On October 21, 2015 a
Party Discovery
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 01:45 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1195 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 PLAINTIFF, OLGA
LIPETS'
BRITTANY M. SCHULMAN, Deceased; ALICIA M. EXPERT
ARUNDEL; OLGA LIPETS; MINDY GRABINA, as WITNESS DISCLOSURE
Administratrix of the Estate of AMY GRABINA, and PURSUANT TO CPLR
MINDY GRABINA, Individually; STEVEN BARUCH, as §3101(d)
Administrator of the Estate of LAUREN BARUCH,
Deceased, and STEVEN BARUCH, Individually; JOELLE Index No.: 611214/2015
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-
ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO,
ROMEO DIMON MARINE SERVICE, 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 remanufacturers,
distributors and/or sellers of the 2007 Lincoln Town Car
stretch limousine involved in the collision,
Defendants.
____________________________________________..______________________Ç
PLEASE TAKE NOTICE THAT, Plaintiff, OLGA LIPETS, by her attorneys,
CHAIKIN, PLLC, and as for her Expert Witness Disclosure Pursuant to CPLR §3101(d)
respectfully submits as follows:
1. Plaintiff expects to call James Pugh, PH.D., P.E., President and Director of
InterCity 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 trial.
"A"
Annexed hereto as Exhibit is a copy of the Curriculum Vitae of James Pugh, PH.D., P.E.
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FILED: SUFFOLK COUNTY CLERK 11/29/2022 01:45 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1195 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 28, 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 28, 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 aforementioned documents
and materials, and as set forth in his Affidavit dated November 28, 2022.
PLAINTIFF RESERVES HER 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: Melville, New York
November 29, 2022
Y rs, etc.
. 1 M. Chaikin, E q.
CHAIKIN, PLLC
-Attorneys for Plaintiff-
OLGA LIPETS
445 Broadhollow Road, Suite 232
Melville, New York 11747
P: (212) 977-2020
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FILED: SUFFOLK COUNTY CLERK 11/29/2022 01:45 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1195 RECEIVED NYSCEF: 11/29/2022
To: BONGIORNO, MONTIGLIO & PALMIERI, PLLC
-Attorneys for Defendants-
ULTIMATE CLASS LIMOUSINE, INC. and
CARLOS PINO
200 Old Country Road, Suite 680
Mineola, NY 11501
(516) 620-0687
CASCONE & KLUEPFEL, LLP
-Attorneys for Defendant-
ROMEO DIMON MARINE SERVICE
1399 Franklin Avenue, Suite 302
Garden City, NY 11530
(516) 747-1990
LEWIS JOHS AVALLONE AVILES
-Attorneys for Defendant-
STEVEN D. ROMEO
1377 Motor Parkway, Suite 400
Islandia, NY 11749
(631) 755-0101
VOLZ & VIGLIOTTA
for Defendant-
-Attorney
TOWN OF SOUTHOLD
280 Smithtown Boulevard
Nesconset, NY 11767
(631) 366-2700
LAW OFFICE OF VINCENT D. McNAMARA
for Defendant-
-Attorney
COUNTY OF SUFFOLK
Tower Square - 1045 Oyster Road - Suite 1
Bay
East Norwich, NY 11732
(516) 922-9100
LAW OFFICES OF ERIC D. FELDMAN
-Attorneys for Defendant-
CABOT COACH BUILDERS, INC. d /a ROYALE LIMOUSINE
P.O. BOX 2903 Hartford, CT 06104
(631) 501-3100
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Preview
FILED: SUFFOLK COUNTY CLERK 11/29/2022 01:45 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1195 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 PLAINTIFF, OLGA LIPETS' BRITTANY M. SCHULMAN, Deceased; ALICIA M. EXPERT ARUNDEL; OLGA LIPETS; MINDY GRABINA, as WITNESS DISCLOSURE Administratrix of the Estate of AMY GRABINA, and PURSUANT TO CPLR MINDY GRABINA, Individually; STEVEN BARUCH, as §3101(d) Administrator of the Estate of LAUREN BARUCH, Deceased, and STEVEN BARUCH, Individually; JOELLE Index No.: 611214/2015 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- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, 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 remanufacturers, distributors and/or sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. ____________________________________________..______________________Ç PLEASE TAKE NOTICE THAT, Plaintiff, OLGA LIPETS, by her attorneys, CHAIKIN, PLLC, and as for her Expert Witness Disclosure Pursuant to CPLR §3101(d) respectfully submits as follows: 1. Plaintiff expects to call James Pugh, PH.D., P.E., President and Director of InterCity 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 trial. "A" Annexed hereto as Exhibit is a copy of the Curriculum Vitae of James Pugh, PH.D., P.E. 1 of 3 FILED: SUFFOLK COUNTY CLERK 11/29/2022 01:45 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1195 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 28, 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 28, 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 aforementioned documents and materials, and as set forth in his Affidavit dated November 28, 2022. PLAINTIFF RESERVES HER 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: Melville, New York November 29, 2022 Y rs, etc. . 1 M. Chaikin, E q. CHAIKIN, PLLC -Attorneys for Plaintiff- OLGA LIPETS 445 Broadhollow Road, Suite 232 Melville, New York 11747 P: (212) 977-2020 2 of 3 FILED: SUFFOLK COUNTY CLERK 11/29/2022 01:45 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1195 RECEIVED NYSCEF: 11/29/2022 To: BONGIORNO, MONTIGLIO & PALMIERI, PLLC -Attorneys for Defendants- ULTIMATE CLASS LIMOUSINE, INC. and CARLOS PINO 200 Old Country Road, Suite 680 Mineola, NY 11501 (516) 620-0687 CASCONE & KLUEPFEL, LLP -Attorneys for Defendant- ROMEO DIMON MARINE SERVICE 1399 Franklin Avenue, Suite 302 Garden City, NY 11530 (516) 747-1990 LEWIS JOHS AVALLONE AVILES -Attorneys for Defendant- STEVEN D. ROMEO 1377 Motor Parkway, Suite 400 Islandia, NY 11749 (631) 755-0101 VOLZ & VIGLIOTTA for Defendant- -Attorney TOWN OF SOUTHOLD 280 Smithtown Boulevard Nesconset, NY 11767 (631) 366-2700 LAW OFFICE OF VINCENT D. McNAMARA for Defendant- -Attorney COUNTY OF SUFFOLK Tower Square - 1045 Oyster Road - Suite 1 Bay East Norwich, NY 11732 (516) 922-9100 LAW OFFICES OF ERIC D. FELDMAN -Attorneys for Defendant- CABOT COACH BUILDERS, INC. d /a ROYALE LIMOUSINE P.O. BOX 2903 Hartford, CT 06104 (631) 501-3100 3 of 3