On October 21, 2015 a
Exhibit,Appendix
was filed
involving a dispute between
Alicia M Arundel,
Arthur A Belli Jr
As Parent And Natural Guardian Of Stephanie Belli, Deceased, And As The Administrator Of The E O Stephanie Belli,
Joelle Dimonte,
Melissa A Crai,
Mindy Grabina
A O E Amy Grabina, And Mindy Grabina, Individually,,
Olga Lipets,
Steven Baruch
A O E Lauren Baruch, Deceased, And Steven Baruch, Individually,,
Suzanne Schulman
As Administratrix Of The Estate Of Brittney M. Schulman, Deceased,
and
Cabot Coach Builders, Inc D B A Royale Limousine,
Carlos F Pino,
County Of Suffolk,
Romeo Dimon Marine Service, Inc.,
Steven D Romeo,
Town Of Southold,
Ultimate Class Limousine, Inc.,
Xyz Companies 1-5
Name Being Fictitious But Intended To Be The Remanufacturers, Distributors, And Or Sellers Of The 2007 Lincoln Town Car Stretch Limousine Involved In The Collision,,
for Tort
in the District Court of Suffolk County.
Preview
FILED: SUFFOLK COUNTY CLERK 06/24/2019 01:03 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 489 RECEIVED NYSCEF: 06/24/2019
EXHIBIT I
FILED: SUFFOLK COUNTY CLERK 06/24/2019 01:03 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 489 RECEIVED NYSCEF: 06/24/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
-------- ------------------------------------ ---------X
ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS Index No.: 611214/15
ADMINISTRATRIX OF THE ESTATE OF BRITTNEY
M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY
GRABlNA, AS ADMINSTRATRIX OF THE ESTATE
OF AMY GRABINA, AND MINDY GRAB1NA,
INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR
OF THE ESTATE OF LAUREN BARUCH, DECEASED, AFFIDAVIT
AND STEVEN BARUCH, INDIVIDUALLY; JOELLE
DIMONTE; AND MELISSA A. CRAI,
Plaintiffs,
-against-
ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO,
ROMEO DIMON MARINE SERVICE, INC., STEVEN
ROMEO, TOWN OF SOUTHOLD and COUNTY OF
SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a
1-5"
ROYALE LIMOUSINE and "XYZ COMPANIES
name being fictitious but intended to be the remanufacturers,
distributors and/or sellers of the 2007 Lincoln Town Car
stretch limousine involved in the collision,
Defendants.
-----------------------'--------------------------------------------X
State of New York )
County of Suffolk )
THOMAS CONNOLLY, being duly sworn deposes and says:
1. I am an Investigator for Travelers Investigator Services. In my role, I was
assigned to locate the 2005 Dodge truck and the 2007 Lincoln taxi involved in this matter. I
FILED: SUFFOLK COUNTY CLERK 06/24/2019 01:03 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 489 RECEIVED NYSCEF: 06/24/2019
found that they were impotmded by the Suffolk County Police Department at their Westhampton
Beach facility. On March 9, 2017, I visited the impound area to determine ifthe vehicles could
be inspect'ed at the SCPD impound yard or removed for an inspection. The Westhampton Beach
facility has a customer inquiry desk and there were 3 or 4 people at the desk answering
questions. I was told by one of the people at the desk that there was a hold placed on the vehicles
by the Suffolk County District Attorney's Office. I did not seek the name of the person. I was
informed that no inspections are permitted to be conducted at the facility and that they could not
be removed from the location because of a hold placed on them by the Suffolk County District
Attorney's Office.
2. I subsequently visited the location several times to determine ifthere was stilla
hold on the vehicles, including but not limited to August 3, 2018, each time being given the same
information. I was last there on December 12, 2018 when I was advised again that there was still
a hold on the vehicles. I did not seek the names of the people I spoke to at the desk.
3. I was then informed by Mr. Steigerwald that he had been told by someone at the
District Attorney's Office that the District Attorney's Office had released the hold on the
vehicles. I was advised by the Police Department that ifthe District Attorney had released the
holds on the vehicles, the owners would have received letters advisiñg them of the release. The
owners could then go and get their vehicles from the SCPD Impound Yard in Westhampton
Beach. I was also told that the vehicles could not be released to me without the release letters
from the District Attorney and a release executed by the owners permitting Travelers to remove
the vehicles.
4. I have also identified a local business that will provide flatbed transportation of
the vehicles and storage in a fenced in yard with cameras that can remove the vehicles. It is
F.
FILED: SUFFOLK COUNTY CLERK 06/24/2019 01:03 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 489 RECEIVED NYSCEF: 06/24/2019
.
Rapid Recovery, 159 W. Montauk Highway, Hampton bays, New York 11946. The location is
an independent business unrelated to Travelers.
THOMAS
S o to before me this
ay of June, 2019
RONALDE REATHERFORD
Notary Public- Stateof NewYork
Notary Pubile NO.01RE6207490
oualified in Suffolk County
My CommissionExpiresJun 15,2021
Document Filed Date
June 24, 2019
Case Filing Date
October 21, 2015
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FILED: SUFFOLK COUNTY CLERK 06/24/2019 01:03 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 489 RECEIVED NYSCEF: 06/24/2019 EXHIBIT I FILED: SUFFOLK COUNTY CLERK 06/24/2019 01:03 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 489 RECEIVED NYSCEF: 06/24/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK -------- ------------------------------------ ---------X ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS Index No.: 611214/15 ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY GRABlNA, AS ADMINSTRATRIX OF THE ESTATE OF AMY GRABINA, AND MINDY GRAB1NA, INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR OF THE ESTATE OF LAUREN BARUCH, DECEASED, AFFIDAVIT AND STEVEN BARUCH, INDIVIDUALLY; JOELLE DIMONTE; AND MELISSA A. CRAI, Plaintiffs, -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a 1-5" ROYALE LIMOUSINE and "XYZ COMPANIES name being fictitious but intended to be the remanufacturers, distributors and/or sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. -----------------------'--------------------------------------------X State of New York ) County of Suffolk ) THOMAS CONNOLLY, being duly sworn deposes and says: 1. I am an Investigator for Travelers Investigator Services. In my role, I was assigned to locate the 2005 Dodge truck and the 2007 Lincoln taxi involved in this matter. I FILED: SUFFOLK COUNTY CLERK 06/24/2019 01:03 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 489 RECEIVED NYSCEF: 06/24/2019 found that they were impotmded by the Suffolk County Police Department at their Westhampton Beach facility. On March 9, 2017, I visited the impound area to determine ifthe vehicles could be inspect'ed at the SCPD impound yard or removed for an inspection. The Westhampton Beach facility has a customer inquiry desk and there were 3 or 4 people at the desk answering questions. I was told by one of the people at the desk that there was a hold placed on the vehicles by the Suffolk County District Attorney's Office. I did not seek the name of the person. I was informed that no inspections are permitted to be conducted at the facility and that they could not be removed from the location because of a hold placed on them by the Suffolk County District Attorney's Office. 2. I subsequently visited the location several times to determine ifthere was stilla hold on the vehicles, including but not limited to August 3, 2018, each time being given the same information. I was last there on December 12, 2018 when I was advised again that there was still a hold on the vehicles. I did not seek the names of the people I spoke to at the desk. 3. I was then informed by Mr. Steigerwald that he had been told by someone at the District Attorney's Office that the District Attorney's Office had released the hold on the vehicles. I was advised by the Police Department that ifthe District Attorney had released the holds on the vehicles, the owners would have received letters advisiñg them of the release. The owners could then go and get their vehicles from the SCPD Impound Yard in Westhampton Beach. I was also told that the vehicles could not be released to me without the release letters from the District Attorney and a release executed by the owners permitting Travelers to remove the vehicles. 4. I have also identified a local business that will provide flatbed transportation of the vehicles and storage in a fenced in yard with cameras that can remove the vehicles. It is F. FILED: SUFFOLK COUNTY CLERK 06/24/2019 01:03 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 489 RECEIVED NYSCEF: 06/24/2019 . Rapid Recovery, 159 W. Montauk Highway, Hampton bays, New York 11946. The location is an independent business unrelated to Travelers. THOMAS S o to before me this ay of June, 2019 RONALDE REATHERFORD Notary Public- Stateof NewYork Notary Pubile NO.01RE6207490 oualified in Suffolk County My CommissionExpiresJun 15,2021