Preview
FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 68 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 RNC INDUSTRIES, LLC
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 RNC INDUSTRIES, LLC 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 compañy and the maximum amount
of all liability coverage of each insurance company, indicating the amount per person, the
amount for allpersons and the amount for each accident.
3. If there is excess or umbrella iñsuiance liability coverage available, state the name
and address of each insurance carrier for such coverage and the amounts of coverage available
# 3766749 v. 2
1 of 4
FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 01/02/2019
from each, the amount per person, the amount of all persons and the amount for each
indicating
accident.
4. Attach copies of all insurance agreements - excess - referred
(primary umbrella)
to herein.
5. Insurance policy effective on the date ofthe alleged accident:
(a) Full and complete certified copies of all primary insurance agreements and
policies of liability insurance, including terms, definitions, additional insured endorsemeñts,
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 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.
PLEASE TAKE FURTHER NOTICE, that the foregoing discovery demands and
notices are continuing demands and notices and that ifany 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. 68 RECEIVED NYSCEF: 01/02/2019
Dated: January 2, 2019
New York, New York Yours, etc.,
Sco 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 I1787
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. 68 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,
THE BOARDOF MANAGERSOFKALAHARI
CONDOMINIUM, WALLACK MANAGEMENT
CO., INC., RNC INDUSTRIES, LLC and WEST NEW
YORK RESTORATION OF CT, INC.,
Defendants.
DEMAND FOR INSURANCE INFORMATION AS TO DEFENDANT
RNC INDUSTRIES, LLC
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, certifies that, upon information and and reasonable inquiry, the contentions contained
belief
in the annexed document are not frivolous.
Dated January 2, 2019 Signature:
Scott H. Bernstein
4 of 4