`NYSCEF DOC. NO. 7
`Print or type, doubb sp.cod, raing bhdr ink only.
`SUPREME COURTOFTHE STATE OF NEWYORX
`COUNTYOFNEWYORK
`
`INDEX NO. 656025/2023
`
`RECEIVED NYSCEF: 01/22/2024
`
`IHL Group lnc
`[fill in neme(s)l
`
`Roger Cabello
`[fill in name(s[
`
`- against-
`
`Plaintiff(s),
`
`Defendant(s).
`
`lndex. umber
`65N25t2023
`
`ANS!1/ER
`
`Roger Cabello
`
`1,4, 10
`
`As and for his / her ansurer to the @nphint herein, the defendant,
`rcspectfully shours and alhgies as fullolw [number lopantg
`pei.gr.phr bolowl:
`A . nOrnit" tt. tuttr of the allegation(s) of paragraph(s)
`of the complaint.
`_L Dailes knwredge or infomation suffcbnt to fom a berief as to the truth of the
`
`9, 14, 16
`
`albgation(s) of Paragraph(s)
`-comp[bint.
`the
`1l . O"ni", the allegations of paragraph(s)
`21,22,23,24,25,26,27,28
`of the complaint.
`
`2,3,5,6,7,8,1 1,1 2,1 3,1 5,1 7,1 8,1 9,20
`
`of
`
`Affirmative O€fenseg
`
`Number 1 - Admits the truth
`Number 2 -.D.enies the a egation. I do not live in crifton nor in the county of passaic
`I live in Cliffwood, NJ in Mounmouth County
`Number 3 -Denies the allegation. There is no agreement submitted, plaintiff failed to
`provide the court witht the signed estimate with the terms of the agreement.
`- As shown in Exhibit A.
`Number 4 - Admits the truth but the plaintiff left out the second outslanding unpaid
`invoice - As shown in Exhibit B.
`And Plaintiff failed to fund project on time as per signed estimate.
`Number 5 -Denies the allegation. Jason wu cancefied the production of those bags,
`Jason wu informed Roger cabeflo, during production that the oags me-ntioneo
`on allegation 6, did not pass the eVC quarity test, had been cancErted andJio
`not have to be produced.
`Number 6 - Denies the aflegation. Jason wu cance[ed the production of those bags,
`Jason wu informed Roger cabe[o, during production that the bags meitioned
`on afiegation 6, did not pass the oVC quarity test, had been cancefied and did
`nol have to be produced.
`Number 7 - Denies the allegation.
`Number 8 - Denies the allegation.
`
`1 .07 lS
`
`1 of 3
`
`
`
`FILED: NEW YORK COUNTY CLERK 01/22/2024 04:33 PM
`NYSCEF DOC. NO. 7
`
`INDEX NO. 656025/2023
`
`RECEIVED NYSCEF: 01/22/2024
`
`AffirmeWe Defenses
`Number I - Denies knowledge or information sufficient to form a belief as to the
`truth of the allegations.
`Number 10 - Admits the truth But the Plaintiff has violated the agreement 2 times.
`Plaintiff falied to fund project on time as slated on the signed
`estimate. Listed under term number 2.
`Plaintiff has violated the copyrights granted 2 times. As shown on
`Exhibit C
`Number 11 - Denies the alleoation.
`
`Bie,W oi ,ga t a?rt Prv Y
`
`Number 12 - Denies the allegation. the Plaintiff falied to paid all invoces.
`The only explanation for the unpaid invoice, has been by Jason Wu,
`who stated that they had almost gone out of business 2 timess last
`year and they had no money.
`
`Number 1 3 - Dlnies the ane#;': " -'d I €.+. yr' 0 F rti P P (u o,{7
`Number 14 - Denies knowledge or infoniration sufficient t6 foim a belief as to the
`truth of the allegations.
`Number 1 5 - Denies the allegation.
`E A?l-ct-rt 0/=./ 6qe".ut zz,/
`--.
`
`Number'16 - Denies knowledfe or information sufficient to fornf a belief as to the
`truth of the allegations.
`0 rze
`N VO.CE
`Pe Mr e/)
`pp Q+cn e,)
`
`n,.dh ?€.r/t€/74
`
`f
`A'iu e € dL e/4 7'
`
`Number 17 -
`
`Number 18 -
`
`Number 1 9 -
`
`Number 20 -
`
`TNF
`
`af{ vft I
`
`f-l=
`
`{. ta
`
`Number 21
`
`Number 22 -
`
`Number 23 -
`
`Number 24 -
`
`Number 25 -
`
`Number 26 -
`
`Number 27 -
`
`Number 28 -
`
`2 0f /J>
`
`2 of 3
`
`
`
`FILED: NEW YORK COUNTY CLERK 01/22/2024 04:33 PM
`NYSCEF DOC. NO. 7
`
`INDEX NO. 656025/2023
`
`RECEIVED NYSCEF: 01/22/2024
`
`WHEREFORE, defendant prays that this court dismiss the complaint of the plaintiff herein, with
`costs and disbursements to defendant, together with any other relief the Court finds to be just
`and proper.
`Dated:
`
`Jan 22nd , 20
`
`24
`
`Signature
`
`Roger Cabello
`Print name
`
`197 County RD
`
`CUffwood NJ 07721
`
`917-7't4-1757
`Address and Telephone Number
`
`VERIFICATION
`
`STATE OF NEWYORK
`
`66y117y 6p New York
`Roger Cabello
`
`""'
`
`being duly swom, deposes and says:
`
`I am th€/a defendant in the abov+€ntitled astion. I have read the foregoing answer and know
`
`the contents thereof. The same are true to my knowledge, except as to matters therein stated to be
`
`alleged on information and belief, and as to those matters, I believe them to be true.
`
`-Zi4-
`@-ou, n"iin rront or a xotaryl
`lL
`[print your name]
`
`Sworn to before me this
`ziL-4ay ot
`
`Notary Public
`
`I-ISA KING
`Notary P0bli€, State of New York
`Fep N
`o.04K10013921
`n New York
`Commission Expires Scpt.is:tfu
`Qualified i
`
`JAN 2 .1024
`
`3 oF/5-
`
`3 of 3
`
`
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