Preview
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVED NYSCEF: 07/14/2022
EXHIBIT C
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
INDEX NO. 6@$988/2015
|FILED:
NYSCEF DOC. SUFEOLK
NO. 911 COUNTY CLERK 83/29/2015 89:55 m$ RECEIVED NYSCEF: 07/14/2022
NYSCEF DOC. NO 985 RECEIVED NYSCEF: $2/24/2318
SUPREME COURT OF THE STATE OF NEW YORK
COlJNTY OF SUFFOLK
________________________________________________Ç
ALICIA M. ARUNDEL,
Plaintiff, Index No: 609082/15
- against - ANSWER TO
DEFENDANT, COUNTY
STEVEN D. ROMEO, ROMEO DIMON MARINE OF SUFFOLK'S
SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS
LIMOUSINE, INC., THE COUNTY OF SUFFOLK and
THE TOWN OF SOUTHOLD,
Defendants.
_....._____________________________________________Ç
Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its
attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendant,
COUNTY OF SUFFOLK 's,cross-claims.
l. Denies each and every allegation contained in defendant's cross-claim.
WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment
dismissing defendant's cross-claims together with costsanddisbursements.
Dated: Garden City, New York
March 28, 2016
By: /
DAVID F. EPFEL, ESQ.
CASCONE & KLUEPFEL, LLP
Attorneys for Defendant
ROMEO DIMON MARINE
SERVICES, INC.
1399 Franklin Avenue, Suite 302
Garden City, New York 1 1530
(516) 747-1990
File No.: 03787DVM
1 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVED
INDEX
NYSCEF:
NO.
07/14/2022
611214/2)15
(FILED: SUFEOLK COUNTY CLERK 11/14 /2019 10:16 AM)
NYSCEF DOC. NO 585 RECEIVED NYSCEF: 11/14/2)19
TO: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230,PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No.: 0114.1460.001C
AHMUlŽ, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
UUTIMATE CLASS LIMOUSINE, INC.
20 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 11
Smithtown, New York 11787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
2 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVEDINDEX
NYSCEF:
NO. 07/14/2022
6@$282/2015
|FILED: SUFFOLK COUNTY CLERK 83/28/2015 89:55 RM|
NYSCEF DOC. NO. 965 RECEIVED NYSCEF: $3/24/2010
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
COUNTY OF NASSAU )ss.:
I,LAUREN LUCCHESE, being duly sworn, say: I am not a party to the action, am over 18 years of
age and reside at Suffolk County, New York:
On March 29, 2016 I served the within ANSWER TO DEFENDANT COUNTY OF SUFFOLK'S
CROSS-CLAIMS
[x] Service by depository under the exclusive care and oflicial
by depositing a true copy thereof in a post-paid wrapper, in an official depository under the
Mail exclusive care and custody of the U.S. Postal Service withinState, addressedto cach of the following
the New York personsat the last known
address set fodhaftereachname:
| |Personal a true copy thereof personally to each person named below at the address indicated. I knew each person served to be the person
by delivering
Served on mentioned and described in said papers as a party therein:
individual
| |Service by by transmitting which number was designated by the attomey for such
the papers by electronic means to the telephone number listed below,
Electronic purpose. I received a signal from the equipment of the attomey served indicating that the transmission was received.
1alsodeposited a true
Means depository under the care and custody of the (J S. Postal Service, addressedto
copy of the papers, enclosed in a post-paid wrapper, in an official
the attorney at the address set forth after each name:
Overnight into the custody of
a true copy thereof, enclosed in a wrapper addressed as shown below,
by depositing UNITED PARCEL SERVICE for
prior to the latest time designated by that service for overnight delivery.
overnight delivery,
TO: THEBONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
20 LU. Willets Road
Albertson, New York 11507
(516) 294-5433
1 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVEDINDEX
NYSCEF:
NO.
07/14/2022
611214/2015
|FILED : SUFFOLK COUNTY CLERK 11/14 /2 019 10 : 16 AM|
NYSCEF DOC. NO . 5 85 RECEIVED NYSCEF: 11/14/2019
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 11
Smithtown, New York 1 I787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
LAUREN LUCCHESE
Sworn to before me this
290'
day of March, 2016
LESLIE GOrv DON
NotaryPublic, aw York
Notary Public
LESLIE GORDON
Notary Pudic.State of New York
No. 01GO6028652
Qualifiedin NassauCoun -
Commission Expires August
2,
2 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF
FILED: DOC. NO. 911
SUFPOLK COUNTY CLERK 83/29/2016 8Q:50
RECEIVEDINDEX NYSCEF:
NO. 07/14/2022
69398a/2 15
RM|
NYSCEF DOC. NO. 985 RECEIVED NYSCEF: $3/2@/2 18
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
________________________________________________Ç
ALICIA M. ARUNDEL,
Plaintiff, Index No: 609082/15
- against - ANSWER TO
DEFENDANTS', PINO
STEVEN D. ROMEO, ROMEO DIMON MARINE AND ULTIMATE'S
SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS
LIMOUSINE, INC., THE COUNTY OF SUFFOLK and
THE TOWN OF SOUTHOLD,
Defendants.
________________________________________Ç
Defendant, ROMEO DIMON MARINE SF3RVICES, INC., by and through its
attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendants,
CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC.'s, cross-claims.
defendants'
1. Denies each and every allegation contained in cross-claim.
WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment
defendants'
dismissing cross-claims together with costs and disbursements.
Dated: Garden City, New York
March 28, 2016
DÃVID F. PFEL, ESQ.
CASCONE & KLUEPFEL, LLP
Attorneys for Defendant
ROMEO DIMON MARINE
SERVICES, INC.
1399 Franklin Avenue, Suite 302
Oarden City, New York 11530
(516) 747-1990
File No.: 03787DVM
1 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
INDEX NO. 611214/2015
FILED: DOC.
NYSCEF SUF¶OLK
NO. 911 COUNTY CLERK 11/14 /2019 10:16 AM) RECEIVED NYSCEF: 07/14/2022
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
TO: THE BONOIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola Boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York I1749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
20 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route I1
Smithtown, New York 11787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys forDefendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
2 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVEDINDEX NYSCEF:
NO. 07/14/2022
6$3083/2315
|FILED: SUF OLK COUNTY CLERK 83/29/ 2016 88: 8 0 RMl
NYSCEF DOC. NO 985 RECEIVED NYSCEF: $2/24/2318
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
--------------------------------_ ____ _____________Ç
ALICIA M. ARUNDEL,
Plaintiff, Index No: 609082/15
- against - ANSWER TO
DEFENDANT, TOWN
STEVEN D. ROMEO, ROMEO DIMON MARINE OF SOUTHOLD'S
SERVICES, INC., CARLOS F. PINO, UlllMATE CLASS CROSS-CLAIMS
LIMOUSINE, INC., THE COUNTY OF SUFFOLK and
THE TOWN OF SOUTHOLD,
Defendants.
__________________________________________Ç
Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its
attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendant,
TOWN OF SOUTHOLD's, cross-claims.
1 Denies each and every allegation contained in defendant's cross-claim.
WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment
dismissing defendant's cross-claims together with costs and disbursements.
Dated: Oarden City, New York
March 28, 2016
By:
19AVID F. KL PFEL, ESQ.
CASCONE & KLUEPFEL, LLP
Attorneys for Defendant
ROMEO DIMON MARINE
SERVICES, INC.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
(516) 747-1990
File No.: 03787DVM
1 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVED
INDEX
NYSCEF:
NO.
07/14/2022
611214/2015
IFILED: SUFEOLK COUNTY CLERK 11/14/2019 10:16 AM|
NYSCEF DOC. NO 585 RECEIVED NYSCEF: 11/14/2019
TO: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola Boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
20 LU. Willets Road
Albertson, New York I1507
(516) 294-5433
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 11
Smithtown, New York I1787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
i
2 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
|FILED: DOC.
NYSCEF SUFFOLK
NO. 911 COUNTY CLERK 83/29/2016 88:00 RECEIVEDINDEXNYSCEF:
NO. 60%07/14/2022
$4/2015
J!tM|
NYSCEF DOC. NO. 805 RECEIVED NYSCEF: @]/24/2010
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
COUNTY OF NASSAU )ss.:
I,LAUREN LUCCHESE, being duly sworn, say: I arn not a to the am over 18
party action, years of
age and reside at Suffolk County, New York:
On March 29, 2016 I served the within ANSWER TO DEFENDANT TOWN OF SOUTHOLD'S
CROSS-CLAIMS
[x| Service by by depositing a true copy thereof in a post-paid wrapper, in an official
depository under the exclusive care and oflicial
depository under
the
Mail exclusive care and custody of the U.S. Postal Service within
the New YorkState, addressedto each of the following
personsat the last known
address set forth after each name:
I |Personal by delivering a true copy thereof personally to each person named below at the address indicated. I knew each person servedto be the person
Served on mentioned and described in said papers as a partytherein:
individual
[ IServiceby by transmitting the papers by electronic means to the telephone number listed below,
which number was designated by the attorney for such
Electronie purpose. I received a signal fi·om the equipment of the attorney served indicating
that the transmission was received,
I alsodepositeda true
Means copy of the papers, enclosed in a post-paid wrapper, in an official
depository under the care and custody of the U.S. Postal Service, addressedto
the attorney at the address set forth aller each name:
[ I Overnight a true copy thereof, enclosed in a wrapper addressed as shown below,
by depositing into the custody of
UNFFED PARCEL SERVICE for
overnight delivery, prior to the latest time designated by that service for overnight delivery.
TO: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
250 Mineola boulevard
Mineola, New York 11501
(516) 741-4170
File No.: 6230.PP
LEWIS JOHS AVALLONE VILES, U,P
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York I1749
(631) 755-0101
File No.: 0114.1460.001C
AHMUTY, DEMERS & McMANUS, ESQ.
Attorneys for Defendants
CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
20 I.U. Willets Road
Albertson, New York I1507
(516) 294-5433
1 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVED NYSCEF: 07/14/2022
INDEX NO. 611214/2 015
FILED: SUFFOLK COUNTY CLERK 11/14 /2019 10:16 AM|
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
DEVITT, SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route I1
Smithtown, New York 11787
(631) 724-8833
SUFFOLK COUNTY ATTORNEY
Attorneys for Defendant
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New York 11788
(631) 853-4049
LAUREN LUCCHESE
Sworn to before me this
29d'
day of March, 2016
LESLIE GORDON
Notary Public. State of New ¼rk
No.01GO6028652
a Qommis n a Augu OÛ
Notary Public
2 of 2
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
FILED : SUFFOLK COUNTY CLERK 18 INDEX NO. 609082/2015
5 1 B : U
NYSCEF DOC. NO. 911 RECEIVED NYSCEF: 07/14/2022
NYSCEF DOC. NO. 505 RECEIVED NYSCEF: 19/G5/2013
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
-----------------------------------------------------------------X Index No.: 609082/2015
ALICIA M. ARUNDEL,
Plaintiff(s),
-against- REPLY TO CROSS-CLAIM
OF DEFENDANT, ROMEO
STEVEN D. ROMEO, ROMEO DIMON MARINE DIMON MARINE SERVICES, INC.
SERVICES, INC. CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.,
Defendant(s).
________________________________________________________________Ç
The defendants, CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC.,
by their attorneys, AHMUTY, DEMERS & McMANUS, ESQS., as and for their reply to
defendant, ROMEO DIMON MARINE SERVICES, INC's cross-claim, alleges upon
information and belief:
AS AND FOR AN ANSWER TO A CROSS-CLAIM
FIRST: Denies each and every allegation contained in paragraphs designated
"20"
of the cross claim.
WHEREFORE, defendants, CARLOS F. PINO and ULTIMATE CLASS
LIMOUSINE, INC., demands judgment dismissing the cross claim of the defendant,
ROMEO DIMON MARINE SERVICES, INC., together with the costs and disbursements
of this action.
Dated: Albertson, New York
October 2, 2015
Yours, etc.
AHMUTY, RS McMANUS, ESQS.
__
By: Neil J. Palmieri, Esq.
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVEDINDEX NYSCEF:
NO. 07/14/2022
611214/2015
IFILED: SUFFOLK COUNTY CLERK 11/14 /2019 10 : 16 AM|
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
Attorneys for CARLOS F. PINO and
ULTIMATE CLASS LIMOUSINE, INC.
200 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
Our File No.: 1BM 068515 NJP
To: The Bongiorno Law Firm, PLLC
Attorneys for Plaintiff
250 Mineola Boulevard
Mineola, New York 11501
(516) 741-4170
File No. 6230.PP
Lewis, Johs, Avallone & Aviles, LLP
Attorneys for Steven D. Romeo
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No. 0114-1460-001C
Cascone & Kluepfel, LLP
Attorneys for Romeo Dimon Marine Services, Inc.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
(516) 747-1990
File No. 03787DVM
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVED NYSCEF: 07/14/2022
INDEX NO. 611214/2015
I FILED : SU F FOLK COUNTY CLERK 11/14 / 2 019 10 : 16 AM1
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
STATE OF NEW YORK )
) ss:
COUNTY OF NASSAU )
TRACEY DAVIDA-HERBST, being duly sworn deposes and says that she is
not a party to this action; that she isover the age of eighteen years; resides in Babylon
Village, New York;
5th
That on the day of October, 2015, she served the within
Reply to Cross-Claim of Defendant, Romeo Dimon Marine Services, Inc.
Upon:
The Bongiorno Law Firm, PLLC
250 Mineola Boulevard
Mineola, New York 11501
Lewis, Johs, Avallone & Aviles, LLP
One CA Plaza, Suite 225
Islandia, New York 11749
Cascone & Kluepfel, LLP
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
the attorneys for the respective parties, hereto at the address designated by them for that
purpose, by depositing a true copy of same enclosed in a postpaid properly addressed
wrapper, in an official depository under the exclusive care and custody of the United
States Post Office Department within the State of New York.
TRA Y . DAV0DA- T
Sworn to before me on this
5th
day of October, 2015
Notary Publi
CHRISTINA JEFFORDS
NotaryPublic,Stateof New York
No. 01RO6137142
QualiBed in NassauCoun
Commission ExpiresNðv. 14,
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 911 RECEIVED
INDEX
NYSCEF:
NO.
07/14/2022
611214 /2 015
|FILED: SUFFOLK COUNTY CLERK 11/14 /2019 10 : 16 AM|
NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK INDEX NO. 609082/2015
ALICIA M. ARUNDEL,
Plaintiff,
-against-
STEVEN D. ROMEO, ROMEO DIMON MARINE SERVICES, INC. CARLOS
F. PINO and ULTIMATE CLASS LIMOUSINE, INC.,
Defendants.
Reply to Cross Claim of Defendant, Romeo Dimon Marine Services, Inc.
AHMUTY, DEMERS & McMANUS
Attorneys for Defendants
CARLOS F. PINO and ULTIMATE CLASS LIMOUSINES, INC.
200 I.U. Willets Road
Albertson, New York 11507
(516) 294-5
Preview
FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVED NYSCEF: 07/14/2022 EXHIBIT C FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 INDEX NO. 6@$988/2015 |FILED: NYSCEF DOC. SUFEOLK NO. 911 COUNTY CLERK 83/29/2015 89:55 m$ RECEIVED NYSCEF: 07/14/2022 NYSCEF DOC. NO 985 RECEIVED NYSCEF: $2/24/2318 SUPREME COURT OF THE STATE OF NEW YORK COlJNTY OF SUFFOLK ________________________________________________Ç ALICIA M. ARUNDEL, Plaintiff, Index No: 609082/15 - against - ANSWER TO DEFENDANT, COUNTY STEVEN D. ROMEO, ROMEO DIMON MARINE OF SUFFOLK'S SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS LIMOUSINE, INC., THE COUNTY OF SUFFOLK and THE TOWN OF SOUTHOLD, Defendants. _....._____________________________________________Ç Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendant, COUNTY OF SUFFOLK 's,cross-claims. l. Denies each and every allegation contained in defendant's cross-claim. WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment dismissing defendant's cross-claims together with costsanddisbursements. Dated: Garden City, New York March 28, 2016 By: / DAVID F. EPFEL, ESQ. CASCONE & KLUEPFEL, LLP Attorneys for Defendant ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 Garden City, New York 1 1530 (516) 747-1990 File No.: 03787DVM 1 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVED INDEX NYSCEF: NO. 07/14/2022 611214/2)15 (FILED: SUFEOLK COUNTY CLERK 11/14 /2019 10:16 AM) NYSCEF DOC. NO 585 RECEIVED NYSCEF: 11/14/2)19 TO: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230,PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No.: 0114.1460.001C AHMUlŽ, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and UUTIMATE CLASS LIMOUSINE, INC. 20 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 11 Smithtown, New York 11787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 2 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVEDINDEX NYSCEF: NO. 07/14/2022 6@$282/2015 |FILED: SUFFOLK COUNTY CLERK 83/28/2015 89:55 RM| NYSCEF DOC. NO. 965 RECEIVED NYSCEF: $3/24/2010 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) COUNTY OF NASSAU )ss.: I,LAUREN LUCCHESE, being duly sworn, say: I am not a party to the action, am over 18 years of age and reside at Suffolk County, New York: On March 29, 2016 I served the within ANSWER TO DEFENDANT COUNTY OF SUFFOLK'S CROSS-CLAIMS [x] Service by depository under the exclusive care and oflicial by depositing a true copy thereof in a post-paid wrapper, in an official depository under the Mail exclusive care and custody of the U.S. Postal Service withinState, addressedto cach of the following the New York personsat the last known address set fodhaftereachname: | |Personal a true copy thereof personally to each person named below at the address indicated. I knew each person served to be the person by delivering Served on mentioned and described in said papers as a party therein: individual | |Service by by transmitting which number was designated by the attomey for such the papers by electronic means to the telephone number listed below, Electronic purpose. I received a signal from the equipment of the attomey served indicating that the transmission was received. 1alsodeposited a true Means depository under the care and custody of the (J S. Postal Service, addressedto copy of the papers, enclosed in a post-paid wrapper, in an official the attorney at the address set forth after each name: Overnight into the custody of a true copy thereof, enclosed in a wrapper addressed as shown below, by depositing UNITED PARCEL SERVICE for prior to the latest time designated by that service for overnight delivery. overnight delivery, TO: THEBONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 20 LU. Willets Road Albertson, New York 11507 (516) 294-5433 1 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVEDINDEX NYSCEF: NO. 07/14/2022 611214/2015 |FILED : SUFFOLK COUNTY CLERK 11/14 /2 019 10 : 16 AM| NYSCEF DOC. NO . 5 85 RECEIVED NYSCEF: 11/14/2019 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 11 Smithtown, New York 1 I787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 LAUREN LUCCHESE Sworn to before me this 290' day of March, 2016 LESLIE GOrv DON NotaryPublic, aw York Notary Public LESLIE GORDON Notary Pudic.State of New York No. 01GO6028652 Qualifiedin NassauCoun - Commission Expires August 2, 2 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF FILED: DOC. NO. 911 SUFPOLK COUNTY CLERK 83/29/2016 8Q:50 RECEIVEDINDEX NYSCEF: NO. 07/14/2022 69398a/2 15 RM| NYSCEF DOC. NO. 985 RECEIVED NYSCEF: $3/2@/2 18 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ________________________________________________Ç ALICIA M. ARUNDEL, Plaintiff, Index No: 609082/15 - against - ANSWER TO DEFENDANTS', PINO STEVEN D. ROMEO, ROMEO DIMON MARINE AND ULTIMATE'S SERVICES, INC., CARLOS F. PINO, ULTIMATE CLASS CROSS-CLAIMS LIMOUSINE, INC., THE COUNTY OF SUFFOLK and THE TOWN OF SOUTHOLD, Defendants. ________________________________________Ç Defendant, ROMEO DIMON MARINE SF3RVICES, INC., by and through its attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendants, CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC.'s, cross-claims. defendants' 1. Denies each and every allegation contained in cross-claim. WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment defendants' dismissing cross-claims together with costs and disbursements. Dated: Garden City, New York March 28, 2016 DÃVID F. PFEL, ESQ. CASCONE & KLUEPFEL, LLP Attorneys for Defendant ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 Oarden City, New York 11530 (516) 747-1990 File No.: 03787DVM 1 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 INDEX NO. 611214/2015 FILED: DOC. NYSCEF SUF¶OLK NO. 911 COUNTY CLERK 11/14 /2019 10:16 AM) RECEIVED NYSCEF: 07/14/2022 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 TO: THE BONOIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola Boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York I1749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 20 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route I1 Smithtown, New York 11787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys forDefendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 2 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVEDINDEX NYSCEF: NO. 07/14/2022 6$3083/2315 |FILED: SUF OLK COUNTY CLERK 83/29/ 2016 88: 8 0 RMl NYSCEF DOC. NO 985 RECEIVED NYSCEF: $2/24/2318 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK --------------------------------_ ____ _____________Ç ALICIA M. ARUNDEL, Plaintiff, Index No: 609082/15 - against - ANSWER TO DEFENDANT, TOWN STEVEN D. ROMEO, ROMEO DIMON MARINE OF SOUTHOLD'S SERVICES, INC., CARLOS F. PINO, UlllMATE CLASS CROSS-CLAIMS LIMOUSINE, INC., THE COUNTY OF SUFFOLK and THE TOWN OF SOUTHOLD, Defendants. __________________________________________Ç Defendant, ROMEO DIMON MARINE SERVICES, INC., by and through its attorneys, CASCONE & KLUEPFEL, LLP, hereby interposes the following answer to defendant, TOWN OF SOUTHOLD's, cross-claims. 1 Denies each and every allegation contained in defendant's cross-claim. WHEREFORE, ROMEO DIMON MARINE SERVICES, INC., demands judgment dismissing defendant's cross-claims together with costs and disbursements. Dated: Oarden City, New York March 28, 2016 By: 19AVID F. KL PFEL, ESQ. CASCONE & KLUEPFEL, LLP Attorneys for Defendant ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 (516) 747-1990 File No.: 03787DVM 1 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVED INDEX NYSCEF: NO. 07/14/2022 611214/2015 IFILED: SUFEOLK COUNTY CLERK 11/14/2019 10:16 AM| NYSCEF DOC. NO 585 RECEIVED NYSCEF: 11/14/2019 TO: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola Boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 20 LU. Willets Road Albertson, New York I1507 (516) 294-5433 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 11 Smithtown, New York I1787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 i 2 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 |FILED: DOC. NYSCEF SUFFOLK NO. 911 COUNTY CLERK 83/29/2016 88:00 RECEIVEDINDEXNYSCEF: NO. 60%07/14/2022 $4/2015 J!tM| NYSCEF DOC. NO. 805 RECEIVED NYSCEF: @]/24/2010 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) COUNTY OF NASSAU )ss.: I,LAUREN LUCCHESE, being duly sworn, say: I arn not a to the am over 18 party action, years of age and reside at Suffolk County, New York: On March 29, 2016 I served the within ANSWER TO DEFENDANT TOWN OF SOUTHOLD'S CROSS-CLAIMS [x| Service by by depositing a true copy thereof in a post-paid wrapper, in an official depository under the exclusive care and oflicial depository under the Mail exclusive care and custody of the U.S. Postal Service within the New YorkState, addressedto each of the following personsat the last known address set forth after each name: I |Personal by delivering a true copy thereof personally to each person named below at the address indicated. I knew each person servedto be the person Served on mentioned and described in said papers as a partytherein: individual [ IServiceby by transmitting the papers by electronic means to the telephone number listed below, which number was designated by the attorney for such Electronie purpose. I received a signal fi·om the equipment of the attorney served indicating that the transmission was received, I alsodepositeda true Means copy of the papers, enclosed in a post-paid wrapper, in an official depository under the care and custody of the U.S. Postal Service, addressedto the attorney at the address set forth aller each name: [ I Overnight a true copy thereof, enclosed in a wrapper addressed as shown below, by depositing into the custody of UNFFED PARCEL SERVICE for overnight delivery, prior to the latest time designated by that service for overnight delivery. TO: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 250 Mineola boulevard Mineola, New York 11501 (516) 741-4170 File No.: 6230.PP LEWIS JOHS AVALLONE VILES, U,P Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York I1749 (631) 755-0101 File No.: 0114.1460.001C AHMUTY, DEMERS & McMANUS, ESQ. Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 20 I.U. Willets Road Albertson, New York I1507 (516) 294-5433 1 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVED NYSCEF: 07/14/2022 INDEX NO. 611214/2 015 FILED: SUFFOLK COUNTY CLERK 11/14 /2019 10:16 AM| NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 DEVITT, SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route I1 Smithtown, New York 11787 (631) 724-8833 SUFFOLK COUNTY ATTORNEY Attorneys for Defendant COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, New York 11788 (631) 853-4049 LAUREN LUCCHESE Sworn to before me this 29d' day of March, 2016 LESLIE GORDON Notary Public. State of New ¼rk No.01GO6028652 a Qommis n a Augu OÛ Notary Public 2 of 2 FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 FILED : SUFFOLK COUNTY CLERK 18 INDEX NO. 609082/2015 5 1 B : U NYSCEF DOC. NO. 911 RECEIVED NYSCEF: 07/14/2022 NYSCEF DOC. NO. 505 RECEIVED NYSCEF: 19/G5/2013 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK -----------------------------------------------------------------X Index No.: 609082/2015 ALICIA M. ARUNDEL, Plaintiff(s), -against- REPLY TO CROSS-CLAIM OF DEFENDANT, ROMEO STEVEN D. ROMEO, ROMEO DIMON MARINE DIMON MARINE SERVICES, INC. SERVICES, INC. CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC., Defendant(s). ________________________________________________________________Ç The defendants, CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC., by their attorneys, AHMUTY, DEMERS & McMANUS, ESQS., as and for their reply to defendant, ROMEO DIMON MARINE SERVICES, INC's cross-claim, alleges upon information and belief: AS AND FOR AN ANSWER TO A CROSS-CLAIM FIRST: Denies each and every allegation contained in paragraphs designated "20" of the cross claim. WHEREFORE, defendants, CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC., demands judgment dismissing the cross claim of the defendant, ROMEO DIMON MARINE SERVICES, INC., together with the costs and disbursements of this action. Dated: Albertson, New York October 2, 2015 Yours, etc. AHMUTY, RS McMANUS, ESQS. __ By: Neil J. Palmieri, Esq. FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVEDINDEX NYSCEF: NO. 07/14/2022 611214/2015 IFILED: SUFFOLK COUNTY CLERK 11/14 /2019 10 : 16 AM| NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 Attorneys for CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC. 200 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 Our File No.: 1BM 068515 NJP To: The Bongiorno Law Firm, PLLC Attorneys for Plaintiff 250 Mineola Boulevard Mineola, New York 11501 (516) 741-4170 File No. 6230.PP Lewis, Johs, Avallone & Aviles, LLP Attorneys for Steven D. Romeo One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No. 0114-1460-001C Cascone & Kluepfel, LLP Attorneys for Romeo Dimon Marine Services, Inc. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 (516) 747-1990 File No. 03787DVM FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVED NYSCEF: 07/14/2022 INDEX NO. 611214/2015 I FILED : SU F FOLK COUNTY CLERK 11/14 / 2 019 10 : 16 AM1 NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 STATE OF NEW YORK ) ) ss: COUNTY OF NASSAU ) TRACEY DAVIDA-HERBST, being duly sworn deposes and says that she is not a party to this action; that she isover the age of eighteen years; resides in Babylon Village, New York; 5th That on the day of October, 2015, she served the within Reply to Cross-Claim of Defendant, Romeo Dimon Marine Services, Inc. Upon: The Bongiorno Law Firm, PLLC 250 Mineola Boulevard Mineola, New York 11501 Lewis, Johs, Avallone & Aviles, LLP One CA Plaza, Suite 225 Islandia, New York 11749 Cascone & Kluepfel, LLP 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 the attorneys for the respective parties, hereto at the address designated by them for that purpose, by depositing a true copy of same enclosed in a postpaid properly addressed wrapper, in an official depository under the exclusive care and custody of the United States Post Office Department within the State of New York. TRA Y . DAV0DA- T Sworn to before me on this 5th day of October, 2015 Notary Publi CHRISTINA JEFFORDS NotaryPublic,Stateof New York No. 01RO6137142 QualiBed in NassauCoun Commission ExpiresNðv. 14, FILED: SUFFOLK COUNTY CLERK 07/14/2022 12:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 911 RECEIVED INDEX NYSCEF: NO. 07/14/2022 611214 /2 015 |FILED: SUFFOLK COUNTY CLERK 11/14 /2019 10 : 16 AM| NYSCEF DOC. NO. 585 RECEIVED NYSCEF: 11/14/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK INDEX NO. 609082/2015 ALICIA M. ARUNDEL, Plaintiff, -against- STEVEN D. ROMEO, ROMEO DIMON MARINE SERVICES, INC. CARLOS F. PINO and ULTIMATE CLASS LIMOUSINE, INC., Defendants. Reply to Cross Claim of Defendant, Romeo Dimon Marine Services, Inc. AHMUTY, DEMERS & McMANUS Attorneys for Defendants CARLOS F. PINO and ULTIMATE CLASS LIMOUSINES, INC. 200 I.U. Willets Road Albertson, New York 11507 (516) 294-5