Exhibit,Appendix: Manuel Melo v. Tphgreenwich Owner Llc, Gilbane Residential Construction, Llc, Accura Restoration & Waterproofing, Llc

On November 26, 2019 a Exhibit,Appendix was filed involving a dispute between Manuel Melo, and Accura Restoration & Waterproofing, Llc, Gilbane Residential Construction, Llc, Tphgreenwich Owner Llc, for Torts - Other (Labor Law) in the District Court of Queens County.

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FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022

April 19, 2022
Via Certified and Regular Mail and Via E-Mail
9489 0090 0027 6374 5178 36
bgilmartin@goldbergsegalla.com
Brendan B. Gilmartin, Esq.
Goldberg Segalla LLP
711 3rd Ave., Ste. 1900
New York, NY 10017

Re: Manuel Melo v. TPHGreenwhich Owner LLC, Gilbane Residential Construction LLC, and Accura
Restoration & Waterproofing, LLC
Named Insured: Hiline Construction Inc; KNG Builders Inc
Policy No.: USA 4262428
Date of Loss: October 10, 2019
Claim No.: 33-022188

Dear Mr. Gilmartin:

As you know, I am a Claims Representative with Meadowbrook, Inc. and I have been assigned to oversee the
above matter on behalf of United Specialty Insurance Company (“USIC”). USIC provided a Commercial Excess
Liability policy for Hiline Construction Inc. for the April 7, 2019 through April 7, 2020 policy period. This policy is
excess to a Commercial General Liability policy issued by AXIS Surplus Insurance Co (“AXIS”).

It is our understanding that AXIS accepted the tender of TPHGreenwich Owner LLC, Gilbane Residential
Construction LLC, and Accura Restoration & Waterproofing LLC and agreed to defend and indemnify these
parties as additional insureds on a primary and non-contributory basis. This letter will supplement our August
23, 2021 correspondence advising of our coverage position with respect to these parties. Upon review of the
facts and the above referenced policy we have determined that there is no coverage for this claim for Hiline
Construction Inc or any other party. As you know, the excess policy issued by United Specialty Insurance
Company contains an exclusion for injury or damaged sustained by an employee of Hiline arising out of an in
the course of his employment by Hiline or performing duties related to the conduct of Hiline’s Business.
Accordingly, because Mr. Melo was an employee of Hiline there is no coverage for this accident. Additionally,
United Specialty Insurance Company’s excess policy contains an exclusion for injury or damage included within
the scaffolding hazard. Accordingly, because Mr. Melo’s alleged injuries arise out of the scaffolding hazard there
is no coverage for this accident. As such, we must maintain our previous coverage position and deny your tender
request on behalf of TPHGreenwich Owner LLC, Gilbane Residential Construction LLC, and Accura Restoration
& Waterproofing LLC. United Specialty Insurance Company must decline to extend defense or indemnification
to your clients in this matter.

Our coverage position is fully outlined in the attached Supplemental Coverage Disclaimer letter addressed to
our insured.

If you have any questions or concerns, please do not hesitate to contact me at any time.

Rachael Hummel
Claims Representative II
Rachael.Hummel@ameritrustgroup.com
Mailing Address: P.O. Box 219559 Kansas City, MO 64121-9559
Phone: 800-825-9489 Fax: 913-549-1648 Direct Line: 913-266-5145

www.ameritrustgroup.com
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 2 of 2

Sincerely,

UNITED SPECIALTY INSURANCE COMPANY

Rachael Hummel AIC
Claims Representative

RH/pjh

Enclosure: Supplemental Disclaimer Of Coverage 4-19-22

cc: Hiline Construction Inc
335 Calyer Street
Brooklyn NY 11222
Via email to: solomon@hilineconstruction.nyc

IGI Insurance Agency Inc.
199 Lee Avenue Suite 475
Brooklyn, NY 11211

Bass Underwriters Inc
150 Motor Parkway Suite 410
Hauppauge NY 11788

Daniel P. Miklos, Esq.
Silberstein, Awad & Miklos, P.C.
600 Old Country Rd
Garden City, NY 11530
Attorneys for Plaintiff
Via email to: dmiklos@ask4sam.net

TPH Greenwich Owner LLC
340 Madison Ave, Suite 3C
New York, NY 10173

Gilbane Residential Construction LLC
111 8th Ave
New York, NY 10011

Accura Restoration & Waterproofing LLC
49-11 31st Street
Long Island City, NY 11101

WARNING
"Any person who knowingly and with intent to defraud any insurance company files an application for insurance or
statement of claim containing any materially false information or conceals for the purpose of misleading, information
concerning any fact material thereto commits a fraudulent insurance act, which is a crime and subjects such person to
criminal and civil penalties."
Revised 01/2013
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022

April 19, 2022
Certified, Regular Mail and Email
9489 0090 0027 6374 5178 43
solomon@hilineconstruction.nyc
Hiline Construction Inc
335 Calyer Street
Brooklyn NY 11222

SUPPLEMENTAL DISCLAIMER OF COVERAGE

Dear Solomon,

I am a Claims Representative with Meadowbrook, Inc. and I have been assigned to oversee the above matter
on behalf of United Specialty Insurance Company, (“USIC”). USIC is in receipt of the above referenced Complaint
filed by Manuel Melo.

USIC provided a Commerical Excess Liability policy (USA 4262428) to Hiline Construction Inc. (“Hiline”) for the
April 7, 2019 through April 7, 2020 policy period. The policy issued by USIC is excess to an Excess Liability
policy issued by AXIS Surplus Insurance Co (“AXIS”) with loss limits of $ per occurrence.

This letter will supplement our previous Partial Disclaimer of Coverage which was issued on August 23, 2021.
Upon investigation and careful review of the facts and the above-referenced policy, we have determined that
there is no coverage for this claim. As such, USIC hereby declines to provide either a defense or indemnity to
Hiline Construction or any other party for this claim. Please read this letter carefully for a more detailed
explanation of USIC’s coverage position.

I. FACTUAL BACKGROUND

The following facts are based in large part upon the allegations contained in the above referenced Complaint.
The allegations are reviewed here simply for the purpose of explaining USIC’s coverage position. USIC’s review
of those allegations should not be construed as a comment on their truthfulness as USIC does not mean to
assert that any or all of the allegations contained in the Complaint are true. That said, please advise us if you
believe that we have misunderstood or misconstrued those allegations.

According to the Complaint, there was an ongoing construction, renovation, and demolition project at the
premises located at 42 Trinity Place New York, NY. The Complaint alleges that the named Defendants contracted

Rachael Hummel
Claims Representative II
Rachael.Hummel@ameritrustgroup.com
Mailing Address: P.O. Box 219559 Kansas City, MO 64121-9559
Phone: 800-825-9489 Fax: 913-549-1648 Direct Line: 913-266-5145

www.ameritrustgroup.com
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 2 of 9

with Hiline Construction for work at the construction project. Plaintiff alleges that on or about October 10, 2019,
he was caused to suffer serious and permanent injuries as a result of an unsafe work environment.

According to Plaintiff’s Verified Bill of Particulars, a copy of which was received by USIC on April 7, 2022, plaintiff
was on a scaffold at an elevated height when he was caused to fall. Plaintiff alleges he sustained various injuries
to his lumbar spine, cervical spine, right shoulder, right knee/hip/leg, and left knee. Plaintiff further alleges that
he was employed by Hiline Construction at the time of the accident and had been working for them for 6 months
prior to the accident.

II. THE POLICY

USIC issued an Excess Commercial Liability policy of insurance to Hiline Construction Inc; KNG Builders Inc.
bearing policy number USA4262428 with effective dates of April 7, 2019 through April 7, 2020 (“the Policy”). The
Policy’s ultimate net loss limit of liability is each occurrence with an aggregate limit of .
This coverage is excess to the underlying Commercial General Liability Policy issued by AXIS Surplus Insurance
Co. with a per occurrence limits of .

Policy USA 4264248 contains the following forms, in pertinent part.

CX 00 01 04/13

COMMERCIAL EXCESS LIABILITY COVERAGE FORM

Various provisions in this policy restrictcoverage. Read the entire policy carefully to determine rights,
duties and what is and is not covered.
....

The insurance provided under this Coverage Part will follow the same provisions, exclusions and limitations
that are contained in the applicable “controlling underlying insurance”, unless otherwise directed by this
insurance. To the extent such provisions differ or conflict, the provisions of this Coverage Part will apply.
However, the coverage provided under this Coverage Part will not be broader than that provided by the
applicable “controlling underlying insurance”.

There may be more than one “controlling underlying insurance” listed in the Declarations and provisions in
those policies conflict, and which are not superseded by the provisions of this Coverage Part. In such a
case the provisions, exclusions and limitations of the “controlling underlying insurance” applicable to the
particular “event” for which a claim is made or suit is brought will apply.

SECTION I – COVERAGES
1. Insuring Agreement
a. We will pay on behalf of the insured the "ultimate net loss" in excess of the "retained limit" because
of "injury or damage" to which insurance provided under this Coverage Part applies.
We will have the right and duty to defend the insured against any suit seeking damages for such
"injury or damage" when the applicable limitsof "controlling underlying insurance" have been
exhausted in accordance with the provisions of such "controlling underlying insurance".
When we have no duty to defend, we will have the right to defend, or to participate in the defense
of, the insured against any other suit seeking damages for "injury or damage".
However, we will have no duty to defend the insured against any suit seeking damages for which
insurance under this policy does not apply.
At our discretion, we may investigate any "event" that may involve this insurance and settle any
resultant claim or suit, for which we have the duty to defend.
But:
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 3 of 9

(1) The amount we will pay for "ultimate net loss" is limited as described in Section II – Limits Of
Insurance; and
(2) Our right and duty to defend ends when we have used up the applicable limit of insurance in
the payment of judgments or settlements under this Coverage Part. However, if the policy of
"controlling underlying insurance" specifies that limits are reduced by defense expenses, our
right and duty to defend ends when we have used up the applicable limit of insurance in the
payment of defense expenses, judgments or settlements under this Coverage Part.
b. This insurance applies to "injury or damage" that is subject to an applicable "retained limit". If any
other limit, such as, a sublimit, is specified in the "controlling underlying insurance", this insurance
does not apply to "injury or damage" arising out of that exposure unless that limit is specified in the
Declarations under the Schedule of "controlling underlying insurance".
c. If the "controlling underlying insurance" requires, for a particular claim, that the "injury or damage"
occur during its policy period in order for that coverage to apply, then this insurance will only apply
to that "injury or damage" if it occurs during the policy period of this Coverage Part. If the "controlling
underlying insurance" requires that the "event" causing the particular "injury or damage" takes place
during its policy period in order for that coverage to apply, then this insurance will apply to the claim
only ifthe "event" causing that "injury or damage" takes place during the policy period of this
Coverage Part.
d. Any additional insured under any policy of "controlling underlying insurance" will automatically be
an additional insured under this insurance. If coverage provided to the additional insured is required
by a contract or agreement, the most we will pay on behalf of the additional insured is the amount
of insurance required by the contract, less any amounts payable by any "controlling underlying
insurance".
Additional insured coverage provided by this insurance will not be broader than coverage provided
by the "controlling underlying insurance".

....

SECTION III – CONDITIONS
The following conditions apply. In addition, the conditions applicable to any "controlling underlying
insurance" are also applicable to the coverage provided under this insurance unless superseded by the
following conditions.

7. Maintenance Of/Changes To Controlling Underlying Insurance
Any "controlling underlying insurance" must be maintained in full effect without reduction of coverage
or limits except for the reduction of aggregate limits in accordance with the provisions of such
"controlling underlying insurance" that results from "injury or damage" to which this insurance applies

10. Loss Payable
Liability under this Coverage Part does not apply to a given claim unless and until:
a. The insured or insured's "controlling underlying insurer" has become obligated to pay the "retained
limit"; and
b. The obligation of the insured to pay the "ultimate net loss" in excess of the "retained limit" has been
determined by a final settlement or judgment or written agreement among the insured, claimant,
"controlling underlying insurer" (or a representative of one or more of these) and us.

12. Transfer Of Defense
a. Defense Transferred To Us
When the limits of "controlling underlying insurance" have been exhausted, in accordance with the
provisions of "controlling underlying insurance", we may elect to have the defense transferred to
us. We will cooperate in the transfer of control to us of any outstanding claims or suits seeking
damages to which this insurance applies and which would have been covered by the "controlling
underlying insurance" had the applicable limit not been exhausted.
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 4 of 9

b. Defense Transferred By Us
When our limits of insurance have been exhausted our duty to provide a defense will cease.

SECTION IV – DEFINITIONS
The definitions applicable to any "controlling underlying insurance" also apply to this insurance. In addition,
the following definitions apply.
1. "Controlling underlying insurance" means any policy of insurance or self-insurance listed in the
Declarations under the Schedule of "controlling underlying insurance".
2. "Controlling underlying insurer" means any insurer who provides any policy of insurance listed in the
Declarations under the Schedule of "controlling underlying insurance".
3. "Event" means an occurrence, offense, accident, act, or other event, to which the applicable "controlling
underlying insurance" applies.
4. "Injury or damage" means any injury or damage, covered in the applicable "controlling underlying
insurance" arising from an "event".
5. "Retained limit" means the available limits of "controlling underlying insurance" applicable to the claim.
6. "Ultimate net loss" means the total sum, after reduction for recoveries, or salvages collectible, that the
insured becomes legally obligated to pay as damages by reason of:
a. Settlements, judgments, binding arbitration; or
b. Other binding alternate dispute resolution proceeding entered into with our consent.
"Ultimate net loss" includes defense expenses if the "controlling underlying insurance" specifies
that limits are reduced by defense expenses.

* * *
(CXL 1157 0614)

THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY.

LIMITATION-SCAFFOLDING HAZARD

This endorsement modifies insurance provided under the following:

COMMERCIAL EXCESS LIABILITY COVERAGE FORM

A. The following exclusions are added to Section I- Coverages, paragraph 2., Exclusions

This insurance does not apply to:

Scaffolding Hazard

Insurance provided under this Coverage Form does not apply and there will be no duty to defend or
indemnify any entity for "bodily injury" and any resulting damage included within the scaffolding hazard.

However, this exclusion does not apply:
1. To "injury or damage" included within the "products-completed operations hazard"; or

2. If no insured or any other entity was cited for violation(s) relating to:

a. The Code of Federal Regulations, Title 29. Labor, Subtitle B. Regulations Relating to Labor,
Chapter XVII. Occupational Safety and Health Administration, Department of Labor, Part 1926.
Safety and Health Regulations for Construction, Subpart L., Scaffolds; or
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 5 of 9

a. Any other applicable occupational safety oversight and enforcement agency's standards
relating to scaffolding erection, use or maintenance.

B. For the purposes of this endorsement, the following definitions apply.

1. Scaffolding hazard includes "injury or damage" arising out of the use of any temporary or moveable
platform(s) for worker(s) to stand or sit on when working at a height above the ground or floor.

2. Products-completed operations hazard:
a. Includes all "injury or damage" occurring away from premises you own or rent and arising out of
"your product" or "your work" except:

(1) Products that are still in your physical possession; or

(2) Work that has not yet been completed or abandoned. However, "your work" will be deemed
completed at the earliest of the following times:
(a) When all of the work called for in your contract has been completed.
(b) When all of the work to be done at the job site has been completed if your contract calls
for work at more than one job site.
(c) When that part of the work done at a job site has been put to its intended use by any
person or organization other than another contractor or subcontractor working on the
same project.
Work that may need service, maintenance, correction, repair or replacement, but which
is otherwise complete, will be treated as completed.
b. Does not include "injury or damage" arising out of:
(1) The transportation of property, unless the "injury or damage" arises out of a condition in or
on a vehicle not owned or operated by you, and that condition was created by the loading
or unloading of that vehicle by any insured; or
(2) The existence of tools, uninstalled equipment or abandoned or unused materials.

3. Loading or unloading means the handling of property:
a. After itis moved from the place where itis accepted for movement into or onto an aircraft,
watercraft, or "auto"; or
b. While it is in or on an aircraft, watercraft or "auto"; or
c. While it is being moved from an aircraft, watercraft or auto to the place where it is finally delivered;
but loading or unloading does not include the movement of property by means of a mechanical
device, other than a hand truck, that is not attached to the aircraft, watercraft or "auto".

All other terms and conditions of this policy remain unchanged.

* * *

Action Over Exclusion (CXL 1185 0214)

EXCLUSION – ACTION OVER

This endorsement modifies insurance provided under the following:

COMMERCIAL EXCESS LIABILITY COVERAGE FORM

SCHEDULE

State(s): New York
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 6 of 9

The following exclusion is added to Section I – Coverages, paragraph 2., Exclusions.

Insurance provided under this Coverage Part does not apply to:
Employer’s Liability
“Injury or damage”, sustained in the state(s) identified in the Schedule above, to:
(1) An “employee” of the Named Insured arising out of and in the course of:
(a) Employment by the Named Insured; or
(b) Performing duties related to the conduct of the Named Insured’s business; or
(2) The spouse, child, parent, brother or sister of that “employee” as a consequence of paragraph
(1) above.
This exclusion applies:
(1) Whether the Named Insured may be liable as an employer or in any other capacity; and
(2) To any obligation to share damages with or repay someone else who must pay damages
because of the “injury or damage”.

All other terms and conditions of this policy remain unchanged.

* * *

CXL 1136a 0215

EXCLUSION – BODILY INJURY TO INDEPENDENT CONTRACTORS –
DESIGNATED STATES

This endorsement modifies insurance provided under the following:

COMMERCIAL EXCESS LIABILITY COVERAGE FORM

SCHEDULE
State(s):
New York, Oregon and Texas

A. The following is added to Section I – Coverages, paragraph 2., Exclusions.
This insurance provided under this Coverage Form does not apply to:
Independent Contractors
“Injury or damage”, sustained in the state(s) identified in the Schedule above, to any:
(1) Independent contractor or the “employee” of any independent contractor; while such independent
contractor or their “employee” is working directly or indirectly on behalf of any insured; or
(2) The spouse, child, parent, brother or sister of such independent contractor or employee or volunteer
worker of the independent contractor and a consequence of (1) above.

This exclusion applies:
(1) Whether the insured may be liable as an employer or in any other capacity; and
(2) To any obligation to share damages with or repay someone else who must pay damages because
of “injury or damage”.
B. For the purposes of this endorsement, independent contractor means any individual, natural person,
or entity, including but not limited to a general contractor, a prime contractor, or a subcontractor
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 7 of 9

performing any work, task, supervision, or other activity either directly or indirectly related to “your
work”, that:

(1) Receives payment or other consideration, is entitled to payment or other consideration, or can be
expected to seek payment or other consideration from any insured arising out of “your work”; or
(2) Receives payment or other consideration, is entitled to payment or other consideration, or can be
expected to seek payment or other consideration from any other entity, person, or party arising out
of “your work”, and
(3) Is not an “employee” of the Named Insured.

This definition applies regardless of the existence or alleged existence of a written or oral contract or
agreement with any insured or other doing work or performing tasks or duties for or on behalf of any
insured.

All other terms and conditions of this policy remain unchanged.

III. USIC’S COVERAGE POSITION

As previously mentioned in our August 23, 2021 correspondence, the excess USIC policy is governed by the
controlling underlying insurance policy issued by AXIS. The excess USIC policy states that the insurance
provided under this Coverage part will follow the same provisions, exclusions and limitations that are contained
in the applicable "controlling underlying insurance" unless otherwise directed by this insurance. To the extent
coverage is not provided by the underlying Excess Liability policy, coverage would likewise be precluded under
this excess policy.

The USIC policy further indicates that coverage under the USIC policy is available only when the limits of the
“controlling underlying insurance” are exhausted. In other words, even if the USIC excess policy afforded
coverage, there would be no coverage available under the USIC policy unless the coverage available to you by
the underlying policies is applied and exhausted.

Despite the coverage determination made by the “controlling underlying insurance” carrier we bring your
attention some exclusion and provisions contained in the excess policy which act to preclude coverage. As
previous mentioned in our August 23, 2021 Partial Disclaimer, the USIC policy contains form CXL 1185 0214,
which excludes coverage for bodily injury to Hiline’s Employees or individuals performing duties related to the
conduct of business of Hiline. Plaintiff’s Verified Bill of Particulars alleges that Manuel Melo was employed by
Hiline at the time of the accident. Accordingly, because Manuel Melo was an employee of Hiline there is no
coverage for this accident. This exclusion extends not only to Hiline but also to any other individual or entity
claiming coverage under Hiline’s policy with USIC, and we therefore disclaim coverage.

Next, please refer to form CXL 1157 0614 entitled Limitation-Scaffolding Hazard. This endorsement excludes
coverage for injury or damage included within the scaffolding hazard. The scaffolding hazard includes “injury or
damage” arising out of the use of any temporary or moveable platform(s) for worker(s) to stand or sit on when
working at a height above the ground or floor. Plaintiff’s Verified Bill of Particulars indicates that Plaintiff was on
a scaffold at an elevated height when he caused to fall. Accordingly, because Manuel Melo’s accident arises out
of the scaffolding hazard, coverage is disclaimed.

For each of these reasons, there is no coverage for this claim and USIC hereby declines to provide Hiline or any
other party with either a defense or indemnity in this matter. There may be other reasons why coverage does
not apply. As such, this letter should not be construed as waving any of USIC’s rights under the policy or
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 8 of 9

applicable law to limit and/or deny coverage. USIC maintains the right to rely on any additional facts, policy
provisions, or other relevant information that may affect coverage to alter its position in the future. We do not
waive our right to disclaim coverage for any other valid reason that may arise.

IV. CONCLUSION

USIC trusts that you understand its coverage position, but if you have any questions or concerns, please do not
hesitate to contact me. Further, if you believe we have omitted any relevant information or if you are aware of,
any additional information you believe may affect USIC’s coverage position, please contact us immediately.
USIC maintains the right to consider additional information and to reassess its coverage position should the
circumstances so warrant. Please do not hesitate to call if you have any questions or concerns.

Should you wish to take this matter up with the New York State Department of Financial Services, you may
do so by contacting the Department either via its website at http://www.dfs.ny.gov/consumer/fileacomplaint.htm
or you may write to or visit the Consumer Assistance Unit, Financial Frauds and Consumer Protection Division,
New York State Department of Financial Services, at: One State Street, New York, NY 10004; One Commerce
Plaza, Albany, NY 12257; 1399 Franklin Avenue, Garden City, NY 11530; or Walter J. Mahoney Office Building,
65 Court Street, Buffalo, NY 14202.

If you have any questions or concerns, please do not hesitate to contact me at any time.

Sincerely,

UNITED SPECIALTY INSURANCE COMPANY

Rachael Hummel AIC
Claims Representative

RH/pjh

cc: IGI Insurance Agency Inc.
199 Lee Avenue Suite 475
Brooklyn, NY 11211

Bass Underwriters Inc
150 Motor Parkway Suite 410
Hauppauge NY 11788

Brendan B. Gilmartin, Esq.
Goldberg Segalla LLP
Via email to: bgilmartin@goldbergsegalla.com

Daniel P. Miklos, Esq.
Silberstein, Awad & Miklos, P.C.
600 Old Country Rd
Garden City, NY 11530
Attorneys for Plaintiff
Via email to: dmiklos@ask4sam.net
FILED: QUEENS COUNTY CLERK 10/28/2022 01:03 PM INDEX NO. 720030/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 10/28/2022
Page 9 of 9

TPH Greenwich Owner LLC
340 Madison Ave, Suite 3C
New York, NY 10173

Gilbane Residential Construction LLC
111 8th Ave
New York, NY 10011

Accura Restoration & Waterproofing LLC
49-11 31st Street
Long Island City, NY 11101

WARNING
"Any person who knowingly and with intent to defraud any insurance company filesan application for insurance or
statement of claim containing any materially false information or conceals for the purpose of misleading, information
concerning any fact material thereto commits a fraudulent insurance act, which is a crime and subjects such person to
criminal and civil penalties."
Revised 01/2013

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Ulysses B Leverett Track Judge’s New Case

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Document Filed Date

October 28, 2022

Case Filing Date

November 26, 2019

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Exhibit,Appendix: Manuel Melo v. Tphgreenwich Owner Llc, Gilbane Residential Construction, Llc, Accura Restoration & Waterproofing, Llc

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