UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACase No. 0:13-Civ-61020-Cohn/Seltzer IGNACIO DAMIAN FIGUEROA,Plaintiff,vs.LYNN SZYMONIAK, ESQUIRE, individuallyand as a shareholder/member/owner of TheSzymoniak Firm, P.A.; THE SZYMONIAK FIRM, P.A., a Florida professional association;HAL J. KLEINMAN, ESQUIRE, individually;JANET, JENNER & SUGGS, LLC,Defendants./
DEFENDANTS HAL J. KLEINMAN, ESQ. AND JANET, JENNER & SUGGS, LLC’ SANSWER AND AFFIRMATIVE DEFENSESCOMES NOW
, the Defendants, HAL J. KLEINMAN, ESQUIRE, individually, andJANET, JENNER & SUGGS, LLC, (hereby collectively referred to as the “Janet Defendants”) by and through their undersigned counsel and file this their Answer and Affirmative Defenses tothe Plaintiff’s claim, and in response thereto state as follows:
PARTIES AND JURISDICTION
The Janet Defendants deny that they are liable to the Plaintiff and therefore denyPlaintiff is entitled to any damages.2.
The Janet Defendants are without knowledge as to the allegations in paragraph 2of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.3.
As the allegations in paragraph 3 of the Complaint are directed to a Co-Defendant, the Janet Defendants neither admit nor deny same.
Case 0:13-cv-61020-JIC Document 18 Entered on FLSD Docket 05/08/2013 Page 1 of 23