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 11/16/2020 01:08 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 720 RECEIVED NYSCEF: 11/16/2020
EXHIBIT H
FILED: SUFFOLK COUNTY CLERK 10/06/2020
11/16/2020 03:16
01:08 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 698
720 RECEIVED NYSCEF: 10/06/2020
11/16/2020
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.: 611214/2015
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
11th
undersigned, will take, on behalf of the Plaintiff, on the day of December, 2020 at 10:00 a.m.
in the forenoon of that date, virtually, the oral examination of CABOT SMITH 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 10/06/2020
11/16/2020 03:16
01:08 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 698
720 RECEIVED NYSCEF: 10/06/2020
11/16/2020
PLEASE TAKE FURTHER NOTICE, that at the time of the taking of the testimony,
the aforesaid parties 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
October 6, 2020
Yours, etc,
Daniel M. Seiden
Daniel M. Seiden, Esq.
BLOCK O’TOOLE & MURPHY, LLP
Attorneys 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 10/06/2020
11/16/2020 03:16
01:08 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 698
720 RECEIVED NYSCEF: 10/06/2020
11/16/2020
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 10/06/2020
11/16/2020 03:16
01:08 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 698
720 RECEIVED NYSCEF: 10/06/2020
11/16/2020
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 June 30,
2020, 2020, 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
______________________________
TIFFANY COYLE
Sworn to before me June 30, 2020
_____________________________________
Notary Public
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Preview
FILED: SUFFOLK COUNTY CLERK 11/16/2020 01:08 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 720 RECEIVED NYSCEF: 11/16/2020 EXHIBIT H FILED: SUFFOLK COUNTY CLERK 10/06/2020 11/16/2020 03:16 01:08 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 698 720 RECEIVED NYSCEF: 10/06/2020 11/16/2020 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.: 611214/2015 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 11th undersigned, will take, on behalf of the Plaintiff, on the day of December, 2020 at 10:00 a.m. in the forenoon of that date, virtually, the oral examination of CABOT SMITH 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 10/06/2020 11/16/2020 03:16 01:08 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 698 720 RECEIVED NYSCEF: 10/06/2020 11/16/2020 PLEASE TAKE FURTHER NOTICE, that at the time of the taking of the testimony, the aforesaid parties 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 October 6, 2020 Yours, etc, Daniel M. Seiden Daniel M. Seiden, Esq. BLOCK O’TOOLE & MURPHY, LLP Attorneys 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 10/06/2020 11/16/2020 03:16 01:08 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 698 720 RECEIVED NYSCEF: 10/06/2020 11/16/2020 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 10/06/2020 11/16/2020 03:16 01:08 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 698 720 RECEIVED NYSCEF: 10/06/2020 11/16/2020 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 June 30, 2020, 2020, 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 ______________________________ TIFFANY COYLE Sworn to before me June 30, 2020 _____________________________________ Notary Public 4 of 4