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FILED: SARATOGA COUNTY CLERK 10/19/2021 06:06 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 10/19/2021
STATE OF NEW YORK
SUPREME COURT COUNTY OF SARATOGA
CANNONE VENTURES, INC. VERIFIED ANSWER
TO COMPLAINT
INDEX NO.: EF20212538
Plaintiff,
-against-
YASMIN NURANI BADRUDDIN a/k/a
YASMIN NURANI, YASMIN NURANI KADERALI
BADRUDDIN and ZAHARAH BADRUDIN
Defendants
________________________________________________________________________
Defendants ZAHARAH BADRUDIN and YASMIN NURANI BADRUDDIN as and for an Answer to
the Complaint in this action, alleges as follows:
1. Defendant admits each and every allegation contained in paragraphs “2”, “3”, “6”, “7”, “8”,
“9”, “10” , “11”, “12”, “13”, “15”, “16”, “17”, “18”, “19”, “20”, “21”, “22”, “23”, “24”, “26”,
“27”, “28”, “29”, “30”, “31”, “32”, “33”
2. Defendant denies knowledge and information sufficient to form a belief as to the allegations
contained in paragraphs “1”, “4”, “5”
3. Defendant denies each and every allegation contained in paragraphs “14”, “25”, “34”, “35”,
“36”, “37”, “38”, “39”, “40”, “41”, “42”, “43”
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FILED: SARATOGA COUNTY CLERK 10/19/2021 06:06 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 10/19/2021
AS AND FOR A FIRST AFFIRMATIVE DEFENSE
4. The Complaint fails to state a cause of action upon which relief can be granted.
AS AND FOR A SECOND AFFIRMATIVE DEFENSE
5. The complaint fails to name a necessary party.
AS AND FOR A THIRD AFFIRMATIVE DEFENSE
6. The Court lacks personal jurisdiction over Defendants due to improper personal service.
WHEREFORE, Defendants respectfully demands the following:
A) An Order dismissing Plaintiff's Complaint in its entirety with prejudice;
B) An award of reasonable fees, cost and disbursement in favor of Defendant; and
C) An award for such other and further relief which seems just and proper to the Court.
Dated 10/15/2021
_____________________________________
Zaharah Badrudin
Defendant
22 Elizabeth Lane
Queensbury, NY, 12804
_____________________________________
Yasmin Nurani Badruddin
Defendant
22 Elizabeth Lane
Queensbury, NY, 12804
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FILED: SARATOGA COUNTY CLERK 10/19/2021 06:06 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 10/19/2021
VERIFICATION
STATE OF NEW YORK }
:ss
COUNTY OF SARATOGA }
ZAHARAH BADRUDIN AND YASMIN NURANI BADRUDDIN, being duly sworn deposes
and says that are the Defendants in theabove entitledaction and that the foregoing Answer
they
istrue to theirown 101 vviedp,c,except as tothose matters herein stated to be alleged on
infarmation and belief and as to thosematters, they believe them to be true.
YASMIN NURANI BADRUDIN ZAHARAH BADRUDIN
15th
Sworn before me this day of October 15,2021
NOTARY PUBLIC
RONALD GREGORY
ETrARY PUBLICIN THE PATTERSON
STATEOF NEW YORK
)ALFED IN SARATOGA
MY COMMISSION CO., NO. 01PA6282076
EXPIRESMAY20, 2Q
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FILED: SARATOGA COUNTY CLERK 10/19/2021 06:06 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 10/19/2021 STATE OF NEW YORK SUPREME COURT COUNTY OF SARATOGA CANNONE VENTURES, INC. VERIFIED ANSWER TO COMPLAINT INDEX NO.: EF20212538 Plaintiff, -against- YASMIN NURANI BADRUDDIN a/k/a YASMIN NURANI, YASMIN NURANI KADERALI BADRUDDIN and ZAHARAH BADRUDIN Defendants ________________________________________________________________________ Defendants ZAHARAH BADRUDIN and YASMIN NURANI BADRUDDIN as and for an Answer to the Complaint in this action, alleges as follows: 1. Defendant admits each and every allegation contained in paragraphs “2”, “3”, “6”, “7”, “8”, “9”, “10” , “11”, “12”, “13”, “15”, “16”, “17”, “18”, “19”, “20”, “21”, “22”, “23”, “24”, “26”, “27”, “28”, “29”, “30”, “31”, “32”, “33” 2. Defendant denies knowledge and information sufficient to form a belief as to the allegations contained in paragraphs “1”, “4”, “5” 3. Defendant denies each and every allegation contained in paragraphs “14”, “25”, “34”, “35”, “36”, “37”, “38”, “39”, “40”, “41”, “42”, “43” 1 of 3 FILED: SARATOGA COUNTY CLERK 10/19/2021 06:06 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 10/19/2021 AS AND FOR A FIRST AFFIRMATIVE DEFENSE 4. The Complaint fails to state a cause of action upon which relief can be granted. AS AND FOR A SECOND AFFIRMATIVE DEFENSE 5. The complaint fails to name a necessary party. AS AND FOR A THIRD AFFIRMATIVE DEFENSE 6. The Court lacks personal jurisdiction over Defendants due to improper personal service. WHEREFORE, Defendants respectfully demands the following: A) An Order dismissing Plaintiff's Complaint in its entirety with prejudice; B) An award of reasonable fees, cost and disbursement in favor of Defendant; and C) An award for such other and further relief which seems just and proper to the Court. Dated 10/15/2021 _____________________________________ Zaharah Badrudin Defendant 22 Elizabeth Lane Queensbury, NY, 12804 _____________________________________ Yasmin Nurani Badruddin Defendant 22 Elizabeth Lane Queensbury, NY, 12804 2 of 3 FILED: SARATOGA COUNTY CLERK 10/19/2021 06:06 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 10/19/2021 VERIFICATION STATE OF NEW YORK } :ss COUNTY OF SARATOGA } ZAHARAH BADRUDIN AND YASMIN NURANI BADRUDDIN, being duly sworn deposes and says that are the Defendants in theabove entitledaction and that the foregoing Answer they istrue to theirown 101 vviedp,c,except as tothose matters herein stated to be alleged on infarmation and belief and as to thosematters, they believe them to be true. YASMIN NURANI BADRUDIN ZAHARAH BADRUDIN 15th Sworn before me this day of October 15,2021 NOTARY PUBLIC RONALD GREGORY ETrARY PUBLICIN THE PATTERSON STATEOF NEW YORK )ALFED IN SARATOGA MY COMMISSION CO., NO. 01PA6282076 EXPIRESMAY20, 2Q 3 of 3