Preview
FILED::
[FILED SUFFOLK
SUFROLK COUNTY
COUNTY CLERK
CLERK 11/14/2019
03/29/2016 10:16
02 :57 AM
PM|
INDEX
INDEX NO.
NO. 611214/2015
609082/2315
NYSCEF
NYSCEF DOC.
DOC. NO.
NO 585
35 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 11/14/2019
03/29/2316
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
----------------------- --------------------------X
ALICIA M. ARUNDEL,
Plaintiff, Index No: 609082/15
- against - ANSWER TO
DEFENDANT, COUNTY
STEVEN D. ROMEO, ROMEO DIMON MARINE OF SUFFOLK'S
SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS
LIMOUSINE, INC., THE COUNTY OF SUFFOLK and
THE TOWN OF SOUTHOLD,
Defendants.
-------------------------------------------------- ¬-----X
Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its
attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendant,
COUNTY OF SUFFOLK 's,cross-claims.
1. Denies each and every allegation contained in defendant's cross-claim.
WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment
dismissing defendant's cross-claims together with costs and disbursements.
Dated: Garden City, New York
March 28, 2016
By:
D1VID F. EPFEL, ESQ.
CASCONE & KLUEPFEL, LLP
Attorneys for Defendant
ROMEO DIMON MARINE
SERVICES, INC.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
(516) 747-1990
File No.: 03787DVM
1 of 2
FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
TO: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
20 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 11
Smithtown, New York 11787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
2 of 2
FILED:
FILED : SUFFOLK
SUFFOLK COUNTY
COUNTY CLERK
CLERK 11/14/2019
03/29/2016 10:16
02 :57 AM
PM)
INDEX
INDEX NO.
NO . 611214/2015
6 0 90 8 2 / 2 0 15
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 585
36 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 11/14/2019
03/29/2016
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
COUNTY OF NASSAU )ss.:
I,LAUREN LUCCHESE, being duly sworn, say: I am not a party to the action, am over 18 years of
age and reside at Suffolk County, New York:
On March 29, 2016 I served the within ANSWER TO DEFENDANT COUNTY OF SUFFOLK'S
CROSS-CLAIMS
[x] service
by a true copy thereof in a post-paid
by depositing wrapper, in an official under the exclusive
depository care and official
depositoryunderthe
Mail exclusive
care and custody
of the U.S. Postal Service within
the NewYork addressed
State, toeach ofthe persons
following atthe last
known
address set forth
after each name:
[] Personal a true copy thereof personally
by delivering to each person named below I knew each person served to be the person
at the address indicated.
Served on mentionedand described in said papers as a party
therein:
individual
[ ]Serviceby the papers by electronic
by transmitting means to the telephone number which
listed below, number was designated by the attomey
for such
Electronic purpose. I received
a signal
from the equipment
of the attorney served indicating transmission
that the was received.
Ialso deposited a true
Means copy of the papers, enclosed in a post-paid
wrapper,in an official under the care and custody of the U.S. Postal Service, addressed to
depository
at the address set forth after each name:
the attorney
[ I Overnight a true copy
by depositing enclosed
thereof, in a wrapper
addressed as shownbelow,intothe custodyofUNITE D PARCEL SERVICE for
overnight prior
delivery, to the latest time designated by that service for overnight
delivery.
TO: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
20 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
1 of 2
FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 11
Smithtown, New York 11787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
LAUREN LUCCHESE
Sworn to before me this
29*
day of March, 2016
LESLtE GORDON
Notary Public, ww York
Notary Public
LESLIE GORDON
NotaryPublic,Stateof New Yodt
No.01GO6028652
Qualified
in Nassau Cou
Commission ExpiresAugust 2,
2 of 2
FILED::
[FILED SUFFOLK
SUF Ej'OLK COUNTY
COUNTY CLERK
CLERK 11/14/2019
03/29/2016 10:16
02 :59 AM
PMI
INDEX
INDEX NO.
NO. 611214/2015
609082/2015
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 585
37 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 11/14/2019
03/29/2316
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
----------------- ---------- ------------X
ALICIA M. ARUNDEL,
Plaintiff, Index No: 609082/15
- against - ANSWER TO
DEFENDANTS', PINO
STEVEN D. ROMEO, ROMEO DIMON MARINE AND ULTIMATE'S
SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS
LIMOUSINE, INC., THE COUNTY OF SUFFOLK and
THE TOWN OF SOUTHOLD,
Defendants.
_________---______---------.......------------ ¬----------------X
Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its
attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendants,
CARLOS F. PlNO and ULTIMATE CLASS LIMOUSINE, INC.'s, cross-claims.
defendants'
1. Denies each and every allegation contained in cross-claim.
WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment
defendants'
dismissing cross-claims together with costs and disbursements.
Dated: Garden City, New York
March 28, 2016
DÁV F. PFEL, ESQ.
CASCONE & KLUEPFEL, LLP
Attorneys for Defendant
ROMEO DIMON MARINE
SERVICES, INC.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
(516) 747-1990
File No.: 03787DVM
1 of 2
FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
TO: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola Boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
20 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 11
Smithtown, New York 11787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
2 of 2
FILED:
FILED : SUFFOLK
SUF i OLK COUNTY
COUNTY CLERK
CLERK 11/14/2019
03/29/2016 10:16
03: 00 AM INDEX
INDEX NO.
NO. 611214/2015
609082/2015
PM)
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 585
39 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 11/14/2019
03/29/2316
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
..___..___________________________________X
ALICIA M. ARUNDEL,
Plaintiff, Index No: 609082/15
- - ANSWER
against TO
DEFENDANT, TOWN
STEVEN D. ROMEO, ROMEO DIMON MARINE OF SOUTHOLD'S
SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS
LIMOUSINE, INC., THE COUNTY OF SUFFOLK and
THE TOWN OF SOUTHOLD,
Defendants.
____________________---- X
Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its
attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendant,
TOWN OF SOUTHOLD's, cross-claims.
1. Denies each and every allegation contained in defendant's cross-claim.
WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment
dismissing defendant's cross-claims together with costs and disbursements.
Dated: Garden City, New York
March 28, 2016
ID PFEL, ESQ.
CASCONE & KLUEPFEL, LLP
Attorneys for Defendant
ROMEO DIMON MARINE
SERVICES, INC.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
(516) 747-1990
File No.: 03787DVM
1 of 2
FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
TO: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola Boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PlNO and
ULTIMATE CLASS LIMOUSINE, INC.
20 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 11
Smithtown, New York 11787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
2 of 2
FILED:
FILED : SUFFOLK
SUFFOLK COUNTY
COUNTY CLERK
CLERK 11/14/2019
03/29/2016 10:16
03: 00 AM
PM|
INDEX
INDEX NO.
NO. 611214/2015
60 90 82 /2 015
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 585
40 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 11/14/2019
03/29/2016
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
COUNTY OF NASSAU )ss.:
I, LAUREN LUCCHESE, being duly sworn, say: I am not a party to the action, am over 18 years of
age and reside at Suffolk County, New York:
On March 29, 2016 I served the within ANSWER TO DEFENDANT TOWN OF SOUTHOLD'S
CROSS-CLAIMS
[x]Serviceby a true copy thereof in a post-paid wrapper,
by depositing in an official under the exclusive
depository care and official
depositoryunderthe
Mail exclusive
care and custody
of the U.S. Postal Service within
the New YorkState, addressed to each of the following
persons at the
last known
address set forth after each name:
[ ]Personal by delivering to each person named below at the address indicated.
a true copy thereof personally I knew each person served to be the person
Served on mentionedand described in said papers as a party
therein:
individual
[ ]Serviceby the papers by electronic
by transmitting means to the telephone number
listed below,
which number was designated by the attomey
for such
Electronic purpose. I received a signal
from the equipment
of the attorney served indicating was received.
that the transmission I also deposited a true
Means copy of the papers, enclosed in a post-paid
wrapper,in an official under the care and custody of the U.S. Postal Service, addressed to
depository
the attorney at the address set forth after each name:
[ ] Overnight a true
by depositing copy enclosed
thereof, in a wrapper
addressed as shownbelow,intothe custodyofUNITED PARCEL SERVICE for
ovemight prior
delivery, to the latest time designated by that service for overnight
delivery.
TO: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
20 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
1 of 2
FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 11
Smithtown, New York 11787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
LAUREN LUCCHESE
Sworn to before me this
29*
day of March, 2016
LESLIE GORDON
Pub Ic
trotary New Wrk
GomÊss E Augu
', 0Û
Notary Public
2 of 2
FILED::
IFILED SUFFOLK
SUFFOLK COUNTY
COUNTY CLERK
CLERK 11/14/2019
10/05/2015 10:16
03: 07 AM
PM|
INDEX
INDEX NO.
NO. 611214/2015
609082/2015
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 585
10 RECEIVED
RECE IVED NYSCEF:
NY SCEF : 11/14/2019
10/05/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
---------------- ------------------------------X Index No.: 609082/2015
ALICIA M. ARUNDEL,
Plaintiff(s),
-against- REPLY TO CROSS-CLAIM
OF DEFENDANT, ROMEO
STEVEN D. ROMEO, ROMEO DIMON MARINE DIMON MARINE SERVICES, INC.
SERVICES, INC. CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.,
Defendant(s).
---- ------¬----------------------- ------------------X
The defendants, CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC.,
by their attorneys, AHMUTY, DEMERS & McMANUS, ESQS., as and for their reply to
defendant, ROMEO DIMON MARINE SERVICES, INC's cross-claim, alleges upon
information and belief:
AS AND FOR AN ANSWER TO A CROSS-CLAIM
FIRST: Denies each and every allegation contained in paragraphs designated
"20"
of the cross claim.
WHEREFORE, defendants, CARLOS F. PINO and ULTIMATE CLASS
LIMOUSINE, INC., demands judgment dismissing the cross claim of the defendant,
ROMEO DIMON MARINE SERVICES, INC., together with the costs and disbursements
of this action.
Dated: Albertson, New York
October 2, 2015
Yours, etc.
AHMUTY, RS McMANUS, ESQS.
By: Neil J. Palmieri, Esq.
FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
Attorneys for CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
200 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
Our File No.: 1BM 068515 NJP
To: The Bongiorno Law Firm, PLLC
Attorneys for Plaintiff
250 Mineola Boulevard
Mineola, New York 11501
(516) 741-4170
File No. 6230.PP
Lewis, Johs, Avallone & Aviles, LLP
Attorneys for Steven D. Romeo
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No. 0114-1460-001C
Cascone & Kluepfel, LLP
Attorneys for Romeo Dimon Marine Services, Inc.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
(516) 747-1990
File No. 03787DVM
FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
STATE OF NEW YORK )
) ss:
COUNTY OF NASSAU )
TRACEY DAVIDA-HERBST, being duly sworn deposes and says that she is
not a party to this action; that she is over the age of eighteen years; resides in Babylon
Village, New York;
5th
That on the day of October, 2015, she served the within
Reply to Cross-Claim of Defendant, Romeo Dimon Marine Services, Inc.
Upon:
The Bongiorno Law Firm, PLLC
250 Mineola Boulevard
Mineola, New York 11501
Lewis, Johs, Avallone & Aviles, LLP
One CA Plaza, Suite 225
Islandia, New York 11749
Cascone & Kluepfel, LLP
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
the attorneys for the respective parties, hereto at the address designated by them for that
purpose, by depositing a true copy of same enclosed in a postpaid properly addressed
wrapper, in an official depository under the exclusive care and custody of the United
States Post Office Department within the State of New York.
TRA Y . DAVÏDA T
Sworn to before me on this
5th
day of October, 2015
Notary Publi
CHRISTINA JEFFORDS
Notary Public,Stateof New York
No. 01RO6137142
Qualifiedin Nassau Count
Commission ExpiresNov. 14,
Preview
FILED:: [FILED SUFFOLK SUFROLK COUNTY COUNTY CLERK CLERK 11/14/2019 03/29/2016 10:16 02 :57 AM PM| INDEX INDEX NO. NO. 611214/2015 609082/2315 NYSCEF NYSCEF DOC. DOC. NO. NO 585 35 RECEIVED RECEIVED NYSCEF: NYSCEF: 11/14/2019 03/29/2316 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ----------------------- --------------------------X ALICIA M. ARUNDEL, Plaintiff, Index No: 609082/15 - against - ANSWER TO DEFENDANT, COUNTY STEVEN D. ROMEO, ROMEO DIMON MARINE OF SUFFOLK'S SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS LIMOUSINE, INC., THE COUNTY OF SUFFOLK and THE TOWN OF SOUTHOLD, Defendants. -------------------------------------------------- ¬-----X Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendant, COUNTY OF SUFFOLK 's,cross-claims. 1. Denies each and every allegation contained in defendant's cross-claim. WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment dismissing defendant's cross-claims together with costs and disbursements. Dated: Garden City, New York March 28, 2016 By: D1VID F. EPFEL, ESQ. CASCONE & KLUEPFEL, LLP Attorneys for Defendant ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 (516) 747-1990 File No.: 03787DVM 1 of 2 FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 TO: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 20 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 11 Smithtown, New York 11787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 2 of 2 FILED: FILED : SUFFOLK SUFFOLK COUNTY COUNTY CLERK CLERK 11/14/2019 03/29/2016 10:16 02 :57 AM PM) INDEX INDEX NO. NO . 611214/2015 6 0 90 8 2 / 2 0 15 NYSCEF NYSCEF DOC. DOC. NO. NO. 585 36 RECEIVED RECEIVED NYSCEF: NYSCEF: 11/14/2019 03/29/2016 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) COUNTY OF NASSAU )ss.: I,LAUREN LUCCHESE, being duly sworn, say: I am not a party to the action, am over 18 years of age and reside at Suffolk County, New York: On March 29, 2016 I served the within ANSWER TO DEFENDANT COUNTY OF SUFFOLK'S CROSS-CLAIMS [x] service by a true copy thereof in a post-paid by depositing wrapper, in an official under the exclusive depository care and official depositoryunderthe Mail exclusive care and custody of the U.S. Postal Service within the NewYork addressed State, toeach ofthe persons following atthe last known address set forth after each name: [] Personal a true copy thereof personally by delivering to each person named below I knew each person served to be the person at the address indicated. Served on mentionedand described in said papers as a party therein: individual [ ]Serviceby the papers by electronic by transmitting means to the telephone number which listed below, number was designated by the attomey for such Electronic purpose. I received a signal from the equipment of the attorney served indicating transmission that the was received. Ialso deposited a true Means copy of the papers, enclosed in a post-paid wrapper,in an official under the care and custody of the U.S. Postal Service, addressed to depository at the address set forth after each name: the attorney [ I Overnight a true copy by depositing enclosed thereof, in a wrapper addressed as shownbelow,intothe custodyofUNITE D PARCEL SERVICE for overnight prior delivery, to the latest time designated by that service for overnight delivery. TO: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 20 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 1 of 2 FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 11 Smithtown, New York 11787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 LAUREN LUCCHESE Sworn to before me this 29* day of March, 2016 LESLtE GORDON Notary Public, ww York Notary Public LESLIE GORDON NotaryPublic,Stateof New Yodt No.01GO6028652 Qualified in Nassau Cou Commission ExpiresAugust 2, 2 of 2 FILED:: [FILED SUFFOLK SUF Ej'OLK COUNTY COUNTY CLERK CLERK 11/14/2019 03/29/2016 10:16 02 :59 AM PMI INDEX INDEX NO. NO. 611214/2015 609082/2015 NYSCEF NYSCEF DOC. DOC. NO. NO. 585 37 RECEIVED RECEIVED NYSCEF: NYSCEF: 11/14/2019 03/29/2316 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ----------------- ---------- ------------X ALICIA M. ARUNDEL, Plaintiff, Index No: 609082/15 - against - ANSWER TO DEFENDANTS', PINO STEVEN D. ROMEO, ROMEO DIMON MARINE AND ULTIMATE'S SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS LIMOUSINE, INC., THE COUNTY OF SUFFOLK and THE TOWN OF SOUTHOLD, Defendants. _________---______---------.......------------ ¬----------------X Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendants, CARLOS F. PlNO and ULTIMATE CLASS LIMOUSINE, INC.'s, cross-claims. defendants' 1. Denies each and every allegation contained in cross-claim. WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment defendants' dismissing cross-claims together with costs and disbursements. Dated: Garden City, New York March 28, 2016 DÁV F. PFEL, ESQ. CASCONE & KLUEPFEL, LLP Attorneys for Defendant ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 (516) 747-1990 File No.: 03787DVM 1 of 2 FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 TO: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola Boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 20 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 11 Smithtown, New York 11787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 2 of 2 FILED: FILED : SUFFOLK SUF i OLK COUNTY COUNTY CLERK CLERK 11/14/2019 03/29/2016 10:16 03: 00 AM INDEX INDEX NO. NO. 611214/2015 609082/2015 PM) NYSCEF NYSCEF DOC. DOC. NO. NO. 585 39 RECEIVED RECEIVED NYSCEF: NYSCEF: 11/14/2019 03/29/2316 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ..___..___________________________________X ALICIA M. ARUNDEL, Plaintiff, Index No: 609082/15 - - ANSWER against TO DEFENDANT, TOWN STEVEN D. ROMEO, ROMEO DIMON MARINE OF SOUTHOLD'S SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS LIMOUSINE, INC., THE COUNTY OF SUFFOLK and THE TOWN OF SOUTHOLD, Defendants. ____________________---- X Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendant, TOWN OF SOUTHOLD's, cross-claims. 1. Denies each and every allegation contained in defendant's cross-claim. WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment dismissing defendant's cross-claims together with costs and disbursements. Dated: Garden City, New York March 28, 2016 ID PFEL, ESQ. CASCONE & KLUEPFEL, LLP Attorneys for Defendant ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 (516) 747-1990 File No.: 03787DVM 1 of 2 FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 TO: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola Boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PlNO and ULTIMATE CLASS LIMOUSINE, INC. 20 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 11 Smithtown, New York 11787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 2 of 2 FILED: FILED : SUFFOLK SUFFOLK COUNTY COUNTY CLERK CLERK 11/14/2019 03/29/2016 10:16 03: 00 AM PM| INDEX INDEX NO. NO. 611214/2015 60 90 82 /2 015 NYSCEF NYSCEF DOC. DOC. NO. NO. 585 40 RECEIVED RECEIVED NYSCEF: NYSCEF: 11/14/2019 03/29/2016 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) COUNTY OF NASSAU )ss.: I, LAUREN LUCCHESE, being duly sworn, say: I am not a party to the action, am over 18 years of age and reside at Suffolk County, New York: On March 29, 2016 I served the within ANSWER TO DEFENDANT TOWN OF SOUTHOLD'S CROSS-CLAIMS [x]Serviceby a true copy thereof in a post-paid wrapper, by depositing in an official under the exclusive depository care and official depositoryunderthe Mail exclusive care and custody of the U.S. Postal Service within the New YorkState, addressed to each of the following persons at the last known address set forth after each name: [ ]Personal by delivering to each person named below at the address indicated. a true copy thereof personally I knew each person served to be the person Served on mentionedand described in said papers as a party therein: individual [ ]Serviceby the papers by electronic by transmitting means to the telephone number listed below, which number was designated by the attomey for such Electronic purpose. I received a signal from the equipment of the attorney served indicating was received. that the transmission I also deposited a true Means copy of the papers, enclosed in a post-paid wrapper,in an official under the care and custody of the U.S. Postal Service, addressed to depository the attorney at the address set forth after each name: [ ] Overnight a true by depositing copy enclosed thereof, in a wrapper addressed as shownbelow,intothe custodyofUNITED PARCEL SERVICE for ovemight prior delivery, to the latest time designated by that service for overnight delivery. TO: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 20 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 1 of 2 FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 11 Smithtown, New York 11787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 LAUREN LUCCHESE Sworn to before me this 29* day of March, 2016 LESLIE GORDON Pub Ic trotary New Wrk GomÊss E Augu ', 0Û Notary Public 2 of 2 FILED:: IFILED SUFFOLK SUFFOLK COUNTY COUNTY CLERK CLERK 11/14/2019 10/05/2015 10:16 03: 07 AM PM| INDEX INDEX NO. NO. 611214/2015 609082/2015 NYSCEF NYSCEF DOC. DOC. NO. NO. 585 10 RECEIVED RECE IVED NYSCEF: NY SCEF : 11/14/2019 10/05/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ---------------- ------------------------------X Index No.: 609082/2015 ALICIA M. ARUNDEL, Plaintiff(s), -against- REPLY TO CROSS-CLAIM OF DEFENDANT, ROMEO STEVEN D. ROMEO, ROMEO DIMON MARINE DIMON MARINE SERVICES, INC. SERVICES, INC. CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC., Defendant(s). ---- ------¬----------------------- ------------------X The defendants, CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC., by their attorneys, AHMUTY, DEMERS & McMANUS, ESQS., as and for their reply to defendant, ROMEO DIMON MARINE SERVICES, INC's cross-claim, alleges upon information and belief: AS AND FOR AN ANSWER TO A CROSS-CLAIM FIRST: Denies each and every allegation contained in paragraphs designated "20" of the cross claim. WHEREFORE, defendants, CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC., demands judgment dismissing the cross claim of the defendant, ROMEO DIMON MARINE SERVICES, INC., together with the costs and disbursements of this action. Dated: Albertson, New York October 2, 2015 Yours, etc. AHMUTY, RS McMANUS, ESQS. By: Neil J. Palmieri, Esq. FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 Attorneys for CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 200 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 Our File No.: 1BM 068515 NJP To: The Bongiorno Law Firm, PLLC Attorneys for Plaintiff 250 Mineola Boulevard Mineola, New York 11501 (516) 741-4170 File No. 6230.PP Lewis, Johs, Avallone & Aviles, LLP Attorneys for Steven D. Romeo One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No. 0114-1460-001C Cascone & Kluepfel, LLP Attorneys for Romeo Dimon Marine Services, Inc. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 (516) 747-1990 File No. 03787DVM FILED: SUFFOLK COUNTY CLERK 11/14/2019 10:16 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 STATE OF NEW YORK ) ) ss: COUNTY OF NASSAU ) TRACEY DAVIDA-HERBST, being duly sworn deposes and says that she is not a party to this action; that she is over the age of eighteen years; resides in Babylon Village, New York; 5th That on the day of October, 2015, she served the within Reply to Cross-Claim of Defendant, Romeo Dimon Marine Services, Inc. Upon: The Bongiorno Law Firm, PLLC 250 Mineola Boulevard Mineola, New York 11501 Lewis, Johs, Avallone & Aviles, LLP One CA Plaza, Suite 225 Islandia, New York 11749 Cascone & Kluepfel, LLP 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 the attorneys for the respective parties, hereto at the address designated by them for that purpose, by depositing a true copy of same enclosed in a postpaid properly addressed wrapper, in an official depository under the exclusive care and custody of the United States Post Office Department within the State of New York. TRA Y . DAVÏDA T Sworn to before me on this 5th day of October, 2015 Notary Publi CHRISTINA JEFFORDS Notary Public,Stateof New York No. 01RO6137142 Qualifiedin Nassau Count Commission ExpiresNov. 14,