On October 21, 2015 a
Party Notice
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 08/04/2022 01:13 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 932 RECEIVED NYSCEF: 08/04/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
_____-_____________________________________________________________Ç
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 -
NOTICE PURSUANT TO
C.P.L.R §3101d
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
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.
________________________________________________________________________Ç
SIRS:
PLEASE BE ADVISED that, the plaintiff, MELISSA CRAI intends to call R. Joy Bergins,
LMSW as an expert witness at the time of trialin this matter.
R. Joy Bergins, LMSW received a Bachelor of Arts degree in Sociology and Psychology from
Boston University. She received her Medication-Assisted Treatment (M.A.T.) Certificate and
license from Manhattanville College in 1975. She obtained her degree for Master of Social Work
in 1981 and obtained her licensor as a Licensed Master Social Worker (LMSW) from Fordham
University School of Social Work in 1988.
R. Joy Bergins. LMSW is a member of the following professional organizations:
National Association of Social Workers;
American Society of Clinical Hypnosis;
New York Society of Clinical Hypnosis; and
Delta Kappa Gamma - Educational Sorority.
LAw OFFICES OF JOSEPH J. TOCK " 963 ROUTE 6, MAHOPAC, NEWYORK 10541
1 of 3
FILED: SUFFOLK COUNTY CLERK 08/04/2022 01:13 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 932 RECEIVED NYSCEF: 08/04/2022
R. Joy Bergins, LMSW has been specializing in Psychotherapy and Hypnosis and has been in
private practice from 1983 through present.
R. Joy Bergins, LMSW is expected to testify to the history and nature of the injuries sustained by
the plaintiff, MELISSA CRAI.
R. Joy Bergins, LMSW will state within a reasonable degree of psychological certainty that the
trauma from the motor vehicle accident of July 18, 2015 was the competent producing cause of
Melissa Crai's Post Traumatic Stress Disorder, Adjustment Disorder with Anxiety and
Depression resulting in a permanent psychological condition; and the trauma from the motor
vehicle accident has resulted in psychological reactions when she is exposed to triggering events,
extreme sorrow, grief, crying episodes, overwhelming guilt, upsetting dreams, relationship
issues, anxiety, depression, restlessness, survivors guilt, fear of driving, nightmares, flashbacks,
feelings of unworthiness, hyper-vigilant behaviors, panic attacks, fatigue and fear related to and
avoidance of the use of any limousine, allof which are permanent and which will significantly
limit and affect certain activities in Melissa's life.
A copy of the curriculum vitae {attached hereto as Exhibit A} and narrative report {attached
hereto as Exhibit B} from R. Joy Bergins, LMSW are attached hereto.
Dated: Mahopac, New York
August 4, 2022 Yours, etc.,
JOSEPH J. TOCK, ESQ.
Attorney for the Plaintiff:
Melissa Crai
963 Route 6
Mahopac, NY 10541
845-628-8080
TO: All via NYCEF e-filing only
LAW OFFICES OF JOSEPH J. TOCK " 963 ROUTE 6, MAHOPAC, NEW YORK 10541
2 of 3
FILED: SUFFOLK COUNTY CLERK 08/04/2022 01:13 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 932 RECEIVED NYSCEF: 08/04/2022
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 BELL1,
Plaintiff(s)
-against-
ULTIMATE CLASS LIMOUSINE INC.,CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC.,STEVEN ROMEO, TOWN OF SOUTHOLD,
1-5"
COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC.,d/b/aROYALE LIMOUSINE and "XYZ COMPANIES name being fictitious
but
intendedto be the remanufacturers, and/or
distributors, sellersof the 2007LincolnTown Car stretch
limousine involvedin the collision,
Defendants(s).
NOTICE PURSUANT TO C.P.L.R. §3101 d
Law Officesof
Joseph J. Tock
Attorney for Plaintiff(Cral)
963 Route 6
Mahopac, NY 10541
(845)628 - 8080
Pursuant to 22 NYCRR 130.1.1,the undersigned,an attorney admittedto practiceinthecourts of New York State,certifies
that,upon
information and beliefand reasonable inquiry,thecontentionscontained in theannexed document are not frivolous.
Dated:......................................... ......................................................................................
PrintSigner's Name: .....................................................................................
Service ofa copy of thewithin is herebyadmitted.
Dated:
Attorney (s)for
PLEASE TAKE NOTICE
thatthe within true
is a (certified) cony of a
entered in theofficeof theclerkof thewithin named Court on
thatan Order of whichthe within is a true
copy willbe presented forsettlementto theNon.
one of the
of the judges within named Court,
at
on 20 , at M.
Dated:
Law Officesof
Joseph J. Tock
Attorney for Plaintiff
963 Route 6
Mahopac, NY 10541
(845) 628- 8080
3 of 3
Preview
FILED: SUFFOLK COUNTY CLERK 08/04/2022 01:13 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 932 RECEIVED NYSCEF: 08/04/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK _____-_____________________________________________________________Ç 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 - NOTICE PURSUANT TO C.P.L.R §3101d 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 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. ________________________________________________________________________Ç SIRS: PLEASE BE ADVISED that, the plaintiff, MELISSA CRAI intends to call R. Joy Bergins, LMSW as an expert witness at the time of trialin this matter. R. Joy Bergins, LMSW received a Bachelor of Arts degree in Sociology and Psychology from Boston University. She received her Medication-Assisted Treatment (M.A.T.) Certificate and license from Manhattanville College in 1975. She obtained her degree for Master of Social Work in 1981 and obtained her licensor as a Licensed Master Social Worker (LMSW) from Fordham University School of Social Work in 1988. R. Joy Bergins. LMSW is a member of the following professional organizations: National Association of Social Workers; American Society of Clinical Hypnosis; New York Society of Clinical Hypnosis; and Delta Kappa Gamma - Educational Sorority. LAw OFFICES OF JOSEPH J. TOCK " 963 ROUTE 6, MAHOPAC, NEWYORK 10541 1 of 3 FILED: SUFFOLK COUNTY CLERK 08/04/2022 01:13 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 932 RECEIVED NYSCEF: 08/04/2022 R. Joy Bergins, LMSW has been specializing in Psychotherapy and Hypnosis and has been in private practice from 1983 through present. R. Joy Bergins, LMSW is expected to testify to the history and nature of the injuries sustained by the plaintiff, MELISSA CRAI. R. Joy Bergins, LMSW will state within a reasonable degree of psychological certainty that the trauma from the motor vehicle accident of July 18, 2015 was the competent producing cause of Melissa Crai's Post Traumatic Stress Disorder, Adjustment Disorder with Anxiety and Depression resulting in a permanent psychological condition; and the trauma from the motor vehicle accident has resulted in psychological reactions when she is exposed to triggering events, extreme sorrow, grief, crying episodes, overwhelming guilt, upsetting dreams, relationship issues, anxiety, depression, restlessness, survivors guilt, fear of driving, nightmares, flashbacks, feelings of unworthiness, hyper-vigilant behaviors, panic attacks, fatigue and fear related to and avoidance of the use of any limousine, allof which are permanent and which will significantly limit and affect certain activities in Melissa's life. A copy of the curriculum vitae {attached hereto as Exhibit A} and narrative report {attached hereto as Exhibit B} from R. Joy Bergins, LMSW are attached hereto. Dated: Mahopac, New York August 4, 2022 Yours, etc., JOSEPH J. TOCK, ESQ. Attorney for the Plaintiff: Melissa Crai 963 Route 6 Mahopac, NY 10541 845-628-8080 TO: All via NYCEF e-filing only LAW OFFICES OF JOSEPH J. TOCK " 963 ROUTE 6, MAHOPAC, NEW YORK 10541 2 of 3 FILED: SUFFOLK COUNTY CLERK 08/04/2022 01:13 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 932 RECEIVED NYSCEF: 08/04/2022 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 BELL1, Plaintiff(s) -against- ULTIMATE CLASS LIMOUSINE INC.,CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC.,STEVEN ROMEO, TOWN OF SOUTHOLD, 1-5" COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC.,d/b/aROYALE LIMOUSINE and "XYZ COMPANIES name being fictitious but intendedto be the remanufacturers, and/or distributors, sellersof the 2007LincolnTown Car stretch limousine involvedin the collision, Defendants(s). NOTICE PURSUANT TO C.P.L.R. §3101 d Law Officesof Joseph J. Tock Attorney for Plaintiff(Cral) 963 Route 6 Mahopac, NY 10541 (845)628 - 8080 Pursuant to 22 NYCRR 130.1.1,the undersigned,an attorney admittedto practiceinthecourts of New York State,certifies that,upon information and beliefand reasonable inquiry,thecontentionscontained in theannexed document are not frivolous. Dated:......................................... ...................................................................................... PrintSigner's Name: ..................................................................................... Service ofa copy of thewithin is herebyadmitted. Dated: Attorney (s)for PLEASE TAKE NOTICE thatthe within true is a (certified) cony of a entered in theofficeof theclerkof thewithin named Court on thatan Order of whichthe within is a true copy willbe presented forsettlementto theNon. one of the of the judges within named Court, at on 20 , at M. Dated: Law Officesof Joseph J. Tock Attorney for Plaintiff 963 Route 6 Mahopac, NY 10541 (845) 628- 8080 3 of 3