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
STEVEN E. PEGALIS GARY M. NIELSEN
ANNAMARIE BONDI-STODDARD ROBERT V. FALLARINO
Admitted in New York& Admitted in New York,
New Jersey North Carolina & District
of Columbia
JAMES B. BAYDAR
ISABEL C. MIRA
SANFORD S. NAGROTSKY Admitted in New York&
Colombia, S.A.
February 11, 2021
Honorable John H. Rouse
Supreme Court Suffolk County
21 Center Drive South
Riverhead, NY 11901
Re: Alicia M. Arundel, et al. v. Ultimate Class Limousine,
et al.
Index No. 611214/2015
Honorable Sir:
This law firm represents Joelle DiMonte, one ofthe plaintiffs in the above-referenced matter.
This is the case involving the tragic limousine accident in Cutchogue in 2015.
In your December 10, 2020 order, this court vacated a Notice of Deposition to take the
deposition of Town of Southold Town Supervisor Scott Russell, and in lieu of the oral deposition,
permitted the plaintiffs to serve and file interrogatories directed to Mr. Russell. See NYSCEC
Docket no. 754.
On January 29, 2021, written interrogatories directed to Mr. Russell were e-filed. See
NYSCEC Docket no. 764. On February 1, 2021, counsel for the Town of Southold e-filed a letter
rejecting the interrogatories as untimely and over broad. See NYSCEC Docket no. 766.
On February 5, I e-mailed with counsel for the Town, David H. Arntsen of the Law Office
of Thomas M. Volz, and we agreed to discuss the interrogatories on Wednesday, February 10, in a
good faith effort to resolve the issue.
The order contained a provision that the interrogatories be filed within 20 days of service
with notice of entry, and the Town's rejection letter noted that filing was late. In our February 10
conversation, Mr. Arntsen, on behalf of the Town, agreed that his office will withdraw any
opposition as to the timeliness of the service of revised and streamlined interrogatories and, in
response to his concerns about the scope of the interrogatories I agreed to file a revised set of
interrogatories in an attempt to streamline the questions. We agreed that the Town's time to answer,
object or otherwise respond to the interrogatories shall be 30 days from the electronic filing of same
absent further agreement of the parties.
1 HOLLOW LANE • SUITE 107 • LAKE SUCCESS, NY 11042
684-2900 • (718)567-7171 • (212)517-9995 • TOLL FREE: (866)633-6257 • FAX: (516)684-2939
(516)
PEGALISLAWGROUP.COM
PEGALIS
LAW GROUP, L L C
As such, we respectfully advise the court that the plaintiff's revised interrogatories to
Supervisor Russell will be e-filed no later than February 19, 2021.
Yours truly,
PEGALIS LAW GROUP, LLC
Gary Nielsen, Esq.
GMN:hs
LAW OFFICES OF THOMAS M. VOLZ, PLLC
Attorneys for Defendant
Town of Southold
280 Smithtown Blvd
Nesconset, New York I1767
LEWIS JOHS AVALLONE AVILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
CASCONE & KLUEPFEL LLP
Attn: David G. Kluepfel, Esq.
Attorneys for Defendant
ROMEO DIMON MARINE SERVICES, INC.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
LAW OFFICES OF VINCENT D. McNAMARA
Attorneys for Defendant
COUNTY OF SUFFOLK
Tower Square- 1045 Oyster Suite 1
Bay Road,
East Norwich, New York 11732
2
PEGALIS
LAW GROUP, tic
BONGIORNO, MONTIGLO & PALMIERI, PLLC
Attorneys for Defendants
ULTIMATE CLASS LIMOUSINE and CARLOS PINO
200 Old Country Road, Suite 680
Mineola, New York 11501
(516) 620-4490
LAW OFFICE OF ANDREA G. SAWYERS
Attorneys for Defendant
CABOT COACH BUILDERS, INC. d/b/a
ROYALE LIMOUSINE
3 Huntington Quadrangle, Suite 102S
Melville, New York 11747
JOSEPH J. TOCK, ESQ.
Attorney for Plaintiff
MELISSA A. CRAI
One Mahopac Plaza
Mahopac, New York 10541
JOHN L. JULIANO, P.C.
Attorney for Plaintiff
ESTATE OF SHULMAN
39 Doyle Court
East Northport, New York 11731
THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
ALICIA M. ARUNDEL
1415 Kellum Place, Suite 205
Garden City, New York 11530
SULLIVAN, PAPAIN, BLOCK,
McGRATH & CANNAVO, P.C.
Attorneys for Plaintiff
ESTATE OF BARUCH
1140 Franklin Avenue, Suite 200
Garden City, New York 11530
3
PEGALIS
LAW GROUP, LLC
FRANK J. LAINE, P.C.
Attorneys for Plaintiff
ESTATE OF GRABINA
449 South Oyster Bay Road
Plainview, New York 11803
PARIS & CHAIKIN, PLLC
Attorney for Plaintiff
OLGA LIPETS
14 Penn Plaza, Suite 2202
New York, New York 10122
BLOCK O'TOOLE & MURPHY, ESQS.
Attorneys for Plaintiff
ESTATE OF BELLI
One Penn Plaza, Suite 5315
New York, New York 10019
4
Preview
STEVEN E. PEGALIS GARY M. NIELSEN ANNAMARIE BONDI-STODDARD ROBERT V. FALLARINO Admitted in New York& Admitted in New York, New Jersey North Carolina & District of Columbia JAMES B. BAYDAR ISABEL C. MIRA SANFORD S. NAGROTSKY Admitted in New York& Colombia, S.A. February 11, 2021 Honorable John H. Rouse Supreme Court Suffolk County 21 Center Drive South Riverhead, NY 11901 Re: Alicia M. Arundel, et al. v. Ultimate Class Limousine, et al. Index No. 611214/2015 Honorable Sir: This law firm represents Joelle DiMonte, one ofthe plaintiffs in the above-referenced matter. This is the case involving the tragic limousine accident in Cutchogue in 2015. In your December 10, 2020 order, this court vacated a Notice of Deposition to take the deposition of Town of Southold Town Supervisor Scott Russell, and in lieu of the oral deposition, permitted the plaintiffs to serve and file interrogatories directed to Mr. Russell. See NYSCEC Docket no. 754. On January 29, 2021, written interrogatories directed to Mr. Russell were e-filed. See NYSCEC Docket no. 764. On February 1, 2021, counsel for the Town of Southold e-filed a letter rejecting the interrogatories as untimely and over broad. See NYSCEC Docket no. 766. On February 5, I e-mailed with counsel for the Town, David H. Arntsen of the Law Office of Thomas M. Volz, and we agreed to discuss the interrogatories on Wednesday, February 10, in a good faith effort to resolve the issue. The order contained a provision that the interrogatories be filed within 20 days of service with notice of entry, and the Town's rejection letter noted that filing was late. In our February 10 conversation, Mr. Arntsen, on behalf of the Town, agreed that his office will withdraw any opposition as to the timeliness of the service of revised and streamlined interrogatories and, in response to his concerns about the scope of the interrogatories I agreed to file a revised set of interrogatories in an attempt to streamline the questions. We agreed that the Town's time to answer, object or otherwise respond to the interrogatories shall be 30 days from the electronic filing of same absent further agreement of the parties. 1 HOLLOW LANE • SUITE 107 • LAKE SUCCESS, NY 11042 684-2900 • (718)567-7171 • (212)517-9995 • TOLL FREE: (866)633-6257 • FAX: (516)684-2939 (516) PEGALISLAWGROUP.COM PEGALIS LAW GROUP, L L C As such, we respectfully advise the court that the plaintiff's revised interrogatories to Supervisor Russell will be e-filed no later than February 19, 2021. Yours truly, PEGALIS LAW GROUP, LLC Gary Nielsen, Esq. GMN:hs LAW OFFICES OF THOMAS M. VOLZ, PLLC Attorneys for Defendant Town of Southold 280 Smithtown Blvd Nesconset, New York I1767 LEWIS JOHS AVALLONE AVILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 CASCONE & KLUEPFEL LLP Attn: David G. Kluepfel, Esq. Attorneys for Defendant ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 LAW OFFICES OF VINCENT D. McNAMARA Attorneys for Defendant COUNTY OF SUFFOLK Tower Square- 1045 Oyster Suite 1 Bay Road, East Norwich, New York 11732 2 PEGALIS LAW GROUP, tic BONGIORNO, MONTIGLO & PALMIERI, PLLC Attorneys for Defendants ULTIMATE CLASS LIMOUSINE and CARLOS PINO 200 Old Country Road, Suite 680 Mineola, New York 11501 (516) 620-4490 LAW OFFICE OF ANDREA G. SAWYERS Attorneys for Defendant CABOT COACH BUILDERS, INC. d/b/a ROYALE LIMOUSINE 3 Huntington Quadrangle, Suite 102S Melville, New York 11747 JOSEPH J. TOCK, ESQ. Attorney for Plaintiff MELISSA A. CRAI One Mahopac Plaza Mahopac, New York 10541 JOHN L. JULIANO, P.C. Attorney for Plaintiff ESTATE OF SHULMAN 39 Doyle Court East Northport, New York 11731 THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff ALICIA M. ARUNDEL 1415 Kellum Place, Suite 205 Garden City, New York 11530 SULLIVAN, PAPAIN, BLOCK, McGRATH & CANNAVO, P.C. Attorneys for Plaintiff ESTATE OF BARUCH 1140 Franklin Avenue, Suite 200 Garden City, New York 11530 3 PEGALIS LAW GROUP, LLC FRANK J. LAINE, P.C. Attorneys for Plaintiff ESTATE OF GRABINA 449 South Oyster Bay Road Plainview, New York 11803 PARIS & CHAIKIN, PLLC Attorney for Plaintiff OLGA LIPETS 14 Penn Plaza, Suite 2202 New York, New York 10122 BLOCK O'TOOLE & MURPHY, ESQS. Attorneys for Plaintiff ESTATE OF BELLI One Penn Plaza, Suite 5315 New York, New York 10019 4