Preview
FILED: QUEENS COUNTY CLERK 04/29/2018 09:09 PM INDEX NO. 703508/2018
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 04/29/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
ISRAEL EXPERIENCE TIDE, INC., Index No.: 703508/2018
Plaintiff,
VERIFIED ANSWER WITH
-against- COUNTERCLAIM
EDUARD PINCHASOW, EDUARD
PINCHASOW, and DANIEL PINCHASOW,
Defendants.
Defendants, by their attorney, Ariel Aminov, Esq., answer the Verified Complaint, as as
follows:
1. Deny any knowledge or information sufficient to form a belief as to each and every
allegation contained in the paragraph of the Verified Complaint numbered "1".
2. Admit the allegations contained in the paragraph of the Verified Complaint numbered "2".
3. Admit the allegations contained in the paragraph of the Verified Complaint numbered "3".
"4"
4. Deny the allegation contained in the paragraph of the Verified Complaint numbered as it
calls for a legal conclusion and refer allquestions of law to the Court.
5. Deny any knowledge or information sufficient to form a belief as to each and every
allegation contained in the paragraph of the Verified Complaint numbered "5", as they call
for legal conclusion and refer allquestions of law to the Court.
6. Deny any knowledge or information sufficient to form a belief as to each and every
allegation contained in the paragraph of the Verified Complaint numbered "6", as they call
for legal conclusion and refer allquestions of law to the Court. Defendants further deny the
allegations relating to the amounts paid and owed.
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7. Deny any knowledge or information sufficient to form a belief as to each and every
allegation contained in the paragraph of the Verified Complaint numbered "7", as they call
for legal conclusion and refer allquestions of law to the Court. Defendants further deny the
allegations relating to the amounts paid and owed.
8. Deny any knowledge or information sufficient to form a belief as to each and every
allegation contained in the paragraph of the Verified Complaint numbered "8".
AS AND FOR A FIRST AFFIRMATIVE DEFENSE
9. This Court lacks jurisdiction over the instant matter, pursuant to New York City Civil Court
Act § 202.
AS AND FOR A SECOND AFFIRMATIVE DEFENSE
10. Defendants paid in excess of the amounts alleged in the Verified Complaint.
AS AND FOR A THIRD AFFIRMATIVE DEFENSE
11. Defendants have not received the services bargained-for.
AS AND FOR A FIRST COUNTERCLAIM AGAINST PLAINTIFF
FOR BREACH OF CONTRACT
12. Defendants repeat, reiterate, renew and realleges all the foregoing allegations contained
in all the paragraphs set forth above, with the same force and effect as though fully set
forth at length herein.
13. Without admitting the existence of any contract or the validity thereof, while Defendants
performed their obligations of payment and enrollment in an educational curriculum in the
State of Israel, Plaintiff failed and/or refused to perform its obligations under such
agreements, by terminating Plaintiff DANIEL PINCHASOW s enrollment without cause,
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conduct which resulted in damages to Defendants in the amount of at least $10,556.00,
exclusive of costs and interest.
WHEREFORE, Defendants demand judgment dismissing the Verified Complaint, and
judgment in the amount of $10,566.00 on the First Counterclaim, together with the costs and
disbursements of this action.
Dated: April 29, 2018
Islip, New York
Ariel Aminov, Esq.
ARIEL AMINOV, PLLC
Attorneys for Defendants
670 Main Street
Islip, NY 11751
Tel: 631-446-4411
Our File No.: LIT185
To:
LAW OFFICES OF DANIEL FRIEDMAN, ESQ.
Of Counsel to LAW OFFICES OF JUDAH SEPTIMUS, ESQ.
Attorneys for Plaintiffs
186
5417 18 Avenue
Brooklyn, NY 11204
Tel: 917-406-8568
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
ISRAEL EXPERIENCE TIDE, INC., Index No.: 703508/2018
Plaintiff,
VERIFICATION
-against-
EDUARD PINCHASOW, EDUARD PINCHASOW,
and DANIEL PINCHASOW,
Defendants.
ARIEL AMINOV, ESQ. an attorney duly admitted to practice law before the Courts of
the State of New York, affirm as follows:
I am the attorney for Defendants herein and as such am familiar with the facts and
circumstances described in the Verified Answer. I have read the foregoing Verified Answer and
know the contents thereof. The contents are true to my own knowledge, except as to matters
therein stated to be alleged upon information and belief, and as to those matters I believe them to
be true. The bases of my claimed knowledge are a review of the filedocuments currently in my
possession and from my conversations with Defendants.
The reason I make this verification is due to the fact that Defendants reside outside the
county wherein I maintain my office.
Dated: April 29, 2018
Islip, New York
Ariel Aminov, Esq.
ARIEL AMINOV, PLLC
Attorneys for Defendants
670 Main Street
Islip, NY 11751
Tel: 631-446-4411
Our File No.: LIT185
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
ISRAEL EXPERIENCE TIDE, INC., Index No.: 703508/2018
Plaintiff,
AFFIRMATION OF SERVICE
-against-
EDUARD PINCHASOW, EDUARD PINCHASOW,
and DANIEL PINCHASOW,
Defendants.
Ariel Aminov, an attorney duly admitted to practice law before the Courts of the State of
New York, affirms as follows:
That on April 28, 2018, I served a true copy of the annexed ANSWER WITH
COUNTERCLAIM by e-filing and by mailing the same in a sealed envelope, with postage
prepaid, thereon, in a post office or official depository of the US Postal Service within the State
of New York, addressed to the last known address of the addressee as indicated below:
To:
LAW OFFICES OF DANIEL FRIEDMAN, ESQ.
Of Counsel to LAW OFFICES OF JUDAH SEPTIMUS, ESQ.
Attorneys for Plaintiffs
186
5417 18 Avenue
Brooklyn, NY 11204
Tel: 917-406-8568
Dated: April 29, 2018
Islip, New York
Ariel Aminov, Esq.
ARIEL AMINOV, PLLC
Attorneys for Defendants
670 Main Street
Islip, NY 11751
Tel: 631-446-4411
Our File No.: LIT185
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NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 04/29/2018
Index No.: 703508/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
Plaintiff,
ISRAEL EXPERIENCE TIDE, INC.,
Plaintiff,
-against-
EDUARD PINCHASOW, EDUARD
PINCHASOW, and DANIEL PINCHASOW,
Defendants.
VERIFIED ANSWER WITH COUNTERCLAIM
ARIEL AMINOV, PLLC
Attorneys for Defendants
670 Main Street
Islip,NY 11751
Tel: 631-446-4411
Our File No.: LIT185
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney duly admitted to practice in the
courts of New York State, certifies that, upon information and belief and rea onable inquiry, the
contentions contained in the annexed documents are not frivolo s.
Dated: April 29, 2018 Sig
Print Signer 'sName: Ariel Aminov
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Preview
FILED: QUEENS COUNTY CLERK 04/29/2018 09:09 PM INDEX NO. 703508/2018 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 04/29/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ISRAEL EXPERIENCE TIDE, INC., Index No.: 703508/2018 Plaintiff, VERIFIED ANSWER WITH -against- COUNTERCLAIM EDUARD PINCHASOW, EDUARD PINCHASOW, and DANIEL PINCHASOW, Defendants. Defendants, by their attorney, Ariel Aminov, Esq., answer the Verified Complaint, as as follows: 1. Deny any knowledge or information sufficient to form a belief as to each and every allegation contained in the paragraph of the Verified Complaint numbered "1". 2. Admit the allegations contained in the paragraph of the Verified Complaint numbered "2". 3. Admit the allegations contained in the paragraph of the Verified Complaint numbered "3". "4" 4. Deny the allegation contained in the paragraph of the Verified Complaint numbered as it calls for a legal conclusion and refer allquestions of law to the Court. 5. Deny any knowledge or information sufficient to form a belief as to each and every allegation contained in the paragraph of the Verified Complaint numbered "5", as they call for legal conclusion and refer allquestions of law to the Court. 6. Deny any knowledge or information sufficient to form a belief as to each and every allegation contained in the paragraph of the Verified Complaint numbered "6", as they call for legal conclusion and refer allquestions of law to the Court. Defendants further deny the allegations relating to the amounts paid and owed. 1 of 6 FILED: QUEENS COUNTY CLERK 04/29/2018 09:09 PM INDEX NO. 703508/2018 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 04/29/2018 7. Deny any knowledge or information sufficient to form a belief as to each and every allegation contained in the paragraph of the Verified Complaint numbered "7", as they call for legal conclusion and refer allquestions of law to the Court. Defendants further deny the allegations relating to the amounts paid and owed. 8. Deny any knowledge or information sufficient to form a belief as to each and every allegation contained in the paragraph of the Verified Complaint numbered "8". AS AND FOR A FIRST AFFIRMATIVE DEFENSE 9. This Court lacks jurisdiction over the instant matter, pursuant to New York City Civil Court Act § 202. AS AND FOR A SECOND AFFIRMATIVE DEFENSE 10. Defendants paid in excess of the amounts alleged in the Verified Complaint. AS AND FOR A THIRD AFFIRMATIVE DEFENSE 11. Defendants have not received the services bargained-for. AS AND FOR A FIRST COUNTERCLAIM AGAINST PLAINTIFF FOR BREACH OF CONTRACT 12. Defendants repeat, reiterate, renew and realleges all the foregoing allegations contained in all the paragraphs set forth above, with the same force and effect as though fully set forth at length herein. 13. Without admitting the existence of any contract or the validity thereof, while Defendants performed their obligations of payment and enrollment in an educational curriculum in the State of Israel, Plaintiff failed and/or refused to perform its obligations under such agreements, by terminating Plaintiff DANIEL PINCHASOW s enrollment without cause, 2 of 6 FILED: QUEENS COUNTY CLERK 04/29/2018 09:09 PM INDEX NO. 703508/2018 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 04/29/2018 conduct which resulted in damages to Defendants in the amount of at least $10,556.00, exclusive of costs and interest. WHEREFORE, Defendants demand judgment dismissing the Verified Complaint, and judgment in the amount of $10,566.00 on the First Counterclaim, together with the costs and disbursements of this action. Dated: April 29, 2018 Islip, New York Ariel Aminov, Esq. ARIEL AMINOV, PLLC Attorneys for Defendants 670 Main Street Islip, NY 11751 Tel: 631-446-4411 Our File No.: LIT185 To: LAW OFFICES OF DANIEL FRIEDMAN, ESQ. Of Counsel to LAW OFFICES OF JUDAH SEPTIMUS, ESQ. Attorneys for Plaintiffs 186 5417 18 Avenue Brooklyn, NY 11204 Tel: 917-406-8568 3 of 6 FILED: QUEENS COUNTY CLERK 04/29/2018 09:09 PM INDEX NO. 703508/2018 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 04/29/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ISRAEL EXPERIENCE TIDE, INC., Index No.: 703508/2018 Plaintiff, VERIFICATION -against- EDUARD PINCHASOW, EDUARD PINCHASOW, and DANIEL PINCHASOW, Defendants. ARIEL AMINOV, ESQ. an attorney duly admitted to practice law before the Courts of the State of New York, affirm as follows: I am the attorney for Defendants herein and as such am familiar with the facts and circumstances described in the Verified Answer. I have read the foregoing Verified Answer and know the contents thereof. The contents are true to my own knowledge, except as to matters therein stated to be alleged upon information and belief, and as to those matters I believe them to be true. The bases of my claimed knowledge are a review of the filedocuments currently in my possession and from my conversations with Defendants. The reason I make this verification is due to the fact that Defendants reside outside the county wherein I maintain my office. Dated: April 29, 2018 Islip, New York Ariel Aminov, Esq. ARIEL AMINOV, PLLC Attorneys for Defendants 670 Main Street Islip, NY 11751 Tel: 631-446-4411 Our File No.: LIT185 4 of 6 FILED: QUEENS COUNTY CLERK 04/29/2018 09:09 PM INDEX NO. 703508/2018 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 04/29/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ISRAEL EXPERIENCE TIDE, INC., Index No.: 703508/2018 Plaintiff, AFFIRMATION OF SERVICE -against- EDUARD PINCHASOW, EDUARD PINCHASOW, and DANIEL PINCHASOW, Defendants. Ariel Aminov, an attorney duly admitted to practice law before the Courts of the State of New York, affirms as follows: That on April 28, 2018, I served a true copy of the annexed ANSWER WITH COUNTERCLAIM by e-filing and by mailing the same in a sealed envelope, with postage prepaid, thereon, in a post office or official depository of the US Postal Service within the State of New York, addressed to the last known address of the addressee as indicated below: To: LAW OFFICES OF DANIEL FRIEDMAN, ESQ. Of Counsel to LAW OFFICES OF JUDAH SEPTIMUS, ESQ. Attorneys for Plaintiffs 186 5417 18 Avenue Brooklyn, NY 11204 Tel: 917-406-8568 Dated: April 29, 2018 Islip, New York Ariel Aminov, Esq. ARIEL AMINOV, PLLC Attorneys for Defendants 670 Main Street Islip, NY 11751 Tel: 631-446-4411 Our File No.: LIT185 5 of 6 FILED: QUEENS COUNTY CLERK 04/29/2018 09:09 PM INDEX NO. 703508/2018 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 04/29/2018 Index No.: 703508/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Plaintiff, ISRAEL EXPERIENCE TIDE, INC., Plaintiff, -against- EDUARD PINCHASOW, EDUARD PINCHASOW, and DANIEL PINCHASOW, Defendants. VERIFIED ANSWER WITH COUNTERCLAIM ARIEL AMINOV, PLLC Attorneys for Defendants 670 Main Street Islip,NY 11751 Tel: 631-446-4411 Our File No.: LIT185 Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney duly admitted to practice in the courts of New York State, certifies that, upon information and belief and rea onable inquiry, the contentions contained in the annexed documents are not frivolo s. Dated: April 29, 2018 Sig Print Signer 'sName: Ariel Aminov 6 of 6