve the right to supplement and/or amend any and all of
the above responses up to and including the time of trial.
Dated: New York, New York
October 25, 2021
_______________________________
Christopher M. Carfora, Esq.
RYAN & CONLON, LLP
Attorneys for Defendants
91-93 FRANKLIN LLC and
Y.N.H. CONSTRUCTION INC.
2 Wall Street, Suite 710
New York, New York 10005
(212) 509-6009
TO: Glenn P. Dolan, Esq.
MORGAN LEVINE DOLAN, P.C.
Attorneys for Plaintiff
JOSE GOMEZ
18 East 41st Street, 6th Floor
New York, New York 10017
(212) 785-5115
BRAND, GLICK & BRAND, P.C.
Attorneys for Defendant
ALPINE READY MIX INC.
600 Old Country Road, Suite 440
Garden City, NY 11530
(516) 746-3500
2 of 2
Document Filed Date
October 25, 2021
Case Filing Date
December 20, 2019
Category
Torts - Other (Labor Law)
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FILED: KINGS COUNTY CLERK 10/25/2021 05:33 PM INDEX NO. 527680/2019 NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------X JOSE GOMEZ, Index No.: 527680/2019 Plaintiff, RESPONSE TO -against- PLAINTIFF’S COMBINED DEMANDS 91-93 FRANKLIN LLC, Y.N.H. CONSTRUCTION INC. and ALPINE READY MIX INC., Defendants. ------------------------------------------------------------------X PLEASE TAKE NOTICE that Defendants, 91-93 FRANKLIN LLC and Y.N.H. CONSTRUCTION INC., by and through their attorneys RYAN & CONLON, LLP, 2 Wall Street, Suite 710, New York, New York, hereby respond to the plaintiff’s Combined Demands dated May 29, 2020, as follows: 1. Witnesses: The responding defendants are unaware of the existence of any witness to the accident or witness statements. 2. Statement of Plaintiff: The responding defendants are not in possession of any other party statements at this time. If any become available, said statements will be provided. 3. Insurance Coverage: The responding defendants are covered through a policy of insurance with United Specialty Insurance Company under policy number PSS1800529 and a policy limit of $1,000,000 per occurrence. 4. Accident Reports: Attached hereto as Exhibit “A”. 5. Photographs: The responding defendants are not in possession of any photographs responsive to this demand. 1 of 2 FILED: KINGS COUNTY CLERK 10/25/2021 05:33 PM INDEX NO. 527680/2019 NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/25/2021 6. Maintenance, Repair and Inspection: The responding defendants are not in possession of any documents/information responsive to this demand. 7. Contracts: Refer to Exhibit “A” of the responding defendants’ Response to Plaintiff’s Notice for Discovery and Inspection, dated October 25, 2021. 8. Expert Witness: The responding defendants have yet to designate an expert witness. All parties will be notified pursuant to the CPLR if and when an expert is retained. 9. Visual Reproductions: The responding defendants are not in possession of any documents/information responsive to this demand. The responding defendants reserve the right to supplement and/or amend any and all of the above responses up to and including the time of trial. Dated: New York, New York October 25, 2021 _______________________________ Christopher M. Carfora, Esq. RYAN & CONLON, LLP Attorneys for Defendants 91-93 FRANKLIN LLC and Y.N.H. CONSTRUCTION INC. 2 Wall Street, Suite 710 New York, New York 10005 (212) 509-6009 TO: Glenn P. Dolan, Esq. MORGAN LEVINE DOLAN, P.C. Attorneys for Plaintiff JOSE GOMEZ 18 East 41st Street, 6th Floor New York, New York 10017 (212) 785-5115 BRAND, GLICK & BRAND, P.C. Attorneys for Defendant ALPINE READY MIX INC. 600 Old Country Road, Suite 440 Garden City, NY 11530 (516) 746-3500 2 of 2