Motion-Secondary: Tameka Mccants v. Joseph Franchi Jr., Roosevelt Island Operating Corporation

On May 29, 2014 a Motion-Secondary was filed involving a dispute between Tameka Mccants, and Joseph Franchi Jr., Roosevelt Island Operating Corporation, for Tort in the District Court of New York County.

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FILED: NEW YORK COUNTY CLERK 06/19/2020 05:03 PM INDEX NO. 155252/2014
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/19/2020

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK Index No.: 155252/2014
---------------------------------------------------------------------X
TAMEKA MCCANTS, Action No.: 1

Plaintiff, -
AFFIRMATION IN
-against- OPPOSITION

JOSEPH FRANCHI JR. as driver and ROOSEVELT
ISLAND OPERATING CORPORATION, as owner, ORAL ARGUMENT
REQUESTED
Defendants.
---------------------------------------------------------------------X
MARIE LOMBARD, Index No.: 158126/14

Plaintiff, Action No.: 2

-against- (DISMISSED)

TAMEKA MCCANTS, JOSEPH FRANCHI, JR.,
ROOSEVELT ISLAND OPERATING CORPORATION,
NEW YORK CITY TRANSIT AUTHORITY, MTA BUS
COMPANY and METROPOLITAN
TRANSPORTATION AUTHORITY,

Defendants.
---------------------------------------------------------------------X

ERIC J. BERGER, an attorney duly admitted to practice in the courts of the State of New

York, hereby affirms under penalty of perjury as follows:

1. I am a member of the firm Cozen O’Connor, attorneys for defendants, JOSEPH

FRANCHI, JR. and ROOSEVELT ISLAND OPERATING CORPORATION (collectively

hereinafter “defendants”), in the above entitled action, and, as such, I am fully aware of the facts

and circumstances of the above-captioned action.

2. This Affirmation is respectfully submitted in opposition to the motion of plaintiff

Tameka McCants (“plaintiff” or “McCants”) to preclude defendants’ experts, accident

reconstructionist John Scott and biomechanical engineer Richard Bandstra, Ph.D.

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3. Plaintiff’s motion to preclude defendants’ accident reconstruction and

biomechanical experts is nothing more than a thinly veiled attempt to improperly gut defendants’

comparative liability and medical causation defenses and create settlement leverage by referencing

cases that do not stand for the principals plaintiff’s counsel cites, are outdated in the State of New

York, and are inapplicable as decisions from other jurisdictions that do not apply New York’s

longstanding Frye jurisprudence.. Simply stated, Mr. Scott and Dr. Bandstra are well qualified

experts, whose subject matter, substance and grounds for the opinions on which they are expected

to testify were disclosed in far more reasonable detail than required by CPLR 3101(d) and are

generally accepted within the scientific community. Thus, plaintiff’s motion should be denied in

its entirety and both Mr. Scott and Dr. Bandstra should be permitted to testify at trial.

A. There is No Basis to Preclude Accident Reconstruction Expert John Scott.

1. The issue of comparative liability is still one to be determined by a jury and
Mr. Scott’s opinions do not usurp the jury’s role.

4. In its summary judgment decision, this Court stated, in pertinent part, that

defendants are entitled to prove the comparative negligence of plaintiff at trial:

Her potential culpable conduct for failing to act reasonably under
the circumstances [by driving too quickly and failing to honk her
horn], if any, is a question for the trier of fact and does not prevent
her obtaining judgment against the adverse vehicle owner and
driver.

See Rodriguez v. City of New York, 31 N.Y.3d 312 (2018).

5. The above finding and Rodriguez, supra, and its progeny, make clear that although

partial summary judgment is granted against defendants, they are still entitled to a full and fair

opportunity to present a case of comparative fault against plaintiff and permit the jury to assign

percentages of fault.

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6. To prove a prima facie case that McCants was comparatively negligent, defendants

must present evidence in admissible form. One means of doing so is to present the testimony of an

accident reconstruction expert who visited the accident scene and took measurements.

7. Expert testimony is admissible if it would help clarify an issue calling for

professional or technical knowledge beyond the ken of typical jurors. De Long v County of Erie,

60 N.Y.2d. 296, 307 (1983). The Third Department has held that “[t]he pivotal concern is whether

such testimony would be helpful, as opposed to unduly confusing.” Goverski v Miller, 282 A.D.2d

789, 790, (2001), citing Prince, Richardson on Evidence § 7-301, at 457 [Farrell 11th ed.].

8. In People v. Lee, 96 N.Y.2d 157 (2001), the Court of Appeals held that

[i]t is for the trial court in the first instance to determine when jurors
are able to draw conclusions from the evidence based on their day-
to-day experience, their common observation and their knowledge,
and when they would be benefited by the specialized knowledge of
an expert witness.’ Essentially, the trial court assesses whether the
proffered expert testimony ‘would aid a lay jury in reaching a
verdict.’ In rendering this determination, courts should be wary not
to exclude such testimony merely because, to some degree, it
invades the jury's province. As we have previously noted, ‘[e]xpert
opinion testimony is used in partial substitution for the jury’s
otherwise exclusive province which is to draw conclusions from the
facts.’ It is a kind of authorized encroachment in that respect.
Id. at 362 (emphasis added) (internal citations omitted).

9. People v Madera, 24 A.D.3d 278 (1st Dep’t 2005), 1v. den. 6 N.Y.3d 815 (2006),

held:

Generally, the admissibility and boundaries of expert testimony lie
primarily within the sound discretion of the trial court. The role of
the trial court in the first instance is to “determine when jurors are
able to draw conclusions from the evidence based on their day-to-
day experience, their common observation and their knowledge, and
when they would be benefitted by the specialized knowledge of an
expert witness”. In rendering its decision, "the courts should be
wary not to exclude such testimony merely because, to some degree,
it invades the jury's province. Indeed, the Court of Appeals has
opined, and reaffirmed, that “[e]xpert opinion testimony is used in
partial substitution for the jury's otherwise exclusive province which
is to draw conclusions from the facts”.. . It is a kind of authorized
encroachment in that respect."

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Id. at 284(internal citations omitted). See also People v Cronin, 60 N.Y.2d. 430, 433 (1983).

10. In Madera, , the First Department held that although the trial court concluded that

the average juror was capable of understanding drug-induced delusional states, “the ability of

narcotics, specifically cocaine, to produce a psychotic, delusional and paranoid state in which

defendant could truly believe his life was in danger, despite minimal, if any, evidence of such

danger, would not be within the ken of the average juror.” Id. The Court noted that “absent such

testimony, the jury was likely left to conclude that no reasonable person would presume that some

unknown person was chasing him and trying to kill him merely because he thought he heard a

‘pop’ and observed a hole in a glass door. Id.

11. More recently, in Jean-Louis v. City of New York, 86 A.D.3d 628 (2d Dep’t 2011),

the Second Department held that the trial court properly denied a defendant’s motion to preclude

plaintiff’s expert because the expert “helped clarify the issue of whether the I-beams constituted a

dangerous condition, which called for ‘professional or technical knowledge, possessed by the

expert and beyond the ken of the typical juror.’” Id., quoting De Long, supra. As the Court of

Appeals stated in De Long, “[t]he guiding principle is that expert opinion is proper when it would

help to clarify an issue calling for professional or technical knowledge, possessed by the expert

and beyond the ken of the typical juror.” De Long, supra at 307.

12. Here, Mr. Scott is expected to testify about a field of science that is beyond the ken

of typical jurors and will be helpful to the jurors’ understanding of how the subject collision

between the two buses occurred. Accordingly, Mr. Scott’s testimony is proper and should be

permitted.

13. The specific facts and opinions on which Mr. Scott is expected to testify are

disclosed in great detail in defendants’ 3101(d) as follows:

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(a) The subject accident event occurred on September 3,2013 at
approximately 8:28 am along or near address 888 Main Street in
Roosevelt Island, Queens New York. At the time of the accident the
weather was clear, and the road surface was dry. The subject
accident area consists of a “T” type intersection to the east and an
angled access driveway for address 888 to the south. The Main
Street T intersection is oriented at an approximate 90-degree angle
and the driveway is oriented at an approximately 35 degrees angle.
The subject accident intersections consist of stop-controlled traffic
signs and pavement markings, painted or marked crosswalks,
concrete sidewalks with curb drop ramps, stop bars, various physical
features such as bus stop signs, vegetation and building structures.

(b) Main Street Avenue in the area of the accident location has a curb
to curb paved width of about 24 feet with each travel lane measuring
about 12 feet which widens to about 70 feet at the east side
intersection. The travel directions are separated by a solid single
yellow line. Painted crosswalks exist at the driveway entrance and
exit areas as well as at the three legs of the Main Street T
intersection. The roadways consisted of asphalt surface and are
relatively level leading up each approach to the accident area.

(c) The posted speed limit along Main Street is 10 mph. A bus stop
designated as Q102 bus is located about 110 feet from the Main
Street T-intersection. The Roosevelt Island Operating Corp bus stop
is located 30 feet from the curb extension for the north/south Main
Street roadway and about 100 feet from the T-intersection.

(d) The stop line and stop sign on the north/south travel direction along
Main Street is located about 120 feet from its T-intersection (this is
to allow right turning large vehicles). The north/south portion of
Main Street has a paved curb to curb width of about 22 feet. Parking
is not permitted along the roadway. constraints in the area.
Numerous observations were made at the site inspection where
every RIOC bus observed made a right turn in the manner that Mr.
Franchi had on the day of the accident. In addition, the bus turning
times and speed were calculated and compared to tested acceleration
values. It was determined that the RIOC bus being operated by
Joseph Franchi made the right turn from a stopped position over a
distance of less than 50 feet. Based upon the foregoing analysis, the
Franchi RIOC bus would have been traveling at speed between 7.5
and 10 mph at the moment of impact.

(e) The east/west section of Main Street (where impact
occurred) consists of a driveway entrance and exit for address # 888.
A landscaped triangle shaped island separates the driveways/access

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areas. The stop line and stop sing for exiting vehicles onto eastbound
Main Street is located about 20 feet from the curb edge.

(f) Twenty-four photographs were taken of the subject vehicles
(the two buses) at their final rest positions were utilized along with
a physical inspection of the roadway dimension and geometry as
well as the subject bus specifications to accurately depict the final
rest locations on a scaled diagram using the AutoCAD computer
assisted drafting program. In addition, the angle of impact, location
of first contact and post-impact movements of the subject buses
were re-established utilizing the damage patterns, turning radii and
bus movement observations.

(g) The initial contact area on the Roosevelt Island Operating
Corp. (RIOC) bus was determined to be approximately 12 inches to
the left of the RIOC bus centerline. The initial contact area on the
MTA bus was determined to be at the left front corner area of the
MTA bus. At the time of impact, the RIOC bus was in the process
of moving from left to right in a turning maneuver.

(h) Based upon an analysis of the foregoing, it was determined
that the RIOC being operated by Joseph Franchi bus had traveled
less than 50 feet from its bus stop/stop line area on the exit driveway
to impact. It was also determined that the left front corner of the
RIOC bus was approximately 7 feet into the opposing westbound
lane of Main Street at initial contact. The MTA bus being operated
by Tameka McCants was positioned with its left front portion about
4 feet from the centerline and at an angle of approximately 20
degrees to the right with respect the roadway centerline. The rear or
the McCants MTA bus at impact was positioned more than 7 feet
into the opposing eastbound lane and at an angle of 20 degrees south
of the roadway centerline.

(i) Based upon the physical dimensions at the accident location,
damage patterns and contact area as well as the final rest positions
of the two buses, it was determined that the McCants MTA bus was
NOT making a proper left turn from northbound Main Street onto
westbound Main Street at the time of the accident event. It was
determined that the McCants MTA bus was not parallel in her lane
of travel at the time of the initial impact and was angled diagonally
across the roadway centerline and stop line area and in the opposing
lane of travel when the accident event occurred.

(j) The physical dimensions of the McCants MTA bus, roadway
layout, turning radius studies, engineering turning templates
(AASIITO) as well as many observations at the scene indicate that
Ms. McCants was, in fact, afforded more than ample room to make

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a proper wide turn such that the MTA bus would have been parallel
the east/west centerline on Main Street before the area of impact. If
Tameka McCants has made a proper left from northbound travel
lane at the T intersection, she would have traversed more than 100
feet in distance from beginning her left turn to reaching the area of
impact.

(k) If Tameka McCants had made a proper left turn at the T
intersection and was traveling at the speed of 10 mph, she would
have utilized as much as 7 seconds of time and would have increased
her line of sight towards the RIOC bus location at the driveway/bus
stop area. Based upon stopping distance for the subject model
McCants MTA bus and a perception and reaction time of 1.5
seconds (on average), Ms. McCants could have braked and stopped
her bus in less than 30 feet of distance. If Ms. McCants was traveling
at her highest testified speed of 2 mph, she could have stopped her
bus in less than 5 feet of distance and less than 2 seconds of time.

(l) If Tameka McCants had made a proper left turn prior to
entering the east/west section of Main Street, her bus position would
have afforded the RIOC bus sufficient time and distance to negotiate
its right turn without incident. This is because the McCants MTA
bus would have stillbeen in the process of a wide left turn well
before reaching the area of impact in the westbound travel lanes.

(m) Tameka McCants’ testimony that she was straight in her
travel lanes at the time of impact is not supported by the physical
evidence. The laws of physics dictate that the MTA bus would not
have shifted to the left as a result of the impact with the RIOC bus.
The force applied to the McCants MTA bus was at the left front
corner which would not have been sufficient enough to rotate the
rear of the bus more than 10 feet to the left and into the opposing
lane. In addition, the McCants’ MTA bus post impact movement to
the right is consistent with the MTA bus being at an angle across the
centerline.

(n) The physical evidence supports that at the time of initial
contact, the McCants bus was likely traveling very slow or at a stop.
This is evidence by the lack of movement from initial contact into
and beyond the contact area of the RIOC bus. This opinion also
indicates that Ms. McCants was nearly 65 feet into the east/west
Main Street roadway before she first observed the RIOC bus making
the left turn.

(o) The turning movement made by Ms. McCants prior to the
impact whereby the MTA bus was operated as going across the
corner (“cutting the corner”) and not around the corner would be

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consistent with Ms. Lombardi’s testimony that the MTA bus was
moving fast.

(p) The turning path of the RIOC bus from the bus stop exit
driveway onto Main Street requires the RIOC bus (or any 40-foot
bus) to travel onto and to occupy a section of the opposing
westbound lane. This fact is due to the RIOC bus size and turning
track of the bus as well at the roadway constraints in the area.
Numerous observations were made at the site inspection where
every RIOC bus observed made a right turn in the manner that Mr.
Franchi had on the day of the accident. In addition, the bus turning
times and speed were calculated and compared to tested acceleration
values. It was determined that the RIOC bus being operated by
Joseph Franchi made the right turn from a stopped position over a
distance of less than 50 feet. Based upon the foregoing analysis, the
Franchi RIOC bus would have been traveling at speed between 7.5
and 10 mph at the moment of impact.

(q) Accident or collision severity is defined as the speed change
a vehicle and its occupants experience over a time-duration. This is
commonly referred to as Delta-V. The amount of Delta-V
experience by the McCants bus and the direction of force was
quantified using several accepted methods such as Momentum
Calculations, Force Balance Approach, Damage Energy,
Work/Sliding Energy and Kinetic Energy formulae. By applying the
above principles to this accident event, it was determined that the
McCants MTA bus would have experienced a Delta-V of less than
6 mph in the subject accident event. The direction of force applied
the left front corner of the McCants MTA bus would have been at
an angle of approximately -30 degrees (with a + or - of 5 degrees to
the left or right) on the left front corner. The average g-force applied
to the McCants MTA bus would have been approximately 3.3g.
See DePaola Affirmation, Exhibit A.

14. Plaintiff’s reliance on People v. Young, 7 N.Y.3d 40 (2006) is misplaced. Aside

from being almost unintelligible, the decision affirms the Fourth Department’s preclusion of

defendant’s expert psychologist in a criminal case based on the fact that corroborating evidence

rendered his testimony of minor importance. Id. at 45. The Court of Appeals did not decide that

the expert’s methodology was lacking or that his area of expertise was within the ken of an ordinary

juror. In fact, the Court of Appeals considered the extent to which the research findings discussed

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by the expert—psychological studies regarding the accuracy of an identification—were relevant

to the victim’s identification of defendant and not within the ken of a lay juror, and specifically

found that they were not. Id. The Fourth Department actually stated, …“could the expert tell the

jury something significant that jurors would not ordinarily be expected to know already? Here, we

think the answer is yes.” Id. Instead, the Court ultimately affirmed the preclusion because the

extent to which that identification was corroborated by other evidence rendered the expert’s

testimony of minor importance.

15. Here, again, although the Court has already found defendants negligent, the subject

of McCants’s comparative negligence remains at issue. Defendants intend to rely on Mr. Scott’s

opinions to provide proof that McCants was somewhere between 1% and 99% negligent, which

they are entitled to do, and are entitled to do through the testimony of an accident reconstruction

expert. See De Long v County of Erie, 60 N.Y.2d. at 307. The opinions or conclusions that Mr.

Scott reaches in (a) through (p) of his disclosure do not in any way invade the province of the jury

because he performed tasks that the jury could not possibly do. Mr. Scott:

• Visited and inspected the accident scene;
• Took measurements of the bus dimensions, roadway distances
and widths, markers, including the distance of the nearby bus
stop to the T-intersection and the curbs and the distance of the
stop sign at the T-intersection and the curbs;
• Calculated the turning times and speeds of RIOC buses at the
intersection similar to the turn that defendant driver Franchi
made;
• Took photographs of the scene;
• Calculated the buses’ final testing locations using the program
AutoCAD to provide exact measurements of the angle of initial
impact, location of initial impact, and post-contact movements;
• Calculated the exact distance traveled by both buses and their
locations at impact;

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• Applied knowledge of Physics, including extent of forces
applied perception and reaction time, along with measurements
of physical dimensions of the accident scene and buses, roadway
layout and the buses’ turning radii, as well as review of the
damage to the buses and the buses’ contact areas, to reach
conclusions regarding how the accident occurred.

16. Simply stated, a jury does not have the ability to visit an accident scene and take

measurements, calculate turning times and speeds, calculate distances traveled, or apply

knowledge of Physics, forces and perception and reaction time. All of these tasks are within the

specialized knowledge of an accident reconstruction expert, who can provide a unique opinion

regarding how this collision occurred. Id.

17. Mr. Scott’s conclusion that McCants made an improper turn is not based on

speculation or wishful thinking; it is based on all of the above tasks that he performed, which as

an accident reconstructionist he has specialized knowledge and training to do. Mr. Scott’s work—

measurements, calculations, and applications of principles of Physics—led to his conclusion that

McCants’ MTA bus was not making a proper left turn from northbound Main Street onto

westbound Main Street at the time of the accident event because her MTA bus was not parallel in

her lane of travel at the time of the initial impact and was angled diagonally across the roadway

centerline and stop line area and in the opposing lane of travel when the accident event occurred.

Further, if Tameka McCants had made a proper left turn at the T intersection and was traveling at

the speed of 10 mph, she would have utilized as much as 7 seconds of time and would have

increased her line of sight towards the RIOC bus location at the driveway/bus stop area. Based

upon stopping distance for the subject model McCants’ MTA bus and a perception and reaction

time of 1.5 seconds (on average), McCants could have braked and stopped her bus in less than 30

feet of distance. If McCants was traveling at her highest testified speed of 2 mph, she could have

stopped the bus in less than 5 feet of distance and less than 2 seconds of time.

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18. Contrary to plaintiff’s assertions, Mr. Scott’s opinions absolutely provide a greater

understanding of how this collision occurred than the jury’s own experience and common sense

observations. Respectfully submitted, the above opinions do not usurp the province of the jury as

they are based on independent work performed by Mr. Scott that a jury could not do, which led to

a scientific conclusion that the jury may credit or discredit. See De Long v County of Erie, 60

N.Y.2d. at 307; Goverski, 282 A.D.2d at 790; Lee, 96 N.Y.2d 157; Madera, 24 A.D.3d at 284;

Cronin, 60 N.Y.2d. at 433; Jean-Louis, 86 A.D.3d 628.

2. Defendants more than reasonably disclosed and detailed the substance and
facts of Mr. Scott’s opinions, and the grounds on which Mr. Scott is expected
to testify.

19. CPLR 3101(d)(1)(i), in pertinent part, requires a party to provide specific expert

discovery upon request as follows:

(d) Trial preparation. 1. Experts. (i) Upon request, each party shall
identify each person whom the party expects to call as an expert
witness at trial and shall disclose in reasonable detail the subject
matter on which each expert is expected to testify, the substance of
the facts and opinions on which each expert is expected to testify,
the qualifications of each expert witness and a summary of the
grounds for each expert’s opinion.

20. While plaintiff’s counsel’s recitation of the text of CPLR 3101(d)(i) is correct, he

fails to point out that Mr. Scott’s anticipated testimony as summarized in 5(q) of defendants’ expert

exchange more than reasonably disclosed and detailed the substance and facts of Mr. Scott’s

opinions.

21. Defendants’ expert disclosure states as follows:

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above principles to this accident event, it was determined that the
McCants MTA bus would have experienced a Delta-V of less than
6 mph in the subject accident event. The direction of force applied
the left front corner of the McCants MTA bus would have been at
an angle of approximately -30 degrees (with a + or - of 5 degrees to
the left or right) on the left front corner. The average g-force applied
to the McCants MTA bus would have been approximately 3.3g.

See DePaola Affirmation, Exhibit A.

22. It is well settled that New York Courts will not preclude an expert from testifying

as long as the expert witness statement, the CPLR 3101(d)(i) expert disclosure, is not so inadequate

as to have been misleading, or to have resulted in prejudice or surprise. Gagliardotto v. Huntington
Hospital, 25 A.D.3d 758 (2d Dep’t 2006); see also Hageman v Jacobson, 202 A.D.2d 160 (1st

Dep’t 1994).

23. Here, Mr. Scott’s opinion is neither inadequate nor misleading, and could not

possibly result in prejudice or surprise. Just the opposite, it is extremely detailed. First, Mr. Scott

defines Delta-V as accident or collision severity—the speed change a vehicle and its occupants

experience over a time-duration, which states is commonly referred to as Delta-V. Second, Mr.

Scott explains what methods he used to quantify the amount of Delta-V experienced by the

McCants bus and the direction of force—he used several accepted methods such as Momentum

Calculations, Force Balance Approach, Damage Energy, Work/Sliding Energy and Kinetic Energy

formulae. Third, Mr. Scott explains that by applying the above principles to this accident event, it
was determined that the McCants MTA bus would have experienced a Delta-V of less than 6 mph

in the subject accident event. Fourth, Mr. Scott explains further that the direction of force applied

to the left front corner of the McCants MTA bus would have been at an angle of approximately -

30 degrees (with a + or - of 5 degrees to the left or right) on the left front corner. Finally, Mr. Scott

states that the average g-force applied to the McCants MTA bus would have been approximately

3.3g.

24. In sum, Mr. Scott concludes that collision of the buses was less than 6 mph, or low

impact or severity. And the information provided far exceeds the requirement to “disclose in

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reasonable detail the subject matter on which each expert is expected to testify” and “the substance

of the facts and opinions on which each expert is expected to testify.” See 3101(d)(i).

25. For the same reasons, defendants more than reasonably disclosed a summary of the

grounds for Mr. Scott’s opinions.

26. Defendants disclosed a summary of the basis of the facts and opinions upon which

Mr. Scott is expected to testify, in list form, as follows:

(a) His review of pleadings, bills of particulars, supplemental bills of
particulars and other discovery responses in this matter;
(b) His review of all deposition testimony which included Tameka McCants,
Joseph Franchi and Marie Lombard;
(c) His review of the New York State Police Accident Report, Accident No.
2988 (2 pages);
(d) His review of MTA MB Brief # 2024, Accident Scene Drawing,
Supervisor’s Accident/Crime Scene Reports, dated September 30, 2013;
(e) Images taken of the subject buses at the accident scene which included six
close-up color images of the involved buses and twenty-four color images
of the vehicles at their final rest locations;
(f) Images taken of the Roosevelt Island Operating Corporation bus which
included forty-two color images, post-accident;
(g) The use of Google Earth and Google Maps/Street view data of the accident
location;
(h) His personal physical inspections of the accident location which included
observations of traffic flow, bus turning movements,

Case Info

Judge

Suzanne J Adams Track Judge’s New Case

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Document Filed Date

June 19, 2020

Case Filing Date

May 29, 2014

County

Parties

BERGER, ERIC J. Attorney for the Defendants
FIDEN, JOAN LYNNE Attorney for the Plaintiff
Greenberg, Alan M. Attorney for the Plaintiff
GUMPERT, SCOTT LEE Attorney for the Defendants
JACOBSON, AUSTIN H Attorney for the Plaintiff
Joseph Franchi JR. Defendant
Marie Lombard Plaintiff in Related Action #2 Non Party
NORRIS, CHARLES BRIAN Attorney for the Plaintiff
Roosevelt Island Operating Corporation Defendant
Tameka Mccants Plaintiff
WEINTRAUB, ALISON M Attorney for the Defendants
ZAFONTE, DOMINIC PAUL Attorney for the Defendants
GARY MANDEL Attorneys for Plaintiffs
JENNIFER SHAFER Attorneys for Plaintiffs
KARA CAMPBELL Attorneys for Plaintiffs
JOSEPH DEPAOLA Attorneys for Plaintiffs
ROBERT MENNA Attorney
BRIAN GREENFIELD Attorneys for Defendants
LOUIS ANNUNZIATA Attorneys for Defendants

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Motion-Secondary: Tameka Mccants v. Joseph Franchi Jr., Roosevelt Island Operating Corporation

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