On October 21, 2015 a
Party Notice
was filed
involving a dispute between
Alicia M Arundel,
Arthur A Belli Jr
As Parent And Natural Guardian Of Stephanie Belli, Deceased, And As The Administrator Of The E O Stephanie Belli,
Joelle Dimonte,
Melissa A Crai,
Mindy Grabina
A O E Amy Grabina, And Mindy Grabina, Individually,,
Olga Lipets,
Steven Baruch
A O E Lauren Baruch, Deceased, And Steven Baruch, Individually,,
Suzanne Schulman
As Administratrix Of The Estate Of Brittney M. Schulman, Deceased,
and
Cabot Coach Builders, Inc D B A Royale Limousine,
Carlos F Pino,
County Of Suffolk,
Romeo Dimon Marine Service, Inc.,
Steven D Romeo,
Town Of Southold,
Ultimate Class Limousine, Inc.,
Xyz Companies 1-5
Name Being Fictitious But Intended To Be The Remanufacturers, Distributors, And Or Sellers Of The 2007 Lincoln Town Car Stretch Limousine Involved In The Collision,,
for Tort
in the District Court of Suffolk County.
Preview
FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
-----------------------------------------------------------------------X
ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS Index No.: 611214/15
ADMINISTRATRIX OF THE ESTATE OF BRITTNEY
M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY
GRABINA, AS ADMINSTRATRIX OF THE ESTATE
OF AMY GRABINA, AND MINDY GRABlNA,
INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR
OF THE ESTATE OF LAUREN BARUCH, DECEASED,
AND STEVEN BARUCH, INDIVIDUALLY; JOELLE
DIMONTE; AND MELISSA A. CRAI,
Plaintiffs, NOTICE FOR DISCOVERY
AND INSPECTION
-against-
ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO,
ROMEO DIMON MARINE SERVICE, INC., STEVEN
ROMEO, TOWN OF SOUTHOLD and COUNTY OF
SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a
1-5"
ROYALE LIMOUSINE and "XYZ COMPANIES
name being fictitious but intended to be the remanufacturers,
distributors and/or sellers of the 2007 Lincoln Town Car
stretch limousine involved in the collision,
Defendants.
——————————— ——————X
-----------------------------------------------------------------------X
TO: Plaintiff, Mindy Grabina, as Administratrix of
the Estate of Amy Grabina
PLEASE TAKE NOTICE, that pursuant to CPLR 3101 et seq. and the applicable case
law, you are hereby required to produce for discovery and supply to the undersigned attorneys for
defendants within twenty (20) days from the date of service of this demand, the following
information, documents and items requested for the purpose of inspection and/or copying:
1) Copies of all funeral and burial bills related to decedent
2) Copies of any photographs taken on the day of the incident involving the women on the
trip,the vehicles and the drivers
3) Authorization to obtain decedent's college records.
1 of 5
FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018
4) Authorization to obtain decedent's employment records from Ernst & Young
5) Authorization to obtain decedent's employment records from Minsky & Grabina
6) The names and addresses of all people that plaintiff claims are witnesses to any claim that
decedent experienced fear of impending death
7) The names and addresses of all people that plaintiff claims are witnesses to any claim that
decedent experienced conscious pain and suffering
8) The names and addresses of all people that plaintiff claims are witnesses to any claim that
decedent experienced pre-impact terror
9) The addresses of Eric Rosen, Marsha and Steve Merin and Pam and Allen Roseman.
10) An authorization to obtain decedent's records from Retro Fitness
11) All documents reflecting decedent's financial contribution to the household
12) The name of the issuer of all credit cards that decedent used for the year 2015 including
the name of the primary person on the account
13) Copies of decedent's tax returns for the 3 years up to and including the date of her death
14) The amount of the fees paid, dates of payment and who paid the fees for the Becker CPA
preparation course
15) Hipaa compliant authorization to obtain decedent's No Fault records.
PLEASE TAKE FURTHER NOTICE, that submission to the undersigned of true and
conformed certified copies of the documents and/or items demanded herein on or before the
aforesaid return date will be deemed compliance with this demand notice.
PLEASE TAKE FURTHER NOTICE that in the event any of the requested documents
and/or items do not exist, a verified statement to that effect is to be served on the undersigned on
or before the aforesaid return date.
PLEASE TAKE FURTHER NOTICE, that this is a continuing demand notice and in the
event any of the requested documents and/or items are obtained after the aforesaid return date,
same are to be furnished to the undersigned within thirty (30) days after receipt.
PLEASE TAKE FURTHER NOTICE, that upon the failure to produce the requested
documents and/or items on the date and at the time and place demanded, a Motion will be made
for the appropriate relief.
PLEASE TAKE FURTHER NOTICE, that failure to comply with said demand
within thirty (30) days from the date herein will result in a motion for appropriate relief.
Dated: January 31, 2018
Melville, New York
Yours, etc.
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FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018
LAW OFFICE OF —
ANPREA G. SAWYERS
By: )
STEVEN A. STEI IERWALD
Attorneys for Defendant
CABOT COACH BUILDERS, INC
p
3 Huntington Quadrangle, Suite 102S
Melville, NY 11747
Mailing Address:
PO Box 2903
Hartford, CT 06104-2903
(631) 501-3100
Matter No.: 2017024539SAS
TO:
John J. Juliano, Esq.
Attorneys for Plaintiff
Estate of Brittany Schulman
39 Doyle Court
E. Northport, NY 11731
(631) 499-9300
Ahmuty Demers & McManus Esqs.
Attorneys for Defendants
Carlos F. Pino and Ultimate Class Limousine, Inc.
200 I.U. Willets Road
Albertson, NY 11507
Cascone & Klupfel, LLP
Attorneys for Defendant
Romero Dimon Marine Services, Inc.
1399 Franklin Avenue, Suite 302
Garden City, NY 11530
(516) 747-1990
Lewis Johs Avallone Aviles, LLP
Attorneys for Defendant
Steven D. Romeo
One CA Plaza
Suite 225
Islandia, NY 11749
(631) 755-0101
The Bongiorno Law Firm, PLLC
Attorneys for Plaintiff
Alicia M. Arundel
1415 Kellum Place
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FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018
Suite 205
Garden City, NY 11530
(516) 741-4170
Paris & Chaikin, PLLC
Attorneys for Plaintiff
Olga Lipets
14 Penn Plaza
Suite 2202
New York, NY 10122
Frank J. Laine, P.C.
Attorneys for Plaintiff
Estate of Amy Grabina
449 South Oyster Bay Road
Plainview, NY 11803
(516) 937-1010
Sullivan Papain Block McGrath & Cannavo, P.C.
Attorneys for Plaintiff
Estate of Lauren Baruch
1140 Franklin Avenue
Suite 200
Garden City, NY 11530
(516) 742-0707
Pegalis 4 Erickson, LLC
Attorneys for Plaintiff
Joelle Dimonte
One Hollow Lane
Suite 10
Lake Success, NY 11042
(516) 684-2939
Joseph J. Tock, Esq.
Attorney for Plaintiff
Melissa A. Crai
963 Route 6
Mahopac, NY 10541
(845) 628-8080
Devitt Spellman Barrett, LLP
Attorneys for Defendant
The Town of Southold
50 Route 111
Suite 314
Smithtown, NY 11787
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FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018
Suffolk County Attorney
Attorneys for Defendant 8
The County of Suffolk g
H. Lee Dennison Building
100 Veterans Memorial Highway
PO Box 6100
Hauppauge, NY 11788 I
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Preview
FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK -----------------------------------------------------------------------X ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS Index No.: 611214/15 ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY GRABINA, AS ADMINSTRATRIX OF THE ESTATE OF AMY GRABINA, AND MINDY GRABlNA, INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR OF THE ESTATE OF LAUREN BARUCH, DECEASED, AND STEVEN BARUCH, INDIVIDUALLY; JOELLE DIMONTE; AND MELISSA A. CRAI, Plaintiffs, NOTICE FOR DISCOVERY AND INSPECTION -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a 1-5" ROYALE LIMOUSINE and "XYZ COMPANIES name being fictitious but intended to be the remanufacturers, distributors and/or sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. ——————————— ——————X -----------------------------------------------------------------------X TO: Plaintiff, Mindy Grabina, as Administratrix of the Estate of Amy Grabina PLEASE TAKE NOTICE, that pursuant to CPLR 3101 et seq. and the applicable case law, you are hereby required to produce for discovery and supply to the undersigned attorneys for defendants within twenty (20) days from the date of service of this demand, the following information, documents and items requested for the purpose of inspection and/or copying: 1) Copies of all funeral and burial bills related to decedent 2) Copies of any photographs taken on the day of the incident involving the women on the trip,the vehicles and the drivers 3) Authorization to obtain decedent's college records. 1 of 5 FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018 4) Authorization to obtain decedent's employment records from Ernst & Young 5) Authorization to obtain decedent's employment records from Minsky & Grabina 6) The names and addresses of all people that plaintiff claims are witnesses to any claim that decedent experienced fear of impending death 7) The names and addresses of all people that plaintiff claims are witnesses to any claim that decedent experienced conscious pain and suffering 8) The names and addresses of all people that plaintiff claims are witnesses to any claim that decedent experienced pre-impact terror 9) The addresses of Eric Rosen, Marsha and Steve Merin and Pam and Allen Roseman. 10) An authorization to obtain decedent's records from Retro Fitness 11) All documents reflecting decedent's financial contribution to the household 12) The name of the issuer of all credit cards that decedent used for the year 2015 including the name of the primary person on the account 13) Copies of decedent's tax returns for the 3 years up to and including the date of her death 14) The amount of the fees paid, dates of payment and who paid the fees for the Becker CPA preparation course 15) Hipaa compliant authorization to obtain decedent's No Fault records. PLEASE TAKE FURTHER NOTICE, that submission to the undersigned of true and conformed certified copies of the documents and/or items demanded herein on or before the aforesaid return date will be deemed compliance with this demand notice. PLEASE TAKE FURTHER NOTICE that in the event any of the requested documents and/or items do not exist, a verified statement to that effect is to be served on the undersigned on or before the aforesaid return date. PLEASE TAKE FURTHER NOTICE, that this is a continuing demand notice and in the event any of the requested documents and/or items are obtained after the aforesaid return date, same are to be furnished to the undersigned within thirty (30) days after receipt. PLEASE TAKE FURTHER NOTICE, that upon the failure to produce the requested documents and/or items on the date and at the time and place demanded, a Motion will be made for the appropriate relief. PLEASE TAKE FURTHER NOTICE, that failure to comply with said demand within thirty (30) days from the date herein will result in a motion for appropriate relief. Dated: January 31, 2018 Melville, New York Yours, etc. 2 of 5 FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018 LAW OFFICE OF — ANPREA G. SAWYERS By: ) STEVEN A. STEI IERWALD Attorneys for Defendant CABOT COACH BUILDERS, INC p 3 Huntington Quadrangle, Suite 102S Melville, NY 11747 Mailing Address: PO Box 2903 Hartford, CT 06104-2903 (631) 501-3100 Matter No.: 2017024539SAS TO: John J. Juliano, Esq. Attorneys for Plaintiff Estate of Brittany Schulman 39 Doyle Court E. Northport, NY 11731 (631) 499-9300 Ahmuty Demers & McManus Esqs. Attorneys for Defendants Carlos F. Pino and Ultimate Class Limousine, Inc. 200 I.U. Willets Road Albertson, NY 11507 Cascone & Klupfel, LLP Attorneys for Defendant Romero Dimon Marine Services, Inc. 1399 Franklin Avenue, Suite 302 Garden City, NY 11530 (516) 747-1990 Lewis Johs Avallone Aviles, LLP Attorneys for Defendant Steven D. Romeo One CA Plaza Suite 225 Islandia, NY 11749 (631) 755-0101 The Bongiorno Law Firm, PLLC Attorneys for Plaintiff Alicia M. Arundel 1415 Kellum Place 3 of 5 FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018 Suite 205 Garden City, NY 11530 (516) 741-4170 Paris & Chaikin, PLLC Attorneys for Plaintiff Olga Lipets 14 Penn Plaza Suite 2202 New York, NY 10122 Frank J. Laine, P.C. Attorneys for Plaintiff Estate of Amy Grabina 449 South Oyster Bay Road Plainview, NY 11803 (516) 937-1010 Sullivan Papain Block McGrath & Cannavo, P.C. Attorneys for Plaintiff Estate of Lauren Baruch 1140 Franklin Avenue Suite 200 Garden City, NY 11530 (516) 742-0707 Pegalis 4 Erickson, LLC Attorneys for Plaintiff Joelle Dimonte One Hollow Lane Suite 10 Lake Success, NY 11042 (516) 684-2939 Joseph J. Tock, Esq. Attorney for Plaintiff Melissa A. Crai 963 Route 6 Mahopac, NY 10541 (845) 628-8080 Devitt Spellman Barrett, LLP Attorneys for Defendant The Town of Southold 50 Route 111 Suite 314 Smithtown, NY 11787 4 of 5 FILED: SUFFOLK COUNTY CLERK 01/31/2018 05:11 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 379 RECEIVED NYSCEF: 01/31/2018 Suffolk County Attorney Attorneys for Defendant 8 The County of Suffolk g H. Lee Dennison Building 100 Veterans Memorial Highway PO Box 6100 Hauppauge, NY 11788 I 5 of 5