Preview
FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/02/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
____________ ____ --------------x
YVETTE MCCLAMB, Index No. 154374/2018
(ECF)
Plaintiff,
v.
HOUSING PARTNERSHIP DEVELOPMENT
CORPORATION, KALAHARI CONDOMINIUM,
THE BOARD OF MANAGERS OF KALAHARI Assigned Judge: Lynn R. Kotler
CONDOMINIUM, WALLACK MANAGEMENT
CO., INC., RNC INDUSTRIES, LLC and WEST
NEW YORK RESTORATION OF CT, INC.,
Defendants.
----------------------------------------------------------------x
DEMAND FOR INSURANCE INFORMATION AS TO
DEFENDANT HOUSING PARTNERSHIP DEVELOPMENT CORPORATION
COUNSELORS:
PLEASE TAKE NOTICE that, pursuant to the CPLR, Cross-Claimant-Defendant, West
New York Restoration of CT, Inc., hereby demands the following information be served within
thirty (30) days:
1. State whether Defendant Housing Partnership Development Corporation has
insurance agreements under which any insurance company may be liable to satisfy part or all of a
judgment which may be entered in the action or to indemnify or reimburse for payments made to
satisfy a judgment.
2. State the name and address of each insurance company and the maximum amount
of all liability coverage of each insurance company, indicating the amount per person, the
amount for all persons and the amount for each accident.
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FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/02/2019
3. If there is excess or umbrella insurance liability coverage available, state the name
and address of each insurance carrier for such coverage and the amounts of coverage available
from each, indicating the amount per person, the amount of all persons and the amount for each
accident.
4. Attach copies of all insurance agrccmcñts - excess - referred
(primary umbrella)
to herein.
5. Insurance policy effective on the date of the alleged accident:
(a) Full and complete certified copies of all primary insurance agreements and
policies of liability insurance, including terms, definitions, additional insured endorsements,
exclusions and certificates of insurance to satisfy part or all of any judgment which may be
entered in this action;
(b) Full and complete certified copies of all umbrella insurance agreements and
policies of liability insurance, including terms, definitions, additional insurance endorsements,
exclusions and certificates of insurance to satisfy part or all of any judgment which may be
entered in this action; and
(c) Full and complete certified copies of all excess insurance agreemeñts and
policies of liability insurance, including terms, definitions, additional insurance endorsements,
exclusions and certificates of insurance to satisfy part or all of any judgment which may be
entered in this action.
PLEASE TAKE FURTHER NOTICE, that the foregoing discovery demands and
notices are continuing demands and notices and that if any of the above items are obtained after
the date of these demands and notices, they are to be promptly furnished to the undersigned
pursuant to these demands and notices.
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FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/02/2019
Dated: January 2, 2019
New York, New York Yours, etc.,
Scott H. Bernstein, Esq.
STRADLEY RONON STEVENS & YOUNG, LLP
ATTORNEYS FOR CROSS-CLAIMANT-DEFENDANT,
WEST NEW YORK RESTORATION OF CT, INC.
100 Park Avenue, Suite 2000
New York, New York 10017
Telephone: (212)
812-4132
Facsimile: (646) 682-7180
Sbernstein@stradley.com
TO:
RHEINGOLD GIUFFRA RUFFO & PLOTKIN LLP
ATTORNEYS FOR PLAINTIFF YVETTE MCCLAMB
Jeremy A. Hellman, Esq.
551 Fifth Avenue, 29th Floor
New York, New York 10176
PERRY, VAN ETTEN, ROZANSKI & PRIMAVERA, LLP
ATTORNEYS FOR DEFENDANT/CROSS-CLAIMANT
RNC INDUSTRIES, LLC
Kenneth J. Kutner, Esq.
60 Broad Street, Suite 3600A
New York, New York 10004
MARGARET G. KLEIN & ASSOCIATES
ATTORNEYS FOR DEFENDANTS/CROSS-CLAIMANTS
KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI
CONDOMINIUM, AND WALLACK MANAGEMENT CO., INC.
Carol Morell, Esq.
200 Madison Avenue, 2nd Floor
New York, New York 10016
DEVITT SPELLMAN BARRETT, LLP
ATTORNEYS FOR DEFENDANT/CROSS-CLAIMANT
HOUSING PARTNERSHIP DEVELOPMENT CORPORATION
Kelly E. Wright, Esq.
50 Route 11, Suite 314
Smithtown, New York 11787
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FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/02/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Index No. 154374/2018.
..
YVETTE MCCLAMB,
Plaintiff,
-against-
HOUSING PARTNERSHIP DEVELOPMENT
CORPORATION, KALAHARI CONDOMINIUM,
THEBOARDOF MANAGERSOFKALAHARI
CONDOMINIUM, WALLACK MANAGEMENT
CO., INC., RNC lNDUSTRIES, LLC and WEST NEW
YORK RESTORATION OF CT, INC.,
Defendants.
DEMAND FOR INSURANCE INFORMATION AS TO DEFENDANT
HOUSING PARTNERSHIP DEVELOPMENT CORPORATION
STRADLEY RONON STEVENS & YOUNG, LLP
Attorneys for Defendant
100 Park Avenue, Suite 2000
New York, New York 10017
(212) 812-4124 (telephone)
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New
York State, certifles that, upon information and belief and reasonable inquiry, the contentions contained
in the annexed document are not frivolous.
Dated: January1, 2019 Signature: _
Scott H. Bernstein
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Preview
FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/02/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ____________ ____ --------------x YVETTE MCCLAMB, Index No. 154374/2018 (ECF) Plaintiff, v. HOUSING PARTNERSHIP DEVELOPMENT CORPORATION, KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI Assigned Judge: Lynn R. Kotler CONDOMINIUM, WALLACK MANAGEMENT CO., INC., RNC INDUSTRIES, LLC and WEST NEW YORK RESTORATION OF CT, INC., Defendants. ----------------------------------------------------------------x DEMAND FOR INSURANCE INFORMATION AS TO DEFENDANT HOUSING PARTNERSHIP DEVELOPMENT CORPORATION COUNSELORS: PLEASE TAKE NOTICE that, pursuant to the CPLR, Cross-Claimant-Defendant, West New York Restoration of CT, Inc., hereby demands the following information be served within thirty (30) days: 1. State whether Defendant Housing Partnership Development Corporation has insurance agreements under which any insurance company may be liable to satisfy part or all of a judgment which may be entered in the action or to indemnify or reimburse for payments made to satisfy a judgment. 2. State the name and address of each insurance company and the maximum amount of all liability coverage of each insurance company, indicating the amount per person, the amount for all persons and the amount for each accident. # 3766749 v. 2 1 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/02/2019 3. If there is excess or umbrella insurance liability coverage available, state the name and address of each insurance carrier for such coverage and the amounts of coverage available from each, indicating the amount per person, the amount of all persons and the amount for each accident. 4. Attach copies of all insurance agrccmcñts - excess - referred (primary umbrella) to herein. 5. Insurance policy effective on the date of the alleged accident: (a) Full and complete certified copies of all primary insurance agreements and policies of liability insurance, including terms, definitions, additional insured endorsements, exclusions and certificates of insurance to satisfy part or all of any judgment which may be entered in this action; (b) Full and complete certified copies of all umbrella insurance agreements and policies of liability insurance, including terms, definitions, additional insurance endorsements, exclusions and certificates of insurance to satisfy part or all of any judgment which may be entered in this action; and (c) Full and complete certified copies of all excess insurance agreemeñts and policies of liability insurance, including terms, definitions, additional insurance endorsements, exclusions and certificates of insurance to satisfy part or all of any judgment which may be entered in this action. PLEASE TAKE FURTHER NOTICE, that the foregoing discovery demands and notices are continuing demands and notices and that if any of the above items are obtained after the date of these demands and notices, they are to be promptly furnished to the undersigned pursuant to these demands and notices. 2 # 3766749 v. 2 2 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/02/2019 Dated: January 2, 2019 New York, New York Yours, etc., Scott H. Bernstein, Esq. STRADLEY RONON STEVENS & YOUNG, LLP ATTORNEYS FOR CROSS-CLAIMANT-DEFENDANT, WEST NEW YORK RESTORATION OF CT, INC. 100 Park Avenue, Suite 2000 New York, New York 10017 Telephone: (212) 812-4132 Facsimile: (646) 682-7180 Sbernstein@stradley.com TO: RHEINGOLD GIUFFRA RUFFO & PLOTKIN LLP ATTORNEYS FOR PLAINTIFF YVETTE MCCLAMB Jeremy A. Hellman, Esq. 551 Fifth Avenue, 29th Floor New York, New York 10176 PERRY, VAN ETTEN, ROZANSKI & PRIMAVERA, LLP ATTORNEYS FOR DEFENDANT/CROSS-CLAIMANT RNC INDUSTRIES, LLC Kenneth J. Kutner, Esq. 60 Broad Street, Suite 3600A New York, New York 10004 MARGARET G. KLEIN & ASSOCIATES ATTORNEYS FOR DEFENDANTS/CROSS-CLAIMANTS KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, AND WALLACK MANAGEMENT CO., INC. Carol Morell, Esq. 200 Madison Avenue, 2nd Floor New York, New York 10016 DEVITT SPELLMAN BARRETT, LLP ATTORNEYS FOR DEFENDANT/CROSS-CLAIMANT HOUSING PARTNERSHIP DEVELOPMENT CORPORATION Kelly E. Wright, Esq. 50 Route 11, Suite 314 Smithtown, New York 11787 3 # 3766749 v. 2 3 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/02/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No. 154374/2018. .. YVETTE MCCLAMB, Plaintiff, -against- HOUSING PARTNERSHIP DEVELOPMENT CORPORATION, KALAHARI CONDOMINIUM, THEBOARDOF MANAGERSOFKALAHARI CONDOMINIUM, WALLACK MANAGEMENT CO., INC., RNC lNDUSTRIES, LLC and WEST NEW YORK RESTORATION OF CT, INC., Defendants. DEMAND FOR INSURANCE INFORMATION AS TO DEFENDANT HOUSING PARTNERSHIP DEVELOPMENT CORPORATION STRADLEY RONON STEVENS & YOUNG, LLP Attorneys for Defendant 100 Park Avenue, Suite 2000 New York, New York 10017 (212) 812-4124 (telephone) Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifles that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: January1, 2019 Signature: _ Scott H. Bernstein 4 of 4