Preview
FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
_________________________________________________________________Ç
PETROS RAGOUSSIS
VERIFIED BILL OF
PARTICULARS
Plaintiff,
-against-
Index No.: 713208/2023
EMPIRE CONTROL ABATEMENT, INC. and NEW
YORK CITY HOUSING AUTHORITY
Defendants.
___________________________________________________Ç
PLEASE TAKE NOTICE that plaintiff PETROS RAGOUSSIS, as and for his Verified
Bill of Particulars and by their attorneys, ARGYROPOULOS & ASSOCIATES, LLC, pursuant
to the demands of the defendant EMPIRE CONTROL ABATEMENT, INC., states the following
upon information and belief:
1. Plaintiff PETROS RAGOUSSIS was injured on October 19, 2022.
2. The occurrence was caused solely and wholly through and by reason of the negligence,
carelessness and recklessness of the defendants by their agents, servants and/or
employees in that the defendants deprived the plaintiff of a safe place to work; in that the
defendants violated Section 200 of the Labor Law; in that the defendants violated Section
241(6) and Section 240 of the Labor Law; in that the defendants violated the various
rules and regulations of the administrative code of the City of New York; in that the
defendants violated various rules and regulation of the Board of Standards and Appeals
more commonly known as Rule 23; in that the defendants violated the Occupational and
Safety Hazard Act more commonly known as OSHA; in that defendants permitted and
allowed a dangerous, hazardous and defective condition to exist in the aforementioned
are in which the plaintiff was working; in that the defendants directed, permitted and
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allowed the plaintiff to work in an area which was dangerous, hazardous and unsafe; in
that the defendants failed to provide the plaintiff with a safe and stable and sufficient
surface from which to perform his work; in causing, directing and allowing the plaintiff
to perform his work in a falling hazard area; in causing, directing and allowing the
plaintiff to perform his work from a unsafe surface; in that the defendants directed,
permitted and allowed the plaintiff to work in a manner which was dangerous, hazardous
and unsafe; in failing to provide proper safety and maintenance procedures so as to
ensure the safety of the area in which the plaintiff was working; in failing to guard
against falling hazards; in failing to have sufficient and/or efficient personnel in and
about the premises; in failing to properly instruct, train and equip personnel upon the
premises; in failing to properly and adequately supervise the progress of work at the
aforementioned premises, and more particularly the area of the premises in which the
plaintiff was working; in permitting, causing and allowing a trap to exist at the premises;
in constructing, repairing and maintaining areas of the area between the third and fourth
floors in a dangerous and hazardous condition and in violation of applicable codes, laws,
rules and statutes; in creating, causing and allowing the premises to be in violation of the
statutes, codes, laws and rules of the City and State of New York; in failing to give
warning or notice of the hazardous and dangerous conditions to the plaintiff herein,
despite having actual and/or construction notice thereof; in failing to correct the
aforementioned hazardous and dangerous conditions, although said conditions existed for
a long enough period of time so that the defendants by their agent, servants and/or
employees should have had or did have, actual knowledge of the said hazardous and
dangerous condition, and neglected and failed to remedy same; in that the defendants
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were further negligent in that the defendants created and maintained an absolute nuisance
under the circumstances; in failing to provide this plaintiff with a safe and unobstructed
place to work; in that the defendants are further negligent in failing to properly guard the
hazardous and dangerous condition; in permitting, allowing and maintaining the
hazardous and dangerous condition to exist therein; in failing to provide protective
barriers in or about the area where the plaintiff was caused to be injured; in failing to
repair known and hazardous conditions; in improperly repairing and maintaining the
premises; in providing a defective and loose, shaky and weak surface from which
plaintiff was directed to work; in providing a defective, loose, shaky and weak scaffold
from which plaintiff was directed to work; in failing to ensure the securing of the scaffold
prior to and during the time in which plaintiff was directed to work therefrom; in failing
to inspect the work place; in failing to maintain the workplace free of hazards; all without
negligence on the part of the plaintiff herein.
3. The condition(s) causing injury to plaintiff was an improper, defective, and unsupported
cross brace in the area from which plaintiff was directed to work. The condition(s)
causing injury to plaintiff was an improper, defective, and unsupported cross brace and
improper and negligent situation and managing of the area from which plaintiff was
directed to work. Further details on improper construction, excavation and/or demolition
work including the manners in which said work was being performed negligently that
contributed to and/or caused the occurrence will be provided upon further discovery from
the defendants.
4. Actual notice of the occurrence as well as the conditions causing the occurrence is
claimed, although it is not known to whom such notice was given and the manner in
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which it was given, and it is further claimed that the defendants caused and created the
conditions causing injury to plaintiff. Constructive notice of the occurrence and the
conditions causing the occurrence is claimed, and it is further claimed that the aforesaid
conditions existed for such an extended and continuous period of time to constitute
constructive notice of the dangerous and hazardous conditions at the premises. Further
particulars will be provided upon discovery by the defendants.
5. See paragraph 5.
6. Plaintiff PETROS RAGOUSSIS claims the following injuries as a result of the
occurrence:
CT of chest on October 19, 2022, reveals displaced left lateral and posterior rib fractures
CT of chest on October 19, 2022, reveals Pulmonary contusion
CT of chest on October 19, 2022, reveals Subcutaneous emphysema
CT of chest on October 19, 2022, reveals Left sided hemothorax
CT of chest on October 19, 2022, reveals medial left pneumothorax
left pleural effusion
bibasilar atelectatic changes
contusion to left lung
plaintiff was compelled to ingest prescription and other medicines for pain, such as
fentanyl, methocarbamol, lisinopril and others.
blunt chest trauma
respiratory failure
preoperative and postoperative diagnosis of closed fracture of multiple ribs of life side,
hemothorax
plaintiff subjected to undergo vats
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plaintiff subjected to undergo thoracoscopy
plaintiff subjected to undergo thoracotomy
plaintiff subjected to undergo decertification open reduction internal fixation ribs
insertion of titanium plates and screws
plaintiff subjected to intubation post-surgery
plaintiff subjected to chest tube
postoperative x-ray of chest reveals interval worsening of the layering of the left pleural
effusion with increasing left retrocardiac opacity
x-ray of chest reveals interval development of opacites in the right midlung field likely
representing subsegmental atelectasis. Possible trace layering right pleural effusion
x-ray of chest reveals density along left lateral chest wall consistent with layering plueral
effusion
x-ray of chest reveals additional lobulated opacity seen along left lateral hemithorax and
in left apex, possibly representing increase in left pleural fluid which is now located
persistent left retrocardiac opacity
right mid lung field atelectasis
thickening of right minor fissure versus the presence of fluid in the fissure
persistent and severe headaches
posttraumatic headaches with possibility of intracranial lesion and subdural hematoma
persistent and severe neck pain
numbness in hands, shoulders, leg, arms, neck
plaintiff was admitted to the hospital for post-surgical pain control, intubation, sedation
and hemodynamic monitoring
plaintiff was compelled to undergo physical therapy, and was referred for home health
care services
plaintiff sustained injuries to the nerves, tendons, ligaments and other soft tissues in and
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around the affected areas and the plaintiff is now subject to premature osteoarthritic
changes
plaintiff claims permanent loss of use and function of the affected areas as well as
chronic and continual pain and restriction and limitation of ranges of motion
plaintiff is unable to engage in those usual and customary daily recreational activities that
were pursued prior to the occurrence
severe emotional distress, manifested by fears, anxieties, restlessness, sleeplessness,
irritability and depression
7. All of the injuries suffered and aforementioned are claimed to be permanent in nature.
8. Plaintiff PETROS RAGOUSSIS was confined to Harlem Hospital Center from October
10, 2022 through October 23, 2022, and was confined to NYU Langone Hospital from
October 23, 2022 through October 26, 2022 and all other dates and occasions on which
said plaintiff was so confined. Plaintiff PETROS RAGOUSSIS has been continued to bed
and to home continuously and intermittently from the date of the occurrence to the
present date and expects to be so confined as such into the foreseeable future.
9. Plaintiff was employed by STV INC. as a construction supervisor.
10. Plaintiff has been incapacitated from the date of the occurrence to the present date and
continuing into the future.
11. Plaintiff has treated at the following facilities:
a. Harlem Hospital Center, 506 Lenox Avenue, New York, NY 10037
b. NYU Langone Hospital, 259 First Street, Mineola, NY 11501
c. Itzhak C Haimovie, 170 Great Neck Road, Great Neck NY 11021
d. Main Street Radiology, 136-25 37th Ave, Queens, NY 11354
e. Ibrahim Abd El-Shafy, MD, 173 Mineola Blvd, Ste. 401, Mineola, NY 11501
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f. Ricardo Jacquez MD, 173 Mineola Blvd Ste. 401, Mineola, NY 11501
g. Abhishek Ganta MD, 134-20 Jamaica Ave, Queens, NY 11418
h. Dr. Scott Schubach, 1300 Franklin Avenue, Suite ML2
i. Alcen Physical Therapy, 44-20 Francis Lewis Blvd
38th
j. Millenium Physical Therapy, 30-63 Street, Astoria, New York 11103
37th
12. Plaintiff was born on January 21, 1971. He resides at 19222 Avenue, Auburndale,
NY 11358. His Social Security Number will be provided.
13. Plaintiff objects to this demand. Pursuant to the holding in Liga v. Long Isl. R.R., 129
A.D.2d 566, 514 N.Y.S.2d 61 (2d Dep't 1987), even where plaintiffs allege statutory
violations in their complaint, plaintiffs may reserve the particularization of such
violations until after the completion of all disclosure herein. This Honorable Court is
respectfully requested to take judicial notice of each and all of those laws, codes,
customs, official directives, statutes, ordinances, and rules and regulations that were or
may have been violated, breached, disregarded, not heeded, disobeyed, not observed, not
conformed to, or not complied with, by the acts and omissions hereinabove set forth.
Dated: Queens, New York
November 10, 2023
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Yours, etc.,
ARGYROPOULOS & ASSOCIATES, LLC
By: PHILIP ARGYROPOULOS, ESQ.
Attorney(s) for Plaintiff(s)
31-08 Broadway, Suite 202
Astoria, New York 11106
(718) 777-1777
TO: Marina A. Spinner, Esq.
Nicoletti Spinner Ryan Gulino Pinter LLP
Attorneys for Defendant
Empire Control Abatement, Inc.
8th
555 Fifth Avenue, PlOOr
New York, New York 10017
212-730-7750
File No.: 10338.00015
New York City Housing Authority
40 Wall Street
New York, New York 10005
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NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023
VERIFICATION
STATE OF NEW YORK )
) ss:
COUNTY OF QUEENS )
, being duly sworn depose and say; I am the
plaintiff in the within action;
That I have read the foregoing , and know
the contents thereof; that the same is true to our own knowledge, except as to those matters therein stated
to be alleged on information and belief, and that as to those matters I believe them to be true.
Dated: Queens, New York
, 20
X
Swo to before e this
& d of jv mW , 2023. /
NOTA f PUBI I f
NICOLE GAJ
NEW YORK
NOTARY PUBUC, STKrE OF
Registrauon No. 01CA6418892
Qualified in Queens County
Commission Expires Jem 21 20
9 of 11
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NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023
STATE OF NEW YORK )
ss.:
COUNTY OF QUEENS)
George Kakivelis, deposes and says:
Deponent is not a party to the action is over 18 years of age and employed at 31-08
Broadway, Suite 202, Astoria, New York.
On November 11, 2023, deponent served the within VERIFIED BILL OF
PARTICULARS upon:
Marina A. Spinner, Esq.
Nicoletti Spinner Ryan Gulino inter LLP
Attorneys for Defendant
Empire Control Abatement, Inc.
802
555 Fifth Avenue, Floor
New York, New York 10017
212-730-7750
File No.: 10338.00015
New York City Housing Authority
40 Wall Street
New York, New York 10005
these/this being the address designated by said attorneys for that purpose by depositing a true copy
of same enclosed in a post-paid properly addressed wrapper, in an official depository mailbox
under the exclusive care and custody of the United States Postal Service within the State of New
York.
orge Kakivelis
Sworn before me th s
10 d November 023
No,a f Public
NOTARY PUBuc, STÃrE oF NEW YORK
Registration No. 01GA6418892
Qualified in Queens County
Commission Expires June 21, 20
10 of 11
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Index No. 713208/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
PETROS RAGOUSSIS,
Plaintiff(s),
-against-
EMPIRE CONTROL ABATEMENT, INC. and NEW YORK CITY HOUSING
AUTHORITY,
Defendant(s).
VERIFIED BILL OF PARTICULARS
NICOLETTE ARGYROPOULOS
Argyropoulos & Associates, LLC
Attorneys for Plaintiff(s)
31-08 Broadway, Suite 202
Astoria,M 11106
(718) 777-1777
To:
Attorney(s) for
Service of a copy of the within is hereby admitted.
Dated: ...............................
Attorney(s) for
Argyropoulos & Associates, LLC
Attorneys for Plaintiff(s)
11 of 11
Preview
FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS _________________________________________________________________Ç PETROS RAGOUSSIS VERIFIED BILL OF PARTICULARS Plaintiff, -against- Index No.: 713208/2023 EMPIRE CONTROL ABATEMENT, INC. and NEW YORK CITY HOUSING AUTHORITY Defendants. ___________________________________________________Ç PLEASE TAKE NOTICE that plaintiff PETROS RAGOUSSIS, as and for his Verified Bill of Particulars and by their attorneys, ARGYROPOULOS & ASSOCIATES, LLC, pursuant to the demands of the defendant EMPIRE CONTROL ABATEMENT, INC., states the following upon information and belief: 1. Plaintiff PETROS RAGOUSSIS was injured on October 19, 2022. 2. The occurrence was caused solely and wholly through and by reason of the negligence, carelessness and recklessness of the defendants by their agents, servants and/or employees in that the defendants deprived the plaintiff of a safe place to work; in that the defendants violated Section 200 of the Labor Law; in that the defendants violated Section 241(6) and Section 240 of the Labor Law; in that the defendants violated the various rules and regulations of the administrative code of the City of New York; in that the defendants violated various rules and regulation of the Board of Standards and Appeals more commonly known as Rule 23; in that the defendants violated the Occupational and Safety Hazard Act more commonly known as OSHA; in that defendants permitted and allowed a dangerous, hazardous and defective condition to exist in the aforementioned are in which the plaintiff was working; in that the defendants directed, permitted and 1 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 allowed the plaintiff to work in an area which was dangerous, hazardous and unsafe; in that the defendants failed to provide the plaintiff with a safe and stable and sufficient surface from which to perform his work; in causing, directing and allowing the plaintiff to perform his work in a falling hazard area; in causing, directing and allowing the plaintiff to perform his work from a unsafe surface; in that the defendants directed, permitted and allowed the plaintiff to work in a manner which was dangerous, hazardous and unsafe; in failing to provide proper safety and maintenance procedures so as to ensure the safety of the area in which the plaintiff was working; in failing to guard against falling hazards; in failing to have sufficient and/or efficient personnel in and about the premises; in failing to properly instruct, train and equip personnel upon the premises; in failing to properly and adequately supervise the progress of work at the aforementioned premises, and more particularly the area of the premises in which the plaintiff was working; in permitting, causing and allowing a trap to exist at the premises; in constructing, repairing and maintaining areas of the area between the third and fourth floors in a dangerous and hazardous condition and in violation of applicable codes, laws, rules and statutes; in creating, causing and allowing the premises to be in violation of the statutes, codes, laws and rules of the City and State of New York; in failing to give warning or notice of the hazardous and dangerous conditions to the plaintiff herein, despite having actual and/or construction notice thereof; in failing to correct the aforementioned hazardous and dangerous conditions, although said conditions existed for a long enough period of time so that the defendants by their agent, servants and/or employees should have had or did have, actual knowledge of the said hazardous and dangerous condition, and neglected and failed to remedy same; in that the defendants 2 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 were further negligent in that the defendants created and maintained an absolute nuisance under the circumstances; in failing to provide this plaintiff with a safe and unobstructed place to work; in that the defendants are further negligent in failing to properly guard the hazardous and dangerous condition; in permitting, allowing and maintaining the hazardous and dangerous condition to exist therein; in failing to provide protective barriers in or about the area where the plaintiff was caused to be injured; in failing to repair known and hazardous conditions; in improperly repairing and maintaining the premises; in providing a defective and loose, shaky and weak surface from which plaintiff was directed to work; in providing a defective, loose, shaky and weak scaffold from which plaintiff was directed to work; in failing to ensure the securing of the scaffold prior to and during the time in which plaintiff was directed to work therefrom; in failing to inspect the work place; in failing to maintain the workplace free of hazards; all without negligence on the part of the plaintiff herein. 3. The condition(s) causing injury to plaintiff was an improper, defective, and unsupported cross brace in the area from which plaintiff was directed to work. The condition(s) causing injury to plaintiff was an improper, defective, and unsupported cross brace and improper and negligent situation and managing of the area from which plaintiff was directed to work. Further details on improper construction, excavation and/or demolition work including the manners in which said work was being performed negligently that contributed to and/or caused the occurrence will be provided upon further discovery from the defendants. 4. Actual notice of the occurrence as well as the conditions causing the occurrence is claimed, although it is not known to whom such notice was given and the manner in 3 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 which it was given, and it is further claimed that the defendants caused and created the conditions causing injury to plaintiff. Constructive notice of the occurrence and the conditions causing the occurrence is claimed, and it is further claimed that the aforesaid conditions existed for such an extended and continuous period of time to constitute constructive notice of the dangerous and hazardous conditions at the premises. Further particulars will be provided upon discovery by the defendants. 5. See paragraph 5. 6. Plaintiff PETROS RAGOUSSIS claims the following injuries as a result of the occurrence: CT of chest on October 19, 2022, reveals displaced left lateral and posterior rib fractures CT of chest on October 19, 2022, reveals Pulmonary contusion CT of chest on October 19, 2022, reveals Subcutaneous emphysema CT of chest on October 19, 2022, reveals Left sided hemothorax CT of chest on October 19, 2022, reveals medial left pneumothorax left pleural effusion bibasilar atelectatic changes contusion to left lung plaintiff was compelled to ingest prescription and other medicines for pain, such as fentanyl, methocarbamol, lisinopril and others. blunt chest trauma respiratory failure preoperative and postoperative diagnosis of closed fracture of multiple ribs of life side, hemothorax plaintiff subjected to undergo vats 4 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 plaintiff subjected to undergo thoracoscopy plaintiff subjected to undergo thoracotomy plaintiff subjected to undergo decertification open reduction internal fixation ribs insertion of titanium plates and screws plaintiff subjected to intubation post-surgery plaintiff subjected to chest tube postoperative x-ray of chest reveals interval worsening of the layering of the left pleural effusion with increasing left retrocardiac opacity x-ray of chest reveals interval development of opacites in the right midlung field likely representing subsegmental atelectasis. Possible trace layering right pleural effusion x-ray of chest reveals density along left lateral chest wall consistent with layering plueral effusion x-ray of chest reveals additional lobulated opacity seen along left lateral hemithorax and in left apex, possibly representing increase in left pleural fluid which is now located persistent left retrocardiac opacity right mid lung field atelectasis thickening of right minor fissure versus the presence of fluid in the fissure persistent and severe headaches posttraumatic headaches with possibility of intracranial lesion and subdural hematoma persistent and severe neck pain numbness in hands, shoulders, leg, arms, neck plaintiff was admitted to the hospital for post-surgical pain control, intubation, sedation and hemodynamic monitoring plaintiff was compelled to undergo physical therapy, and was referred for home health care services plaintiff sustained injuries to the nerves, tendons, ligaments and other soft tissues in and 5 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 around the affected areas and the plaintiff is now subject to premature osteoarthritic changes plaintiff claims permanent loss of use and function of the affected areas as well as chronic and continual pain and restriction and limitation of ranges of motion plaintiff is unable to engage in those usual and customary daily recreational activities that were pursued prior to the occurrence severe emotional distress, manifested by fears, anxieties, restlessness, sleeplessness, irritability and depression 7. All of the injuries suffered and aforementioned are claimed to be permanent in nature. 8. Plaintiff PETROS RAGOUSSIS was confined to Harlem Hospital Center from October 10, 2022 through October 23, 2022, and was confined to NYU Langone Hospital from October 23, 2022 through October 26, 2022 and all other dates and occasions on which said plaintiff was so confined. Plaintiff PETROS RAGOUSSIS has been continued to bed and to home continuously and intermittently from the date of the occurrence to the present date and expects to be so confined as such into the foreseeable future. 9. Plaintiff was employed by STV INC. as a construction supervisor. 10. Plaintiff has been incapacitated from the date of the occurrence to the present date and continuing into the future. 11. Plaintiff has treated at the following facilities: a. Harlem Hospital Center, 506 Lenox Avenue, New York, NY 10037 b. NYU Langone Hospital, 259 First Street, Mineola, NY 11501 c. Itzhak C Haimovie, 170 Great Neck Road, Great Neck NY 11021 d. Main Street Radiology, 136-25 37th Ave, Queens, NY 11354 e. Ibrahim Abd El-Shafy, MD, 173 Mineola Blvd, Ste. 401, Mineola, NY 11501 6 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 f. Ricardo Jacquez MD, 173 Mineola Blvd Ste. 401, Mineola, NY 11501 g. Abhishek Ganta MD, 134-20 Jamaica Ave, Queens, NY 11418 h. Dr. Scott Schubach, 1300 Franklin Avenue, Suite ML2 i. Alcen Physical Therapy, 44-20 Francis Lewis Blvd 38th j. Millenium Physical Therapy, 30-63 Street, Astoria, New York 11103 37th 12. Plaintiff was born on January 21, 1971. He resides at 19222 Avenue, Auburndale, NY 11358. His Social Security Number will be provided. 13. Plaintiff objects to this demand. Pursuant to the holding in Liga v. Long Isl. R.R., 129 A.D.2d 566, 514 N.Y.S.2d 61 (2d Dep't 1987), even where plaintiffs allege statutory violations in their complaint, plaintiffs may reserve the particularization of such violations until after the completion of all disclosure herein. This Honorable Court is respectfully requested to take judicial notice of each and all of those laws, codes, customs, official directives, statutes, ordinances, and rules and regulations that were or may have been violated, breached, disregarded, not heeded, disobeyed, not observed, not conformed to, or not complied with, by the acts and omissions hereinabove set forth. Dated: Queens, New York November 10, 2023 7 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 Yours, etc., ARGYROPOULOS & ASSOCIATES, LLC By: PHILIP ARGYROPOULOS, ESQ. Attorney(s) for Plaintiff(s) 31-08 Broadway, Suite 202 Astoria, New York 11106 (718) 777-1777 TO: Marina A. Spinner, Esq. Nicoletti Spinner Ryan Gulino Pinter LLP Attorneys for Defendant Empire Control Abatement, Inc. 8th 555 Fifth Avenue, PlOOr New York, New York 10017 212-730-7750 File No.: 10338.00015 New York City Housing Authority 40 Wall Street New York, New York 10005 8 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 VERIFICATION STATE OF NEW YORK ) ) ss: COUNTY OF QUEENS ) , being duly sworn depose and say; I am the plaintiff in the within action; That I have read the foregoing , and know the contents thereof; that the same is true to our own knowledge, except as to those matters therein stated to be alleged on information and belief, and that as to those matters I believe them to be true. Dated: Queens, New York , 20 X Swo to before e this & d of jv mW , 2023. / NOTA f PUBI I f NICOLE GAJ NEW YORK NOTARY PUBUC, STKrE OF Registrauon No. 01CA6418892 Qualified in Queens County Commission Expires Jem 21 20 9 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 STATE OF NEW YORK ) ss.: COUNTY OF QUEENS) George Kakivelis, deposes and says: Deponent is not a party to the action is over 18 years of age and employed at 31-08 Broadway, Suite 202, Astoria, New York. On November 11, 2023, deponent served the within VERIFIED BILL OF PARTICULARS upon: Marina A. Spinner, Esq. Nicoletti Spinner Ryan Gulino inter LLP Attorneys for Defendant Empire Control Abatement, Inc. 802 555 Fifth Avenue, Floor New York, New York 10017 212-730-7750 File No.: 10338.00015 New York City Housing Authority 40 Wall Street New York, New York 10005 these/this being the address designated by said attorneys for that purpose by depositing a true copy of same enclosed in a post-paid properly addressed wrapper, in an official depository mailbox under the exclusive care and custody of the United States Postal Service within the State of New York. orge Kakivelis Sworn before me th s 10 d November 023 No,a f Public NOTARY PUBuc, STÃrE oF NEW YORK Registration No. 01GA6418892 Qualified in Queens County Commission Expires June 21, 20 10 of 11 FILED: QUEENS COUNTY CLERK 11/14/2023 03:30 PM INDEX NO. 713208/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/14/2023 Index No. 713208/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS PETROS RAGOUSSIS, Plaintiff(s), -against- EMPIRE CONTROL ABATEMENT, INC. and NEW YORK CITY HOUSING AUTHORITY, Defendant(s). VERIFIED BILL OF PARTICULARS NICOLETTE ARGYROPOULOS Argyropoulos & Associates, LLC Attorneys for Plaintiff(s) 31-08 Broadway, Suite 202 Astoria,M 11106 (718) 777-1777 To: Attorney(s) for Service of a copy of the within is hereby admitted. Dated: ............................... Attorney(s) for Argyropoulos & Associates, LLC Attorneys for Plaintiff(s) 11 of 11