throbber
FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`
`INDEX NO. 53567/2015
`
`
`
`
`
`
`
`Index No.: 53567/2015
`
`NOTICE OF APPEAL
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF WESTCHESTER
`-------------------------------------------------------------------X
`PEDRO MOROCHO,
`
`Plaintiff,
`
`-against-
`
`DORAN CONSTRUCTION CORP., and HM
`BUILDERS CORPORATION,
`
`Defendants.
`-------------------------------------------------------------------X
`DORAN CONSTRUCTION CORP.,
`
`Third-Party Plaintiff,
`
`-against-
`
`BIPEX CONSTRUCTION,
`
`Third-Party Defendant.
`-------------------------------------------------------------------X
`
`
`PLEASE TAKE NOTICE, that plaintiff PEDRO MOROCHO hereby appeals to the
`
`Appellate Division of the Supreme Court, in and for the Second Judicial Department, from those
`
`parts of the Decision and Order of this Court which denied plaintiff's post-trial motion to set
`
`aside the jury's awards as to past and future pain and suffering as inadequate and to increase
`
`those awards, entered with the Clerk of the Supreme Court, Westchester County, on June 29,
`
`2018 (NYSCEF Doc. # 199) and served with a Notice of Entry on or about July 2, 2018
`
`(NYSCEF Doc. # 200).
`
`Dated: New York, New York
`August 1, 2018
`
`1 of 16
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`
`INDEX NO. 53567/2015
`
`Yours, etc.,
`
`QUELLER, FISHER, WASHOR,
`FUCHS & KOOL, LLP
`
`S/
`
`By:
`
`Matthew J. Maiorana
`Attorneys for Plaintiff
`233 Broadway
`New York, New York 10279
`(212) 406-1700
`
`
`
`
`
`
`
`To: Marks, O'Neill, O'Brien, Doherty & Kelly, P.C.
`Attorneys for Defendant/Third-Party Plaintiff Doran Construction
`530 Saw Mill River Road
`Elmsford, New York 10523
`
`
`
`
`
`
`
`
`Baxter Smith & Shapiro, P.C.
`Attorneys for Third-Party Defendant Bipex Construction
`200 Mamaroneck Avenue, Suite 601
`White Plains, New York 10601
`
`HM Builders Corporation did not appear and a default judgment was granted (NYSCEF
`Dkt. #17)
`
`
`
`
`
`
`
`
`2
`
`2 of 16
`
`

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`FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`
`INDEX NO. 53567/2015
`
`Pedro Morocho,
`
`Plaintiff
`
`
`
`
`
`
`
`v.
`
`Doran Construction Corp., and HM Builders Corp.,
`
`
`
`
`
`Defendants
`
`3 of 16
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`
`INDEX NO. 53567/2015
`
`Supreme Court
`June 29, 2018
`Terry Jane Ruderman
`
`Westchester
`June 29, 2018
`53567/2015
`
`That portion of the Order which denied plaintiff's motion pursuant to CPLR 4404(a) for an order setting aside
`the jury verdict as to past and future pain and suffering as inadequate and increasing those awards.
`
`Whether the trial court erred in declining to set aside the jury awards for past and future pain and suffering as
`inadequate and to increase those awards.
`
`4 of 16
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`
`INDEX NO. 53567/2015
`
`Pedro Morocho
`Doran Construction Corp.
`HM Builders Corp.
`BIPEX Construction
`
`Plaintiff
`Defendant/Third-Party Plaintiff
`Defendant
`Third-Party Plaintiff
`
`Appellant
`Respondent
`Respondent
`Respondent
`
`5 of 16
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`
`INDEX NO. 53567/2015
`
`Queller Fisher Washor Fuchs & Kool, LLP
`233 Broadway
`New York
`
`NY
`
`10279
`
`Marks O'Neill O'Brien Doherty & Kelly, P.C.
`530 Saw Mill River Road
`Elmsford
`
`NY
`
`10523
`
`1
`
`212-406-1700
`
`914-345-3701
`
`2
`HM Builders Corp - Did not appear and default judgment entered
`9 Split Rock Road
`Mahopac
`
`10541
`
`NY
`
`Baxter Smith & Shapiro, P.C.
`200 Mamaroneck Avenue, Suite 601
`White Plains
`
`NY
`
`10601
`
`3
`
`4
`
`914-684-1055
`
`6 of 16
`
`

`

`
`FILED: WESTCHESTER COUNTY CLERK 06/29/2018 04:56 PMFILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`
`NYSCEF DOC. NO. 199NYSCEF DOC. NO. 204
`
`RECEIVED NYSCEF: 06/29/2018RECEIVED NYSCEF: 08/03/2018
`
`
`
`INDEX NO. 53567/2015INDEX NO. 53567/2015
`
`':Tocommence the statutory time for ,appeals as of fight
`(CPLR 55l3(a]), you are advised to serve a copy
`of this order, with notice of entry ,upon all parties,
`
`SUPREME COURT,OFTHESTATE
`OF NEW YORK
`, 'COUNTY OF WESTCHESTER
`"
`'
`'--------------------~---------~-------~~--~----------~-~---~------J{
`pEDRO MOROCHQ,
`
`Plaintiff,
`
`-against-
`"
`DORAN CONSTRUCTION CORP., and JIM
`BUILDERS CORPORATION"
`
`Defenda.nts.'
`~-----------~------------~-----------~----~--~~7------~--~~--~---:J{
`DORAN CONSTRUCTION CORP;,
`
`Third-PahyPlaintiff,
`
`-against-
`
`.
`
`BIPEX CONSTRUCTION,
`
`,
`
`,
`Third-PartyDefenclant.
`'
`~-----------------------~7----~~---------------------~------------J{
`RUDERMAN, 1.
`
`DECISION and ORDER
`
`,Motion Sequence NO.9
`Index No. 53567/2015
`(
`
`The following papers were considered in ,connection~ithplaintiff'
`
`s posHrial motion
`
`pursuant
`
`to CPLR4404(a)
`
`for an order setting a.side thej ury verdict as to pastand future pain
`
`and suffering as inadyquatearid'for
`
`an increase in the award of past medicaleJ{penses as against
`
`r
`
`Jhe weight of the evidence,:
`
`Numbered
`
`123
`
`Papers
`Notice ofM6tion,Affinpation,
`., Memorandum of Law
`Affiri11ationinOpposition
`Reply,MemoranduJ:l1 of Law
`
`EJ{hibits 1 - 13 and
`
`1
`
`
`
`1 of 77 of 16
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`

`

`
`FILED: WESTCHESTER COUNTY CLERK 06/29/2018 04:56 PMFILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`
`NYSCEF DOC. NO. 199NYSCEF DOC. NO. 204
`
`RECEIVED NYSCEF: 06/29/2018RECEIVED NYSCEF: 08/03/2018
`
`
`
`INDEX NO. 53567/2015INDEX NO. 53567/2015
`
`This matter came before thi~ Court for trial on the issue of damages, after summary
`
`judgment was granted in favor of plaintiff on the issue of defendants'
`
`liability, based on
`
`plaintiff's worksite fall of approximately 30 feet from an unsecured extension ladder while he
`
`was performing carpentry work.
`
`At trial, plaintiff presented the testimony of Dr. Louis Amorosa, a trauma orthopedic
`
`spine surgeon who treated plaintiff. Amorosa testified that as a result of his fall plaintiff
`
`.
`
`suffered a fractured dislocation ofT12-Ll
`
`and a transected spinal cord. While he performed
`
`surgery to stabilize the spinal column, the injury has resulted in complete paralysis below the
`
`\
`
`ievel of the spinal injury. Because of this paraplegia, plaintiff has lio control of or sensation in
`
`his legs, and has no bladder or b,owel control; he must insert.a catheter approximately five times
`
`per day to expel urine, Amorosa characterized plaintiff's condition as a "chronic, horrible pain
`
`syndrome," and stated that plaintiff's condition is permanent, and precludes plaintiff from
`
`employment.
`
`In addition, .Amorosa suggested that plaintiff will probably need further surgery,
`
`because two screws that were inserted during surgery have not fused and are loose, m,eaning that
`
`they will probably fail at some point.
`
`Dr. Bradley Cash testified with regard to the treatment of plaintiff's pain. He explained
`
`that the crushed nerves in plaintiff's back generate pain signals, and that notwithstanding the
`
`prescribed pain medication, plaintiff's neuropathic pain is real, severe, and disabling. Cash also
`
`maintained that plaintiff is permanently and totally disabled.
`
`Plaintifftestified'that
`
`prior to his injury, he was very active, working six days per week
`
`and playing soccer. He explained at length the nature and extent of the. pain, discomfort and
`
`distress caused by his paraplegia. He.discussed being taught during rehabilitation how to
`
`maneuver himself into and out of his bed and wheelchair, which process he described as very
`
`2
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`
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`2 of 78 of 16
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`

`

`
`FILED: WESTCHESTER COUNTY CLERK 06/29/2018 04:56 PMFILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`
`NYSCEF DOC. NO. 199NYSCEF DOC. NO. 204
`
`RECEIVED NYSCEF: 06/29/2018RECEIVED NYSCEF: 08/03/2018
`
`
`
`INDEX NO. 53567/2015INDEX NO. 53567/2015
`
`hard. He also described the procedure of having to catheterize his bladder himself five time each
`
`day, and being unable to control his bowel movements. He further testified that he was required
`
`to inject himself in the stomach to administer a medication to prevent blood clots.
`
`In the course of the jury's deliberations,
`
`it made a number of requests.
`
`In one note, it
`
`requested "an itemized statement of his [plaintiffs]
`
`past unpaid bills and bills that Pedro
`
`,[plaintift] paid." Counsel for both parties agreed that because there was no such itemized
`
`statement
`
`in the record, that the jury must be informed that no itemized statement existed, and
`
`that they must rely on the documents in evidence. However, plaintiffs
`
`counsel also proposed
`
`that because the question differentiated between paid and unpaid bills, the court should provide
`
`an additional
`
`instruction the jury that "whether the bills were paid by Mr. Morocho or not has
`
`nothing to do with whether he's entitled to past medical [expenses]."
`
`The Court declined that
`
`suggestion, because it required the court to infer merely from the question's naming two
`
`categories of bills, that the jury believed plaintiff s entitlement
`
`to an award for medical expenses
`
`depended on whether the expenses had been paid or not. After the jury's note was answered,
`
`counsel for plaintiff suggested that the Court's instruction had implied that the medical bills
`
`were not in evidence; and asked the Court to further instruct the jury that the bills were in
`
`evidence. That proposal was rejected.
`
`Having heard' all the evidence,
`
`the jury awarded plaintiff $375,000 for past pain and
`
`'suffering, $4,625,000 for future pain and suffering for a period of 40 years, zero for past medical
`
`expenses, and $11,200,000 for future medical expenses for a period of 37 years.
`
`.
`Plaintiff now contends that both awards for pain and suffering are inadequate; he also
`
`.
`
`attributes the jury's determination regarding past medical expenses to this Court; s failure to
`
`properly instruct the jury regarding the evidence in that regard.
`
`3
`
`
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`3 of 79 of 16
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`

`

`
`FILED: WESTCHESTER COUNTY CLERK 06/29/2018 04:56 PMFILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`
`NYSCEF DOC. NO. 199NYSCEF DOC. NO. 204
`
`RECEIVED NYSCEF: 06/29/2018RECEIVED NYSCEF: 08/03/2018
`
`
`
`INDEX NO. 53567/2015INDEX NO. 53567/2015
`
`Pain and Suffering
`
`Discussion
`
`A trial court may set aside a jury verdict under CPLR 4404(a) based on inadequacy,
`
`ifit
`
`"deviates materially from what would be reasonable compensation"
`
`(see Gorman v Mathew, 151
`
`AD3d 816,817 [2d Dept 2017]). This analysis is conducted by comparing the plaintiffs
`
`injuries
`
`with the injuries and awards in comparable cases (see Kayes v Liberati, 104 AD3d 739, 741 [2d
`
`Dept 2013]). Plaintiff contends that this Court should set aside the award of damages for both
`
`past and future pain and suffering as inadequate. The Court declines to do so.
`
`Here, the awards for-past and future pain and suffering, $375,000 and $4,625,000
`
`respectively,
`
`totaling $5 million, do not deviate materially from compensation granted in
`
`comparable cases.
`
`In Herrera v Sf. Martin (34 AD3d 529 [2nd Dept 2006]), where the
`
`plaintiffs
`
`injuries "resulted in a total paralysis in her lower extremities, and bowel and bladder
`
`incontinence,"
`
`the Court reduced the plaintiffs damages award for past pain and suffering from
`
`$1,500,000 to $1,000,000, and the damages award for future pain and suffering from $2,500,000
`
`to $2,000,000 for a period of 10 years.
`
`In Schifelbine v. Foster Wheeler Corp. (4 AD3d 736 [4th Dept 2004]), plaintiff was
`
`rendered quadriplegic, sustained a skull fracture and underwent above knee amputation. The
`
`,fourth Department affirmed the jury's awards for past and future pain and suffering, which the
`
`trial court's decision reflects were $1 million for past pain and suffering and $5.5 million in
`,
`future pain and suffering (see Schifelbine v Foster Wheeler Corp., 3 Misc 3d 151, 153 [Sup Ct
`
`<AlleganyCounty 2002]).
`
`In Miraglia v H & L Holding Corp., 36 AD3d 456,456 [1st Dept 2007]), where the
`
`plaintiff suffered "paraplegia and associated complications" and Was awarded $5 million for past
`
`4
`
`
`
`4 of 710 of 16
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`

`

`
`FILED: WESTCHESTER COUNTY CLERK 06/29/2018 04:56 PMFILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`
`NYSCEF DOC. NO. 199NYSCEF DOC. NO. 204
`
`RECEIVED NYSCEF: 06/29/2018RECEIVED NYSCEF: 08/03/2018
`
`
`
`INDEX NO. 53567/2015INDEX NO. 53567/2015
`
`'pain and suffering and $10 million for future pain and suffering over 35 years, the award for
`
`future pain and suffering was reduced to $5,000,000.
`
`The jury's total award of pain and suffering in this case is comparable to similar cases.
`
`While plaintiff suggests that the past pain and suffering awards in other cases were consistently
`
`greater than the $375,000,
`
`the difference between this and other cases does not warrant additur,
`
`particularly when it is considered that the jury appears to have broken down a total award of
`
`$5,000,000 into two proportioned segments;
`
`"In no two cases are the quality and quantity of
`
`J
`
`such damages identical" (Caprara v Chrysler Corp.,52 NY2d 114, 127 [1981]), and comparisons
`
`cannot be made with mathematical precision (see Reedv CifyojNew York, 304 AD2d 1, 7 [1st
`
`Dept 2003]).
`
`'Past Medical Expenses
`
`With regard to the jury's decision to award nothing for plaintiff s past medical expenses,
`
`review of the record,
`
`including the noteask~ng for ':an itemized statement of his [plaintiff s] past
`
`unpaid bills and bills that Pedro [plaintiff] paid:' makes it unlikely that the jury's lack of an
`
`award for past medical expenses is attributable to the Court's response to that request.
`
`Initially;
`
`the court correctly responded that the requested items,,including such an itemized statement,
`
`were not in evidence, and that the jury was required to make its decision based only on the
`
`exhibits and the testimony. The Court's statement
`
`that "these items are not in evidence"
`
`referred, of course, to the requested items, not to the medical bills.
`
`The jury's failure to arrive at an award for past medical expenses is more likely due to
`
`the manner in which the evidence of plaintiff spast medical expenses was presented to the jury.
`
`Specifically, plaintiff relied on documents that were included among quantities of other
`
`documents in a large box of evidence, without providing testimony that explained that evidence
`
`5
`
`
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`5 of 711 of 16
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`

`

`
`FILED: WESTCHESTER COUNTY CLERK 06/29/2018 04:56 PMFILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`
`NYSCEF DOC. NO. 199NYSCEF DOC. NO. 204
`
`RECEIVED NYSCEF: 06/29/2018RECEIVED NYSCEF: 08/03/2018
`
`
`
`INDEX NO. 53567/2015INDEX NO. 53567/2015
`
`pr broke down that c(itegory of damages. Notably, many ofthe bills were included within large
`
`exhibits without any dear. delineation.
`
`I
`
`"
`
`.
`
`~
`
`-Although the documentary evidence admitted at trial
`
`-
`
`:.
`
`.
`
`.-
`
`•.
`
`established plaintiff' ~past medical expenses in th~am.oul1t n6w claimed of $52~,926.59,
`
`the jury
`
`,
`
`"-'"
`
`may well have been ata loss, in the absence of explanatiorior guidance, as to how to ferret out
`
`.
`
`the relevant medical bills to make its assessment of that category of damages.
`
`'.'
`
`,I.
`
`.
`
`:.
`
`"
`
`.
`
`.
`
`.
`
`However, notwithst~dingthejury's,possible
`
`difficulty or confusion,
`
`those past medical
`
`expenses were established without contradiction in documents that were admitted int() evidence
`
`by stipulation.- The ffi~dical bills admitted into evidence by stipulation were from:
`
`\.
`
`- Westchester Medical Center, Plaintiff's E~hibit 17, fmchargesof
`
`$491,5JO.33;.
`
`- University Orihope,dics, pa~~fPla.intiff'sExhibit
`
`2; for chargesof$12,686.53;
`
`- Spine Options, part of Plaintiff sExhibit 3, for charges ~f$2;804.92;
`
`- Empress EmergencyMedical
`
`Services, Plaintiff's.Exhibit4,
`
`for charges.of $831.00;
`
`- Dominican Sisters Family Health Service, part of Plaintiff's Exhibit 5, for charges of
`~.
`
`-.
`
`"'.'
`
`.
`
`,.
`
`$9,805.00;
`
`- Dr. AndrewMerola,pari
`
`of Plaintiff's Exhibit.7, for charges of $148.69;
`
`- Firstlight HomeCa.re of Westchester, part of Plaintiff's E){hibit 9;Jorcharges
`
`of$3,765.12;
`
`- Dr. Sheldon Axelmd, part of Plaintiff's Exhibif16;
`
`for charges of$1,375.00.
`
`The total of those bills is $522,926.59;
`
`The only partY who has submitted opposition tothis motion does not dispute the validi!y
`
`or accuracy of these bills in evidence." Rather ;1t relies on CPL~ 4518 to argue that the
`
`Westchester MedicaL C~nter hillfor $491,510.3 3 may not be "treated.aspri!lla facie evidence
`
`because it does not bear the propercei"tification .. However,.having stipulated to the adrpission
`
`(and therefore the admissibility) of this evidence at trial, defendant may not now challenge any
`
`6
`
`
`
`6 of 712 of 16
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`

`

`
`FILED: WESTCHESTER COUNTY CLERK 06/29/2018 04:56 PMFILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`
`NYSCEF DOC. NO. 199NYSCEF DOC. NO. 204
`
`RECEIVED NYSCEF: 06/29/2018RECEIVED NYSCEF: 08/03/2018
`
`
`
`INDEX NO. 53567/2015INDEX NO. 53567/2015
`
`\
`
`.{1reliance onit as evidence;
`
`it has waived any protection CPLR 4518 provided to it.' Accordingly,
`-
`the fact of those medical bills" and theirtotaJ amount, are established' as an:atter of law.
`
`.',
`
`'.
`
`Based upon the foregoing,
`.
`
`'.
`
`.
`
`it is hereby,
`-
`
`.
`
`..
`
`,"
`
`ORDERED that plaintiff smotion pursuant
`
`toCPLR' 4404 (a) is denied to the extent it
`
`'seeks to set aside .asinadequate the jury's award for pa,st and future pain and suffering, and is
`,
`-
`
`"
`
`,..".
`-
`
`.
`
`.
`
`.
`
`granted to the extent that it seeks to set'aside'somuch
`
`of the jl.uyverdictas.awarded
`
`plaintiff
`
`nothing for past medical expenses,andin
`
`place of thatamountis
`
`substituted an award of
`
`$522,926.59 for past medical expenses, based on the stipulated triaLevidence.
`- ~ '.
`'.
`This constitutes the Decision arid Order of the Court.
`
`'.
`
`June t. ,,20i8
`Dated: White1!l-p.ains, .•.New York
`"
`
`,
`
`,
`
`.l"'
`
`,.
`
`\
`
`,
`
`7
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`7 of 713 of 16
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`

`
`INDEX NO. 53567/2015
`FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`INDEX \10' 53567/2015
`FILED: WESTCHESTER COUNTY CLERK 08m2018 04:33 PM
`
`
`
`
`
`NYSC
`3F DOC. NO. 204
`RaCaIVaD NYSCEF: 08/03/2018
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`
`
`
`AFFIRMATION OF SERVICE
`
`MATTHEW J. MAIORANA, an attorney admitted to practice law before the Courts of
`the State ofNew York, affirms the following under the penalties of perjury:
`
`I am a member of QUELLER, FISHER, WASHOR, FUCHS & KOOL, LLP, attorneys
`for the plaintiff herein.
`
`I served a true copy of the annexed Notice of Appeal, Request for Appellate Division
`Intervention, and paper appealed fi'om on August 1, 2018 by uploading same to NYSCEF -
`Westchester County Supreme Court. A true copy of the confirmation is annexed hereto indicating
`the persons to whom notification was sent.
`
`Dated: New York, New York
`
`August 3, 2018
`
`Ma
`
`6
`
`rana
`
`14 of 16
`14 of 16
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`

`

`FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`NYSCEF - Westchester County Supreme Court
`Confirmation Notice
`
`INDEX NO. 53567/2015
`
`This is an automated response for Supreme Court cases. The NYSCEF site has received your
`electronically filed documents for the following case.
`
`53567/2015
`
`PEDRO MOROCHO - v. - DORAN CONSTRUCTION CORP. et al
`
`Assigned Judge: Terry Jane Ruderman
`
`Documents Received on
`
`08/01/2018 04:33 PM
`
`Doc #
`204
`
`Document Type
`NOTICE OF APPEAL/RADI/COPY OF ORDER/PROOF OF SERVICE
`Does not contain an SSN or CPI as defined in 202.5(e) or 206.5(e)
`
`Motion #
`
`Filing User
`Matthew John Maiorana
`Name:
`Phone #:
`Fax #:
`
`E-mail Address:
`Work Address:
`
`mmaiorana@quellerfisher.com
`233 BROADWAY FL 18TH
`NEW YORK, NY 10279
`
`E-mail Notifications
`An e-mail notification regarding this filing has been sent to the following address(es) on
`08/01/2018 04:33 PM :
`
` BAXTER, ROBERT C - rbaxter@bssnylaw.com
` CONNOLLY, KEVIN WILLIAM - kconnolly@pmtlawfirm.com
` DWECK, STUART MARC - Stuartdweck@aol.com
` KOOL, JONNY - jkool@quellerfisher.com
` LOMBARDI, FRANK D - flombardi@mooclaw.com
` MAIORANA, MATTHEW JOHN - mmaiorana@quellerfisher.com
` MULLANE, CHRISTOPHER JOHN - christopher.mullane@brodyoconnor.com
` SECHTER, ADAM BENJAMIN - asechter@bssnylaw.com
` SHAPIRO, SIM R. - sshapiro@bssnylaw.com
` SKELLY, JAMES M. - jmskelly@moodklaw.com
` WARYCHA, JENNIFER A - jwarycha@bssnylaw.com
`
`Timothy C. Idoni - http://www.westchesterclerk.com
`Email: e-file@westchestergov.com
`
`NYSCEF Resource Center - EFile@nycourts.gov
`Fax:
`Phone:
`(646) 386-3033
`(212) 401-9146
`
`Website:
`
`www.nycourts.gov/efile
`
`Page 1 of 2
`15 of 16
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 08/01/2018 04:33 PM
`NYSCEF DOC. NO. 204
`RECEIVED NYSCEF: 08/03/2018
`NYSCEF - Westchester County Supreme Court
`Confirmation Notice
`
`INDEX NO. 53567/2015
`
`53567/2015
`
`PEDRO MOROCHO - v. - DORAN CONSTRUCTION CORP. et al
`
`Assigned Judge: Terry Jane Ruderman
`
`E-mail Notifications
`An e-mail notification regarding this filing has been sent to the following address(es) on
`08/01/2018 04:33 PM :
`
` BAXTER, ROBERT C - rbaxter@bssnylaw.com
` CONNOLLY, KEVIN WILLIAM - kconnolly@pmtlawfirm.com
` DWECK, STUART MARC - Stuartdweck@aol.com
` KOOL, JONNY - jkool@quellerfisher.com
` LOMBARDI, FRANK D - flombardi@mooclaw.com
` MAIORANA, MATTHEW JOHN - mmaiorana@quellerfisher.com
` MULLANE, CHRISTOPHER JOHN - christopher.mullane@brodyoconnor.com
` SECHTER, ADAM BENJAMIN - asechter@bssnylaw.com
` SHAPIRO, SIM R. - sshapiro@bssnylaw.com
` SKELLY, JAMES M. - jmskelly@moodklaw.com
` WARYCHA, JENNIFER A - jwarycha@bssnylaw.com
`
`NOTE: If submitting a working copy of this filing to the court, you must include
`as a notification page firmly affixed thereto a copy of this Confirmation Notice.
`
`Timothy C. Idoni - http://www.westchesterclerk.com
`Email: e-file@westchestergov.com
`
`NYSCEF Resource Center - EFile@nycourts.gov
`Phone: (646) 386-3033
`Fax: (212) 401-9146 Website: www.nycourts.gov/efile
`
`Page 2 of 2
`16 of 16
`
`

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