Professional Documents
Culture Documents
COUNTY OF QUEENS
-----------------------------------X Index No. CV-079576-10/QU
LR CREDIT 21, LLC
ANSWER
Plaintiff,
- against -
Kenneth Chow
Defendant.
-----------------------------------X
action.
THIRD AFFIRMATIVE DEFENSE
action.
against defendant.
2
NINTH AFFIRMATIVE DEFENSE
this action.
can be granted.
estoppel.
3
SIXTEENTH AFFIRMATIVE DEFENSE
evidence.
22. That defendant has never seen the alleged credit card
allegation above.
4
26. That plaintiff knowingly, intentionally, maliciously, and
allegation above.
5
31. That plaintiff knew that the service of the purported
allegation above.
over defendant.
6
36. Defendant has been forced to answer the purported
allegation above.
action.
7
41. That as a result of the aforesaid frivolous conduct,
and costs.
allegation above.
8
45. That as a result of the foregoing, defendant respectfully
requests that this Court award the greater of one hundred thousand
allegation above.
plaintiff.
allegation above.
9
attempted frauds in the course of attempting to collect this
costs.
the Fair Credit Reporting Act, plus punitive damages, together with
10
defendant’s costs, disbursements, and attorneys’ fees; One Hundred
attorneys’ fees; and such other and further relief as the Court
Yours, etc.
________________________
S. JOHN LENOIR
LENOIR LAW FIRM
Attorneys for Defendant
461 Central Park West
Suite 3L
New York, N.Y. 10025
(212) 531-0284
11