On January 08, 2022 a
Motion-Secondary
was filed
involving a dispute between
Kenneth Sternfeld Individually
A A O Ronni Sternfeld,
and
Eq8Health Corporation
D B A Careone Concierge,
Peter Bechtel,
Welltrackone Corporation,
for Commercial - Contract
in the District Court of Nassau County.
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FILED: NASSAU COUNTY CLERK 04/17/2022 11:20 PM INDEX NO. 600728/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/17/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
────────────────────────────────────
Kenneth Sternfeld, individually and as Index No.: 600728/2022
Assignee of Ronni Sternfeld,
Plaintiff, VERIFIED
REPLY
-against -
Welltrackone Corporation, eQ8Health
Corporation d/b/a Careone Concierge and
Peter Bechtel,
Defendants.
────────────────────────────────────
Plaintiff hereby submits the following reply to Defendant’s counterclaims:
1. Denies the truth of the allegations contained in paragraphs ninth, tenth
eleventh, twelfth, thirteenth, fourteenth, fifteenth and sixteenth of the answer.
AS A FIRST AFFIRMATIVE DEFENSE
2. The counterclaims fail to set forth a cause of action upon which relief may
be granted.
AS A SECOND AFFIRMATIVE DEFENSE
4. The counterclaims are precluded by documentary evidence.
AS A THIRD AFFIRMATIVE DEFENSE
4. Plaintiff’s actions were not the proximate cause of any damages that may
have been sustained by Defendants.
WHEREFORE, Plaintiff requests that the counterclaims be dismissed in their
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FILED: NASSAU COUNTY CLERK 04/17/2022 11:20 PM INDEX NO. 600728/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/17/2022
entirety, together with such other and further relief as this court may deem just and
proper.
Dated: New York, New York
April 18, 2022
Yours etc.,
s/ Kenneth Sternfeld
______________________
Kenneth Sternfeld
Plaintiff Pro Se
902 Sutton court
Uniondale, NY 11553
516-817-7410
To: Joseph Falbo, Jr.
Attorney for Defendants
145 Willis Avenue
Mineola, NY 11501
516-794-4666
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FILED: NASSAU COUNTY CLERK 04/17/2022 11:20 PM INDEX NO. 600728/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/17/2022
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Document Filed Date
April 17, 2022
Case Filing Date
January 08, 2022
Category
Commercial - Contract
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FILED: NASSAU COUNTY CLERK 04/17/2022 11:20 PM INDEX NO. 600728/2022 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/17/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ──────────────────────────────────── Kenneth Sternfeld, individually and as Index No.: 600728/2022 Assignee of Ronni Sternfeld, Plaintiff, VERIFIED REPLY -against - Welltrackone Corporation, eQ8Health Corporation d/b/a Careone Concierge and Peter Bechtel, Defendants. ──────────────────────────────────── Plaintiff hereby submits the following reply to Defendant’s counterclaims: 1. Denies the truth of the allegations contained in paragraphs ninth, tenth eleventh, twelfth, thirteenth, fourteenth, fifteenth and sixteenth of the answer. AS A FIRST AFFIRMATIVE DEFENSE 2. The counterclaims fail to set forth a cause of action upon which relief may be granted. AS A SECOND AFFIRMATIVE DEFENSE 4. The counterclaims are precluded by documentary evidence. AS A THIRD AFFIRMATIVE DEFENSE 4. Plaintiff’s actions were not the proximate cause of any damages that may have been sustained by Defendants. WHEREFORE, Plaintiff requests that the counterclaims be dismissed in their 1 of 3 FILED: NASSAU COUNTY CLERK 04/17/2022 11:20 PM INDEX NO. 600728/2022 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/17/2022 entirety, together with such other and further relief as this court may deem just and proper. Dated: New York, New York April 18, 2022 Yours etc., s/ Kenneth Sternfeld ______________________ Kenneth Sternfeld Plaintiff Pro Se 902 Sutton court Uniondale, NY 11553 516-817-7410 To: Joseph Falbo, Jr. Attorney for Defendants 145 Willis Avenue Mineola, NY 11501 516-794-4666 2 of 3 FILED: NASSAU COUNTY CLERK 04/17/2022 11:20 PM INDEX NO. 600728/2022 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/17/2022 3 of 3