On October 21, 2015 a
Motion-Secondary
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 11/29/2022 11:53 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 11/29/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
----______________________________________________________________----_____________Ç
SUZANNE SCHULMAN, AS ADMINISTRATRIX OF THE
ESTATE OF BRITTNEY M. SHULMAN DECEASED; ALICA
M. ARUNDEL; OLGA LIPTETS; MINDY GRABINA, AS
ADMINISTRATRIX OF THE ESTATE AMY GRABINA, Index No: 611214/15
AND MINDY GRABINA INDIVIDUALLY; STEVEN BARUCH,
AS ADMINISTRATOR OF THE ESTATE OF LAUREN BARUCH,
DECEASED AND STEVEN BARUCH, INDIVIDUALLY; JOELLE
DIMONTE; 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 BELLI,
Plaintiffs,
- against - PLAINTIFF
MELISSA A. CRAI
ULTIMATE CLASS LIMOUSINE, INC., CARLOS F. PINO, EXPERT WITNESS
ROMEO DIMON MARINE SERVICES, INC., STEVEN D. ROMEO, DISCLOSURE
TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, PURSUANT TO
CABOT COACH BUILDERS, INC., d/b/a ROYALE LIMOUSINE CPLR § 3101 (d)
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
Plaintiff, MELISSA A. CRAI, by her attorneys, LAW OFFICES OF JOSEPH J. TOCK,
as and for her Expert Witness Disclosure pursuant to C.P.L.R. §3101(d) respectfully submits as
follows:
1. Plaintiff expects to call James President and Director of Inter-
Pugh, PH.D.,P.E.,
City Testing & Consulting Corporation with offices located at 620 Broadway, Suite 2F, New
York, NY 10012, as an expert witness in the field of biomechanical engineering at the time of
"A"
trial. Annexed hereto as Exhibit is a copy of the Curriculum Vitae of James Pugh,
PH.D.,P.E.
LAW OFFICES OF JOSEPH J. TOCK " 963 ROUTE 6, MAHOPAC, NEW YORK 10541
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FILED: SUFFOLK COUNTY CLERK 11/29/2022 11:53 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 11/29/2022
2. The subject matter upon which Mr. Pugh is expected to testify is set forth in detail
"B"
in his Affidavit dated November 22, 2022, a copy which is annexed hereto as Exhibit and
incorporated by reference herein.
3. The facts and opinions upon which Mr. Pugh is expected to testify are based on
his review of testimony, documents, affidavits, materials, photographs, expert reports, and other
materials relating to this matter, and as set forth in his Affidavit dated November 22, 2022.
4. The grounds for Mr. Pugh's opinions come from his education, training, and
experience in the field of Biomedical Engineering and his review of the aforesaid documents and
materials, and as set forth in his Affidavit dated November 22, 2022.
PLAINTIFF RESERVES THE RIGHT TO SUPPLEMENT THIS EXPERT WITNESS
DISCLOSURE UP UNTIL THE TIME OF TRIAL AS SAID EXPERT WILL TESTIFY AS TO
HIS EXPERTISE ON THE SUBJECT MATTER OF THIS CASE AND RESERVES HIS
RIGHT TO SUPPLEMENT HIS OPINIONS BASED ON THE PROOF, OR OTHERWISE,
THAT MAY BE ADDUCED AT THE TIME OF TRIAL.
Dated: November 29, 2022
Mahopac, NY Respectfully Submitted,
Joseph J Tocl sq.
LAW FICES OF JOSEPH J. TOCK
Attorney for: MELISSA A. CRAI
963 Route 6
Mahopac, NY 10541
845.628.8080
To: All parties via NYCEF e-filing only
LAW OFFICES OF JOSEPH J. TOCK " 963 ROUTE 6, MAHOPAC, NEW YORK 10541
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FILED: SUFFOLK COUNTY CLERK 11/29/2022 11:53 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 11/29/2022
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 BELLI,
Plaintiff(s)
-against-
ULTIMATE CLASS LIMOUSINE INC.,CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC.,STEVEN ROMEO, TOWN OF SOUTHOLD,
I-5"
COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC.,d/b/aROYALE LIMOUSINE and "XYZ COMPANIES name beingfictitious
but
intendedto be the remanufacturers, and/or
distributors, sellersof the 2007
Lincoln Town Car stretch
limousine involvedin the collision,
Defendants(s).
PLAINTIFF'S EXPERT WITNESS DISCLOSURE PURSUANT TO C.P.L.R. §3101 d
Law Officesof
Joseph J. Tock
Attorney for Plaintiff(Crai)
963 Route 6
Mahopac, NY 10541
(845) 628 - 8080
Pursuant to 22 NYCRR 130.1.1,the undersigned,an attorney admittedto practice
in thecourts 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 ofthe within is herebyadmitted.
Dated:
Attorney (s)for
PLEASE TAKE NOTICE
thatthe within true
is a (certified) cony of a
entered inthe officeof theclerkof thewithin named Court on
thatan Order of whichthewithin is a true
copy willbe presented forsettlement tothe Non.
one of the judgesof thewithinnamed Court,
at
on 20 , at M.
Dated:
Law Officesof
Joseph J. Tock
Attorney for Plaintiff
963 Route 6
Mahopac, NY 10541
(845)628 - 8080
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Preview
FILED: SUFFOLK COUNTY CLERK 11/29/2022 11:53 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 11/29/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ----______________________________________________________________----_____________Ç SUZANNE SCHULMAN, AS ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M. SHULMAN DECEASED; ALICA M. ARUNDEL; OLGA LIPTETS; MINDY GRABINA, AS ADMINISTRATRIX OF THE ESTATE AMY GRABINA, Index No: 611214/15 AND MINDY GRABINA INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR OF THE ESTATE OF LAUREN BARUCH, DECEASED AND STEVEN BARUCH, INDIVIDUALLY; JOELLE DIMONTE; 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 BELLI, Plaintiffs, - against - PLAINTIFF MELISSA A. CRAI ULTIMATE CLASS LIMOUSINE, INC., CARLOS F. PINO, EXPERT WITNESS ROMEO DIMON MARINE SERVICES, INC., STEVEN D. ROMEO, DISCLOSURE TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, PURSUANT TO CABOT COACH BUILDERS, INC., d/b/a ROYALE LIMOUSINE CPLR § 3101 (d) 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 Plaintiff, MELISSA A. CRAI, by her attorneys, LAW OFFICES OF JOSEPH J. TOCK, as and for her Expert Witness Disclosure pursuant to C.P.L.R. §3101(d) respectfully submits as follows: 1. Plaintiff expects to call James President and Director of Inter- Pugh, PH.D.,P.E., City Testing & Consulting Corporation with offices located at 620 Broadway, Suite 2F, New York, NY 10012, as an expert witness in the field of biomechanical engineering at the time of "A" trial. Annexed hereto as Exhibit is a copy of the Curriculum Vitae of James Pugh, PH.D.,P.E. LAW OFFICES OF JOSEPH J. TOCK " 963 ROUTE 6, MAHOPAC, NEW YORK 10541 1 of 3 FILED: SUFFOLK COUNTY CLERK 11/29/2022 11:53 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 11/29/2022 2. The subject matter upon which Mr. Pugh is expected to testify is set forth in detail "B" in his Affidavit dated November 22, 2022, a copy which is annexed hereto as Exhibit and incorporated by reference herein. 3. The facts and opinions upon which Mr. Pugh is expected to testify are based on his review of testimony, documents, affidavits, materials, photographs, expert reports, and other materials relating to this matter, and as set forth in his Affidavit dated November 22, 2022. 4. The grounds for Mr. Pugh's opinions come from his education, training, and experience in the field of Biomedical Engineering and his review of the aforesaid documents and materials, and as set forth in his Affidavit dated November 22, 2022. PLAINTIFF RESERVES THE RIGHT TO SUPPLEMENT THIS EXPERT WITNESS DISCLOSURE UP UNTIL THE TIME OF TRIAL AS SAID EXPERT WILL TESTIFY AS TO HIS EXPERTISE ON THE SUBJECT MATTER OF THIS CASE AND RESERVES HIS RIGHT TO SUPPLEMENT HIS OPINIONS BASED ON THE PROOF, OR OTHERWISE, THAT MAY BE ADDUCED AT THE TIME OF TRIAL. Dated: November 29, 2022 Mahopac, NY Respectfully Submitted, Joseph J Tocl sq. LAW FICES OF JOSEPH J. TOCK Attorney for: MELISSA A. CRAI 963 Route 6 Mahopac, NY 10541 845.628.8080 To: All parties 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 11/29/2022 11:53 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 11/29/2022 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 BELLI, Plaintiff(s) -against- ULTIMATE CLASS LIMOUSINE INC.,CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC.,STEVEN ROMEO, TOWN OF SOUTHOLD, I-5" COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC.,d/b/aROYALE LIMOUSINE and "XYZ COMPANIES name beingfictitious but intendedto be the remanufacturers, and/or distributors, sellersof the 2007 Lincoln Town Car stretch limousine involvedin the collision, Defendants(s). PLAINTIFF'S EXPERT WITNESS DISCLOSURE PURSUANT TO C.P.L.R. §3101 d Law Officesof Joseph J. Tock Attorney for Plaintiff(Crai) 963 Route 6 Mahopac, NY 10541 (845) 628 - 8080 Pursuant to 22 NYCRR 130.1.1,the undersigned,an attorney admittedto practice in thecourts 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 ofthe within is herebyadmitted. Dated: Attorney (s)for PLEASE TAKE NOTICE thatthe within true is a (certified) cony of a entered inthe officeof theclerkof thewithin named Court on thatan Order of whichthewithin is a true copy willbe presented forsettlement tothe Non. one of the judgesof thewithinnamed 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