SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ========================================== X TODD COURTNEY, Index No.: 151677/17 -against- Plaintiff, THE BOARD OF MANAGERS OF THE CHADWIN HOUSE CONDOMINIUM, THE CHADWIN DRIVEWAY ASSOCIATION, INC., THE BOARD OF MANAGERS OF THE CHADWIN HOUSE CONDOMINIUM GARAGE, MARK GREENBERG REAL ESTATE CO. INC., MARK GREENBERG REAL ESTATE CO. LLC, JAMES GOLDSTICK, INFINITY CORPORATION and SAM KOUBTI, Defendants. ========================================== X RESPONSE TO PRELIMINARY CONFERENCE ORDER PLEASE TAKE NOTICE, that plaintiff TODD COURTNEY ( Mr. Courtney ), by his attorneys, THE LAW OFFICE OF AARON M. SCHLOSSBERG, ESQ., P.L.L.C., to the extent not already provided, hereby responds to the Preliminary Conference Order, dated January 9, 2018, and respectfully submits the following: WITNESSES 1. In addition to witness information previously exchanged and produced in this matter, Mr. Courtney is currently aware of the following responsive witnesses. Mr. Courtney reserves his right to supplement and/or amend this response up to and including the time of trial of this action. EYE WITNESSES A. James Goldstick B. Sam Koubti The Chadwin House
C. John Tarmontano First Republic Bank D. Richard Page E. Carlos Delgado F. Carlos Coste The Chadwin House Maintenance Employee G. Sal Hermidan H. Each and every additional Chadwin House employee from the date of April 2011 through and including the I. Each and every Member of the Board of Managers of the Chadwin House Condominium from the date of April 2011 through and including the J. Each and every Member of the Board of Managers of the Chadwin House Condominium Garage from the date of April 2011 through and including the K. Each and every Chadwin House residents from the date of April 2011 through and including the
L. Each and every Member and/or employee of the Chadwin Driveway Association, Inc. from the date of April 2011 through and including the M. Robert T. Holland Belkin Burden Wenig & Goldman, LLP 270 Madison Ave N. Barry G. Margolis Abrams Garfinkel Margolis Bergson, LLC 1430 Broadway, 17 th Floor New York, New York 10018 O. David Richman Mark Greenberg Real Estate Co. LLC P. Each and every additional employee of Mark Greenberg Real Estate Co. LLC from Q. Each and every employee of Mark Greenberg Real Estate Co. Inc. from R. Each and every employee of Infinity Corporation from the date of April 2011 through and including the S. Each and every Member of the Board of Charles H. Greenthal Corp. from T. Each and every employee of Charles H. Greenthal Corp. from
U. Doe Insurance Company(s) 1 V. Ari Teman W. Cliff Pereira, Apt. 1-S X. Margherita Aloi Pereria, Apt. 1-S NOTICE WITNESSES A. James Goldstick B. Sam Koubti The Chadwin House C. John Tarmontano First Republic Bank D. Richard Page E. Carlos Delgado F. Carlos Coste The Chadwin House Maintenance 1 Defendants are obligated to provide full insurance coverage information by February 22, 2018, and upon our receipt of same we will amend this response to name the applicable insurance companies as appropriate.
G. Sal Hermidan H. Each and every additional Chadwin House employee from the date of April 2011 through and including the I. Each and every Member of the Board of Managers of the Chadwin House Condominium from the date of April 2011 through and including the J. Each and every Member of the Board of Managers of the Chadwin House Condominium Garage from the date of April 2011 through and including the K. Each and every Chadwin House residents from the date of April 2011 through and including the L. Each and every Member and/or employee of the Chadwin Driveway Association, Inc. from the date of April 2011 through and including the M. Robert T. Holland Belkin Burden Wenig & Goldman, LLP 270 Madison Ave N. Barry G. Margolis Abrams Garfinkel Margolis Bergson, LLC 1430 Broadway, 17 th Floor New York, New York 10018 O. David Richman Mark Greenberg Real Estate Co. LLC
P. Each and every additional employee of Mark Greenberg Real Estate Co. LLC from Q. Each and every employee of Mark Greenberg Real Estate Co. Inc. from R. Each and every employee of Infinity Corporation from the date of April 2011 through and including the S. Each and every Member of the Board of Charles H. Greenthal Corp. from T. Each and every employee of Charles H. Greenthal Corp. from U. Doe Insurance Company(s) 2 V. Ari Teman W. Cliff Pereira, Apt. 1-S X. Margherita Aloi Pereria, Apt. 1-S 2 Defendants are obligated to provide full insurance coverage information by February 22, 2018, and upon our receipt of same we will amend this response to name the applicable insurance companies as appropriate.
STATEMENTS 2. In addition to those records previously exchanged and produced, please see attached Exhibit A. PHOTOGRAPHS 3. Aside from those records previously exchanged and produced, Mr. Courtney is not currently in possession of any additional responsive photographs. Mr. Courtney reserves his right to supplement and/or amend this response up to and including the time of trial of this action. PLEASE TAKE FURTHER NOTICE, that defendant Mr. Courtney reserves his right to supplement and/or amend this response up to and including the time of trial of this action. Dated: New York, New York February 6, 2018 THE LAW OFFICE OF AARON M. SCHLOSSBERG, ESQ., P.L.L.C. By: Aaron M. Schlossberg, Esq., Attorneys for Plaintiff 275 Madison Avenue, 14 th Floor (212) 878-8804 TO: ABRAMS GARFINKEL MARGOLIS BERGSON, LLP Attorneys for defendants 1430 Broadway, 17 th Floor New York, New York 10018