On June 07, 2018 a
Answer
was filed
involving a dispute between
Kenneth Miller,
and
David Strothers,
Eric Bevard,
Gretchen Bevard,
for Real Property - Other (Declaratory Judgment/Ease)
in the District Court of Jefferson County.
Preview
FILED: JEFFERSON COUNTY CLERK 07/18/2018 04:22 PM INDEX NO. EF2018-00001369
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 07/18/2018
SUPREME COURT
STATE OF NEW YORK COUNTY OF JEFFERSON
KENNETH MILLER,
10505 Snow Heights Blvd, NE
Albuquerque, New Mexico 87112
Plaintif.
REPLY TO VERIFIED ANSWER
vs. Index No.: EF2018-00001369
CHARLES PETER HUNKELE, JR., and
DAVID STROTHERS
Defendants.
As and for a Reply, Plaintiff alleges as follows:
1. The Plaintiff denies the allegations contained in paragraphs 16 and 17 of the
Verified Answer and Counterclaim.
AS AND FOR A FIRST AFFIRMATIVE DEFENSE
2. The Plaintiff has an easement as set forth in the Complaint.
' '
WHEREFORE, Plaintiff requests a Judgment of the Co ing the Counterclaim
together with such other and further relief as the Court y d J d proper.
Dated: July 17, 2018
THO S P. . GIV , Q
PAP , COX, IGMP DD & LEVINE, P.C.
Attorneys for Plaintiff
614 James Street
Syracuse, New York 13203
Tel: (315) 472-4481
Fax: (315) 472-2289
Email·
Email:
BmaiL trivas@pappascoxlaw.com
To: ROBERT J. SLYE, ESQ.
SLYE LAW OFFICES, P.C.
Attorneys for Defendant- David Strothers
104 Washington Street
Watertown, New York 13601
Tel: (315) 786-0266
Pappas, Coa; Khnpel, Dodi
d Lenne. P.C
Spacuse, New York
Page lI oj'2
of 2
1 of 2
FILED: JEFFERSON COUNTY CLERK 07/18/2018 04:22 PM INDEX NO. EF2018-00001369
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 07/18/2018
VERIFICATION
N
]V~ -text
Pex~
STATE OF NEW-¥0RK )
COUNTY OF m) Bdna // ) SS:
KENNETH MILLER, being duly sworn, deposes and says that Deponent is the Plaintiff in
the within action; that Deponent has read the foregoing Answer and knows the contents thereof; that
the same istrue to Deponent's own knowledge, except as to the matter therein stated to be alleged on
information and belief, and that as to those matters Deponent believes itto be true; the basis of
Plaintiff's knowledge is he isthe owner of the real property in connection with this action.
ÑETH ~
AWLBWX gy~~~
Sworn before me this ~~ J~
day of hl .1 2018.
OF FICIAL SEAL
/i' '
), iams
Matthew B.
~
NOTARY PUBLIC
Notary Pu 10 3 STATE OF NEW IEX 0
_C' f 6
j Commission Expires: / (3 f
My
Pappas. Cox, Kimpel. Dodd 4 Levine, P,C.
Syracuse, New York
Page 2 a/2
os
2 of 2
Document Filed Date
July 18, 2018
Case Filing Date
June 07, 2018
Category
Real Property - Other (Declaratory Judgment/Ease)
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FILED: JEFFERSON COUNTY CLERK 07/18/2018 04:22 PM INDEX NO. EF2018-00001369 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 07/18/2018 SUPREME COURT STATE OF NEW YORK COUNTY OF JEFFERSON KENNETH MILLER, 10505 Snow Heights Blvd, NE Albuquerque, New Mexico 87112 Plaintif. REPLY TO VERIFIED ANSWER vs. Index No.: EF2018-00001369 CHARLES PETER HUNKELE, JR., and DAVID STROTHERS Defendants. As and for a Reply, Plaintiff alleges as follows: 1. The Plaintiff denies the allegations contained in paragraphs 16 and 17 of the Verified Answer and Counterclaim. AS AND FOR A FIRST AFFIRMATIVE DEFENSE 2. The Plaintiff has an easement as set forth in the Complaint. ' ' WHEREFORE, Plaintiff requests a Judgment of the Co ing the Counterclaim together with such other and further relief as the Court y d J d proper. Dated: July 17, 2018 THO S P. . GIV , Q PAP , COX, IGMP DD & LEVINE, P.C. Attorneys for Plaintiff 614 James Street Syracuse, New York 13203 Tel: (315) 472-4481 Fax: (315) 472-2289 Email· Email: BmaiL trivas@pappascoxlaw.com To: ROBERT J. SLYE, ESQ. SLYE LAW OFFICES, P.C. Attorneys for Defendant- David Strothers 104 Washington Street Watertown, New York 13601 Tel: (315) 786-0266 Pappas, Coa; Khnpel, Dodi d Lenne. P.C Spacuse, New York Page lI oj'2 of 2 1 of 2 FILED: JEFFERSON COUNTY CLERK 07/18/2018 04:22 PM INDEX NO. EF2018-00001369 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 07/18/2018 VERIFICATION N ]V~ -text Pex~ STATE OF NEW-¥0RK ) COUNTY OF m) Bdna // ) SS: KENNETH MILLER, being duly sworn, deposes and says that Deponent is the Plaintiff in the within action; that Deponent has read the foregoing Answer and knows the contents thereof; that the same istrue to Deponent's own knowledge, except as to the matter therein stated to be alleged on information and belief, and that as to those matters Deponent believes itto be true; the basis of Plaintiff's knowledge is he isthe owner of the real property in connection with this action. ÑETH ~ AWLBWX gy~~~ Sworn before me this ~~ J~ day of hl .1 2018. OF FICIAL SEAL /i' ' ), iams Matthew B. ~ NOTARY PUBLIC Notary Pu 10 3 STATE OF NEW IEX 0 _C' f 6 j Commission Expires: / (3 f My Pappas. Cox, Kimpel. Dodd 4 Levine, P,C. Syracuse, New York Page 2 a/2 os 2 of 2