On November 18, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Carlos M. Bello Rodriguez,
and
Plakos Scrap Processing, Inc.,
for Torts - Product Liability (Defective Machine)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 02/05/2021 01:44 PM INDEX NO. 523006/2020
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/05/2021
From: Harkavy, Steven
To: Plakos Scrap
Subject: RE: Bello-Rodriguez Legal defense Client NYNY33781 I ndex# 523996/ 2020
Date: Wednesday, February 3, 2021 8:26:00 PM
Attachments: Bello - Exhibit 1-10437.pdf
Josephine
Thanks you for taking my telephone call this afternoon.
Per our conversation Petitioner is claiming that the Gensco DTX 4/600, does not appear to be the
machine which injured Mr. Bello Rodriguez. They are basing their opinion based on Page 12 of the
owner manual that I attached as an exhibit. They specifically allege that on page 12 of the manual for
a diagram of the machine it references is a different shape and seems to be a completely different
machine from the one depicted in the attached photos of the machine, depicted on the photographs
that I attached to this email.
Per our conversation today, you advised me again, that the machine in question is a Gensco DTX
4/600.
What I am requesting per our conversation today is if you could this morning, (2-4-21) Physically
confirm the make, model and manufacturer on the machine depicted in in the photographs listed as
Exhibit 1, & possibly attach the photo of the machine.
Thanks you for your help & cooperation in this matter. Should you have any questions, comments,
&/or suggestions, please do not hesitate to contact me.
Thanks again
STEVEN JEFFREY HARKAVY
SENIOR TRIAL ATTORNEY
KOWALSKI & DEVITO
80 PINE STREET – SUITE 300
NEW YORK CITY, NEW YORK 10005
718-250-1100 EXT 61106
718-250-1168 FAX
STEVEN.HARKAVY@AIG.COM
To learn more about Staff Counsel & Coverage Counsel, click here
This email message is confidential, intended only for the named recipient(s) and may contain information that is privileged
attorney-client communications, attorney work product, or exempt from disclosure under applicable law.
If you are not the
intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited.
In
addition, please immediately delete or destroy all copies or versions you have of this message and notify the sender at (718)
250-1100 or steven.harkavy@aig.com in order that we may take steps to prevent any further inadvertent disclosures.
Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
From: Harkavy, Steven
Sent: Wednesday, February 03, 2021 7:36 PM
To: 'Plakos Scrap'
Subject: Bello-Rodriguez Legal defense Client NYNY33781 I ndex# 523996/ 2020
Josephine
FILED: KINGS COUNTY CLERK 02/05/2021 01:44 PM INDEX NO. 523006/2020
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/05/2021
Thanks you for taking my telephone call this afternoon.
Per our conversation Plaintif is claiming that the
STEVEN JEFFREY HARKAVY
SENIOR TRIAL ATTORNEY
KOWALSKI & DEVITO
80 PINE STREET – SUITE 300
NEW YORK CITY, NEW YORK 10005
718-250-1100 EXT 61106
718-250-1168 FAX
STEVEN.HARKAVY@AIG.COM
To learn more about Staff Counsel & Coverage Counsel, click here
This email message is confidential, intended only for the named recipient(s) and may contain information that is privileged
attorney-client communications, attorney work product, or exempt from disclosure under applicable law.
If you are not the
intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited.
In
addition, please immediately delete or destroy all copies or versions you have of this message and notify the sender at (718)
250-1100 or steven.harkavy@aig.com in order that we may take steps to prevent any further inadvertent disclosures.
Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
Document Filed Date
February 05, 2021
Case Filing Date
November 18, 2020
Category
Torts - Product Liability (Defective Machine)
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Preview
FILED: KINGS COUNTY CLERK 02/05/2021 01:44 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/05/2021 From: Harkavy, Steven To: Plakos Scrap Subject: RE: Bello-Rodriguez Legal defense Client NYNY33781 I ndex# 523996/ 2020 Date: Wednesday, February 3, 2021 8:26:00 PM Attachments: Bello - Exhibit 1-10437.pdf Josephine Thanks you for taking my telephone call this afternoon. Per our conversation Petitioner is claiming that the Gensco DTX 4/600, does not appear to be the machine which injured Mr. Bello Rodriguez. They are basing their opinion based on Page 12 of the owner manual that I attached as an exhibit. They specifically allege that on page 12 of the manual for a diagram of the machine it references is a different shape and seems to be a completely different machine from the one depicted in the attached photos of the machine, depicted on the photographs that I attached to this email. Per our conversation today, you advised me again, that the machine in question is a Gensco DTX 4/600. What I am requesting per our conversation today is if you could this morning, (2-4-21) Physically confirm the make, model and manufacturer on the machine depicted in in the photographs listed as Exhibit 1, & possibly attach the photo of the machine. Thanks you for your help & cooperation in this matter. Should you have any questions, comments, &/or suggestions, please do not hesitate to contact me. Thanks again STEVEN JEFFREY HARKAVY SENIOR TRIAL ATTORNEY KOWALSKI & DEVITO 80 PINE STREET – SUITE 300 NEW YORK CITY, NEW YORK 10005 718-250-1100 EXT 61106 718-250-1168 FAX STEVEN.HARKAVY@AIG.COM To learn more about Staff Counsel & Coverage Counsel, click here This email message is confidential, intended only for the named recipient(s) and may contain information that is privileged attorney-client communications, attorney work product, or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited. In addition, please immediately delete or destroy all copies or versions you have of this message and notify the sender at (718) 250-1100 or steven.harkavy@aig.com in order that we may take steps to prevent any further inadvertent disclosures. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege. From: Harkavy, Steven Sent: Wednesday, February 03, 2021 7:36 PM To: 'Plakos Scrap' Subject: Bello-Rodriguez Legal defense Client NYNY33781 I ndex# 523996/ 2020 Josephine FILED: KINGS COUNTY CLERK 02/05/2021 01:44 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/05/2021 Thanks you for taking my telephone call this afternoon. Per our conversation Plaintif is claiming that the STEVEN JEFFREY HARKAVY SENIOR TRIAL ATTORNEY KOWALSKI & DEVITO 80 PINE STREET – SUITE 300 NEW YORK CITY, NEW YORK 10005 718-250-1100 EXT 61106 718-250-1168 FAX STEVEN.HARKAVY@AIG.COM To learn more about Staff Counsel & Coverage Counsel, click here This email message is confidential, intended only for the named recipient(s) and may contain information that is privileged attorney-client communications, attorney work product, or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited. In addition, please immediately delete or destroy all copies or versions you have of this message and notify the sender at (718) 250-1100 or steven.harkavy@aig.com in order that we may take steps to prevent any further inadvertent disclosures. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.