FAMILY COURT OF THE CITY OF NEW YORK COUNTY OF KINGS _____________________________________________________ ELENA SVENSON,Petitioner,-against-MICHAEL KRICHEVSKY,Respondent. _____________________________________________________ INDEX NO.F-28901-08/10B
VERIFIED ANSWER JURY TRIALDEMANDED
C O U N S E L O R S :The respondent MICHAEL KRICHEVSKY, Pro Se, as and for his Verified Answer tothe Petition to Hold Respondent in Contempt of Court for not paying money he does not have,thereby not complying with court’s order, respectfully alleges:
Denies allegations contained in paragraph numbered 2 and 5 of the Petition.2.Lacks information or knowledge sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph numbered 6, 7, 8 of the Petition.
Admits each allegation contained in paragraph numbered 1, 3, and 4, of thePetition.AS AND FOR A FIRST AFFIRMATIVE DEFENSE – FAILURE TO STATE A CAUSE OFACTION UPON WHICH RELIEVE CAN BE SOUGHT (
Out of fraud no actionarises
The Petition in its entirety fails to particularly state wrongdoing by respondentthat caused petitioner to complain. Petitioner and her lawyer,
”), are well aware that this court order obtained by perjury and fraud upon thecourt, and therefore void.
Petitioner and her lawyer are well aware that respondent filed petition for modification of child support order because actions of petitioner and her lawyer causedrespondent to lose his job.