`NYSCEF DOC. NO. 24
`
`INDEX NO. 156729/2017
`
`RECEIVED NYSCEF: 09/12/2018
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`----------------------------------------------------------------------x
`LADONNA ARTHURS,
`
`
`Plaintiff,
`
`
`v.
`
`MARRIOTT INTERNATIONAL, INC., RENAISSANCE
`HOTEL MANAGEMENT COMPANY LLC, SOL
`GOLDMAN INVESTMENTS, LLC. APPLE EIGHT
`HOSPITALITY MANAGEMENT, INC. AND APPLE EIGHT
`HOSPITALITY OWNERSHIP, INC.
`
`
`Index No.: 156729/2017
`(ECF)
`
`
`
`RESPONSE TO
`PRELIMINARY
`CONFERENCE ORDER
`
`
`
`Defendants.
`----------------------------------------------------------------------x
`
` PLEASE TAKE NOTICE, that Defendants, Marriott International, Inc., Apple Eight
`
`Hospitality Management, Inc. , Sol Goldman Investments, LLC and Apple Eight Hospitality
`
`Ownership, Inc., by its attorneys, Eustace, Marquez, Epstein, Prezioso & Yapchanyk, hereby
`
`respond to this Court's Preliminary Conference Order dated August 15, 2018 as follows:
`
`INSURANCE INFORMATION
`
`Defendants are insured under Chubb Group of Insurance Companies Policy Number
`
`99476047, effective November 1, 2015 through November 1, 2016. Said policy provides
`
`coverage in the amount of $1,000,000 per loss per year.
`
`
`
`Defendants are also insured under Fireman’s Fund Excess Policy Number SHX-000-
`
`2450-0761, effective November 1, 2015 to November 1, 2016. Said policy provides excess
`
`coverage in the amount of $50,000,000 per loss.
`
`WITNESSES
`
`
`
`The following individuals may have knowledge or information relative to the subject
`
`incident:
`
`1 of 4
`
`
`
`FILED: NEW YORK COUNTY CLERK 09/12/2018 11:15 AM
`NYSCEF DOC. NO. 24
`
`INDEX NO. 156729/2017
`
`RECEIVED NYSCEF: 09/12/2018
`
`Pedro Gutierrez
`
`William Bravo
`
`STATEMENTS OF OPPOSING PARTIES
`
`Defendants are not in possession of adverse party statements relative to this action.
`
`PHOTOGRAPHS
`
`Defendants are not in possession of photos or videotapes relative to the subject incident.
`
`
`
`
`
`See Exhibit A.
`
`ACCIDENT REPORT
`
`EXPERT WITNESSES
`
`Defendants have not yet designated expert witnesses to testify at the time of trial of this
`
`action, but hereby reserve(s) all such rights pursuant to CPLR § 3101 (d)(1).
`
`
`
`Defendants hereby reserve the right to amend and/or supplement this response up to and
`
`including the time of trial.
`
`DATED: September 13, 2018
` New York, New York
`
`
`
`
`2 of 4
`
`Eustace, Marquez, Epstein, Prezioso &
`Yapchanyk
`Attorneys for Defendants,
`MARRIOTT INTERNATIONAL, INC.,
`APPLE EIGHT HOSPITALITY
`MANAGEMENT, INC. , SOL
`GOLDMAN INVESTMENTS, LLC AND
`APPLE EIGHT HOSPITALITY
`OWNERSHIP, INC.
`55 Water Street, 28th Floor
`New York, New York 10041
`(212) 612-4200
`
`
`
`By: ___________________________
`Miles A. Linefsky
`
`
`
`FILED: NEW YORK COUNTY CLERK 09/12/2018 11:15 AM
`NYSCEF DOC. NO. 24
`
`INDEX NO. 156729/2017
`
`RECEIVED NYSCEF: 09/12/2018
`
`
`TO:
`
`Charles N. Pizzolo, Esq.
`Attorneys for Plaintiff,
`Ladonna Arthurs
`394 Old Country Road
`Garden City, New York 11530
`(917) 670-4818
`
`
`
`3 of 4
`
`
`
`FILED: NEW YORK COUNTY CLERK 09/12/2018 11:15 AM
`NYSCEF DOC. NO. 24
`
`INDEX NO. 156729/2017
`
`RECEIVED NYSCEF: 09/12/2018
`
`
`Index No.: 156729/2017 (ECF)
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`
`
`LADONNA ARTHURS,
`
`
`Plaintiff,
`
`
`MARRIOTT INTERNATIONAL, INC., RENAISSANCE HOTEL
`MANAGEMENT COMPANY LLC, SOL GOLDMAN INVESTMENTS,
`LLC. APPLE EIGHT HOSPITALITY MANAGEMENT, INC. AND APPLE
`EIGHT HOSPITALITY OWNERSHIP, INC.
`
`
`-against-
`
` Defendants.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`RESPONSE TO PRELIMINARY CONFERENCE ORDER
`
`
`_______________________________________________________________
`
`
`
`
`
`EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK
`Attorneys for Defendants
`Marriott International, Inc., Apple Eight Hospitality Management, Inc. , Sol Goldman
`Investments, LLC and Apple Eight Hospitality Ownership, Inc.
`Office and Post Office Address
`55 Water Street, 28th Floor
`New York, New York 10041
`(212) 612-4200
`
`
`
`
`
`4 of 4
`
`
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