FILED: QUEENS COUNTY CLERK 06/21/2019 01:46 PM
`NYSCEF DOC. NO. 13
`
`INDEX NO. 713599/2018
`
`RECEIVED NYSCEF: 06/21/2019
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF QUEENS
`
`MARIA PERALTA,
`
`Index No.: 713599/2018
`
`Plaintiff,
`
`-against-
`
`THE PORT AUTHORITY OF NEW YORK AND
`NEW JERSEY and DELTA AIR LINES, INC,
`
`Defendants.
`
`DEFENDANTS’ RESPONSE
`TO PRELIMINARY
`CONFERENCE ORDER
`
`Defendants, by and through their attorneys, FisherBroyles LLP, by way of their Response
`
`to the Preliminary Conference Order dated May 22, 2019 state as follows:
`
`1.
`
`Insurance Coverage.
`
`RESPONSE: Defendants are insured through a policy of insurance issued by
`various Underwriters at Interest with the lead insurer being Global Aerospace and
`policy limits in excess of any amount that could be reasonably recovered in this
`action.
`
`2.
`
`Names and Addresses of All Witnesses.
`
`RESPONSE: Defendants are currently in the process of determining the identity
`and addresses of any witnesses and will supplement this response if appropriate as
`their investigation into this smatter continues.
`
`3.
`
`Opposing Party Statements.
`
`RESPONSE: Other than those statements contained in Plaintiff’s Notice of
`Claim, Verified Complaint and The Port Authority Patron Accident Report
`annexed hereto, Defendants are not currently aware of any additional
`responsive statements.
`
`1 of 4
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`

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`FILED: QUEENS COUNTY CLERK 06/21/2019 01:46 PM
`NYSCEF DOC. NO. 13
`
`INDEX NO. 713599/2018
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`RECEIVED NYSCEF: 06/21/2019
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`4.
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`Photographs.
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`RESPONSE: Defendants are not currently in possession of any responsive
`photographs.
`
`5.
`
`Depositions, Expert Disclosures, Physical Examinations, Impleader.
`
`RESPONSE: All to be conducted per the terms contained in the May 22,
`2019 Preliminary Conference Order and/or to be otherwise agreed upon by the
`parties.
`
`
`
`PLEASE TAKE NOTICE that Defendants continue to investigate this matter and
`
`reserve their right to amend and supplement the above responses should additional responsive
`
`items become available up to and through the time of trial.
`
`Dated: New York, New York
`
`June 21, 2019
`
`FISHERBROYLES LLP
`
`
`By:_________________________________
`
`John. R. Oh
`445 Park Avenue, Ninth Floor
`New York, New York 10022
`All original papers to be delivered to
`P.O. Box 0580
`Summit, New Jersey 07902
`Any copies to be sent via email attachment
`Tel. (646) 239-9204
`Fax (800) 820-5925
`Email: john.oh@fisherbroyles.com
`Attorneys for Defendants
`
`
`
`TO:
`
`
`
`
`
`
`SERVICE VIA ECF FILING
`Dmitriy Nam, Esq.
`SHULMAN & HILL, PLLC
`26 Court Street, Suite 2100
`Brooklyn, New York 11242
`Tel. (718) 852-4700, ext. 230
`Fax: (718) 878-3608
`Email: dmitriy.nam@shulman-hill.com
`Attorneys for Plaintiff
`
`2
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`2 of 4
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`

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`FILED: QUEENS COUNTY CLERK 06/21/2019 01:46 PM
`NYSCEF DOC. NO. 13
`
`INDEX NO. 713599/2018
`
`RECEIVED NYSCEF: 06/21/2019
`
`NYSCEF DOC. NO. 13
`
`'UEENS COUNTY CLERK 06m2019 01
`
`,
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`INDEX NO. 713599/2018
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`RECEIVED NYSCEF: 06/21/2019
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`

`

`FILED: QUEENS COUNTY CLERK 06/21/2019 01:46 PM
`NYSCEF DOC. NO. 13
`
`INDEX NO. 713599/2018
`
`RECEIVED NYSCEF: 06/21/2019
`
`
`
`
`
`_FILED: 'UEENS COUNTY CLERK 06 2019 01
`
`NYSCEF DOC. No. 13
`
`INDEX NO. 713599/2018
`
`RECEIVED NYSCEF: 06/21/2919
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`
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`Any Evidence of
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`If Taken to First Aid,
`How?
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` ' Was Injured Familiar
`With Terminal?
`Did local Jurisdiction
`Police R - . nd?
`
`
`
`
`
`_
`
`Damage Involved
`
`
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`
`Total PA Damage. U None El S lOOOorless El Over5 1000
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`. _ FacilityManager'sSignature
`
`
`
`
`
`
`:.- To Be Completed By Superfisor
`Ifthe followingsection cannotbe completed immediately, fomard this report as is,
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`should be forwarded as n sum—lemt to the re-ort.
`Personnel Assigned to Am
`
`
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`Inspected Motor Stairs, Stationary Stairs .
`
`Ar
`
`iast Coating of Area (If Applicable)
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`IU EE
`
`
`
`
`
`—_
`Print in Black Ink
`Identify all witnesses
`
`Signature of Person Making Inspection
`
`
`INSTRUCTIONS
`
`
`5. Forward this form to Manager, Claims Administration
`4 of 4
`6.
`IfPA. Propertyis damaged, prepare Maintenance Work Order
`
`
`