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  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY 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 v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, 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, DISTRIBUTORS, AND/OR SELLERS OF THE 2007 LINCOLN TOWN CAR STRETCH LIMOUSINE INVOLVED IN THE COLLISION, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY 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 v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, 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, DISTRIBUTORS, AND/OR SELLERS OF THE 2007 LINCOLN TOWN CAR STRETCH LIMOUSINE INVOLVED IN THE COLLISION, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY 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 v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, 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, DISTRIBUTORS, AND/OR SELLERS OF THE 2007 LINCOLN TOWN CAR STRETCH LIMOUSINE INVOLVED IN THE COLLISION, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY 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 v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, 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, DISTRIBUTORS, AND/OR SELLERS OF THE 2007 LINCOLN TOWN CAR STRETCH LIMOUSINE INVOLVED IN THE COLLISION, Tort document preview 
						
                                
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                                (FILED: SUFFOLK COUNTY CLERK 0870472021 09:58 AM INDEX NO. 611214/2015

NYSCEF DOC. NO. 804 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK

ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS Index No.: 611214/15
ADMINISTRATRIX OF THE ESTATE OF BRITTNEY

M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY

GRABINA, AS ADMINSTRATRIX OF THE ESTATE

OF AMY GRABINA, AND MINDY GRABINA,

NDIVIDUALLY ; STEVEN BARUCH, AS ADMINISTRATOR

OF THE ESTATE OF LAUREN BARUCH, DECEASED, AFFIRMATION OF
AND STEVEN BARUCH, INDIVIDUALLY; JOELLE GOOD FAITH
DIMONTE; AND MELISSA A. CRAI,

Plaintiffs,
-against-

ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO,
ROMEO DIMON MARINE SERVICE, INC., STEVEN
ROMEO, TOWN OF SOUTHOLD and COUNTY OF
SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a
ROYALE LIMOUSINE and “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,

Defendants.

STEVEN A. STEIGERWALD, an attomey at law of the State of New Y ork, duly
admitted to practice law in the Courts of the State of New Y ork, hereby affirms the following to
be true under the penalties of perjury pursuant to CPLR 2106:

1. I am associated with the Law Office of Eric D. Feldman, attomeys for defendant
CABOT COACH BUILDERS, INC. (CABOT), and make this A ffirmation of Good Faith in
support of defendant's motion.

2. I had been in contact on several occasions with Mr. Lange’s secretary to set up a
deposition date. One was set up and then we were advised that he would not be able to stay past

2 p.m. so we agreed to set another date. While in the process of setting that date, I was contacted

1 of 2(FILED: SUFFOLK COUNTY CLERK 0870472021 09:58 AM INDEX NO. 611214/2015

NYSCEF DOC. NO. 804 RECEIVED NYSCEF: 08/04/2021

by a person identifying herself as Shannon M. Kos who told me that Mr. Lange had changed his
mind and would not appear for his deposition pursuant to the subpoena. She told me that I did
not have the authority to subpoena Mr. Lange. It turns out that she is an attorney admitted in
Michigan (not New Y ork according to the New Y ork State Unified Court System listing of
admitted attorneys) with an office in Michigan. Every time I attempted to correct her mis-
statements and assumptions, she spoke over me. When I attempted to tell her that Mr. Lange then
needed to make a motion to quash, she would not even discuss it. A fter being lectured for some
time, I advised her that we would be making the instant motion for contempt and terminated the

call.

3. As aresult of the foregoing, the instant motion is necessary.

Dated: Melville, New Y ork
August 3, 2021

STEVEN A. STEIGERWALD

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