Preview
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 958 RECEIVED NYSCEF: 09/02/2022
EXHIBIT "G"
FILED: SUFFOLK COUNTY CLERK 04/21/2022
09/02/2022 07:40
02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 864
958 RECEIVED NYSCEF: 04/21/2022
09/02/2022
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; Index No: 0611214/2015
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; STEVEN BARUCH
INDIVIDUALLY; JOELLE DIMONTE, MELISSA
A. CRAI, ARTHUR A. BELLI, JR., AS PARENT AND
NATURAL GUARDIAN OF STEPHANIE BELLI,
DECEASED AND AS ADMINISTRATOR OF THE
ESTATE OF STEPHANIE BELLI,
SUPPLEMENTAL
Plaintiffs, RESPONSE TO
INTERROGATORIES
-against- BY CABOT COACH
BUILDERS
ULTIMATE CLASS LIMOUSINE, INC., CARLOS F.
PINO, ROMEO DIMON MARINE SERVICES, INC.,
STEVEN D. ROMEO, TOWN OF SOUTHOLD,
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 remanufactures, distributors and/sellers of the
2007 Lincoln Town Car stretch limousine involved in
the collision,
Defendants.
----------------------------------------------------------------------X
The Plaintiff, Joelle DiMonte, by her attorneys, the Pegalis Law Group, LLC, hereby
Supplements her October 3, 2017, response to the defendant Cabot Coach Builders, Inc.’s,
Interrogatories to the Plaintiff, Joelle Dimonte, upon information and belief, as follows:
SUPPLEMENTAL RESPONSES TO INTERROGATORIES
18. If the answer to the preceding interrogatory is in the affirmative, please:
a. Give a complete description of those injuries plaintiff claims she would have sustained
absent that defect or defective condition;
b. Describe the injuries decedent sustained in the incident.
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FILED: SUFFOLK COUNTY CLERK 04/21/2022
09/02/2022 07:40
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NYSCEF DOC. NO. 864
958 RECEIVED NYSCEF: 04/21/2022
09/02/2022
c. Describe how the defect or defective condition resulted in the exacerbation of
the injuries from (a) to (c).
ANSWER
a. Plaintiff objects to the demand for the complete description of those injuries plaintiff
claims she would have sustained absent that defect or defective condition as said
demand is palpably improper and vague.
b. As a result of the defendant’s negligence, the plaintiff, Joelle DiMonte, was caused
to sustain severe and permanent injuries. Ms. Dimonte sustained a severe physical
traumatic injury which resulted in multiple rib fractures, a right hip sprain, a
laceration to her left elbow which required sutures (on July 18, 2015), a right elbow
sprain, a right shoulder sprain and sprains in her cervical, thoracic and lumbar spine.
As a result of the trauma, she experiences pain in her neck, mid-back, low back, right
shoulder, right elbow and right hip. Her low back pain radiates to her thighs. She
requires physical therapy for her injuries. Ms. DiMonte also sustained a significant
injury to her right eye in the form of an 8-9 mm corneal laceration. The laceration
was surgically repaired (on July 19, 2015) and stitches were put in her eye. She will
require removal of the sutures. She sustained a permanent impairment of visual
acuity in the right eye. The impairment cannot be fully corrected. As a result of the
injury, Ms. DiMonte has a 8-9 mm scar. As a result of the eye injury, Ms. DiMonte
has a developing cataract in the right eye which will worsen over time and it is
anticipated that she will need additional surgery to repair the damage. As a result of
the accident, moreover, her contact lens was propelled behind her eye and had to be
removed with surgical instruments. She has difficulty driving at night due to glare.
She will require long-term follow up care by an ophthalmologist. As a result of the
accident, moreover, Ms. Dimonte has sustained psychological and emotional injuries,
stemming from the accident and stemming from the fact that four of her friends,
including her closest friend, were killed in the accident, and other friends were
injured. She has been diagnosed with post traumatic stress disorder, increased
anxiety and depression as a result of the accident, and has required and will continue
to require mental health therapy.
The plaintiff’s injuries are both physical and psychological. Ms. Dimonte sustained
a rupture of the globe of her right eye, laceration of her right eye, fractured ribs,
sprains to her cervical, thoracic and lumbar spine, a sprained right shoulder and
elbow and a sprained right hip, a laceration of the left elbow, and profound
psychological and emotional trauma. She was hospitalized from July 18 through July
20, 2015, at Peconic Bay Medical Center. She underwent emergency eye surgery
there to treat a corneal laceration and ruptured globe in the right eye, and has come
under the care of an ophthalmologist, Dr. Daniel Hamou of East End Eye Associates.
She required an artificial lens. She has difficulty driving at night.
As a result of the penetrating injury to the right eye, she developed anisometropia
2 of 8
FILED: SUFFOLK COUNTY CLERK 04/21/2022
09/02/2022 07:40
02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 864
958 RECEIVED NYSCEF: 04/21/2022
09/02/2022
(cataract development due to significant imbalance in refraction) in the left eye, which
required the implant of an artificial lense in that eye in 2017. Since then, she has had
additional eye surgeries (most recently in February, 2020) and will require surgical correction
(and replacement of the artificial lenses) throughout her life. Since the accident, she has had
over 30 follow up visits with her ophthalmologist and will require a lifetime of constant
monitoring. As a result of the traumatic injury, she is in life-long danger of developing early
cateracts and glaucoma in the right eye.
Ms. DiMonte has required extensive physical therapy and has never overcome the results of
her physical injuries. She continues to suffer from pain in her neck, mid-back, low back,
right shoulder, right elbow and right hip. Her low back pain radiates to her thighs.
Ms. DiMonte sustained psychological and emotional injuries, stemming from the horrific
nature of the accident and from the fact that she witnessed four of her friends, including her
closest friend, killed in the accident, and three others severely injured, exacerbated by the
relentless legal and media aftermath of the accident. She has been diagnosed with post
traumatic stress disorder (PTSD) with serious anxiety and depression, is under the care of a
therapist and takes anti depressant medication. As a result of the occurrence, she suffers from
anxiety and depression, feelings of unworthiness, survivor’s guilt, nightmares, flashbacks,
panic attacks, uncontrollable sadness and fatigue.
c. Plaintiff objects to the demand for how the defect or defective condition resulted in the
exacerbation of the injuries above as said demand is palpably improper and vague.
Notwithstanding this objection, and without waiving its effect at trial , the plaintiff contends
that, due to the defective condition, the impact was made worse, and notes that the failure
of the intrusion bar contributed to the death and injury around her and thus contributed to her
psychological and emotional injuries.
Dated: Lake Success, New York
April 21, 2022
PEGALIS LAW GROUP, LLC
_________________________
By: Gary Nielsen, Esq.
Of Counsel
Attorneys for Plaintiff
Joelle Dimonte
One Hollow Lane Suite 107
Lake Success, New York 11042
516.684.2900
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NYSCEF DOC. NO. 864
958 RECEIVED NYSCEF: 04/21/2022
09/02/2022
TO: JOHN L. JULIANO, ESQ.
Attorneys for Plaintiff
Suzanne Schulman, as Administratrix
of the Estate of Brittney M. Schulman Deceased
39 Doyle Court
E. Northport, New York 11731
631.499.9300
JOSEPH J. TOCK, ESQ.
Attorney for plaintiff
Melissa A. Crai
One Mahopac Plaza
Mahopac, New York 10541
914.628.8080
BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
Alicia M. Arundel
1415 Kellum Place, Ste 205
Garden City, New York 11530
516.741.4170
SULLIVAN PAPAIN BLOCK MCGRATH
Attorneys for Plaintiff
Steven Baruch, as Administrator of the
Estate of Lauren Baruch,
and Steven Baruch Individually
1140 Franklin Avenue-ste.200
Garden City, New York 11530
516.742.0707
PARIS & CHAIKIN, PLLC
Attorneys for Plaintiff
Olga Lipets
14 Penn Plaza, Suite 2202
New York, New York 10122
212.742.0476
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09/02/2022 07:40
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NYSCEF DOC. NO. 864
958 RECEIVED NYSCEF: 04/21/2022
09/02/2022
FRANK J. LAINE, P.C.
Attorneys for Plaintiff
Mindy Grabina, as Administratrix
of the Estate of Amy Grabina,
and Mindy Grabina Individually
449 South Oyster Bay Road
Plainview, New York 11803
516.937.1010
BLOCK O'TOOLE & MURPHY, ESQS.
Attorneys for Plaintiff Arthur A. Belli, Jr.,
as Parent and Natural Guardian of Stephanie Belli,
Deceased and as Administrator of the
Estate of Stephanie Belli
One Penn Plaza, Ste 5315
New York, New York 10119
212.736.5300
BONGIORNO MONTIGLIO & PALMIERI
Attorneys for Defendants
Ultimate Class Limousine, Inc. and Carlos Pino
200 Old Country Road, Ste 680
Mineola, New York 11501
516.849.7565
CASCONE & KLUEPFEL, LLP
Attorneys for Defendant
Romeo Dimon Marine Services, Inc.
1399 Franklin Avenue, Ste 302
Garden City, New York 11530
516.747.1990
LEWIS JOHS AVALLONE AVILES
Attorneys for Defendant
Steven D. Romeo
One CA Plaza, Ste 225
Islandia, New York 11749
631.755.0101
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NYSCEF DOC. NO. 864
958 RECEIVED NYSCEF: 04/21/2022
09/02/2022
VINCENT D. MCNAMARA, ESQ.
Attorney for Defendant
County of Suffolk
1045 Oyster Bay Rd, Suite 1
East Norwich, New York 11732
516.922.9100
THOMAS M. VOLZ, PLLC
Attorneys for Defendant
Town of Southold
280 Smithtown Blvd.
Nesconset, New York 11767
631.366.2700
LAW OFFICE OF ANDREA G. SAWYERS
Attorneys for Defendant
Cabot Coach Builders, Inc., d/b/a Royale Limousine
3 Huntington Quadrangle, Suite 102S
Melville, New York 11747
631.501.3100
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NYSCEF DOC. NO. 864
958 RECEIVED NYSCEF: 04/21/2022
09/02/2022
ATTORNEY’S VERIFICATION
Gary Nielsen, Esq, an attorney duly admitted under the laws of the State of New York,
affirms under the penalties of perjury, pursuant toCPLR 2106:
1. I am of counsel to the Pegalis Law Group, LLC, the attorneys for the plaintiff, Joelle
DiMonte.
2. I have read the foregoing Response to Interrogatories and know its contents. The same
is true to my knowledge, except to those matters herein stated to be alleged on information and
belief, and as to those matters I believe it to be true.
3. The reason this verification is made by me and not by Ms. DiMonte is that the plaintiff
does not reside in the county in which I have my office.
4. The grounds of my belief as to all matters not stated upon my own knowledge are
conversations with the plaintiff and a review of relevant records.
______________________
Gary Nielsen, Esq.
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FILED: SUFFOLK COUNTY CLERK 04/21/2022
09/02/2022 07:40
02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 864
958 RECEIVED NYSCEF: 04/21/2022
09/02/2022
RIDER TO INTERROGATORIES
Dimonte v. Ultimate Class Limousine, Inc., et.al.
Index No.: 603536/2016
April 21, 2022
PROVIDER COST INSURANCE PAID BY CLIENT
Peconic Bay Medical Center * * *
1300 Roanoke Avenue
Riverhead, NY 11901
Dr. Steven Wishner * * *
Huntington Medical Group
180 East Pulaski Road
Huntington Station, NY 11746
Dr. Susanna Cooperman * * *
Huntington Medical Group
180 East Pulaski Road
Huntington Station, NY 11746
Daniel Hamou, MD * * *
Eric Vinokur, MD
East End Eye Associates
937 East Main Street
Riverhead, NY 11901
Lino Chuang * * *
Excellent Choice
Physical Therapy, P.C.
180 East Pulaski Road
Huntington Station, NY 11746
* Based on currently available information. All amounts recited are subject to revision. The plaintiff
reserves the right to update the response as further information becomes available.
8 of 8
Preview
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 958 RECEIVED NYSCEF: 09/02/2022 EXHIBIT "G" FILED: SUFFOLK COUNTY CLERK 04/21/2022 09/02/2022 07:40 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 864 958 RECEIVED NYSCEF: 04/21/2022 09/02/2022 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; Index No: 0611214/2015 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; STEVEN BARUCH INDIVIDUALLY; JOELLE DIMONTE, MELISSA A. CRAI, ARTHUR A. BELLI, JR., AS PARENT AND NATURAL GUARDIAN OF STEPHANIE BELLI, DECEASED AND AS ADMINISTRATOR OF THE ESTATE OF STEPHANIE BELLI, SUPPLEMENTAL Plaintiffs, RESPONSE TO INTERROGATORIES -against- BY CABOT COACH BUILDERS ULTIMATE CLASS LIMOUSINE, INC., CARLOS F. PINO, ROMEO DIMON MARINE SERVICES, INC., STEVEN D. ROMEO, TOWN OF SOUTHOLD, 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 remanufactures, distributors and/sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. ----------------------------------------------------------------------X The Plaintiff, Joelle DiMonte, by her attorneys, the Pegalis Law Group, LLC, hereby Supplements her October 3, 2017, response to the defendant Cabot Coach Builders, Inc.’s, Interrogatories to the Plaintiff, Joelle Dimonte, upon information and belief, as follows: SUPPLEMENTAL RESPONSES TO INTERROGATORIES 18. If the answer to the preceding interrogatory is in the affirmative, please: a. Give a complete description of those injuries plaintiff claims she would have sustained absent that defect or defective condition; b. Describe the injuries decedent sustained in the incident. 1 of 8 FILED: SUFFOLK COUNTY CLERK 04/21/2022 09/02/2022 07:40 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 864 958 RECEIVED NYSCEF: 04/21/2022 09/02/2022 c. Describe how the defect or defective condition resulted in the exacerbation of the injuries from (a) to (c). ANSWER a. Plaintiff objects to the demand for the complete description of those injuries plaintiff claims she would have sustained absent that defect or defective condition as said demand is palpably improper and vague. b. As a result of the defendant’s negligence, the plaintiff, Joelle DiMonte, was caused to sustain severe and permanent injuries. Ms. Dimonte sustained a severe physical traumatic injury which resulted in multiple rib fractures, a right hip sprain, a laceration to her left elbow which required sutures (on July 18, 2015), a right elbow sprain, a right shoulder sprain and sprains in her cervical, thoracic and lumbar spine. As a result of the trauma, she experiences pain in her neck, mid-back, low back, right shoulder, right elbow and right hip. Her low back pain radiates to her thighs. She requires physical therapy for her injuries. Ms. DiMonte also sustained a significant injury to her right eye in the form of an 8-9 mm corneal laceration. The laceration was surgically repaired (on July 19, 2015) and stitches were put in her eye. She will require removal of the sutures. She sustained a permanent impairment of visual acuity in the right eye. The impairment cannot be fully corrected. As a result of the injury, Ms. DiMonte has a 8-9 mm scar. As a result of the eye injury, Ms. DiMonte has a developing cataract in the right eye which will worsen over time and it is anticipated that she will need additional surgery to repair the damage. As a result of the accident, moreover, her contact lens was propelled behind her eye and had to be removed with surgical instruments. She has difficulty driving at night due to glare. She will require long-term follow up care by an ophthalmologist. As a result of the accident, moreover, Ms. Dimonte has sustained psychological and emotional injuries, stemming from the accident and stemming from the fact that four of her friends, including her closest friend, were killed in the accident, and other friends were injured. She has been diagnosed with post traumatic stress disorder, increased anxiety and depression as a result of the accident, and has required and will continue to require mental health therapy. The plaintiff’s injuries are both physical and psychological. Ms. Dimonte sustained a rupture of the globe of her right eye, laceration of her right eye, fractured ribs, sprains to her cervical, thoracic and lumbar spine, a sprained right shoulder and elbow and a sprained right hip, a laceration of the left elbow, and profound psychological and emotional trauma. She was hospitalized from July 18 through July 20, 2015, at Peconic Bay Medical Center. She underwent emergency eye surgery there to treat a corneal laceration and ruptured globe in the right eye, and has come under the care of an ophthalmologist, Dr. Daniel Hamou of East End Eye Associates. She required an artificial lens. She has difficulty driving at night. As a result of the penetrating injury to the right eye, she developed anisometropia 2 of 8 FILED: SUFFOLK COUNTY CLERK 04/21/2022 09/02/2022 07:40 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 864 958 RECEIVED NYSCEF: 04/21/2022 09/02/2022 (cataract development due to significant imbalance in refraction) in the left eye, which required the implant of an artificial lense in that eye in 2017. Since then, she has had additional eye surgeries (most recently in February, 2020) and will require surgical correction (and replacement of the artificial lenses) throughout her life. Since the accident, she has had over 30 follow up visits with her ophthalmologist and will require a lifetime of constant monitoring. As a result of the traumatic injury, she is in life-long danger of developing early cateracts and glaucoma in the right eye. Ms. DiMonte has required extensive physical therapy and has never overcome the results of her physical injuries. She continues to suffer from pain in her neck, mid-back, low back, right shoulder, right elbow and right hip. Her low back pain radiates to her thighs. Ms. DiMonte sustained psychological and emotional injuries, stemming from the horrific nature of the accident and from the fact that she witnessed four of her friends, including her closest friend, killed in the accident, and three others severely injured, exacerbated by the relentless legal and media aftermath of the accident. She has been diagnosed with post traumatic stress disorder (PTSD) with serious anxiety and depression, is under the care of a therapist and takes anti depressant medication. As a result of the occurrence, she suffers from anxiety and depression, feelings of unworthiness, survivor’s guilt, nightmares, flashbacks, panic attacks, uncontrollable sadness and fatigue. c. Plaintiff objects to the demand for how the defect or defective condition resulted in the exacerbation of the injuries above as said demand is palpably improper and vague. Notwithstanding this objection, and without waiving its effect at trial , the plaintiff contends that, due to the defective condition, the impact was made worse, and notes that the failure of the intrusion bar contributed to the death and injury around her and thus contributed to her psychological and emotional injuries. Dated: Lake Success, New York April 21, 2022 PEGALIS LAW GROUP, LLC _________________________ By: Gary Nielsen, Esq. Of Counsel Attorneys for Plaintiff Joelle Dimonte One Hollow Lane Suite 107 Lake Success, New York 11042 516.684.2900 3 of 8 FILED: SUFFOLK COUNTY CLERK 04/21/2022 09/02/2022 07:40 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 864 958 RECEIVED NYSCEF: 04/21/2022 09/02/2022 TO: JOHN L. JULIANO, ESQ. Attorneys for Plaintiff Suzanne Schulman, as Administratrix of the Estate of Brittney M. Schulman Deceased 39 Doyle Court E. Northport, New York 11731 631.499.9300 JOSEPH J. TOCK, ESQ. Attorney for plaintiff Melissa A. Crai One Mahopac Plaza Mahopac, New York 10541 914.628.8080 BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff Alicia M. Arundel 1415 Kellum Place, Ste 205 Garden City, New York 11530 516.741.4170 SULLIVAN PAPAIN BLOCK MCGRATH Attorneys for Plaintiff Steven Baruch, as Administrator of the Estate of Lauren Baruch, and Steven Baruch Individually 1140 Franklin Avenue-ste.200 Garden City, New York 11530 516.742.0707 PARIS & CHAIKIN, PLLC Attorneys for Plaintiff Olga Lipets 14 Penn Plaza, Suite 2202 New York, New York 10122 212.742.0476 4 of 8 FILED: SUFFOLK COUNTY CLERK 04/21/2022 09/02/2022 07:40 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 864 958 RECEIVED NYSCEF: 04/21/2022 09/02/2022 FRANK J. LAINE, P.C. Attorneys for Plaintiff Mindy Grabina, as Administratrix of the Estate of Amy Grabina, and Mindy Grabina Individually 449 South Oyster Bay Road Plainview, New York 11803 516.937.1010 BLOCK O'TOOLE & MURPHY, ESQS. Attorneys for Plaintiff Arthur A. Belli, Jr., as Parent and Natural Guardian of Stephanie Belli, Deceased and as Administrator of the Estate of Stephanie Belli One Penn Plaza, Ste 5315 New York, New York 10119 212.736.5300 BONGIORNO MONTIGLIO & PALMIERI Attorneys for Defendants Ultimate Class Limousine, Inc. and Carlos Pino 200 Old Country Road, Ste 680 Mineola, New York 11501 516.849.7565 CASCONE & KLUEPFEL, LLP Attorneys for Defendant Romeo Dimon Marine Services, Inc. 1399 Franklin Avenue, Ste 302 Garden City, New York 11530 516.747.1990 LEWIS JOHS AVALLONE AVILES Attorneys for Defendant Steven D. Romeo One CA Plaza, Ste 225 Islandia, New York 11749 631.755.0101 5 of 8 FILED: SUFFOLK COUNTY CLERK 04/21/2022 09/02/2022 07:40 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 864 958 RECEIVED NYSCEF: 04/21/2022 09/02/2022 VINCENT D. MCNAMARA, ESQ. Attorney for Defendant County of Suffolk 1045 Oyster Bay Rd, Suite 1 East Norwich, New York 11732 516.922.9100 THOMAS M. VOLZ, PLLC Attorneys for Defendant Town of Southold 280 Smithtown Blvd. Nesconset, New York 11767 631.366.2700 LAW OFFICE OF ANDREA G. SAWYERS Attorneys for Defendant Cabot Coach Builders, Inc., d/b/a Royale Limousine 3 Huntington Quadrangle, Suite 102S Melville, New York 11747 631.501.3100 6 of 8 FILED: SUFFOLK COUNTY CLERK 04/21/2022 09/02/2022 07:40 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 864 958 RECEIVED NYSCEF: 04/21/2022 09/02/2022 ATTORNEY’S VERIFICATION Gary Nielsen, Esq, an attorney duly admitted under the laws of the State of New York, affirms under the penalties of perjury, pursuant toCPLR 2106: 1. I am of counsel to the Pegalis Law Group, LLC, the attorneys for the plaintiff, Joelle DiMonte. 2. I have read the foregoing Response to Interrogatories and know its contents. The same is true to my knowledge, except to those matters herein stated to be alleged on information and belief, and as to those matters I believe it to be true. 3. The reason this verification is made by me and not by Ms. DiMonte is that the plaintiff does not reside in the county in which I have my office. 4. The grounds of my belief as to all matters not stated upon my own knowledge are conversations with the plaintiff and a review of relevant records. ______________________ Gary Nielsen, Esq. 7 of 8 FILED: SUFFOLK COUNTY CLERK 04/21/2022 09/02/2022 07:40 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 864 958 RECEIVED NYSCEF: 04/21/2022 09/02/2022 RIDER TO INTERROGATORIES Dimonte v. Ultimate Class Limousine, Inc., et.al. Index No.: 603536/2016 April 21, 2022 PROVIDER COST INSURANCE PAID BY CLIENT Peconic Bay Medical Center * * * 1300 Roanoke Avenue Riverhead, NY 11901 Dr. Steven Wishner * * * Huntington Medical Group 180 East Pulaski Road Huntington Station, NY 11746 Dr. Susanna Cooperman * * * Huntington Medical Group 180 East Pulaski Road Huntington Station, NY 11746 Daniel Hamou, MD * * * Eric Vinokur, MD East End Eye Associates 937 East Main Street Riverhead, NY 11901 Lino Chuang * * * Excellent Choice Physical Therapy, P.C. 180 East Pulaski Road Huntington Station, NY 11746 * Based on currently available information. All amounts recited are subject to revision. The plaintiff reserves the right to update the response as further information becomes available. 8 of 8