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Due to the following arguments, I urge this Court to grant Plaintiff’s Motion for Declaratory Judgment and enter judgment declaring that no duty exists on its part to defend or indemnify defendants in the Underlying Action.
Plumbing Repairs
No matter if it’s residential or commercial plumbing repairs that you require, our team of qualified professionals is committed to providing exceptional customer service and high-quality work. Expect complete transparency during our quoting process, as well as constant communication throughout your project.
As a plumber, you’re constantly dealing with changing compliance laws, which can be tricky to manage without assistance from reliable sources. Victoria Plumbing & Heating Supply understands your needs and is here to provide that support – our wide variety of code-compliant products combined with expert staff makes us a go-to resource.
Jerez alleges he was injured while performing construction work at a milk processing facility owned and operated by Chen and Bhola and contracted out for plumbing by Tri-State, at which he worked. According to Jerez, these injuries resulted from and occurred during his employment by Tri-State, and they are entitled to damages under New York law.
The plaintiff has filed its Motion for Default Judgment with the Court, asking it to order that there is no duty on it to defend or indemnify the defendants in this underlying action. According to their plain language policies, neither Chen nor Bhola is insured under them and, therefore, are not subject to Plaintiff’s obligation of defense or indemnification.
Drain Cleaning
Plumbing drains should operate smoothly to deliver household wastewater directly into a municipal sewer line or septic tank for disposal without creating back-ups and other plumbing problems. Clogs, however, can lead to backups that necessitate regular drain cleaning for prevention of back-ups or any other complications with plumbing systems. In order to maintain proper drainage operation, it is necessary to do regular drain maintenance services to stay ahead of any potential issues with drainage pipes and their drains.
Homeowners can often perform drain cleaning themselves using products sold at hardware and grocery stores. Unfortunately, such cleaners may mask blockages by coating pipes with chemical layers, which hasten corrosion. As a result, drains are likely to clog again within a short timeframe.
An experienced plumber can ensure a more thorough drain cleaning by using a special camera to inspect your plumbing pipes. This camera can detect whether there are any clogs present and where they’re located, after which he/she will use a drain snake to break them up and clear them away.
High-pressure water jetting is another effective way of clearing drains, providing an alternative approach that can clear stubborn clogs without having to dig up pipes and remove debris physically. Furthermore, tree roots that have infiltrated drain pipes may even be removed with this technique.
Contact Tri-State Plumbing now to discover more about how they can assist your construction project! Their team is committed to delivering top-quality work with professional customer service at every turn – and ensures complete transparency during every stage.
Water Heater Repairs
Water heaters are an essential appliance in your home. When they start leaking water or not providing hot water as desired, repair services must be sought immediately to avoid flooding and expensive repairs. Rusty or brown-colored water may indicate corrosion in your tank, which will require repair as soon as a leak becomes imminent; additionally, rotten egg-like smells could mean too much bacteria has entered your system’s supply system, and this should also be addressed immediately.
Toilet Repairs
Toilets are one of the most essential and complex appliances in any home, so when they break down or don’t function correctly, they can cause severe damage and cost you significant sums of money. That is why you must recognize when it is time to contact a plumber. Here are a few signs it might be time for an upgrade:
If your toilet is leaking water or is covered by standing water, immediate action must be taken. Ignoring this problem could result in flooding and costly repairs later. Also, take notice if it fails to flush correctly or does not fill after each flush.
No matter the scale of your bathroom renovation or plumbing repair needs, Tri-State can assist. We pride ourselves in offering professional, transparent service as well as high-quality work – so call us now to start the process!
The Complaint alleges that Jerez was injured as a result of construction work performed by Chen and Bhola on the subject property. Based on AEIC Senior Claims Representative David Johnson’s Affidavit (“Johnson Aff,” Dkt 16-9) and Tri-State Insurance Policy/Umbrella Policy issued by AEIC (“Policy,” Dkt 16-10 and “Umbrella Policy,” Dkt 16-11), Tri-State is exempt from both policies, thus justifying granting their Motion for Summary Judgment by both policies.
