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  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY GRABINA, INDIVIDUALLY,, Steven Baruch A/O/E 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 E/O STEPHANIE BELLI v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, Inc., Steven D Romeo, Town Of Southold, County Of Suffolk, Cabot Coach Builders, Inc D/B/A Royale Limousine, 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, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY GRABINA, INDIVIDUALLY,, Steven Baruch A/O/E 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 E/O STEPHANIE BELLI v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, Inc., Steven D Romeo, Town Of Southold, County Of Suffolk, Cabot Coach Builders, Inc D/B/A Royale Limousine, 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, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY GRABINA, INDIVIDUALLY,, Steven Baruch A/O/E 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 E/O STEPHANIE BELLI v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, Inc., Steven D Romeo, Town Of Southold, County Of Suffolk, Cabot Coach Builders, Inc D/B/A Royale Limousine, 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, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY GRABINA, INDIVIDUALLY,, Steven Baruch A/O/E 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 E/O STEPHANIE BELLI v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, Inc., Steven D Romeo, Town Of Southold, County Of Suffolk, Cabot Coach Builders, Inc D/B/A Royale Limousine, 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, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY GRABINA, INDIVIDUALLY,, Steven Baruch A/O/E 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 E/O STEPHANIE BELLI v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, Inc., Steven D Romeo, Town Of Southold, County Of Suffolk, Cabot Coach Builders, Inc D/B/A Royale Limousine, 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, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY GRABINA, INDIVIDUALLY,, Steven Baruch A/O/E 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 E/O STEPHANIE BELLI v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, Inc., Steven D Romeo, Town Of Southold, County Of Suffolk, Cabot Coach Builders, Inc D/B/A Royale Limousine, 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, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY GRABINA, INDIVIDUALLY,, Steven Baruch A/O/E 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 E/O STEPHANIE BELLI v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, Inc., Steven D Romeo, Town Of Southold, County Of Suffolk, Cabot Coach Builders, Inc D/B/A Royale Limousine, 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, Tort document preview
  • Suzanne Schulman as Administratrix of the Estate of Brittney M. Schulman, Deceased, Alicia M Arundel, Olga Lipets, Mindy Grabina A/O/E AMY GRABINA, AND MINDY GRABINA, INDIVIDUALLY,, Steven Baruch A/O/E 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 E/O STEPHANIE BELLI v. Ultimate Class Limousine, Inc., Carlos F Pino, Romeo Dimon Marine Service, Inc., Steven D Romeo, Town Of Southold, County Of Suffolk, Cabot Coach Builders, Inc D/B/A Royale Limousine, 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, Tort document preview
						
                                

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FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 EXHIBIT E FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 SUPREME COURT OF THE S'fATE OF NEW YORK \j jii COUNTY OF SUFFOLK. ---------------------------------------------------------------------------)( SUZANNE SCHULMAN, as Administratrix of the Index #: 611214/15 ESTATE OF BRITTANY SCHULMAN, deceased, Plaintiff, -against- RESPONSE TO NOTICE TO ADMIT ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, Defendants . .................. " . , . . .., ---------------------------------------------------------------------------)( The defendant, County of Suffolk, by it attorney, DENNIS M. BROWN, Suffclk County Attorney, Christopher A. Jeffreys, Assistant County Attorney, as and for its response to the plaintiffs Notice to Admit dated October 24,2016, alleges the following, upon information and belief: 1, Admit. 2. Deny, 3. Denies the allegations in this paragraph, except admits that the County ofSufl(llk performed road maintenance on County Road 48 prior to July 18,2015. 4. Admit. 5. Deny, 6. Admit. 7. Deny, FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 8. The defendant can neither admit nor deny this paragraph as it is presently phrased. '1'he County of Suffolk performed paving of County Road 48 at or about its intersection with Depot Lane prior to July 18, 20 I 5. ~gQ response to paragraphs 11 and 17. 9. Denies the allegations in this paragraph, except admits that the County of Suffulk performed road repairs on County Road 48 prior to July 18,2015. 10. Deny. II. Denies the allegations in this paragraph, except admits that the County of Suffolk performed road repairs on County Road 48 at or about its intersection with Depot Lane prior to July 18,2015. 12; Denies ,the al legatiol1si n' this paragraph, 'cxcept admits that the County 0 f Suffolk' performed road inspections of County Road 48 prior to July 18, 20 I 5. 13. Denies the allegations in this paragraph, except admits that the County of Suffolk peri()rmed road inspections of Depot Lane for the purposes of traffic studies prior to July 18,2015. 14. Denies the allegations in this paragraph, except admits that the County of Suffolk performed road inspections of County Road 48 at or about its intersection with Depot Lane prior to July 18,2015. 15. Denies the allegations in this paragraph, except admits that the County of Suffolk performed paving of County Road 48 prior to July 18, 2015. 16. Deny. 17. Denies the allegations in this paragraph, except admits that the County of Suffolk performed paving of County Road 48 at or about its intersection with Depot Lane prior to July 18,2015. 2 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 18. Denies the allegations in this paragraph, except admits that the County of Suffolk made reasoned and discretionary determinations concerning the placement of tranic signage on County Road 48 prim' to July 18,2015. 19. Denies the allegations in this paragraph, except admits that the County of Suffolk made reasoned and discretionary determinations concerning the placement of traffic signage on Depot Lane at its intersection with County Road 48 prior to July 18,2015. 20. Denies the allegations in this paragraph, except admits that the County of Suffolk made· reasoned and discretionary determinations concerning the placement of traffic signage on County Road 48 prior to July 18,201 S. . .. ..... 21: Denies-the-allegati onsinthis-paragraph, except· admi tsthattheConnty'OfSulTolkpl aced or directed to be placed traffic signage on County Road 48 at or about its intersection with Depot Lane prior to July 18, 2015. 22. Denies the allegations in this paragraph, except admits that the County of Suffolk made reasoned and discretionary determinations concerning the placement of traffic signals on County Road 48 prior to July 18, 201 S. 23. Denies the allegations in this paragraph, except admits that the County of Suffolk made reasoned and discretionary determinations concerning the placement of traffic Jignals on Depot Lane prior to July 18, 2015. 24. Denies the allegations in this paragraph, except admits that the County of Suffolk made reasoned and discretionary determinations concerning the placement of traffic signals on County Road 48 at or about its intersection with Depot Lane prior to July 18,201 S. 3 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 25, Denies the allegations in this paragraph, except admits that there was no red/amber/green traffic signal controlling the intersection of County Road 48 at or about its intersection with Depot Lane prior to July 18,2015, 26, Denies the allegations in this paragraph, except admits that the County of Suffolk made reasoned and discretionary determinations concerning the road design of County Road 48 prior to July 18,2015, 27, Deny, 28, Denies the allegations in this paragraph, except admits that the County of Suffolk made reasoned and discretionary determinations concerning the road dcsign of County Road 48 -ut-or-ubout its in lersecliol1withBepotLanepri ortoJuly-18; 2015, 29, Admit. 30, Admit. DATED: Hauppauge, New York November 4, 2016 DENNIS M, BROWN Suffolk County Attorney Attorney for Defendant, County 1-1,Lee Dennison Building 100 Veterans Memorial Highway P,O, Box 6100 Hauppauge, NY 11788-0099 631-853,t 5 0 .51 ~ <-I>tJ?_­ (j;-~The ~t.JfeyS -- Asi@Pt~ouny Attorney TO: JOHN L. JULIANO P,C, Attorney for Plaintiff, Schulman 39 Doyle Court East NOlihport, NY 11731 (631) 499-9300 4 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 AHMUTY DEMERS & McMANUS Attorney for Defendant, Ultimate Class Limo and Pino 200 l. U. Willets Road Albertson, New York 11507 (516) 294-5433 LEWIS JOHS AVALLONE AVILES LLP Attorney for Defendant, Romeo One CA Plaza Suite 225 Islandia, NY 11749 (631) 755-0101 CASCONE & KLUEPFEL LLP Attorneys for defendant, Romeo Dimon Marine Service, Inc. 1399 Franklin Avenue, Suite 302 ..................... Ga:nJenCity;NewYarlcl1··:l30···· (516) 747-1990 DEVITT SPELLMAN & BARRETT LLP Attorney for Defendant, Town of Southold 50 Route 111 Smithtown, NY 11788 (631) 724-8833 Courtesy Copies Sent To: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff, Arundel 1415 Kellum Place, Suite 205 Garden City, New York 11530 516-741-4170 SULLIVAN PAPAIN BLOCK McGRATH & CANNAVO P.C. Attorneys for Plaintiff, Baruch 1140 Franklin Avenue, Suite 200 Garden City, NY 11530 516-742-0707 5 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 STATE OF NEW YORK: COUNTY OF SUFFOLK Christopher A. Jeffreys, Esq., an attorney admitted to practice in the Courts of the State of New York, affirms that the following statements are true under penalties of peljury: Deponent is an Assistant County Attorney for the County of Suffolk, and as such, make this verification pursuant to CPLR § 3020(d)(2). Deponent has read the foregoing Response to Notice to Admit, knows the contents thereof, and that the same is true to deponent's own knowledge, except as to the matters therein stated to be alleged upon information and belief, and The grounds of deponent's belief as to all matters not stated upon deponent's knowledge are as follows: statements of the defendant, office records, and deponent's general investigation into the facts of this case. DATED: Hauppauge, New York November 4, 2016 Assistant County Attorney 7 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 Index No. 61 1214/20 15 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK SUZANNE SCHULMAN, AS ADMIN ISTRATRJX OF THE ESTATE OF BRITTNEY M. SCHULMAN, DECEASED, Plaintiff, -against- ULTIMATE CLASS LI MOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERV ICE, INC., STEVEN ROMEO, TOWN or SOUTHOLD and COUNTY OF SUFFOLK, Defendants. RESPONSE TO NOTICE TO ADI (lIT Dennis M. Brown Suffo lk County Attorney By: Christop her A. Jeffreys Assistant County Attorney Attorney fo r Defendant County of Suffo lk H. Lee Dennison Building 100 Veterans Memorial Highway P.O. Box 6 100 Hauppauge, New York 11 788-0099 (63 1) 853-4049 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 SUPREME COURT OF THE STATE OF NEW YORK m 1 20 COUNTY OF SUFFOLK ------..--------------------------------------..Ç SUZANNE SCHULMAN, AS ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M. SCHULMAN, DECEASED, Index No.: 611214/15 Plaintiff, NOTICE TO ADMIT (E-FILE CASE) -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, Defendants. ------------------------------------------------------X TO: Defendant, COUNTY OF SUFFOLK: Pursuant to the Civil Practice Law and Rules § 3123 and within twenty (20) days after service of this notice, the Plaintiff, SUZANNE SCHULMAN, AS ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M. SCHULMAN, DECEASED, hereby requests you to admit, for purposes of this action only and subject to all pertinent objections to admissibility which may be interposed at the time of trial,the truth of the following matters of fact: 1. That the defendant, COUNTY OF SUFFOLK, was the owner of CR 48, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 2. That the defendant, COUNTY OF SUFFOLK, was the owner of Depot Lane, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 3. That the defendant, COUNTY OF SUFFOLK, its agents servants and employees, performed road maintenance and/or maintained CR 48, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 1 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 . . . . 4. That the defendant, COUNTY OF SUFFOLK, managed, supervised and/or controlled CR 48, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 5. That the defendant, COUNTY OF SUFFOLK, managed, supervised and/or controlled Depot Lane, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 6. That the defendant, COUNTY OF SUFFOLK, managed, supervised and/or controlled CR 48 at or about its intersection with of Depot Lane, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 7. That the defendant, COUNTY OF SUFFOLK, itsagents servants and employees, performed road maintenance and/or maintained Depot Lane, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 8. That the defendant, COUNTY OF SUFFOLK, itsagents servants and employees, performed road maintenance and maintained CR 48 at or about its intersection with of Depot Lane, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 9. That the defendant, COUNTY OF SUFFOLK, itsagents servants and employees, performed road repairs, necessary or otherwise, on CR 48 Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 10. That the defendant, COUNTY OF SUFFOLK, itsagents servants and employees, performed road repairs, necessary or otherwise, on Depot Lane, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 11. That the defendant, COUNTY OF SUFFOLK, itsagents servants and employees, performed road repairs, necessary or otherwise, on CR 48 at or about itsintersection with of 2 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 Depot Lane, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 12. That the defendant, COUNTY OF SUFFOLK, its agents servants and employees, performed road inspections of CR 48 Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 13. That the defendant, COUNTY OF SUFFOLK, its agents servants and employees, performed road inspections of Depot Lane Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 14. That the defendant, COUNTY OF SUFFOLK, its agents servants and employees, performed road inspections on CR 48 at or about itsintersection with of Depot Lane, Town of Southold County of Suffolk State of New York prior to and on July 18, 2015. 15. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees, performed paying of CR 48, Town of Southold County of Suffolk State of New York. 16. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees, performed paying of Depot Lane, Town of Southold County of Suffolk State of New York. 17. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees, performed paying of CR 48 at or about its intersection with of Depot Lane, Town of Southold County of Suffolk State of New York. 18. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the placement traffic signage on CR 48 Town of Southold County of Suffolk State of New York. 3 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 . 19. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the placement traffic signage on Depot Lane, Town of Southold County of Suffolk State of New York. 20. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the placement traffic signage on CR 48 at or about its intersection with of Depot Lane, Town of Southold County of Suffolk State of New York. 21. That the defendant, COUNTY OF SUFFOLK, its agents servants and employees, placed or directed to be placed traffic signage on CR 48 ator about itsintersection with of Depot Lane, Town of Southold County of Suffolk State of New York on or before July 18, 2015. 22. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the placement of traffic signals on CR 48 Town of Southold County of Suffolk State of New York. 23. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the placement of traffic signals on Depot Lane, Town of Southold County of Suffolk State of New York. 24. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the placement of traffic signals on CR 48 at or about its intersection with of Depot Lane, Town of Southold County of Suffolk State of New York. 4 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 25. That on or before July 18, 2015, there was no traffic signal controlling traffic at the intersection of CR 48 at or about itsintersection with of Depot Lane, Town of Southold County of Suffolk State of New York. 26. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the road design of CR 48 Town of Southold County of Suffolk State of New York. 27. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the road design of Depot Lane, Town of Southold County of Suffolk State of New York. 28. That on or before July 18, 2015, the defendant, COUNTY OF SUFFOLK, its agents servants and employees was responsible for and/or made decisions concerning the road design of CR 48 at or about its intersection with of Depot Lane, Town of Southold County of Suffolk State of New York. 29. That there were motor vehicle accidents on CR48 at or near the intersection of CR 48 and Depot Lane in the Town of Southold County of Suffolk State of New York, prior to July 18, 2015. 30. That the defendant, COUNTY OF SUFFOLK, performed a traffic stud(ies) at or near the intersection of CR 48 and Depot Lane in the Town of Southold County of Suffolk State 5 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 . . of New York prior to July 18, 2015. Dated: East Northport, New York October 24, 2016 L. JUL NO, P.C. Atto or P aintif Suzanne Schu man, as Administratrix of ·~- state M. Schulman, of Brittney deceased. 39 Doyle Court East Northport, New York 11731 (631) 499-9300 TO: DENNIS M. BROWN Attorney for Defendant, County of Suffolk H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, NY 11788 DEVITT SPELLMAN BARRETT, LLP Attorney for Defendant, Town of Southold 50 Route 111 Smithtown, NY 11787 AHMUTY, DEMERS & McMANUS Attorney for Defendants, Carlos Pino and Ultimate Class Limousine Inc. 200 I.U. Willets Road Albertson, NY 11507 CASCONE & KLUEPFEL, LLP Attorney for Defendant Romeo Dimon Marine Service, Inc. 1399 Franklin Avenue, Suite 302 Garden City, NY 11530 LEWIS JOHS AVALLONE AVILES LLP Attorney for Defendant, Steven Romeo One CA Plaza, Suite 225 Islandia, New York 11749 6 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 . RECEIVED NYSCEF: 09/06/2022 . SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Index No.: 611214/15 .------...-----------------------------..-----------X SUZANNE SCHULMAN, AS ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M. SCHULMAN, DECEASED, Plaintiff, AFFIDAVIT OF SERVICE -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, Defendants. ----------..----------------------------------------Ç State of New York) ss.) County of Suffolk) Christopher Martinson, being duly sworn, deposes and says as follows: I am not a party to the within action, I am at least (18) years of age and reside in Lake Grove, New York, That on October 24, 2016, I served the within Notice to Admit upon: DENNIS M. BROWN Attorney for Defendant, County of Suffolk H. Lee Dennison Building 100 Veterans Memorial Highway Hauppauge, NY 11788 DEVITT SPELLMAN BARRETT, LLP Attorney for Defendant, Town of Southold 50 Route 111 Smithtown, NY 11787 1 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 RECEIVED NYSCEF: 09/06/2022 AHMUTY, DEMERS & McMANUS Attorney for Defendants, Carlos Pino and Ultimate Class Limousine Inc. 200 I.U. Willets Road Albertson, NY 11507 CASCONE & KLUEPFEL, LLP Attorney for Defendant Romeo Dimon Marine Service, Inc. 1399 Franklin Avenue, Suite 302 Garden City, NY 11530 LEWIS JOHS AVALLONE AVILES LLP Attorney for Defendant, Steven Romeo One CA Plaza, Suite 225 Islandia, New York 11749 by depositing a true copy thereof in a post-paid, properly addressed envelope in an official depository under the exclusive care and custody of the U.S. Postal Service within New York State. Christopher Martinson Sworn to before me on October 24, 2016 T Y PUBLI BERNADETTE BALBOA Notary Public,5-.: of New York No. 01bA5u37034 Qualii.od inSuffolk Cour Comm:cwon Exoires Desamber 1 00 2 FILED: SUFFOLK COUNTY CLERK 09/06/2022 05:44 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1011 MeRECEIVED o. m2M-MNYSCEF: 09/06/2022 SUPREME COURT, 1 , STATE OF NEW YORK, COUNTY OF SUFFOLK Index No. Year 20 SUZANNE SCHULMAN, AS ADMINISTRATRIX OF THE . ESTATE OF BRITTNEY M. SCHULMAN, DECEASED, Plaintiff, -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, Defendants. NOTICE TO ADMIT JOHN L. JULIANO, P.C. Attorney(s)for Officeand Post OfficeAddress,Telephone HILLSIDE BUILDING 39 Doyle Court EAST NORTHPORT, NEW YORK 11731 Telephone (631) 499-9300 Fax # (631) 462-2532 Service of a copy of the within To is hereby admitted. Dated:..-....................-...............20..-.... ...............................................................-- Attorney(s) for PLEASE TAKE NOTICE: O NOTICE OF ENTRY that the within is a (certiñed) true copy of a entered in the office of the clerk of the within named court on 20 duly O NOTICE OF SETTLEMENT that an order of which the within is a true copy will be presented for settlement to the HON. one of the judges of the within named Court, at on 20 at M. Dated, Yours, etc. JOHN L. JULIANO, P.C.