Preview
FILED: WESTCHESTER COUNTY CLERK 10/11/2023 01:42 PM INDEX NO. 55548/2023
NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/11/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
PABLO FABIAN MEDRANDA PARRALES,
ANSWER TO CROSS-
Plaintiff, CLAIMS OF
CONSTRUCTION
-against- RESOURCES
CORPORATION OF NEW
THE WHITING-TURNER CONTRACTING YORK
COMPANY, PURCHASE SENIOR LEARNING
COMMUNICITY INC., PURCHASE COLLEGE AND
ADVANCEMENT CORPORATION, and
BLUEPRINT PARTNERS CORP,
Index No.: 55548/2023
Defendants.
THE WHITING-TURNER CONTRACTING
COMPANY, PURCHASE SENIOR LEARNING
COMMUNICITY INC., PURCHASE COLLEGE AND
ADVANCEMENT CORPORATION
Third-Party Plaintiffs,
-against-
AGUINA BROTHERS CONTRACTING, LLC and
CONSTRUCTION RESOURCES CORPORATION
OF NEW YORK,
Third-Party Defendants.
DEFENDANT BLUEPRINT PARTNERS CORP’S ANSWER TO CROSS-CLAIMS OF
THIRD-PARTY DEFENDANT
CONSTRUCTION RESOURCES CORPORATION OF NEW YORK
Defendant Blueprint Partners Corp, (“Blueprint”) by its attorneys, Whiteford, Taylor &
Preston, LLP, as and for its Verified Answer to Cross-Claims of Third-Party Defendant
Construction Resources of New York, states as follows:
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FILED: WESTCHESTER COUNTY CLERK 10/11/2023 01:42 PM INDEX NO. 55548/2023
NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/11/2023
AS TO THE FIRST CROSS CLAIM
Blueprint denies each and every allegation contained in the unnumbered paragraphs of the
Cross Claim contained in third-party defendant, CONSTRUCTION RESOURCES
CORPORATION OF NEW YORK, Verified Answer to Plaintiff’s Second Amended Complaint
with Cross Claims, dated September 14, 2023.
AS TO THE SECOND CROSS CLAIM
Blueprint denies each and every allegation contained in the unnumbered paragraphs of the
Cross Claim contained in third-party defendant, CONSTRUCTION RESOURCES
CORPORATION OF NEW YORK, Verified Answer to Plaintiff’s Second Amended Complaint
with Cross Claims, dated September 14, 2023.
AS TO THE THIRD CROSS CLAIM
Blueprint denies each and every allegation contained in the unnumbered paragraphs of the
Cross Claim contained in third-party defendant, CONSTRUCTION RESOURCES
CORPORATION OF NEW YORK, Verified Answer to Plaintiff’s Second Amended Complaint
with Cross Claims, dated September 14, 2023.
AS TO THE FOURTH CROSS CLAIM
Blueprint denies each and every allegation contained in the unnumbered paragraphs of the
Cross Claim contained in third-party defendant, CONSTRUCTION RESOURCES
CORPORATION OF NEW YORK, Verified Answer to Plaintiff’s Second Amended Complaint
with Cross Claims, dated September 14, 2023.
WHEREFORE, Defendant Blueprint demands judgment dismissing the Cross Claims
herein, with costs.
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FILED: WESTCHESTER COUNTY CLERK 10/11/2023 01:42 PM INDEX NO. 55548/2023
NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/11/2023
Respectfully Submitted,
Dated: Baltimore, Maryland WHITEFORD, TAYLOR & PRESTON L.L.P.
October 11, 2023
By: /s/Patrick D. McKevitt
Patrick D. McKevitt
Patrick D. McKevitt
7 Saint Paul St., Suite 1500
Baltimore, Maryland 21202
4th
444 Madison Avenue, FlOOr
New York NY, 10022
Telephone: (410) 347-9447
Facsimile: (410) 223-3498
pmckevitt@whitefordlaw.com
Attorneys for Defendant Blueprint Partners Corp
d/b/a Blueprint Robotics
AFFIDAVIT OF SERVICE BY ELECTRONIC FILING
STATE OF MARYLAND )
) ss:
COUNTY OF HOWARD )
Patrick D. McKevitt, being duly sworn, deposes and says; that deponent is not a party to
this action, that he is at least 18 years of age, and that he is employed by Whiteford, Taylor &
Preston, LLP, attorneys for Blueprint Partners Corp, d/b/a/ Blueprint Robotics, in the entitled
11th
action, that on the day of October, 2023, I served the within ANSWER TO CROSS CLAIMS
OF THIRD-PARTY DEFENDANT CONSTRUCTION RESOURCES CORPORATION OF
NEW YORK upon all parties appearing on the Supreme Court, State of New York Electronic
Filing Website at the e-mail addresses designated by said parties.
Patrick D. McKevitt
Sworn to before me this
11th
day of October, 2023
NOTARY PUBLIC
SARA ANN DiMEGLIO
Notary Public-Maryland
Howard County
M es
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Preview
FILED: WESTCHESTER COUNTY CLERK 10/11/2023 01:42 PM INDEX NO. 55548/2023 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/11/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER PABLO FABIAN MEDRANDA PARRALES, ANSWER TO CROSS- Plaintiff, CLAIMS OF CONSTRUCTION -against- RESOURCES CORPORATION OF NEW THE WHITING-TURNER CONTRACTING YORK COMPANY, PURCHASE SENIOR LEARNING COMMUNICITY INC., PURCHASE COLLEGE AND ADVANCEMENT CORPORATION, and BLUEPRINT PARTNERS CORP, Index No.: 55548/2023 Defendants. THE WHITING-TURNER CONTRACTING COMPANY, PURCHASE SENIOR LEARNING COMMUNICITY INC., PURCHASE COLLEGE AND ADVANCEMENT CORPORATION Third-Party Plaintiffs, -against- AGUINA BROTHERS CONTRACTING, LLC and CONSTRUCTION RESOURCES CORPORATION OF NEW YORK, Third-Party Defendants. DEFENDANT BLUEPRINT PARTNERS CORP’S ANSWER TO CROSS-CLAIMS OF THIRD-PARTY DEFENDANT CONSTRUCTION RESOURCES CORPORATION OF NEW YORK Defendant Blueprint Partners Corp, (“Blueprint”) by its attorneys, Whiteford, Taylor & Preston, LLP, as and for its Verified Answer to Cross-Claims of Third-Party Defendant Construction Resources of New York, states as follows: 1 1 of 3 FILED: WESTCHESTER COUNTY CLERK 10/11/2023 01:42 PM INDEX NO. 55548/2023 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/11/2023 AS TO THE FIRST CROSS CLAIM Blueprint denies each and every allegation contained in the unnumbered paragraphs of the Cross Claim contained in third-party defendant, CONSTRUCTION RESOURCES CORPORATION OF NEW YORK, Verified Answer to Plaintiff’s Second Amended Complaint with Cross Claims, dated September 14, 2023. AS TO THE SECOND CROSS CLAIM Blueprint denies each and every allegation contained in the unnumbered paragraphs of the Cross Claim contained in third-party defendant, CONSTRUCTION RESOURCES CORPORATION OF NEW YORK, Verified Answer to Plaintiff’s Second Amended Complaint with Cross Claims, dated September 14, 2023. AS TO THE THIRD CROSS CLAIM Blueprint denies each and every allegation contained in the unnumbered paragraphs of the Cross Claim contained in third-party defendant, CONSTRUCTION RESOURCES CORPORATION OF NEW YORK, Verified Answer to Plaintiff’s Second Amended Complaint with Cross Claims, dated September 14, 2023. AS TO THE FOURTH CROSS CLAIM Blueprint denies each and every allegation contained in the unnumbered paragraphs of the Cross Claim contained in third-party defendant, CONSTRUCTION RESOURCES CORPORATION OF NEW YORK, Verified Answer to Plaintiff’s Second Amended Complaint with Cross Claims, dated September 14, 2023. WHEREFORE, Defendant Blueprint demands judgment dismissing the Cross Claims herein, with costs. 2 2 of 3 FILED: WESTCHESTER COUNTY CLERK 10/11/2023 01:42 PM INDEX NO. 55548/2023 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 10/11/2023 Respectfully Submitted, Dated: Baltimore, Maryland WHITEFORD, TAYLOR & PRESTON L.L.P. October 11, 2023 By: /s/Patrick D. McKevitt Patrick D. McKevitt Patrick D. McKevitt 7 Saint Paul St., Suite 1500 Baltimore, Maryland 21202 4th 444 Madison Avenue, FlOOr New York NY, 10022 Telephone: (410) 347-9447 Facsimile: (410) 223-3498 pmckevitt@whitefordlaw.com Attorneys for Defendant Blueprint Partners Corp d/b/a Blueprint Robotics AFFIDAVIT OF SERVICE BY ELECTRONIC FILING STATE OF MARYLAND ) ) ss: COUNTY OF HOWARD ) Patrick D. McKevitt, being duly sworn, deposes and says; that deponent is not a party to this action, that he is at least 18 years of age, and that he is employed by Whiteford, Taylor & Preston, LLP, attorneys for Blueprint Partners Corp, d/b/a/ Blueprint Robotics, in the entitled 11th action, that on the day of October, 2023, I served the within ANSWER TO CROSS CLAIMS OF THIRD-PARTY DEFENDANT CONSTRUCTION RESOURCES CORPORATION OF NEW YORK upon all parties appearing on the Supreme Court, State of New York Electronic Filing Website at the e-mail addresses designated by said parties. Patrick D. McKevitt Sworn to before me this 11th day of October, 2023 NOTARY PUBLIC SARA ANN DiMEGLIO Notary Public-Maryland Howard County M es 3 of 3