Preview
FILED: SUFFOLK COUNTY CLERK 02/10/2022 03:29 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 849 RECEIVED NYSCEF: 02/10/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
__--__ __------------------------------------------------X
ALICA M. ARUNDEL; SUZANNE SCHULMAN, AS
ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M.
SHULMAN DECEASED; OLGA LIPTETS; MINDY
GRABINA, AS ADMINISTRATRIX OF THE ESTATE Index Nos: 611214/15
AMY GRABINA, AND MINDY GRABINA INDIVIDUALLY; 609082/15
STEVEN BARUCH, AS ADMINISTRATOR OF THE ESTATE 600055/16
OF LAUREN BARUCH, DECEASED AND STEVEN BARUCH, 603536/16
INDIVIDUALLY; JOELLE DIMONTE; MELISSA A. CRAI, AND 003364/16
ARTHUR A. BELLI JR, AS PARENT AND NATURAL GUARDIAN 001831/16
OF STEPHANIE BELLI, DECEASED, AND AS THE 607598/16
ADMINISTRATOR OF THE ESTATE OF STEPHANIE BELLI, 614685/16
Plaintiffs,
- against - PLAINTIFF CRAI
RESPONSE TO DEFENDANT
COUNTY DEMAND
STEVEN D. ROMEO, ROMEO DIMON MARINE SERVICES, INC., FOR AUTHORIZATIONS
CARLOS F. PINO, ULTIMATE CLASS LIMOUSINE, INC.,
COUNTY OF SUFFOLK, TOWN OF SOUTHOLD and
CABOT COACH BUILDERS, INC., d/b/a ROYALE LIMOUSINE
1-5"
and "XYZ COMPANIES name being fictitious but intended
to be the remanufacturers, distributors and/sellers of the 2007 Lincoln
Town Car stretch limousine involved in the collision,
Defendants.
--------------------------------------------- -----------------X
Plaintiff, MELISSA A. CRAI, by her attorney, JOSEPH J. TOCK, as and for her Response to the
Defendant County Demands for Discovery dated August 9, 2021, sets forth:
1. The fully executed transcripts for the 50-h conducted on January 12, 2016 was
forwarded to your office on July 25, 2017. The only exhibit presented during this
hearing was a copy of the Notice of Claim on behalf of Plaintiff, Melissa Crai
A"
marked as "Exhibit which your office presented.
2. Our office is not in possession of any copies of any transcripts along with
corresponding exhibits from the Department of Motor Vehicles.
3. Our office in not in possession of any transcripts of any individuals who testified
in the Criminal (Investigative) Grand Jury.
LAW OFFICES OF JOSEPH J. TOCK • 963 ROUTE 6, MAHOPAC, NEWYORK 10541
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FILED: SUFFOLK COUNTY CLERK 02/10/2022 03:29 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 849 RECEIVED NYSCEF: 02/10/2022
4. Our office is aware of the following persons transcripts who testified in the Civil
(Special) Grand Jury proceeding as follows: Michael Eckhardt, Ernest Smith,
Chief Martin Flatley, Jennifer Casey, Matthew Cereola, Vincent Orlando,
William Duffy, Charles Gandolfo, Daniel Dresch, Tony Savarese, Robert Zxavier,
Joseph Zohaski, Robert Fisher, Jeffrey DeMarco, Jonathan Nicastro, PO Robert
Copozzi, Trooper Fabio Daino, Salvatore Diliberto, Jeffrey Lange, Det. Michael
Friehl, Richard Cupka, Ram Krishnaswami, Phillip Stock, Matthew Silver and
Jeff Lange.
5. Our office is not in possession or receipt of any New York State Liquor Authority
documents pertaining to Vineyard 48 and/or its respective corporate entities.
6. At this time we object to the request of copies of any and allmedia reporting
concerning the July 18, 2015 motor vehicle accident. Any and all news articles
are public information, which you can easily obtain.
7.-8. Duly compliant HIPAA authorizations to obtain medical records from all medical
facilities and/or providers were previously provided under our cover letters dated
January 19, 2017 and June 1, 2021.
9. Our office is not in possession of any documents pertaining to the criminal
proceedings against Carlos Pino relating to the motor vehicle accident of July 18,
2015.
10. Our office is not in possession of any documents pertaining to the criminal
proceedings against Steven D. Romeo relating to the motor vehicle accident of
July 18, 2015.
11. No-Fault or Supplementary Un/Underinsured Motorist Insurance have not
scheduled or conducted any Independent Medical Examinations of Plaintiff
Melissa A. Crai.
12. Our office is not in receipt of any written statements, emails, text messages or any
postings on any and all social media platforms from potential witnesses to the July
18, 2015 motor vehicle accident.
13. Our office is not in possession of any additional photographs taken of the crash
scene with respect to the July 18, 2015 motor vehicle accident.
14. A compliant HIPAA authorization to obtain Plaintiff's Melissa A. Crai's no-
duly
fault filefrom One Beacon Insurance was previously provided under our cover
letter dated January 19, 2017.
LAw OFFICES OF JOSEPH J. TOCK • 963 ROUTE 6, MAHOPAC, NEw YORK 10541
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FILED: SUFFOLK COUNTY CLERK 02/10/2022 03:29 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 849 RECEIVED NYSCEF: 02/10/2022
The plaintiff herein reserves the right to amend the responses contained herein up to and
including the time of the trialas and when any new and or further information becomes known.
DATED: Mahopac, New York Yours, etc.,
February 10, 2022 JOSEPH J. TOCK, ESQ.
Attorney for: MELISSA A. CRAI
963 Route 6
Mahopac, New York 10541
(845) 628-8080
To: All Counsel via NYCEF e-filing only
LAw OFFICES OF JOSEPH J. TOCK • 963 ROUTE 6, MAHOPAC, NEW YORK 10541
3 of 4
FILED: SUFFOLK COUNTY CLERK 02/10/2022 03:29 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 849 RECEIVED NYSCEF: 02/10/2022
Index No. 611214/15 Year
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
ALICIA M. ARUNDEL; SUZANNE SCHULMAN, as Administratrix of the Estate of BRITTNEY M. SCHULMAN,
deceased; OLGA LIPETS; MINDY GRABINA, as Administratrix of the Estate of AMY GRABINA, and MINDY
GRABINA, Individually; STEVEN BARUCH, as Administrator of the Estate of LAUREN BARUCH, deceased and
STEVEN BARUCH, Individually; JOELLE DIMONTE; and MELISSA A. CRAI, and ARTHUR A. BELLI, JR. as
parent and Natural Guardian of STEPHANIE BELLI, deceased, and as the Administrator of THE ESTATE OF
STEPHANIE BELLI,
Plaintiff(s)
-against-
ULTIMATE CLASS LIMOUSINE INC.,CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC.,STEVEN ROMEO, TOWN OF SOUTHOLD,
COUNTY OF SUFFOLK, CABOT COACH 1-5"
BUILDERS, INC., d/b/aROYALE LIMOUSINE and "XYZ COMPANIES name beingfictitious
but
intendedto be the r-anufacturers, and/or
distributors, sellers
of the 2007Lincoln Town Car stretch
limousine involvedin the collision,
Defendants(s).
PLAINTIFF CRAI RESPONSE TO DEFENDANT COUNTY OF SUFFOLK DEMAND FOR DISCOVERY
Law Officesof
Joseph J. Tock
Attorney for Plaintiff(Crai)
963 Route 6
Mahopac, NY 10541
(845)628 - 8080
Pursuant to 22 NYCRR 130.1.1,the undersigned,an attorney admittedto practice
in thecourts of New York certifies
State, that,upon
liifarnistion
and beliefand reasonable inquiry,the c -;ñ=d inthe annexed docummt are not fi·ivcicies.
Dateri•
Print Signer'sName:
Service of a copyof thewithin is herebyadmitted
Dated:
Attorney (s)for
PLEASE TAKE NOTICE
thatthe within is a (certified)
truecony of a
entered inthe officeof theclerkof thewithinnamed Court on
thatan Order of which the withinis a true
copy will be presentedforsettlement tothe Non.
one of the judgesof thewithinnamed Court,
at
on 20 , at M.
Dated:
Law Officesof
Joseph J. Tock
Attorney for Plaintiff
963 Route 6
Mahapac, NY 10541
(845)628 - 8080
4 of 4
Preview
FILED: SUFFOLK COUNTY CLERK 02/10/2022 03:29 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 849 RECEIVED NYSCEF: 02/10/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK __--__ __------------------------------------------------X ALICA M. ARUNDEL; SUZANNE SCHULMAN, AS ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M. SHULMAN DECEASED; OLGA LIPTETS; MINDY GRABINA, AS ADMINISTRATRIX OF THE ESTATE Index Nos: 611214/15 AMY GRABINA, AND MINDY GRABINA INDIVIDUALLY; 609082/15 STEVEN BARUCH, AS ADMINISTRATOR OF THE ESTATE 600055/16 OF LAUREN BARUCH, DECEASED AND STEVEN BARUCH, 603536/16 INDIVIDUALLY; JOELLE DIMONTE; MELISSA A. CRAI, AND 003364/16 ARTHUR A. BELLI JR, AS PARENT AND NATURAL GUARDIAN 001831/16 OF STEPHANIE BELLI, DECEASED, AND AS THE 607598/16 ADMINISTRATOR OF THE ESTATE OF STEPHANIE BELLI, 614685/16 Plaintiffs, - against - PLAINTIFF CRAI RESPONSE TO DEFENDANT COUNTY DEMAND STEVEN D. ROMEO, ROMEO DIMON MARINE SERVICES, INC., FOR AUTHORIZATIONS CARLOS F. PINO, ULTIMATE CLASS LIMOUSINE, INC., COUNTY OF SUFFOLK, TOWN OF SOUTHOLD and CABOT COACH BUILDERS, INC., d/b/a ROYALE LIMOUSINE 1-5" and "XYZ COMPANIES name being fictitious but intended to be the remanufacturers, distributors and/sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. --------------------------------------------- -----------------X Plaintiff, MELISSA A. CRAI, by her attorney, JOSEPH J. TOCK, as and for her Response to the Defendant County Demands for Discovery dated August 9, 2021, sets forth: 1. The fully executed transcripts for the 50-h conducted on January 12, 2016 was forwarded to your office on July 25, 2017. The only exhibit presented during this hearing was a copy of the Notice of Claim on behalf of Plaintiff, Melissa Crai A" marked as "Exhibit which your office presented. 2. Our office is not in possession of any copies of any transcripts along with corresponding exhibits from the Department of Motor Vehicles. 3. Our office in not in possession of any transcripts of any individuals who testified in the Criminal (Investigative) Grand Jury. LAW OFFICES OF JOSEPH J. TOCK • 963 ROUTE 6, MAHOPAC, NEWYORK 10541 1 of 4 FILED: SUFFOLK COUNTY CLERK 02/10/2022 03:29 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 849 RECEIVED NYSCEF: 02/10/2022 4. Our office is aware of the following persons transcripts who testified in the Civil (Special) Grand Jury proceeding as follows: Michael Eckhardt, Ernest Smith, Chief Martin Flatley, Jennifer Casey, Matthew Cereola, Vincent Orlando, William Duffy, Charles Gandolfo, Daniel Dresch, Tony Savarese, Robert Zxavier, Joseph Zohaski, Robert Fisher, Jeffrey DeMarco, Jonathan Nicastro, PO Robert Copozzi, Trooper Fabio Daino, Salvatore Diliberto, Jeffrey Lange, Det. Michael Friehl, Richard Cupka, Ram Krishnaswami, Phillip Stock, Matthew Silver and Jeff Lange. 5. Our office is not in possession or receipt of any New York State Liquor Authority documents pertaining to Vineyard 48 and/or its respective corporate entities. 6. At this time we object to the request of copies of any and allmedia reporting concerning the July 18, 2015 motor vehicle accident. Any and all news articles are public information, which you can easily obtain. 7.-8. Duly compliant HIPAA authorizations to obtain medical records from all medical facilities and/or providers were previously provided under our cover letters dated January 19, 2017 and June 1, 2021. 9. Our office is not in possession of any documents pertaining to the criminal proceedings against Carlos Pino relating to the motor vehicle accident of July 18, 2015. 10. Our office is not in possession of any documents pertaining to the criminal proceedings against Steven D. Romeo relating to the motor vehicle accident of July 18, 2015. 11. No-Fault or Supplementary Un/Underinsured Motorist Insurance have not scheduled or conducted any Independent Medical Examinations of Plaintiff Melissa A. Crai. 12. Our office is not in receipt of any written statements, emails, text messages or any postings on any and all social media platforms from potential witnesses to the July 18, 2015 motor vehicle accident. 13. Our office is not in possession of any additional photographs taken of the crash scene with respect to the July 18, 2015 motor vehicle accident. 14. A compliant HIPAA authorization to obtain Plaintiff's Melissa A. Crai's no- duly fault filefrom One Beacon Insurance was previously provided under our cover letter dated January 19, 2017. LAw OFFICES OF JOSEPH J. TOCK • 963 ROUTE 6, MAHOPAC, NEw YORK 10541 2 of 4 FILED: SUFFOLK COUNTY CLERK 02/10/2022 03:29 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 849 RECEIVED NYSCEF: 02/10/2022 The plaintiff herein reserves the right to amend the responses contained herein up to and including the time of the trialas and when any new and or further information becomes known. DATED: Mahopac, New York Yours, etc., February 10, 2022 JOSEPH J. TOCK, ESQ. Attorney for: MELISSA A. CRAI 963 Route 6 Mahopac, New York 10541 (845) 628-8080 To: All Counsel via NYCEF e-filing only LAw OFFICES OF JOSEPH J. TOCK • 963 ROUTE 6, MAHOPAC, NEW YORK 10541 3 of 4 FILED: SUFFOLK COUNTY CLERK 02/10/2022 03:29 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 849 RECEIVED NYSCEF: 02/10/2022 Index No. 611214/15 Year SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ALICIA M. ARUNDEL; SUZANNE SCHULMAN, as Administratrix of the Estate of BRITTNEY M. SCHULMAN, deceased; OLGA LIPETS; MINDY GRABINA, as Administratrix of the Estate of AMY GRABINA, and MINDY GRABINA, Individually; STEVEN BARUCH, as Administrator of the Estate of LAUREN BARUCH, deceased and STEVEN BARUCH, Individually; JOELLE DIMONTE; and MELISSA A. CRAI, and ARTHUR A. BELLI, JR. as parent and Natural Guardian of STEPHANIE BELLI, deceased, and as the Administrator of THE ESTATE OF STEPHANIE BELLI, Plaintiff(s) -against- ULTIMATE CLASS LIMOUSINE INC.,CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC.,STEVEN ROMEO, TOWN OF SOUTHOLD, COUNTY OF SUFFOLK, CABOT COACH 1-5" BUILDERS, INC., d/b/aROYALE LIMOUSINE and "XYZ COMPANIES name beingfictitious but intendedto be the r-anufacturers, and/or distributors, sellers of the 2007Lincoln Town Car stretch limousine involvedin the collision, Defendants(s). PLAINTIFF CRAI RESPONSE TO DEFENDANT COUNTY OF SUFFOLK DEMAND FOR DISCOVERY Law Officesof Joseph J. Tock Attorney for Plaintiff(Crai) 963 Route 6 Mahopac, NY 10541 (845)628 - 8080 Pursuant to 22 NYCRR 130.1.1,the undersigned,an attorney admittedto practice in thecourts of New York certifies State, that,upon liifarnistion and beliefand reasonable inquiry,the c -;ñ=d inthe annexed docummt are not fi·ivcicies. Dateri• Print Signer'sName: Service of a copyof thewithin is herebyadmitted Dated: Attorney (s)for PLEASE TAKE NOTICE thatthe within is a (certified) truecony of a entered inthe officeof theclerkof thewithinnamed Court on thatan Order of which the withinis a true copy will be presentedforsettlement tothe Non. one of the judgesof thewithinnamed Court, at on 20 , at M. Dated: Law Officesof Joseph J. Tock Attorney for Plaintiff 963 Route 6 Mahapac, NY 10541 (845)628 - 8080 4 of 4