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Ravo Capital LLC v. Complete Neuropsychology, P.C. et al

Docket 706466/2024, New York State, Queens County, Supreme Court (Mar. 26, 2024)
Case TypeCommercial - Contract
TagsCommercial, Civil, Contract
Plaintiff Ravo Capital LLC
Defendant Complete Neuropsychology, P.C.
Defendant Full Psychology, P.C.
...
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ANSWER TO THIRD PARTY COMPLAINT Third-Party Defendants Answer to Third-Party Complaint

Document Ravo Capital LLC v. Complete Neuropsychology, P.C. et al, 706466/2024, 11 (N.Y. Sup. Ct., Queens County Oct. 9, 2024)
Answering Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph “7” of the Third-Party Complaint, and refer to the referenced pleading for the timing and details thereof.
Answering Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph “8” of the Third-Party Complaint, and refer to the referenced pleading for the timing and details thereof.
Answering Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph “9” of the Third-Party Complaint, and refer to the referenced pleading for the timing and details thereof.
At all times relevant hereto, the Answering Defendants did not act in a negligent, reckless, or careless manner or in breach or violation of any contract, statute or applicable law.
Answering Defendants reserve the right to assert additional affirmative defenses as warranted based on the results of further investigation and discovery in this matter.
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ANSWER

Document Ravo Capital LLC v. Complete Neuropsychology, P.C. et al, 706466/2024, 6 (N.Y. Sup. Ct., Queens County Jul. 24, 2024)
Defendants deny sufficient knowledge or information to form a belief about the allegations set forth in paragraphs 2, 9, 10, 12, 19 and 21of the Complaint.
Defendants deny the allegations set forth in paragraphs 1, 6, 7, 13, 14, 16, 20, 22, 26, 27, 28, 29, 31, 32, 34, 42, 44, 49 and 51 and defer all questions of law to this Honorable Court.
This action is barred by laches, unclean hands, bad faith, waiver, and estoppel.
Plaintiff’s claims are barred by the way of documentary evidence and under the terms of the controlling agreements, and other governing documents, rules, and any amendments thereto.
The plaintiff published or communicated to third persons false statements purporting them to be facts, which caused harm to defendant SARA MALAGOLD’s reputation.
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THIRD PARTY NOTICE OF APPEARANCE Third Party Summons and Complaint

Document Ravo Capital LLC v. Complete Neuropsychology, P.C. et al, 706466/2024, 7 (N.Y. Sup. Ct., Queens County Jul. 24, 2024)
Third-Party Defendant THE RYBAK FIRM, PLLC (“Rybak Firm”) is a domestic professional limited liability corporation registered to conduct business in the State of New York.
Defendants/Third-Party Plaintiffs engaged Third-Party Defendants, a law firm and attorneys with purported expertise in no-fault collection and litigation and financing agreement negotiations.
Thereafter, in 2021 Third-Party Defendants represented Defendants/Third- Party plaintiffs in connection with numerous settlement agreements with different insurance companies, including but not limited to GEICO, State Farm and Liberty Mutual (“Settlement Agreements”).
Because of that breach, the Defendants/Third P{arty Plaintiffs have incurred substantial legal costs and can eventually be liable for the relief requested in Ravo’s Complaint.
Eitan Magendzo, an attorney duly admitted to practice in the Courts of this State, affirms the following to be true under the penalties of perjury:
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SUMMONS + COMPLAINT

Document Ravo Capital LLC v. Complete Neuropsychology, P.C. et al, 706466/2024, 1 (N.Y. Sup. Ct., Queens County Mar. 26, 2024)
Plaintiff RAVO CAPITAL LLC (“Ravo”), by their attorneys Jacobs Law, P.C., brings this action against Defendants COMPLETE NEUROPSYCHOLOGY, P.C. (“Complete Neuro”), FULL PSYCHOLOGY, P.C. (“Full Psychology”), and SARA MALAGOLD (“Dr.
To the extent Ravo failed to perform any of its contractual obligations, its failure to do so was directly caused by Complete Neuro and Dr. Malagold’s willful breach, misconduct, and bad faith.
To the extent Ravo failed to perform any of its contractual obligations, its failure to do so was directly caused by Full Psychology and Dr. Malagold’s willful breach, misconduct, and bad faith.
On the 1st, 3rd, and 5th causes of action, awarding Ravo compensatory damages jointly and severally against Complete Neuro and Dr. Malagold in an amount to be determined at trial, but in no event less than $646,494.12;
On the 2nd, 4th, and 6th causes of action, awarding Ravo compensatory damages jointly and severally against Full Psychology and Dr. Malagold in an amount to be determined at trial, but in no event less than $1,160,430.70; and
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AFFIRMATION/AFFIDAVIT OF SERVICE Michael Kroopnick

Document Ravo Capital LLC v. Complete Neuropsychology, P.C. et al, 706466/2024, 8 (N.Y. Sup. Ct., Queens County Sep. 24, 2024)
NOTARYPUBLIC State of NewYork No.01RO6340662 in Nassau County Qualified Commission Expires April 18, 2028
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AFFIRMATION/AFFIDAVIT OF SERVICE Rybak Firm

Document Ravo Capital LLC v. Complete Neuropsychology, P.C. et al, 706466/2024, 10 (N.Y. Sup. Ct., Queens County Sep. 24, 2024)
NOTARYPUBLIC State of NewYork No.01RO6340662 in Nassau County Qualified Commission Expires April 18, 2028
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AFFIRMATION/AFFIDAVIT OF SERVICE Oleg Rybak

Document Ravo Capital LLC v. Complete Neuropsychology, P.C. et al, 706466/2024, 9 (N.Y. Sup. Ct., Queens County Sep. 24, 2024)
FILED: QUEENS COUNTY CLERK 09/24/2024 10:16 PM NYSCEF DOC. NO. 9 INDEX NO. 706466/2024 RECEIVED NYSCEF: 09/24/2024 AFFIDAVIT OF SUBSTITUTESERVICE STATEMENTPURSUANTTO RULE 3402 & THIRD PARTYSUMMONS& THIRD PARTYCOMPLAINT& NOTICE OF ELECTRONICFILING INDEX NUMBER706466/2024 #
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