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 06/15/2022 02:36 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 897 RECEIVED NYSCEF: 06/15/2022
Josh H. Kardisch
From: Josh H. Kardisch
Sent: Tuesday, May 31, 2022 11:34 AM
To: Dave Teixeira
Cc: VDM Info; Olivia Segota
Subject: RE: Joelle Dimonte v.County f Suffolk,et al
Please advise if you are claiming that there is any discovery outstanding other than a further ebt
of our client. Thanks. fal
JOSH H. KARDISCH, ESQ.
PEGALIS LAW GROUP, LLC
Attorneys and Counselors at Law
1 Hollow Lane, Suite 107
Lake Success, New York 11042
office: (516) 684-2900
cell: (516) 578-3637
fax: (516) 684-2939
e-mail: jkardisch@pegalislawgroup.com
From: Dave Teixeira
Sent: Tuesday, May 31, 2022 11:30 AM
To: Josh H. Kardisch
Cc: VDM Info ; Olivia Segota ; Dave Teixeira
Subject: RE: Joelle Dimonte v. County f Suffolk, et al
Good Morning, Josh:
I hope you had a nice holiday weekend.
After further discussion, interrogatories or something of that nature will not be sufficient given the
additional eye surgeries/treatment being claimed by Ms. Dimonte, and we will require a further
deposition on those points. The deposition could be done virtually, as have others in this matter, to
accommodate scheduling.
As a courtesy, wanted to further advise that we will be filing a motion to vacate the Note of Issue
later today. I understand that we spoke last week, but from what I can tell, today is our deadline to
do so, so we are constrained to at least interpose the motion to protect the County's interests.
That said, happy to continue our conversation in the interim and work toward a resolution of this
issue.
1
FILED: SUFFOLK COUNTY CLERK 06/15/2022 02:36 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 897 RECEIVED NYSCEF: 06/15/2022
Thanks,
Dave
CHARLES D. TEIXEIRA, ESQ.
Law Office of Vincent D. McNamara
1045 Oyster Bay Road, Suite 1
East Norwich, NY 11732
T: 516-922-9100
F: 516-922-9208
E: dteixeira@vdm-law.com
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Document Filed Date
June 15, 2022
Case Filing Date
October 21, 2015
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FILED: SUFFOLK COUNTY CLERK 06/15/2022 02:36 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 897 RECEIVED NYSCEF: 06/15/2022 Josh H. Kardisch From: Josh H. Kardisch Sent: Tuesday, May 31, 2022 11:34 AM To: Dave Teixeira Cc: VDM Info; Olivia Segota Subject: RE: Joelle Dimonte v.County f Suffolk,et al Please advise if you are claiming that there is any discovery outstanding other than a further ebt of our client. Thanks. fal JOSH H. KARDISCH, ESQ. PEGALIS LAW GROUP, LLC Attorneys and Counselors at Law 1 Hollow Lane, Suite 107 Lake Success, New York 11042 office: (516) 684-2900 cell: (516) 578-3637 fax: (516) 684-2939 e-mail: jkardisch@pegalislawgroup.com From: Dave Teixeira Sent: Tuesday, May 31, 2022 11:30 AM To: Josh H. Kardisch Cc: VDM Info ; Olivia Segota ; Dave Teixeira Subject: RE: Joelle Dimonte v. County f Suffolk, et al Good Morning, Josh: I hope you had a nice holiday weekend. After further discussion, interrogatories or something of that nature will not be sufficient given the additional eye surgeries/treatment being claimed by Ms. Dimonte, and we will require a further deposition on those points. The deposition could be done virtually, as have others in this matter, to accommodate scheduling. As a courtesy, wanted to further advise that we will be filing a motion to vacate the Note of Issue later today. I understand that we spoke last week, but from what I can tell, today is our deadline to do so, so we are constrained to at least interpose the motion to protect the County's interests. That said, happy to continue our conversation in the interim and work toward a resolution of this issue. 1 FILED: SUFFOLK COUNTY CLERK 06/15/2022 02:36 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 897 RECEIVED NYSCEF: 06/15/2022 Thanks, Dave CHARLES D. TEIXEIRA, ESQ. Law Office of Vincent D. McNamara 1045 Oyster Bay Road, Suite 1 East Norwich, NY 11732 T: 516-922-9100 F: 516-922-9208 E: dteixeira@vdm-law.com CONFIDENTIAL: ATTORNEY-CLIENT PRIVILEGED; ATTORNEY WORK PRODUCT: Emails and attachments received from us may be protected by the attorney-client privilege, as attorney work-product or based on other privileges or provisions of law. If you are not an intended recipient of this email, do not read, copy, use, forward or disclose the email or any of its attachments to others. Instead, immediately notify the sender by replying to this email and then delete it from your system. We strictly prohibit any unauthorized disclosure, copying, distribution or use of emails or attachments sent by us.