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EXHIBIT B
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
__ _________________________________________ -----x
CAROLYN DISBROW, VERIFIED
ANSWER WITH
Plaintiff, CROSS-CLAIMS
Index No.: 651602/2020
-against-
THE NORMANDIE CONDOMINIUM, THE
BOARD OF MANAGERS OF THE NORMANDIE
CONDOMINIUM, METRO MANAGEMENT &
DEVELOPMENT, INC., GLOBAL SOLUTIONS
APPLIANCE REPAIR INC., GLOBAL
SOLUTIONS APPLIANCE REPAIR NYC LLC,
HADAS A. JACOBI, BRIAN STRONG, AND
KERI STRONG,
Defendants.
------------------------------------------------------- ------------x
The Defendants, THE NORMANDIE CONDOMINIUM, THE BOARD OF
MANAGERS OF THE NORMANDIE CONDOMINIUM and METRO MANAGEMENT
& DEVELOPMENT, INC., by their attorneys, FIXLER & LAGATTUTA, LLP, answering the
verified complaint ofthe Plaintiffherein, respectfully alleges upon information and belief:
NATURE OF THE ACTION
1. Deny each and every allegation contained in the paragraph of Plaintiff's complaint
designated as follows:
"2"
"1", and "3".
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PARTIES
2. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"10"
"4", "8", "9", and "11".
3. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"6" "7"
"5", and
and respectfully refers allquestions of law raised therein to the trierof law and all questions of
fact to the trierof fact.
JURISDICTION AND VENUE
4. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"12"
and "13".
and respectfully refers allquestions of law raised therein to the trierof law and all questions of
fact to the trierof fact.
FACTUAL ALLEGATIONS
5. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"24", "25", "26", "27", "28", "29", "30", "31", "32", "33", "34", "35", "38", "41", "42",
"56"
"45", "46", "50", "55", and "57".
6. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"22" "53"
"15", "16", "17", "18", "19", "20", "21", and
and respectfully refers all questions of law raised therein to the trier of law and all questions of
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fact to the trierof fact.
7. Deny each and every allegation contained in the paragraphs of Plaintiff's complaint
designated as follows:
"14", "23", "32", "36", "37",."39", "40", "43", "44", "45", "47", "48", "49", "51", "52",
"54"
and "58".
FIRST CAUSE OF ACTION
(Breach of Contract Against Normandiel
"59"
8. In response to paragraph of Plaintiff's verified complaint, Defendant repeat,
"1" "58"
reiterate and reallege each and every response to paragraphs through as though more
fully set forth herein.
9. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"60"
and respectfully refers all questions of law raised therein to the trier of law and allquestions of
fact to the trierof fact.
10. Deny each and every allegation contained in the paragraphs of Plaintiff's
complaiñt designated as follows:
"64"
"61", "62", "63", and "65".
SECOND CAUSE OF ACTION
(Neeliscace Against Normsed½ and the Board)
"66"
11. In response to paragraph of Plaintiff's verified complaint, Defendant repeat,
"1" "65"
reiterate and reallege each and every response to paragraphs through as though more
fully set forth herein.
12. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"67"
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and respectfully refers all questions of law raised therein to the trier of law and all questions of
fact to the trierof fact.
13. Deny each and every allegation contained in the paragraphs of Plaintiff's
complaint designated as follows:
"70"
"68", "69", and "71".
THIRD CAUSE OF ACTION
{Breach of Fiduciary Duty Against the Board)
"72"
14. In response to paragraph of Plaintiff's verified complaint, Defendant repeat,
"1" "71"
reiterate and reallege each and every response to paragraphs through as though more
fully set forth herein.
15. Deny each and every allegation contained in the paragraphs of Plaintiff's
complaint designated as follows:
"74"
"73", and "75".
FOURTH CAUSE OF ACTION
(N_egligence Against Metrol
"76"
16. In response to paragraph of Plaintiff's verified complaint, Defendant repeat,
"1" "75"
reiterate and reallege each and every response to paragraphs through as though more
fully set forth herein.
17. Deny each and every allegation contained in the paragraphs of Plaintiff's
complaint designated as follows:
"80"
"77", "78", "79", and "81".
FIFTH CAUSE OF ACTION
(Negligence Against The GS Entities)
"82"
18. In response to paragraph of Plaintiff's verified complaint, Defendant repeat,
"1" "81"
reiterate and reallege each and every response to paragraphs through as though more
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fully set forth herein.
19. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"88"
"83", "84", "85", "86", "87", and "89".
SIXTH CAUSE OF ACTION
(Neali2êñce Against Jacobi)
"90"
20. In response to paragraph of Plaintiff's verified complaint, Defendant repeat,
"1" "89"
reiterate and reallege each and every response to paragraphs through as though more
fully set forth herein.
21. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in the paragraphs of the verified complaint designated as follows:
"95"
"91", "92", "93", "94", and "96".
SEVENTH CAUSE OF ACTION
(Breach of Contract Against the Strongs)
"97"
22. In response to paragraph of Plaintiff's verified complaint, Defendant repeat,
"1" "96"
reiterate and reallege each and every response to paragraphs through as though more
fully set forth herein.
23. Deny knowledge or information sufficient to form a belief as to the truth of each
and every allegation contained in theparagraphs of the verified complaint designated as follows:
"104"
"98", "99", "100", "101", "102", and "105".
AS AND FOR A FIRST SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
24. That damages, injury and/or injuries sustained by Plaintiff were caused in
any
whole or part the culpable conduct and fault attributable to the Plaintiff, including, but not
by
limited to, negligence and/or want of care, and/or the Plaintiff's assumption of the
contributory
risk, and the amount recovered, ifany, should be diminished pursuant to CPLR §1412 by the
proportion which the culpable conduct attributed to the Plaintiff bear to the culpable conduct
which caused the damages, ifany.
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AS AND FOR A SECOND SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
25. If Plaintiff suffered damages as alleged, then plaintiff failed to mitigate such
damages.
26. Any award made to plaintiff for the alleged injuries must be reduced in such
proportion that the alleged injuries were caused, aggravated and contributed to by Plaintiff's
failure to mitigate damages.
27. That the damages claimed to have been suffered, either in whole or in part, are
greater than any damages that may have been actually suffered, and that plaintiff failed to
mitigate the same.
AS AND FOR A THIRD SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
28. If Plaintiff received remuneration and/or compensation for some or all of their
claimed economic loss, the answering defendant are entitled to have Plaintiff's award, if any,
reduced by the amount of that remuneration and/or compensation pursuant to CPLR §4545.
AS AND FOR A FOURTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
29. If Plaintiff was caused to sustain damages at the time and place set forth in the
Plaintiff's verified complaint, itwas due to the culpable conduct of person or persons presently
unknown.
AS AND FOR A FIFTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
30. The liability of the answering defendant is limited by law under the terms of Article
Sixteen of the CPLR.
AS AND FOR A SIXTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
31. That any and all risks, hazards and dangers were open, obvious and apparent,
natural and inherent and known or should have been known by the Plaintiff herein and that
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Plaintiff assumed all such risks,hazards and defects.
AS AND FOR A SEVENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
32. That if the Plaintiff's sustained the injuries complained of in the manner alleged,
said injuries were caused by the negligence of parties over whom the answering defendant were
not obligated to exercise supervision or control.
AS AND FOR AN EIGHTH SEPARATE AND COMPLETE
AFFIRM_ATIVE DEFENSE:
33. Any award recovered by Plaintiff from the answering defendant is subject to offset
pursuant to General Obligations Law §l5-108.
AS AND FOR A NINTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
34. No acts or omissions of defendant proximately caused any injuries and/or
damages sustained by Plaintiff.
AS AND FOR A TENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
35. Plaintiff does not have standing to bring this action as they have either waived
their right to bring this action, assigned their right to bring this accident and/or are collaterally
estopped from bringing this action.
AS AND FOR A ELEVENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
36. That Plaintiff is not entitled to recover for their own negligent and/improper
conduct and actions.
AS AND FOR A TWELFTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
37. The complaint fails to statea cause of action upon which relief can be founded.
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AS AND FOR A THIRTEENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
38. Plaintiff's action is barred by the doctrines of waiver, release, estoppel, laches
and/or ratification. Plaintiff's Complaint is barred by the Doctrine of Legal Estoppel and/or by
the Doctrine of Equitable Estoppel. The Plaintiff's claims forming the basis of the Verified
Complaint were previously litigated and a judgment was issued dismissing Plaintiff's claims.
Thus, allclaims asserted in the Verified Complaint are barred.
AS AND FOR A FOURTEENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
39. That any award recovered by Plaintiff must be reduced by the receipt of collateral
source payments.
AS AND FOR A FIFTEENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
40. Plaintiffhave failed to join a necessary party to the instant action.
AS AND FOR A SIXTEENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
41. Defendants are immune from liabilitybased on the business judgment rule and all
actions taken were in good-faith.
AS AND FOR A SEVENTEENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
42. Plaintiff's complaint and underlying causes ofaction are limited by contract.
AS AND FOR AN EIGHTEENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
43. The defendant are immune from liability based upon the acts of an
answering
independent contractor.
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AS AND FOR A NINETEENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
44. That the cause of action alleged against answering defendant is barred by reason of
the terms of the but not limited waiver of subrogation and/or anti-
lease, including, to,
subrogation.
AS AND FOR A NINETEENTH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
45. That at all times mentioned herein, Plaintiff's apartment was fit for human
habitation, provided essential functions of a residence and the occupants were not subjected to
hazardous conditions. At alltimes alleged herein Plaintiff were provided with, at the very least,
a minimum standard for essential functions and Plaintiff's apartment was never rendered
uninhabitable.
AS AND FOR A TWENTIETH SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
46. The allegations in the complaint are not actionable as defendant are protected from
any liabilityto Plaintiff pursuant to the business judgment rule and any acts were in good faith
and in the exercise of honest judgment in the lawful and legitimate furtherance of corporate
purposes.
AS AND FOR A TWENTY-FIRST SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
47. That at all times mentioned herein, Plaintiff failed to give defendant notice of the
failed condition and reasonable opportunity to correct the condition.
AS AND FOR A TWENTY-SECOND SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE:
48. Plaintiff were compensated for all damages alleged herein by the own
fully
insurance carrier when filed a claim for damages prior to the commencement of this action
they
and have assigned rights of recovery for the damages alleged herein to a third-party.
any
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AS AND FOR A TWENTY-THIRD SEPARATE AND COMPLETE
AFFIRMATIVE DEFENSE1
49. The answering defendant will rely upon any and all further defenses which become
available or appear during discovery in this action and hereby specifically reserves its right to
amend itsanswer for the purpose of asserting any such additional defenses.
AS AND FOR A CROSS-CLAIM AGAINST THE DEFENDANTS, GLOBAL
SOLUTIONS APPLIANCE REPAIR INC., GLOBAL SOLUTIONS APPLIANCE
REPAIR NYC LLC, HADAS A. JACOBI, BRIAN STRONG, AND KERI STRONG, THE
DEFENDANTS, THE NORMANDIE CONDOMINIUM, THE BOARD OF MANAGERS
OF THE NORMANDIE CONDOMINIUM AND METRO MANAGEMENT &
DEVELOPMENT. INC.. ALLEGES_:
50. That ifthe plaintiff was caused to sustain damages at the time and place set forth in
the plaintiff's complaint through any carelessness, recklessness, negligence and/or breach of
warranty other than the plaintiff's own carelessness, recklessness and negligence, said damages
were sustained by reason of the carelessness, recklessness and negligence and/or acts of omission
or commission and/or breach of contract by the defendants, GLOBAL SOLUTIONS
APPLIANCE REPAIR INC., GLOBAL SOLUTIONS APPLIANCE REPAIR NYC LLC,
HADAS A. JACOBI, BRIAN STRONG, AND KERI STRONG, itsagents, servants and/or
employees; and if any judgment is recovered herein by the plaintiff against the answering
defendants, THE NORMANDIE CONDOMINIUM, THE BOARD OF MANAGERS OF
THE NORMANDIE CONDOMINIUM and METRO MANAGEMENT DEVELOPMENT,
INC. they will be damaged thereby, and the defendants, GLOBAL SOLUTIONS
APPLIANCE REPAIR INC., GLOBAL SOLUTIONS APPLIANCE REPAIR NYC LLC,
HADAS A. JACOBI, BRIAN STRONG, AND KERI STRONG will be responsible therefor
in whole or in part.
5 1. That by reason of the foregoing, the defendants, GLOBAL SOLUTIONS
APPLIANCE REPAIR INC., GLOBAL SOLUTIONS APPLIANCE REPAIR NYC LLC,
HADAS A. JACOBI, BRIAN STRONG, AND KERI STRONG, in the event and in the full
amount of a recovery herein by the plaintiff or alternatively, for that proportion thereof cause by
the relative responsibility of the defendants, GLOBAL SOLUTIONS APPLIANCE REPAIR
INC., GLOBAL SOLUTIONS APPLIANCE REPAIR NYC LLC, HADAS A. JACOBI,
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BRIAN STRONG, AND KERI STRONG are bound to pay any and all expenses and
attorneys'
fees and the costs and disbursements thereof.
AS AND FOR A SECOND CROSS-CLAIM AGAINST THE DEFENDANTS, GLOBAL
SOLUTIONS APPLIANCE REPAIR INC., GLOBAL SOLUTIONS APPLIANCE
REPAIR NYC LLC, HADAS A. JACOBI, BRIAN STRONG, AND KERI STRONG, THE
DEFENDANTS, THE NORMANDIE CONDOMINIUM, THE BOARD OF MANAGERS
OF THE NORMANDIE CONDOMINIUM AND METRO MANAGEMENT &
DEVELOPMENT. INC.. ALLEGES:
52. That ifthe plaintiffwas caused to sustain damages at the time and place set forth in
the plaintiff's complaint and in the manner alleged therein through any carelessness,
recklessness, acts, omissions, negligence and/or breach of duty, warranty and/or contract and/or
strict tort liability other than of the plaintiff, then said injuries and damages arose out of the
several and joint carelessness, recklessness, acts, omissions, negligence and/or breaches of duty
and/or obligations, and/or statute and/or contract in fact or implied in law, upon the part of the
codefendants, with indemnification and save harmless agreement, and/or responsibility by them
in fact, and/or implied in law, and without any breaches or any negligence of this pleading
defendant contributing thereto, and if this pleading defendant is found negligent as to the
plaintiff for injuries and damages as set forth in the plaintiff's Complaint, then and in that event,
the relative responsibilities of all said defendants must be apportioned by separate determination,
and the said defendants, GLOBAL SOLUTIONS APPLIANCE REPAIR INC., GLOBAL
SOLUTIONS APPLIANCE REPAIR NYC LLC, HADAS A. JACOBI, BRIAN STRONG,
AND KERI STRONG herein will be liable over jointly and severally to the pleading defendant
and bound to fully indemnify and hold this pleading defendants harmless for the fullamount of
any verdict or judgment that the plaintiff herein may recover against the pleading defendant in
this action, together with legal fees, costs and disbursements.
WHEREFORE, Defendants, THE NORMANDIE CONDOMINIUM, THE BOARD
OF MANAGERS OF THE NORMANDIE CONDOMINIUM and METRO
MANAGEMENT & DEVELOPMENT, INC., demands judgment against the Plaintiff as
follows:
1) dismissing Plaintiff's complaint with prejudice, together with the costs and
disbursements of this action;
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2) in the alternative, and in the event that Plaintiff prevail, the Defendants, THE
NORMANDIE CONDOMINIUM, THE BOARD OF MANAGERS OF THE
NORMANDIE CONDOMINIUM and METRO MANAGEMENT & DEVELOPMENT,
INC., demands judgment determining the respective percentages of fault on the part of the
defendant and Plaintiff,thereby reducing the amount of damages as against this defendant by the
respective percentage of fault of the Plaintiff and defendant; and
3) award defendants, THE NORMANDIE CONDOMINIUM, THE BOARD OF
MANAGERS OF THE NORMANDIE CONDOMINIUM and METRO MANAGEMENT
attorneys'
& DEVELOPMENT, INC., itscosts, disbursements and fees; and
4) for such other and further relief as the Court deems just, proper and necessary.
Dated: New York, New York
May 14, 2020
By:
PAUL F. LAGATTUTA III
FIXLER & LAGATTUTA, LLP
Attorneys for Defendants
THE NORMANDIE CONDOMINIUM,
THE BOARD OF MANAGERS OF THE
NORMANDIE CONDOMINIUM and
METRO MANAGEMENT &
DEVELOPMENT, INC.
120 - Suite 1350
Broadway
New York, New York 10271
(212) 785-9800
File No. 2760.197
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TO: HERRICK, FEINSTEIN LLP
Attorneys for Plaintiff
CAROLYN DISBROW
2 Park Avenue
New York, New York 10016
212-592-1400
LOUIS FOGEL & ASSOCIATES
Attorney for Defendant
HADAS A. JACOBI
5 Nottingham Road
Annandale, New Jersey 08801
(908) 730-7692
GLOBAL SOLUTIONS APPLIANCE
REPAIR INC.
102-02 Queens Boulevard, Apt 6C
Forest Hills,New York 11375
GLOBAL SOLUTIONS APPLIANCE
REPAIR NYC LLC
109-05 72nd Avenue
Forest Hills, l 1375
BRIAN STRONG
100 West 119th Street, Apt 6B
New York, New York 10026
KERI STRONG
100 West 119th Street, Apt 6B
New York, New York 10026
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Attorney Verification
The undersigned, under the penalties of perjury, affirms:
That he is Paul F. LaGattuta Ill a member ofthe firm of FIXLER & LAGATTUTA, LLP,
that he has read the foregoing papers and the sa