Exhibit,Appendix: James Moran v. Grand Slam Ventures, Llc, Jon Steinberg, Glenn A. Reiner, Jg Real Estate Ventures, Llc, 'John Does' 1-10 Inclusive, The Last Ten Names Being Fictitious And Unknown To Plaintiff

On May 27, 2022 a Exhibit,Appendix was filed involving a dispute between James Moran, and Glenn A. Reiner, Grand Slam Ventures, Llc, Jg Real Estate Ventures, Llc, 'John Does' 1-10 Inclusive, The Last Ten Names Being Fictitious And Unknown To Plaintiff, Jon Steinberg, for Other Matters - Contract - Other in the District Court of Nassau County.

Preview
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

EXHIBIT “2”
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
---------------------------------------------------------------------x
JAMES MORAN,

Plaintiff,
VERIFIED ANSWER
-against-
Index No. 001052/2019
GRAND SLAM VENTURES, LLC, JON STEINBERG,
GLENN A. REINER, JG REAL ESTATE VENTURES,
LLC, and "JOHN DOES"# 1-10 inclusive, the last ten
names being fictitious and unknown to plaintiff,

Defendants.
- - - - - - - - - - - - - - - - - - - -X
PLEASE TAKE NOTICE, that the above-named Defendants, by their attorneys, Siegel &

Reiner, LLP, answering the Verified Complaint of the-Plaintiff, alleges as follows:

1. Deny knowledge or information sufficient to form a belief as to the truth of the

allegation contained in Paragraph "1" of the Verified Complaint.

2. Admit the allegations contained in Paragraph "2 11 of the Verified Complaint.

3. Admit the allegations contained in Paragraph "3" of the Verified Complaint.

4. Admit the allegations contained in Paragraph "4" of the Verified Complaint.

5. Admit the allegations contained in Paragraph "5" of the Verified Complaint.

6. Admit the allegations contained in Paragraph "6 11 of the Verified Complaint.

7. Deny the allegations contained in Paragraph "7" of the Verified Complaint except

admit that Defendant Glenn A. Reiner ("Defendant Reiner") is a member of

Defendant JG Real Estate Ventures, LLC ("Defendant JG").

8. Deny the allegations contained in Paragraph "8" of the Verified Complaint.

9. Admit the allegations contained in Paragraph "9" of the Verified Complaint.
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

10. Deny knowledge or information sufficient to form a belief as to the truth of the

allegation contained in Paragraph "10" of the Verified Complaint.

11. Deny knowledge or information sufficient to form a belief as to the truth of the

allegation contained in Paragraph "11" of the Verified Complaint.

12. Deny knowledge or information sufficient to fo1m a belief as to the truth of the

allegation contained in Paragraph "12" of the Verified Complaint.

13. Admit the allegations contained in Paragraph "13" of the Verified Complaint.

14. Admit the allegations contained in Paragraph "14" of the Verified Complaint.

15. Admit the allegations contained in Paragraph "15 11 of the Verified Complaint.

16. Admit the allegations contained in Paragraph "16" of the Verified Complaint.

17. Admit the allegations contained in Paragraph "17" of the Verified Complaint.

18. Admit the allegations contained in Paragraph "18" of the Verified Complaint.

19. Admit the allegations contained in Paragraph "19" of the Verified Complaint.

20. Admit the allegations contained in Paragraph "20" of the Verified Complaint.

21. Deny the allegations contained in Paragraph "21" of the Verified Complaint.

22. Admit the allegations contained in Paragraph "22" of the Verified Complaint.

23. Admit the allegations contained in Paragraph "23" of the Verified Complaint

except deny that the consideration for the assignment was Ten ($10.00) Dollars.

24. Admit the allegations contained in Paragraph "24" of the Verified Complaint.

25. Deny knowledge or information sufficient to form a belief as to the truth of the

allegation contained in Paragraph "25" of the Verified Complaint.

26. Admit the allegations contained in Paragraph "26 11 of the Verified Complaint

2
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

except deny that the consideration was One Million Five-Hundred Thousand

($1,500,000.00) Dollars.

27. Admit the allegations contained in Paragraph "27" of the Verified Complaint.

28. Admit the allegations contained in Paragraph "28" of the Verified Complaint

except deny that Defendant Grand Slam Ventures, LLC ("Defendant Grand

Slam") "refused" or "willfully neglected" to appear.

29. Admit the allegations contained in Paragraph "29" of the Verified Complaint.

30. Admit the allegations contained in Paragraph "30" of the Verified Complaint.

31. Admit the allegations contained in Paragraph "31 11 of the Verified Complaint

except affirmatively state that the referenced deposition occtmed subsequent to

the assignment referenced in Paragraph "23 11 above.

32. Admit the allegations contained in Paragraph "32" of the Verified Complaint.

33. Admit the allegations contained in Paragraph "33" of the Verified Complaint

except affirmatively state that the referenced deposition occurred subsequent to

the conveyance referenced in Paragraph "26" above.

34. Admit the allegations contained in Paragraph "34" of the Verified Complaint.

35. Admit the allegations contained in Paragraph "35" of the Verified Complaint.

36. Deny knowledge or information sufficient to form a belief as to the truth of the

allegation contained in Paragraph "36" of the Verified Complaint.

37. Admit the allegations contained in Paragraph "37" of the Verified Complaint.

38. Admit the allegations contained in Paragraph "38" of the Verified Complaint.

39. Admit the allegations contained in Paragraph "39" of the Verified Complaint.

3
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

40. Deny the allegations contained in Paragraph "40° of the Verified Complaint.

41. Deny the allegations contained in Paragraph "41" of the Verified Complaint.

42. Deniy the allegations contained in Paragraph "42" of the Verified Complaint

except admit that Defendant JG was formed on September 23, 2013.

43. Deny the allegations contained in Paragraph "43" of the Vedfied Complaint.

44. Deny the allegations contained in Paragraph "44" of the Verified Complaint.

45. Deny the allegations contained in Paragraph "45" of the Verified Complaint

46. Deny the allegations contained in Paragraph "46" of the Verified Complaint.

47. Deny the allegations contained in Paragraph "47" of the Verified Complaint.

48. Deny the allegations contained in Paragraph "48" of the Verified Complaint.

49. As to Paragraph "49" of the Verified Complaint, Defendants repeat and reiterate

each and every allegation of their Answer as if set forth at length herein.

50. Deny the allegations contained in Paragraph "50" of the Verified Complaint.

51. Deny the allegations contained in Paragraph "51" of the Verified Complaint.

52. Deny the allegations contained in Paragraph "52" of the Verified Complaint.

53. Deny the allegations contained in Paragraph "53" of the Verified Complaint.

54. Deny the allegations contained in Paragraph "54" of the Verified Complaint.

55. Deny the allegations contained in Paragraph "55" of the Verified Complaint.

56. Deny the allegations contained in Paragraph "56" of the Verified Complaint.

57. As to Paragraph "57" of the Complaint, Defendants repeat and reiterate each and

every allegation of their Answer as if set forth at length herein.

58. Deny the allegations contained in Paragraph "58" of the Verified Complaint.

4
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

59. Deny the allegations contained in Paragraph "59 11 of the Verified Complaint.

60. Deny the allegations contained in Paragraph "60" of the Verified Complaint.

61. Deny the allegations contained in Paragraph "61 11 of the Verified Complaint.

62. As to Paragraph "62" of the Complaint, Defendants repeat and reiterate each and

every allegation of their Answer as if set forth at length herein.

63. Deny the allegations contained in Paragraph "63" of the Verified Complaint.

64. Deny the allegations contained in Paragraph "64 11 of the Verified Complaint.

65. Deny the allegations contained in Paragraph "65" of the Verified Complaint.

66. Deny the allegations contained in Paragraph "66" of the Verified Complaint.

67. Deny the allegations contained in Paragraph "67" of the Verified Complaint.

68. Deny the allegations contained in Paragraph "68" of the Verified Complaint.

69. As to Paragraph "69" of the Complaint, Defendants repeat and reiterate each and

every allegation of their Answer as if set forth at length herein.

70. Deny the allegations contained in Paragraph "70" of the Verified Complaint.

71. Deny the allegations contained in Paragraph "71 11 of the Verified Complaint.

72. Deny the allegations contained in Paragraph "72" of the Verified Complaint.

73. Deny the allegations contained in Paragraph "73 11 of the Verified Complaint.

74. Deny the allegations contained in Paragraph "74" of the Verified Complaint.

75. Deny the allegations contained in Paragraph "75" of the Verified Complaint.

76. Deny the allegations contained in Paragraph "76" of the Verified Complaint.

77. As to Paragraph "77" of the Complaint, Defendants repeat and reiterate each and

every allegation of their Answer as if set forth at length herein.

5
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

78. Deny the allegations contained in Paragraph "78" of the Verified Complaint.

79. Deny the allegations contained in Paragraph "79" of the Verified Complaint.

80. Deny the allegations contained in Paragraph "80 11 of the Verified Complaint.

81. Deny the allegations contained in Paragraph "81 11 of the Verified Complaint.

82. Deny the allegations contained in Paragraph "82" of the Verified Complaint.

83. Deny the allegations contained in Paragraph "83" of the Verified Complaint.

84. As to Paragraph "84" of the Complaint, Defendants repeat and reiterate each and

every allegation of their Answer as if set fo11h at length herein.

85. Deny the allegations contained in Paragraph "85" of the Verified Complaint.

86. Deny the allegations contained in Paragraph "86" of the Verified Complaint.

87. Deny the allegations contained in Paragraph "87'' of the Verified Complaint.

88. Deny the allegations contained in Paragraph "88" of the Verified Complaint.

89. Deny the allegations contained in Paragraph "89" of the Verified Complaint.

90. Deny the allegations contained in Paragraph "90" of the Verified Complaint.

DEFENDANTS' FIRST AFFIRMATIVE DEFENSE

91. Plaintiff's claims are barred by the Statute of Limitations.

DEFENDANTS' SECOND AFFIRMATIVE DEFENSE

92. Defendant Glenn A. Reiner is not a proper party to this action.

DEFENDANTS' THIRD AFFIRMATIVE DEFENSE

93. The Plaintiff's claims are barred by the defense oflaches.

AS AND FOR A FOURTH AFFIRMATIVE DEFENSE

6
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

94. Plaintiff comes to this action with unclean hands.

AS AND FOR A FIFTH AFFIRMATIVE DEFENSE

95. Defendant Grand Slam's conveyance of certain real property to Defendant JG was

an arm's length transaction.

WHEREFORE, Defendants demand judgment as follows:

( 1) Dismissing Plaintiffs Complaint;

(2) An award of costs, disbursements ru1d reasonable attorneys fees; and

(3) Such other and further relief as this Court deems just and proper.

Dated: New York, New York
October 29, 2019

Yours, etc.

Richard H. Del Valle, Esq.
Siegel & Reiner, LLP
Attorneys for Defendants
130 East 59th Sh·eet, 12th Floor
New York, New York 10022
(646) 745-2805

7
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 06/23/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
---------------------------------------------------------------------x
JAMES MORAN,

Plaintiff,
VERIFICATION
-against-

GRAND SLAM VENTURES, LLC, JON STEINBERG,
GLENN A. REINER, JG REAL ESTATE VENTURES,
LLC, and "JOHN DOES"# 1-10 inclusive, the last ten
names being fictitious and unknown to plaintiff,

Defendants.
- - - - - - - - - - - )- - - - - - - - - -X
STATE OF NEW YORK
ss.:
COUNTY OF NEW YORK )

Glenn A. Reiner, being duly sworn, deposes and says:

He is one of the individual Defendants in the above entitled action; that he has read the

foregoing Answer and knows the contents thereof; that the same is true to his knowledge, except

as to the matters therein stated to be alleged upon information and belief, and that as to those

matters he believes them to be true.

Sworn to before me this
29th day of October, 2019

Notary Publi~--

RICHARD DELVALLE
Notary Public, State of New York
, No ..02DE6004969
Qual1f1ed ,in New York County
Comm1ss1on Expires April 20, :i ':i J-.

Case Info

Judge

Francis Ricigliano Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

June 23, 2022

Case Filing Date

May 27, 2022

County

Parties

For full print and download access, please subscribe at https://www.trellis.law/.