[ ] Tort[ ] Motor vehicle ] Medical ] Other [ [ negligence malpractice tort [ X ] Contract ] Contested [ } Uncontested [ Tax certiorari [ Condemnation [ Other (not [ matrimonial matrimonial itemized above) specify Special preference under claimed on the ground that for Plaintiff(s) Attorney(s) & P.O.

Clerk will note of unless by a certifkate not accept this issue acc:n;::!sd readiñêss.

Medical reports exchanged Appraisal reports exchanged Compliance with the Rules in matrimonial actions Discovery proceedings to be completed pursuant There are no nutstanding requests for discovery.

If a medical nialpractice action, there has been conipliance with any order issued pursuañt to 22 NYCRR 202.56.

Address Office -- type name Signature David Gise, Esq. below.

Pro Se, separating herself from all other Defendants hereby answers the Plaintiff's complaint as follows: Defendant generally denies each and every allegation contained in the Complaint and each cause of action set down therein and denies that Plaintiff sustained damages in any and all such sums sums alleged or in any other at all.

For a Fourth and Separate Affirmative Defense to the Complaint on file herein, and to and cause of action set down this Defendant Plaintiff each every therein, answering alleges that engaged in conduct and activities by reason of which Plaintiff is equitably estopped to assert any alleged claims or demands against this answering Defendant.

For a Fifth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant alleges that Plaintiff engaged in conduct and activities tainted with bad faith by reason of which Plaintiff should not permitted to use processes of for further of bad be the this court instances faith.

For a Ninth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering defendant alleges that if Plaintiff suffered any loss, damage or injury and this is expressly denied, such damage was the direct and of omissions of or of this proximate result the acts or others and not the acts omissions answering Defendant.

For and Tenth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant reserves her right to amend this Answer to add other applicable and pertinent Affirmative any Defense not otherwise listed.

Pro Se, separating himself from all other Defendants hereby answers the Plaintiff's complaint as follows: Defendant generally denies each and every allegation contained in the Complaint and each cause of action set down therein and denies that Plaintiff sustained damages in any and all sums alleged or in any other such sums at all.

For a Fourth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant alleges that Plaintiff engaged in conduct and activities by reason of which Plaintiff is equitably estopped to assert any claims or demands against this Defendant.

For a Fifth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant alleges that Plaintiff engaged in conduct and activities tainted with bad faith by reason of which Plaintiff should not be permitted to use the processes of this court for further instances of bad faith.

For a Ninth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering defendant alleges that if Plaintiff suffered any loss, damage or injury and this is expressly denied, such damage was the direct and result of or omissions not the acts or omissions of this proximate Defendant.

For and Tenth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant reserves her right to amend this Answer to add any other applicable and pertinent Affirmative Defense not otherwise listed.

Pro Se, separating herself from all other Defendants hereby answers the Plaintiff's complaint as follows: Defendant generally denies each and every allegation contained in the Complaint and each cause of action set down therein and denies that Plaintiff sustained damages in any and all sums alleged or in any other such sums at all.

For a First and Separate Affirmative Defense to the Complaint on file herein, and to each alleged cause of action set down therein, this answering defendant alleges that the Complaint, and each purported cause of action therein fails to state facts sufficient to constitute

For a Fourth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant alleges that Plaintiff engaged in conduct and activities by reason of which Plaintiff is equitably estopped to assert any alleged claims or demands against this answering Defendant.

a Fifth and Affirmative Defense to the file herein, and to each and every cause of action set down therein, this answering Defendant alleges that Plaintiff engaged in conduct and activities tainted with bad faith by reason of which Plaintiff should not be permitted to use the processes of this court for further instances of bad faith.

For a Ninth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering defendant alleges that if Plaintiff suffered any loss, damage or injury and this is expressly denied, such damage was the direct and proximate result of the acts or omissions of others and not the acts or omissions of this Defendant.

upon the Complaint, service, Affirmation of David Gise, duly affirmed on April 30, 2019, and the exhibits annexed thereto, and upon the Affirmation in Opposition of Leonard Gretah, duly affirmed on June 7, 2019, and the Affidavit in Opposition of Argiritsa Kirschner, duly sworn to on June 7, 2019, and the Todd sworn on and exhibits Affidavit in Opposition of Kirschner, duly to June 7, 2019, the thereto, and upon written order of this Court, dated August 15, 2019 and entered by the Clerk of Nassau County on August 22, 2019 (the "Order"), granting default judgment in favor of Plaintiff and against the Corporate Defendants and awarding Plaintiff

a judgment in favor Plaintiff against Atek for liability on the Ninth Cause of Action; and the Order with notice of of entry having been duly served upon the Corporate Defendants;

Old Country Road, Plainview, New York, and do recover from defendant Plainview Hardware, Inc. the sum of Thirty Six Thousand Eight Hundred Ninety Dollars and Ninety Cents ($36,890.98), plus interest from 31, 2018 through , at 9% per annum, in July the amount of , making a total of , and that Plaintiff shall have execution therefor; and it is further

that Plaintiff's Second Cause of Action based on the recovery of reasonable attorneys' fees and costs is hereby severed and an assessment thereof is directed; and it is further

$200.00 $200.00 David state Gise, under to practice licensed law duly at an attorney to CPLR pursuant of perjury, penalty § 2106, in the State as follows: hereby of New York, does I am counsel to the Morton Village are statements plaintiff, foregoing law firm Realty true, Co., under of RIVKIN in the penalties Inc., the

days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the Complaint.

is, and at all times hereinafter mentioned was, a corporation duly organized and existing by virtue of the laws of the State of New York, and has a last known place of business located at

Old Road, Plainview, New York 11803 in the Center ("Premises") Country Shopping pursuant to a written Lease, dated May 12, 1997, between Plaintiff, as landlord, and Hardware

As set forth above, upon information and belief, the transfer of the stock and inventory, assets, good will, and the equipment was made without fair, due, and adequate consideration.

As set forth above, upon information and belief, the transfer of the stock, inventory, assets, good will and the equipmeñt was made without fair, due, and adequate consideration.

request) Counselor: The above referenced action has been scheduled for

a DCM Case No motions Coordinator be made are to prior to without the PC date.

Service prior authorization may of The Failure being appear to ordered in may your result absence.

in the imposition of sanctions and a case management plan the

At Preliminary review for by removed the be must counsel the of bills Conference, a determination so court, pursuant Court of complaint County copy for particulars may to CPLR chamber's medical and be made 325(d).