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Answer and Affirmative Defenses in Figueroa v. Szymoniak

Answer and Affirmative Defenses in Figueroa v. Szymoniak

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Published by Martin Andelman
Defendants in Figueroa v. Szymoniak Answer and Affirmative Defenses
Defendants in Figueroa v. Szymoniak Answer and Affirmative Defenses

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Published by: Martin Andelman on Sep 16, 2013
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05/05/2014

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACASE NO. 13-61020-CIV-COHN-SELTZER IGNACIO DAMIAN FIGUEROA,Plaintiff,vs.LYNN SZYMONIAK, ESQUIRE, individuallyand as shareholder/member/owner of The Szymoniak Firm, P.A.; THE SZYMONIAK FIRM, P.A., a Florida professional association;HAL J. KLEINMAN, ESQUIRE, individually,JANET, JENNER & SUGGS, LLC,Defendants. _____________________________________________/
DEFENDANTS, LYNN SZYMONIAK, ESQUIRE AND THE SZYMONIAK FIRM,P.A.’S, ANSWER AND AFFIRMATIVE DEFENSES
Defendants, LYNN SZYMONIAK, ESQUIRE, and THE SZYMONIAK FIRM, P.A., byand through their undersigned attorneys, hereby file their Answer and Affirmative Defenses toPlaintiff’s Complaint and Demand for Jury Trial and state:
ANSWER 
 1. Admitted.2. Denied.3. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, was an attorneylicensed to practice law in the State of Florida. All other allegations are denied as alleged.4. Denied.
Case 0:13-cv-61020-JIC Document 19 Entered on FLSD Docket 05/08/2013 Page 1 of 13
 
 25. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, was the soleowner of Defendant, THE SYZMONIAK FIRM, P.A. All other allegations are denied asalleged.6. Defendants, LYNN SZYMONIAK, ESQUIRE and THE SZYMONIAK FIRM,P.A., are without knowledge and therefore deny.7. Defendants, LYNN SZYMONIAK, ESQUIRE and THE SZYMONIAK FIRM,P.A., are without knowledge and therefore deny.8. Defendants, LYNN SZYMONIAK, ESQUIRE and THE SZYMONIAK FIRM,P.A., are without knowledge and therefore deny.9. Denied.10. Denied.11. Defendants, LYNN SZYMONIAK, ESQUIRE and THE SZYMONIAK FIRM,P.A., are without knowledge and therefore deny.12. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, had contact withPlaintiff at some time. All other allegations are denied.13. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, met Plaintiff inWest Palm Beach, Florida. All other allegations are denied.14. Denied.15. Denied.16. Denied.17. Denied.18. Denied.
Case 0:13-cv-61020-JIC Document 19 Entered on FLSD Docket 05/08/2013 Page 2 of 13
 
 319. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, and Plaintiff communicated at times through email. All other allegations are denied.20. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, and Plaintiff communicated at times through email. All other allegations are denied.21. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, and Plaintiff communicated at times through email. All other allegations are denied.22. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, and Plaintiff communicated at times through email. All other allegations are denied.23. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, and Plaintiff communicated at times through email. All other allegations are denied.24. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, and Plaintiff communicated at times through email. All other allegations are denied.25. Denied.26. Denied.27. Denied.28. Denied.29. Denied.30. It is admitted that Defendant, LYNN SZYMONIAK, ESQUIRE, and Plaintiff communicated at times through email. All other allegations are denied.31. It is admitted that defendant, LYNN SZYMONIAK, ESQUIRE, and Plaintiff communicated at times through email. All other allegations are denied.32. Denied.
Case 0:13-cv-61020-JIC Document 19 Entered on FLSD Docket 05/08/2013 Page 3 of 13

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