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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK


-------------------------------------------------------------x
In re
LEHR CONSTRUCTION CORP.,
Debtor.
-------------------------------------------------------------x
Chapter 11
Case No. 11-10723-shl
DECLARATION IN
SUPPORT OF MOTION
ROBERT K. ERLANGER does hereby declare pursuant to 28 U.S.C. 1746:
1. I represent movants Jerome Russo and Deborah Russo (movants). Movants request
that this Court vacate the automatic stay imposed under section 362(a) of the Bankruptcy Code
pursuant to 11 U.S.C. 362(d) as to their interests in the action Russo v. Norsel Realties, Index
No. 150133/10 pending before the Supreme Court of the State of New York, New York County
(the action)(Complaint, Ex.1) and any general liability policy covering debtor Lehr
Construction Corp. (Lehr) for their claims alleged in the action.
2. Movants are plaintiffs in the action.
3. Jerome Russo is a journeyman mechanic and was employed by Flooring
Technologies, Inc. to install carpeting at a leased property at 575 Madison Avenue in Manhattan.
His employer was a subcontractor to subcontractor Green Flooring Systems LLC (Green
Flooring).
4. The named defendants in the action are the property owners (Norsel Realties and 575
Associates L.L.C.), the general contractor (Lehr Construction), and the property lessee (Katten
Muchin Rosenman LLP ).
5. Jerome Russo is seeking damages for injuries suffered on May 21, 2010 as the result
of defendants negligence. Those injuries include a torn left medial meniscus and possible reflex
sympathetic dystrophy syndrome/complex regional pain syndrome, along with loss of income.
6. Jerome Russo filed a Workers Compensation claim and is receiving income
compensation and well as coverage of medical bills.
7. Deborah Russo has alleged a loss of consortium claim.
8. As general contractor, Lehr is covered as an additional insured under the Commercial
Package Policy, MPA 0M1969, issued to Green Flooring, during the period 08/29/09 and
08/29/10 (Policy, Ex.2). The coverage per occurrence is $1 million.
9. Beyond the initial coverage, I have been advised by Lehrs defense counsel in the
Russo litigation, Gallo Vitucci Klar LLP, there is $5 million excess coverage under Policy
BE0M1969 issued by Harleysville Insurance.
10. The value of plaintiffs claims is within the excess coverage if not the $1 million
underlying coverage.
11. Jerome and Deborah Russo respectfully request that this Court grant their motion to
lift the automatic stay so that they may prosecute their lawsuit against Lehr and the other
defendants.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on March 9, 2011.
s/ Robert K. Erlanger
Robert K. Erlanger
2
EXHIBIT 1
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
---------------------------------------------------------------------------X
JEROME RUSSO and DEBORAH RUSSO,
Plaintiffs,
-against-
NORSEL REAL TIES, 575 ASSOCIATES L.L.C.,
KATTEN MUCHIN ROSENMAN LLP, and LEHR
CONSTRUCTION CORP.,
Defendants.
----------------------------------------------------------------------------X
Index No. 150143/10
VERIFIED
COMPLAINT
Plaintiffs JEROME RUSSO and DEBORAH RUSSO, through their attorneys, the
Erlanger Law Firm PLLC, as and for a Verified Complaint against defendants, allege as follows:
PARTIES
1. Plaintiffs are residents of Suffolk County.
2. Plaintiffs are married and reside together.
3. Plaintiff Jerome Russo is a journeyman mechanic.
4. Defendant Norse! Realties ("Norsel") is an unincorporated company.
5. On May 21, 2010, Norsel owned the building known as 575 Madison Avenue, New
York, New York ("the property").
6. Defendant 575 Madison Associates L.L.C. ("575 Madison") is a New York limited
liability corporation.
7. On May 21, 2010, 575 Madison owned the property.
8. Defendant Katten Muchin Rosenman LLP ("Katten") is a New York limited liability
partnership.
9. On May 21, 2010. Katten leased the 11th floor at the property ("the premises"), which
was being renovated, upon information and belief, according to its plans and direction.
10. Lehr Construction Corp. ("Lchr") is a New York corporation.
11. On May 21, 2010, Lehr was the General Contractor for renovation work at the
premises.
12. Non-party Flooring Technologies, Inc. ("Flooring Technologies"), upon information
and belief was referred to Lehr by non-party Green Flooring Systems LLC. Flooring
Technologies was hired to do carpeting work at the premises.
13. On May 21, 2010, Flooring Technologies's employees, including plaintiff Jerome
Russo, were working at the premises.
FACTUAL BACKGROUND
14. Between 8:45a.m. and 9:00a.m. on May 21,2010, plaintiff Jerome Russo and
another Flooring Technologies employee were on the premises carrying a roll of carpet to be
installed.
15. Plaintiff and his co-worker were required to negotiate down an approximately
70-foot passageway to reach a room where the carpet was to be installed. The passageway
walking space was reduced to approximately three feet by obstructions and scattered tools and
materials on both sides of the passageway.
16. Because plaintiff and his co-worker had no alternative but to carry the carpet down
the passageway to install it in the large room, the passageway was an integral part of their work
area.
17. The debris, obstructions, tools and materials on both sides of the passageway
2
included several dumpsters, hanging electrical extension cords, uninstalled millwork, rolls of
carpet, plywood sheets, boxes of electrical fixtures or bulbs, subcontractor gang boxes, and saw
horses.
18. The passageway floor was also not level due to incomplete or in process work.
19. The condition of the passageway is known in the construction business as a
jam."
20. As the result of the debris, obstructions and tools and materials in the passageway,
plaintiff Jerome Russo lost his balance and tripped and fell, suffering serious injuries.
21. At the time of plaintiffs accident, Lehr knew of the passageway's condition
AS AND FOR A FIRST COUNT
(Violation of Labor Law 200)
22. Plaintiffs repeat and reallege each and every allegation of Paragraphs 1 through 21
as if more fully set forth herein.
23. Lehr owed a duty to plaintiff Jerome Russo to use reasonable care to make the
workplace that was under its control reasonably safe.
24. Lehr owed a duty to plaintiff Jerome Russo to correct any unsafe condition that was
known to it or any of its employees and any unsafe condition which existed for so long that, in
the use of reasonable care, it or its employees should have known of and corrected it.
25. Lehr exercised control over Flooring Technology's work.
26. Lehr breached its duties to plaintiff Jerome Russo and he suffered serious injuries as
a result.
27. Lehr's breach of its duties to plaintiff Jerome Russo were a substantial cause of his
serious injuries.
3
AS AND FOR A SECOND COUNT
(Violation ofLabor Law 241(6))
28. Plaintiffs repeat and reallege each and every allegation of Paragraphs I through 27
as if more fully set forth herein.
29. Defendants each had a non-delegable duty under 12 NYCRR 23.1.7(e)(l) to insure
that passageways and work areas in the premises were kept free of debris and any other
obstructions or conditions which could cause tripping and sharp projections which could cut or
puncture.
30. Defendants each had a non-delegable duty under 12 NYCRR 23.1.7(e)(2) to insure
that floors and similar areas where persons work or pass shall be keep free of debris and scattered
tools and materials and sharp projections.
31. Plaintiff Jerome Russo was injured for defendants' failure to meet their obligations
under 12 NYCRR 23.l.7(e)(l) and 12 NYCRR 23.1.7(e)(2).
32. As the result of defendants' failure to meet their obligations, plaintiff Jerome Russo
suffered serious injuries.
33. Defendants' conduct was a substantial cause of plaintiff Jerome Russo's injuries.
AS AND FOR A THIRD COUNT
(Loss of Consortium)
34. Plaintiffs repeat and reallege each and every allegation of Paragraphs 1 through 33 as
if more fully set forth herein.
35. As a direct consequence of defendants' conduct, Deborah Russo suffered the loss of
Jerome Russo's care and services.
36. Plaintiff Deborah Russo is entitled to damages for her loss of consortium.
4
37. The amount of damages sought by plaintiffs exceeds the jurisdictional limits of all
lower courts which would otherwise have jurisdiction.
WHEREFORE, plaintiffs demand judgment against defendants for damages in
compensation for the injuries suffered by him, attorneys' fees and costs, and for such other and
further relief as may be deemed just and proper.
Dated: New York, New York
July I, 2010
5
ERLANGER LAW FIRM PLLC
Attorneys for Plaintiffs
By: Is/ Robert K. Erlanger
Robert K. Erlanger
I 22 East 42 Street, Suite 519
New York, New York 10168
(212) 686-8045
AFFIRMATION
ROBERT K. ERLANGER, an attorney admitted to the bar of the State of New
York, does hereby affirm under the penalty of perjury pursuant to CPLR 2106:
I am counsel for plaintiffs in this action, and I have read and know the contents of the
foregoing Complaint, which are true to my own knowledge, except as to matters alleged upon
information and belief, and as to those matters I believe it to be true.
The sources of my information and grounds of my belief as to all matters in the foregoing
document not stated to be made upon my knowledge are as follows: plaintiff Jerome Russo and
witnesses.
This Affirmation is made by me because neither plaintiff works or resides in the county
where my offices are located, New York County.
Dated: New York, New York
July 1, 2010
6
Is/ Robert K. Erlanger
Robert K. Erlanger
EXHIBIT 2

*


Named Insured.
Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester, MA 01608-1408
www.harleysvillegroup.com
GREEN FLOORING SYSTEMS LLC
2116 MERRICK AVENUE
MERRICK NY 11566
Type Of Entity: Limited Liability Company
Business Description: Gc--Flooring Systems
COMMERCIAL PACKAGE POLICY
MPAOM1969
Account
Policy Term
OM1969
08129/09 to 08/29/10
12:01 A.M. Standard Time
Issue Date 07129/09
Reason for Issue Renewal Certificate
For assistance please contact your agent
KEEVIL Y SPERO-WHITELAW INC
at 914-381-6611
Code 84-6024)
In return for the payment of the premium and subject to all the terms of this
policy, we agree to provide the insurance as stated in this policy. If you
request cancellation of this policy, there is a minimum premium retention
of $100.
This policy consists of the following coverage part(s). The premium may be
subject to adjustment.
Commercial General Liability
Commercial Inland Marine
Commercial Property
Worcester 03 03 DB
PD-0113 (Ed. 6-8S)
p
New York Fire Insurance Fee:
Total:
Page 1 Continued
Annual
Premium
$15,517.00
$3,000.00
$1,099.00
$0.59
$19,616.59
Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester, MA 01608-1408
V/IN'olll. harleysvillegroup. com
COMMERCIAL PACKAGE POLICY
MPAOM1969

* .,.

Harleysvtlleou
GREEN FLOORING SYSTEMS LLC
SCHEDULE OF LOCATIONS/PREMISES
Policy Term
Issue Date
Agent Code
08/29/09 to 08129/10
12:01 A.M. Standard Time
07/29/09
84-6024
This schedule is for address information only. Refer to attached coverage
part(s) to determine application of coverage.
Loc
Na Location Descriptian
001 2116 Merrick Avenue Merrick NV 11566
FORMS AND ENDORSEMENTS
The are applicable to all coverage parts:
Number Edit ian
CG0104 1204
PJ0003 0205
IL0017 1185
IL0268 0205
:.EIL0952 0308
IL0985 0108
IL7141 1198
Title
New York Changes - Premium Audit
Policy Jacket
Common Policy Conditions
New York Changes - Cancellation and Nonrenewal
Cap On Losses From Certified Acts Of Terrorism
Disclosure Pursuant To Terrorism Risk Insurance
Act
Exclusion of Certain Computer-Related Losses
The material contains important information. Please read it carefully.
:JEILW7149
ST7115
ST7481
ST7555
:IEST7653
Z887
1298
0900
0405
1104
0309
1299
Conditional Renewal Notice <New York)
Premium Audit Notice
Real Estate Management "Best Practices"
Important Notice To Policyholders
Best Practices For General Contractors And
Subcontractors
Direct Claims Reporting Saves Vou Time and Money!
:JE Indicates a new or replacement form.
RENEWAL INSURING AGREEMENT
We renew this policy for the period stated on the renewal declarations in
return for your payment of the premium. The renewal is subject to all
forms and endorsements attached to the policy or to this renewal
declaration.
Renewal offer requires payment for prior policy term.
Worcester 03 03 DB
PD-0113 (Ed. 6-85)
p Page 2 Continued
lit.
* ....


Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester, MA 01608-1408
WMN.harleysvillegroup.com
GREEN FLOORING SYSTEMS LLC
COMMERCXAL GENERAL LXABILXTY COVERAGE PART
Effective Date: 08/29/09
This policy contains aggregate limits; refer to
Section III - Limits of Insurance for details
SCHEDULE OF COVERAGES
Limits of Insurance
Each Occurrence Limit
COMMERCIAL PACKAGE POLICY
MPAOM1969
Policy Term
Issue Date
Agent Code
08/29/09 to 08/29/10
12:01 A.M. Standard Time
07/29109
84-6024
Damage to Premises Rented to You Limit Any one premises
$1,000,000
$100.,000
$5,000
$1,000,000
Medical Expense Limit Any one person
Personal and Advertising Injury Limit
Any one person or organization
General Aggregate Limit
(Other than Products-Completed Operations)
Products/Completed Operations Aggregate Limit
$2,000,000
$2,000,000
SCHEDULE FOR COMMERCIAL GENERAL LIABILITY CLASSIFICATIONS
Location/
Bldg or
Premises
Classification
Premium Base
000/000 Floor Covering Distributors
Gross Sales Premium Base =
000/000 Contractors- Subcontracted Work- In Connection
With Construction., Reconstruction, Repair Or
Erection Of Buildings- For Industrial Use
Total Cost Premium Base =
SCHEDULE OF OTHER COVERAGES AND ENDORSEMENTS
Additional Insured - Owners., Lessees Or
Contractors - Scheduled Person Or Organization
Name of Person or Organization:
Madison 3rd Avenue Building
825 Third Avenue
New York NV 10001
Only Job 825 Third Ave
Additional Insured-Managers or Lessors of Premises
Designation of Premises:
Lacatian 001 Building 001
Name of Person or Organization:
Commodore Trading Corporation
2116 Merrick Avenue
Merrick NV 11566
Worcester 03 03 DB
PD-0113 (Ed. 6-85)
p
Page 3 Continued
All Products/
Other Completed
Operations
(Class Code)
12797
3,143.,329
91584
909.,662
12797
91584
Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester, MA 01608-1408
VNNJ.harleysvillegroup.com
COMMERCIAL PACKAGE POLICY
MPAOM1969
GREEN FLOORING SYSTEMS LLC
Policy Term
Issue Date
Agent Code
Additional - OwnersJ Lessees
- Automatic Status When Required In
Construction With Vou
ANV PERSON DR ORGANIZATION WHEN REQUIRED
BV A WRITTEN CONTRACT
Additional Insured - OwnersJ Lessees Or
Contractors - Completed Operations
ANV PERSON OR ORGANIZATION WHEN REQUIRED IN A
WRITTEN CONTRACT
Waiver of Transfer of Rights of Recovery Against
Others to Us
ANY PERSON DR ORGANIZATION WHEN REQUIRED BY
A WRITTEN CONTRACT
General Liability Enhancement Endorsement - Contra
ctors - New York
FORMS AND ENDORSEMENTS
CGOOOI
CG0163
CG2010
CG2011
CG2033
CG2037
CG2147
CG2170
CG2404
CG2426
CG2621
*CG7105
CG7108
CG7195
CG7209
CG7248
1204
0999
0704
0196
0704
0704
0798
0108
1093
0704
1091
0901
1201
0901
0901
1204
General Liability Coverage Form
New Vork Changes - Commercial General Liability
Coverage Form
Additional Insured - Owners, Lessees Or
Contractors - Scheduled Person Or Organization
Additional Insured-Managers or Lessors of Premises
Additional Insured - Owners, Lessees Or
Contractors - Automatic Status When Required In
Construction Agreement With You
Additional Insured - OwnersJ Lessees Or
Contractors - Completed Operations
Employment-Related Practices Exclusion
Cap On Losses From Certified Acts Of Terrorism
of Transfer of Rights of Recovery Against
Others to Us
Amendment Of Insured Contract Definition
New York Changes- Transfer of Duties When a Limit
of Insurance is Used Up
Two or More Policies Issued by Us
Exclusion - AsbestosJ or Talc
Exclusion - Year 2000 Computer-Related and Other
Problems
Lead Liability Exclusion - New Vork
Exclusion - Unsolicited FaxesJ Telephone Calls And
Emails
08/29/09 to 08/29/10
12:01 A.M. Standard Time
07/29/09
84-6024
Lac/
state Bldg
NY 000000
NV 000000
NV 000000
CG7249
CG7281
1204
1006
Other Insurance Amendment NV
General Liability Enhancement Endorsement - Contra NV
ctors - New York
000000
000000
IL0021
IL7115
0498
0600
Nuclear Energy Liability Exclusion Endorsement
<Broad Form)
Exclusion--Exterior Insulation and Finish Systems
Worcester 03 03 DB
PD-0113 (Ed. 6-85)
p Page 4 Continued
Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester, MA 01608-1408
WNW.harleysvi!legroup.com
GREEN FLOORING SYSTEMS LLC
CEIFS)
COMMERCIAL PACKAGE POLICY
MPAOM1969
Policy Term
Issue Date
Agent Code
08/29/09 to 08/29110
12:01 A.M. Standard Time
07/29/09
84-6024
* Indicates a new or replacement form. Retain listed farms nat replaced.
Worcester 03 03 DB
PD-0113 (Ed. 6-85)
p Page 5 Continued
Har1eysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester. MA 01608-1408
WNN.harleysvillegroup.com
COMMERCIAL PACKAGE POLICY
MPAOM1969

*


GREEN FLOORING SYSTEMS LLC
COMMERCZAL ZNLAND MARINE COVERAGE PART
Effective Date: 08/29/09
SCHEDULE OF COVERAGES
Installation Coverage Form
Deductible: $1,000
Job Site
Prem Bldg
No No covered Property
Description installation or project:
Blanket covered property
ANV SINGLE JOB SITE LOCATION
Per Statement of Values on File With Us.
Coinsurance: 90Y.
Description of installation or project:
ANV TEMPORARY STORAGE LOCATION
Property in Transit
Description of installation or project;
MAXIMUM ANY ONE OCCURRENCE
Special Provisions
Policy Term
Issue Date
Agent Code
Loss payable provision - for covered property in which both you
and a loss payee shown in the declarations have an insurable
interest, we will:
1. Adjust losses with you; and
2. Pay any claim for loss or damage jointly to you and the lass
payee3 as interests may appear.
SCHEDULE OF OTHER COVERAGES AND ENDORSEMENTS
Prem Bldg
No No
Loss payee
Lehr Construction Carp
902 Broadway
New York NV 10010
Description Of Property
MATERIAL TEMP STORAGE LOC
ATIMA
6th Floor
Worcester DB
PD-0113 (Ed. 6-85)
p Page 6 Continued
08/29/09 to 08/29/10
12:01 A.M. Standard Time
07/29/09
84-6024
Limit of
Insurance
$500,000
$500,000
$50,000
$500,000
lit. it.'+
'*

HarleysVIIIesw
Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester. MA 01608-1408
VNNv.harleysvillegroup.ccm
GREEN FLOORING SYSTEMS LLC
FORMS AND ENDORSEMENTS
CMDOOl
CM7312
0904 Inland Marine Conditions
0887 Installation Coverage Form
COMMERCIAL PACKAGE POLICY
MPAOM1969
Policy Term
Issue Date
Agent Code
08/29/09 to 08/29/10
12:01 A.M. Standard Time
07/29/09
84-6024
LOC/
state Bldg
* Indicates a new or replacement form. Retain listed forms not replaced.
Worcester 03 03 DB
PD-0113 (Ed. 6-85)
p
Page 7 Continued

*

HarleysVIIIe5V
Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester, MA 01608-1408
WtNoN. harleysvillegroup.com
GREEN FLOORING SYSTEMS LLC
COMMERCIAL PROPERTY COVERAGE PART
Effective date: 08/29/09
SCHEDULE OF DEDUCTZBLES
COMMERCIAL PACKAGE POLICY
MPAOM1969
Policy Term
Issue Date
Agent Code
08/29/09 to 08/29/10
12:01 A.M. Standard Time
07/29/09
84-6024
"Deductible" modifies insurance provided under the following: building and
personal property coverage form, builders' risk coverage form, condominium
association coverage form, condominium commercial unit-owners coverage form.
Deductibles apply only when the coverage form is listed under the schedule of
coverages.
Deductible: $500
These terms do not apply to any earthquake deductible or to any
windstorm or hail percentage deductible provided elsewhere in
this policy.
SCHEDULE OF COVERAGES
coverages:
cave rage

Type
Lac 001 Bldg 001 State NY Terr 300
Descriptian af Premises:
Occupancy: Contractor
Construction: Joisted Masonry
Building and Personal Property Coverage Form
Your Business Personal Property
Optional Coverages:
Replacement Cost
Business Income (and Extra Expense)
Coverage Form
Business Income other than Rental Value
Mercantile or Non-Manufacturing Risk
SCHEDULE OF OTHER COVERAGES AND ENDORSEMENTS
Commercial Property Plus II Endorsement
Prem Bldg
No Na
FORMS AND ENDORSEMENTS
causes cain- Limit of
of Loss surance Insurance
Special
Special
$20,000
Loc/
state Bldg
CPDOlD
CP0030
1000 Building and Personal Property Coverage Form
1000 Business Income (and Extra Expense) Coverage Form
Worcester 03 03 DB
PD-0113 (Ed. 6-85)
p
Page 8 Continued
lit- it. "'"
.,_
.....

CP0090
Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester, MA 01608-1408
WNW.harleysvillegroup.com
GREEN FLOORING SYSTEMS LLC
0788 Commercial Property Conditions
0409 New York Changes
1000 Causes of loss - Special Form
1003 Equipment Breakdown Endorsement
COMMERCIAL PACKAGE POLICY
MPAOM1969
Policy Term
Issue Date
Agent Code
08129/09 to 08/29/10
12:01 A.M. Standard Time
07/29/09
84-6024
*CP0133
CP1030
CP7136
CP7147
IL0183
0304 Commercial Property Plus II Endorsement
0395 New Vork Changes - Fraud
NY 000000
* Indicates a new or replacement form. Retain listed forms not replaced.
Worcester 03 03 DB
PD-0113 (Ed. 6-85)
p Page 9
Harleysville Worcester Insurance Company
120 Front Street, Suite 500
Worcester. MA 01608-1408
VNNJ.harleysviltegroup.com
COMMERCIAL PACKAGE POLICY
MPAOM1969

"'
lf..

Policy Term
Issue Date
08/29109 to 08/29/10
12:01 A.M. Standard Time
07/29/09
Agent Code 84-6024
GREEN FLOORING SYSTEMS LLC
Premium Sheet GL Class Code:
coverage Part: commercial General Liability Pro Rate Factor:
Subject To Audit
Loc 000 Bldg 000 state 31 Terr 007
Class 12797 Floor Coveri-All Other Coverage/Pram Base-Sales /Lmt ID 2
Base Rate P/0 Adj Dev cap Factor Dep -+XCU Fringe Med Lead
0.900 1.000 1.750 1.000
Final Prem
Cov Adj (ILF-Ded) * Pkg RHF. : Rate Base
1.62 1.000 .870 2.220
TRANS
Adj = Annual Prem
$6,978.00
Class 12797 Floor Coveri-Products Coverage /Prem Base-Sales /Lmt ID B
Base Rate P/0 Adj Dev Cap Factor Dep -+XCU Fringe Med Lead
0.135 1.750 1.000
Final
Cav Adj M (ILF-Ded) M Pkg M RMFI : Rate
1.64 1.000 .870 0.337
Prem TRANS
Base Adj
3 .. 143.,329
Class 91584 A Rate Contractors--All Other Coverage/Pram Base-Cost
= Annual Prem
$1,059.00
/Lmt ID 3
Base Rate P/0 Adj :1i Dev Cap Factor Dep -+XCU Fringe Med Lead
1.390 1.000 1.750 1.000
Final Prem
Cov Adj * (ILF-Ded) Pkg * RHF8 : Rate Base
2.05 1.000 .870 4.338
TRANS
Adj = Annual Prem

12797
1.000
Class 91584 A Rate Contractors--Products Coverage /Prem Base-Cost /Lmt ID C
Base Rate P/0 Adj Dev Cap Factor Dep -+XCU Fringe Med Lead
1.020 1.750 1.000
Final
Cav Adj M (ILF-Dedl M Pkg RMFI : Rate
1.90 1.000 .870 2.951
Additional I CG2033
Additional I CG2037
General Liab CG7281
Dwners,Lesse Addl Intr
Prem
Base
909.,662
03 03 DB
PD-Q113 (Ed. 6-85)
p Page 1 Continued
TRANS
M Adj = Annual Prem
$2,684.00
Annual Prem
$250.00
Annual Prem
$250.00
Annual Prem
$100.00
Annual Prem
$200.00

'* ...
:!f.

Harleysville Worcester Insurance Company
120 Frcnt Street, Suite 500
Worcester, MA 01608-1408
www. harleysvillegroup.com
GREEN FLOORING SYSTEMS LLC
Loc 001 Bldg 001
Owners
1
Hanag Addl Intr
COMMERCIAL PACKAGE POLICY
MPAOM1969
Policy Term
Issue Date
Agent Code
08129/09 to 08/29/10
12:01 A.M. Standard Time
07/29/09
84-6024
Annual Prem
$50.00
Estimated Total Annual Premium: $15,517.00
For This Coverage Part
I (TIP /Camm /other) (SCH /Camm /other) EXP LOSSF SEC = RMF
1.000 1.000 1.000 .870 1.000 1.000 1.000 1.000 1.000 .870
Worcester 03 03 DB
PD-0113 (Ed. 6-85)
p Page 2 Continued
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------------------------------x
In re
LEHR CONSTRUCTION CORP.,
Debtor.
-------------------------------------------------------------x
Chapter 11
Case No. 11-10723-shl
ORDER PURSUANT TO 11 U.S.C. 362(d)
MODIFYING THE AUTOMATIC STAY IMPOSED BY 11 U.S.C. 362(a)
Upon motion dated March 23, 2011 (the Motion) of movants Jerome Russo and
Deborah Russo (movants) for an order pursuant to 362(d) of title 11 of the United States Code
(the Bankruptcy Code) vacating the automatic stay imposed in the above-captioned case by
section 362(a) of the Bankruptcy Code to allow movants to prosecute their claims against the
Debtor in the action Russo v. Norsel Realties, Index No. 150133/10, pending before the Supreme
Court of the State of New York, New York County (the lawsuit), to the extent the Debtor is
covered under any commercial liability insurance policy covering such claims; and due and
proper notice of the Motion having been made on all necessary parties; and the Court having held
a hearing on the Motion on March 23, 2011; and their being no opposition to the Motion; and
upon all of the proceedings had before the Court; and after due deliberation and sufficient cause
appearing; it is hereby
ORDERED that the motion is granted as provided herein; and it is further
ORDERED that the automatic stay imposed in this case by section 362(a) of the
Bankruptcy Code is vacated under section 362(d) of the Bankruptcy Code to allow movants to
prosecute their claims against the Debtor in the lawsuit to the extent the Debtor is covered under
any commercial liability insurance policy covering such claims
Dated: March _____, 2011
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UNITED STATES BANKRUPTCY JUDGE