Preview
FILED: KINGS COUNTY CLERK 11/16/2018 12:12 PM INDEX NO. 519845/2018
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/16/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
___
-______________.........___..__________ ..·-----------------X
JOSE V. FERNANDEZ,
INDEX NO.: 519845/2018
Plaintiff(s),
VERIFIED ANSWER,
- against - BILL OF PARTICULARS &
.C..OMBINED DEMANDS
JORGE LUIS RIVERA,
Our File No.: 1030761
Defendant(s). Case ID No.: 97300
____-_________.._________.___.________________.._______,------------X
The Defendant(s) JORGE LUIS RIVERA by their/his/her attorneys, BAKER, MCEVOY,
MORRISSEY & MOSKOVITS, P.C. answering the Complaint of the Plaintiff herein, respectfully
shows and alleges upon information and belief, as follows:
ANSWER
FIRST CAUSE OF ACTION
Deny(ies) each and every allegation in the paragraphs of the Complaint designated as
follows: 14, 15, 17, 18, 19, 20, 21.
Deny(ies) any knowledge or information thereof, sufficient to form a belief as to the truth
of the allegations contained in the paragraphs of the Complaint designated as follows: 1, 2,6, 7, 9,
12, 16.
SECOND CAUSE OF ACTIOli
Defendant(s) repeats, reiterates, and realleges their responses to each and every allegation
contained in the preceding paragraphs of this Answer with the same force and effect as iffully set
forth herein.
Deny(ies) each and every allegation in the paragraphs of the Complaint designated as
follows: 23, 24.
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AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
By reason of the provisions of Article 51 of the New York Comprehensive Motor Vehicle
Insurance Reparations Act, Sections 5101 to 5108, this Court lacks jurisdiction over the subject
matter of this action and Plaintiff(s) is/are expressly prohibited from maintaining this action.
SECOND AFFIRMATIVE DEFENSE
Pursuant to the C.P.L.R. Sections 1411 and 1412, any damages sustained by the Plaintiff(s)
was/were caused by the culpable conduct of Plaintiff(s), including contributory negligence or
assumption of the risk, and not by the culpable conduct or negligence of the answering
Defendant(s).
THIRD AFFIRMATIVE DEFENSE
Pursuant to C.P.L.R. 4545, Plaintiffs recovery should be reduced by any amounts received
or that will be received by Plaintiff(s) from collateral sources of payment.
FOURTH AFFIRMATIVE DEFENSE
If Plaintiff(s) suffered injury and damage in the manner and at the time and place alleged
in the Complaint, which Defendant(s) deny, and if it is determined that said injury and damage
were caused by and contributed to the Plaintiffs failure to use or properly use seat belts, shoulder
harness(es) or other restraining devices, pursuant to the authority of Spier V Barker, 35 N.Y.2d
444, 363 N.Y.S.2d 916, Defendant(s) pleads Plaintiff's failure to mitigate damages.
FIFTH AFFIRMATIVE DEFENSE
If it isdetermined that Plaintiff(s) or any party to this lawsuit has proceeded to arbitration
with respect to any issue related to this action that results in an adverse ruling to said Plaintiff(s)
or party, then the answering Defendant(s) pleads said adverse ruling or award on the theory of
collateral estoppel under the authority of Matter of American Insurance Co. (Messenger-Aetna
Cas. & Sur. Co.), 43 N.Y.2d 184, 401 N.Y.S.2d 36; Altman v. Queens Tr. Corp., 94 Misc.2d 549,
405 N.Y.S.2d 212; Dermatossian v. New York City Transit Authority, 67 N.Y.2d 219, 501
N.Y.S.2d 784; c.f. Baldwin v. Brooks, 83 A.D.2d 85, 443 N.Y.S.2d 906; Clemmens v. Apple, 65
N.Y.2d 746 and Schultz v. Boyscouts of America, 65 N.Y.2d 189.
SIXTH AFFIRMATIVE DEFENSE
The defendant-operator acted under emergency conditions not created by him, which
qualify under the "emergency doctrine". Such doctrine holds that those faced with a sudden and
unexpected circumstance, not of their own making, which leaves them with little or no time for
reflection or reasonably causes them to be so disturbed that they are compelled to make a quick
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decision without weighing alternative courses of conduct, may not be negligent if their actions are
reascriable and prudent in the context of the emergency, even ifit later appears that the actor made
a wrong decision, provided the actor has not created the emergency. Bello V Transit Auth., 12
(2nd
A.D. 3d 58, 60 Dept. 2004); Caristo v. Sanzone, 96 N.Y. 2d 172, 174 (2001); Rivera v. New
York City Tr. Auth., 77 N.Y.2d 322, 327 (1991); Kuci v. Manhattan & Bronx Surface Tr. Operating
(2nd
Auth., 88 N.Y. 2d 923 (1996); Pawlukiewicz v. Boisson, 275 A.D.2d 446 Dept. 2000); Carmela
(2nd
Roviello v Schoolman Transportation System Inc., 10 A.D. 3d 356 Dept. 2004).
RESERVATION OF RIGHTS
Defendant(s) reserve(s) the right to amend the answer, defenses, and/or any counterclaims
and cross claims at a later date.
WHEREFORE, Defendant(s) demand(s) judgment dismissing the Complaint in itsentirety
or diminishing the damages recoverable by Plaintiff(s) in proportion to the culpable conduct
attributable to Plaintiff(s), together with the costs, disbursements, and attorney's fees of thisaction.
Dated: November 16, 2018
Brooklyn, N.Y. Bak , Evoy, Morrissey & s ovits, PC
A rian J. Leven, sq.
Attorney(s) for the Defen ant
JORGE LUIS RI ERA
I'
One Metrotech C ter, Fl
Brooklyn, NY112
Tel: (212) 857-8230
JOSHUA BRIAN IRWIN, P.C.
Attorney(s) for the Plaintiff(s)
JOSE V. FERNANDEZ
2171 86TH STREET SUITE 2
BROOKLYN, NY 11214
Tel: (718) 449-7491
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-----------------------------------------··----------------------X
JOSE V. FERNANDEZ, INDEX NO.: 519845/2018
Plaintiff(s), ATTORNEY VERIFICATION
- against - Our File No.: 1030761
Case ID No.: 97300
JORGE LUIS RIVERA,
Defendant(s).
--------- --------
-----------¬----------------------------X
I, ADRIANNE J. LEVEN, an attorney admitted to the practice of law before the courts of
the State of New York, and not a party to the above-referenced action, affirm the following to be
true under the penalties of perjury:
1. Affirmant is a member of the law firm of Baker, McEvoy, Morrissey & Moskovits,
P.C., attorneys of record for answering Defendant(s) in the above-referenced action.
2. Affirmant has read the VERIFIED ANSWER, BILL OF PARTICULARS, &
COMBINED DEMANDS and knows the contents thereof; that same is true to Affirmant's own
knowledge, except as to the matters therein stated to be alleged on information and belief, and as
to those matters Affirmant believes them to be true.
3. This verification is made by Affirmant and not by answering Defendant(s), because
said Defendant(s) were not within the County in which Baker, McEvoy, Morrissey & Moskovits,
P.C. maintain their offices for the practice of law when this VERIFIED ANSWER, BILL OF
PARTICULARS, & COMBINED DEMANDS was drafted.
4. The grounds of Affirmant's belief as to all matters not stated upon Affirmant's
knowledge is as follows: BOOKS AND RECORDS MAINTAINED BY THE FIRM OF BAKER,
MCEVOY, MORRISSEY & MOSKOVITS, P.C. AND INFORMATION SUPPL BY
AMERICAN TRANSIT INSURANCE COMPANY.
Dated: November 16, 2018
Brooklyn, NY
Ad J. Leven, Esq.
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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.-------¬--------------X
JOSE V. FERNANDEZ, INDEX NO.: 519845/2018
DEMAND FOR BILL OF
Plaintiff(s), PARTICULARS &
COMBINED DEMANDS
- against - Our File No.: 1030761
Case ID No.: 97300
JORGE LUIS RIVERA,
Defendant(s).
--------------------------- ---- -¬-----------------------X
PLEASE TAKE NOTICE that pursuant to Article 30 of the CPLR, you are hereby required
to file and serve upon the undersigned the following Verified Bill of Particulars of Plaintiffs
alleged cause of action herein within thirty (30) days from the date of service hereof.
1. The name and address of the Plaintiff(s).
2. The age and date of birth of the Plaintiff(s).
3. The social security numbers of Plaintiff(s).
4. The date and time of the occurrence.
5. State the location of the accident/occurrence in sufficient detail to permit identification of
the accident, providing in detail the direction in which each car was proceeding at the time
of the accident.
6. Separate statenients setting forth all of the acts or omissions constituting the negligence of
each Defendant(s).
7. State what part(s) of each vehicle came in contact with each other, including contacts with
each pedestrian, fixed object(s) or parked vehicle(s).
8. State the statutes, rules, laws and/or ordinances that alleged Defendant(s) has/have
violated. If property damage is being claimed, please set forth the applicable laws and
circumstances in full detail.
Plaintiff(s)'
9. State the make, model and the year of manufacture of vehicle, the reasonable
market value of same immediately prior to and immediately after the alleged accident.
10. If personal injuries are being claimed, please set forth in full detail. Include the nature,
extent, location and duration of each and every injury alleged to have been sustained by
the Plaintiff(s) and if any are claimed to be permanent.
11. If Plaintiff(s) admitted to any hospital or emergency room resulting from the
accident/occurrence, state names and addresses of the facilities, treating physicians & date
of admission and discharge each facility.
12. Ifapplicable, the length of time, giving specific dates, that Plaintiff(s) was/were confined
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to bed and to home as a result of the alleged injuries.
13. The length of time during which Plaintiff was incapacitated from employment and/or
household duties as a result of the alleged injuries, giving specific dates. Set forth the
amount of earnings or wages claimed to have been lost and the rate of wages or basis of
remuneration received by the Plaintiff(s).
14. If applicable, provide the amounts claimed for special damages for:
Physicians'
a. services,
b. Medical supplies,
Nurses'
c. services,
d. Hospital expenses,
e. X-ray expenses,
f. Chiropractors,
g. Physiotherapists
h. Drugs and medications,
i. Loss of earnings, and
j. Any other items of special damages claimed.
15. The names and last known addresses of any witness to the occurrence herein, pursuant to
Zayas V Morales, 45 A.D.2d 610, 360 N.Y.S.2d 279.
16. The name and last known address of any person who has information concerning the
condition of the vehicle owned by the Plaintiff(s) and involved in the subject occurrence
herein, as it was on the date of accident or at the time itwas last in the custody and control
of the Plaintiff(s).
Plaintiff(s)'
17. State Plaintiffs occupation; narne & address of employer at the time of the
accident. If Plaintiff(s) is/are self-employed, please state nature of business, business name
and address, and Federal I.D. number.
18. If Plaintiff(s) was a student at the time of the alleged occurrence, set forth the name and
address of the school attended at time of accident and designated class or grade, and the
length of time Plaintiff was unable to attend classes.
19. Set forth any and all collateral sources under C.P.L.R. 4545(c), specifying date paid,
amount of collateral source payment, by whom paid, specifying name, address, fileor claim
number and all particulars identifying the payer.
20. State in what respect Plaintiff(s) has/have sustained a serious injury, as defined in
subdivision (d) of Section 5102 of the Insurance Law or economic loss greater than basic
economic loss, as defimed in subdivision (a) of Section 5102 of the Insurance Law.
21. If Plaintiff(s) claims aggravation or precipitation of pre-existing injury or condition, state
the nature and extent of such. Provide the name and address of each hospital, clinic,
institution, physician, and other health care provider that treated or examined Plaintiff(s)
for such pre-existing injury.
22. If loss of service is claimed, state or describe the nature of such service, the length of time
each Plaintiff was deprived of such service, and the value of such service. If wrongful
death and/or conscious pain and suffering is claimed, as defined by law, please set forth in
reasonable detail.
23. If applicable, set forth the place and date of the marriage of the decedent, if married, and
to whom at the time of death. If the Plaintiff was not married to decedent, set forth the
relationship at the time of death.
24. If applicable, set forth with specificity, the name(s) and address(es) of the decedent's next
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of kin, heirs at law and distributes.
25. If applicable, state the manner in which the damages sustained decedent's next
allegedly by
of kin and heirs at law and distributes were computed.
Dated: November 16, 2018
Brooklyn, N.Y. Baker, McEvoy, Morrissey & Moskovits, PC
s/Adrianne J. Leven
Adrianne J. Leven, Esq.
Attorney(s) for the Defendant
JORGE LUIS RIVERA
8h
One Metrotech Center, F1
Brooklyn, NY11201
Tel: (212) 857-8230
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_____.__________...... -- -----------------X
JOSE V. FERNANDEZ, INDEX NO.: 519845/2018
Plaintiff(s), NOTICE FOR DISCOVERY
& INSPECTION
- against -
Our File No.: 1030761
JORGE LUIS RIVERA, Case ID No.: 97300
Defendant(s).
--------------------------
----------X
PLEASE TAKE NOTICE, that pursuant to Rule 3120 ofthe Civil Practice Law and Rules,
Defendant(s) demands that Plaintiff(s) produce and permit discovery by him, his attorneys, or
another acting on his behalf of the following articles, documents, and things for inspection,
copying, testing, and photographing within thirty (30) days after receipt hereof, at BAKER,
8th
MCEVOY, MORRISSEY & MOSKOVITS, PC, ONE METROTECH CENTER, FLOOR,
BROOKLYN, NY 11201, at which time said articles, documents and things will be physically
inspected, copied tested, photographed, and mechanically reproduced.
In lieu of strict compliance with the terms and conditions of this Notice, the undersigned
will accept clearly legible photocopies of the said items, if received by the undersigned at least
Plaintiff(s)'
five (5) days prior to the return date hereof, together with a letter from the attorneys
advising as to the completeness of the items provided.
1. If applicable, provide a copy of Letters Testamentary or Limited Letters of Administration.
2. Itemized statements of the alleged damages to Plaintiffs vehicle, together with the cost of
repairs of each item, the garage or shop that performed the repairs, along with the shop
license numbers.
3. If claim is made for loss of earnings, please provide W-2 forms or certified copies of tax
returns for one year prior to occurrence and the for the year at time of occurrence.
4. True copy of any statement of Defendant(s) and Plaintiff(s) herein, pursuant to CPLR
3101(e).
5. Photographs of any vehicle involved in the accident, the accident scene or of any of the
parties herein following the accident.
6. Records of inspection, maintenance, and report of the vehicle owned by the Plaintiff(s)
which was involved in this occurrence for a period of one year prior to the accident date
herein.
7. True copy of any accident report concerning this occurrence in the custody and control of
Plaintiff(s) made in the ordinary course of business, pursuant to C.P.L.R. 3101(g).
8. True copy of any MV 104 and police report filed by the operators of any motor vehicles
involved in this accident.
9. Authorization to obtain no fault file,and/or worker's compensation file. All authorizations
must be HIPAA compliant pursuant to section 164.508 of the Federal Mandated Final
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Privacy Rule.
10. Authorization to obtain employment record(s) and workers compensation record(s). All
Authorizations must be HIPAA compliant pursuant to section 164.508 of the Federal
Mandated Final Privacy Rule.
11. Notice of Arbitration and Award in any Arbitration Proceeding arising from the accident,
which is the subject of this action.
physician(s)'
12. Authorization to obtain all treating reports, bills, hospital records, surgical
reports, pathology reports, toxicology reports, autopsy reports and bills of any medical
condition(s) claimed to have been activated, precipitated or aggravated by the accident
which is the subject of this action. Authorizations must be HIPAA compliant pursuant to
Section 164.508 of the Federal Mandated Final Privacy Rule.
13. Copy of primary and/or excess insurance policy limits of Co-Defendant(s).
14. Produce authorization(s) to obtain any and all prior medical treatment records, reports and
diagnostic films, pertaining to any medical treatment for a prior injury to the same body
parts or systems, which Plaintiff(s) will allege were injured in the accident in issue.
15. Produce authorization(s) to obtain Summons and Complaint, Bill of Particulars (or like
pleading) and any and all Medical Record(s) and Report(s) exchanged in all prior personal
injury lawsuits brought by Plaintiff(s).
PLEASE TAKE FURTHER NOTICE that upon failure to comply with this demand, a
Motion to Compel or Strike Plaintiffs pleading will be made pursuant to CPLR 3120 and 3124.
PLEASE TAKE FURTHER NOTICE that the request for items specified in this document
is a continuing demand and should any of the information requested become available or known
in the future, you are required to furnish same at such time.
Dated: November 16, 2018
Brooklyn, N.Y. Baker, McEvoy, Morrissey & Moskovits, PC
s/Adrianne J. Leven
Adrianne J. Leven, Esq.
Attorney(s) for the Defendant
JORGE LUIS RIVERA
8h
One Metrotech Center, p
Brooklyn, NY11201
Tel: (212) 857-8230
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------- ------------------- X
JOSE V. FERNANDEZ, INDEX NO.: 519845/2018
Plaintiff(s), NOTICE PURSUANT
T_O CPLR 2103(e)
- against -
Our File No.: 1030761
JORGE LUIS RIVERA, Case ID No.: 97300
Defendant(s).
________________________________.............__.__..............____..........
...-X
PLEASE TAKE NOTICE that pursuant to CPLR 2103(e), demand hereby is made upon
you to supply the undersigned, in writing, with a list of those parties who have appeared in the
action and the names and addresses of their attorneys.
Dated: November 16, 2018
Brooklyn, NY Baker, McEvoy, Morrissey & Moskovits, PC
s/Adrianne J. Leven
Adrianne J. Leven, Esq.
Attorney(s) for the Defendant
JORGE LUIS RIVERA
8h
One Metrotech Center,
Brooklyn, NY11201
Tel: (212) 857-8230
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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-------------------------¬-----------X
JOSE V. FERNANDEZ, INDEX NO.: 519845/2018
Plaintiff(s), DEMAND FOR MEDICAL
INFORMATION & FOR
- against - PHYSICAL E_XAMINATION
JORGE LUIS RIVERA, Our File No.: 1030761
Case ID No.: 97300
Defendant(s).
---------------------------------------------------- -----------X
PLEASE TAKE NOTICE that pursuant to the Rules of Court, you are required to serve
upon and deliver to the undersigned and all other parties to the action, the following:
l. Copies of the medical reports of those physicians who have previously treated or examined
the party seeking recovery and who will testify on his behalf. These shall include a detailed
recital of the injuries and conditions as to which testimony will be offered at the trial,
technicians'
referring to and identifying those x-rays and reports which will be offered at
the trial.
2. Duly executed and acknowledged written authorization permitting all parties to obtain and
make copies of all hospital records and such other records, including x-rays, MRI films,
surgical reports, toxicology reports, pathology reports, reports of all treating physicians
technicians'
and reports, as may be referred to and identified in the statement of the
examined party's physician. All authorizations must be HIPAA compliant pursuant to Sec.
164.508 of the federally mandated and Final Privacy Rule.
The above shall be the basis for the holding of a physical examination(s), which is hereby
being demanded and will be held after all pertinent medicals are obtained by this office.
Dated: November 16, 2018
Brooklyn, NY Baker, McEvoy, Morrissey & Moskovits, PC
s/Adrianne J. Leven
Adrianne J. Leven, Esq.
Attorney(s) for the Defendant
JORGE LUIS RIVERA
8''
One Metrotech Center, Fl
Brooklyn, NYl 1201
Tel: (212) 857-8230
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------- -----------------------------------X INDEX NO.: 519845/2018
JOSE V. FERNANDEZ, COMBINED DEMANDS FOR:
1. NAMES & ADDRESSES OF
Plaintiff(s), ALL WITNESSES
2. EXPERT DISCLOSURE
3. PRODUCTION OF ALL
- against - STATEMENTS TAKEN OF
ANSWERING DEFENDANT(S)
JORGE LUIS RIVERA,
Our File No.: 1030761
Defendant(s). Case ID No.: 97300
- ---------------------------------------------- ---X
PLEASE TAKE NOTICE that Defendant(s) demand(s) that you set forth in writing, under
oath, and serve upon us within Thirty (30) days of this date, the names and addresses of each
person known or claimed by you to be witness to the occurrence and as to notice of the condition,
ifany, alleged in the complaint in this action.
PLEASE TAKE FURTHER NOTICE, that pursuant to C.P.L.R. 3101 (d) (1), you are
hereby required to set forth the following:
1. The name and address of each and every person you expect to call as an expert witness at
the trial of this action;
2. In reasonable detail, the subject matter on which each expert is expected to testify;
3. The substance of the facts and opinions on which each expert is expected to testify;
4. The qualifications of each expert, and;
5. A summary of the grounds for each expert's opinion.
PLEASE TAKE FURTHER NOTICE that the answering Deféñdant(s) demand(s) that
each and every party to this action produce legible copies of any and all statements, written or
electronically recorded, taken of the answering Defendant(s) by any other party to this action
within Thirty (30) days of this date. The above are on-going demands.
Dated: November 16, 2018 Baker, McEvoy, Morrissey & Moskovits, PC
s/Adrianne J. Leven
Adrianne J. Leven, Esq.
Attorney(s) for the Defendant
JORGE LUIS RIVERA
8h
One Metrotech Center, p
Brooklyn, NY11201
Tel: (212) 857-8230
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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JOSE V. FERNANDEZ, INDEX NO.: 519845/2018
Plaintiff(s), NOTICE OF DECLINING
SERVICE BY
- against - FASCIMILE TRANSMITTAL
JORGE LUIS RIVERA, Our File No.: 1030761
Case ID No.: 97300