Preview
FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
-------------------------------------------------------------------------)(
ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS
ADMINISTRATRI)( OF THE ESTATE OF BRITTNEY M. Index No. 611214/15
SCHULMAN, DECEASED; OLGA LIPETS; MINDY
GRABINA, AS ADMINISTRATRI)( OF THE ESTATE RESPONSE TO
OF AMY GRABINA, AND MINDY GRAB INA, SUPPLEMENTAL
INDIVIDUALL Y; STEVEN BARUCH, AS DEMAND TO
ADMINISTRATOR OF THE ESTATE OF LAUREN PRODUCE
BARUCH, DECEASED, AND STEVEN BARUCH
INDIVIDUALL Y; JOELLE DIMONTE; MELISSA A.
CRAI; ARTHUR A. BELLI JR., AS PARENT AND
NATURAL GUARDIAN OF STEPHANIE BELLI,
DECEASED, AND AS THE ADMINISTRATOR OF THE
ESTATE OF STEPHANIE BELLI,
Plaintiffs,
- against-
ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO,
ROMEO DIMON MARINE SERVICE, INC., STEVEN D.
ROMEO, TOWN OF SOUTHOLD, COUNTY OF
SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a
ROYALE LIMOUSINE and ")(YZ COMPANIES 1-5"
name being fictitious but intended to be the remanufacturers,
distributors andlor sellers of the 2007 Lincoln Town Car
stretch limousine involved in the collision,
Defendants.
-------------------------------------------------------------------------)(
SIRS:
PLEASE TAKE NOTICE, that defendant, TOWN OF SOUTHOLD, by their attorneys
LAW OFFICES OF THOMAS M. VOLZ, PLLC, in response to plaintiff Crai's, Further
Supplemental Demand to Produce, dated November-IS, 2019, state as follows upon information
and belief:
1. All communications, emails, texts messages, memos, documents between the Town of
Southold Engineer Jamie Richter and/or any representative, employee, andlor any agent of
the County of Suffolk regarding U-turns and traffic issues at CR 48 and Depot Lane.
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RESPONSE: Objection, the responding defendant objects to this request as overly broad,
unduly burdensome, indefinite in duration and timeframe and neither material nor necessary
to the prosecution of this matter, thus the demand is patently improper. Subject to the
objection, please see the enclosed documents bates stamped numbered TSOU000832 through
TSOU000833. The responding defendant reserves the right to supplement this response if and
when any additional discoverable information or documentation is discovered.
2. Any and all traffic and traffic control device studies, engineering, and site plans addressing
U-turns and traffic safety issues at CR 48 and Depot Lane regarding the premises known
and designated as 18910 County Rd 48 #48, Cutchogue, NY 11935, Town ofSouthold Tax
Map No. 890.9600.04000.04003 and also known as "Vineyard 48" from the following
departments with the Town of Southold: Building Department, Highway Department,
Planning Department, Public Works, Zoning Board of Appeals, Town Attorney, Town
Clerk, Town Trustees, Town Supervisor and the Town Board.
RESPONSE: Objection, the responding defendant objects to this request as overly broad, unduly
burdensome, indefinite in duration and timeframe and neither material nor necessary to the
prosecution of this matter, thus the demand is patently improper. Subject to the objection, please
see the enclosed documents bates stamped numbered TSOU000834 through TSOU000850. The
responding defendant reserves the right to supplement this response if and when any additional
discoverable information or documentation is discovered.
Dated: Nesconset, New York
November 27, 2019
Yours, etc.,
LAW OFFICES OF THOMAS M. VOLZ, PLLC
Attorneys for Defendant
TOWN OF SOUTHOLD
280 Smithtown Boulevard
TO: JOSEPH J. TOCK
Attorneys for Plaintiff
MELISSA A. CRAI
963 Route 6
Mahopac, New York 10541
(845) 628-8080
2
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LEWIS JOHS AVALLONE AVILES, LLP
Attorneys for Defendant
STEVEN D. ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
Attn: Rebecca K. Devlin, Esq.
(Your File No.: 0114.1460.003C)
CASCONE & KLUEPFEL LLP
Attn: David G. Kluepfel, Esq.
Attorneys for Defendant
ROMEO DIMON MARINE SERVICES, INC.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
(Your File No.: 04128DVM)
LAW OFFICES OF VINCENT D. McNAMARA
Attorneys for Defendant
COUNTY OF SUFFOLK
Tower Square- 1045 Oyster Bay Road, Suite 1
East Norwich, New York 11732
(Your File No.: 907-4577)
BONGIORNO, MONTIGLO & PALMIERI, PLLC
Attorneys for Defendants
ULTIMATE CLASS LIMOUSINE and CARLOS PINO
200 Old Country Road, Suite 680
Mineola, New York 11501
(516) 620-4490
(Your File No.: IBM 068515 NJP)
LAW OFFICE OF ANDREA G. SAWYERS
Attn: Steven A. Steigerwald, Esq.
Attorneys for Defendant
CABOT COACH BUILDERS, INC. d/b/a
ROYALE LIMOUSINE
3 Huntington Quadrangle, Suite 102S
Melville, New York 11747
(Your File No.: 2017024539SAS)
JOHN L. mLIANO, P.C.
Attorney for Plaintiff
ESTATE OF SHULMAN
39 Doyle Court
East Northport, New York 11731
3
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THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
ALICIA M. ARUNDEL
1415 Kellum Place, Suite 205
Garden City, New York 11530
SULLIVAN, PAPAIN, BLOCK,
McGRATH & CANNAVO, P.C.
Attorneys for Plaintiff
ESTATE OF BARUCH
1140 Franklin Avenue, Suite 200
Garden City, New York 11530
PEGALIS & ERICKSON, LLC
Attorneys for Plaintiff
JOELLE DIMONTE
One Hollow Lane, Suite 107
Lake Success, New York 11042
FRANK J. LAINE, P.C.
Attorneys for Plaintiff
ESTATE OF GRABINA
449 South Oyster Bay Road
Plainview, New York 11803
PARIS & CHAIKIN, PLLC
Attorney for Plaintiff
OLGALIPETS
14 Penn Plaza, Suite 2202
New York, New York 10122
BLOCK O'TOOLE & MURPHY, ESQS.
Attorneys for Plaintiff
ESTATE OF BELLI
One Penn Plaza, Suite 5315
New York, New York 10019
4
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Cummings, Brian A.
From: Hillman, Robert
Sent: Thursday, June 20, 2013 9:23 AM
To: Lanza, Heather
Cc: Cummings, Brian A.; Dresch, Daniel
Subject: RE: No Parking/Standing on CR 48 in Cutchogue
Heather,
The Town has the authority to restrict parking / stopping on CR 48 under the town code. Once a town board resolution
is passed to include the restriction in the town code, the Town is responsible to install and maintain the signage.
The one-way signs will be installed by SC DPW. We are preparing a work order now, so they should be installed soon.
Bob Hillman
SCDPW
631-852-4086
From: Lanza, Heather [mgilto~heather.la!lza@tOWIl.southold.I1Y,yS)
Sent: Thursday, June 20, 2013 8:53 AM
To: Hillman, Robert
Cc: Cummings, Brian A.
Subject: No Parking/Standing on CR 48 in Cutchogue
Bob,
What does SCDPW need from the Town to put up No Parking or Standing signs on CR48?
Does the Town put the signs up or SCDPW? Do you need a Town Board resolution? Or just a letter of request?
The same for the one-way signs across from their driveway(s) - we think those should go up immediately. Will SCDPW
take that responsibility or does the Town pay for and install those signs?
Also, we'll be sending another letter to you with the site plan asking for SCDPW's approval ofthe plan before we'll give
any approvals. What we'd be looking for from you is comments on the plan prior to any approvals by your agency.
Thanks for your help.
Heather
Heather Lanza,AICP
Town Planning Director
Southold Town Planning
53095 Route 25
P.O. Box 1179
Southold, New York 11971
Phone: (631)765*1938
E-mail: heathel',k!l1Y~JJ2Jl.~({wJ1!1Ld-,l1tl;~
1
CONFIDENTIAL TSOU000832
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NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019
No Parking or Standing signs on County Road 48 in Cutchogue.
Both sides ofthe road, from Depot Lane west to the private road approximately 1,420
feet. Areas where the signs are to be installed are shown in black below.
CONFIDENTIAL TSOU000833
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NRB Inc. 631-734-6235 p.1
SOlPrI-IOLD TI{ANSPORTr\TION
CO)-lwfISSION
TOIotI1HaN
P. O. Box 1119
53095 Mail! R!.la4
Southold. NY 11971-OIISS
i'hone (631) 1615-1938
F8lI (631) 765.:sJ3/i
TO: Heather Lanza
Town Planning Director
SeottA. Russell, Supervisor
FROM; Neboysha R Brashich ~ ~ ~ D- t..vt-Â
Chairman {
DATE: April25,2012
RE: The Draft AgricuHure Chapter for
Town's New Comprehensive Plan
During the Commission's monthly ApnT 23Jd meeting. subject draft chapter was
discussed.
As you are aware, the Commission prepared a draft farm stand ordinance
transportation element in June 2008 given our mounting concern with safety
issues surrounding parking at some fann stands. Representatives of the
Agricultural Committee were invited and participated in the ensuing discussions
regarding the rationale for this draft proposal. In the end. the Agricutture
Committee did not include this element in the farm stand ordinance.
The Commission decided to restate its case to the PJanning Board during the
open season for comments on the draft. chapter, given our continuing safety
issue concerns. Attached is the draft document in question.
Please let us know the outcome of this request.
Attachment: als
CONFIDENTIAL TSOU000834
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p.2
11/27/2019
NRBlno, 631-734-6235
PARK STJUn) ORDlHUCE TRANSPORTATION ELEMENT
DBFJ:lIITIOII
Retail Farm St:and (BPS). Farm stands operating primarily as
retail operations characterized by having relatively short
customer visit time (typicall.y less than flfteen minutes) for
the primary purpose of purchasing retail farm stand products.
Destina~ion Farm Sund (DFS). A farm stand where significant
reoreation, education, and entertai~~ent activities in addition
to retail sales, produce customer visit times of one hour or
more. .An RFS may be temporarily classified as a DFS when
conducting special one-day or weekend-long events.
Specia~ Event. Scbedu~ed DFS events that generate higber
customer traffic levels than normal operating hours traffic.
ACCESS
llighway access to both RFS and. DPS operations must conform to
applicable highway standards of the state, county, and or town
highways where they are located.
A dedicated access point must be provided for both RFS and DFS
operations to direct drivers off and back onto the highway fram
the stand'S parking area(s} _ ]?arking access may be a single
locat.ion, combining entrance and ekit or multi.ple entry/exit
points, depending on site layout and size.
PARKIRG
Existing code requires Retail Farm Stand operations to provide
one parking space for every 100 square feet of farm stand or
accessory greenhouse, per the exist.ing town code. An average
customer length of stay :for an RFS is assumed to be 10 minutes.
Destination Farm Stand operations lIlust declare t.beir anticipated
customer load and provide parking spaces adequate to support
this load, based on an averaqe customeJ: length of stay of one
bour. Addit.ional parking area(s) must be provided to support
soheduled Special Events.
TRAP'FIC CONTROL
DFS operations holding special events generating greater than
normal traffic loads will provide private traffic control
person( s) to direct customers into their parking lot (s). These
traffic control persons must per:formtheir duties on private
property and will not stand within the h~qhwa1 right-of-way_
l'agc 1 of ( Snbtlliued: June 2008 by Jim Baker
CONFIDENTIAL TSOU000835
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Jun 2813 02:11p NRB Ino. ( 11-734-6235 p.1
Pp, ~J~T\f£-
S()l7rlI() LJ) rrI~A.NSPO H.rr.A.TI ON
t(~
COIV[!\lISSION
Town Hall
: P.O.Box1179
•53095 Main Road
Southold. NY 11911"0959
Phone (631) 765-1938
Fax «(31) 165-1823
TO: Heather Lanza
Town Planning Director
FROM: Neboysha R Brashich
Chairman
DATE: June 26, 2013
RE: Amended Site Plan for Vineyard 48
Located at 18910 CR 48, Cutchogue
SCTM#: 1000-96-4-4.3
Further to your June 11th memorandum request, the Commission reviewed
subject site plan at our monthly meeting on June 17, 2013_
.Essentially, we felt that the plan did not address major public safety issues
surrounding this site.
Hence, the Commission would like to propose three recommendations for
consideration by the Planning Board:
1. "No Standing" signs should be erected from Zuhski's Lane to Depot Lane
on both sides of CR 48.
2. "Ingress and Egress" signs should be clearly marked and erected at this
site.
3. "Right Way Only" sign should be erected in the median across from the
egress area.
In addition, the Commission strongly recommends that parking of buses and
limos must follow Town Code requirements
CONFIDENTIAL TSOU000836
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NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019
Southold Transportation Commission
Southold Town Hall
June 17, 2013 Meeting
Called to Order 10:02 AM by Chainnan Neb Brashich.
Members Present:
Frank Field, Chief Martin Flatley, Margaret Brown, Planning Director Heather Lanza & Brian
Cummings, Jim Baker, Greenport Rep. Bob Feger, Rona Smith and Tom Fox. Town Engineer
Jamie Richter arrived just before adjournment.
Minutes of May 20, 2013
A motion to approve the minutes was made by Bob Feger, was seconded by Margaret Brown
and was carried.
Planning Board Requests
Town Comprehensive Plan
Issuance of the Transportation & Infrastructure Chapter has now been delayed to December
2013.
Vineyard 48 & ParkingfTraffic Problems, Cutchogue
Subsequent to his memo of June 11th concerning the amended site plan, Brian Cummings
made a video presentation of a Google Earth view of the Vineyard 48 site and the immediate
surrounding area.
The amended plan proposes a re-design of the existing parking areas and the addition of an
over-flow parking area in the rear for 100 parking spaces. Vehicular access to the rear parking
area would be via the fann road immediately west of the site with a pedestrian access path to
the venue.
It was reported that limos and buses currently park or wait on local residential roads and at
offsite locations such as the parking lot at Our Lady of Ostrabrama Church. After a discussion
of several suggestions, it was recommended that appropriate traffic control and parking signage
be placed on Route 48 and adjacent roads.
As the Town Code currently requires that buses, vans and limos park only on-site only, that
requirement should be strictly enforced as a matter of public safety.
East End Transportation Council
Fleet Fuel Management
Although neither Neb nor Heather were able to attend the June 12th meeting, Heather later
participated in an email exchange with EETC members concerning the difficulties associated
with implementing that proposal. As a starting alternative, Tom Fox suggested that only an East
End fuel purchasing consortium be considered, with bulk fuel deliveries to be scheduled to
designated individual municipal sites.
Supervisor's Requests
MTA Capital Plan for 2015-2019
Subsequent to the discussion at the Commission's May 20th meeting, local proposals
concerning that plan are now due by august, 4, 2013. Neb and Heather will discuss the issue.
CONFIDENTIAL TSOU000837
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Current Transportation Issues
Southold/Greenport Bus Shelters
Neb has learned from the SCDPW that the Greenport shelter is to be installed shortly.
However, in an unexpected development, renewed approval by the NYSDOT will be required for
placement of the Southold shelter.
Orientation I Interpretive Signage Project - RBA Phase II
As detailed in the SuperviSOr's memo, four proposals were received from bidders. The lowest
bid received was for $120,005, with the others at $122,911, $154,560 and $720,940. As
previously reported, about $99,000 is available for construction and installation of the project.
On that basis, as funding allows, priority will be given to the five kiosks with the four
interpretative signs to follow. The Supervisor will seek funding for the difference between the
$90,000 currently available and RBA's estimated cost.
The estimated total cost for each kiosk is about $15,000, while the signs should cost about
$4,500 each. RBA will redeSign the RFP proposal for resubmission.
SC Transit
NYS has given Suffolk County an increase of $2 million in its annual STOA funding (Surface
Transit Operating Assistance) to enhance SCT operations and to support increased service.
However, it has been reported that, after a compromise between the County Executive and the
County Legislature, only $1 million of that funding will be available for increased transit
operations.
Old Business
Parking Issues- Sterling Street, Greenport
Bob Feger thanked the Commission for its suggestions that public safety is an overriding issue
and that the proposal for adjusted parking spaces should be considered on that basis.
New Business
None
Next Meeting
The next meeting will take place on July 220,2013 at 10:00 AM in the conference room at
Town Hall.
Adjournment
11:06AM
Cc: Town Clerk
Respectfully submitted,
Thomas F. Fox
CONFIDENTIAL TSOU000838
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NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019
Josh Shteierman
From: Richter, Jamie
Sent: Wednesday, January 27, 2016 10:48 AM
To: Kiely, Stephen
Subject: FW: Roundabouts
James A. Richter
James A. Hichter, R.A.
StonnwaterManager
Office of the l'Algincer
Town or Southold, N ew York
Stormwater Management Control Plan Website:
http://www.southoldtownny,gQYIjndex.aspx:?nig=19~
Office: 631-765-1560
Cell: 631-926-9430
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged
information. It is solely for the use of the intended reciplent(s). Unauthorized interception, review, use or disclosure is
prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the
intended recipient, please contact the sender and destroy all copies of the communication.
From: Flatley, Martin
Sent: Thursday, January 29, 2009 9:52 PM
To: Richter, Jamie
Subject: RE: Roundabouts
I understand your pOint, we should talk. I'll give you a call and discuss
From: Richter, Jamie
Sent: Tuesday, January 27, 2009 12:59 PM
To: Flatley, Martin
Subject: RE: Roundabouts
Hi Marty:
I would agree with one exception.
Roundabouts do not work very well in concert with traffic control lights.
What I mean is that if you have a traffic control light within a short distance of a roundabout it will defeat the purpose.
I also disagree that several roundabouts in succession would slot traffic too much.
There have been cases in up state NY where this was also a fear prior to construction.
One such project was scaled back to two, one at each end of the project.
Within months of completion it was evident that they were wrong.
A second project was then initiated and the other four roundabouts were installed in between the first two.
When you get a chance, we should talk.
I would rather ask for more than we need and scale back rather than the other way around.
CONFIDENTIAL
1 TSOU000839
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Jamie
From: Flatley, Martin
Sent: Tuesday, January 27,2009 11:08 AM
To: Richter, Jamie
Subject: RE: Roundabouts
Hi Jamie,
As you know, I am a proponent of roundabouts on Rt. 48, I just feel that too many of them in one localized area would
slow the traffic flow too much. I would be more in favor of one, tops two, per hamlet such as: Rt 48 and Cox Neck
Rt. 48 and Wickham
Rt. 48 and Cox's Lane
Rt. 48 and Peconic Lane
Rt. 48 and Youngs
And Rt. 48 and Main Street, Gpt
I too feel that Rt. 25 and Love Lane is a good choice
From: Richter, Jamie
Sent: Tuesday, January 27,2009 8:32 AM
To: Flatley, Martin
Subject: Roundabouts
Hi Marty:
I wanted to give you a preliminary look at the intersections I feel would be better suited as a roundabout.
Please take a look and let me know what you think about these intersections.
Street Cross Street Hamlet
Route 25 Love Lane Mattituck
Route 48 Cox Neck Road Mattituck
Route 48 Westphalia Road Mattituck
Route 48 Wickham Avenue Mattituck
Route 48 Depot Lane Cutchogue
Route 48 Cox's Lane Cutchogue
Route 48 Peconic Lane Peconic
Route 48 Horton's Lane Southold
Route 48 Young's Avenue Southold
Route 48 Boisseau Avenue Southold
Route 48 Main Street / Route 25 Greenport
Basically, almost all of these locations have some form of Traffic light.
The intersection of Love Lane needs traffic calming for many reasons.
A roundabout at this location will also afford better pedestrian traffic safety.
Boisseau has already been modified or constructed to handle traffic.
However, if we start a program to upgrade the other intersections, this location could be made conforming.
Let me know your feeling on these locations.
We should discuss this before I put a package together for Neb.
CONFIDENTIAL 2 TSOU000840
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NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019
Jamie
3
CONFIDENTIAL TSOU000841
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NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019
MAY 27,2008 01:13P 6311346235
~o t ,"'PI f()f.l) 'rl·L\ :\'fSPO I~r"/\,PIOX
(~()Ml\rISSIOX
TOI'fIIH~11
P.O.llulll79
530~5 Main Rwd
So\ItIIokI. HI'111l11,OOOO
PIIooe 16311 1115· 1138
f.. 16$11766·3136
TO: Heather M. Lanza, Director of Plann~. K
FROM: Nebaysha R. Brashich. Chairman·· ~. O/...l.tfr-
DATE: May 27, 2008
RE: Peconic Recycling and Transfer Station Project - Depot Lane
As discussed in today's monthly Commission meeting. we had been informed
that the Planning Board had requested a SEQRA review of subject project. There
was a possibility that this process may engender a calJ for a trafficlight at the
intersedion of Depot Lane and County Road 48 currently serviced by a flashing
light.
The Commission would like to state for the record that
• the area behind the Town Landfill had been zoned commercial quite II few
years ago;
III the Town Board had voted to keep County Road 48 as a pass-through
mute also a number of years ago; and,
• adding additional traffic lights would only further negate the effema of this
policy.
There is at traffIC light at the Intersection of Cox l.ana and County Road 46 that
provides sufficient Intervals to enable egress and Ingress from Depot Lane.
Hence, the Commission is not in favor of replacing th,fl eJl,dng flashing IQHt: rors" .......,
traffic light. ) ,'.
n'\' \.,1::-Â\
4~''''
,.;,',
MAY 2. {
CONFIDENTIAL TSOU000842
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NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019
Jun281302:11p NRBlno. ( 11-734-6235 p.1
P0\~J~T\rc
~~[t
SO{;rrIIOLD'I'HANSPOH.rrATION
COl\:{~fISSION
•Town Hall
P. O. Box 1179
~ 53005 Main Road
; Southold./(( 11971-0959
; Phone (631)165·1938
. Fax (631) 765·1823
TO: Heather Lanza
Town Planning Director
FROM: Neboysha R Brashich
Chairman
DATE: June 26,2013
RE: Amended Site Plan for Vineyard 48
Located at 18910 CR 48. Cutchogue
SCTM#: 1000-96-4-4.3
Further to your June 11th memorandum request, the Commission reviewed
subject site plan at our monthly meeting on June 17. 2013 .
.Essentially. we felt that the plan did not address major public safety issues
surrounding this site.
Hence, the Commission would like to propose three recommendations for
consideration by the Planning Board:
1. "No Standing" signs should be erected from Zuhski's Lane to Depot Lane
on both sides of CR 48.
2. "Ingress and Egress" signs should be clearly marked and erected at this
site.
3. "Right Way Only" sign should be erected in the median across from the
egress area.
In addition. the Commission strongly recommends that parking of buses and
limos must follow Town Code requirements
CONFIDENTIAL TSOU000843
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NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019
MAILING ADDRESS:
PLANNING BOARD MEl\mERS P.O. Box 1179
DONALD J. WILCENSKI Southold, NY 11971
Chair
OFFICE LOCATION:
WILLIAM J. CREMERS Town Hall Annex
PIERCE RAFFERTY 54375 State Route 25
JAMES H. RICH m (cor. Main Rd. & Youngs Ave.)
MART1N H. SID
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FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK -------------------------------------------------------------------------)( ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS ADMINISTRATRI)( OF THE ESTATE OF BRITTNEY M. Index No. 611214/15 SCHULMAN, DECEASED; OLGA LIPETS; MINDY GRABINA, AS ADMINISTRATRI)( OF THE ESTATE RESPONSE TO OF AMY GRABINA, AND MINDY GRAB INA, SUPPLEMENTAL INDIVIDUALL Y; STEVEN BARUCH, AS DEMAND TO ADMINISTRATOR OF THE ESTATE OF LAUREN PRODUCE BARUCH, DECEASED, AND STEVEN BARUCH INDIVIDUALL Y; JOELLE DIMONTE; MELISSA A. CRAI; ARTHUR A. BELLI JR., AS PARENT AND NATURAL GUARDIAN OF STEPHANIE BELLI, DECEASED, AND AS THE ADMINISTRATOR OF THE ESTATE OF STEPHANIE BELLI, Plaintiffs, - against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN D. ROMEO, TOWN OF SOUTHOLD, COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a ROYALE LIMOUSINE and ")(YZ COMPANIES 1-5" name being fictitious but intended to be the remanufacturers, distributors andlor sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. -------------------------------------------------------------------------)( SIRS: PLEASE TAKE NOTICE, that defendant, TOWN OF SOUTHOLD, by their attorneys LAW OFFICES OF THOMAS M. VOLZ, PLLC, in response to plaintiff Crai's, Further Supplemental Demand to Produce, dated November-IS, 2019, state as follows upon information and belief: 1. All communications, emails, texts messages, memos, documents between the Town of Southold Engineer Jamie Richter and/or any representative, employee, andlor any agent of the County of Suffolk regarding U-turns and traffic issues at CR 48 and Depot Lane. 1 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 RESPONSE: Objection, the responding defendant objects to this request as overly broad, unduly burdensome, indefinite in duration and timeframe and neither material nor necessary to the prosecution of this matter, thus the demand is patently improper. Subject to the objection, please see the enclosed documents bates stamped numbered TSOU000832 through TSOU000833. The responding defendant reserves the right to supplement this response if and when any additional discoverable information or documentation is discovered. 2. Any and all traffic and traffic control device studies, engineering, and site plans addressing U-turns and traffic safety issues at CR 48 and Depot Lane regarding the premises known and designated as 18910 County Rd 48 #48, Cutchogue, NY 11935, Town ofSouthold Tax Map No. 890.9600.04000.04003 and also known as "Vineyard 48" from the following departments with the Town of Southold: Building Department, Highway Department, Planning Department, Public Works, Zoning Board of Appeals, Town Attorney, Town Clerk, Town Trustees, Town Supervisor and the Town Board. RESPONSE: Objection, the responding defendant objects to this request as overly broad, unduly burdensome, indefinite in duration and timeframe and neither material nor necessary to the prosecution of this matter, thus the demand is patently improper. Subject to the objection, please see the enclosed documents bates stamped numbered TSOU000834 through TSOU000850. The responding defendant reserves the right to supplement this response if and when any additional discoverable information or documentation is discovered. Dated: Nesconset, New York November 27, 2019 Yours, etc., LAW OFFICES OF THOMAS M. VOLZ, PLLC Attorneys for Defendant TOWN OF SOUTHOLD 280 Smithtown Boulevard TO: JOSEPH J. TOCK Attorneys for Plaintiff MELISSA A. CRAI 963 Route 6 Mahopac, New York 10541 (845) 628-8080 2 2 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 LEWIS JOHS AVALLONE AVILES, LLP Attorneys for Defendant STEVEN D. ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 Attn: Rebecca K. Devlin, Esq. (Your File No.: 0114.1460.003C) CASCONE & KLUEPFEL LLP Attn: David G. Kluepfel, Esq. Attorneys for Defendant ROMEO DIMON MARINE SERVICES, INC. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 (Your File No.: 04128DVM) LAW OFFICES OF VINCENT D. McNAMARA Attorneys for Defendant COUNTY OF SUFFOLK Tower Square- 1045 Oyster Bay Road, Suite 1 East Norwich, New York 11732 (Your File No.: 907-4577) BONGIORNO, MONTIGLO & PALMIERI, PLLC Attorneys for Defendants ULTIMATE CLASS LIMOUSINE and CARLOS PINO 200 Old Country Road, Suite 680 Mineola, New York 11501 (516) 620-4490 (Your File No.: IBM 068515 NJP) LAW OFFICE OF ANDREA G. SAWYERS Attn: Steven A. Steigerwald, Esq. Attorneys for Defendant CABOT COACH BUILDERS, INC. d/b/a ROYALE LIMOUSINE 3 Huntington Quadrangle, Suite 102S Melville, New York 11747 (Your File No.: 2017024539SAS) JOHN L. mLIANO, P.C. Attorney for Plaintiff ESTATE OF SHULMAN 39 Doyle Court East Northport, New York 11731 3 3 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff ALICIA M. ARUNDEL 1415 Kellum Place, Suite 205 Garden City, New York 11530 SULLIVAN, PAPAIN, BLOCK, McGRATH & CANNAVO, P.C. Attorneys for Plaintiff ESTATE OF BARUCH 1140 Franklin Avenue, Suite 200 Garden City, New York 11530 PEGALIS & ERICKSON, LLC Attorneys for Plaintiff JOELLE DIMONTE One Hollow Lane, Suite 107 Lake Success, New York 11042 FRANK J. LAINE, P.C. Attorneys for Plaintiff ESTATE OF GRABINA 449 South Oyster Bay Road Plainview, New York 11803 PARIS & CHAIKIN, PLLC Attorney for Plaintiff OLGALIPETS 14 Penn Plaza, Suite 2202 New York, New York 10122 BLOCK O'TOOLE & MURPHY, ESQS. Attorneys for Plaintiff ESTATE OF BELLI One Penn Plaza, Suite 5315 New York, New York 10019 4 4 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 Cummings, Brian A. From: Hillman, Robert Sent: Thursday, June 20, 2013 9:23 AM To: Lanza, Heather Cc: Cummings, Brian A.; Dresch, Daniel Subject: RE: No Parking/Standing on CR 48 in Cutchogue Heather, The Town has the authority to restrict parking / stopping on CR 48 under the town code. Once a town board resolution is passed to include the restriction in the town code, the Town is responsible to install and maintain the signage. The one-way signs will be installed by SC DPW. We are preparing a work order now, so they should be installed soon. Bob Hillman SCDPW 631-852-4086 From: Lanza, Heather [mgilto~heather.la!lza@tOWIl.southold.I1Y,yS) Sent: Thursday, June 20, 2013 8:53 AM To: Hillman, Robert Cc: Cummings, Brian A. Subject: No Parking/Standing on CR 48 in Cutchogue Bob, What does SCDPW need from the Town to put up No Parking or Standing signs on CR48? Does the Town put the signs up or SCDPW? Do you need a Town Board resolution? Or just a letter of request? The same for the one-way signs across from their driveway(s) - we think those should go up immediately. Will SCDPW take that responsibility or does the Town pay for and install those signs? Also, we'll be sending another letter to you with the site plan asking for SCDPW's approval ofthe plan before we'll give any approvals. What we'd be looking for from you is comments on the plan prior to any approvals by your agency. Thanks for your help. Heather Heather Lanza,AICP Town Planning Director Southold Town Planning 53095 Route 25 P.O. Box 1179 Southold, New York 11971 Phone: (631)765*1938 E-mail: heathel',k!l1Y~JJ2Jl.~({wJ1!1Ld-,l1tl;~ 1 CONFIDENTIAL TSOU000832 5 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 No Parking or Standing signs on County Road 48 in Cutchogue. Both sides ofthe road, from Depot Lane west to the private road approximately 1,420 feet. Areas where the signs are to be installed are shown in black below. CONFIDENTIAL TSOU000833 6 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 NRB Inc. 631-734-6235 p.1 SOlPrI-IOLD TI{ANSPORTr\TION CO)-lwfISSION TOIotI1HaN P. O. Box 1119 53095 Mail! R!.la4 Southold. NY 11971-OIISS i'hone (631) 1615-1938 F8lI (631) 765.:sJ3/i TO: Heather Lanza Town Planning Director SeottA. Russell, Supervisor FROM; Neboysha R Brashich ~ ~ ~ D- t..vt- Chairman { DATE: April25,2012 RE: The Draft AgricuHure Chapter for Town's New Comprehensive Plan During the Commission's monthly ApnT 23Jd meeting. subject draft chapter was discussed. As you are aware, the Commission prepared a draft farm stand ordinance transportation element in June 2008 given our mounting concern with safety issues surrounding parking at some fann stands. Representatives of the Agricultural Committee were invited and participated in the ensuing discussions regarding the rationale for this draft proposal. In the end. the Agricutture Committee did not include this element in the farm stand ordinance. The Commission decided to restate its case to the PJanning Board during the open season for comments on the draft. chapter, given our continuing safety issue concerns. Attached is the draft document in question. Please let us know the outcome of this request. Attachment: als CONFIDENTIAL TSOU000834 7 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: p.2 11/27/2019 NRBlno, 631-734-6235 PARK STJUn) ORDlHUCE TRANSPORTATION ELEMENT DBFJ:lIITIOII Retail Farm St:and (BPS). Farm stands operating primarily as retail operations characterized by having relatively short customer visit time (typicall.y less than flfteen minutes) for the primary purpose of purchasing retail farm stand products. Destina~ion Farm Sund (DFS). A farm stand where significant reoreation, education, and entertai~~ent activities in addition to retail sales, produce customer visit times of one hour or more. .An RFS may be temporarily classified as a DFS when conducting special one-day or weekend-long events. Specia~ Event. Scbedu~ed DFS events that generate higber customer traffic levels than normal operating hours traffic. ACCESS llighway access to both RFS and. DPS operations must conform to applicable highway standards of the state, county, and or town highways where they are located. A dedicated access point must be provided for both RFS and DFS operations to direct drivers off and back onto the highway fram the stand'S parking area(s} _ ]?arking access may be a single locat.ion, combining entrance and ekit or multi.ple entry/exit points, depending on site layout and size. PARKIRG Existing code requires Retail Farm Stand operations to provide one parking space for every 100 square feet of farm stand or accessory greenhouse, per the exist.ing town code. An average customer length of stay :for an RFS is assumed to be 10 minutes. Destination Farm Stand operations lIlust declare t.beir anticipated customer load and provide parking spaces adequate to support this load, based on an averaqe customeJ: length of stay of one bour. Addit.ional parking area(s) must be provided to support soheduled Special Events. TRAP'FIC CONTROL DFS operations holding special events generating greater than normal traffic loads will provide private traffic control person( s) to direct customers into their parking lot (s). These traffic control persons must per:formtheir duties on private property and will not stand within the h~qhwa1 right-of-way_ l'agc 1 of ( Snbtlliued: June 2008 by Jim Baker CONFIDENTIAL TSOU000835 8 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 Jun 2813 02:11p NRB Ino. ( 11-734-6235 p.1 Pp, ~J~T\f£- S()l7rlI() LJ) rrI~A.NSPO H.rr.A.TI ON t(~ COIV[!\lISSION Town Hall : P.O.Box1179 •53095 Main Road Southold. NY 11911"0959 Phone (631) 765-1938 Fax «(31) 165-1823 TO: Heather Lanza Town Planning Director FROM: Neboysha R Brashich Chairman DATE: June 26, 2013 RE: Amended Site Plan for Vineyard 48 Located at 18910 CR 48, Cutchogue SCTM#: 1000-96-4-4.3 Further to your June 11th memorandum request, the Commission reviewed subject site plan at our monthly meeting on June 17, 2013_ .Essentially, we felt that the plan did not address major public safety issues surrounding this site. Hence, the Commission would like to propose three recommendations for consideration by the Planning Board: 1. "No Standing" signs should be erected from Zuhski's Lane to Depot Lane on both sides of CR 48. 2. "Ingress and Egress" signs should be clearly marked and erected at this site. 3. "Right Way Only" sign should be erected in the median across from the egress area. In addition, the Commission strongly recommends that parking of buses and limos must follow Town Code requirements CONFIDENTIAL TSOU000836 9 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 Southold Transportation Commission Southold Town Hall June 17, 2013 Meeting Called to Order 10:02 AM by Chainnan Neb Brashich. Members Present: Frank Field, Chief Martin Flatley, Margaret Brown, Planning Director Heather Lanza & Brian Cummings, Jim Baker, Greenport Rep. Bob Feger, Rona Smith and Tom Fox. Town Engineer Jamie Richter arrived just before adjournment. Minutes of May 20, 2013 A motion to approve the minutes was made by Bob Feger, was seconded by Margaret Brown and was carried. Planning Board Requests Town Comprehensive Plan Issuance of the Transportation & Infrastructure Chapter has now been delayed to December 2013. Vineyard 48 & ParkingfTraffic Problems, Cutchogue Subsequent to his memo of June 11th concerning the amended site plan, Brian Cummings made a video presentation of a Google Earth view of the Vineyard 48 site and the immediate surrounding area. The amended plan proposes a re-design of the existing parking areas and the addition of an over-flow parking area in the rear for 100 parking spaces. Vehicular access to the rear parking area would be via the fann road immediately west of the site with a pedestrian access path to the venue. It was reported that limos and buses currently park or wait on local residential roads and at offsite locations such as the parking lot at Our Lady of Ostrabrama Church. After a discussion of several suggestions, it was recommended that appropriate traffic control and parking signage be placed on Route 48 and adjacent roads. As the Town Code currently requires that buses, vans and limos park only on-site only, that requirement should be strictly enforced as a matter of public safety. East End Transportation Council Fleet Fuel Management Although neither Neb nor Heather were able to attend the June 12th meeting, Heather later participated in an email exchange with EETC members concerning the difficulties associated with implementing that proposal. As a starting alternative, Tom Fox suggested that only an East End fuel purchasing consortium be considered, with bulk fuel deliveries to be scheduled to designated individual municipal sites. Supervisor's Requests MTA Capital Plan for 2015-2019 Subsequent to the discussion at the Commission's May 20th meeting, local proposals concerning that plan are now due by august, 4, 2013. Neb and Heather will discuss the issue. CONFIDENTIAL TSOU000837 10 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 Current Transportation Issues Southold/Greenport Bus Shelters Neb has learned from the SCDPW that the Greenport shelter is to be installed shortly. However, in an unexpected development, renewed approval by the NYSDOT will be required for placement of the Southold shelter. Orientation I Interpretive Signage Project - RBA Phase II As detailed in the SuperviSOr's memo, four proposals were received from bidders. The lowest bid received was for $120,005, with the others at $122,911, $154,560 and $720,940. As previously reported, about $99,000 is available for construction and installation of the project. On that basis, as funding allows, priority will be given to the five kiosks with the four interpretative signs to follow. The Supervisor will seek funding for the difference between the $90,000 currently available and RBA's estimated cost. The estimated total cost for each kiosk is about $15,000, while the signs should cost about $4,500 each. RBA will redeSign the RFP proposal for resubmission. SC Transit NYS has given Suffolk County an increase of $2 million in its annual STOA funding (Surface Transit Operating Assistance) to enhance SCT operations and to support increased service. However, it has been reported that, after a compromise between the County Executive and the County Legislature, only $1 million of that funding will be available for increased transit operations. Old Business Parking Issues- Sterling Street, Greenport Bob Feger thanked the Commission for its suggestions that public safety is an overriding issue and that the proposal for adjusted parking spaces should be considered on that basis. New Business None Next Meeting The next meeting will take place on July 220,2013 at 10:00 AM in the conference room at Town Hall. Adjournment 11:06AM Cc: Town Clerk Respectfully submitted, Thomas F. Fox CONFIDENTIAL TSOU000838 11 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 Josh Shteierman From: Richter, Jamie Sent: Wednesday, January 27, 2016 10:48 AM To: Kiely, Stephen Subject: FW: Roundabouts James A. Richter James A. Hichter, R.A. StonnwaterManager Office of the l'Algincer Town or Southold, N ew York Stormwater Management Control Plan Website: http://www.southoldtownny,gQYIjndex.aspx:?nig=19~ Office: 631-765-1560 Cell: 631-926-9430 CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended reciplent(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication. From: Flatley, Martin Sent: Thursday, January 29, 2009 9:52 PM To: Richter, Jamie Subject: RE: Roundabouts I understand your pOint, we should talk. I'll give you a call and discuss From: Richter, Jamie Sent: Tuesday, January 27, 2009 12:59 PM To: Flatley, Martin Subject: RE: Roundabouts Hi Marty: I would agree with one exception. Roundabouts do not work very well in concert with traffic control lights. What I mean is that if you have a traffic control light within a short distance of a roundabout it will defeat the purpose. I also disagree that several roundabouts in succession would slot traffic too much. There have been cases in up state NY where this was also a fear prior to construction. One such project was scaled back to two, one at each end of the project. Within months of completion it was evident that they were wrong. A second project was then initiated and the other four roundabouts were installed in between the first two. When you get a chance, we should talk. I would rather ask for more than we need and scale back rather than the other way around. CONFIDENTIAL 1 TSOU000839 12 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 Jamie From: Flatley, Martin Sent: Tuesday, January 27,2009 11:08 AM To: Richter, Jamie Subject: RE: Roundabouts Hi Jamie, As you know, I am a proponent of roundabouts on Rt. 48, I just feel that too many of them in one localized area would slow the traffic flow too much. I would be more in favor of one, tops two, per hamlet such as: Rt 48 and Cox Neck Rt. 48 and Wickham Rt. 48 and Cox's Lane Rt. 48 and Peconic Lane Rt. 48 and Youngs And Rt. 48 and Main Street, Gpt I too feel that Rt. 25 and Love Lane is a good choice From: Richter, Jamie Sent: Tuesday, January 27,2009 8:32 AM To: Flatley, Martin Subject: Roundabouts Hi Marty: I wanted to give you a preliminary look at the intersections I feel would be better suited as a roundabout. Please take a look and let me know what you think about these intersections. Street Cross Street Hamlet Route 25 Love Lane Mattituck Route 48 Cox Neck Road Mattituck Route 48 Westphalia Road Mattituck Route 48 Wickham Avenue Mattituck Route 48 Depot Lane Cutchogue Route 48 Cox's Lane Cutchogue Route 48 Peconic Lane Peconic Route 48 Horton's Lane Southold Route 48 Young's Avenue Southold Route 48 Boisseau Avenue Southold Route 48 Main Street / Route 25 Greenport Basically, almost all of these locations have some form of Traffic light. The intersection of Love Lane needs traffic calming for many reasons. A roundabout at this location will also afford better pedestrian traffic safety. Boisseau has already been modified or constructed to handle traffic. However, if we start a program to upgrade the other intersections, this location could be made conforming. Let me know your feeling on these locations. We should discuss this before I put a package together for Neb. CONFIDENTIAL 2 TSOU000840 13 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 Jamie 3 CONFIDENTIAL TSOU000841 14 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 MAY 27,2008 01:13P 6311346235 ~o t ,"'PI f()f.l) 'rl·L\ :\'fSPO I~r"/\,PIOX (~()Ml\rISSIOX TOI'fIIH~11 P.O.llulll79 530~5 Main Rwd So\ItIIokI. HI'111l11,OOOO PIIooe 16311 1115· 1138 f.. 16$11766·3136 TO: Heather M. Lanza, Director of Plann~. K FROM: Nebaysha R. Brashich. Chairman·· ~. O/...l.tfr- DATE: May 27, 2008 RE: Peconic Recycling and Transfer Station Project - Depot Lane As discussed in today's monthly Commission meeting. we had been informed that the Planning Board had requested a SEQRA review of subject project. There was a possibility that this process may engender a calJ for a trafficlight at the intersedion of Depot Lane and County Road 48 currently serviced by a flashing light. The Commission would like to state for the record that • the area behind the Town Landfill had been zoned commercial quite II few years ago; III the Town Board had voted to keep County Road 48 as a pass-through mute also a number of years ago; and, • adding additional traffic lights would only further negate the effema of this policy. There is at traffIC light at the Intersection of Cox l.ana and County Road 46 that provides sufficient Intervals to enable egress and Ingress from Depot Lane. Hence, the Commission is not in favor of replacing th,fl eJl,dng flashing IQHt: rors" ......., traffic light. ) ,'. n'\' \.,1::-Â\ 4~'''' ,.;,', MAY 2. { CONFIDENTIAL TSOU000842 15 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 Jun281302:11p NRBlno. ( 11-734-6235 p.1 P0\~J~T\rc ~~[t SO{;rrIIOLD'I'HANSPOH.rrATION COl\:{~fISSION •Town Hall P. O. Box 1179 ~ 53005 Main Road ; Southold./(( 11971-0959 ; Phone (631)165·1938 . Fax (631) 765·1823 TO: Heather Lanza Town Planning Director FROM: Neboysha R Brashich Chairman DATE: June 26,2013 RE: Amended Site Plan for Vineyard 48 Located at 18910 CR 48. Cutchogue SCTM#: 1000-96-4-4.3 Further to your June 11th memorandum request, the Commission reviewed subject site plan at our monthly meeting on June 17. 2013 . .Essentially. we felt that the plan did not address major public safety issues surrounding this site. Hence, the Commission would like to propose three recommendations for consideration by the Planning Board: 1. "No Standing" signs should be erected from Zuhski's Lane to Depot Lane on both sides of CR 48. 2. "Ingress and Egress" signs should be clearly marked and erected at this site. 3. "Right Way Only" sign should be erected in the median across from the egress area. In addition. the Commission strongly recommends that parking of buses and limos must follow Town Code requirements CONFIDENTIAL TSOU000843 16 of 25 FILED: SUFFOLK COUNTY CLERK 11/27/2019 12:37 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 599 RECEIVED NYSCEF: 11/27/2019 MAILING ADDRESS: PLANNING BOARD MEl\mERS P.O. Box 1179 DONALD J. WILCENSKI Southold, NY 11971 Chair OFFICE LOCATION: WILLIAM J. CREMERS Town Hall Annex PIERCE RAFFERTY 54375 State Route 25 JAMES H. RICH m (cor. Main Rd. & Youngs Ave.) MART1N H. SID