On April 12, 2021 a
Motion-Secondary
was filed
involving a dispute between
Henri Parra Parra,
and
Construction Realty Safety Group Inc.,
Kingdom Associates Inc.,
Red Apple Surf Realty Ii Llc,
The Rossi Corporation,
for Torts - Other (Labor Law/Negligence)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 10/12/2021 12:27 PM INDEX NO. 508585/2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 10/12/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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HENRI PARRA PARRA,
Index No.: 508585/2021
Plaintiff,
-against-
CONSTRUCTION REALTY SAFETY GROUP INC., RESPONSE TO
THE ROSSI CORPORATION, KINGDOM ASSOCIATES COMBINED DEMANDS
INC. and RED APPLE SURF REALTY II LLC,
Defendants.
--------------------------------------------------------------------X
Defendant CONSTRUCTION REALTY SAFETY GROUP, INC. (hereinafter “CR SAFETY”)
by its attorney, LAW OFFICE OF ERIN M. MCGINNIS, PLLC, as and for its response to Kingdom
Associates Inc.’s Combined Demands dated September 23, 2021, states upon information and belief as
follows:
NOTICE TO PRODUCE
CR SAFETY objects to the request on the grounds that it is overbroad, unduly burdensome and/or
requests information that is irrelevant, immaterial or not reasonably calculated to lead to the
discovery of admissible evidence. Notwithstanding and without waiving the foregoing objection,
CR SAFETY is not aware of any known witnesses to plaintiff’s alleged accident.
NOTICE FOR DISCOVERY OF STATEMENT OF PARTY
CR SAFETY objects to the request on the grounds that it is overbroad, unduly burdensome and/or
requests information that is irrelevant, immaterial or not reasonably calculated to lead to the
discovery of admissible evidence. Notwithstanding and without waiving the foregoing objection,
CR SAFETY is not aware of any statements made by or taken from defendant KINGDOM
ASSOCIATES INC.
DEMAND FOR PHOTOGRAPHS
CR Safety objects to this request on the grounds that it is overbroad, unduly burdensome and/or
requests information that is irrelevant, immaterial or not reasonably calculated to lead to the
discovery of admissible evidence. Notwithstanding and without waiving the foregoing objection,
CR Safety is not in possession of any documentation responsive to this request.
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FILED: KINGS COUNTY CLERK 10/12/2021 12:27 PM INDEX NO. 508585/2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 10/12/2021
DEMAND FOR EXPERT WITNESSES INFORMATION
At the present time, CR SAFETY has not retained the services of any persons expected to be called
as expert witnesses. To the extent CR SAFETY retains any expert witness, CR SAFETY will
supplement this response.
DEMAND PURSUANT TO SECTION 2103 OF THE CPLR
ERIN M. MCGINNIS, ESQ.
Attorney for Defendant
CR SAFETY
248 West 35th Street, 8th Fl
New York, NY 10001
NOTICE FOR DISCOVERY AND INSPECTION
Accident Reports: Please see attached.
Contract: Please see attached.
Job records: CR Safety objects to this request on the grounds that it is overbroad, unduly
burdensome and/or requests information that is irrelevant, immaterial or not reasonably calculated
to lead to the discovery of admissible evidence. Notwithstanding and without waiving the
foregoing objection, see the logs contained in CR Safety’s Site Safety Logs for a period of 30 days
prior to Plaintiff’s accident.
Bills: CR Safety objects to this request on the grounds that it is overbroad, unduly burdensome
and/or requests information that is irrelevant, immaterial or not reasonably calculated to lead to
the discovery of admissible evidence.
Dated: New York, New York
October 12, 2021
LAW OFFICE OF ERIN M. MCGINNIS, PLLC
By: /s/ Erin M. McGinnis_______
ERIN M. MCGINNIS, ESQ.
Attorney for Defendant
CR SAFETY
248 West 35th Street, 8th Fl
New York, NY 10001
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FILED: KINGS COUNTY CLERK 10/12/2021 12:27 PM INDEX NO. 508585/2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 10/12/2021
3 of 3
Document Filed Date
October 12, 2021
Case Filing Date
April 12, 2021
Category
Torts - Other (Labor Law/Negligence)
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FILED: KINGS COUNTY CLERK 10/12/2021 12:27 PM INDEX NO. 508585/2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 10/12/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X HENRI PARRA PARRA, Index No.: 508585/2021 Plaintiff, -against- CONSTRUCTION REALTY SAFETY GROUP INC., RESPONSE TO THE ROSSI CORPORATION, KINGDOM ASSOCIATES COMBINED DEMANDS INC. and RED APPLE SURF REALTY II LLC, Defendants. --------------------------------------------------------------------X Defendant CONSTRUCTION REALTY SAFETY GROUP, INC. (hereinafter “CR SAFETY”) by its attorney, LAW OFFICE OF ERIN M. MCGINNIS, PLLC, as and for its response to Kingdom Associates Inc.’s Combined Demands dated September 23, 2021, states upon information and belief as follows: NOTICE TO PRODUCE CR SAFETY objects to the request on the grounds that it is overbroad, unduly burdensome and/or requests information that is irrelevant, immaterial or not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and without waiving the foregoing objection, CR SAFETY is not aware of any known witnesses to plaintiff’s alleged accident. NOTICE FOR DISCOVERY OF STATEMENT OF PARTY CR SAFETY objects to the request on the grounds that it is overbroad, unduly burdensome and/or requests information that is irrelevant, immaterial or not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and without waiving the foregoing objection, CR SAFETY is not aware of any statements made by or taken from defendant KINGDOM ASSOCIATES INC. DEMAND FOR PHOTOGRAPHS CR Safety objects to this request on the grounds that it is overbroad, unduly burdensome and/or requests information that is irrelevant, immaterial or not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and without waiving the foregoing objection, CR Safety is not in possession of any documentation responsive to this request. 1 of 3 FILED: KINGS COUNTY CLERK 10/12/2021 12:27 PM INDEX NO. 508585/2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 10/12/2021 DEMAND FOR EXPERT WITNESSES INFORMATION At the present time, CR SAFETY has not retained the services of any persons expected to be called as expert witnesses. To the extent CR SAFETY retains any expert witness, CR SAFETY will supplement this response. DEMAND PURSUANT TO SECTION 2103 OF THE CPLR ERIN M. MCGINNIS, ESQ. Attorney for Defendant CR SAFETY 248 West 35th Street, 8th Fl New York, NY 10001 NOTICE FOR DISCOVERY AND INSPECTION Accident Reports: Please see attached. Contract: Please see attached. Job records: CR Safety objects to this request on the grounds that it is overbroad, unduly burdensome and/or requests information that is irrelevant, immaterial or not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and without waiving the foregoing objection, see the logs contained in CR Safety’s Site Safety Logs for a period of 30 days prior to Plaintiff’s accident. Bills: CR Safety objects to this request on the grounds that it is overbroad, unduly burdensome and/or requests information that is irrelevant, immaterial or not reasonably calculated to lead to the discovery of admissible evidence. Dated: New York, New York October 12, 2021 LAW OFFICE OF ERIN M. MCGINNIS, PLLC By: /s/ Erin M. McGinnis_______ ERIN M. MCGINNIS, ESQ. Attorney for Defendant CR SAFETY 248 West 35th Street, 8th Fl New York, NY 10001 2 of 3 FILED: KINGS COUNTY CLERK 10/12/2021 12:27 PM INDEX NO. 508585/2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 10/12/2021 3 of 3