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Answer of Kleinman in Figueroa v. Szymoniak

Answer of Kleinman in Figueroa v. Szymoniak

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Published by Martin Andelman
Named in Figueroa's complaint, this is a law firm that Lynn brought in for some reason.
Named in Figueroa's complaint, this is a law firm that Lynn brought in for some reason.

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Published by: Martin Andelman on Sep 16, 2013
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09/16/2013

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 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 
1.
 
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
 
Case No. 0:13-Civ-61020-Cohn/Seltzer 24.
 
As the allegations in paragraph 4 of the Complaint are directed to a Co-Defendant, the Janet Defendants neither admit nor deny same.5.
 
As the allegations in paragraph 5 of the Complaint are directed to a Co-Defendant, the Janet Defendants neither admit nor deny same.6.
 
Defendant Kleinman admits he is an attorney licensed in the State of Illinois andPennsylvania to practice law. Defendant Kleinman denies he was retained by or entered into anattorney-client relationship with the Plaintiff.7.
 
Defendant Janet Jenner & Suggs, LLC admits only that it is a Maryland LimitedLiability Company. Defendant Janet Jenner & Suggs LLC denies that it represented or had anattorney-client relationship with the Plaintiff and further denies the remaining allegations of  paragraph 7 of the Plaintiff’s Complaint.8.
 
Defendants Janet admit only that Defendant Kleinman was an employee of Defendant Janet Jenner & Suggs. The Janet Defendants deny that they represented or had anattorney-client relationship with the Plaintiff.9.
 
The allegations in paragraph 9 of the Plaintiff’s Complaint are denied.10.
 
The allegations in paragraph 10 of the Plaintiff’s Complaint are denied.
GENERAL ALLEGATIONS 
11.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 11of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.12.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 12of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.13.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 13of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.
Case 0:13-cv-61020-JIC Document 18 Entered on FLSD Docket 05/08/2013 Page 2 of 23
 
Case No. 0:13-Civ-61020-Cohn/Seltzer 314.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 14of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.15.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 15of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.16.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 16of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.17.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 17of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.18.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 18of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.19.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 19of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.20.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 20of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.The Janet Defendants deny that they had an attorney-client relationship with the Plaintiff.21.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 21of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.22.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 22of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.The Janet Defendants deny that they had an attorney-client relationship with the Plaintiff.23.
 
The Janet Defendants are without knowledge as to the allegations in paragraph 23of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.The Janet Defendants deny that they had an attorney-client relationship with the Plaintiff.
Case 0:13-cv-61020-JIC Document 18 Entered on FLSD Docket 05/08/2013 Page 3 of 23

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