Preview
FILED: KINGS COUNTY CLERK 05/17/2019 11:33 AM INDEX NO. 521771/2018
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/17/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------x Index No.: 521771/2018
MOHAMAD TOUFIC EID, (ECF)
Plaintiff,
v. RESPONSE TO
PLAINTIFF’S COMBINED
CINE MAGIC EAST RIVER STUDIOS, LLC AND DEMANDS
SALLY T. KAPSALIS,
Defendants.
----------------------------------------------------------------------x
PLEASE TAKE NOTICE that Defendants, Cine Magic East River Studios, LLC and Sally
T. Kapsalis, by its attorneys, Eustace, Prezioso & Yapchanyk, responds to Plaintiff, Mohamad
Toufic Eid Combined Demands as follows:
NAMES AND ADDRESSES OF ALL WITNESSES
Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis herein are not aware of
any notice and/or eyewitnesses to this alleged occurrence other than those listed in the police
accident report.
STATEMENTS
Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis herein are not in
possession of any adverse party statements.
INSURANCE INFORMATION
Please be advised that we have been informed by the Chubb Group of Insurance Companies, a
division of Federal Insurance Company, that there is $1,000,000 primary coverage issued by
Federal Insurance Company, policy number 79936879 applicable to this litigation. Please be
further advised that we have also been informed of the following excess coverage written by
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FILED: KINGS COUNTY CLERK 05/17/2019 11:33 AM INDEX NO. 521771/2018
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/17/2019
Federal Insurance Company, policy number 79933431, with a limit of $10,000,000 applicable to
this litigation.
PHOTOGRAPHS AND VIDEOTAPES
Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis herein are not in
possession of any photographs or videotapes.
ACCIDENT/INCIDENT REPORTS
A copy of the police accident report was previously provided.
NOTICE FOR DISCOVERY AND INSPECTION DATED 3/18/19
Defendants object to this request to the extent it is overbroad, intrusive, immaterial, irrelevant
and seeks disclosure of information subject to attorney-client privilege.
NOTICE FOR DISCOVERY AND INSPECTION DATED 3/26/19
Defendants object to this request to the extent it is overbroad, intrusive, immaterial, irrelevant
and seeks disclosure of documents or records not reasonably calculated to lead to the discovery
of information bearing on the claims.
DEMAND PURSUANT TO CPLR 3101(4)(D)(1) DATED 3/26/19
Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis herein have not yet
decided whom they will call as expert witnesses to testify at the time of trial of this action, but
hereby reserve all such rights pursuant to CPLR § 3101 (d)(1).
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FILED: KINGS COUNTY CLERK 05/17/2019 11:33 AM INDEX NO. 521771/2018
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/17/2019
Defendants acrchy reserve the right to am-4 and/or supple:nent this response up to and
including the time of trial.
DATED: May 17, 2019
New York, New York
EUSTACE, PREZIOSO & YAPCHANYK
Attorneys for Defendants
Cine Magic East River Studios, LLC and
Sally T. Kapsalis
55 Water Street, 28th Floor
New York, New York 10041
(212) 612-4200
By
Robert M. l\bazzei
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FILED: KINGS COUNTY CLERK 05/17/2019 11:33 AM INDEX NO. 521771/2018
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/17/2019
Index No.: 521771/2018 (ECF)
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
MOHAMAD TOUFIC EID,
Plaintiff,
-against-
CINE MAGIC EAST RIVER STUDIOS, LLC AND
SALLY T. KAPSALIS,
Defendants.
RESPONSE TO PLAINTIFF’S COMBINED DEMANDS
_______________________________________________________________
EUSTACE, PREZIOSO & YAPCHANYK
Attorneys for Defendants
Cine Magic East River Studios, LLC and Sally T. Kapsalis
Office and Post Office Address
55 Water Street, 28th Floor
New York, New York 10041
(212) 612-4200
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Preview
FILED: KINGS COUNTY CLERK 05/17/2019 11:33 AM INDEX NO. 521771/2018 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/17/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------------x Index No.: 521771/2018 MOHAMAD TOUFIC EID, (ECF) Plaintiff, v. RESPONSE TO PLAINTIFF’S COMBINED CINE MAGIC EAST RIVER STUDIOS, LLC AND DEMANDS SALLY T. KAPSALIS, Defendants. ----------------------------------------------------------------------x PLEASE TAKE NOTICE that Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis, by its attorneys, Eustace, Prezioso & Yapchanyk, responds to Plaintiff, Mohamad Toufic Eid Combined Demands as follows: NAMES AND ADDRESSES OF ALL WITNESSES Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis herein are not aware of any notice and/or eyewitnesses to this alleged occurrence other than those listed in the police accident report. STATEMENTS Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis herein are not in possession of any adverse party statements. INSURANCE INFORMATION Please be advised that we have been informed by the Chubb Group of Insurance Companies, a division of Federal Insurance Company, that there is $1,000,000 primary coverage issued by Federal Insurance Company, policy number 79936879 applicable to this litigation. Please be further advised that we have also been informed of the following excess coverage written by 1 of 4 FILED: KINGS COUNTY CLERK 05/17/2019 11:33 AM INDEX NO. 521771/2018 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/17/2019 Federal Insurance Company, policy number 79933431, with a limit of $10,000,000 applicable to this litigation. PHOTOGRAPHS AND VIDEOTAPES Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis herein are not in possession of any photographs or videotapes. ACCIDENT/INCIDENT REPORTS A copy of the police accident report was previously provided. NOTICE FOR DISCOVERY AND INSPECTION DATED 3/18/19 Defendants object to this request to the extent it is overbroad, intrusive, immaterial, irrelevant and seeks disclosure of information subject to attorney-client privilege. NOTICE FOR DISCOVERY AND INSPECTION DATED 3/26/19 Defendants object to this request to the extent it is overbroad, intrusive, immaterial, irrelevant and seeks disclosure of documents or records not reasonably calculated to lead to the discovery of information bearing on the claims. DEMAND PURSUANT TO CPLR 3101(4)(D)(1) DATED 3/26/19 Defendants, Cine Magic East River Studios, LLC and Sally T. Kapsalis herein have not yet decided whom they will call as expert witnesses to testify at the time of trial of this action, but hereby reserve all such rights pursuant to CPLR § 3101 (d)(1). 2 of 4 FILED: KINGS COUNTY CLERK 05/17/2019 11:33 AM INDEX NO. 521771/2018 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/17/2019 Defendants acrchy reserve the right to am-4 and/or supple:nent this response up to and including the time of trial. DATED: May 17, 2019 New York, New York EUSTACE, PREZIOSO & YAPCHANYK Attorneys for Defendants Cine Magic East River Studios, LLC and Sally T. Kapsalis 55 Water Street, 28th Floor New York, New York 10041 (212) 612-4200 By Robert M. l\bazzei 3 of 4 FILED: KINGS COUNTY CLERK 05/17/2019 11:33 AM INDEX NO. 521771/2018 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/17/2019 Index No.: 521771/2018 (ECF) SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS MOHAMAD TOUFIC EID, Plaintiff, -against- CINE MAGIC EAST RIVER STUDIOS, LLC AND SALLY T. KAPSALIS, Defendants. RESPONSE TO PLAINTIFF’S COMBINED DEMANDS _______________________________________________________________ EUSTACE, PREZIOSO & YAPCHANYK Attorneys for Defendants Cine Magic East River Studios, LLC and Sally T. Kapsalis Office and Post Office Address 55 Water Street, 28th Floor New York, New York 10041 (212) 612-4200 4 of 4