Preview
FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
DESIREE BRADLEY, Index No. 508504/2023
Plaintiff,
-against- RESPONSE TO NOTICE
OF DISCOVERY &
INSPECTION and
2701 PROPERTY OWNER LLC, COMBINED DEMANDS
NEPTUNE MECHANICAL, INC., and JOHN DOE.,
Defendants.
---------------------------------------------------------------------X
COUNSELORS:
PLEASE TAKE NOTICE THAT defendant, NEPTUNE MECHANICAL, INC., herein
after (“Defendant”) by its attorneys THE LAW OFFICE OF KEVIN P. WESTERMAN, 990
Stewart Avenue, Suite 400, New York 11530 in response to plaintiff’s Notice of Discovery &
Inspection and Combined Demands dated November 9, 2023, sets forth the following upon
information and belief:
AS TO ALL CONTRACTS PF INSURANCE
1. Enclosed as Exhibit “A” is a copy of the policies and/or dec sheets in our possession.
AS TO ALL LIABILITY POLICES
2. Upon information and belief, responding defendant, NEPTUNE MECHANICAL, INC.,
was insured by Nationwide/Harleysville Insurance Company in the amount of $2,000,000
per occurrence and $4,000,000 general aggregate under policy number GL0000003210BN
from February 3, 2022 through February 3, 2023.
AS TO EXCESS OR UMBRELLA INSURANCE
3. NEPTUNE MECHANICAL, INC., was covered in Excess by Nationwide/Harleysville
Insurance Company from February 3, 2022 through February 3, 2023 under policy number
CMB0000003211BN in the amount of $3,000,000.
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AS PLAINTIFF’S STATEMENTS
4. Responding defendant does not have any statements made by plaintiff, DESIREE
BRADLEY, or her representatives with regards to the incident alleged in plaintiffs’
complaint.
AS TO WRITTEN ACCIDENT REPORTS
5. Enclosed as Exhibit “B” is the incident/accident report in our possession.
AS TO NAMES OF WITNESS
6. Responding defendant is not aware of any witnesses to the incident alleged in plaintiffs’
complaint except those identified during the course of this litigation.
AS TO PHOTOS OF SCENE
7. Responding defendant does not have any photographs or surveillance material depicting
the scene/location of plaintiffs alleged incident or of the plaintiff or plaintiffs’ injuries with
regards to the incident alleged in the complaint.
AS TO ALL PHOTOGRAPHS, VIDEO TAPES AND/OR OTHER VISUAL
REPRODUCITONS
8. See response to number (7) above.
AS TO OTHER LAWSUITS
9. Responding defendant objects to this demand as overbroad, unduly burdensome, not likely
to lead to related discovery and not tailored in content or scope. Notwithstanding the
aforementioned objection, responding defendant is not aware of nor do they have access to
any other lawsuits arising out of the incident alleged in plaintiffs’ complaint.
AS TO PRIOR TESTIMONY
10. Responding defendant does not have any documents or information responsive to this
demand.
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AS TO DEMAND FOR DOCUMENTS
11. To be provided under separate cover.
12. Responding defendant does not have any documents or information responsive to this
demand.
13. Enclosed as Exhibit “C” is a copy of the contract in our possession.
14. See response to number (13) above.
15. Responding defendant does not have any documents or information responsive to this
demand.
16. Responding defendant does not have any documents or information responsive to this
demand.
17. Responding defendant does not have any documents or information responsive to this
demand.
18. Responding defendant does not have any documents or information responsive to this
demand.
19. Responding defendant does not have any documents or information responsive to this
demand.
20. Responding defendant does not have any documents or information responsive to this
demand. We are awaiting medical records from authorizations that were recently
processed.
21. Responding defendant does not have any documents or information responsive to this
demand.
22. See response to number (13) above.
23. See response to number (5) above.
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24. Responding defendant does not have any documents or information responsive to this
demand.
25. Responding defendant does not have any documents or information responsive to this
demand.
26. Responding defendant does not have any documents or information responsive to this
demand.
27. Responding defendant does not have any documents or information responsive to this
demand.
28. Responding defendant objects to this demand as overbroad, unduly burdensome, not likely
to lead to related discovery and not tailored in content or scope. Notwithstanding the
aforementioned objection, responding defendant is not aware of nor do they have access to
any written complaints arising out of the incident alleged in plaintiffs’ complaint.
29. Responding defendant does not have any documents or information responsive to this
demand.
30. Responding defendant does not have any documents or information responsive to this
demand.
a-g)Responding defendant has not designated any experts to give testimony on their behalf,
however, defendant reserves the right pursuant to the CPLR 3101(d), to retain said liability
and medical expert(s) and conducting independent medical examination(s). Defendant also
reserves the right to call any and all doctors that treated or examined the plaintiff as expert
witnesses at the time of trial. Responding defendant will not waive plaintiff’s independent
medical examination(s).
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PLEASE TAKE FURTHER NOTICE that defendant, NEPTUNE MECHANICAL,
INC., expressly reserves the right to supplement or amend this response up to the time of the trial
of this action.
Dated: Garden City, New York
December 8, 2023
Yours, etc.,
THE LAW OFFICES OF KEVIN P.
WESTERMAN
By:
_____________________
AUSTIN P. MURPHY, Jr.
Attorneys for Defendant
NEPTUNE MECHANICAL, INC.
990 Stewart Avenue – Suite 400
Garden City NY 11530
(516) 493 – 4501
File No.: 23-005643
MURPHA29@nationwide.com
TO: Shahar Azoulay, Esq.
LAW OFFICE OF MICHAEL S. LAMONSOFF
Attorneys for Plaintiff
32 Old Slip – 8th Floor
New York, NY 10005
(212) 962-1020
File No.: 33814
sazoulay@msllegal.com
John T. Kalin, Esq.
PILLINGER MILLER TARALLO, LLP
555 Taxter Road, 5th Floor
Elmsford, NY 10523
(914) 703-6300
File No.: D-NATCL-00297/JTK
jkalin@pmtlawfirm.com
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
Exhibit A
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
COMMERCIAL LINES COMMON POLICY DECLARATIONS
Named Insured and Mailing Address: Agent:
Neptune Mechanical Inc ARTHUR J GALLAGHER RISK MNGT SERV
29 10 120th Street 1 JERICHO PLAZA SUITE 200
Flushing, NY 11354 JERICHO, NY 11753
Agency Code: 743595
Phone Number: (800)234-8367
Policy Period: 02/03/2022 to 02/03/2023 at 12:01 A.M. Standard Time at your mailing address
shown above.
Business Description: Form of Business:
Commercial Plumbing Contractor CORPORATION
IN RETURN FOR THE PAYMENT OF THE PREMIUM, AND SUBJECT TO ALL THE TERMS OF THIS POLICY,
WE AGREE WITH YOU TO PROVIDE THE INSURANCE AS STATED IN THIS POLICY. IF YOU REQUEST
CANCELLATION OF THIS POLICY, THE COMPANY WILL RETAIN A MINIMUM PREMIUM OF $
THIS POLICY CONSISTS OF THE FOLLOWING COVERAGE PARTS FOR WHICH A PREMIUM IS
INDICATED. THIS PREMIUM MAY BE SUBJECT TO ADJUSTMENT.
Coverage Part Premium
Commercial Property Coverage Part
Commercial General Liability Coverage Part
Crime and Fidelity Policy Coverage Part
Commercial Inland Marine Coverage Part
Commercial Auto Coverage Part
Commercial Liability Umbrella Policy
Sub-Total
Fees and Surcharge – See Schedule GU-7015 (If Applicable)
Total
FORM(S) AND ENDORSEMENT(S) MADE A PART OF THIS POLICY:
SEE SCHEDULES GU-7004 and GU-7009
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
GU-7000 (Ed. 4-16) Includes copyrighted material of Insurance Services Office with its permission. Page: 1 of 1
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
DECLARATIONS PAGE EXTENSION - IMPORTANT INFORMATION
NEW YORK NOTICE AND DISCLOSURE ADDENDUM - EMPLOYEE BENEFITS LIABILITY COVERAGE
THIS NOTICE AND DISCLOSURE ADDENDUM APPLIES TO EMPLOYEE BENEFITS LIABILITY
COVERAGE AND IS ATTACHED TO AND MADE A PART OF THE DECLARATIONS OF THE POLICY.
NOTICE:
1. This endorsement is written on a claims-made basis. This endorsement applies only to damage
arising out of an act, error, or omission in the "administration" of your "Employee Benefit
Program", between the the retroactive date, if any, shown in the schedule of this endorsement
and the end of policy period.
2. This endorsement applies only to claims made against the insured after the inception date and
before the end of the policy period and all coverage under this endorsement ceases upon termination
of this endorsement, except for the automatic basic extended reporting period, unless you purchase
the supplemental extended reporting period coverage.
3. Claims submitted after the extended reporting period terminates will not be covered and the
insured may have coverage gaps.
4. A basic extended reporting period is automatically provided without additional charge. This
period starts with the end of the policy period and lasts for a period of sixty (60) calendar days.
5. A supplemental extended reporting period for one (1) year is available, but only by endorsement
and for an additional charge. The supplemental extended reporting period starts at the end of the
policy period. The additional premium for the supplemental extended reporting period shall be 75%
of the annual premium for this Employee Benefits endorsement.
6. During the first several years of the claims made relationship, claims made rates are
comparatively lower than occurrence rates. The insured can expect substantial annual premium
increases, independent of overall rate level increases, until the claims made relationship reaches
maturity.
GU-7013 (Ed. 4-09) Page 1 of 1
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
LOCATION SCHEDULE
Premises Bldg.
No. No. Address
001 ALL 29 10 120th Street
Flushing, NY 11354
002 ALL 28 35 119th Street
Flushing, NY 11354
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
GU-7005 (Ed. 4-16) Page 1 of 1
Issued: 01/11/2022
9 of 119
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
NAMED INSURED SCHEDULE
Neptune Mechanical, LLC
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
GU-7008 (Ed. 4-16) Page 1 of 1
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
FORM SCHEDULE
* INDICATES A NEW OR REPLACEMENT FORM. RETAIN THESE AND LISTED FORMS NOT REPLACED
Form Edition Description
POLICY FORMS
PJ0004 0416 Policy Jacket- HPIC
* GU7005 0416 Location Schedule
* GU7008 0416 Named Insured Schedule
GU7013 0409 Declaration Page Extension
IL0003 0702 Calculation of Premium
IL0017 1198 Common Policy Conditions
IL0023 0702 Nuclear Energy Liability Exclusion Endorsement
IL0185 0702 New York Changes - Calculation of Premium
IL0268 0114 New York Changes - Cancellation and Nonrenewal
* IL0985 0115 Disclosure Pursuant to Terrorism Risk Insurance Act
* IL7185 0910 Notice of Canc and Nonren for Designated Person or Org
LIABILITY FORMS
CG0001 1207 Commercial General Liability Coverage Form
CG0068 0509 Recording/Distr Matl or Info in Violation of Law Exc
CG0104 1204 New York Changes - Premium Audit
CG0163 0711 New York Changes-Commercial General Liability Cov Form
* CG0300 0196 Deductible Liability Insurance
* CG2012 0509 Addl Ins - State or Political Subdivisions - Permits
* CG2026 0704 Addl Ins - Designated Person or Organization
CG2106 0514 Exclusion-Access Or Disclosure Of Info-With Limited BI
CG2147 1207 Employment-Related Practices Exclusion
CG2170 0115 Cap on Losses from Certified Acts of Terrorism
* CG2426 0704 Amendment of Insured Contract Definition
CG2621 1091 NY Changes-Transfer of Duties When Limit is Used Up
CG7195 1210 Exclusion - Computer-Related/Other Electronic Problems
CG7209 0901 Lead Liability Exclusion - New York
CG7304 1210 Exclusion - Silica - New York
CG7305 1210 Exclusion - Asbestos - New York
CG7342 1109 Blanket AI-Engineers, Arch or Surveyors Not Engaged NY
CG7345 1109 Blanket AI-Lessor of Leased Equip -Automatic Status NY
CG7347 0710 Blanket Locations Separate General Aggregate Limit
CG7350 0710 Exclusion -Contractors Professional Liability
* CG7351 0710 Employee Benefits Liability - New York
CG7357 1210 General Liability Enhancement Plus Endt-Contractors-NY
CG7365 0812 CG7365-Blanket Additional Insured-Permits
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
GU-7004 (Ed. 4-16) Page 1 of 2
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
FORM SCHEDULE
* INDICATES A NEW OR REPLACEMENT FORM. RETAIN THESE AND LISTED FORMS NOT REPLACED
Form Edition Description
CG7383 1111 Excl-Blanket Ops Covered By A Cons Wrap-Up Ins Prog
CG7430 0117 Def of Occurrence Amendatory Endt Constr Defects
* CG8007 1015 Data Compromise Coverage - New York
CG8012 1015 Identity Recovery Coverage - New York
IL7115 0600 Excl-Exterior Insulation and Finish Systems (EIFS)
* MANU1 0704 Manuscript Endorsement
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
GU-7004 (Ed. 4-16) Page 2 of 2
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
POLICYHOLDER NOTICE SCHEDULE
The following material contains important information about your policy. Please read it carefully.
ALL FORMS ARE ATTACHED. RETAIN UNLESS DELETED OR REPLACED. * INDICATES A NEW OR REPLACEMENT FORM.
Form Edition Description
POLICY FORMS
ST7115 0416 Premium Audit Notice
ST7520 0704 Amendment Of Insured Contract Definition
ST7653 0416 Contractor and Property Owners Best Practices
ST7687 0121 Notice to Policyholders
ST7851 1114 Notice to Policyholders - Be Prepared For Data Breach
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
GU-7009 (Ed. 4-16) Page 1 of 1
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
COMMERCIAL GENERAL LIABILITY COVERAGE PART DECLARATIONS
See Supplemental Schedule
LIMITS OF INSURANCE:
$ 2,000,000 Each Occurrence Limit
$ 100,000 Damage to Premises Rented to You Limit
$ 5,000 Medical Expense Limit (Any One Person)
$ 2,000,000 Personal and Advertising Injury Limit (Any One Person or Organization)
$ 4,000,000 General Aggregate Limit (Other than Products-Completed Operations)
$ 4,000,000 Products/Completed Operations Aggregate Limit
FORM OF BUSINESS: CORPORATION
Business Description: Commercial Plumbing Contractor
Location of All Premises You Own, Rent or Occupy: SEE SCHEDULE GU-7005
AUDIT PERIOD, ANNUAL, UNLESS OTHERWISE STATED:
Rates Advance Premiums
Classifications Code No. Premium Basis Prem./ Ops. Prod./ Comp.Ops Prem./ Ops. Prod./ Comp. Ops.
SEE SCHEDULE CG-7275
TOTAL PREMIUM FOR THIS COVERAGE PART:
FORM(S) AND ENDORSEMENT(S) APPLICABLE TO THIS COVERAGE PART:
SEE SCHEDULES GU-7004 AND GU-7009
_____________________
01/11/2022 __________________________________________
ARTHUR J GALLAGHER RISK MNGT SERV
Countersignature Date Authorized Representative
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
CG-7274 (Ed. 4-16) Page 1 of 1
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
COMMERCIAL GENERAL LIABILITY COVERAGE PART
SUPPLEMENTARY SCHEDULE
Rates Advance Premiums
Premium Prem./ Prod./ Prem./ Prod./
Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops.
BOILER INSPECT/INSTALL/CLEAN
PAYROLL
CONTR-EXECUTIVE SUPERVISOR
Prod/Comp Op subj to PAYROLL
Gen Agg Limit
CONTR-SUB-REPAIR-N/BLDG-NOC
TOTAL COST
FIRE SUPPRESSION SYSTEM-INSTAL
PAYROLL
HEAT EQUIP DEAL-INSTALL-N/LPG
PAYROLL
PLUMBING-COMMERCIAL/INDUSTRIAL
PAYROLL
PLUMBING-RESIDENTIAL/DOMESTIC
PAYROLL
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
CG-7275 (Ed. 4-16) Page 1 of 22
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Insured: Policy Number:
Agent: Policy Period:
COMMERCIAL GENERAL LIABILITY COVERAGE PART
SUPPLEMENTARY SCHEDULE
Rates Advance Premiums
Premium Prem./ Prod./ Prem./ Prod./
Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops.
PREM NO. 002
HEAT EQUIP DEAL-INSTALL-N/LPG 95647 IF ANY
DATA COMPROMISE/IDENTITY RECOVERY IF ANY
BLANKET LOCATIONS SEPARATE GEN AGG LIMIT IF ANY
CG7342-BLANKET ADDL INS-ENGN/ARCHIT/SURV IF ANY
CG7345-BLANKET ADDL LESSR/EQUIP/AUTO IF ANY
GL ENHANCEMENT PLUS ENDT CONTRACTORS IF ANY
EMPLOYEE BENEFITS LIABILITY
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Natio
CG-7275 (Ed. 4-16) Page 2 of 22
Issued:
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FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
COMMERCIAL GENERAL LIABILITY COVERAGE PART
SUPPLEMENTARY SCHEDULE
Rates Advance Premiums
Premium Prem./ Prod./ Prem./ Prod./
Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops.
MANUAL PREMIUM - FULLY EARNED
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUAL PREMIUM - FULLY EARNED
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
CG-7275 (Ed. 4-16) Page 3 of 22
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
COMMERCIAL GENERAL LIABILITY COVERAGE PART
SUPPLEMENTARY SCHEDULE
Rates Advance Premiums
Premium Prem./ Prod./ Prem./ Prod./
Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops.
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUAL PREMIUM - FULLY EARNED
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
CG-7275 (Ed. 4-16) Page 4 of 22
Issued: 01/11/2022
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NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023
GL0000003210BN
Harleysville Preferred Insurance Company
One West Nationwide Blvd.
Columbus, OH 43215
Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN
Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023
RENEWAL CERTIFICATE
COMMERCIAL GENERAL LIABILITY COVERAGE PART
SUPPLEMENTARY SCHEDULE
Rates Advance Premiums
Premium Prem./ Prod./ Prem./ Prod./
Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops.
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
MANUAL PREMIUM - FULLY EARNED
MANUSCRIPT ENDORSEMENT IF ANY
MANUSCRIPT ENDORSEMENT IF ANY
Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide
CG-7275 (Ed. 4-16) Page 5 of 22
Issued: 01/11/2022
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FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------------X DESIREE BRADLEY, Index No. 508504/2023 Plaintiff, -against- RESPONSE TO NOTICE OF DISCOVERY & INSPECTION and 2701 PROPERTY OWNER LLC, COMBINED DEMANDS NEPTUNE MECHANICAL, INC., and JOHN DOE., Defendants. ---------------------------------------------------------------------X COUNSELORS: PLEASE TAKE NOTICE THAT defendant, NEPTUNE MECHANICAL, INC., herein after (“Defendant”) by its attorneys THE LAW OFFICE OF KEVIN P. WESTERMAN, 990 Stewart Avenue, Suite 400, New York 11530 in response to plaintiff’s Notice of Discovery & Inspection and Combined Demands dated November 9, 2023, sets forth the following upon information and belief: AS TO ALL CONTRACTS PF INSURANCE 1. Enclosed as Exhibit “A” is a copy of the policies and/or dec sheets in our possession. AS TO ALL LIABILITY POLICES 2. Upon information and belief, responding defendant, NEPTUNE MECHANICAL, INC., was insured by Nationwide/Harleysville Insurance Company in the amount of $2,000,000 per occurrence and $4,000,000 general aggregate under policy number GL0000003210BN from February 3, 2022 through February 3, 2023. AS TO EXCESS OR UMBRELLA INSURANCE 3. NEPTUNE MECHANICAL, INC., was covered in Excess by Nationwide/Harleysville Insurance Company from February 3, 2022 through February 3, 2023 under policy number CMB0000003211BN in the amount of $3,000,000. 1 1 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 AS PLAINTIFF’S STATEMENTS 4. Responding defendant does not have any statements made by plaintiff, DESIREE BRADLEY, or her representatives with regards to the incident alleged in plaintiffs’ complaint. AS TO WRITTEN ACCIDENT REPORTS 5. Enclosed as Exhibit “B” is the incident/accident report in our possession. AS TO NAMES OF WITNESS 6. Responding defendant is not aware of any witnesses to the incident alleged in plaintiffs’ complaint except those identified during the course of this litigation. AS TO PHOTOS OF SCENE 7. Responding defendant does not have any photographs or surveillance material depicting the scene/location of plaintiffs alleged incident or of the plaintiff or plaintiffs’ injuries with regards to the incident alleged in the complaint. AS TO ALL PHOTOGRAPHS, VIDEO TAPES AND/OR OTHER VISUAL REPRODUCITONS 8. See response to number (7) above. AS TO OTHER LAWSUITS 9. Responding defendant objects to this demand as overbroad, unduly burdensome, not likely to lead to related discovery and not tailored in content or scope. Notwithstanding the aforementioned objection, responding defendant is not aware of nor do they have access to any other lawsuits arising out of the incident alleged in plaintiffs’ complaint. AS TO PRIOR TESTIMONY 10. Responding defendant does not have any documents or information responsive to this demand. 2 2 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 AS TO DEMAND FOR DOCUMENTS 11. To be provided under separate cover. 12. Responding defendant does not have any documents or information responsive to this demand. 13. Enclosed as Exhibit “C” is a copy of the contract in our possession. 14. See response to number (13) above. 15. Responding defendant does not have any documents or information responsive to this demand. 16. Responding defendant does not have any documents or information responsive to this demand. 17. Responding defendant does not have any documents or information responsive to this demand. 18. Responding defendant does not have any documents or information responsive to this demand. 19. Responding defendant does not have any documents or information responsive to this demand. 20. Responding defendant does not have any documents or information responsive to this demand. We are awaiting medical records from authorizations that were recently processed. 21. Responding defendant does not have any documents or information responsive to this demand. 22. See response to number (13) above. 23. See response to number (5) above. 3 3 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 24. Responding defendant does not have any documents or information responsive to this demand. 25. Responding defendant does not have any documents or information responsive to this demand. 26. Responding defendant does not have any documents or information responsive to this demand. 27. Responding defendant does not have any documents or information responsive to this demand. 28. Responding defendant objects to this demand as overbroad, unduly burdensome, not likely to lead to related discovery and not tailored in content or scope. Notwithstanding the aforementioned objection, responding defendant is not aware of nor do they have access to any written complaints arising out of the incident alleged in plaintiffs’ complaint. 29. Responding defendant does not have any documents or information responsive to this demand. 30. Responding defendant does not have any documents or information responsive to this demand. a-g)Responding defendant has not designated any experts to give testimony on their behalf, however, defendant reserves the right pursuant to the CPLR 3101(d), to retain said liability and medical expert(s) and conducting independent medical examination(s). Defendant also reserves the right to call any and all doctors that treated or examined the plaintiff as expert witnesses at the time of trial. Responding defendant will not waive plaintiff’s independent medical examination(s). 4 4 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 PLEASE TAKE FURTHER NOTICE that defendant, NEPTUNE MECHANICAL, INC., expressly reserves the right to supplement or amend this response up to the time of the trial of this action. Dated: Garden City, New York December 8, 2023 Yours, etc., THE LAW OFFICES OF KEVIN P. WESTERMAN By: _____________________ AUSTIN P. MURPHY, Jr. Attorneys for Defendant NEPTUNE MECHANICAL, INC. 990 Stewart Avenue – Suite 400 Garden City NY 11530 (516) 493 – 4501 File No.: 23-005643 MURPHA29@nationwide.com TO: Shahar Azoulay, Esq. LAW OFFICE OF MICHAEL S. LAMONSOFF Attorneys for Plaintiff 32 Old Slip – 8th Floor New York, NY 10005 (212) 962-1020 File No.: 33814 sazoulay@msllegal.com John T. Kalin, Esq. PILLINGER MILLER TARALLO, LLP 555 Taxter Road, 5th Floor Elmsford, NY 10523 (914) 703-6300 File No.: D-NATCL-00297/JTK jkalin@pmtlawfirm.com 5 5 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 Exhibit A 6 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE COMMERCIAL LINES COMMON POLICY DECLARATIONS Named Insured and Mailing Address: Agent: Neptune Mechanical Inc ARTHUR J GALLAGHER RISK MNGT SERV 29 10 120th Street 1 JERICHO PLAZA SUITE 200 Flushing, NY 11354 JERICHO, NY 11753 Agency Code: 743595 Phone Number: (800)234-8367 Policy Period: 02/03/2022 to 02/03/2023 at 12:01 A.M. Standard Time at your mailing address shown above. Business Description: Form of Business: Commercial Plumbing Contractor CORPORATION IN RETURN FOR THE PAYMENT OF THE PREMIUM, AND SUBJECT TO ALL THE TERMS OF THIS POLICY, WE AGREE WITH YOU TO PROVIDE THE INSURANCE AS STATED IN THIS POLICY. IF YOU REQUEST CANCELLATION OF THIS POLICY, THE COMPANY WILL RETAIN A MINIMUM PREMIUM OF $ THIS POLICY CONSISTS OF THE FOLLOWING COVERAGE PARTS FOR WHICH A PREMIUM IS INDICATED. THIS PREMIUM MAY BE SUBJECT TO ADJUSTMENT. Coverage Part Premium Commercial Property Coverage Part Commercial General Liability Coverage Part Crime and Fidelity Policy Coverage Part Commercial Inland Marine Coverage Part Commercial Auto Coverage Part Commercial Liability Umbrella Policy Sub-Total Fees and Surcharge – See Schedule GU-7015 (If Applicable) Total FORM(S) AND ENDORSEMENT(S) MADE A PART OF THIS POLICY: SEE SCHEDULES GU-7004 and GU-7009 Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide GU-7000 (Ed. 4-16) Includes copyrighted material of Insurance Services Office with its permission. Page: 1 of 1 Issued: 01/11/2022 7 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE DECLARATIONS PAGE EXTENSION - IMPORTANT INFORMATION NEW YORK NOTICE AND DISCLOSURE ADDENDUM - EMPLOYEE BENEFITS LIABILITY COVERAGE THIS NOTICE AND DISCLOSURE ADDENDUM APPLIES TO EMPLOYEE BENEFITS LIABILITY COVERAGE AND IS ATTACHED TO AND MADE A PART OF THE DECLARATIONS OF THE POLICY. NOTICE: 1. This endorsement is written on a claims-made basis. This endorsement applies only to damage arising out of an act, error, or omission in the "administration" of your "Employee Benefit Program", between the the retroactive date, if any, shown in the schedule of this endorsement and the end of policy period. 2. This endorsement applies only to claims made against the insured after the inception date and before the end of the policy period and all coverage under this endorsement ceases upon termination of this endorsement, except for the automatic basic extended reporting period, unless you purchase the supplemental extended reporting period coverage. 3. Claims submitted after the extended reporting period terminates will not be covered and the insured may have coverage gaps. 4. A basic extended reporting period is automatically provided without additional charge. This period starts with the end of the policy period and lasts for a period of sixty (60) calendar days. 5. A supplemental extended reporting period for one (1) year is available, but only by endorsement and for an additional charge. The supplemental extended reporting period starts at the end of the policy period. The additional premium for the supplemental extended reporting period shall be 75% of the annual premium for this Employee Benefits endorsement. 6. During the first several years of the claims made relationship, claims made rates are comparatively lower than occurrence rates. The insured can expect substantial annual premium increases, independent of overall rate level increases, until the claims made relationship reaches maturity. GU-7013 (Ed. 4-09) Page 1 of 1 Issued: 01/11/2022 8 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE LOCATION SCHEDULE Premises Bldg. No. No. Address 001 ALL 29 10 120th Street Flushing, NY 11354 002 ALL 28 35 119th Street Flushing, NY 11354 Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide GU-7005 (Ed. 4-16) Page 1 of 1 Issued: 01/11/2022 9 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE NAMED INSURED SCHEDULE Neptune Mechanical, LLC Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide GU-7008 (Ed. 4-16) Page 1 of 1 Issued: 01/11/2022 10 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE FORM SCHEDULE * INDICATES A NEW OR REPLACEMENT FORM. RETAIN THESE AND LISTED FORMS NOT REPLACED Form Edition Description POLICY FORMS PJ0004 0416 Policy Jacket- HPIC * GU7005 0416 Location Schedule * GU7008 0416 Named Insured Schedule GU7013 0409 Declaration Page Extension IL0003 0702 Calculation of Premium IL0017 1198 Common Policy Conditions IL0023 0702 Nuclear Energy Liability Exclusion Endorsement IL0185 0702 New York Changes - Calculation of Premium IL0268 0114 New York Changes - Cancellation and Nonrenewal * IL0985 0115 Disclosure Pursuant to Terrorism Risk Insurance Act * IL7185 0910 Notice of Canc and Nonren for Designated Person or Org LIABILITY FORMS CG0001 1207 Commercial General Liability Coverage Form CG0068 0509 Recording/Distr Matl or Info in Violation of Law Exc CG0104 1204 New York Changes - Premium Audit CG0163 0711 New York Changes-Commercial General Liability Cov Form * CG0300 0196 Deductible Liability Insurance * CG2012 0509 Addl Ins - State or Political Subdivisions - Permits * CG2026 0704 Addl Ins - Designated Person or Organization CG2106 0514 Exclusion-Access Or Disclosure Of Info-With Limited BI CG2147 1207 Employment-Related Practices Exclusion CG2170 0115 Cap on Losses from Certified Acts of Terrorism * CG2426 0704 Amendment of Insured Contract Definition CG2621 1091 NY Changes-Transfer of Duties When Limit is Used Up CG7195 1210 Exclusion - Computer-Related/Other Electronic Problems CG7209 0901 Lead Liability Exclusion - New York CG7304 1210 Exclusion - Silica - New York CG7305 1210 Exclusion - Asbestos - New York CG7342 1109 Blanket AI-Engineers, Arch or Surveyors Not Engaged NY CG7345 1109 Blanket AI-Lessor of Leased Equip -Automatic Status NY CG7347 0710 Blanket Locations Separate General Aggregate Limit CG7350 0710 Exclusion -Contractors Professional Liability * CG7351 0710 Employee Benefits Liability - New York CG7357 1210 General Liability Enhancement Plus Endt-Contractors-NY CG7365 0812 CG7365-Blanket Additional Insured-Permits Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide GU-7004 (Ed. 4-16) Page 1 of 2 Issued: 01/11/2022 11 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE FORM SCHEDULE * INDICATES A NEW OR REPLACEMENT FORM. RETAIN THESE AND LISTED FORMS NOT REPLACED Form Edition Description CG7383 1111 Excl-Blanket Ops Covered By A Cons Wrap-Up Ins Prog CG7430 0117 Def of Occurrence Amendatory Endt Constr Defects * CG8007 1015 Data Compromise Coverage - New York CG8012 1015 Identity Recovery Coverage - New York IL7115 0600 Excl-Exterior Insulation and Finish Systems (EIFS) * MANU1 0704 Manuscript Endorsement Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide GU-7004 (Ed. 4-16) Page 2 of 2 Issued: 01/11/2022 12 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE POLICYHOLDER NOTICE SCHEDULE The following material contains important information about your policy. Please read it carefully. ALL FORMS ARE ATTACHED. RETAIN UNLESS DELETED OR REPLACED. * INDICATES A NEW OR REPLACEMENT FORM. Form Edition Description POLICY FORMS ST7115 0416 Premium Audit Notice ST7520 0704 Amendment Of Insured Contract Definition ST7653 0416 Contractor and Property Owners Best Practices ST7687 0121 Notice to Policyholders ST7851 1114 Notice to Policyholders - Be Prepared For Data Breach Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide GU-7009 (Ed. 4-16) Page 1 of 1 Issued: 01/11/2022 13 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE COMMERCIAL GENERAL LIABILITY COVERAGE PART DECLARATIONS See Supplemental Schedule LIMITS OF INSURANCE: $ 2,000,000 Each Occurrence Limit $ 100,000 Damage to Premises Rented to You Limit $ 5,000 Medical Expense Limit (Any One Person) $ 2,000,000 Personal and Advertising Injury Limit (Any One Person or Organization) $ 4,000,000 General Aggregate Limit (Other than Products-Completed Operations) $ 4,000,000 Products/Completed Operations Aggregate Limit FORM OF BUSINESS: CORPORATION Business Description: Commercial Plumbing Contractor Location of All Premises You Own, Rent or Occupy: SEE SCHEDULE GU-7005 AUDIT PERIOD, ANNUAL, UNLESS OTHERWISE STATED: Rates Advance Premiums Classifications Code No. Premium Basis Prem./ Ops. Prod./ Comp.Ops Prem./ Ops. Prod./ Comp. Ops. SEE SCHEDULE CG-7275 TOTAL PREMIUM FOR THIS COVERAGE PART: FORM(S) AND ENDORSEMENT(S) APPLICABLE TO THIS COVERAGE PART: SEE SCHEDULES GU-7004 AND GU-7009 _____________________ 01/11/2022 __________________________________________ ARTHUR J GALLAGHER RISK MNGT SERV Countersignature Date Authorized Representative Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide CG-7274 (Ed. 4-16) Page 1 of 1 Issued: 01/11/2022 14 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE COMMERCIAL GENERAL LIABILITY COVERAGE PART SUPPLEMENTARY SCHEDULE Rates Advance Premiums Premium Prem./ Prod./ Prem./ Prod./ Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops. BOILER INSPECT/INSTALL/CLEAN PAYROLL CONTR-EXECUTIVE SUPERVISOR Prod/Comp Op subj to PAYROLL Gen Agg Limit CONTR-SUB-REPAIR-N/BLDG-NOC TOTAL COST FIRE SUPPRESSION SYSTEM-INSTAL PAYROLL HEAT EQUIP DEAL-INSTALL-N/LPG PAYROLL PLUMBING-COMMERCIAL/INDUSTRIAL PAYROLL PLUMBING-RESIDENTIAL/DOMESTIC PAYROLL Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide CG-7275 (Ed. 4-16) Page 1 of 22 Issued: 01/11/2022 15 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Insured: Policy Number: Agent: Policy Period: COMMERCIAL GENERAL LIABILITY COVERAGE PART SUPPLEMENTARY SCHEDULE Rates Advance Premiums Premium Prem./ Prod./ Prem./ Prod./ Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops. PREM NO. 002 HEAT EQUIP DEAL-INSTALL-N/LPG 95647 IF ANY DATA COMPROMISE/IDENTITY RECOVERY IF ANY BLANKET LOCATIONS SEPARATE GEN AGG LIMIT IF ANY CG7342-BLANKET ADDL INS-ENGN/ARCHIT/SURV IF ANY CG7345-BLANKET ADDL LESSR/EQUIP/AUTO IF ANY GL ENHANCEMENT PLUS ENDT CONTRACTORS IF ANY EMPLOYEE BENEFITS LIABILITY Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Natio CG-7275 (Ed. 4-16) Page 2 of 22 Issued: 16 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE COMMERCIAL GENERAL LIABILITY COVERAGE PART SUPPLEMENTARY SCHEDULE Rates Advance Premiums Premium Prem./ Prod./ Prem./ Prod./ Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops. MANUAL PREMIUM - FULLY EARNED MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUAL PREMIUM - FULLY EARNED MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide CG-7275 (Ed. 4-16) Page 3 of 22 Issued: 01/11/2022 17 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE COMMERCIAL GENERAL LIABILITY COVERAGE PART SUPPLEMENTARY SCHEDULE Rates Advance Premiums Premium Prem./ Prod./ Prem./ Prod./ Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops. MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUAL PREMIUM - FULLY EARNED Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide CG-7275 (Ed. 4-16) Page 4 of 22 Issued: 01/11/2022 18 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508504/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/08/2023 GL0000003210BN Harleysville Preferred Insurance Company One West Nationwide Blvd. Columbus, OH 43215 Insured: Neptune Mechanical Inc Policy Number: GL0000003210BN Agent: ARTHUR J GALLAGHER RISK MNGT SERV Policy Period: 02/03/2022 to 02/03/2023 RENEWAL CERTIFICATE COMMERCIAL GENERAL LIABILITY COVERAGE PART SUPPLEMENTARY SCHEDULE Rates Advance Premiums Premium Prem./ Prod./ Prem./ Prod./ Classifications Code No. Basis Ops. Comp. Ops. Ops. Comp. Ops. MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY MANUAL PREMIUM - FULLY EARNED MANUSCRIPT ENDORSEMENT IF ANY MANUSCRIPT ENDORSEMENT IF ANY Nationwide, the Nationwide N and Eagle, and Nationwide is on your side are service marks of Nationwide Mutual Insurance Company. © 2016 Nationwide CG-7275 (Ed. 4-16) Page 5 of 22 Issued: 01/11/2022 19 of 119 FILED: KINGS COUNTY CLERK 12/08/2023 01:58 PM INDEX NO. 508