`FILED: KINGS COUNTY CLERK 07m2017 09:40 AM
`
`NYSCEF DOC. NO.
`lO
`NYSCEF DOC. NO. 10
`
`500609/2017
`INDEX NO. 500609/2017
`INDEX NO.
`
`
`
`
`
`RnCfiIVfiD VYSCEF:
`07/29/2017
`RECEIVED NYSCEF: 07/29/2017
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF KINGS
`______________________________________ X
`
`MYRTLE CREVELLE and CLYDENE MEDAS,
`
`Plaintiffs,
`
`- against —
`
`DEFENDANT'S RESPONSE
`TO PRELIMINARY
`
`APPLE—METRO INC. d/b/a APPLEBEE’S,
`
`CONFERENCE ORDER
`
`-------------------------------------- X
`
`Index No. 500609/2017
`IAS Part
`
`Defendant.
`
`Defendant Apple—Metro, Inc. d/b/a Applebee's, by Pillinger
`
`Miller Tarallo, LLP,
`
`in compliance with the preliminary conference
`
`order dated June 14, 2017, hereby sets forth the following:
`
`1.
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`Witnesses: The
`
`responding defendant
`
`is unaware of
`
`any
`
`witnesses to the occurrence, other than the names set forth
`
`in the accident report.
`
`Party Statements: Please see annexed hereto as Exhibit "A".
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`Insurance Coverage: At
`
`the time of
`
`the occurrence,
`
`the
`
`defendant was covered under Policy #ICC—CL—OOlOZ7l—5, with
`
`a per occurrence limit of $1,000,000. A copy of
`
`the
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`aforementioned policy of insurance will be provided under
`
`separate cover.
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`PhotographsI Audiotapes. Slided, Videotapes
`
`and Motion
`
`Pictures: At this time the defendant is not in possession
`
`of any such documents called for in this demand.
`
`1 of 2
`1 of 2
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`
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`FILED: KINGS COUNTY CLERK 07/29/2017 09:40 AM
`FILED: KINGS COUNTY CLERK 07m2017 09:40 AM
`
`NYSCEF DOC. NO. 10
`NYSCEF DOC. NO. 10
`
`500609/2017
`INDEX NO. 500609/2017
`INDEX NO~
`
`
`
`
`
`RaCaIVaD VYSCEF:
`07/29/2017
`RECEIVED NYSCEF: 07/29/2017
`
`
`
`5.
`
`Accident Reports: Attached hereto as Exhibit “A” is a copy
`
`of the accident report.
`
`6.
`
`Expert Witness: At the present time,
`
`the defendant has not
`
`retained an expert to testify at the trial of this matter.
`
`However, defendant reserves the right
`
`to supplement this
`
`response if and when an expert is retained.
`
`This defendant reserves the right to amend and/or supplement
`
`this response should additional information become available.
`
`Dated: Westchester, New York
`July 25, 2017
`
`Ybu
`
`PILL NG
`
`MILLE
`
`i;ZAW
`
`LLO LLP
`
`T
`
`ttorneys for Defendant
`Apple—Metro, Inc. d/b/a Applebee's
`555 Taxter Road, 5th Floor
`Elmsford, NY 10523
`(914) 703-6300
`Our File NO. NOVA-00207/JTM
`
`TO:
`
`LOUIS C. FIABANE, ESQ.
`Attorney for Plaintiffs
`Myrtle Crevelle and Clydene Medas
`304 East 49th Street
`New York, NY 10017
`(212) 888-8922
`
`JTM/jos
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`2 of 2
`2 of 2
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