Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 06/23/2022
"B"
EXHIBIT
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC.SARATOGA
NO. 37 RECEIVEDINDEXNYSCEF:
NO. 06/23/2022
EF20212538
FILED: COUNTY CLERK 10/19/2021 0 6 : 0 6 PM|
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",
"10"
"9", , "11", "12", "13", "15", "16", "17", "18", "19", "20", "21", "22", "23", "24", "26",
"33"
"27", "28", "29", "30", "31", "32",
2. Defendant denies knowledge and information sufficient to form a belief as to the allegations
"5"
contained in paragraphs "1", "4",
3. Defendant denies each and every allegation contained in paragraphs "14", "25", "34", "35",
"43"
"36", "37", "38", "39", "40", "41", "42",
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FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC.SARATOGA
NO. 37 RECEIVEDINDEXNYSCEF:
NO. EF20212538
06/23/2022
(FILED: COUNTY CLERK 10/19/2021 0 6 : 0 6 PM|
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 10/19/2021
AS AND FOR A FIRST AFFIRMATIVE DEFENSE
4. The Complaint failsto state a cause of action upon which reliefcan 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 itsentirety 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 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF
FILED: DOC. SARATOGA
NO. 37 COUNTY CLERK 10/19/2021 06:06 RECEIVED INDEXNYSCEF:
NO. 06/23/2022
EF20212538
PM|
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 arethe Defendants inthe above action
entitled and that the foregoing Answer
they
is truetotheirown knowledge, except as tothose matters hereinstatedto be alleged on
information and behef and as tothose matters,they believethernto be true
YASMIN NURANI BADRUDIN ZAHARAH BADRUDTN
Sworn 15th
beforeme this day of October 15, 2021
NOTARY PUBLIC
RONALD GREGORY F o
MTARY ITE r%Q N
PUBLICIN THE STATEOF
ED IN SARATOGACO NL V YCf
Aff COMMISSON NO 01PAb262D/b
EXPiRESMAY20 20
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Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 06/23/2022 "B" EXHIBIT FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC.SARATOGA NO. 37 RECEIVEDINDEXNYSCEF: NO. 06/23/2022 EF20212538 FILED: COUNTY CLERK 10/19/2021 0 6 : 0 6 PM| 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", "10" "9", , "11", "12", "13", "15", "16", "17", "18", "19", "20", "21", "22", "23", "24", "26", "33" "27", "28", "29", "30", "31", "32", 2. Defendant denies knowledge and information sufficient to form a belief as to the allegations "5" contained in paragraphs "1", "4", 3. Defendant denies each and every allegation contained in paragraphs "14", "25", "34", "35", "43" "36", "37", "38", "39", "40", "41", "42", 1 of 3 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC.SARATOGA NO. 37 RECEIVEDINDEXNYSCEF: NO. EF20212538 06/23/2022 (FILED: COUNTY CLERK 10/19/2021 0 6 : 0 6 PM| NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 10/19/2021 AS AND FOR A FIRST AFFIRMATIVE DEFENSE 4. The Complaint failsto state a cause of action upon which reliefcan 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 itsentirety 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 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF FILED: DOC. SARATOGA NO. 37 COUNTY CLERK 10/19/2021 06:06 RECEIVED INDEXNYSCEF: NO. 06/23/2022 EF20212538 PM| 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 arethe Defendants inthe above action entitled and that the foregoing Answer they is truetotheirown knowledge, except as tothose matters hereinstatedto be alleged on information and behef and as tothose matters,they believethernto be true YASMIN NURANI BADRUDIN ZAHARAH BADRUDTN Sworn 15th beforeme this day of October 15, 2021 NOTARY PUBLIC RONALD GREGORY F o MTARY ITE r%Q N PUBLICIN THE STATEOF ED IN SARATOGACO NL V YCf Aff COMMISSON NO 01PAb262D/b EXPiRESMAY20 20 3 of 3