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Kovalesky v Tabar Answer

Kovalesky v Tabar Answer

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Published by david_lat
Kovalesky v. Tabar: Answer
Kovalesky v. Tabar: Answer

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Published by: david_lat on Mar 24, 2014
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09/20/2014

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 John G. Balestriere  Jillian L. McNeil
BALESTRIERE, FARIELLO & ABRAMS LLP
225 Broadway, 29
th
 Floor New York, NY 10007 Telephone: (212) 374-5401 Facsimile: (212) 208-2613  john.balestriere@balestrierefariello.com  jillian.mcneil@balestrierefariello.com
 Attorneys for Defendant-Counterclaim Plaintiff
SUPREME COURT OF THE STATE OF NEW YORK, NEW YORK COUNTY
ANGELA KOVALESKY,
 Plaintiff, -against-
SAMIR TABAR,
Defendant. Index No. 151034/2014
VERIFIED ANSWER AND COUNTERCLAIMS SAMIR TABAR,
Counter-Plaintiff, -against-
ANGELA KOVALESKY,
Counter-Defendant.
Defendant Samir Tabar (“Tabar”), by and through his attorneys, Balestriere,
Fariello & Abrams LLP, upon information and belief, denies each and every allegation
FILED: NEW YORK COUNTY CLERK 03/24/2014
INDEX NO. 151034/2014NYSCEF DOC. NO. 2RECEIVED NYSCEF: 03/24/2014
 
 
2
of the Plaintiff’s
 
(“Plaintiff” or “Kovalesky”)
 
Verified Complaint (the “Verified Complaint”)
, except as follows:
 
1.
 
Tabar denies the allegations asserted in paragraph 1 of the Verified Complaint. 2.
 
Tabar denies the allegations asserted in paragraph 2 of the Verified Complaint. 3.
 
Tabar
admits that he texted one member of Plaintiff’s family regarding Plaintiff’s drug use.
Tabar denies the remaining allegations asserted in paragraph 3 of the Verified Complaint. 4.
 
Tabar denies the allegations asserted in paragraph 4 of the Verified Complaint. 5.
 
Tabar denies the allegations asserted in paragraph 5 of the Verified Complaint. 6.
 
Upon information and belief, Tabar denies the allegations asserted in paragraph 6 of the Verified Complaint. 7.
 
Tabar denies the allegations asserted in paragraph 7 of the Verified Complaint. 8.
 
Tabar denies the allegations asserted in paragraph 8 of the Verified Complaint. 9.
 
Paragraph 9 states a legal conclusion to which no response is required. 10.
 
Paragraph 10 states a legal conclusion to which no response is required.
 
 
3 11.
 
Tabar denies knowledge or information sufficient to form a belief as to the truth of the allegations asserted in paragraph 11 of the Verified Complaint. 12.
 
Tabar admits the allegations asserted in paragraph 12 of the Verified Complaint. 13.
 
Tabar denies the allegations asserted in paragraph 13 of the Verified Complaint. 14.
 
Tabar denies the allegations asserted in paragraph 14 of the Verified Complaint. 15.
 
Tabar denies the allegations asserted in paragraph 15 of the Verified Complaint. 16.
 
Tabar denies the allegations asserted in paragraph 16 of the Verified Complaint. 17.
 
Tabar denies the allegations asserted in paragraph 17 of the Verified Complaint. 18.
 
Tabar denies the allegations asserted in paragraph 18 of the Verified Complaint. 19.
 
Tabar denies the allegations asserted in paragraph 19 of the Verified Complaint. 20.
 
Tabar denies knowledge or information sufficient to form a belief as to the truth of the allegations asserted in paragraph 20 of the Verified Complaint. 21.
 
Tabar denies the allegations asserted in paragraph 21 of the Verified Complaint.

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