JAFFE & ASHER up ATTORNEYS AT LAW PLEASE RESPOND TO WHITE PLAINS OFFICE 600 THIRD AVENUE New York, NY 10016-1901 ESTABLISHED 1974 445 HAMILTON AVENUE, SUITE 405 2 | 2-68 7-3000 www.,JAFFEANDASHER.COM Wuite Piains, NY 10601 ToL. FREE 888-625-9895 TEL 212-687-3000 Fax 914-437-8076
September 15, 2022 VIA ECF Hon. Denise L. Cote, U.S.D.J. Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Liberty Insurance Corporation v. New York Marine and General] Insurance Company, American Empire Surplus Lines Insurance Company, and Hudson Excess Insurance Company Civil Action No. : 1:22-cv-01081-DLC Dear Judge Cote: Our firm represents plaintiff Liberty Insurance Corporation (“Liberty”) in the referenced matter. This letter is submitted pursuant to paragraph 2. C. of Your Honor’s Individual Practices in Civil Cases, in opposition to the letter motion filed on September 13, 2022, by defendant Hudson Excess Insurance Company (“Hudson”), seeking permission to move to quash the subpoena that Liberty served on Hudson’s insured, Skittles Service Corp. (“Skittles”). In this action, Liberty seeks recovery of co-insurance contribution from defendants for a common insured, 45 John NY LLC (“45 John”), for an underlying tort action entitled Juarez v. Primework Construction Corp.. Avacon Management LLC and 45 John NY LLC, Index Number 160728/2017, pending in New York Supreme Court, New York County (the “Underlying Action”). A key determinative issue as to whether Hudson owes coverage to 45 John is whether Hudson’s Named Insured, Skittles, “agreed in writing in a contract or agreement” to include 45 John, as a additional insured. Attached, as Exhibit “A”, is a copy of the written agreement that we believe satisfies this requirement. We attempted to authenticate this document via Notice to Admit, to no avail. We even offered to withdraw the Skittles subpoena if Hudson would stipulate to the authenticity of this document, that it was signed by Avacon and Skittles on the dates indicated, and that it applies to the project at issue. Hudson refused; as such, we need to move forward with discovery on this issue. We specifically issued the subpoena to address this issue. This deposition is not duplicative of any discovery in the Underlying Action. The individual deposed, Isaias Barrera Perez (“Barrera”), was a foreman and he was not involved in the contracts related to the Underlying Action. His testimony related to the tort issues — the
CALIFORNIA FLORIDA GEORGIA New JERSEY TEXAS
Hon. Denise L. Cote, U.S.D.J. September 15, 2022 Page 2 cause of the alleged accident. Barrera did not testify on any subject related to the key coverage issues herein. Indeed, Barrera specifically testified that he had no knowledge of the written contracts related to the job. In contrast, in this action, we seek a deposition to address insurance issues, specifically the contracts related to the job, including the exhibit annexed hereto. As such, we served the subpoena on a principal of Skittles, Araceli Rivero. A copy of the Affidavit of Service is attached hereto as Exhibit “B”. Hudson’s argument that Liberty should not be allowed to depose a different Skittles witness to testify about the contract documents because it could elicit inconsistent testimony is completely frivolous. First, Barrera could not testify about the contract because he lacked knowledge. Second, there is no rule of law preventing discovery because it may elicit inconsistent testimony. The pending summary judgment motion in the Underlying Action should not preclude or delay discovery herein. We have a discovery deadline of October 28, 2022. The motion in State Court does not stay discovery herein. Hudson’s assertion that Skittles was dissolved in 2020 is also not a legitimate reason to quash the Skittles subpoena. Even if Skittles was dissolved as a corporation in 2020, it still must respond to a subpoena concerning pre-dissolution activity. McCready v. Nat'l Credit Inc., No. 07 CIV. 7705 DAB/JCF, 2010 WL 815079 (S.D.N.Y. Mar. 9, 2010). Finally, Hudson’s application for permission to move to quash and/or any motion to quash the Skittles subpoena should be denied because it is untimely. The subpoena was returnable September 12, 2022. Pursuant to Fed. R. Civ. P. 45(d)(3), in order to be timely, a motion to quash a subpoena generally must be filed before the return date of the subpoena. In re Rule 45 Subpoena Issued To JP Morgan Chase Bank, N.A., 319 F.R.D. 132 (S.D.N.Y. 2016). For the above reasons and law, Liberty respectfully submits that Hudson’s application for permission to move to quash the Skittles subpoena should be denied. Moreover, Skittles did not appear on the date noticed in the Skittles subpoena. We received an email from counsel purporting to represent Skittles in connection with the subpoena, Jonathan Banks, Esq. Mr. Banks advised us that he was unavailable to go forward with Skittles’ deposition on the date in the subpoena and would get back to us with an adjourned date. He did not. Liberty respectfully requests that this Court direct Skittles to appear for a deposition in compliance with the subpoena. Permission for Hudson Excess Respee aysubrmutied. Insurance Company to move . to JAFFE & ASHER, LLP quash the subpoena is denied. 9/19/22 By: Went Praag Florence Langer, Esq.
DENISE COTE United States District Judge
Hon. Denise L. Cote, U.S.D.J. September 15, 2022 Page 3 FL:fl cc: William F. Stewart, Esq. (via ECF w/ exh.) Nancy Zangrilli (via ECF w/ exh.) Daniel F. McFaul, Jr., Esq. (via ECF w/ exh.) Michael Panayotou, Esq. (via ECF w/ exh.) Jonathan Banks, Esq. (via email w/ exh.)
Exhibit A SUBCONTRACT AGREEMENT RIDER (CONTRACTOR/SUBCONTRACTOR)
indemnity. in consideration of fhe Contract Agreement, and to the fullest exten! permitted by iow, the Subconirecior shall defend and shall indemnify, and hola normiess, af Subcorirociors sole exoeme, fhe Contraction ab entmes the Contracior ’s required indemnify and hoid harmiess. the Owner of tne properly. ana the officers, directors. agents. employees. successors and assians of each of from and agains! oll fablity or claimed liabiily for bodily aniury or death to any operons}, and for any and all oroperly damage or economic damage. including oll attomey fees, disbursements and relofed costs, arising out of or resulling from ine Work covered by this Contract Agreement! fo the exient such Work was performed by or contracted through the Subcontracior or by anyone for whose acts the Subcontractor moy be held fable, excluding only labmiy created by the sole and exclusive negligence of fhe Indemnified Parfles. This indemnity agreement! shat survive the compiction of the Work specified in tne Contract Agreement. 2. Insurance. The Subcontractor shall oracure ond shall maintain unfl find acceotonce of ine Work. such insurance as wil orotec! the Contractor, all entities ‘ne Caoniracior □ required Indernnily ond hold marvess, Ihe Owner, and ther officers, directors, agenis and emmioyees. for claims ansing out of or resulling from Subcontracior’s Work under this Conract Agreement’, whether oerformed by the Suocontroctor, of by anyone directly or indirechy emoloyed by Subcorniractor. or by anyone for whose acts Subcoriractar may be Hoble. Such insurance shal pe prowided by an insurance carrer rated “A-" or better py A.M. Bes! and lawfully authorized to do business in the lurisdiction where the Work is being oerformed. Si. The Subcortrvactor’s imsurarece spall mctuode contractual habity coverage ana adotional insured’ coverage for the benefit of the Contractor. Owner anc anyone else the OQwneris.rcecquired roname fas sel foriivin the schedule peiow), and shal speciicahy inciude coverage for compieica omerations.
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JAFFE & ASHER up ATTORNEYS AT LAW PLEASE RESPOND TO WHITE PLAINS OFFICE 600 THIRD AVENUE New York, NY 10016-1901 ESTABLISHED 1974 445 HAMILTON AVENUE, SUITE 405 2 | 2-68 7-3000 www.,JAFFEANDASHER.COM Wuite Piains, NY 10601 ToL. FREE 888-625-9895 TEL 212-687-3000 Fax 914-437-8076
September 15, 2022 VIA ECF Hon. Denise L. Cote, U.S.D.J. Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Liberty Insurance Corporation v. New York Marine and General] Insurance Company, American Empire Surplus Lines Insurance Company, and Hudson Excess Insurance Company Civil Action No. : 1:22-cv-01081-DLC Dear Judge Cote: Our firm represents plaintiff Liberty Insurance Corporation (“Liberty”) in the referenced matter. This letter is submitted pursuant to paragraph 2. C. of Your Honor’s Individual Practices in Civil Cases, in opposition to the letter motion filed on September 13, 2022, by defendant Hudson Excess Insurance Company (“Hudson”), seeking permission to move to quash the subpoena that Liberty served on Hudson’s insured, Skittles Service Corp. (“Skittles”). In this action, Liberty seeks recovery of co-insurance contribution from defendants for a common insured, 45 John NY LLC (“45 John”), for an underlying tort action entitled Juarez v. Primework Construction Corp.. Avacon Management LLC and 45 John NY LLC, Index Number 160728/2017, pending in New York Supreme Court, New York County (the “Underlying Action”). A key determinative issue as to whether Hudson owes coverage to 45 John is whether Hudson’s Named Insured, Skittles, “agreed in writing in a contract or agreement” to include 45 John, as a additional insured. Attached, as Exhibit “A”, is a copy of the written agreement that we believe satisfies this requirement. We attempted to authenticate this document via Notice to Admit, to no avail. We even offered to withdraw the Skittles subpoena if Hudson would stipulate to the authenticity of this document, that it was signed by Avacon and Skittles on the dates indicated, and that it applies to the project at issue. Hudson refused; as such, we need to move forward with discovery on this issue. We specifically issued the subpoena to address this issue. This deposition is not duplicative of any discovery in the Underlying Action. The individual deposed, Isaias Barrera Perez (“Barrera”), was a foreman and he was not involved in the contracts related to the Underlying Action. His testimony related to the tort issues — the
CALIFORNIA FLORIDA GEORGIA New JERSEY TEXAS
Hon. Denise L. Cote, U.S.D.J. September 15, 2022 Page 2 cause of the alleged accident. Barrera did not testify on any subject related to the key coverage issues herein. Indeed, Barrera specifically testified that he had no knowledge of the written contracts related to the job. In contrast, in this action, we seek a deposition to address insurance issues, specifically the contracts related to the job, including the exhibit annexed hereto. As such, we served the subpoena on a principal of Skittles, Araceli Rivero. A copy of the Affidavit of Service is attached hereto as Exhibit “B”. Hudson’s argument that Liberty should not be allowed to depose a different Skittles witness to testify about the contract documents because it could elicit inconsistent testimony is completely frivolous. First, Barrera could not testify about the contract because he lacked knowledge. Second, there is no rule of law preventing discovery because it may elicit inconsistent testimony. The pending summary judgment motion in the Underlying Action should not preclude or delay discovery herein. We have a discovery deadline of October 28, 2022. The motion in State Court does not stay discovery herein. Hudson’s assertion that Skittles was dissolved in 2020 is also not a legitimate reason to quash the Skittles subpoena. Even if Skittles was dissolved as a corporation in 2020, it still must respond to a subpoena concerning pre-dissolution activity. McCready v. Nat'l Credit Inc., No. 07 CIV. 7705 DAB/JCF, 2010 WL 815079 (S.D.N.Y. Mar. 9, 2010). Finally, Hudson’s application for permission to move to quash and/or any motion to quash the Skittles subpoena should be denied because it is untimely. The subpoena was returnable September 12, 2022. Pursuant to Fed. R. Civ. P. 45(d)(3), in order to be timely, a motion to quash a subpoena generally must be filed before the return date of the subpoena. In re Rule 45 Subpoena Issued To JP Morgan Chase Bank, N.A., 319 F.R.D. 132 (S.D.N.Y. 2016). For the above reasons and law, Liberty respectfully submits that Hudson’s application for permission to move to quash the Skittles subpoena should be denied. Moreover, Skittles did not appear on the date noticed in the Skittles subpoena. We received an email from counsel purporting to represent Skittles in connection with the subpoena, Jonathan Banks, Esq. Mr. Banks advised us that he was unavailable to go forward with Skittles’ deposition on the date in the subpoena and would get back to us with an adjourned date. He did not. Liberty respectfully requests that this Court direct Skittles to appear for a deposition in compliance with the subpoena. Permission for Hudson Excess Respee aysubrmutied. Insurance Company to move . to JAFFE & ASHER, LLP quash the subpoena is denied. 9/19/22 By: Went Praag Florence Langer, Esq.
DENISE COTE United States District Judge
Hon. Denise L. Cote, U.S.D.J. September 15, 2022 Page 3 FL:fl cc: William F. Stewart, Esq. (via ECF w/ exh.) Nancy Zangrilli (via ECF w/ exh.) Daniel F. McFaul, Jr., Esq. (via ECF w/ exh.) Michael Panayotou, Esq. (via ECF w/ exh.) Jonathan Banks, Esq. (via email w/ exh.)
Exhibit A SUBCONTRACT AGREEMENT RIDER (CONTRACTOR/SUBCONTRACTOR)
indemnity. in consideration of fhe Contract Agreement, and to the fullest exten! permitted by iow, the Subconirecior shall defend and shall indemnify, and hola normiess, af Subcorirociors sole exoeme, fhe Contraction ab entmes the Contracior ’s required indemnify and hoid harmiess. the Owner of tne properly. ana the officers, directors. agents. employees. successors and assians of each of from and agains! oll fablity or claimed liabiily for bodily aniury or death to any operons}, and for any and all oroperly damage or economic damage. including oll attomey fees, disbursements and relofed costs, arising out of or resulling from ine Work covered by this Contract Agreement! fo the exient such Work was performed by or contracted through the Subcontracior or by anyone for whose acts the Subcontractor moy be held fable, excluding only labmiy created by the sole and exclusive negligence of fhe Indemnified Parfles. This indemnity agreement! shat survive the compiction of the Work specified in tne Contract Agreement. 2. Insurance. The Subcontractor shall oracure ond shall maintain unfl find acceotonce of ine Work. such insurance as wil orotec! the Contractor, all entities ‘ne Caoniracior □ required Indernnily ond hold marvess, Ihe Owner, and ther officers, directors, agenis and emmioyees. for claims ansing out of or resulling from Subcontracior’s Work under this Conract Agreement’, whether oerformed by the Suocontroctor, of by anyone directly or indirechy emoloyed by Subcorniractor. or by anyone for whose acts Subcoriractar may be Hoble. Such insurance shal pe prowided by an insurance carrer rated “A-" or better py A.M. Bes! and lawfully authorized to do business in the lurisdiction where the Work is being oerformed. Si. The Subcortrvactor’s imsurarece spall mctuode contractual habity coverage ana adotional insured’ coverage for the benefit of the Contractor. Owner anc anyone else the OQwneris.rcecquired roname fas sel foriivin the schedule peiow), and shal speciicahy inciude coverage for compieica omerations. ine msurance requred fo be caried by fhe Supcontacior and any Suso-Sub- Contractors shall be PRIMARY AND NON-CONTRIBLITORY. With recnect to each 'yoe of insurance weqched herounder, the Cantraciors and Owner's SSurorkces shot DG excess to Subcontractors meurance. 22. Tee Subcontractor worants tmah the coverage orowded uncer the cormmenngal qenerai naoaty ooscy smal be writen on an “occurence” oasis with coverage as brood as ine insurance Service Office inc.’s form and that AO OOicCy provisions sali resinici, rechece, limit or otherwise imoar contractual hamlly coverage or the Contractor's. Owners lor olners as required and as asiea below} satus as addifional insured,
FA Not less fron five (S) doys oeorio curmencemen! of tne Work and unt hina gececgiance of fhe Work, Subcontractor shall prowide Conkactor wih certificate(s) of insurance evidencing the required imurance coverage wir tho limits stated below or Gsewhere in ine Subcomiract documents. The Subcontractor smah orovide Contractor thirty (30) dave writen nofce of a change of cancellahon in coverage. in addon. ai insurance policies smal state that the insurer wit orovide Contractor thirty (20) days poor written nohce of a Change or canceliaton in coverage. 24, Unless oinervse shmsated in the Conlroct Agreement, fhe Subcontracior snail mrainiain ma jess than the iimits smecihed for cach of the following insurance COVerIges: oi Commerca General Liobify usmag an industry standard unmodited coverage form imciuding contractual liability vin minimum iimils of $1,000,000 each ccecvrence. $2,000,000 aggregate and $2,000,000 Products completed operations aagregate with either per orolect or per rocation endonement for property Garnaqge and bodily injury: 0) 0 6
a) Umbrella Uabity Insurance with a iv of $1,000,000 per occurrence and general aggregate of $1,000,060. Scaffolding, demolition. ano excavation conmractors require Umbrelia Uability Insurance with o amit of $2,000,000 oer Occurence and general aggregate of $2,000,000.
2.9. The Subcontractor and his insurer shail waive ail rights of subrogation egainst the Contractor, Owner and any other indemnified party, excep? asrespecs Workers Compensation insurance. 2.6 Supcorractor engages oa SubSubcontractor, it is the ofirmative duty of the Suncontractor in ensure that any Sub Subcontractor complies with whe insurance ard indemnification reavremenis of this Cortract Agreemen.
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i □□ □□ CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. | DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLIC THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORI OR PRODUCER, AND THE CERTIFICATE HOLDER. “ORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. If SUBROGATION IS WAIVED, subje terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to holder in lieu of such endorsement(s). Nowe’ KATHERINE HUNG □ GENERAL AGENCY, INC. PHONE ext), (718) 283-4068 Noy, □□□□□ 747-848; 204 BAYSIDE AVE STE 10UA EMAIL... INFO@JEMINSURE.COM INSURER{S) AFFORDING COVERAGE NAIC NY 11354-2331 | wsurera; HUDSON EXCESS INSURANCE COMPANY 1448 INSURER B; ACE PROPERTY & CASUALTY INSURANCE CO 206! SKITTLES SERVICES CORP IwsURERC: NEW YORK STATE INSURANCE FUND iNsuRERO: STANDARD SECURITY LIFE INSURANCE | 69037 377 SHARON AVE STATEN ISLAND NY 10301-1414 [insurere- CERTIFICATE NUMBER: REVISION NUMBER: ARAL NALA UTS ARIAL □□ TT SDC SERIO NAS tt □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ HIS 1S TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PER NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH 1 MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN:IS SUBJECT TO ALL THE TER AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS, _tvreormsurance [Ngo wve|_———sPOUCY NBER ____[ money | aameerr LINATS [>< | COMMERCIAL GENERAL LIABILITY gs 1,000,000 |_|} camsmace occur PREMISES (ea occurrence) | $ 50,000 i MED EXP (Anyone person) | $ 5,000 Y | Y | HXMP100996 05/08/2017 | 05/08/2018 s 1,000,000 AGGREGATE LIMIT APPLIES PER: □□□□□□□□□ X)roucr!}88 [ive | | Fers: coe nas | □□□□□ □□ OTHER: TS AUTONOSLELABLTY eens [—) sgigguen | [BODicy HUY easier] | {aid pees i umereniauiae [XT occur | s_1,000,000 |_| cLaims.mape| Y | Y | UMBNYD390945512 05/08/2017 | 05/08/2018 □□ 1,000,000 [rerennons ps WORKERS COMPENSATION bekrure |< OTH- AND EMPLOYERS" LIABILITY YIN |__| Sxrure ee □ □□□□□□□ Or SR EXECUTIVE NIA | 23119662 11/06/2016 | 11/06/2017 □□□ | | [ex osease en cuPioved □ 1,000,000 OF OPERATIONS below E.L. DISEASE - Poticy Limit. 7,000,000
BENEFITS | | 1R72493-000 | 41/06/2016 | 11/06/2017 |STATUTORY | OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached If more space is required) itional insured: Avacon Management LLC DBA Avacon Builders 345 Route 17 South Upper Saddle River, NJ 07458; 45 John NY LLC 150 Broadway, Su New York, NY 10038
HOLDER CANCELLATION SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFO! Management LLC DBA Avacon Builders THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED 17 South ACCORDANCE WITH THE POLICY PROVISIONS. r Saddle River, NJ 07458 AUTHORIZED REPRESENTATIVE
© 1988-2014 ACORD CORPORATION. All rights □□□□□□□ RD 25 (2014/04) The ACARNT nama and lann are □□□□□□□□□□□□□□□□□□□□□□ nt APADL
Exhibit B UNITED STATES DISTRICT COURT FOR THE index Number: 1:22-CV-01081(DLC) SOUTHERN DISTRICT OF NEW YORK Court Date: 09/12/2022 LIBERTY INSURANCE CORPORATION Plaintiff vs NEW YORK MARINE AND GENERAL INSURANCE COMPANY ET AL
Defendant OF NEW YORK, COUNTY OF RICHMOND, SS.: AFFIDAVIT OF SERVICE Joseph P.F. Donovan __, being sworn deposes and states that, the Deponent is not a party herein, is over the age of years and resides in the State of New York. on 9/1/2022, at 6:29 PM at 377 SHARON AVENUE APT 2F, STATEN ISLAND, NY 10301, Deponent served the within Subpoena to at a Deposition in a Civil Action . On: SKITTLES SERVICES CORP , Witness therein named, ( hereinafter referred to as subject").
delivering to and leaving with Araceli Rivero said individual to be President who specifically stated he/she was authorized to accept on behalf of the Corporation/Government Agency/Entity. A description of Araceli Rivero is as follows:
Sex: Female Color skin: Brown Color of hair: Gray Age: 55 Height: 5ft0in-5ft3in Weight: 100-130 Lbs. Other : glasses
to before me on September 2, 2022 _2 me TF Nee ara Donovan ‘<> v3 rs a : "Process Server, Please Sign Notary Public - State of New York bre te Joseph P.F. Donovan No. 01006210234 alee Qualified in Richmond County fay rh Lic# 4292936 My Commission Expires 08-10-2025 Client’s File No.: 2230602 Job #: 2228871 ALEXANDER POOLE & COMPANY, INC! SERVICE DISTRIBUTED BY INTER COUNTY JUDICIAL SERVICES LLC, 685] JERICHO TURNPIKE, Suite 180, Syosset NY (1791 LICENSE # 1371771