No Value: Jose Gomez v. 91-93 Franklin Llc, Y.N.H. Construction Inc., Alpine Ready Mix Inc.

On December 20, 2019 a No Value 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 08/03/2022 05:19 PM INDEX NO. 527680/2019
NYSCEF DOC. NO. 128 RECEIVED NYSCEF: 08/03/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------x
JOSE GOMEZ,
Plaintiffs, Index No.: 527680/2019
-against-
Certification
91-93 FRANKLIN LLC,
Y.N.H. CONSTRUCTION INC. and
ALPINE READY MIX INC.,
Defendants.
---------------------------------------------------------------------x
91-93 FRANKLIN LLC, and Y.N.H. CONSTRUCTION
INC.,

Third-Party Plaintiff,
-against-

CAPITAL CONCRETE NY, INC.

Third-Party Defendant.
---------------------------------------------------------------------x
C O U N S E L O R S:

PLEASE TAKE NOTICE, that the annexed documents are hereby Certified by the

signature which appears below.

Dated: New York, New York
August 3, 2022

FUCHS ROSENZWEIG PLLC

/s/ Douglas R. Rosenzweig
By: Douglas R. Rosenzweig
Attorneys for Third-Party Defendant
Capital Concrete NY Inc.
11 Broadway, Suite 570
New York, New York 10004
Our File No.: 7024.12049
(646) 760-5449

To: All Parties via NYSCEF

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------x
JOSE GOMEZ,
Plaintiffs, Index No.: 527680/2019
-against-
Demand for Bills of
Particulars
91-93 FRANKLIN LLC,
Y.N.H. CONSTRUCTION INC. and
ALPINE READY MIX INC.,
Defendants.
---------------------------------------------------------------------x
91-93 FRANKLIN LLC, and Y.N.H. CONSTRUCTION
INC.,

Third-Party Plaintiff,
-against-

CAPITAL CONCRETE NY, INC.

Third-Party Defendant.
---------------------------------------------------------------------x
To: Plaintiff, Jose Gomez

PLEASE TAKE NOTICE, that you are hereby required to serve and file the

following verified particulars of plaintiff’s alleged cause of action herein, within thirty (30) days

from the date hereof:

1. The date of birth, social security number and residence of each plaintiff.

2. Date, approximate time, location and condition of weather at time of accident.

3. State the exact manner in which plaintiff alleges or will allege the accident

occurred.

4. A statement of the acts or omissions constituting the negligence claimed.

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5. Give the nature, extent, location and duration of each and every injury claimed to

have been sustained by each plaintiff specifying each injury which is claimed permanent or that

none is permanent.

6. How long will it be claimed that each plaintiff was confined to (a) hospital or

hospitals, giving specific dates of admission and discharge, (b), bed and (c) home, giving the

specific dates of confinement.

7. If x-rays, MRIs, CT Scans, EMGs or other diagnostic tests were taken, state the

name and address of the place where they were taken, the name and address of the person who

took them, the date each was taken and what it disclosed.

8. If treated by doctors or medical care providers, state the name and present address

of each doctor or medical care provider, the dates and places where treatments were received and

the date of last treatment. Annex true copies of all written reports rendered to you by any such

doctors whom you propose to have testify in your behalf.

9. If still being treated, the name and address of each doctor rendering treatment,

where and how often treatment is received and the nature thereof.

10. If a previous injury, disease, illness or condition is claimed to have been aggravated,

accelerated or exacerbated, specify in detail the nature of each and the name and present address

of each doctor, if any, who rendered treatment for said condition.

11. If employed at the time of accident, state: (a) The name and address of the

employer. (b) Position held and nature of work performed. (c) Average weekly wages for past

year. (d) Period of time lost from employment, giving dates. (e) Amount of wages lost, if any.

12. If other loss of income, profit or earnings is claimed:

(a) State total amount of said loss.

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(b) Give a complete detailed computation of said loss.

of deprivation thereof.

13. Itemize any and all other losses or expenses incurred not otherwise set forth.

14. State what earnings, if any, each plaintiff claims to have lost.

15. If there has been a return to employment or occupation, state:

(a) Name and address of present employer.

(b) Position held and nature of work performed.

16. State the sum of money claimed incurred or spent by or on behalf of each plaintiff

for:

(a) medicines,

(b) physicians services,

(d) nurses' services, itemizing amounts paid to each doctor or hospital.

17. Describe all injuries sustained by you in any prior accident.

18. Annex hereto copies of all interrogatories or bills of particular ever signed by you

in said prior incidents.

19. If damage to property is claimed to have resulted from such accident:

a. describe in detail each and every item of property allegedly damaged;

b. state the cost to repair or replace each and every item of damage to plaintiff's

property;

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c. state the amount of damages sustained by plaintiff for loss of profits and

how this amount was calculated.

20. If the accident involves property or premises, state:

a. the exact part or portion of the premises wherein the alleged accident

occurred;

b. if said occurrence took place upon a stairway the location and the step

thereon. If accident happened on sidewalk, the distance from the nearest

intersection and the nearest curb or building line;

c. the exact defect which caused the alleged occurrence and in what manner

the defendants were negligent;

d. whether this defendant had actual and/or constructive notice of the alleged

defective condition;

e. if such notice was actual, state who gave such notice, to whom same was

given and the date and who gave such notice. If constructive, the length of

time the condition existed.

f. if it is claimed that negligent repairs were made, state when, where and by

whom on behalf of the defendant they were made, and in what manner such

repairs were negligent.

21. If an intentional act or tort is claimed:

a. set forth in detail the circumstances leading up to the alleged intentional act,

including but not limited to, the physical acts, verbal threats, etc.,

b. set forth the exact acts which are alleged to constitute the intentional act.

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22. State what statutes, regulations, rules, ordinances, industry wide customs or

practices it will be claimed were violated by this defendant, specifying the chapter, section,

subdivision, article or practice thereof:

a. the date of each alleged violation;

b. how and in what manner was each violation committed by this defendant.

23. State whether plaintiff was married at the time of the occurrence alleged in the

Complaint.

24. Set forth the name and address of plaintiff's spouse.

25. If a claim will be made for loss of service or consortium set forth the manner in

which such damages are calculated.

a. identify the nature of the loss of services or consortium;

b. set forth the length of time for which such claim is made.

PLEASE TAKE FURTHER NOTICE, that in the event of the plaintiff's failure to

comply with the foregoing demand within thirty (30) days, the defendant will move to preclude

the offering of any evidence as to the matters herein demanded.

Dated: New York, New York
August 3, 2022

FUCHS ROSENZWEIG PLLC
Attorneys for Third-Party Defendant
Capital Concrete NY Inc.
11 Broadway, Suite 570
New York, New York 10004
Our File No.: 7024.12049
(646) 760-5449

To: All Parties via NYSCEF

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NYSCEF DOC. NO. 128 RECEIVED NYSCEF: 08/03/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------x
JOSE GOMEZ,
Plaintiffs, Index No.: 527680/2019
-against-
Demand for Third-Party
91-93 FRANKLIN LLC, Bills of Particulars
Y.N.H. CONSTRUCTION INC. and
ALPINE READY MIX INC.,
Defendants.
---------------------------------------------------------------------x
91-93 FRANKLIN LLC, and Y.N.H. CONSTRUCTION
INC.,

Third-Party Plaintiff,
-against-

CAPITAL CONCRETE NY, INC.

Third-Party Defendant.
---------------------------------------------------------------------x
To: Third Party Plaintiffs: 91-93 FRANKLIN LLC, and Y.N.H. CONSTRUCTION INC.

PLEASE TAKE NOTICE, that you are hereby required to serve upon the undersigned a

verified bill of particulars within ten (10) days after service of this demand setting forth:

1. If it is claimed that this answering third party/second third-party defendant breached

any agreement or contract or is liable pursuant to the terms of any agreement or contract:

a. state whether it will be claimed that such agreement or contract was oral or
in writing;

b. if oral:

i. the date said agreement or contract was entered into;
ii. where the said agreement or contract was entered into;
iii. who acted on behalf of each party in negotiating and executing said
agreement;
iv. set forth all of the terms and conditions of that agreement or contract
and specify which terms and conditions were allegedly breached;
v. the state whose law applies to the interpretation
and application of the agreement.

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c. if in writing, set forth a full, true and complete copy of the agreement or
contract and state:

i. the date said agreement or contract was entered into;
ii. where the said agreement or contract was entered into;
iii. who acted on behalf of each party in negotiating and executing said
agreement;
iv. all of the terms and conditions of that agreement or contract and
specify which terms and conditions were allegedly breached;
v. the state whose law applies to the interpretation
and application of the agreement.

d. set forth a copy of the bill for work, if any, allegedly sent by this answering
third party defendant(s) to the party serving the cross-claim or third party
complaint.

2. In what manner will it be claimed that this answering third party/second third-party

defendant breached its agreement or contract, setting forth the specific terms and conditions which

were allegedly breached.

3. If any dangerous or defective condition is alleged by co-defendant or third

party/second third-party plaintiff(s) whose pleading is being answered by the undersigned:

a. describe the nature and location of the condition complained of in your
pleadings;

b. state whether it will be claimed that this answering third party/second third-
party defendant had actual or constructive notice thereof;

c. if actual notice is claimed, state when, how, by whom, and to whom the
actual notice was given;

d. if it is alleged that this answering third party/second third-party defendant,
agent, servant, and/or employee caused or created the condition, state the
name and position of the person who caused or created the condition, any
witnesses to the alleged creation and the date when the condition was
allegedly caused or created;

e. if constructive notice is claimed, state the length of time using
minutes/hours/days/weeks the condition existed before that accident.

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4. Set forth all specific acts/omissions which you allege constitute this third-

party/second third-party defendant's negligence.

5. Set forth all facts which support your claim that the impleading or cross-claiming

party which has asserted a claim against this answering third party/second third-party defendant

was only secondarily or passively negligent.

6. Set forth a full, true and complete copy of plaintiff's bill of particulars.

7. State the exact date, time and place of the occurrence herein complained of.

8. State the exact manner in which third party plaintiff alleges or will allege the

accident(s) occurred.

9. If an intentional act or tort is claimed:

a. set forth in detail the circumstances leading up to the alleged intentional act,
including but not limited to the physical acts, verbal threats, etc.,

b. set forth the exact acts which are alleged to constitute the intentional act.

10. Set forth a statement of the acts or omissions constituting the negligence claimed.

11. State what statutes, regulations, rules, ordinances, industry wide customs or

practices itwill be claimed were violated by this third party defendant, specifying the chapter,

section, subdivision, article or practice thereof. In addition,

a. set forth the date of each violation;

b. set forth each act/omission which supports each violation allegedly
committed by this third-party/second third-party defendant.

12. With regard to third party plaintiff's claim that the product which is the subject

matter of this litigation was (1) defective, (2) unmerchantable, and/or (3) unfit, as the case may be,

state separately for each sub-part as follows:

a. if a design defect, specify the nature and type of defect and the specific part
involved, providing its name and the serial numbers involved;

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b. if a manufacturing defect, specify the nature and type of defect and the
specific part involved, providing its name and the serial numbers involved;

c. state whether you claim a combination of both (a) and (b) above;

d. state whether you claim some other type of defect or unfitness;

e. set forth in what manner third-party/second third-party plaintiff asserts the
product was defective.

13. Does third party plaintiff contend that this answering third-party/second third-party

defendant breached any warranties, whether expressed or implied? If so, state:

a. what warranty or warranties were breached;

b. whether said warranties were expressed or implied;

c. the exact nature and wording of any written warranty;

d. the exact nature and wording or purported substance of any oral warranty;

e. whether said warranty came from a manufacturer;

f. the name and address of each person or entity purporting to make such
warranty and the date and place such warranty purportedly was made or
published;

g. the general substance of any oral warranties and, the individual who made
same and the individual to whom it was made; and

h. the date the product was alleged sold by this answering party.

14. State each and every fact which third party plaintiff claims gives rise to breach of

an expressed or implied warranty by this answering third party defendant.

15. Set forth the purpose or use for which third party plaintiff purchased third party

defendant's product.

16. Describe in detail each of the conditions which third party plaintiff contends made

the product either unsafe or unfit for the purpose for which it was being used.

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17. Set forth in detail the factual basis for third party plaintiff's claim under strict

products liability as alleged in the complaint.

18. How was the allegedly defective product used at the time the alleged injury or

damage?

19. State each and every item of damage by providing specific dollar amounts which

were proximately caused by this answering party's alleged wrongful conduct, setting forth in detail

how you arrived at such computation.

PLEASE TAKE FURTHER NOTICE, that in the event of the third-party/second third-

party plaintiff's failure to comply with the foregoing demand within ten (10) days, third

party/second third-party defendant will move to preclude the offering of any evidence as to the

matters herein demanded.

Dated: New York, New York
August 3, 2022

FUCHS ROSENZWEIG PLLC
Attorneys for Third-Party Defendant
Capital Concrete NY Inc.
11 Broadway, Suite 570
New York, New York 10004
Our File No.: 7024.12049
(646) 760-5449

To: All Parties via NYSCEF

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------x
JOSE GOMEZ,
Plaintiffs, Index No.: 527680/2019
-against-
Notice to take Deposition
91-93 FRANKLIN LLC,
Y.N.H. CONSTRUCTION INC. and
ALPINE READY MIX INC.,
Defendants.
---------------------------------------------------------------------x
91-93 FRANKLIN LLC, and Y.N.H. CONSTRUCTION
INC.,

Third-Party Plaintiff,
-against-

CAPITAL CONCRETE NY, INC.

Third-Party Defendant.
---------------------------------------------------------------------x
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules

the testimony, upon oral examination, of all adverse parties will be taken before a Notary Public

who is not an attorney, or employee of an attorney, for any party or prospective party herein and

is not a person who would be disqualified to act as a juror because of interest or because of

consanguinity or affinity to any party herein, at the offices of FUCHS ROSENZWEIG, PLLC, 11

Broadway, Suite 570, New York, New York 10004, on the 28th day of September 2022, at 10:00

o'clock in the forenoon of that day with respect to the evidence material and necessary in the

defense of this action.

That the said person to be examined is required to produce at such examination the

following: books, records and papers pertaining to the above action.

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Dated: New York, New York
August 3, 2022

FUCHS ROSENZWEIG PLLC
Attorneys for Third-Party Defendant
Capital Concrete NY Inc.
11 Broadway, Suite 570
New York, New York 10004
Our File No.: 7024.12049
(646) 760-5449

To: All Parties via NYSCEF

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NYSCEF DOC. NO. 128 RECEIVED NYSCEF: 08/03/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------x
JOSE GOMEZ,
Plaintiffs, Index No.: 527680/2019
-against-
Combined Demands with
91-93 FRANKLIN LLC, First Notice to Produce
Y.N.H. CONSTRUCTION INC. and Documents
ALPINE READY MIX INC.,
Defendants.
---------------------------------------------------------------------x
91-93 FRANKLIN LLC, and Y.N.H. CONSTRUCTION
INC.,

Third-Party Plaintiff,
-against-

CAPITAL CONCRETE NY, INC.

Third-Party Defendant.
---------------------------------------------------------------------x
PLEASE TAKE NOTICE, that pursuant to CPLR Section 3101 et seq., you are hereby

required to comply with this Combined Discovery Demand and First Notice to Produce within

twenty (20) days from the date of service hereof:

First Notice to Produce Documents

1. All documents that relate to or support your claim that this defendant was negligent.

2. All documents that relate to or support your claim that this defendant had notice,

either actual or constructive, of the condition that your claim caused your accident.

3. All documents that relate to or support your claim that plaintiffs sustained

permanent or disabling injuries.

4. All documents that relate to or support your claim that plaintiffs sustained lost

income or diminished earning capacity as a result of the incident in question.

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5. All documents, bills, and statements that relate to or support your claim quantifying

plaintiffs’ total medical bills.

6. All documents, bills, and statements that relate to or support your claim quantifying

those amounts paid by any collateral source including insurance for plaintiffs’ medical bills.

7. All documents, bills, and statements that relate to or support your claim quantifying

those amounts paid out of pocket by or on behalf of plaintiffs for plaintiffs’ medical bills.

Demand for Names and Addresses of Experts

Set forth in writing:

1. The name and address of each and every expert witness.

2. The qualifications of each and every expert witness.

3. The subject matter on which each and every expert is expected to testify.

4. The substance of the facts on which each and every expert is expected to testify.

5. The substance of the opinion of each and every witness.

6. A summary of the grounds of each and every expert's opinion.

Demand for Statements

1. A copy of the statement of any party, agent, servant and/or employee of any party

represented by the undersigned whether signed or unsigned or the transcript of any electronically

recorded statement in accordance with CPLR 3101(e).

PLEASE TAKE FURTHER NOTICE that if said party is a corporation, the undersigned

demands that you serve upon him a copy of a written statement, whether signed or unsigned, or

the transcript of any electronically recorded statement of any officer, director, agent, servant or

employee in accordance with CPLR 3101(e).

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PLEASE TAKE FURTHER NOTICE that the term “statement” shall be defined in

accordance with the definition set forth in accordance with CPLR 3101(e).

Demand for Witnesses (Eyewitness, Notice and Admissions):

Pursuant to CPLR 3101, et. seq., plaintiff(s) and co-defendant(s) are required to serve upon

and deliver to the undersigned, the names and addresses of any and all witnesses to the occurrence

complained of herein, whether or not obtained by investigation made after the date of the

occurrence and regardless of how made.

PLEASE TAKE FURTHER NOTICE, that demand is also made for the names and

addresses of any and all witnesses whose testimony will be relied on to prove the existence of a

defective condition, whether or not obtained by investigation made after the date of the occurrence

and regardless of how made.

PLEASE TAKE FURTHER NOTICE, that demand is also made for the names and

addresses of any witnesses concerning any admission allegedly made by any party.

PLEASE TAKE FURTHER NOTICE, that demand is also made for the name and last

known place of residence or business of any person with information or knowledge of facts

relevant to the incident(s) or occurrence(s) which is the subject of this litigation.

PLEASE TAKE FURTHER NOTICE, that this demand shall be deemed to continue

during the pendency of the action including the trial thereof. In the event of failure or refusal to

comply with this demand, the defendant(s) shall seek to preclude the testimony of any such

witnesses.

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Demand for Accident Reports

Copies of all written reports of the accident or occurrence which is the subject of this

lawsuit prepared in the regular course of business operations or practices of any person, firm,

corporation, association or other public or private entity.

Demand for Project File

Copy of defendant’s entire project file with respect to the location referred to in the

pleadings, or concerning work at the premises where the incident allegedly occurred, including but

not limited to daily logs, photographs, and architectural drawings.

Demand for Collateral Source Information Pursuant to CPLR 4545

1. A statement whether any part of the cost of medical care, dental care, custodial care,

rehabilitation services, loss of earnings, or other economic loss sought to be recovered herein was

replaced or indemnified, in whole or in part, from any collateral source such as insurance, social

security, workers' compensation, employee benefits programs, etc.

2. If so, state the full name and address of each organization, program or entity

providing such replacement or indemnification.

3. An itemized statement of the amount in which each such claim of economic loss

was replaced or indemnified by each organization, program or entity identified in (2) above.

4. Duly executed and acknowledged original written authorizations allowing us to

obtain all such records.

PLEASE TAKE FURTHER NOTICE that, you are required to timely supplement your

responses to the foregoing demands with any additional or further information which becomes

known to you or your attorneys during this action from plaintiff’s health, disability or other insurer

or entity paying or reimbursing such economic loss.

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Demand for Employment Records

1. The names and addresses of all plaintiff(s)' employers for five (5) years prior to the

accident and up to the present, including the dates of employment by each such employer;

2. Duly executed and acknowledged original written authorizations to allow us to

obtain the complete employment records for the plaintiff(s) from each of the employers identified

in (1) above;

Demand for Medical Records

Please take notice, that demand is hereby made that you serve upon the undersigned duly

executed HIPAA compliant authorizations for the release of records pertaining to the care and

treatment rendered to plaintiff(s) in any and all hospitals.

Demand is additionally made for the production of the records of treating physicians and

HIPAA compliant authorizations permitting the inspection of said records, together with a list of

the names and addresses of all treating physicians.

Demand is additionally made for the production of medical reports of those physicians who

have previously treated or examined the plaintiff(s) and who will testify on his/her behalf. These

shall include a detailed recital of the injuries and conditions as to which testimony will be offered

at the trial, referring to and identifying those x-rays and technician reports which will be offered

at the trial.

Demand is additionally made for all medical records, reports, charts, x-rays and tests (or

duly executed authorization to obtain same), from any and all sources concerning the injuries,

illness, physical or mental condition of plaintiff(s) as respects any injury, illness, physical or

mental condition referred to in plaintiff(s) bill of particulars, answers to interrogatories or

deposition.

Case Info

Judge

DEBRA SILBER Track Judge’s New Case

Case No.

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Document Filed Date

August 03, 2022

Case Filing Date

December 20, 2019

County

Parties

91-93 FRANKLIN LLC Defendant
ALPINE READY MIX INC. Defendant
CARFORA, CHRISTOPHER Attorney for the Defendant
COSTIGAN, SEAN MICHAEL Attorney for the Defendant
DOLAN, GLENN PATRICK Attorney for the Plaintiff
Jose Gomez Plaintiff
LEVINE, JARED T Attorney for the Plaintiff
MARVIN, RACHAEL HANNA Attorney for the Defendant
MAZZUCHIN, ROBERT S. Attorney for the Defendant
MORGAN LEVINE DOLAN, P.C. Attorney for the Plaintiff
Y.N.H. CONSTRUCTION INC. Defendant
ZHU, MICHAEL H. Attorney for the Plaintiff
JEFFREY MIRAGLIOTTA Attorneys for Plaintiffs
MEHREEN HAYAT Attorneys for Defendants
PAUL WELLS Attorneys for Defendants
RACHEL MAIMIN Attorneys for Defendants
WILLIAM REGAN Attorney
DAVID DALE Attorney
KELECHI ACHOLONU Attorney
ROBERT STEINBAUM Attorney
ERIC LOPEZ Attorneys for Defendants
CHRISTOPHER MONE Attorney
SHANNON FILLMORE Attorney
JOSHUA PINKHASOV Attorneys for Defendants

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No Value: Jose Gomez v. 91-93 Franklin Llc, Y.N.H. Construction Inc., Alpine Ready Mix Inc.

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