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FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/28/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
ANDIFRED REALTY CORP.,
Plaintiff,
Index No. 604900/2023
v.
NOTICE FOR DISCOVERY
THE CINCINNATI INSURANCE COMPANY, AND INSPECTION
FINESSE CARPENTRY and BRYAN HENN d/b/a OF DOCUMENTS
FINESSE CARPENTRY,
Defendants.
PLEASE TAKE NOTICE that pursuant to CPLR Article 31, Defendant, The Cincinnati
Insurance Company (“Cincinnati”) hereby requests that Plaintiff produce at the offices of Horst,
Krekstein & Runyon LLC, 80 Broad Street, 5th Floor, New York, NY 10004, within thirty (30)
days of the date hereof, the following documents for discovery, inspection and copying by
Defendant, Cincinnati, its attorneys or other representatives.
DEFINITIONS
The following definitions are applicable to each Demand:
(a) The term “DOCUMENT,” as used herein, means the original, any drafts and all
copies of all written, printed, typed or other graphic matter of any kind or nature,
whether sent or received or neither, and any other tangible thing in your possession,
custody or control or known by you to exist, including but not limited to:
(i) all contracts, agreements, letter agreements, representations, warranties,
certifications and opinions;
(ii) all letters or other forms of correspondence or communications, including
envelopes and notes, e-mails, telegrams, cables, telex messages, phone
messages, facsimile transmissions (faxes), reports, notes, notations and
memoranda of or relating to telephone conversations, meetings or
conferences;
(iii) all memoranda, reports, test results, financial statements or reports, notes,
scripts, transcripts, tabulations, studies, analysis, evaluations, projections,
work-papers, corporate records or copies thereof, expressions or statements
or policy, lists, comparisons, questionnaires, surveys, charts, graphs,
summaries, extracts, statistical statements or records, compilations and
opinions or reports of consultants;
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(iv) all desk calendars, appointment books and diaries;
(v) all minutes, records or transcripts of meetings and conferences and lists of
persons attending meetings or conferences;
(vi) all reports and summaries of interviews and negotiations;
(vii) all books, articles, press releases, magazines, newspapers, booklets,
brochures, pamphlets, circulars, bulletins, notices, instructions and
manuals;
(viii) all motion pictures and photographs (whether developed or undeveloped),
tape recordings, microfilms, phonographs or other records, punch-cards,
magnetic tapes, disks, data cells, drums, printouts and other data
compilations from which information can be obtained; and
(ix) drafts of any document revisions or drafts of any documents and original or
preliminary notes.
(b) The terms “RELATE(S) TO” or “RELATING TO,” as used herein, mean to
constitute, refer to, reflect, concern, pertain to or in any way logically or factually
connect with the matter described in the Demand.
(c) The term “COMMUNICATIONS,” as used herein, means all statements,
admissions, denials, inquiries, discussions, conversations, negotiations, documents,
agreements, contracts, understandings, meetings, telephone conversations, letters,
emails, correspondence, notes, telegrams, telexes, facsimile transmissions (faxes),
advertisements, or any other form of written or verbal intercourse.
(d) Unless otherwise indicated by the context, the term “IDENTIFY” or “IDENTITY,”
as used herein:
(i) when referring to a document, shall require identification of such document
by furnishing a brief description of the document, its title or identifying
symbol, its date, name and address of persons originating, name and address
of persons (if any) to whom it was directed, the location thereof and its
present custodian;
(ii) when used in connection with an oral communication, shall require
identification of each person by whom and to whom such communication
was made, and the parties in whose presence such statement,
communication or utterance was given or transmitted, the date it was made,
whether it was made by telephone, and the place at which each person was
located;
(iii) when used in referring to a person, shall require furnishing the following
information concerning such person:
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(1) full name;
(2) age;
(3) the current or last known business and home addresses;
(4) the current or last known employment position (the current or last
known business title); and
(5) the current or last known telephone number.
(e) The term “PERSON,” as used herein, means any natural person, partnership,
corporation or other business entity and all present and former officers, directors,
agents, employees, representatives, attorneys and others acting or purporting to act
on behalf of such natural person, partnership, corporation or other business entity.
(f) The singular shall include the plural and the plural shall include the singular.
(g) The masculine, feminine or neuter pronoun shall not exclude the other genders.
(h) The term “DATE OF LOSS,” as used herein, refers to the date(s) of loss identified
in Plaintiffs’ Complaint, or if no such date appears in Plaintiffs’ Complaint, the
date(s) identified in these responses as the date(s) of the alleged incident or
damages.
(i) The word “OR” means “AND/OR.”
(j) The term “LITIGATION,” means the case captioned as Andifred Realty Corp. v.
The Cincinnati Insurance Company, Finesse Carpentry and Bryan Henn d/b/a
Finesse Carpentry, Index No. 604900/2023, Supreme County of the State of New
York, County of Nassau.
(k) The term “COMPLAINT” means the Complaint filed by Plaintiff in the Litigation
and any amendments.
(l) The term “PROPERTY” means the property located 240 Glen Head Road, Glen
Head New York 11545 and referenced in the Complaint.
(m) The term “POLICY” refers to the commercial insurance policy, number ENP 055
01 09, effective September 1, 2021 to September 1, 2022, issued to Plaintiff by
Cincinnati.
(n) The term “CLAIM” refers to the insurance claim made by Plaintiffs to Defendant
The Cincinnati Insurance Company that is the subject of the Litigation.
(o) The terms “YOU” and “YOUR” refer to Plaintiff Andifred Realty Corp., and each
of its employees, servants, heirs, attorneys, agents, representatives and/or person
acting for each of them or on their behalf in any capacity.
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INSTRUCTIONS
(a) Work Product or Privilege. With respect to each such document, oral statement, or
communication inquired about in any Request for Production of Documents that
you claim to be privileged or to constitute work product:
(i) identify the document, oral statement, or communication to the fullest
extent possible;
(ii) include the date, maker, recipient, and type of document (e.g., letter,
memoranda); and
(iii) the specific basis of the claim of privilege or work product for each
document.
(b) Data Stored on Software or Other Media. In those instances where requested
information is stored only on software or other data compilations, you should either
produce the raw data along with all codes and programs for translating it into usable
form or produce the information in a finished usable form, which would include all
necessary glossaries, keys and indices for interpretation of the material.
(c) Cessation of Document Destruction. It is requested that all documents and/or other
data compilations that might impact on the subject matter of the Complaint and/or
the Litigation be preserved and that any ongoing process of document destruction
involving such documents cease.
(d) Organization of Responses. The documents shall be organized by you, labeled with
reference to the request to which they are responsive and produced in accordance
with the categories in the Request.
(e) Duty to Amend/Supplement. These Requests for Production of Documents are
deemed continuing in character, and if at any time Plaintiffs obtain information
which would make a prior answer inaccurate, incomplete or incorrect, Plaintiffs are
required to communicate said new information to the defendant through counsel.
This duty to amend continues up to the time of trial.
REQUESTS FOR PRODUCTION
1. All documents identified in or relating to your response to Defendant, Cincinnati’s Demand
for Bill of Particulars or in any deposition relating to the Litigation.
2. All documents related to the initial installation or construction of the Property’s roof.
3. All documents related to repairs, maintenance, remodeling, or reconstruction of the
Property’s roof prior to January 3, 2022.
4. All communications between Andifred and Finesse Carpentry or Bryan Henn related to the
roof, including prior to Finesse’s work on the roof in September 2019.
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5. All documents and communications relating to complaints or reports of roof leaks at the
Property.
6. All documents or communications between Andifred and any contractor, architect, or other
entity that performed work on or related to the Property’s roof.
7. Copies of all photographs and/or videos taken that relate to all claimed damages in the
Claim, the Complaint and Litigation.
8. All documents or communications between Andifred and Tim Stapleton or other
employees, agents, or individuals involved in the management of the Property related to
the Property’s roof, leaks, maintenance, or construction at the Property.
9. All documents or communications between Andifred and any third party, including but not
limited to any employees of the United States Postal Service, relating to complaints,
reports, or other correspondence relating to the Property’s roof or leaks within the interior
of the Property prior to January 3, 2022.
10. All documents supporting or relating to Plaintiff’s contention that the damage to the
Property’s roof constitutes a “Covered Loss” pursuant to the Policy, as alleged in
Paragraphs 1, 31, and 32 of the Complaint.
11. All documents supporting or relating to Plaintiff’s contention that Cincinnati’s denial of
coverage for the damage to the Property’s roof constitutes a breach of contract, as alleged
in Paragraph 34 of the Complaint, including identification of all specific provisions of the
Policy that you contend were breached.
12. If you contend that Defendant, Cincinnati, violated any law, statute, ordinance, rule, or
regulation, provide any and all documents which support each contention.
13. All of your diaries, logs, personal journals, or personal calendars, if any, that relate in any
way to the facts, claims, causes of action, allegations, or contentions against Defendant,
Cincinnati, set out in the Complaint.
14. The entire contents of any file(s) and any other documents in your possession that support
or relate to any claim for benefits you have made to Defendant, Cincinnati, regarding the
Claim that is the subject of Andifred’s Complaint.
15. The entire contents of any file(s) and any other documents in your possession that support
or relate to your claims against Finesse Carpentry or Bryan Henn.
16. All documents that identify the cause, origin, scope and date of loss relating to the damages
at issue in the Claim and the Litigation, including, but not limited to, reports of experts.
17. All documents relating to the condition of the Property’s roof and the damage it suffered
both prior to and including January 3, 2022, including documents prepared by engineers,
architects, contractors, or other persons.
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18. All statements concerning the action from all witnesses, including any statements from the
parties herein, or their respective agents, servants, or employees.
19. All documents containing the names and home and business addresses of all persons
contacted as potential witnesses.
20. Reports of any and all experts who will testify at trial along with a curriculum vitae or
résumé of each.
21. All documents or tangible things, including reports, physical models, compilations of data
and other material prepared by or for an expert in anticipation of the expert’s trial or
deposition testimony.
22. All documents prepared by or given to any expert who may testify at the trial in this matter
or whose opinions or reports form the basis for any opinion possessed by any expert in
connection with this Litigation.
23. All documents that you intend to use as exhibits at the deposition and/or trial in the
Litigation.
24. All documents received pursuant to subpoena in the Litigation.
Dated: June 28, 2023 HORST KREKSTEIN & RUNYON LLC
By: s/William Krekstein, Esquire
N.Y. ID No. 4128419
80 Broad Street, 5th Floor
New York, NY 10004
Tel: 212-837-7824
Email: wkrekstein@hkr.law
Counsel for Defendant,
The Cincinnati Insurance Company
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FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
ANDIFRED REALTY CORP.,
Plaintiff,
v. Index No. 604900/2023
THE CINCINNATI INSURANCE COMPANY, CERTIFICATE OF SERVICE
FINESSE CARPENTRY and BRYAN HENN d/b/a
FINESSE CARPENTRY,
Defendants.
A true and correct copy of The Cincinnati Insurance Company’s Notice for Discovery and
Inspection of Documents was served via electronic filing upon the following parties:
Meredith B. Castelli Kevin P. Smith, Esquire
Harfenist Kraut & Perlstein, LLP Stutman Law
3000 Marcus Avenue, Suite 2E1 200 Vesey St., 24th Floor
Lake Success, New York 11042 New York, NY 10281
mcastelli@hkplaw.com smithk@stutmanlaw.com
Attorney for Plaintiff – Andifred Realty Attorney for Defendant – The Cincinnati
Corp. Insurance Company
The Demand was served via Certified and First Class Mail on:
Finesse Carpentry Bryan Henn d/b/a Finesse Carpentry
Officer, Managing or General Agent 34 Oaklawn Avenue
34 Oaklawn Avenue Farmingville, New York 11738
Farmingville, New York 11738
Dated: June 28, 2023 HORST KREKSTEIN & RUNYON LLC
By: s/William Krekstein, Esquire
N.Y. ID No. 4128419
80 Broad Street, 5th Floor
New York, NY 10004
Tel: 212-837-7824
Email: wkrekstein@hkr.law
Counsel for Defendant,
The Cincinnati Insurance Company
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Preview
FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/28/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ANDIFRED REALTY CORP., Plaintiff, Index No. 604900/2023 v. NOTICE FOR DISCOVERY THE CINCINNATI INSURANCE COMPANY, AND INSPECTION FINESSE CARPENTRY and BRYAN HENN d/b/a OF DOCUMENTS FINESSE CARPENTRY, Defendants. PLEASE TAKE NOTICE that pursuant to CPLR Article 31, Defendant, The Cincinnati Insurance Company (“Cincinnati”) hereby requests that Plaintiff produce at the offices of Horst, Krekstein & Runyon LLC, 80 Broad Street, 5th Floor, New York, NY 10004, within thirty (30) days of the date hereof, the following documents for discovery, inspection and copying by Defendant, Cincinnati, its attorneys or other representatives. DEFINITIONS The following definitions are applicable to each Demand: (a) The term “DOCUMENT,” as used herein, means the original, any drafts and all copies of all written, printed, typed or other graphic matter of any kind or nature, whether sent or received or neither, and any other tangible thing in your possession, custody or control or known by you to exist, including but not limited to: (i) all contracts, agreements, letter agreements, representations, warranties, certifications and opinions; (ii) all letters or other forms of correspondence or communications, including envelopes and notes, e-mails, telegrams, cables, telex messages, phone messages, facsimile transmissions (faxes), reports, notes, notations and memoranda of or relating to telephone conversations, meetings or conferences; (iii) all memoranda, reports, test results, financial statements or reports, notes, scripts, transcripts, tabulations, studies, analysis, evaluations, projections, work-papers, corporate records or copies thereof, expressions or statements or policy, lists, comparisons, questionnaires, surveys, charts, graphs, summaries, extracts, statistical statements or records, compilations and opinions or reports of consultants; 1 of 7 FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/28/2023 (iv) all desk calendars, appointment books and diaries; (v) all minutes, records or transcripts of meetings and conferences and lists of persons attending meetings or conferences; (vi) all reports and summaries of interviews and negotiations; (vii) all books, articles, press releases, magazines, newspapers, booklets, brochures, pamphlets, circulars, bulletins, notices, instructions and manuals; (viii) all motion pictures and photographs (whether developed or undeveloped), tape recordings, microfilms, phonographs or other records, punch-cards, magnetic tapes, disks, data cells, drums, printouts and other data compilations from which information can be obtained; and (ix) drafts of any document revisions or drafts of any documents and original or preliminary notes. (b) The terms “RELATE(S) TO” or “RELATING TO,” as used herein, mean to constitute, refer to, reflect, concern, pertain to or in any way logically or factually connect with the matter described in the Demand. (c) The term “COMMUNICATIONS,” as used herein, means all statements, admissions, denials, inquiries, discussions, conversations, negotiations, documents, agreements, contracts, understandings, meetings, telephone conversations, letters, emails, correspondence, notes, telegrams, telexes, facsimile transmissions (faxes), advertisements, or any other form of written or verbal intercourse. (d) Unless otherwise indicated by the context, the term “IDENTIFY” or “IDENTITY,” as used herein: (i) when referring to a document, shall require identification of such document by furnishing a brief description of the document, its title or identifying symbol, its date, name and address of persons originating, name and address of persons (if any) to whom it was directed, the location thereof and its present custodian; (ii) when used in connection with an oral communication, shall require identification of each person by whom and to whom such communication was made, and the parties in whose presence such statement, communication or utterance was given or transmitted, the date it was made, whether it was made by telephone, and the place at which each person was located; (iii) when used in referring to a person, shall require furnishing the following information concerning such person: 2 2 of 7 FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/28/2023 (1) full name; (2) age; (3) the current or last known business and home addresses; (4) the current or last known employment position (the current or last known business title); and (5) the current or last known telephone number. (e) The term “PERSON,” as used herein, means any natural person, partnership, corporation or other business entity and all present and former officers, directors, agents, employees, representatives, attorneys and others acting or purporting to act on behalf of such natural person, partnership, corporation or other business entity. (f) The singular shall include the plural and the plural shall include the singular. (g) The masculine, feminine or neuter pronoun shall not exclude the other genders. (h) The term “DATE OF LOSS,” as used herein, refers to the date(s) of loss identified in Plaintiffs’ Complaint, or if no such date appears in Plaintiffs’ Complaint, the date(s) identified in these responses as the date(s) of the alleged incident or damages. (i) The word “OR” means “AND/OR.” (j) The term “LITIGATION,” means the case captioned as Andifred Realty Corp. v. The Cincinnati Insurance Company, Finesse Carpentry and Bryan Henn d/b/a Finesse Carpentry, Index No. 604900/2023, Supreme County of the State of New York, County of Nassau. (k) The term “COMPLAINT” means the Complaint filed by Plaintiff in the Litigation and any amendments. (l) The term “PROPERTY” means the property located 240 Glen Head Road, Glen Head New York 11545 and referenced in the Complaint. (m) The term “POLICY” refers to the commercial insurance policy, number ENP 055 01 09, effective September 1, 2021 to September 1, 2022, issued to Plaintiff by Cincinnati. (n) The term “CLAIM” refers to the insurance claim made by Plaintiffs to Defendant The Cincinnati Insurance Company that is the subject of the Litigation. (o) The terms “YOU” and “YOUR” refer to Plaintiff Andifred Realty Corp., and each of its employees, servants, heirs, attorneys, agents, representatives and/or person acting for each of them or on their behalf in any capacity. 3 3 of 7 FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/28/2023 INSTRUCTIONS (a) Work Product or Privilege. With respect to each such document, oral statement, or communication inquired about in any Request for Production of Documents that you claim to be privileged or to constitute work product: (i) identify the document, oral statement, or communication to the fullest extent possible; (ii) include the date, maker, recipient, and type of document (e.g., letter, memoranda); and (iii) the specific basis of the claim of privilege or work product for each document. (b) Data Stored on Software or Other Media. In those instances where requested information is stored only on software or other data compilations, you should either produce the raw data along with all codes and programs for translating it into usable form or produce the information in a finished usable form, which would include all necessary glossaries, keys and indices for interpretation of the material. (c) Cessation of Document Destruction. It is requested that all documents and/or other data compilations that might impact on the subject matter of the Complaint and/or the Litigation be preserved and that any ongoing process of document destruction involving such documents cease. (d) Organization of Responses. The documents shall be organized by you, labeled with reference to the request to which they are responsive and produced in accordance with the categories in the Request. (e) Duty to Amend/Supplement. These Requests for Production of Documents are deemed continuing in character, and if at any time Plaintiffs obtain information which would make a prior answer inaccurate, incomplete or incorrect, Plaintiffs are required to communicate said new information to the defendant through counsel. This duty to amend continues up to the time of trial. REQUESTS FOR PRODUCTION 1. All documents identified in or relating to your response to Defendant, Cincinnati’s Demand for Bill of Particulars or in any deposition relating to the Litigation. 2. All documents related to the initial installation or construction of the Property’s roof. 3. All documents related to repairs, maintenance, remodeling, or reconstruction of the Property’s roof prior to January 3, 2022. 4. All communications between Andifred and Finesse Carpentry or Bryan Henn related to the roof, including prior to Finesse’s work on the roof in September 2019. 4 4 of 7 FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/28/2023 5. All documents and communications relating to complaints or reports of roof leaks at the Property. 6. All documents or communications between Andifred and any contractor, architect, or other entity that performed work on or related to the Property’s roof. 7. Copies of all photographs and/or videos taken that relate to all claimed damages in the Claim, the Complaint and Litigation. 8. All documents or communications between Andifred and Tim Stapleton or other employees, agents, or individuals involved in the management of the Property related to the Property’s roof, leaks, maintenance, or construction at the Property. 9. All documents or communications between Andifred and any third party, including but not limited to any employees of the United States Postal Service, relating to complaints, reports, or other correspondence relating to the Property’s roof or leaks within the interior of the Property prior to January 3, 2022. 10. All documents supporting or relating to Plaintiff’s contention that the damage to the Property’s roof constitutes a “Covered Loss” pursuant to the Policy, as alleged in Paragraphs 1, 31, and 32 of the Complaint. 11. All documents supporting or relating to Plaintiff’s contention that Cincinnati’s denial of coverage for the damage to the Property’s roof constitutes a breach of contract, as alleged in Paragraph 34 of the Complaint, including identification of all specific provisions of the Policy that you contend were breached. 12. If you contend that Defendant, Cincinnati, violated any law, statute, ordinance, rule, or regulation, provide any and all documents which support each contention. 13. All of your diaries, logs, personal journals, or personal calendars, if any, that relate in any way to the facts, claims, causes of action, allegations, or contentions against Defendant, Cincinnati, set out in the Complaint. 14. The entire contents of any file(s) and any other documents in your possession that support or relate to any claim for benefits you have made to Defendant, Cincinnati, regarding the Claim that is the subject of Andifred’s Complaint. 15. The entire contents of any file(s) and any other documents in your possession that support or relate to your claims against Finesse Carpentry or Bryan Henn. 16. All documents that identify the cause, origin, scope and date of loss relating to the damages at issue in the Claim and the Litigation, including, but not limited to, reports of experts. 17. All documents relating to the condition of the Property’s roof and the damage it suffered both prior to and including January 3, 2022, including documents prepared by engineers, architects, contractors, or other persons. 5 5 of 7 FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/28/2023 18. All statements concerning the action from all witnesses, including any statements from the parties herein, or their respective agents, servants, or employees. 19. All documents containing the names and home and business addresses of all persons contacted as potential witnesses. 20. Reports of any and all experts who will testify at trial along with a curriculum vitae or résumé of each. 21. All documents or tangible things, including reports, physical models, compilations of data and other material prepared by or for an expert in anticipation of the expert’s trial or deposition testimony. 22. All documents prepared by or given to any expert who may testify at the trial in this matter or whose opinions or reports form the basis for any opinion possessed by any expert in connection with this Litigation. 23. All documents that you intend to use as exhibits at the deposition and/or trial in the Litigation. 24. All documents received pursuant to subpoena in the Litigation. Dated: June 28, 2023 HORST KREKSTEIN & RUNYON LLC By: s/William Krekstein, Esquire N.Y. ID No. 4128419 80 Broad Street, 5th Floor New York, NY 10004 Tel: 212-837-7824 Email: wkrekstein@hkr.law Counsel for Defendant, The Cincinnati Insurance Company 6 6 of 7 FILED: NASSAU COUNTY CLERK 06/28/2023 10:43 AM INDEX NO. 604900/2023 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 06/28/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ANDIFRED REALTY CORP., Plaintiff, v. Index No. 604900/2023 THE CINCINNATI INSURANCE COMPANY, CERTIFICATE OF SERVICE FINESSE CARPENTRY and BRYAN HENN d/b/a FINESSE CARPENTRY, Defendants. A true and correct copy of The Cincinnati Insurance Company’s Notice for Discovery and Inspection of Documents was served via electronic filing upon the following parties: Meredith B. Castelli Kevin P. Smith, Esquire Harfenist Kraut & Perlstein, LLP Stutman Law 3000 Marcus Avenue, Suite 2E1 200 Vesey St., 24th Floor Lake Success, New York 11042 New York, NY 10281 mcastelli@hkplaw.com smithk@stutmanlaw.com Attorney for Plaintiff – Andifred Realty Attorney for Defendant – The Cincinnati Corp. Insurance Company The Demand was served via Certified and First Class Mail on: Finesse Carpentry Bryan Henn d/b/a Finesse Carpentry Officer, Managing or General Agent 34 Oaklawn Avenue 34 Oaklawn Avenue Farmingville, New York 11738 Farmingville, New York 11738 Dated: June 28, 2023 HORST KREKSTEIN & RUNYON LLC By: s/William Krekstein, Esquire N.Y. ID No. 4128419 80 Broad Street, 5th Floor New York, NY 10004 Tel: 212-837-7824 Email: wkrekstein@hkr.law Counsel for Defendant, The Cincinnati Insurance Company 7 of 7