On June 07, 2018 a
Exhibit,Appendix
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 07/18/2019 01:02 PM INDEX NO. EF2018-00001369
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 07/18/2019
EXHIBIT C
FILED: JEFFERSON COUNTY CLERK 07/18/2019 01:02 PM INDEX NO. EF2018-00001369
NYSCEF DOC. NO.FFERSON
46 INDEX
RECEIVED NO.NYSCEF:
EF2018-00001369
07/18/2019
FILED : JE COUNTY CLERK 07 /18 / 2 018 0 4 : 22 PI4
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
Plaintiff.
REPLY TO VERIFIED ANSWER
vs. Index No.: EF2018-00001369
CHARLES PETER HUNKELE, JR., and
DAVID STROTHERS
Defendants.
As and fora Reply, Plaintiffalleges 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.
Plaintiff requests a Judgment of the inm . mg the Counterclaim
WHEREFORE,
together with such other and father reliefas the Court,m y d proper.
Dated: July 17, 2018
THO . GIVk, 4'sQ
PAP , COX, KIMPE ODD & LEVINE, P.C,
Attorneys for Plaintiff ,
614 James Street
Syracuse, New York 13203
Tel: (315) 472-4481
Fax: (315) 472-2289
Email: trivas@oaguascoxlaw.em
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
Pqppa,, Cox Kimpet, Dodf & lanne, P.C
Synscuse,New York
Pose 1 of 2
1 of 2
FILED: JEFFERSON COUNTY CLERK 07/18/2019 01:02 PM INDEX NO. EF2018-00001369
NYSCEF DOC. NO. 46 INDEX
RECEIVED NO.NYSCEF:
EF2018-000013
07/18/201969
IFILED : JEFFERSON COUNTY CLERK 07/18/2018 04: 22 PM
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 07/18/2018
STATE OF NEW40RK )
Seca4ll ) SS:
COUNTY OF )
KENNETH1HrII.T.ER, being duly sworn, deposes and says that Deponent is thePlaintiff in
the within action; thatDeponent has read the foregoing Answer and knows the contents thereo% that
the same is trueto Depenent's own knowledge, except as tothe matter therein stated to be alleged on
information and belief, and that as to those matters Deponent believes it tobe true; the basis of
Plaintiff'sknowledge ishe isthe owner of the realproperty in connecdon with this action.
TH . .
Sworn before me this
day of 11 2018.
OF FICIAL SEAL
Matthew B. WIIllams
NOTARY PUBLIC
Notary STATE OF NEW EX O
My Commission Expises;
Pqpar, Cax, Konpet Dodi a Invine, P,C.
Syracuse,New York
Page2 of2
2 of 2
Document Filed Date
July 18, 2019
Case Filing Date
June 07, 2018
Category
Real Property - Other (Declaratory Judgment/Ease)
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FILED: JEFFERSON COUNTY CLERK 07/18/2019 01:02 PM INDEX NO. EF2018-00001369 NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 07/18/2019 EXHIBIT C FILED: JEFFERSON COUNTY CLERK 07/18/2019 01:02 PM INDEX NO. EF2018-00001369 NYSCEF DOC. NO.FFERSON 46 INDEX RECEIVED NO.NYSCEF: EF2018-00001369 07/18/2019 FILED : JE COUNTY CLERK 07 /18 / 2 018 0 4 : 22 PI4 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 Plaintiff. REPLY TO VERIFIED ANSWER vs. Index No.: EF2018-00001369 CHARLES PETER HUNKELE, JR., and DAVID STROTHERS Defendants. As and fora Reply, Plaintiffalleges 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. Plaintiff requests a Judgment of the inm . mg the Counterclaim WHEREFORE, together with such other and father reliefas the Court,m y d proper. Dated: July 17, 2018 THO . GIVk, 4'sQ PAP , COX, KIMPE ODD & LEVINE, P.C, Attorneys for Plaintiff , 614 James Street Syracuse, New York 13203 Tel: (315) 472-4481 Fax: (315) 472-2289 Email: trivas@oaguascoxlaw.em 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 Pqppa,, Cox Kimpet, Dodf & lanne, P.C Synscuse,New York Pose 1 of 2 1 of 2 FILED: JEFFERSON COUNTY CLERK 07/18/2019 01:02 PM INDEX NO. EF2018-00001369 NYSCEF DOC. NO. 46 INDEX RECEIVED NO.NYSCEF: EF2018-000013 07/18/201969 IFILED : JEFFERSON COUNTY CLERK 07/18/2018 04: 22 PM NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 07/18/2018 STATE OF NEW40RK ) Seca4ll ) SS: COUNTY OF ) KENNETH1HrII.T.ER, being duly sworn, deposes and says that Deponent is thePlaintiff in the within action; thatDeponent has read the foregoing Answer and knows the contents thereo% that the same is trueto Depenent's own knowledge, except as tothe matter therein stated to be alleged on information and belief, and that as to those matters Deponent believes it tobe true; the basis of Plaintiff'sknowledge ishe isthe owner of the realproperty in connecdon with this action. TH . . Sworn before me this day of 11 2018. OF FICIAL SEAL Matthew B. WIIllams NOTARY PUBLIC Notary STATE OF NEW EX O My Commission Expises; Pqpar, Cax, Konpet Dodi a Invine, P,C. Syracuse,New York Page2 of2 2 of 2