`NYSCEF DOC. NO. 19
`
`INDEX NO. 517678/2018
`
`RECEIVED NYSCEF: 05/23/2019
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF KINGS
`
`-----------------------------------------------------------X
`YLEIN SANCHEZ,
`
`
`Plaintiff,
`
`
`
`-against-
`
`
`146 LINDEN BLVD LLC and BIG APPLE
`DESIGNERS INC.,
`
`
`
`Index No: 517678/2018
`
`RESPONSE TO PRELIMINARY
`CONFERENCE ORDER AND
`DEFENDANT 146 LINDEN BLVD
`LLC’S COMBINED DEMANDS
`
`Defendants.
`------------------------------------------------------------X
`
`
`
`PLEASE TAKE NOTICE that the defendant BIG APPLE DESIGNERS, INC., and their
`
`attorneys, LAW OFFICE OF KEVIN J. PHILBIN, as and for their response to the Preliminary
`
`Conference Order and Defendant 146 LINDEN BLVD LLC’s Combined Demands, upon
`
`information and belief, set forth the following:
`
`Insurance Coverage:
`
`This office has been provided with the following insurance information: Scottsdale Insurance
`Company, issued General Liability Policy No. NCS0001106 to the above named Defendant, BIG
`APPLE DESIGNERS, INC., with policy limits of $1,000,000.00 per occurrence and
`$2,000,000.00 per general aggregate for the policy period July 9, 2017 to July 9, 2018.
`
`Excess/ Umbrella Insurance Information: NONE.
`
`All parties to exchange the names and addresses of all witnesses:
`
`Other than the parties, the agents, servants, and/or employees, or any witnesses identified by
`plaintiff, or any witness identified in any accident reports or in plaintiff’s medical records,
`defendant is unaware of any additional witnesses.
`
`Party statements:
`
`Other than the pleadings, any statements contained in any accident reports, or in plaintiff’s
`medical records, defendant is not in possession of any statements by plaintiff.
`
`Photographs:
`
`Responding defendant is not in possession of any photographs.
`
`1 of 4
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`FILED: KINGS COUNTY CLERK 05/23/2019 09:55 AM
`NYSCEF DOC. NO. 19
`
`INDEX NO. 517678/2018
`
`RECEIVED NYSCEF: 05/23/2019
`
`Surveillance
`
`videos:
`
`Responding
`
`defcadañt
`
`is
`
`not
`
`in
`
`possession
`
`of
`
`any
`
`surveillance
`
`videos.
`
`Accident
`
`reports:
`
`Responding
`
`defendant
`
`is
`
`not
`
`in
`
`possession
`
`of
`
`any
`
`accidcñt
`
`reports.
`
`All
`
`parties
`
`shall
`
`supply
`
`expert
`
`witness
`
`disclosure
`
`pursuant
`
`to
`
`the
`
`CPLR:
`
`acfc=dsst
`
`has
`
`not
`
`yet
`
`retained
`
`an
`
`expert
`
`witness.
`
`When
`
`an
`
`will
`
`exchange
`
`their
`
`expert
`
`witness
`
`disclesüre
`
`with
`
`all
`
`parties
`
`pursuant
`
`Responding
`defendant
`
`3101(d).
`
`PLEASE
`
`TAKE
`
`NOTICE
`
`that
`
`defendan+'s
`
`investigation
`
`into
`
`the
`
`facts
`
`surroüñdiñg
`
`the
`
`incident
`
`complai-ed
`
`of
`
`and
`
`if
`
`said
`
`investigation
`
`reveals
`
`any
`
`the
`
`subject
`
`of
`
`the
`
`Prcl±2¬f
`
`Conference
`
`Order,
`
`dcfc-dante
`
`reserve
`
`their
`
`right
`
`and/or
`
`amend
`
`this
`
`Response,
`
`provided
`
`that
`
`such
`
`informanen
`
`is
`
`not
`
`otherwise
`
`privileged.
`
`Dated:
`
`New York,
`May
`
`16,
`
`NY
`2019
`
`Yours,
`
`etc.
`
`OF KEVIN
`
`J. PHILBIN
`
`Defendant
`DESIGNERS
`- 13™
`NY 10004-2109
`248-9100
`
`Street
`
`INC.
`
`Floor
`
`LAW OFFICE
`for
`Attorneys
`BIG APPLE
`
`One Whitehall
`New York,
`Phone:
`(212)
`18-017498
`
`2 of 4
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`File
`
`No.:
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`
`
`FILED: KINGS COUNTY CLERK 05/23/2019 09:55 AM
`NYSCEF DOC. NO. 19
`
`INDEX NO. 517678/2018
`
`RECEIVED NYSCEF: 05/23/2019
`
`TO: MIRMAN MARKOVITS & LANDAU, PC
`Attorneys for Plaintiff
`291 Broadway, 6th Floor
`New York, NY 10007
`(212) 227-4000
`
`HARRIS BEACH PLLC
`Attorneys for Defendant
`100 Wall Street
`New York, New York 10005
`(212) 687-0100
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3 of 4
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`
`
`FILED: KINGS COUNTY CLERK 05/23/2019 09:55 AM
`NYSCEF DOC. NO. 19
`
`INDEX NO. 517678/2018
`
`RECEIVED NYSCEF: 05/23/2019
`
`
`
`
`
`
`Index No. 517678
`
`Year: 2018
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF KINGS
`______________________________________________________________________
`YLEIN SANCHEZ,
`
`
`Plaintiff,
`
`
`
`-against-
`
`
`146 LINDEN BLVD LLC and BIG APPLE DESIGNERS INC.,
`
`
`
`
`
`Defendants.
`
`
`
`
`
`
`
`RESPONSE TO PRELIMINARY CONFERENCE ORDER AND DEFENDANT 146
`LINDEN BLVD LLC’S COMBINED DEMANDS
`______________________________________________________________________
`LAW OFFICE OF KEVIN J. PHILBIN
`Attorneys for Defendant
`ELAN RADAY, ESQ.
`One Whitehall Street, 13th floor
`New York, New York 10004
`(212) 248-9100
`
`NOTICE OF ENTRY
`
`Sir: Please take notice that the within is a (certified) true copy of the duly entered in
`the office of the Clerk of the within named court on , 2019.
`
`Dated: New York, New York
`
`
`4 of 4
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