On October 21, 2015 a
Party Discovery
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 09/26/2019 01:15 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 545 RECEIVED NYSCEF: 09/26/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
_______________________________________----------- -----------X
SUZANNE SCHULMAN AS ADMINISTRATRIX OF THE NOTICE TO TAKE
ESTATE OF BRITTNEY M. SCHULMAN, DECEASED, DEPOSITION
ALICIA M. ARUNDAL, OLGA LIPETS, MINDY
GRABINA, A/O/E AMY GRABINA, AND MINDY Index No.: 061499/2013
GRABINA INDIVIDUALLY, STEVEN BARUCH A/O/E
LAUREN BARUCH, DECEASED, AND STEVEN
BARUCH INDIVIDUALLY, JOELLE DIMONTE,
MELISSA A. CRAI, ARTHUR A. BELLI, JR., AS
PARENT AND NATURAL GUARDIAN OF STEPHANIE
BELLI, DECEASED, AND AS THE ADMINISTRATOR
OF THE E/O STEPHANIE BELLI,
Plaintiffs,
-against-
ULTIMATE CLASS LIMOUSINE, INC., CARLOS F.
PINO, ROMEO DIMON MARINE SERVICES, INC.,
STEVEN D. ROMEO, TOWN OF SOUTHOLD, COUNTY
OF SUFFOLK, CABOT COACH BUILDERS, INC. D/B/A
ROYALE LIMOUSINE, XYZ COMPANIES 1-5 NAME
BEING FICTITIOUS BUT INTENDED TO BE THE
REMANUFACTURERS, DISTRIBOTORS, AND/OR
SELERS OF THE 2007 LINCOLN TOWN CAR STRETCH
LIMOUSINE INVOLVED IN THE COLLISION,
Defendants.
---- ¬-----------------------------------------------X
PLEASE TAKE NOTICE, that pursuant to the CPLR, Section 3101 et seq, the
undersigned, will take, on behalf of the Plaintiff, on the 12th of November, 2019 at 10:00 a.m.
in the forenoon of that date, at 3 Huntington Quadrangle, Melville, NY, the oral examination of
PATRICK MARCHESE, as a witness herein. Said examination will continue from day to day
until completed, concerning all of the relevant facts and circumstances in connection with this
litigation, including negligence, contributory negligence, liability or damages.
Plaintiff shall reserve the right to use electronic audio and visual means to record
pursuant to applicable Court rules.
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FILED: SUFFOLK COUNTY CLERK 09/26/2019 01:15 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 545 RECEIVED NYSCEF: 09/26/2019
PLEASE TAKE FURTHER NOTICE, that at the time of the taking of the testimony,
the aforesaid party is hereby required to produce the following records which may be used by the
person so testifying to refresh their recollection as to the matters herein above set forth: All
photographs and videotapes of the accident scene, accident location, vehicles involved in this
accident, and the Plaintiff herein; all accident report, incident reports, and witness statements; all
records of conviction and insurance policies; all maintenance, repair, and/or inspection records
pertaining to the subject vehicle; all work logs and/or records pertaining to the upfitting of the
subject vehicle; all guidelines, procedures, handbooks, rules, and/or protocols pertaining to
upfitting the subject vehicle, or similar vehicles; all guidelines, procedures, handbooks, rules,
and/or protocols pertaining to welding by Defendant Cabot, Ford, or the QVM program; any and
all training materials pertaining to upfitting vehicles of the same type as the subject vehicle; any
and all training materials pertaining to welding; any and all welding certifications and/or
licensees; any and all documentation pertaining to Defendant's QVM status; all other notes,
writings and memoranda relative to this claim.
Dated: New York, New York
September 26, 2019
Yours, etc
D 1 M. Seiden, Esq.
OCK O'TOOLE & MURPHY, LLP
ttorneys for Plaintiff
ARTHUR A. BELLI, JR., AS PARENT
AND NATURAL GUARDIAN OF
STEPHANIE BELLI, DECEASED
One Penn Plaza, Suite 5315
New York, New York 10119
(212) 736-5300
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FILED: SUFFOLK COUNTY CLERK 09/26/2019 01:15 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 545 RECEIVED NYSCEF: 09/26/2019
To Law Office of Andrea G. Sawyers
3 Huntington Quadrangle, Suite 102S
Melville, New York 11747
ALL OTHER PARTIES VIA ECF
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FILED: SUFFOLK COUNTY CLERK 09/26/2019 01:15 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 545 RECEIVED NYSCEF: 09/26/2019
AFFIDAVIT OF SERVICE
STATE OF NEW YORK
ss.:
COUNTY OF NEW YORK
TIFFANY COYLE being duly sworn, deposes and says:
I am over 18 years of age, I am not a party to the action, and I reside in Nassau County in
the State of New York.
I served a true copy of the annexed, NOTICE TO TAKE DEPOSITION, on
September 26, 2019, by mailing the same in a sealed envelope, with postage prepaid thereon, in
a post office or official depository of the U.S. Postal Service within the State of New York,
addressed to the last known address of the addressee as indicated below:
TO: Law Office of Andrea G. Sawyers
3 Huntington Quadrangle, Suite 102S
Melville, New York 11747
ALL OTHER PARTIES VIA ECF
Tl FA Y COYL
Sworn to before e September 26, 2019
Notary Pûblj
ANA L PENA
COMMISSIONER OF DEEDS
YORK-NO. 3-7511
CITY OF NEW
NEW YORK COU
CERT. FILED IN
EXPIRES: 7-1-20.
COMMISSION
4 of 4
Preview
FILED: SUFFOLK COUNTY CLERK 09/26/2019 01:15 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 545 RECEIVED NYSCEF: 09/26/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK _______________________________________----------- -----------X SUZANNE SCHULMAN AS ADMINISTRATRIX OF THE NOTICE TO TAKE ESTATE OF BRITTNEY M. SCHULMAN, DECEASED, DEPOSITION ALICIA M. ARUNDAL, OLGA LIPETS, MINDY GRABINA, A/O/E AMY GRABINA, AND MINDY Index No.: 061499/2013 GRABINA INDIVIDUALLY, STEVEN BARUCH A/O/E LAUREN BARUCH, DECEASED, AND STEVEN BARUCH INDIVIDUALLY, JOELLE DIMONTE, MELISSA A. CRAI, ARTHUR A. BELLI, JR., AS PARENT AND NATURAL GUARDIAN OF STEPHANIE BELLI, DECEASED, AND AS THE ADMINISTRATOR OF THE E/O STEPHANIE BELLI, Plaintiffs, -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS F. PINO, ROMEO DIMON MARINE SERVICES, INC., STEVEN D. ROMEO, TOWN OF SOUTHOLD, COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC. D/B/A ROYALE LIMOUSINE, XYZ COMPANIES 1-5 NAME BEING FICTITIOUS BUT INTENDED TO BE THE REMANUFACTURERS, DISTRIBOTORS, AND/OR SELERS OF THE 2007 LINCOLN TOWN CAR STRETCH LIMOUSINE INVOLVED IN THE COLLISION, Defendants. ---- ¬-----------------------------------------------X PLEASE TAKE NOTICE, that pursuant to the CPLR, Section 3101 et seq, the undersigned, will take, on behalf of the Plaintiff, on the 12th of November, 2019 at 10:00 a.m. in the forenoon of that date, at 3 Huntington Quadrangle, Melville, NY, the oral examination of PATRICK MARCHESE, as a witness herein. Said examination will continue from day to day until completed, concerning all of the relevant facts and circumstances in connection with this litigation, including negligence, contributory negligence, liability or damages. Plaintiff shall reserve the right to use electronic audio and visual means to record pursuant to applicable Court rules. 1 of 4 FILED: SUFFOLK COUNTY CLERK 09/26/2019 01:15 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 545 RECEIVED NYSCEF: 09/26/2019 PLEASE TAKE FURTHER NOTICE, that at the time of the taking of the testimony, the aforesaid party is hereby required to produce the following records which may be used by the person so testifying to refresh their recollection as to the matters herein above set forth: All photographs and videotapes of the accident scene, accident location, vehicles involved in this accident, and the Plaintiff herein; all accident report, incident reports, and witness statements; all records of conviction and insurance policies; all maintenance, repair, and/or inspection records pertaining to the subject vehicle; all work logs and/or records pertaining to the upfitting of the subject vehicle; all guidelines, procedures, handbooks, rules, and/or protocols pertaining to upfitting the subject vehicle, or similar vehicles; all guidelines, procedures, handbooks, rules, and/or protocols pertaining to welding by Defendant Cabot, Ford, or the QVM program; any and all training materials pertaining to upfitting vehicles of the same type as the subject vehicle; any and all training materials pertaining to welding; any and all welding certifications and/or licensees; any and all documentation pertaining to Defendant's QVM status; all other notes, writings and memoranda relative to this claim. Dated: New York, New York September 26, 2019 Yours, etc D 1 M. Seiden, Esq. OCK O'TOOLE & MURPHY, LLP ttorneys for Plaintiff ARTHUR A. BELLI, JR., AS PARENT AND NATURAL GUARDIAN OF STEPHANIE BELLI, DECEASED One Penn Plaza, Suite 5315 New York, New York 10119 (212) 736-5300 2 of 4 FILED: SUFFOLK COUNTY CLERK 09/26/2019 01:15 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 545 RECEIVED NYSCEF: 09/26/2019 To Law Office of Andrea G. Sawyers 3 Huntington Quadrangle, Suite 102S Melville, New York 11747 ALL OTHER PARTIES VIA ECF 3 of 4 FILED: SUFFOLK COUNTY CLERK 09/26/2019 01:15 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 545 RECEIVED NYSCEF: 09/26/2019 AFFIDAVIT OF SERVICE STATE OF NEW YORK ss.: COUNTY OF NEW YORK TIFFANY COYLE being duly sworn, deposes and says: I am over 18 years of age, I am not a party to the action, and I reside in Nassau County in the State of New York. I served a true copy of the annexed, NOTICE TO TAKE DEPOSITION, on September 26, 2019, by mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee as indicated below: TO: Law Office of Andrea G. Sawyers 3 Huntington Quadrangle, Suite 102S Melville, New York 11747 ALL OTHER PARTIES VIA ECF Tl FA Y COYL Sworn to before e September 26, 2019 Notary Pûblj ANA L PENA COMMISSIONER OF DEEDS YORK-NO. 3-7511 CITY OF NEW NEW YORK COU CERT. FILED IN EXPIRES: 7-1-20. COMMISSION 4 of 4