Preview
FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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SEAN YOUNG and KIMBERLY YOUNG,
RESPONSE TO THIRD-PARTY
Plaintiffs, DEFENDANT BRODERVILLE
-against- PICTURES’ COMBINED
DEMANDS
JAMESTOWN 450 WEST 15TH STREET L.P.,
JAMESTOWN PROPERTIES CORP., Index No: 161241/2020
AGB 15TH STREET L.L.C, MILK STUDIOS,
LLC, and “ABC CORPORATION” a fictitious TP# 595299/2022
Corporation representing unidentified individudals,
businesses and/or corporations who owed, controlled,
maintained or was otherwise responsible for the
subject premises,
Defendants.
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MILK STUDIOS, LLC,
Third-Party Plaintiff,
-against-
BRODERVILLE PICTURES and WINDMILL
STUDIOS NYC,
Third-Party Defendants.
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C O U N S E L O R S:
PLEASE TAKE NOTICE, that the defendant/third-party plaintiff, MILK STUDIOS,
LLC, by their attorneys, The Law Offices of Terrence F. Kuhn, as and for itsResponse to the
Combined Demands of the third-party defendant, BRODERVILLE PICTURES, dated July 7,
2022, herein states as follows upon information and belief:
RESPONSE TO DEMAND FOR AUTHORIZATIONS AND MEDICAL REPORTS
This demand is more appropriately addressed to Plaintiff.
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RESPONSE TO DEMAND FOR VIDEO/AUDIO RECORDINGS OF PLAINTIFF(S)
TAKEN AT INDEPENDENT MEDICAL EXAMINATION(S)
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR NOTICE OF CLAIM AND 50-H HEARING
TRANSCRIPT
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR STATEMENTS
At the present time, the defendant/third-party plaintiff is not in possession of any party
statements.
RESPONSE TO DEMAND FOR LEGAL REPRESENTATION
Legal representation for the parties having appeared to date in this matter is as follows:
WEITZ & LUXENBERG
By Jared Lacertosa, Esq.
Attorneys for Plaintiffs
SEAN YOUNG AND KIMBERLY YOUNG
700 Broadway,
New York, NY 10003
CORREIA, KING, McGINNIS & LIFERIEDGE
By Vincent Brescia, Esq.
Attorneys for Defendants
JAMESTOWN 450 WEST 15TH STREET, L.P.
and JAMESTOWN PROPERTIES CORP.
One Battery Park Plaza, 29th Floor
New York, NY 10004
LAW OFFICES OF TERRENCE F. KUHN
By Curtis Gilfillan, Esq.
Attorneys for Defendant/Third-Party Plaintiff
MILK STUDIOS, LLC
One Pennsylvania Plaza, Suite 5003
New York, New York 10119
As of the date of this Response, there has not yet been an appearance on behalf of third-
party defendant, WINDMILL STUDIOS NYC.
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RESPONSE TO DEMAND FOR COLLATERAL SOURCES
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR NAMES OF ALL WITNESSES
The defendant/third-party plaintiff is unaware of the names and addresses of any
witnesses to the alleged accident other than those that maybe enclosed in an accident/incident
report or in Plaintiff’s medical records. Defendant/third-party plaintiff reserves the right to
amend their response should he become aware of the name and addresses of any witnesses at a
later date pursuant to C.P.L.R.
RESPONSE TO DEMAND FOR PHOTOGRAPHS, SLIDES, VIDEO TAPES AND
MOTION PICTURES AND SUVEILLANCE TAPES
The defendant/third-party plaintiff is not in possession of any photographs, slides,
videotapes or motion pictures responsive to this demand at this time.
RESPONSE TO DEMAND FOR POST OFFICE INFORMATION
The defendant/third-party plaintiff objects to this demand as being overly broad, palpably
improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite
specificity called for in that Article. All correspondence should be directed to counsel for the
parties herein.
RESPONSE TO REQUEST FOR DISCOVERY OF EXPERT WITNESS
INFORMATION
The defendant/third-party plaintiff has not yet retained the services of an expert witness.
If and when an expert is retained, name, address, qualifications and subject matter of the expert’s
testimony will be provided.
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RESPONSE TO DEMAND FOR INSURANCE COVERAGE
On the date of loss, the defendant/third-party plaintiff, MILK STUDIOS, LLC, was
afforded coverage through The Hartford Fire Insurance Co., under policy number
13UUNBI5740, effective dates 11/03/17 to 11/03/18, with limits of $1,000,000. A copy of this
primary policy is annexed as Exhibit “A”. The within defendant/third-party plaintiff was also
afforded umbrella coverage through The Hartford Casualty Insurance Company with limits of
$10,000,000 under policy number 13RHUBK9090. A copy of the umbrella policy is annexed as
Exhibit “B”.
RESPONSE TO DEMAND FOR EMPLOYMENT AUTHORIZATIONS
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR SCHOOL AUTHORIZATIONS
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR AUTHORIZATIONS FOR TAX RETURNS
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR AUTHORIZATIONS FOR NO-FAULT RECORDS
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR ACCIDENT REPORTS
The defendant/third-party plaintiff is not in possession of any accident or incident reports
responsive to this demand at this time.
RESPONSE TO DEMAND FOR MAINTENANCE AND REPAIR RECORDS
The third-party defendant objects to this demand as being overly broad, palpably
improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite
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specificity called for in that Article. Without waiving said objections, third-party defendant is not
in possession of materials responsive to this demand.
RESPONSE TO DEMAND FOR PHONE RECORDS
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR LEGAL CERTIFICATES
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR AD DAMNUM
This demand is more appropriately addressed to Plaintiff.
RESPONSE TO DEMAND FOR PLEADINGS
All pleadings exchanged between the parties to date are available on NYSCEF.
RESPONSE TO DEMAND FOR AFFIDAVIT OF SERVICE
Attached hereto as Exhibit “C” is the Affidavit of Service of the Third-Party Summons
and Complaint on third-party defendant, BRODERVILLE PICTURES.
RESPONSE TO DEMAND TO RETAIN, PRESERVE, PROTECT AND INSPECT
PHYSICAL EVIDENCE
The third-party defendant objects to this demand as being overly broad, palpably
improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite
specificity called for in that Article.
RESPONSE TO DEMAND FOR COPIES OF TAPE RECORDINGS
The third-party defendant objects to this demand as being overly broad, palpably
improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite
specificity called for in that Article. Without waiving said objections, third-party defendant is not
in possession of materials responsive to this demand.
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RESPONSE TO DEMAND FOR COPIES OF EMAILS
The third-party defendant objects to this demand as being overly broad, palpably
improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite
specificity called for in that Article. Without waiving said objections, third-party defendant is not
in possession of materials responsive to this demand.
RESPONSE TO DEMAND FOR CONTRACTS
The third-party defendant objects to this demand as being overly broad, palpably
improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite
specificity called for in that Article. Without waiving said objections, the defendant/third-party
plaintiff is not in possession of leases, repair estimates, repair records, cancelled checks,
inventory, inventory loss statements, recapitulation, or adjusting notes. Notwithstanding,
annexed hereto, collectively, as Exhibit “D” are a license agreement and invoice between the
defendant/third-party plaintiff and third-party defendant, BRODERVILLE PICTURES,
pertaining to the subject premises for the date of loss.
RESPONSE TO DEMAND FOR UNION AUTHORIZATIONS
This demand is more appropriately addressed to Plaintiff.
PLEASE TAKE FURTHER NOTICE that defendant/third-party plaintiff, MILK
STUDIOS, LLC, reserves the right to supplement and/or amend the above responses prior to the
time of trial.
Dated: New York, New York
August 22, 2022
Curtis B. Gilfillan
______________________________
Curtis B. Gilfillan, Esq.
Law Offices of Terrence F. & Kuhn
Attorneys for Defendant/Third-Party Plaintiff
MILK STUDIOS, LLC
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One Pennsylvania Plaza, Suite 5003
New York, New York 10119
Tel No.: (212) 553-8700/
File No: Y2KL05308-001/ CBG/ps
To: WEITZ & LUXENBERG
Gary Klein, Esq.
Attorneys for Plaintiffs
SEAN YOUNG AND KIMBERLY YOUNG
700 Broadway,
New York, NY 10003
Gklein@weitzlux.com
CORREIA, KING, McGINNIS & LIFERIEDGE
Vincent Brescia, Esq.
Attorneys for Defendants
JAMESTOWN 450 WEST 15TH STREET, L.P.
and JAMESTOWN PROPERTIES CORP.
One Battery Park Plaza
29th Floor
New York, NY 10004
Vincent.Brescia@LibertyMutual.com
MORRIS, DUFFY, ALONSO, FALEY & PITCOFF
William J. Manning, Jr., Esq.
Attorneys for Third-Paryt Defendant
BRODERVILLE PICTURES
101 Greenwich Street, 22nd Floor
New York, NY 10006
(212) 766-1888
File No.: (FIF) 74103
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EXHIBIT “A”
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Prepare. Protect. Prevail.
THE
HARTFORD
Business
Insurance
EmployeeBenefits
Auto
HCITS
April 16, 2021
Re: Insured: MILK STUDIOS LLC
Policy Number: 13 UUN BI5740
Term: 11/03/2017 - 11/03/2018
Policy
Writing Company: HARTFORD FIRE INSURANCE COMPANY
This will verify that, to the best of the undersigneds knowledge, the attached is a
complete and accurate representation of insurance policy referenced above. Documents
and/or information produced herewith are kept and maintained in the ordinary course of
business.
Kyona Lawrence
Operations Support Specialist
Clinton Business Center
Hartford Office Location
301 Woods Park Dr.
Clinton, NY 13323
Toll Free: 888-525-2652
Fax: 866-809-1178
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NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022
Important Information
For New York Property
Owners and Tenants
As a result of New York Labor Law Section 240, you may be liable for injuries to
contractors you hire to do work at or on your property.
Learn more about this law and what you can do to reduce your risk.
As a New York property owner or a tenant who hires contractors to repair, alter, paint, erect, demolish,
clean or point a building or structure under New York Law Section 240, you may be liable for injuries
sustained by the contractor's workers who fallfrom heights or who are struck by falling objects.
This law places responsibility for worksite safety on owners and tenants who hire contractors. Liability
under New York Labor Law Section 240 may be imposed regardless of whether the property owner
exercised supervision or control over the injured worker.
Examples of Claims and Lawsuits
Contractors often work at heights and use ladders, scaffolding or other devices in order to get a job done.
Itwould not be uncommon for a contractor's employee (injured in a fall
from a height on your property) to
bring a legal action against you or your company. Examples of situations that resulted in a claim and/or
lawsuit under Section 240 of the New York Labor Law include:
o A maintenance worker fellfrom a ladder and was injured while taking down ceiling tilesfor a
store owner to correct a drafty condition created by improperly installed ceiling insulation.
o Trade Association hired a contractor to assist in installinga stage. an
Plaintiff, employee of
the contractor, fellfour feet and was injured.
o A worker was injured when he fellfrom an elevated height while removing and replacing
piping for a machine oilsupply and return system for our manufacturing risk.
o A worker was injured in a fall
from a steel beam. There was no scaffold beneath the beam.
In each of these cases, the property owner or business owner was alleged to be liable based on the fact
that they had hired a contractor to do work.
Impact on Insurance Coverage
Claims and lawsuits under Section 240 of the New York Labor Law may have an adverse effect on your
company's finances and insurance program.
o The most significant risk isa judgment against your company in excess of your policy's limitof
liability.
Some claims based on this law have been $1 millionor more.
o Your future insurance premiums may increase as a resultof lawsuits against your company.
o Because favorable claim history is a key component of your insurability, insurance
liability
may become difficult
to obtain.
Form 106373 Page 1 of 2
© 2016, The Hartford
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NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022
Reducing Your Risk
There are a few simple risk management techniques that should be considered in consultation with your
attorney or insurance agent to help reduce the chances of your business being involved in litigation:
1. Prior to the start of any work, have a written contract in place that includes an
appropriate indemnification clause. Ensure that all contracts and indemnification
clauses are reviewed by a qualified attorney priorto signing.
"primary" "non-contributory"
2. Be named as a and Additional Insured on the
contractor's General Liability Policy. This method of transferring risk could be
significantin the event of a loss.
3. Only hire reputable contractors to perform work of any kind on your property, whether
owned or leased. Pre-qualify contractors by reviewing previous work, securing
recommendations from previous customers, reviewing the contractor's financial
condition, inquiring about past losses, and ensuring the contractor has adequate and
Workers'
appropriate insurance coverage, including Compensation coverage.
4. Require all contractors you hireto strictlyfollow allOSHA and NY State Industrial
Regulations. Ensure that the contractor is aware of the applicable regulations and
laws that apply to thisexposure.
Taking these simple steps willhelp minimize the possibility of the New York Labor Law having an adverse
effect on your company's finances and insurance program, as a result of hiring a contractor. For more
business'
information about how The Hartford can help meet your risk management and insurance needs,
please contact your agent.
New York Labor Law Section 240 (1) provides, in part, as follows:
"Allcontractors and owners and their agents, except owners of one and two-family dwellings who
contract for but do not direct or control the work, in the erection, demolition, repairing, altering,
painting, cleaning or pointing of a building or structure shallfurnish or erect, or cause to be furnished
or erected for the performance of such labor, scaffolding, hoists, stays, ladders, slings, hangers,
blocks, pulleys, braces, irons, ropes and other devices which shall be so constructed, placed and
employed."
operated as to give proper protection to a person so
The informationprovidedabove is ofa generalnatureand may legal
not be considered advice.The content of this
document may
omit certaindetails
and cannot be regarded as advicethat would be applicabletoallbusinesses. As such, thisinformationis
provided forinformationalpurposes only Readers seeking resolution
of specificsafety,legalor businessissues or concerns
regardingthistopicshould consulttheirsafetyconsultant,
attorneyand/or business advisorsThe information
presented isnot a
for
substitute a thorough loss control
survey of yourbusinessor operationsor an analysis
of the or appropriateness
legality of your
business practices.We do not warrantthat the implementationof any view or recommendation contained herein will
be an
appropriatelegalor business
practice. we
Further, do not warrantthatthe implementation
of any viewor recommendation will avoid
any or all liability.
THE
HAR T FOR D
Form 106373 Page 2 of 2
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NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022
IMPORTANT NOTICE TO POLICYHOLDERS
THE HARTFORD CYBER CENTER WEBSITE ACCESS
Thank you for choosing The Hartford for your business insurance needs.
You are receiving thisNotice because you purchased a general or
liability property policy from The Hartford, which
includes access to The Hartford Cyber Center. This portal was created because we recognize that businesses
face a variety of cyber-related exposures and need help managing the related risks. These exposures include
data breaches, computer virus attacks and cyber extortion threats.
Through the Hartford Cyber Center, you have access to:
o A panel of thirdparty incident response service providers
o Third party cybersecurity pre-incident service providers and a listof approved services to help protect your
business before a cyber-threat occurs
o Risk management tools, including self-assessments, best practice guides, templates, sample incident
response plans, and data breach cost calculators
o White papers, blogs and webinars from leading privacy and security practitioners
o Up-to-date cyber-related news and events, including examples of privacy and security related events
Accessing The Hartford Cyber Center iseasy
1. Visitwww.thehartford.com/cybercenter
2. Enter policyholder information
3. Access code: 952689
4. Login to The Hartford Cyber Center
Please be aware that:
o The Hartford Cyber Center is a proprietary web portal exclusively provided to customers of The Hartford.
Please do not share the access code with anyone outside your organization.
o Registration is required to access the Cyber Center. You may register as many users as necessary.
o Contacting a service provider about any issue does not constitute providing The Hartford notice of a claim
as required under your insurance policy. Read your insurance policy and discuss any questions with your
agent or broker.
o The Hartford Cyber Center provides third party service provider references and materials for educational
purposes only. The Hartford does not specifically endorse any such service provider within The Hartford
Cyber Center and hereby disclaims all with
liability respect to use of or reliance on such service providers.
AII service providers are independent contractors and not agents of The Hartford. The Hartford does not
warrant the performance of the service providers, even ifsuch services are covered under your policy.
providers'
We strongly encourage you to conduct your own assessments of the service services and the
fitness or adequacy of such services for your particular needs. This Notice does not amend or otherwise
affectthe provisions of your policy.
The Hartford offers a variety of endorsements to your policy that can help protect your business from a broad
range of cyber-related threats. Please review your coverage with your insurance agent or broker to determine the
most appropriate cyber coverages and limitsfor your business.
Ifyou have a claim, you can report it bycalling The Hartforos toll-freeclaims line at 1-800-327-3636.
Should you have any questions, please contact your insurance agent, broker or you may contact us directly.
We appreciate your business and look forward to being of continued service to you.
Form G-4033-1 (07/16 ED.) Page 1 of 1
© 2016, The Hartford
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NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022
Insurance Policy Billing Information
Thank you for selecting The Hartford for your business insurance needs.
Shortly, you will receive your first bill from us. You are receiving this Notice so you know
what to expect as a valued customer of The Hartford. Should you have any questions after
reviewing this information, please contact us at 866-467-8730, and we will be happy to
assist you.
o Your total policy premium will appear on your policy's Declarations Page. You willbe billedbased on the payment
plan you selected.
due"
o You may pay the "minimum as it appears on your insurance billor pay the policy balance in full.
due"
o An installment service fee is added to each installment. A latefee willalso be applied ifthe "minimum is not
received by the due date shown on your bill.
Service and late payment fees do not apply in allstates.
o Ifyou selected installment billing,any credit or additional premium due as the result of a change made to your
policy, willbe spread over the remaining billinginstallments. Additional premium due as a result of an audit willbe
billedin fullon your next bill
date following the completion of the audit.
o Ifyou elected Electronic Funds Transfer (EFT), policy changes may result inchanges to the amount automatically
withdrawn from your bank account. The invoice you receive following a policy change will include future withdrawal
amounts, Ifyou need to adjust or stop your next scheduled EFT withdrawal, please contact us at least 3 days
prior to the scheduled withdrawal date at the telephone number shown below.
o Ifyou selected installment billingand pay the premiums for your firstpolicy term on time, at renewal, your account
Installment"
may qualifyfor our "Equal feature. This means that the percentage due for each installment, including
the initialrenewal installment, willbe the same throughout the term - you better manage cash flow.
policy helping
Equal installments willcontinue as long as you pay your premiums on time and no cancellation notices are issued
for any policy on your account. Ifyou no longer qualify for Equal Installments, future renewals willbe billedbased
on the payment plan you selected, which includes a higher initial
installment amount.
o Ifyour policy is eligiblefor renewal, your billforthe upcoming policy term will be sent to you approximately 30 days
prior to your policy's renewal date. Ifyour insurance needs change, please contact us at least 60 days priorto your
renewal date so we can properly address any adjustments needed.
o One billconvenience -- you have the option of all eligibleHartford policies on one single bill
combining allowing
you tomake one payment for allpolicies on your account as payments are due.
You're In Control
In addition to selecting a bill
plan option that best meets your budget, you have the to
flexibility decide how your
payments are made ...
o Repetitive EFT: Sign up for Repetitive EFT payments and have payments automatically withdrawn from your bank
account. This option saves you money by reducing the amount of the installment service fee.
o Pay Online: Register at www.thehartford.com/servicecenter. Online BillPay isQuick, Easy and Secure!
o Pay by Check: Send a check with your remittance stub in the envelope provided with your bill.
o Pay by Phone: Call toll-free1-866-467-8730.
Should you have any questions about your bill,please call Customer Service toll-free number:
1-866-467-8730 - 7AM - 7PM CST. We look forward to of service to you.
being
Form 100722 11th Rev. Printed in U.S.A.
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NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022
Special Multi-Flex
Business Insurance Policy
THE
HARTFORD
Form HM 00 01 03 14 Page 1 of 1
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NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022
This SPECIAL MULTI-FLEX POLICY is provided by the stock insurance company(s) of The Hartford Insurance
Group, shown below.
COMMON POLICY DECLARATIONS
POLICY NUMBER: 13 UUN BI5740 DB Tun
RENEWAL OF: 13 UUN BI5740 HARTFORD
Named Insured and Address: MILK STUDIOS LLC
Mailing
(No., Street, Town, State, SEE IH1204
Zip Code)
450 W 15TH ST
NEW YORK , NY 10011
(NEW YORK COUNTY)
Period: From 11/03/17 To 11/03/18
Policy
12:01 A.M. , Standard time at your address shown above.
mailing
In return for thepayment of the premium, and subject to allof the terms of thispolicy, we agree with you to provide
insurance as stated in thispolicy. The Coverage Parts that are a part of thispolicy are listedbelow. The Advance
Premium shown may be subject to adjustment.
Total Advance Premium:
Coverage Part and insurance Company Summary Advance Premium
PROPERTY CHOICE
HARTFORD FIRE INSURANCE COMPANY
ONE HARTFORD PLAZA
HARTFORD, CONNECTICUT 06155
COMMERCIAL INLAND MARINE
HARTFORD FIRE INSURANCE COMPANY
ONE HARTFORD PLAZA
HARTFORD, CONNECTICUT 06155
LISTING OF ADDITIONAL COVERAGE PARTS CONTINUED ON THE FOLLOWING PAGE,
Form Numbers of Coverage Parts, Forms and Endorsements that are a part of this policy and that are not
listed in the Coverage Parts.
HM0001 IL00171198 IH00010795 IH01150795 IHO9850115 IH12040312 1H99400409
LISTING OF ADDITIONAL FORM NUMBERS CONTINUED ON A SUBSEQUENT PAGE.
Agent/BrokerName: WORLD INSURANCE ASSOCIATES LLC
Countersigned by 11/17/17
(Where required by law) Authorized Representative Date
Preview
FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------- SEAN YOUNG and KIMBERLY YOUNG, RESPONSE TO THIRD-PARTY Plaintiffs, DEFENDANT BRODERVILLE -against- PICTURES’ COMBINED DEMANDS JAMESTOWN 450 WEST 15TH STREET L.P., JAMESTOWN PROPERTIES CORP., Index No: 161241/2020 AGB 15TH STREET L.L.C, MILK STUDIOS, LLC, and “ABC CORPORATION” a fictitious TP# 595299/2022 Corporation representing unidentified individudals, businesses and/or corporations who owed, controlled, maintained or was otherwise responsible for the subject premises, Defendants. ------------------------------------------------------------------- MILK STUDIOS, LLC, Third-Party Plaintiff, -against- BRODERVILLE PICTURES and WINDMILL STUDIOS NYC, Third-Party Defendants. ------------------------------------------------------------------- C O U N S E L O R S: PLEASE TAKE NOTICE, that the defendant/third-party plaintiff, MILK STUDIOS, LLC, by their attorneys, The Law Offices of Terrence F. Kuhn, as and for itsResponse to the Combined Demands of the third-party defendant, BRODERVILLE PICTURES, dated July 7, 2022, herein states as follows upon information and belief: RESPONSE TO DEMAND FOR AUTHORIZATIONS AND MEDICAL REPORTS This demand is more appropriately addressed to Plaintiff. 1 of 291 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 RESPONSE TO DEMAND FOR VIDEO/AUDIO RECORDINGS OF PLAINTIFF(S) TAKEN AT INDEPENDENT MEDICAL EXAMINATION(S) This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR NOTICE OF CLAIM AND 50-H HEARING TRANSCRIPT This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR STATEMENTS At the present time, the defendant/third-party plaintiff is not in possession of any party statements. RESPONSE TO DEMAND FOR LEGAL REPRESENTATION Legal representation for the parties having appeared to date in this matter is as follows: WEITZ & LUXENBERG By Jared Lacertosa, Esq. Attorneys for Plaintiffs SEAN YOUNG AND KIMBERLY YOUNG 700 Broadway, New York, NY 10003 CORREIA, KING, McGINNIS & LIFERIEDGE By Vincent Brescia, Esq. Attorneys for Defendants JAMESTOWN 450 WEST 15TH STREET, L.P. and JAMESTOWN PROPERTIES CORP. One Battery Park Plaza, 29th Floor New York, NY 10004 LAW OFFICES OF TERRENCE F. KUHN By Curtis Gilfillan, Esq. Attorneys for Defendant/Third-Party Plaintiff MILK STUDIOS, LLC One Pennsylvania Plaza, Suite 5003 New York, New York 10119 As of the date of this Response, there has not yet been an appearance on behalf of third- party defendant, WINDMILL STUDIOS NYC. 2 of 291 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 RESPONSE TO DEMAND FOR COLLATERAL SOURCES This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR NAMES OF ALL WITNESSES The defendant/third-party plaintiff is unaware of the names and addresses of any witnesses to the alleged accident other than those that maybe enclosed in an accident/incident report or in Plaintiff’s medical records. Defendant/third-party plaintiff reserves the right to amend their response should he become aware of the name and addresses of any witnesses at a later date pursuant to C.P.L.R. RESPONSE TO DEMAND FOR PHOTOGRAPHS, SLIDES, VIDEO TAPES AND MOTION PICTURES AND SUVEILLANCE TAPES The defendant/third-party plaintiff is not in possession of any photographs, slides, videotapes or motion pictures responsive to this demand at this time. RESPONSE TO DEMAND FOR POST OFFICE INFORMATION The defendant/third-party plaintiff objects to this demand as being overly broad, palpably improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite specificity called for in that Article. All correspondence should be directed to counsel for the parties herein. RESPONSE TO REQUEST FOR DISCOVERY OF EXPERT WITNESS INFORMATION The defendant/third-party plaintiff has not yet retained the services of an expert witness. If and when an expert is retained, name, address, qualifications and subject matter of the expert’s testimony will be provided. 3 of 291 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 RESPONSE TO DEMAND FOR INSURANCE COVERAGE On the date of loss, the defendant/third-party plaintiff, MILK STUDIOS, LLC, was afforded coverage through The Hartford Fire Insurance Co., under policy number 13UUNBI5740, effective dates 11/03/17 to 11/03/18, with limits of $1,000,000. A copy of this primary policy is annexed as Exhibit “A”. The within defendant/third-party plaintiff was also afforded umbrella coverage through The Hartford Casualty Insurance Company with limits of $10,000,000 under policy number 13RHUBK9090. A copy of the umbrella policy is annexed as Exhibit “B”. RESPONSE TO DEMAND FOR EMPLOYMENT AUTHORIZATIONS This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR SCHOOL AUTHORIZATIONS This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR AUTHORIZATIONS FOR TAX RETURNS This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR AUTHORIZATIONS FOR NO-FAULT RECORDS This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR ACCIDENT REPORTS The defendant/third-party plaintiff is not in possession of any accident or incident reports responsive to this demand at this time. RESPONSE TO DEMAND FOR MAINTENANCE AND REPAIR RECORDS The third-party defendant objects to this demand as being overly broad, palpably improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite 4 of 291 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 specificity called for in that Article. Without waiving said objections, third-party defendant is not in possession of materials responsive to this demand. RESPONSE TO DEMAND FOR PHONE RECORDS This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR LEGAL CERTIFICATES This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR AD DAMNUM This demand is more appropriately addressed to Plaintiff. RESPONSE TO DEMAND FOR PLEADINGS All pleadings exchanged between the parties to date are available on NYSCEF. RESPONSE TO DEMAND FOR AFFIDAVIT OF SERVICE Attached hereto as Exhibit “C” is the Affidavit of Service of the Third-Party Summons and Complaint on third-party defendant, BRODERVILLE PICTURES. RESPONSE TO DEMAND TO RETAIN, PRESERVE, PROTECT AND INSPECT PHYSICAL EVIDENCE The third-party defendant objects to this demand as being overly broad, palpably improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite specificity called for in that Article. RESPONSE TO DEMAND FOR COPIES OF TAPE RECORDINGS The third-party defendant objects to this demand as being overly broad, palpably improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite specificity called for in that Article. Without waiving said objections, third-party defendant is not in possession of materials responsive to this demand. 5 of 291 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 RESPONSE TO DEMAND FOR COPIES OF EMAILS The third-party defendant objects to this demand as being overly broad, palpably improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite specificity called for in that Article. Without waiving said objections, third-party defendant is not in possession of materials responsive to this demand. RESPONSE TO DEMAND FOR CONTRACTS The third-party defendant objects to this demand as being overly broad, palpably improper and outside the scope of Article 31 of the CPLR, and same lacks the requisite specificity called for in that Article. Without waiving said objections, the defendant/third-party plaintiff is not in possession of leases, repair estimates, repair records, cancelled checks, inventory, inventory loss statements, recapitulation, or adjusting notes. Notwithstanding, annexed hereto, collectively, as Exhibit “D” are a license agreement and invoice between the defendant/third-party plaintiff and third-party defendant, BRODERVILLE PICTURES, pertaining to the subject premises for the date of loss. RESPONSE TO DEMAND FOR UNION AUTHORIZATIONS This demand is more appropriately addressed to Plaintiff. PLEASE TAKE FURTHER NOTICE that defendant/third-party plaintiff, MILK STUDIOS, LLC, reserves the right to supplement and/or amend the above responses prior to the time of trial. Dated: New York, New York August 22, 2022 Curtis B. Gilfillan ______________________________ Curtis B. Gilfillan, Esq. Law Offices of Terrence F. & Kuhn Attorneys for Defendant/Third-Party Plaintiff MILK STUDIOS, LLC 6 of 291 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 One Pennsylvania Plaza, Suite 5003 New York, New York 10119 Tel No.: (212) 553-8700/ File No: Y2KL05308-001/ CBG/ps To: WEITZ & LUXENBERG Gary Klein, Esq. Attorneys for Plaintiffs SEAN YOUNG AND KIMBERLY YOUNG 700 Broadway, New York, NY 10003 Gklein@weitzlux.com CORREIA, KING, McGINNIS & LIFERIEDGE Vincent Brescia, Esq. Attorneys for Defendants JAMESTOWN 450 WEST 15TH STREET, L.P. and JAMESTOWN PROPERTIES CORP. One Battery Park Plaza 29th Floor New York, NY 10004 Vincent.Brescia@LibertyMutual.com MORRIS, DUFFY, ALONSO, FALEY & PITCOFF William J. Manning, Jr., Esq. Attorneys for Third-Paryt Defendant BRODERVILLE PICTURES 101 Greenwich Street, 22nd Floor New York, NY 10006 (212) 766-1888 File No.: (FIF) 74103 7 of 291 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 EXHIBIT “A” 8 of 291 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 Prepare. Protect. Prevail. THE HARTFORD Business Insurance EmployeeBenefits Auto HCITS April 16, 2021 Re: Insured: MILK STUDIOS LLC Policy Number: 13 UUN BI5740 Term: 11/03/2017 - 11/03/2018 Policy Writing Company: HARTFORD FIRE INSURANCE COMPANY This will verify that, to the best of the undersigneds knowledge, the attached is a complete and accurate representation of insurance policy referenced above. Documents and/or information produced herewith are kept and maintained in the ordinary course of business. Kyona Lawrence Operations Support Specialist Clinton Business Center Hartford Office Location 301 Woods Park Dr. Clinton, NY 13323 Toll Free: 888-525-2652 Fax: 866-809-1178 9 of 291 PCN: 30014202104182000460 DCN: 30014202104182000460001 Received Date/Time: 4/18/2021 7:53:44 AM Page 3 of 239 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 Important Information For New York Property Owners and Tenants As a result of New York Labor Law Section 240, you may be liable for injuries to contractors you hire to do work at or on your property. Learn more about this law and what you can do to reduce your risk. As a New York property owner or a tenant who hires contractors to repair, alter, paint, erect, demolish, clean or point a building or structure under New York Law Section 240, you may be liable for injuries sustained by the contractor's workers who fallfrom heights or who are struck by falling objects. This law places responsibility for worksite safety on owners and tenants who hire contractors. Liability under New York Labor Law Section 240 may be imposed regardless of whether the property owner exercised supervision or control over the injured worker. Examples of Claims and Lawsuits Contractors often work at heights and use ladders, scaffolding or other devices in order to get a job done. Itwould not be uncommon for a contractor's employee (injured in a fall from a height on your property) to bring a legal action against you or your company. Examples of situations that resulted in a claim and/or lawsuit under Section 240 of the New York Labor Law include: o A maintenance worker fellfrom a ladder and was injured while taking down ceiling tilesfor a store owner to correct a drafty condition created by improperly installed ceiling insulation. o Trade Association hired a contractor to assist in installinga stage. an Plaintiff, employee of the contractor, fellfour feet and was injured. o A worker was injured when he fellfrom an elevated height while removing and replacing piping for a machine oilsupply and return system for our manufacturing risk. o A worker was injured in a fall from a steel beam. There was no scaffold beneath the beam. In each of these cases, the property owner or business owner was alleged to be liable based on the fact that they had hired a contractor to do work. Impact on Insurance Coverage Claims and lawsuits under Section 240 of the New York Labor Law may have an adverse effect on your company's finances and insurance program. o The most significant risk isa judgment against your company in excess of your policy's limitof liability. Some claims based on this law have been $1 millionor more. o Your future insurance premiums may increase as a resultof lawsuits against your company. o Because favorable claim history is a key component of your insurability, insurance liability may become difficult to obtain. Form 106373 Page 1 of 2 © 2016, The Hartford 10 of 291 PCN: 30014202104182000460 DCN: 30014202104182000460001 Received Date/Time: 4/18/2021 7:53:44 AM Page 4 of 239 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 Reducing Your Risk There are a few simple risk management techniques that should be considered in consultation with your attorney or insurance agent to help reduce the chances of your business being involved in litigation: 1. Prior to the start of any work, have a written contract in place that includes an appropriate indemnification clause. Ensure that all contracts and indemnification clauses are reviewed by a qualified attorney priorto signing. "primary" "non-contributory" 2. Be named as a and Additional Insured on the contractor's General Liability Policy. This method of transferring risk could be significantin the event of a loss. 3. Only hire reputable contractors to perform work of any kind on your property, whether owned or leased. Pre-qualify contractors by reviewing previous work, securing recommendations from previous customers, reviewing the contractor's financial condition, inquiring about past losses, and ensuring the contractor has adequate and Workers' appropriate insurance coverage, including Compensation coverage. 4. Require all contractors you hireto strictlyfollow allOSHA and NY State Industrial Regulations. Ensure that the contractor is aware of the applicable regulations and laws that apply to thisexposure. Taking these simple steps willhelp minimize the possibility of the New York Labor Law having an adverse effect on your company's finances and insurance program, as a result of hiring a contractor. For more business' information about how The Hartford can help meet your risk management and insurance needs, please contact your agent. New York Labor Law Section 240 (1) provides, in part, as follows: "Allcontractors and owners and their agents, except owners of one and two-family dwellings who contract for but do not direct or control the work, in the erection, demolition, repairing, altering, painting, cleaning or pointing of a building or structure shallfurnish or erect, or cause to be furnished or erected for the performance of such labor, scaffolding, hoists, stays, ladders, slings, hangers, blocks, pulleys, braces, irons, ropes and other devices which shall be so constructed, placed and employed." operated as to give proper protection to a person so The informationprovidedabove is ofa generalnatureand may legal not be considered advice.The content of this document may omit certaindetails and cannot be regarded as advicethat would be applicabletoallbusinesses. As such, thisinformationis provided forinformationalpurposes only Readers seeking resolution of specificsafety,legalor businessissues or concerns regardingthistopicshould consulttheirsafetyconsultant, attorneyand/or business advisorsThe information presented isnot a for substitute a thorough loss control survey of yourbusinessor operationsor an analysis of the or appropriateness legality of your business practices.We do not warrantthat the implementationof any view or recommendation contained herein will be an appropriatelegalor business practice. we Further, do not warrantthatthe implementation of any viewor recommendation will avoid any or all liability. THE HAR T FOR D Form 106373 Page 2 of 2 11 of 291 PCN: 30014202104182000460 DCN: 30014202104182000460001 Received Date/Time: 4/18/2021 7:53:44 AM Page 5 of 239 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 IMPORTANT NOTICE TO POLICYHOLDERS THE HARTFORD CYBER CENTER WEBSITE ACCESS Thank you for choosing The Hartford for your business insurance needs. You are receiving thisNotice because you purchased a general or liability property policy from The Hartford, which includes access to The Hartford Cyber Center. This portal was created because we recognize that businesses face a variety of cyber-related exposures and need help managing the related risks. These exposures include data breaches, computer virus attacks and cyber extortion threats. Through the Hartford Cyber Center, you have access to: o A panel of thirdparty incident response service providers o Third party cybersecurity pre-incident service providers and a listof approved services to help protect your business before a cyber-threat occurs o Risk management tools, including self-assessments, best practice guides, templates, sample incident response plans, and data breach cost calculators o White papers, blogs and webinars from leading privacy and security practitioners o Up-to-date cyber-related news and events, including examples of privacy and security related events Accessing The Hartford Cyber Center iseasy 1. Visitwww.thehartford.com/cybercenter 2. Enter policyholder information 3. Access code: 952689 4. Login to The Hartford Cyber Center Please be aware that: o The Hartford Cyber Center is a proprietary web portal exclusively provided to customers of The Hartford. Please do not share the access code with anyone outside your organization. o Registration is required to access the Cyber Center. You may register as many users as necessary. o Contacting a service provider about any issue does not constitute providing The Hartford notice of a claim as required under your insurance policy. Read your insurance policy and discuss any questions with your agent or broker. o The Hartford Cyber Center provides third party service provider references and materials for educational purposes only. The Hartford does not specifically endorse any such service provider within The Hartford Cyber Center and hereby disclaims all with liability respect to use of or reliance on such service providers. AII service providers are independent contractors and not agents of The Hartford. The Hartford does not warrant the performance of the service providers, even ifsuch services are covered under your policy. providers' We strongly encourage you to conduct your own assessments of the service services and the fitness or adequacy of such services for your particular needs. This Notice does not amend or otherwise affectthe provisions of your policy. The Hartford offers a variety of endorsements to your policy that can help protect your business from a broad range of cyber-related threats. Please review your coverage with your insurance agent or broker to determine the most appropriate cyber coverages and limitsfor your business. Ifyou have a claim, you can report it bycalling The Hartforos toll-freeclaims line at 1-800-327-3636. Should you have any questions, please contact your insurance agent, broker or you may contact us directly. We appreciate your business and look forward to being of continued service to you. Form G-4033-1 (07/16 ED.) Page 1 of 1 © 2016, The Hartford 12 of 291 PCN: 30014202104182000460 DCN: 30014202104182000460001 Received Date/Time: 4/18/2021 7:53:44 AM Page 6 of 239 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 Insurance Policy Billing Information Thank you for selecting The Hartford for your business insurance needs. Shortly, you will receive your first bill from us. You are receiving this Notice so you know what to expect as a valued customer of The Hartford. Should you have any questions after reviewing this information, please contact us at 866-467-8730, and we will be happy to assist you. o Your total policy premium will appear on your policy's Declarations Page. You willbe billedbased on the payment plan you selected. due" o You may pay the "minimum as it appears on your insurance billor pay the policy balance in full. due" o An installment service fee is added to each installment. A latefee willalso be applied ifthe "minimum is not received by the due date shown on your bill. Service and late payment fees do not apply in allstates. o Ifyou selected installment billing,any credit or additional premium due as the result of a change made to your policy, willbe spread over the remaining billinginstallments. Additional premium due as a result of an audit willbe billedin fullon your next bill date following the completion of the audit. o Ifyou elected Electronic Funds Transfer (EFT), policy changes may result inchanges to the amount automatically withdrawn from your bank account. The invoice you receive following a policy change will include future withdrawal amounts, Ifyou need to adjust or stop your next scheduled EFT withdrawal, please contact us at least 3 days prior to the scheduled withdrawal date at the telephone number shown below. o Ifyou selected installment billingand pay the premiums for your firstpolicy term on time, at renewal, your account Installment" may qualifyfor our "Equal feature. This means that the percentage due for each installment, including the initialrenewal installment, willbe the same throughout the term - you better manage cash flow. policy helping Equal installments willcontinue as long as you pay your premiums on time and no cancellation notices are issued for any policy on your account. Ifyou no longer qualify for Equal Installments, future renewals willbe billedbased on the payment plan you selected, which includes a higher initial installment amount. o Ifyour policy is eligiblefor renewal, your billforthe upcoming policy term will be sent to you approximately 30 days prior to your policy's renewal date. Ifyour insurance needs change, please contact us at least 60 days priorto your renewal date so we can properly address any adjustments needed. o One billconvenience -- you have the option of all eligibleHartford policies on one single bill combining allowing you tomake one payment for allpolicies on your account as payments are due. You're In Control In addition to selecting a bill plan option that best meets your budget, you have the to flexibility decide how your payments are made ... o Repetitive EFT: Sign up for Repetitive EFT payments and have payments automatically withdrawn from your bank account. This option saves you money by reducing the amount of the installment service fee. o Pay Online: Register at www.thehartford.com/servicecenter. Online BillPay isQuick, Easy and Secure! o Pay by Check: Send a check with your remittance stub in the envelope provided with your bill. o Pay by Phone: Call toll-free1-866-467-8730. Should you have any questions about your bill,please call Customer Service toll-free number: 1-866-467-8730 - 7AM - 7PM CST. We look forward to of service to you. being Form 100722 11th Rev. Printed in U.S.A. 13 of 291 PCN: 30014202104182000460 DCN: 30014202104182000460001 Received Date/Time: 4/18/2021 7:53:44 AM Page 7 of 239 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 Special Multi-Flex Business Insurance Policy THE HARTFORD Form HM 00 01 03 14 Page 1 of 1 14 of 291 PCN: 30014202104182000460 DCN: 30014202104182000460001 Received Date/Time: 4/18/2021 7:53:44 AM Page 8 of 239 FILED: NEW YORK COUNTY CLERK 08/22/2022 01:10 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 08/22/2022 This SPECIAL MULTI-FLEX POLICY is provided by the stock insurance company(s) of The Hartford Insurance Group, shown below. COMMON POLICY DECLARATIONS POLICY NUMBER: 13 UUN BI5740 DB Tun RENEWAL OF: 13 UUN BI5740 HARTFORD Named Insured and Address: MILK STUDIOS LLC Mailing (No., Street, Town, State, SEE IH1204 Zip Code) 450 W 15TH ST NEW YORK , NY 10011 (NEW YORK COUNTY) Period: From 11/03/17 To 11/03/18 Policy 12:01 A.M. , Standard time at your address shown above. mailing In return for thepayment of the premium, and subject to allof the terms of thispolicy, we agree with you to provide insurance as stated in thispolicy. The Coverage Parts that are a part of thispolicy are listedbelow. The Advance Premium shown may be subject to adjustment. Total Advance Premium: Coverage Part and insurance Company Summary Advance Premium PROPERTY CHOICE HARTFORD FIRE INSURANCE COMPANY ONE HARTFORD PLAZA HARTFORD, CONNECTICUT 06155 COMMERCIAL INLAND MARINE HARTFORD FIRE INSURANCE COMPANY ONE HARTFORD PLAZA HARTFORD, CONNECTICUT 06155 LISTING OF ADDITIONAL COVERAGE PARTS CONTINUED ON THE FOLLOWING PAGE, Form Numbers of Coverage Parts, Forms and Endorsements that are a part of this policy and that are not listed in the Coverage Parts. HM0001 IL00171198 IH00010795 IH01150795 IHO9850115 IH12040312 1H99400409 LISTING OF ADDITIONAL FORM NUMBERS CONTINUED ON A SUBSEQUENT PAGE. Agent/BrokerName: WORLD INSURANCE ASSOCIATES LLC Countersigned by 11/17/17 (Where required by law) Authorized Representative Date