Preview
FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK Index No.: 611214/15
----------------------------------------------------------------X
ALICIA M. ARUNDEL; SUZANNE SCHULMAN, as
Administratrix of the ESTATE OF BRITTANY SCHULMAN,
deceased; OLGA LIPETS; MINDY GRABINA, as
Administratrix of the Estate of AMY GRABINA, and
MINDY GRABINA, Individually; STEVEN BARUCH, NOTICE
as Administrator of the Estate of LAUREN BARUCH, deceased TO TAKE
and STEVE BARUCH, Individually; JOELLE DIMONTE; and DEPOSITION
MELISSA A. CRAI, ARTHUR A. BELLI JR., as Parent and UPON ORAL
natural Guardian of STEPHANIE BELLI, deceased, and as the EXAMINATION
Administrator of the Estate of STEPHANIE BELLI,
Plaintiffs,
-against-
ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO,
ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO,
TOWN OF SOUTHOLD, COUNTY OF SUFFOLK,
CABOT COACH BUILDERS, INC. d/b/a ROYALE LIMOUSINE
1-5"
and "XYZ COMPANIES name being fictitious but intended
to be the remanufactureres, distributors and/or sellers of the 2007
Lincoln Town Car stretch limousine involved in the collision,
Defendants.
---------------------------------------------------- -----X
TO: COUNTYOFSUFFOLK
PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and
Rules, notice is hereby made to take testimony upon oral examination of Suffolk County DPW
Traffic Engineer III, ROBERT HILLMAN, JR., 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,
1 of 5
FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019
LOCATION: To Be Agreed Upon
DATE/TIME: September 4, 2019, 10:00 a.m.
with respect to evidence material and necessary in the prosecution/defense of this action and all
relevant facts and circumstances in connection with the accident which occurred on July 18,
2015, including negligence, contributory negligence, liability and damages.
That, said to be examined, is required to produce at such examination all evidence
relative to the negligence, liability and damages of any party to this lawsuit.
Dated: Garden City, New York
July 29, 2019
Yours, etc.,
THEJONGIO O LAW FIRM, PLLC
BRANDON M. CRUZ
Attorneys for Plaintff
ALICIA ARUNDE
1415 Kellum ce, Suite 205
Gardewetry New York 11530
(516) 741-4170
TO:
LAW OFFICE OF VINCENT D. McNAMARA
Attorney for Defendant County ofSuffolk
TOWER SQUARE - 1045 OYSTER BAY ROAD
SUITE 1
EAST NORWICH, NY 11732
(516) 922-9100
FILE NO.: 907-4677
BONGIORNO, MONTIGLIO & PALMIERI, PLLC
Attorneys for Defendants Carlos Pino and Ultimate Class Limousine, Inc.
200 OLD COUNTRY ROAD, SUITE 680
MINEOLA, NY 11530
ATTN: NEIL J. PALMlERI, ESQ.
(516) 620-4490
FILE NO.: 1BM 068515 NJP
2 of 5
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NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019
CASCONE & KLUEPFEL, LLP
Attorneys for Defendant Romeo Dimon Marine Service
1399 FRANKLIN AVENUE, STE 302
GARDEN CITY, NY 11530
(516) 747-1990
FILE NO.: 03787 DVM
LAW OFFICES OF THOMAS M. VOLZ, PLLC
Attorney for Defendant Town ofSouthold
280 SMITHTOWN BLVD.
NESCONSET, NY 11767
(631) 366-2700
LEWIS JOHS AVALLONE AVILES
Attorneys for Defendant Steven D. Romeo
ONE CA PLAZA, STE 225
ISLANDIA, NY 11749
(631) 755-0101
FILE NO.: 0114.1460.001C
LAW OFFICES OF ANDREA SAWYERS
Attorneys for Defendant
CABOT COACH BUILDERS, INC. d/b/a ROYALE LIMOUSINE
P.O. BOX 2903
HARTFORD, CT 06104
(631) 501-3100
FILE NO.: 2017024539SAS
3 of 5
FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019
AFFIDAVIT OF ELECTRONIC FILING
STATE OF NEW YORK )
)ss.:
COUNTY OF NASSAU )
Linda Lyles, being duly sworn, says; Iam not a party to thisaction,am over 18 years of age and reside in
Nassau County, New York.
On the day of ,2019, I served the within NOTICE TO TAKE DEPOSITION UPON
ORAL EXAMINATION (AS TO D. FENDANT. COUNTY OF SUFFOLK), by electronicfilingthisdate to:
LAW OFFICE OF VINCENT D. McNAMARA
Attorney for Defendant County of Suffolk
TOWER SQUARE - 1045 OYSTER BAY ROAD - SUITE I
EAST NORW1CH, NY 11732
BONGIORNO, MONTIGLIO & PALMIERI, PLLC
Attorneys for Defendants Carlos Pino and Ultimate Class Limousine, Inc.
200 OLD COUNTRY ROAD, SUITE 680
MINEOLA, NY 11530
CASCONE & KLUEPFEL, LLP
Attorneys for De fendant Romeo Dimon Marine Service
1399 FRANKLIN AVENUE, STE 302
GARDEN CITY, NY 11530
LAW OFFICES OF THOMAS M. VOLZ, PLLC
Attorney for Defendant Town ofSouthold
280 SMITHTOWN BLVD.
NESCONSET, NY 11767
LEWIS JOHS AVALLONE AVILES
Attorneys for Steven D. Romeo
ONE CA PLAZA, STE 225
ISLANDIA., NY 11749
LAW OFFICES OF ANDREA SAWYERS
Attorneys for Defendant
CABOT COACH BUILDERS, INC. d/b/aROYALE LIMOUSINE
P.O. BOX 2903
HARTFORD, CT 06104
indÉLyles
Sworn to before me thisÚ of
day ( 4/ , 2019.
BRANDON M. CRUZ
Notary blic, Sta ew Yo Notary PublicState of Ne w York
No. 02CR6003649
Qualified
in Nassau County
ConunissionExpiresMarch 9, 2022
4 of 5
FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK Index No.: 611214/2015
ALICIA M. ARUNDEL; SUZANNE SCHULMAN, as Administratrix of the ESTATE OF
BRITTANY SCHULMAN, deceased; OLGA LIPETS; MINDY GRABINA, as Administratrix of the
Estate of AMY GRABINA, and MINDY GRABINA, Individually; STEVEN BARUCH, as
Administrator of the Estate of LAUREN BARUCH, deceased and STEVE BARUC.H, Individually;
JOELLE DIM.ONTE; and MELISSA A. CRAl, ARTHUR A. BELL[ JR., as Parent and natural
Guardian of STEPHANIE .BELLI, deceased, and as the Administrator of the Estate of STEPHANIE
BELLI,
Plaintiffs,
-against-
ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE,
INC., STEVEN ROMEO, TOWN OF SOUTHOLD, COUNTY OF SU FFOLK, CABOT COACH.
BUILDERS, INC. d/b/a ROYALE LIMOUSINE and "XYZ COMPANIES 1-5"name being fictitious but
intended to be the remanufactureres, distributors and/or sellers of the 2007 Lincoln Town Car stretch
limousine involved in the collision,
Defendants.
NOTICE TO TAKE DEPOSITION
UPON ORAL EXAMINATION
THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
ALICIA M. ARUNDEL
1415 Kellum Place, Suite 205
Garden City, New York 11530
(516) 741-417
ATTORNEY CERTIFICATION: Pursuant to NYCRR 130-1.1, the undersigned, an attorney admitted to
practice in the Courts of the State of New York, certifies, to the best of his knowledge after reasonable
inquiry, that the contentions contained in the annexed document re ot frivolous.
Dated: Garden City, New York By:
July 29, 2019 BRA Ol CR , ESQ.
PLEASE TAKE NOTICE
___ NOTICE OF ENTRY that the within isa true copy of a enter d in the
office of the clerk of the within named Court on
NOTICE OF SETTLEMENT that an Order of which the within is a truecopy will be presented
for settlement to the Hon. one of the judges of the within named Court, on
5 of 5
Preview
FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Index No.: 611214/15 ----------------------------------------------------------------X ALICIA M. ARUNDEL; SUZANNE SCHULMAN, as Administratrix of the ESTATE OF BRITTANY SCHULMAN, deceased; OLGA LIPETS; MINDY GRABINA, as Administratrix of the Estate of AMY GRABINA, and MINDY GRABINA, Individually; STEVEN BARUCH, NOTICE as Administrator of the Estate of LAUREN BARUCH, deceased TO TAKE and STEVE BARUCH, Individually; JOELLE DIMONTE; and DEPOSITION MELISSA A. CRAI, ARTHUR A. BELLI JR., as Parent and UPON ORAL natural Guardian of STEPHANIE BELLI, deceased, and as the EXAMINATION Administrator of the Estate of STEPHANIE BELLI, Plaintiffs, -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD, COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC. d/b/a ROYALE LIMOUSINE 1-5" and "XYZ COMPANIES name being fictitious but intended to be the remanufactureres, distributors and/or sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. ---------------------------------------------------- -----X TO: COUNTYOFSUFFOLK PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and Rules, notice is hereby made to take testimony upon oral examination of Suffolk County DPW Traffic Engineer III, ROBERT HILLMAN, JR., 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, 1 of 5 FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019 LOCATION: To Be Agreed Upon DATE/TIME: September 4, 2019, 10:00 a.m. with respect to evidence material and necessary in the prosecution/defense of this action and all relevant facts and circumstances in connection with the accident which occurred on July 18, 2015, including negligence, contributory negligence, liability and damages. That, said to be examined, is required to produce at such examination all evidence relative to the negligence, liability and damages of any party to this lawsuit. Dated: Garden City, New York July 29, 2019 Yours, etc., THEJONGIO O LAW FIRM, PLLC BRANDON M. CRUZ Attorneys for Plaintff ALICIA ARUNDE 1415 Kellum ce, Suite 205 Gardewetry New York 11530 (516) 741-4170 TO: LAW OFFICE OF VINCENT D. McNAMARA Attorney for Defendant County ofSuffolk TOWER SQUARE - 1045 OYSTER BAY ROAD SUITE 1 EAST NORWICH, NY 11732 (516) 922-9100 FILE NO.: 907-4677 BONGIORNO, MONTIGLIO & PALMIERI, PLLC Attorneys for Defendants Carlos Pino and Ultimate Class Limousine, Inc. 200 OLD COUNTRY ROAD, SUITE 680 MINEOLA, NY 11530 ATTN: NEIL J. PALMlERI, ESQ. (516) 620-4490 FILE NO.: 1BM 068515 NJP 2 of 5 FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019 CASCONE & KLUEPFEL, LLP Attorneys for Defendant Romeo Dimon Marine Service 1399 FRANKLIN AVENUE, STE 302 GARDEN CITY, NY 11530 (516) 747-1990 FILE NO.: 03787 DVM LAW OFFICES OF THOMAS M. VOLZ, PLLC Attorney for Defendant Town ofSouthold 280 SMITHTOWN BLVD. NESCONSET, NY 11767 (631) 366-2700 LEWIS JOHS AVALLONE AVILES Attorneys for Defendant Steven D. Romeo ONE CA PLAZA, STE 225 ISLANDIA, NY 11749 (631) 755-0101 FILE NO.: 0114.1460.001C LAW OFFICES OF ANDREA SAWYERS Attorneys for Defendant CABOT COACH BUILDERS, INC. d/b/a ROYALE LIMOUSINE P.O. BOX 2903 HARTFORD, CT 06104 (631) 501-3100 FILE NO.: 2017024539SAS 3 of 5 FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019 AFFIDAVIT OF ELECTRONIC FILING STATE OF NEW YORK ) )ss.: COUNTY OF NASSAU ) Linda Lyles, being duly sworn, says; Iam not a party to thisaction,am over 18 years of age and reside in Nassau County, New York. On the day of ,2019, I served the within NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION (AS TO D. FENDANT. COUNTY OF SUFFOLK), by electronicfilingthisdate to: LAW OFFICE OF VINCENT D. McNAMARA Attorney for Defendant County of Suffolk TOWER SQUARE - 1045 OYSTER BAY ROAD - SUITE I EAST NORW1CH, NY 11732 BONGIORNO, MONTIGLIO & PALMIERI, PLLC Attorneys for Defendants Carlos Pino and Ultimate Class Limousine, Inc. 200 OLD COUNTRY ROAD, SUITE 680 MINEOLA, NY 11530 CASCONE & KLUEPFEL, LLP Attorneys for De fendant Romeo Dimon Marine Service 1399 FRANKLIN AVENUE, STE 302 GARDEN CITY, NY 11530 LAW OFFICES OF THOMAS M. VOLZ, PLLC Attorney for Defendant Town ofSouthold 280 SMITHTOWN BLVD. NESCONSET, NY 11767 LEWIS JOHS AVALLONE AVILES Attorneys for Steven D. Romeo ONE CA PLAZA, STE 225 ISLANDIA., NY 11749 LAW OFFICES OF ANDREA SAWYERS Attorneys for Defendant CABOT COACH BUILDERS, INC. d/b/aROYALE LIMOUSINE P.O. BOX 2903 HARTFORD, CT 06104 indÉLyles Sworn to before me thisÚ of day ( 4/ , 2019. BRANDON M. CRUZ Notary blic, Sta ew Yo Notary PublicState of Ne w York No. 02CR6003649 Qualified in Nassau County ConunissionExpiresMarch 9, 2022 4 of 5 FILED: SUFFOLK COUNTY CLERK 07/31/2019 11:58 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 515 RECEIVED NYSCEF: 07/31/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Index No.: 611214/2015 ALICIA M. ARUNDEL; SUZANNE SCHULMAN, as Administratrix of the ESTATE OF BRITTANY SCHULMAN, deceased; OLGA LIPETS; MINDY GRABINA, as Administratrix of the Estate of AMY GRABINA, and MINDY GRABINA, Individually; STEVEN BARUCH, as Administrator of the Estate of LAUREN BARUCH, deceased and STEVE BARUC.H, Individually; JOELLE DIM.ONTE; and MELISSA A. CRAl, ARTHUR A. BELL[ JR., as Parent and natural Guardian of STEPHANIE .BELLI, deceased, and as the Administrator of the Estate of STEPHANIE BELLI, Plaintiffs, -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD, COUNTY OF SU FFOLK, CABOT COACH. BUILDERS, INC. d/b/a ROYALE LIMOUSINE and "XYZ COMPANIES 1-5"name being fictitious but intended to be the remanufactureres, distributors and/or sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff ALICIA M. ARUNDEL 1415 Kellum Place, Suite 205 Garden City, New York 11530 (516) 741-417 ATTORNEY CERTIFICATION: Pursuant to NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the Courts of the State of New York, certifies, to the best of his knowledge after reasonable inquiry, that the contentions contained in the annexed document re ot frivolous. Dated: Garden City, New York By: July 29, 2019 BRA Ol CR , ESQ. PLEASE TAKE NOTICE ___ NOTICE OF ENTRY that the within isa true copy of a enter d in the office of the clerk of the within named Court on NOTICE OF SETTLEMENT that an Order of which the within is a truecopy will be presented for settlement to the Hon. one of the judges of the within named Court, on 5 of 5