Conference: Jose L. Perez v. Alan K. Kaypour, Koresh Alan Kaypour As Executor Of The Estate Of Nina Kaypour

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                                FILED:         NASSAU        COUNTY         CLERK        10/14/2019             06:25       PM                      INDEX    NO.   601520/2019
   NYSCEF     DOC.   NO.   12                                                                                 RECEIVED      NYSCEF:     10/14/2019




                       SUPREME       COURT      OF  THE    STATE     OF  NEW     YORK
                       COUNTY       OF  NASSAU
                       ---------------------                                --------------X
                       JOSE   L.  PEREZ,                                                       Index  No.:   601520/2019

                                                                   Plaintiff,
                                                                                               RESPONSE        TO   THE
                                                                                               PRELIMINARY
                                                                                               CONFERENCE            ORDER
                                - against-



                       ALAN     K.  KAYPOUR       and  NINA     KAYPOUR,


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



                                PLEASE      TAKE      NOTICE,      that  the  defendant(s),     ALAN     K.   KAYPOUR         and


                       NINA    KAYPOUR,        by  their attorneys,   the  LAW    OFFICE     OF   ANDREA       G.  SAWYERS,


                       hereby    sets  forth  the   following    upon    information     and   belief  as  a  response    to  the



                       Preliminary     Conference     Order    of  the   Honorable     Justice   Randy     Sue   Marber     dated


                       September     18, 2019:


                                1. Travelers   advises  that defendants    were   a named    insured  under   a policy  of
                       insurance   with  policy  limits  of $500,000.


                                2. Defendants    are not  aware   of any  witnesses   to the  accident,  are  not in possession
                       of any  adverse   party  statements,   or photos   of the  accident  scene   or of the vehicles
                       involved.


                                3. Defendants    will choose   the  expert/experts    to testify at the time  of trial pursuant
                       to CPLR    3101d.


                                Defendants    reserve  their  right to supplement     and/or  amend    this response   up  to and

                       including   the time  of trial.


                                         PLEASE      TAKE     FURTHER        NOTICE,      that  the  undersigned    reserves   all


                       rights to  supplement    and/or  alter  any  or all of the  foregoing   if and  when   additional   and/or



                       different  information    becomes    available.




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   FILED:         NASSAU        COUNTY         CLERK        10/14/2019             06:25       PM                      INDEX    NO.   601520/2019
   NYSCEF     DOC.   NO.   12                                                                                 RECEIVED      NYSCEF:     10/14/2019




                      Dated:    October   14,  2019

                               Melville,   New   York



                                                                            Yours,   etc.


                                                                            LAW     OFFICE     OF  ANDREA        G. SAWYERS




                                                                            PETER     A.  PERONE

                                                                            Attorney    for Defendant
                                                                            ALAN     K.  KAYPOUR        and  NINA    KAYPOUR
                                                                            Mailing    Address:

                                                                            P.O.  Box   2903

                                                                            Hartford,   CT   06104-2903

                                                                            (631)   501-3100
                                                                            Matter   No.:  2019058285KTF




                       TO:      DELL    &  DEAN,     PLLC

                                Attorney   for Plaintiff

                                JOSE   L. PEREZ
                                1225  Franklin   Avenue,    Suite  450
                                Garden   City,  NY    11530

                                (516)  880-9700




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