FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`--------------------------------------------------------------------X
`BRIAN ANYANWU,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`-against-
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` 9
`
`Index No.: 155557/2021
`
`
`STATEMENT
`PURSUANT TO
`CPLR §3402(B)
`
`
`
`
`Third-Party Index No.:
`
`
`
`
` EAST 75TH LLC and CLARK CONSTRUCTION
`CORPORATION,
`Defendants
`
`
`
`
`
`--------------------------------------------------------------------X
`CLARK CONSTRUCTION CORPORATION,
`
`
`
`
`
`
`
`
`
`
`
`
`
`Third-Party Plaintiff,
`
`
` -against-
`
`
`
`CURAM CONSTRUCTION CONCEPTS LLC
`
`Third-Party Defendant.
`
`
`
`
`-----------------------------------------------------------------------X
`
`
`
`PLEASE TAKE NOTICE that in the above-entitled action, the Defendant/Third-Party
`
`Plaintiff, CLARK CONSTRUCTION COMPANY, that the caption of this action is now as set
`
`forth above; that a copy of this statement has been served upon all parties who have appeared in
`
`this action, said appearances being noted below; and that this action has not been noticed for trial
`
`in the Supreme Court, County of New York.
`
`Dated: New York, New York
`
`July 29, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`LITCHFIELD CAVO LLP
`
`Louis F. Eckert
`Louis F. Eckert, Esq.
`420 Lexington Avenue, Suite 2104
`
`
`
`
`
`1 of 11
`
`
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`--------------------------------------------------------------------X
`BRIAN ANYANWU,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`-against-
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` 9
`
`Index No.: 155557/2021
`
`
`STATEMENT
`PURSUANT TO
`CPLR §3402(B)
`
`
`
`
`Third-Party Index No.:
`
`
`
`
` EAST 75TH LLC and CLARK CONSTRUCTION
`CORPORATION,
`Defendants
`
`
`
`
`
`--------------------------------------------------------------------X
`CLARK CONSTRUCTION CORPORATION,
`
`
`
`
`
`
`
`
`
`
`
`
`
`Third-Party Plaintiff,
`
`
` -against-
`
`
`
`CURAM CONSTRUCTION CONCEPTS LLC
`
`Third-Party Defendant.
`
`
`
`
`-----------------------------------------------------------------------X
`
`
`
`PLEASE TAKE NOTICE that in the above-entitled action, the Defendant/Third-Party
`
`Plaintiff, CLARK CONSTRUCTION COMPANY, that the caption of this action is now as set
`
`forth above; that a copy of this statement has been served upon all parties who have appeared in
`
`this action, said appearances being noted below; and that this action has not been noticed for trial
`
`in the Supreme Court, County of New York.
`
`Dated: New York, New York
`
`July 29, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`LITCHFIELD CAVO LLP
`
`Louis F. Eckert
`Louis F. Eckert, Esq.
`420 Lexington Avenue, Suite 2104
`
`
`
`
`
`1 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`New York, New York 10170
`Tel: (212) 434-0100
`Attorneys for Defendant/Third-Party
`Plaintiff
`CLARK CONSTRUCTION CONCEPTS,
`LLC
`
`
`
`To:
`Via Secretary of State
`Curam Construction Concepts LLC
`187 Wolf Road, Suite 101
`Albany, NY 11205
`New York, NY, 12205
`Third-Party Defendant
`
`Via Secretary of State
`Curam Construction Concepts LLC
`147 West 35th Street, #211
`New York, NY 10001
`Third-Party Defendant
`
`Steven R. Payne, Esq.
`GINARTE GALLARDO GONZALEZ, WINOGRAD LLP
`233 Broadway, 24th Floor
`New York, NY 10007
`212-601-9700
`Attorneys for Plaintiff
`
`Via Secretary of State
`9 EAST 75TH LLC
` Isla Vista Holdings
`375 Park Avenue, Suite 2501
`New York, NY 10152
`Defendant
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`--------------------------------------------------------------------X
`BRIAN ANYANWU,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`-against-
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` 9
`
`Index No.: 155557/2021
`
`
`THIRD-PARTY SUMMONS
`
`
`
`
`Third-Party Index No.:
`
`
`
`
` EAST 75TH LLC and CLARK CONSTRUCTION
`CORPORATION,
`Defendants
`
`
`
`
`
`--------------------------------------------------------------------X
`CLARK CONSTRUCTION CORPORATION,
`
`
`
`
`
`
`
`
`
`
`
`
`
`Third-Party Plaintiff,
`
`
` -against-
`
`
`
`CURAM CONSTRUCTION CONCEPTS LLC
`
`Third-Party Defendant.
`
`
`
`
`-----------------------------------------------------------------------X
`TO THE ABOVE NAMED THIRD-PARTY DEFENDANT:
`
`
`
`YOU ARE HEREBY SUMMONED to answer the Third-Party Complaint of the
`
`Defendant/Third-Party Plaintiff, CLARK CONSTRUCTION CORPORATION, a copy of which
`
`is herewith served upon you, and to serve copies of your Answer upon the undersigned,
`
`LITCHFIELD CAVO, LLP, attorneys
`
`for Defendant/Third-Party Plaintiff, CLARK
`
`CONSTRUCTION CORPORATION, and upon all attorneys of record, within twenty (20) days
`
`after service of this Third-Party Summons and Third-Party Complaint, exclusive of the date of
`
`service, or within thirty (30) days after service if service is made by any method other than personal
`
`delivery to you within the State of New York.
`
`3 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`In the event of your failure to answer the Third-Party Complaint, judgment will be taken
`
`against you on the default for the relief sought in the Third-Party Complaint.
`
`LITCHFIELD CAVO LLP
`
`Dated: New York, New York
`
`July 29, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`
`
`Louis F. Eckert
`Louis F. Eckert, Esq.
`420 Lexington Avenue, Suite 2104
`New York, New York 10170
`Tel: (212) 434-0100
`Attorneys for Defendant/Third-Party
`Plaintiff
`CLARK CONSTRUCTION CONCEPTS,
`LLC
`
`
`
`To:
`Via Secretary of State
`Curam Construction Concepts LLC
`187 Wolf Road, Suite 101
`Albany, New York 11205
`New York, NY, 12205
`Third-Party Defendant
`
`Via Secretary of State
`Curam Construction Concepts LLC
`147 West 35th Street, #211
`New York, NY 10001
`Third-Party Defendant
`
`Steven R. Payne, Esq.
`GINARTE GALLARDO GONZALEZ, WINOGRAD LLP
`233 Broadway, 24th Floor
`New York, NY 10007
`212-601-9700
`Attorneys for Plaintiff
`
`Via Secretary of State
`9 EAST 75TH LLC
`Isla Vista Holdings
`375 Park Avenue, Suite 2501
`New York, NY 10152
`Defendant
`
`
`
`4 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`--------------------------------------------------------------------X
`BRIAN ANYANWU,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`-against-
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Index No.: 155557/2021
`
`
`THIRD-PARTY COMPLAINT
`
`
`
`
`Third-Party Index No.:
`
`
`
`
` 9
`
` EAST 75TH LLC and CLARK CONSTRUCTION
`CORPORATION,
`Defendants
`
`
`
`
`
`--------------------------------------------------------------------X
`CLARK CONSTRUCTION CORPORATION,
`
`
`
`
`
`
`
`
`
`
`
`
`
`Third-Party Plaintiff,
`
`
` -against-
`
`
`
`CURAM CONSTRUCTION CONCEPTS LLC
`
`Third-Party Defendant.
`
`
`
`
`-----------------------------------------------------------------------X
`
`Defendant/Third-Party Plaintiff, CLARK CONSTRUCTION CORPORATION, by its
`
`attorneys, LITCHFIELD CAVO, LLP, as and for its Third Party Complaint against Third-Party
`
`Defendant, CURAM CONSTRUCTION CONCEPTS LLC, respectfully alleges upon information
`
`and belief as follows:
`
`1.
`
`Defendant/Third-Party Plaintiff, CLARK CONSTRUCTION CORPORATION is
`
`a Domestic Business Corporation authorized to do and doing business in the State of New York.
`
`2.
`
`That at all times hereinafter mentioned, Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, was and still is a domestic corporation organized and
`
`existing under and by virtue of the laws of the State of New York.
`
`5 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`3.
`
`That at all relevant times hereinafter mentioned, Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, was and is a New York Foreign Limited Partnership.
`
`4.
`
`That at all times hereinafter mentioned, Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, was and still is a foreign corporation actually doing business
`
`within the State of New York.
`
`5.
`
`That at all times hereinafter mentioned, Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, was and still is a foreign corporation transacting business
`
`within the State of New York and/or contracting to buy or sell goods and/or services within the
`
`State of New York.
`
`6.
`
`That at all times hereinafter mentioned, Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, was and still is a partnership organized and existing under
`
`and by virtue of the laws of the State of New York.
`
`7.
`
`That at all times hereinafter mentioned, Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, was and still is limited liability company, organized and
`
`existing under and by virtue of the laws of the State of New York.
`
`8.
`
`That at all times hereinafter mentioned, Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, was and still is a limited liability partnership organized and
`
`existing under and by virtue of the laws of the State of New York.
`
`9.
`
`That at all times hereinafter mentioned Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, transacted business within the State of New York.
`
`10.
`
`On or about June 9, 2021, Plaintiff, BRIAN ANYANWU, initiated this action by
`
`filing a Summons and Verified Complaint with the Clerk of the Court for New York County,
`
`against, inter alia, Defendant/Third-Party Plaintiff, seeking recovery for damages and personal
`
`6 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`injuries allegedly sustained by Plaintiff on or about April 22, 2021, when he fell through a defective
`
`floor covering in the course of his employment at the premises located at 9-13 East 75th Street,
`
`New York, New York. A copy of Plaintiff’s Summons and Complaint is annexed hereto as Exhibit
`
`“A” and made a part hereof, without admitting any of the allegations contained therein.
`
`AS AND FOR A
`FIRST CAUSE OF ACTION FOR
`COMMON LAW INDEMNIFICATION
`AGAINST CURAM CONSTRUCTION CONCEPTS, LLC
`
`Defendant/Third-Party Plaintiff, repeats and reiterates each and every allegation
`
`11.
`
`contained in Paragraphs 1 through 10 set forth above, as though more fully set forth at length
`
`herein.
`
`12.
`
`In the event of any verdict or judgment against Defendant/Third-Party Plaintiff,
`
`any liability being expressly denied, then said verdict or judgment will have been brought about
`
`by the intentional conduct and/or negligence, reckless, wanton and grossly negligent conduct of
`
`Third-Party Defendant, CURAM CONSTRUCTION CONCEPTS LLC, and Defendant/Third-
`
`Party Plaintiff will be entitled to a judgment over and against Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, for indemnity based upon its conduct being primary and
`
`active, whereas Defendant/Third-Party Plaintiff’s conduct was secondary and passive.
`
`AS AND FOR A SECOND CAUSE
`OF ACTION FOR CONTRIBUTION
`AGAINST CURAM CONSTRUCTION CONCEPTS LLC
`
`Defendant/Third-Party Plaintiff, repeats and reiterates each and every allegation
`
`13.
`
`contained in Paragraphs 1 through 12 set forth above, as though more fully set forth at length
`
`herein.
`
`14.
`
`Pursuant to CPLR Article 14 and common law principles, in the event of any verdict
`
`or judgment against Defendant/Third-Party Plaintiff, any liability being expressly denied, then
`
`7 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`such verdict or judgment will have been caused by the conduct of Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, and Defendant/Third-Party Plaintiff will be entitled to a
`
`judgment over and against Third-Party Defendant, CURAM CONSTRUCTION CONCEPTS
`
`LLC, for contribution and/or proportionate sharing of damages. In addition, Third-Party
`
`Defendant, CURAM CONSTRUCTION CONCEPTS LLC, must also pay attorneys’ fees, costs
`
`and disbursements to Defendant/Third-Party Plaintiff.
`
`15.
`
`Defendant/Third-Party Plaintiff has been damaged by the above-referenced
`
`breaches, actions and/or inactions of Third-Party Defendant, CURAM CONSTRUCTION
`
`CONCEPTS LLC.
`
`
`
`16.
`
`
`
` AS AND FOR A THIRD CAUSE OF ACTION
`FOR CONTRACTUAL INDEMNIFICATION
`AGAINST CURAM CONSTRUCTION CONCEPTS LLC
`
`Defendant/ Third-Party Plaintiff, repeats and reiterates each and every allegation
`
`contained in Paragraphs 1 through 15 set forth above, as though more fully set forth at length
`
`herein.
`
`17.
`
`Upon information and belief, Defendant/Third-Party Plaintiff, entered into a
`
`contract with Third-Party Defendant, CURAM CONSTRUCTION CONCEPTS LLC, for the
`
`benefit of Defendant/Third-Party Plaintiff.
`
`
`
`18.
`
`Pursuant to the aforesaid contract and/or as extended, Third-Party Defendant,
`
`CURAM CONSTRUCTION CONCEPTS LLC, was obligated to undertake the defense,
`
`indemnify and hold harmless Defendant/Third-Party Plaintiff, CLARK CONSTRUCTION
`
`CORPORATION, from any claims for personal injury, such as the claims asserted by Plaintiff,
`
`BRIAN ANYANWU, in the underlying Verified Complaint, and for any resulting cross-claims,
`
`counter-claims, and/or third-party claims against Defendant/Third-Party Plaintiff.
`
`8 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`19.
`
`Third-Party Defendant, CURAM CONSTRUCTION CONCEPTS LLC, has failed
`
`to provide defense and indemnity to Defendant/Third-Party Plaintiff in violation of its contractual
`
`obligations.
`
`20.
`
`Upon information and belief, Defendant/Third-Party Plaintiff are entitled to a
`
`defense and
`
`to contractual
`
`indemnification
`
`from Third-Party Defendant, CURAM
`
`CONSTRUCTION CONCEPTS LLC, and all costs including legal fees related to this action.
`
`AS AND FOR A FOURTH CAUSE OF ACTION
`FOR BREACH OF CONTRACT
`AGAINST CURAM CONSTRUCTION CONCEPTS LLC
`
`Defendant/Third-Party Plaintiff repeats and reiterates each and every allegation
`
`21.
`
`contained in Paragraphs 1 through 20 set forth above, as though more fully set forth at length
`
`herein.
`
`22.
`
`Third-Party Defendant, CURAM CONSTRUCTION CONCEPTS LLC, also
`
`contracted to provide insurance coverage for Defendant/Third-Party Plaintiff, protecting them
`
`from liability in lawsuits of the type filed by Plaintiff, and any resulting cross-claims, counter-
`
`claims and/or third-party claims against Defendant/Third-Party Plaintiff.
`
`23.
`
`Third-Party Defendant, CURAM CONSTRUCTION CONCEPTS LLC, has failed
`
`to obtain insurance coverage for Defendant/Third-Party Plaintiff, CLARK CONSTRUCTION
`
`CORPORATION, as required by its contractual obligations to indemnify and defend
`
`Defendant/Third-Party Plaintiff against the claims made by Plaintiff, and/or any resulting cross-
`
`claims, counter-claims, and/or third-party claims.
`
`24.
`
`In the alternative, despite having obtained insurance coverage for Defendant/Third-
`
`Party Plaintiff as required by its contractual obligations to indemnify and defend Defendant/Third-
`
`Party Plaintiff against the claims made by Plaintiff, and/or any resulting cross-claims, counter-
`
`9 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`claims and/or
`
`third-party claims, Third-Party Defendant, CURAM CONSTRUCTION
`
`CONCEPTS LLC, has failed to make the necessary claims to its insurance carrier in order for said
`
`insurance carrier to assume the defense and indemnity of Defendant/Third-Party Plaintiff.
`
`25.
`
`Defendant/Third-Party Plaintiff have been damaged by the above-referenced
`
`breaches, actions and/or inactions of Third-Party Defendant, CURAM CONSTRUCTION
`
`CONCEPTS LLC.
`
`WHEREFORE, Defendant/Third-Party Plaintiff, CLARK CONSTRUCTION
`
`CORPORATION, demands judgment in their Third-Party Complaint against Third-Party
`
`Defendant, CURAM CONSTRUCTION CONCEPTS LLC, for a defense, indemnity, contribution
`
`and/or proportionate sharing of damages, and damages for breach of contract, together with costs,
`
`fees, expenses, attorneys’ fees, and such other and further relief as this Court deems just and
`
`
`By:
`
`
`
`
`
`proper.
`
`Dated: New York, New York
`
`July 29, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`To:
`Via Secretary of State
`Curam Construction Concepts LLC
`187 Wolf Road, Suite 101
`Albany, New York 11205
`New York, NY, 12205
`Third-Party Defendant
`
`
`LITCHFIELD CAVO LLP
`
`
`
`
`
`Louis F. Eckert
`Louis F. Eckert, Esq.
`420 Lexington Avenue, Suite 2104
`New York, New York 10170
`Tel: (212) 434-0100
`Attorneys for Defendant/Third-Party
`Plaintiff
`CLARK CONSTRUCTION CONCEPTS,
`LLC
`
`10 of 11
`
`
`
`FILED: NEW YORK COUNTY CLERK 07/29/2021 12:02 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 155557/2021
`
`RECEIVED NYSCEF: 07/29/2021
`
`Via Secretary of State
`Curam Construction Concepts LLC
`147 West 35th Street, #211
`New York, NY 10001
`Third-Party Defendant
`
`Steven R. Payne, Esq.
`GINARTE GALLARDO GONZALEZ, WINOGRAD LLP
`233 Broadway, 24th Floor
`New York, NY 10007
`212-601-9700
`Attorneys for Plaintiff
`
`Via Secretary of State
`9 EAST 75TH LLC
`Isla Vista Holdings
`375 Park Avenue, Suite 2501
`New York, NY 10152
`Defendant
`
`
`11 of 11
`
`
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