Preview
FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
-----------------------------------------------------------------------X
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,
INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR
OF THE ESTATE OF LAUREN BARUCH, DECEASED,
AND STEVEN BARUCH, INDIVIDUALLY; JOELLE
DIMONTE; AND MELISSA A. CRAI,
Plaintiffs, DEMAND FOR EXECUTION
OF TRANSCRIPT
-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.
-----------------------------------------------------------------------X
PLEASE TAKE NOTICE that, pursuant to C.P.L.R. Rule 3116 governing the exchange,
execution and/or signing of deposition transcripts, enclosed herewith is the following:
1. A copy of the transcript of the examination before trial upon oral questions
conducted of non-party witness, Jeffrey Lange.
PLEASE TAKE FURTHER NOTICE, that demand is hereby made that the transcript be
read by or to the deponent, and that the deponent sign said transcript where indicated, before an
officer authorized to administer an oath, and return same to the undersigned.
1 of 229
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PLEASE TAKE FURTHER NOTICE, that pursuant to C.P.L.R. Rule 3116 (a) and the
controlling cases of Columbia v. Lee, 239 A.D. 849, 264 N.Y.S. 423 (2d Dept. 1933) and Skeaney
v. Silver Beach Realty Corp., 10 A.D.2d 537, 201 N.Y.S.2d 163 (1st Dept. 1960), which hold that
witnesses may not in any way delete, erase or obliterate the answers as transcribed. Before the
witness signs and subscribes his or her testimony, he or she may add to the end of the deposition
on a sheet provided for said purpose, any changes in the form or substance of said transcript along
with a statement of the reasons for making such changes. After adding such a statement, he or she
may sign and subscribe his or her testimony in the transcript and on the correction page.
PLEASE TAKE FURTHER NOTICE, that pursuant to C.P.L.R. Rule 3116(a), if we do
not receive the duly executed original transcripts with any corrections or changes within sixty (60)
days, we shall deem the copies to be an original for all purposes provide by the C.P.L.R, and may
use same as though signed. No changes to the transcript may be made by the witness more than
sixty (60) days after submission to the witness for review and examination.
Dated: January 4, 2022
Melville, New York
Yours, etc.
LAW OFFICE OF ERIC D. FELDMAN
By:________________________________
STEVEN A. STEIGERWALD
Attorneys for Defendant
CABOT COACH BUILDERS, INC
Please note our new mailing address:
PO Box 2903
Hartford, CT 06104-2903
(631) 501-3100
Matter No.: 2017024539SAS
TO:
SHEPS LAW GROUP, P.C.
Robert Sheps, Esq.
Attorneys for Non-Party Witness
JEFFREY LANGE
25 High Street
Huntington, NYT 11743
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Law Office of Vincent D. McNamara
Attorneys for Defendant
The County of Suffolk
Tower Square-1045 Oyster Bay Road
East Norwich, NY 11732
(516)922-9100
Lewis Johs Avallone Aviles, LLP
Attorneys for Defendant
Steven D. Romeo
1377 Motor Parkway
Suite 400
Islandia, NY 11749
(631) 755-0101
Sullivan Papain Block McGrath & Cannavo, P.C.
Attorneys for Plaintiff
Estate of Lauren Baruch
1140 Franklin Avenue
Suite 200
Garden City, NY 11530
(516) 742-0707
Pegalis & Erickson, LLC
Attorneys for Plaintiff
Joelle Dimonte
One Hollow Lane
Suite 10
Lake Success, NY 11042
(516) 684-2939
Joseph J. Tock, Esq.
Attorney for Plaintiff
Melissa A. Crai
963 Route 6
Mahopac, NY 10541
(845) 628-8080
John J. Juliano, Esq.
Attorneys for Plaintiff
Estate of Brittany Schulman
39 Doyle Court
E. Northport, NY 11731
(631) 499-9300
The Bongiorno Law Firm, PLLC
Attorneys for Plaintiff
Alicia M. Arundel
1415 Kellum Place
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Suite 205
Garden City, NY 11530
(516) 741-4170
Paris & Chaikin, PLLC
Attorneys for Plaintiff
Olga Lipets
14 Penn Plaza
Suite 2202
New York, NY 10122
Frank J. Laine, P.C.
Attorneys for Plaintiff
Estate of Amy Grabina
449 South Oyster Bay Road
Plainview, NY 11803
(516) 937-1010
Block O’Toole & Murphy LLP
Attorneys for Plaintiff
Estate of Stephanie Belli
One Penn Plaza, Suite 5315
New York, NY 10119
(212)736-5300
Cascone & Klupfel, LLP
Attorneys for Defendant
Romeo Dimon Marine Services, Inc.
497 Main Street
Farmingdale, NY 11735
(516) 747-1990
Volz & Vigliotta, PLLC
Attorneys for Defendant
The Town of Southold
280 Smithtown Boulevard
Nesconset, NY 11767
(631)366-2700
Bongiorno, Montiglio & Palmieri, PLLC
Attorneys for Defendants
Carlos F. Pino and Ultimate Class Limousine, Inc.
200 Old Country Road
Suite 680
Mineola, New York 11501
(516)620-0687
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Page 1
October 19, 2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
----------------------------------------x
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, MELISSA A.
CRAI, ARTHUR A. BELLI JR, AS PARENT AND
NATURAL GUARDIAN OF STEPHANIE BELLI,
DECEASED, AND AS THE ADMINISTRATOR OF
THE ESTATE OF STEPHANIE BELLI,
Plaintiffs,
-against- Index No:
611214/15
69082/15
600055/16
603536/16
003364/16
607598/16
001831/16
STEVEN D. ROMEO, ROMEO DIMON MARINE
SERVICES, INC., CARLOS F. PINO, ULTIMATE
CLASS LIMOUSINE, INC., COUNTY OF SUFFOLK,
TOWN OF SOUTHOLD and 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.
----------------------------------------x
(Caption continued on the next page.)
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 2
October 19, 2021
1
2 VIDEOCONFERENCE EXAMINATION BEFORE
3 TRIAL of the Non-Party Witness, JEFFREY LANGE,
4 taken by the Defendants, pursuant to So-Ordered
5 Stipulation, on October 19, 2021, at 10:20
6 a.m., before a Notary Public of the State of
7 New York.
8 ***********************************************
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 3
October 19, 2021
1 A P P E A R A N C E S:
2
3 THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
4 ALICIA M. ARUNDEL
1415 Kellum Place, Suite 205
5 Garden City, New York 11530
6 BY: PETER BONGIORNO, ESQ.
7
8 LAW OFFICE OF JOHN L. JULIANO, P.C.
Attorney for Plaintiff
9 ESTATE OF BRITTNEY SCHULMAN
39 Doyle Court
10 East Northport, New York 11731
11
12 CHAIKIN, PLLC
Attorneys for Plaintiff
13 OLGA LIPETS
14 Penn Plaza, Suite 2202
14 New York, New York 10122
15 BY: IAN CHAIKIN, ESQ.
16
17 FRANK J. LAINE, P.C.
Attorneys for Plaintiff
18 ESTATE OF AMY GRABINA
449 South Oyster Bay Road
19 Plainview, New York 11803
20 BY: JOANNE PORCELLI, ESQ.
21
SULLIVAN PAPAIN BLOCK McGRATH COFFINAS &
22 CANNAVO, P.C.
Attorneys for Plaintiff
23 ESTATE OF LAUREN BARUCH
1140 Franklin Avenue, Suite 200
24 Garden City, New York 11530
25 BY: BETH JABLON, ESQ.
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 4
October 19, 2021
1 A P P E A R A N C E S: (CONTINUED)
2
3 PEGALIS LAW GROUP, LLC
4 Attorneys for Plaintiff
JOELLE DIMONTE
5 One Hollow Lane, Suite 107
Lake Success, New York 11042
6 BY: GARY NIELSON, ESQ.
7
8 LAW OFFICES OF JOSEPH J. TOCK
Attorney for Plaintiff
9 MELISSA A. CRAI
963 Route 6
10 Mahopac, New York 10541
11
BLOCK O'TOOLE & MURPHY, LLP
12 Attorneys for Plaintiff
ALICIA M. ARUNDEL
13 One Pennsylvania Plaza, Suite 5315
New York, New York 10119
14 BY: DANIEL M. SEIDEN, ESQ.
15
16
LEWIS JOHS AVALLON & AVILES, LLP
17 Attorneys for Defendant
STEVEN D. ROMEO
18 1377 Motor Parkway, Suite 400
Islandia, New York 11749
19 BY: REBECCA K. DEVLIN, ESQ.
20 FILE #: 1141416
21
22 CASCONE & KLUEPFEL, LLP
Attorneys for Defendant
23 ROMEO DIMON MARINE SERVICES, INC.
1399 Franklin Avenue, Suite 302
24 Garden City, New York 11530
25 BY: DAVID TAVELLA, ESQ.
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 5
October 19, 2021
1 A P P E A R A N C E S: (CONTINUED)
2
3 BONGIORNO, MONTIGLIO, MITCHELL & PALMIERI, PLLC
Attorneys for Defendants
4 CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
5 200 Old Country Road, Suite 680
Mineola, New York 11501
6 BY: NEIL PALMIERI, ESQ.
7
8
LAW OFFICE OF VINCENT D. McNAMARA
9 Attorneys for Defendant
THE COUNTY OF SUFFOLK
10 1045 Oyster Bay Road
East Norwich, New York 11732
11 BY: DAVID TEIXEIRA, ESQ.
12 FILE #: 9074677
13
14 VOLZ & VIGLIOTA, PLLC
Attorneys for Defendant
15 TOWN OF SOUTHOLD
280 Smithtown Boulevard
16 Nesconset, New York 11767
17 BY: DAVID ARNTSEN, ESQ.
18 FILE #: HCC19.10
19
20 THE LAW OFFICE OF ERIC D. FELDMAN
Attorneys for Defendant
21 CABOT COACH BUILDERS, INC., d/b/a
ROYALE LIMOUSINE
22 2 Corporate Center Drive, Suite 300
Melville, New York 11747
23 BY: STEVEN STEIGERWALD, ESQ.
24
25
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 6
October 19, 2021
1 A P P E A R A N C E S: (CONTINUED)
2
3 SHEPS LAW GROUP, P.C.
Attorney for Non-Party Witness
4 JEFFREY LANGE
25 High Street
5 Huntington, New York 11743
6 BY: ROBERT SHEPS, ESQ.
7
8
ALSO PRESENT:
9
DARA ROSENBAUM, ESQ. - ROSENBAUM & TAYLOR, P.C.
10
MICHAEL FRITTOLA, ESQ. - LESTER SCHWAB KATZ &
11 DWYER, LLP
12 PAUL KASSIRER, ESQ. - LESTER SCHWAB KATZ &
DWYER, LLP
13
PAMELA HOLMES - DOCUMENT TECHNICIAN
14
15
16
17
18
19
20
21
22
23
24
25
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 7
October 19, 2021
1
2 J E F F R E Y L A N G E, the witness herein,
3 having been first duly sworn by a Notary Public
4 of the State of New York, was examined and
5 testified as follows:
6 EXAMINATION BY
7 MR. STEIGERWALD:
8 Q. State your name for the record, please.
9 A. Jeffrey Lange.
10 Q. State your business address for the
11 record, please.
12 A. 751 Long Island Avenue, Deer Park, New
13 York 11729.
14 Q. Good morning, Mr. Lange. My name is
15 Steven Steigerwald. How are you?
16 A. I am good.
17 Q. I assume you have been to depositions
18 before.
19 A. I have.
20 Q. And you know that if you need to take a
21 break at any time, you can do so simply by
22 letting us know. The only thing I would ask
23 you to do is finish answering any open question
24 before you take a break. All right?
25 A. Yes.
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 8
October 19, 2021
1 J. LANGE
2 Q. I will do my best to wait for you to
3 complete your answer if you promise to do your
4 best to allow me to complete my questions,
5 because Janice has the hardest job here today
6 to take the entire record.
7 A. That's fine.
8 Q. You gave us your business address. What
9 business is located there?
10 A. I am sorry. Question?
11 Q. What business is located at that
12 address?
13 A. Lange Technical Services, L-A-N-G-E.
14 Q. What type of business is Lange Technical
15 Services?
16 A. It's a forensic automotive engineering
17 company.
18 Q. Are you the proprietor of Lange
19 Technical Services?
20 A. Yes.
21 Q. For how long have you been the
22 proprietor of Lange Technical Services?
23 A. I have been president for approximately
24 12 years, but an owner since -- 1992 was the
25 incorporation date or year, I should say.
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 9
October 19, 2021
1 J. LANGE
2 Q. Can you give us just some examples of
3 the type of work that Lange Technical Services
4 does?
5 A. We investigate the cause of vehicle
6 malfunctions that may include failures of the
7 various systems, mechanical brakes,
8 accelerator. We investigate the manifestations
9 of those malfunctions, fires, collisions,
10 generally for the purposes of insurance claim
11 investigation or products' liability. We
12 also -- I am sorry, we also perform accident
13 reconstruction and collision damage analysis.
14 Q. At some point, were you hired to
15 investigate an incident that occurred on
16 July 18th of 2015?
17 A. Yes.
18 Q. Who hired you at that point?
19 A. The Suffolk County District Attorney's
20 office, specifically, John Scott Prudenti and
21 Mark Linderman.
22 Q. Can you give us a brief background of
23 your education?
24 A. My engineering degree is in
25 electromechanical computer engineering. My
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 10
October 19, 2021
1 J. LANGE
2 master's degree is in forensic examination.
3 That would be my formal education.
4 Q. And your initial degree, was that a
5 bachelor's degree?
6 A. That was a bachelor's degree, yes.
7 Q. It was bachelor of science?
8 A. It was a bachelor of technology.
9 Q. Where did you get that?
10 A. New York Institute of Technology.
11 Q. And your master's, where did you get
12 that?
13 A. Touro. I would assume it's associated
14 with the law school. I don't know what school
15 it was associated with, but it was Touro
16 College.
17 Q. When did you get your degree from
18 New York Institute of Technology?
19 A. I am sorry. You broke up a little bit.
20 Q. When?
21 A. When, June of 1989.
22 Q. How about your master's? When did you
23 get that?
24 A. May of 2003.
25 Q. As part of your responsibilities of
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 11
October 19, 2021
1 J. LANGE
2 forensic at Lange Technical Services, do you do
3 the auto accident reconstructions?
4 A. I do some of them. But I have one
5 technician who specifically handles accident
6 reconstruction. I have four other -- three
7 other technicians that do what we call
8 collision damage analysis. And I also do
9 either of those as necessary.
10 Q. Who is the technician that does the
11 accident reconstruction?
12 A. Michael J. O'Connor.
13 Q. Who are the technicians that do the
14 damage analysis?
15 A. Mr. O'Connor does some of the damage
16 analysis. Ray Moranda does collision damage
17 analysis specifically and Larry Montanez,
18 M-O-N-T-A-N-E-Z.
19 Q. In this particular accident, you said
20 Mr. Prudenti was one of the people that hired
21 you?
22 A. Yes.
23 Q. When were you contacted by Mr. Prudenti
24 or someone else from the Suffolk County
25 District Attorney's office?
DEITZ Court Reporting... A Lexitas Company
800-678-0166
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Page 12
October 19, 2021
1 J. LANGE
2 A. If I may refer to my notes, I can tell
3 you exactly.
4 Q. Sure. Just tell us what it is that you
5 are referring to.
6 A. I am referring to my own notes that I
7 made, but they are in the documents that you
8 have from the first subpoena duces tecum. I
9 was contacted on May 31, 2016.
10 Q. So about ten and a half months after
11 this accident occurred?
12 A. No. I was under the impression the
13 accident occurred in July of 2015.
14 Q. And you were contacted in May of 2016?
15 A. Yes.
16 Q. No contact between July 18th of 2015 and
17 May 31st of 2016; is that correct?
18 A. That's correct.
19 Q. By phone or in some other manner?
20 A. I believe it was by phone.
21 Q. What were you told at that time?
22 A. I was told that there was a collision
23 that I was aware of from, you know, being a
24 Long Islander and seeing it in the news. I was
25 told they were investigating the response of
DEITZ Court Reporting... A Lexitas Company
800-678-0166
Preview
FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK -----------------------------------------------------------------------X 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, INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR OF THE ESTATE OF LAUREN BARUCH, DECEASED, AND STEVEN BARUCH, INDIVIDUALLY; JOELLE DIMONTE; AND MELISSA A. CRAI, Plaintiffs, DEMAND FOR EXECUTION OF TRANSCRIPT -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. -----------------------------------------------------------------------X PLEASE TAKE NOTICE that, pursuant to C.P.L.R. Rule 3116 governing the exchange, execution and/or signing of deposition transcripts, enclosed herewith is the following: 1. A copy of the transcript of the examination before trial upon oral questions conducted of non-party witness, Jeffrey Lange. PLEASE TAKE FURTHER NOTICE, that demand is hereby made that the transcript be read by or to the deponent, and that the deponent sign said transcript where indicated, before an officer authorized to administer an oath, and return same to the undersigned. 1 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 PLEASE TAKE FURTHER NOTICE, that pursuant to C.P.L.R. Rule 3116 (a) and the controlling cases of Columbia v. Lee, 239 A.D. 849, 264 N.Y.S. 423 (2d Dept. 1933) and Skeaney v. Silver Beach Realty Corp., 10 A.D.2d 537, 201 N.Y.S.2d 163 (1st Dept. 1960), which hold that witnesses may not in any way delete, erase or obliterate the answers as transcribed. Before the witness signs and subscribes his or her testimony, he or she may add to the end of the deposition on a sheet provided for said purpose, any changes in the form or substance of said transcript along with a statement of the reasons for making such changes. After adding such a statement, he or she may sign and subscribe his or her testimony in the transcript and on the correction page. PLEASE TAKE FURTHER NOTICE, that pursuant to C.P.L.R. Rule 3116(a), if we do not receive the duly executed original transcripts with any corrections or changes within sixty (60) days, we shall deem the copies to be an original for all purposes provide by the C.P.L.R, and may use same as though signed. No changes to the transcript may be made by the witness more than sixty (60) days after submission to the witness for review and examination. Dated: January 4, 2022 Melville, New York Yours, etc. LAW OFFICE OF ERIC D. FELDMAN By:________________________________ STEVEN A. STEIGERWALD Attorneys for Defendant CABOT COACH BUILDERS, INC Please note our new mailing address: PO Box 2903 Hartford, CT 06104-2903 (631) 501-3100 Matter No.: 2017024539SAS TO: SHEPS LAW GROUP, P.C. Robert Sheps, Esq. Attorneys for Non-Party Witness JEFFREY LANGE 25 High Street Huntington, NYT 11743 2 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Law Office of Vincent D. McNamara Attorneys for Defendant The County of Suffolk Tower Square-1045 Oyster Bay Road East Norwich, NY 11732 (516)922-9100 Lewis Johs Avallone Aviles, LLP Attorneys for Defendant Steven D. Romeo 1377 Motor Parkway Suite 400 Islandia, NY 11749 (631) 755-0101 Sullivan Papain Block McGrath & Cannavo, P.C. Attorneys for Plaintiff Estate of Lauren Baruch 1140 Franklin Avenue Suite 200 Garden City, NY 11530 (516) 742-0707 Pegalis & Erickson, LLC Attorneys for Plaintiff Joelle Dimonte One Hollow Lane Suite 10 Lake Success, NY 11042 (516) 684-2939 Joseph J. Tock, Esq. Attorney for Plaintiff Melissa A. Crai 963 Route 6 Mahopac, NY 10541 (845) 628-8080 John J. Juliano, Esq. Attorneys for Plaintiff Estate of Brittany Schulman 39 Doyle Court E. Northport, NY 11731 (631) 499-9300 The Bongiorno Law Firm, PLLC Attorneys for Plaintiff Alicia M. Arundel 1415 Kellum Place 3 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Suite 205 Garden City, NY 11530 (516) 741-4170 Paris & Chaikin, PLLC Attorneys for Plaintiff Olga Lipets 14 Penn Plaza Suite 2202 New York, NY 10122 Frank J. Laine, P.C. Attorneys for Plaintiff Estate of Amy Grabina 449 South Oyster Bay Road Plainview, NY 11803 (516) 937-1010 Block O’Toole & Murphy LLP Attorneys for Plaintiff Estate of Stephanie Belli One Penn Plaza, Suite 5315 New York, NY 10119 (212)736-5300 Cascone & Klupfel, LLP Attorneys for Defendant Romeo Dimon Marine Services, Inc. 497 Main Street Farmingdale, NY 11735 (516) 747-1990 Volz & Vigliotta, PLLC Attorneys for Defendant The Town of Southold 280 Smithtown Boulevard Nesconset, NY 11767 (631)366-2700 Bongiorno, Montiglio & Palmieri, PLLC Attorneys for Defendants Carlos F. Pino and Ultimate Class Limousine, Inc. 200 Old Country Road Suite 680 Mineola, New York 11501 (516)620-0687 4 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 5 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 6 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 1 October 19, 2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ----------------------------------------x 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, MELISSA A. CRAI, ARTHUR A. BELLI JR, AS PARENT AND NATURAL GUARDIAN OF STEPHANIE BELLI, DECEASED, AND AS THE ADMINISTRATOR OF THE ESTATE OF STEPHANIE BELLI, Plaintiffs, -against- Index No: 611214/15 69082/15 600055/16 603536/16 003364/16 607598/16 001831/16 STEVEN D. ROMEO, ROMEO DIMON MARINE SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS LIMOUSINE, INC., COUNTY OF SUFFOLK, TOWN OF SOUTHOLD and 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. ----------------------------------------x (Caption continued on the next page.) DEITZ Court Reporting... A Lexitas Company 800-678-0166 7 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 2 October 19, 2021 1 2 VIDEOCONFERENCE EXAMINATION BEFORE 3 TRIAL of the Non-Party Witness, JEFFREY LANGE, 4 taken by the Defendants, pursuant to So-Ordered 5 Stipulation, on October 19, 2021, at 10:20 6 a.m., before a Notary Public of the State of 7 New York. 8 *********************************************** 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 8 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 3 October 19, 2021 1 A P P E A R A N C E S: 2 3 THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 4 ALICIA M. ARUNDEL 1415 Kellum Place, Suite 205 5 Garden City, New York 11530 6 BY: PETER BONGIORNO, ESQ. 7 8 LAW OFFICE OF JOHN L. JULIANO, P.C. Attorney for Plaintiff 9 ESTATE OF BRITTNEY SCHULMAN 39 Doyle Court 10 East Northport, New York 11731 11 12 CHAIKIN, PLLC Attorneys for Plaintiff 13 OLGA LIPETS 14 Penn Plaza, Suite 2202 14 New York, New York 10122 15 BY: IAN CHAIKIN, ESQ. 16 17 FRANK J. LAINE, P.C. Attorneys for Plaintiff 18 ESTATE OF AMY GRABINA 449 South Oyster Bay Road 19 Plainview, New York 11803 20 BY: JOANNE PORCELLI, ESQ. 21 SULLIVAN PAPAIN BLOCK McGRATH COFFINAS & 22 CANNAVO, P.C. Attorneys for Plaintiff 23 ESTATE OF LAUREN BARUCH 1140 Franklin Avenue, Suite 200 24 Garden City, New York 11530 25 BY: BETH JABLON, ESQ. DEITZ Court Reporting... A Lexitas Company 800-678-0166 9 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 4 October 19, 2021 1 A P P E A R A N C E S: (CONTINUED) 2 3 PEGALIS LAW GROUP, LLC 4 Attorneys for Plaintiff JOELLE DIMONTE 5 One Hollow Lane, Suite 107 Lake Success, New York 11042 6 BY: GARY NIELSON, ESQ. 7 8 LAW OFFICES OF JOSEPH J. TOCK Attorney for Plaintiff 9 MELISSA A. CRAI 963 Route 6 10 Mahopac, New York 10541 11 BLOCK O'TOOLE & MURPHY, LLP 12 Attorneys for Plaintiff ALICIA M. ARUNDEL 13 One Pennsylvania Plaza, Suite 5315 New York, New York 10119 14 BY: DANIEL M. SEIDEN, ESQ. 15 16 LEWIS JOHS AVALLON & AVILES, LLP 17 Attorneys for Defendant STEVEN D. ROMEO 18 1377 Motor Parkway, Suite 400 Islandia, New York 11749 19 BY: REBECCA K. DEVLIN, ESQ. 20 FILE #: 1141416 21 22 CASCONE & KLUEPFEL, LLP Attorneys for Defendant 23 ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 24 Garden City, New York 11530 25 BY: DAVID TAVELLA, ESQ. DEITZ Court Reporting... A Lexitas Company 800-678-0166 10 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 5 October 19, 2021 1 A P P E A R A N C E S: (CONTINUED) 2 3 BONGIORNO, MONTIGLIO, MITCHELL & PALMIERI, PLLC Attorneys for Defendants 4 CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 5 200 Old Country Road, Suite 680 Mineola, New York 11501 6 BY: NEIL PALMIERI, ESQ. 7 8 LAW OFFICE OF VINCENT D. McNAMARA 9 Attorneys for Defendant THE COUNTY OF SUFFOLK 10 1045 Oyster Bay Road East Norwich, New York 11732 11 BY: DAVID TEIXEIRA, ESQ. 12 FILE #: 9074677 13 14 VOLZ & VIGLIOTA, PLLC Attorneys for Defendant 15 TOWN OF SOUTHOLD 280 Smithtown Boulevard 16 Nesconset, New York 11767 17 BY: DAVID ARNTSEN, ESQ. 18 FILE #: HCC19.10 19 20 THE LAW OFFICE OF ERIC D. FELDMAN Attorneys for Defendant 21 CABOT COACH BUILDERS, INC., d/b/a ROYALE LIMOUSINE 22 2 Corporate Center Drive, Suite 300 Melville, New York 11747 23 BY: STEVEN STEIGERWALD, ESQ. 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 11 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 6 October 19, 2021 1 A P P E A R A N C E S: (CONTINUED) 2 3 SHEPS LAW GROUP, P.C. Attorney for Non-Party Witness 4 JEFFREY LANGE 25 High Street 5 Huntington, New York 11743 6 BY: ROBERT SHEPS, ESQ. 7 8 ALSO PRESENT: 9 DARA ROSENBAUM, ESQ. - ROSENBAUM & TAYLOR, P.C. 10 MICHAEL FRITTOLA, ESQ. - LESTER SCHWAB KATZ & 11 DWYER, LLP 12 PAUL KASSIRER, ESQ. - LESTER SCHWAB KATZ & DWYER, LLP 13 PAMELA HOLMES - DOCUMENT TECHNICIAN 14 15 16 17 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 12 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 7 October 19, 2021 1 2 J E F F R E Y L A N G E, the witness herein, 3 having been first duly sworn by a Notary Public 4 of the State of New York, was examined and 5 testified as follows: 6 EXAMINATION BY 7 MR. STEIGERWALD: 8 Q. State your name for the record, please. 9 A. Jeffrey Lange. 10 Q. State your business address for the 11 record, please. 12 A. 751 Long Island Avenue, Deer Park, New 13 York 11729. 14 Q. Good morning, Mr. Lange. My name is 15 Steven Steigerwald. How are you? 16 A. I am good. 17 Q. I assume you have been to depositions 18 before. 19 A. I have. 20 Q. And you know that if you need to take a 21 break at any time, you can do so simply by 22 letting us know. The only thing I would ask 23 you to do is finish answering any open question 24 before you take a break. All right? 25 A. Yes. DEITZ Court Reporting... A Lexitas Company 800-678-0166 13 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 8 October 19, 2021 1 J. LANGE 2 Q. I will do my best to wait for you to 3 complete your answer if you promise to do your 4 best to allow me to complete my questions, 5 because Janice has the hardest job here today 6 to take the entire record. 7 A. That's fine. 8 Q. You gave us your business address. What 9 business is located there? 10 A. I am sorry. Question? 11 Q. What business is located at that 12 address? 13 A. Lange Technical Services, L-A-N-G-E. 14 Q. What type of business is Lange Technical 15 Services? 16 A. It's a forensic automotive engineering 17 company. 18 Q. Are you the proprietor of Lange 19 Technical Services? 20 A. Yes. 21 Q. For how long have you been the 22 proprietor of Lange Technical Services? 23 A. I have been president for approximately 24 12 years, but an owner since -- 1992 was the 25 incorporation date or year, I should say. DEITZ Court Reporting... A Lexitas Company 800-678-0166 14 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 9 October 19, 2021 1 J. LANGE 2 Q. Can you give us just some examples of 3 the type of work that Lange Technical Services 4 does? 5 A. We investigate the cause of vehicle 6 malfunctions that may include failures of the 7 various systems, mechanical brakes, 8 accelerator. We investigate the manifestations 9 of those malfunctions, fires, collisions, 10 generally for the purposes of insurance claim 11 investigation or products' liability. We 12 also -- I am sorry, we also perform accident 13 reconstruction and collision damage analysis. 14 Q. At some point, were you hired to 15 investigate an incident that occurred on 16 July 18th of 2015? 17 A. Yes. 18 Q. Who hired you at that point? 19 A. The Suffolk County District Attorney's 20 office, specifically, John Scott Prudenti and 21 Mark Linderman. 22 Q. Can you give us a brief background of 23 your education? 24 A. My engineering degree is in 25 electromechanical computer engineering. My DEITZ Court Reporting... A Lexitas Company 800-678-0166 15 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 10 October 19, 2021 1 J. LANGE 2 master's degree is in forensic examination. 3 That would be my formal education. 4 Q. And your initial degree, was that a 5 bachelor's degree? 6 A. That was a bachelor's degree, yes. 7 Q. It was bachelor of science? 8 A. It was a bachelor of technology. 9 Q. Where did you get that? 10 A. New York Institute of Technology. 11 Q. And your master's, where did you get 12 that? 13 A. Touro. I would assume it's associated 14 with the law school. I don't know what school 15 it was associated with, but it was Touro 16 College. 17 Q. When did you get your degree from 18 New York Institute of Technology? 19 A. I am sorry. You broke up a little bit. 20 Q. When? 21 A. When, June of 1989. 22 Q. How about your master's? When did you 23 get that? 24 A. May of 2003. 25 Q. As part of your responsibilities of DEITZ Court Reporting... A Lexitas Company 800-678-0166 16 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 11 October 19, 2021 1 J. LANGE 2 forensic at Lange Technical Services, do you do 3 the auto accident reconstructions? 4 A. I do some of them. But I have one 5 technician who specifically handles accident 6 reconstruction. I have four other -- three 7 other technicians that do what we call 8 collision damage analysis. And I also do 9 either of those as necessary. 10 Q. Who is the technician that does the 11 accident reconstruction? 12 A. Michael J. O'Connor. 13 Q. Who are the technicians that do the 14 damage analysis? 15 A. Mr. O'Connor does some of the damage 16 analysis. Ray Moranda does collision damage 17 analysis specifically and Larry Montanez, 18 M-O-N-T-A-N-E-Z. 19 Q. In this particular accident, you said 20 Mr. Prudenti was one of the people that hired 21 you? 22 A. Yes. 23 Q. When were you contacted by Mr. Prudenti 24 or someone else from the Suffolk County 25 District Attorney's office? DEITZ Court Reporting... A Lexitas Company 800-678-0166 17 of 229 FILED: SUFFOLK COUNTY CLERK 01/13/2022 02:38 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 01/13/2022 Page 12 October 19, 2021 1 J. LANGE 2 A. If I may refer to my notes, I can tell 3 you exactly. 4 Q. Sure. Just tell us what it is that you 5 are referring to. 6 A. I am referring to my own notes that I 7 made, but they are in the documents that you 8 have from the first subpoena duces tecum. I 9 was contacted on May 31, 2016. 10 Q. So about ten and a half months after 11 this accident occurred? 12 A. No. I was under the impression the 13 accident occurred in July of 2015. 14 Q. And you were contacted in May of 2016? 15 A. Yes. 16 Q. No contact between July 18th of 2015 and 17 May 31st of 2016; is that correct? 18 A. That's correct. 19 Q. By phone or in some other manner? 20 A. I believe it was by phone. 21 Q. What were you told at that time? 22 A. I was told that there was a collision 23 that I was aware of from, you know, being a 24 Long Islander and seeing it in the news. I was 25 told they were investigating the response of DEITZ Court Reporting... A Lexitas Company 800-678-0166