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 07/25/2019 08:15 AM INDEX NO. EF2018-00001369
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 07/25/2019
EXHIBIT C
EXHIBIT C
FILED: JEFFERSON COUNTY CLERK 07/25/2019 08:15 AM INDEX NO. EF2018-00001369
INDEX NO. EF2018-00001369
(FILED DOC.
NYSCEF : JE
NO.FFERSON
53 COUNTY CLE-RK 07/18/2018 04:22 PM1 RECEIVED NYSCEF: 07/25/2019
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 for a Reply, Plaintiff alleges as follows:
1. The Plaintiff denies the ãllegations ccituhised 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 Complai±
'
WHEREFORE, Plaintiff ragmb a Judgment of the Co ing the Counterclaim
togetle with such other and further relief as the Court,m y d proper.
Dated: July 17, 2018
THO .GIVhaf, tsQ
PAP KIMP * ODD & P.C.
, COX, LEVlNE,
Attorneys for Plaintiff ,
614 James Street
Syracuse, New York 13203
Tel: (315) 472-4481
Fax: (315) 472-2289
Email· rgivas(à panpmcoxlays.com
To: ROBERT J. SLYE, ESQ.
SLYE LAWOFFICES, P.C.
Attorneys for Defendant- David Strothers
104 Washington Street
Watertown, New York 13601
Tel: (315) 786-0266
Pappar, Cox,Khnpet, Dodd & lavine, P.C
Syracuse,New York
Pase 1 of2
1 of 2
FILED: JEFFERSON COUNTY CLERK 07/25/2019 08:15 AM INDEX NO. EF2018-00001369
FILED DOC. INDEX NO. EF2018-00001369
NYSCEF : JEFFERSON
NO. 53 COUNTY CLERK 07/18/2018 04: 2 2 Pld RECEIVED NYSCEF: 07/25/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 07/18/2018
Ve.w herio
STATE OF NEW-Y0RK )
Schli 5/# ) SS:
COUNTY OF EFFERSON-)
KENNETH]WII.T deposes and says that Deponent is the Plaintiff in
ER3 being duly sworn,
the within action; that Deenett has read the foregoing Answer and knows the contents thereof; that
the same is true to Deponent's own knowledge, exceptas to the matter therein stated to be alleged on
information and belief, and that as to those matters Deponent believes it to be true; the basis of
Plaintiff's knowiêdge is he is the owner of the real property in connection with this action.
TH . .
Sworn before me this }
day of 11 2018.
OF FICIAL SEAL
Matthew B. Williams
NOTARY PUBLIC
Notary c STATE OF NEW EX O
My Commission Expiress
Ppppan Cam Khapel, Dost & Levine,P.C.
Syraceae,New York
Page2 of2
2 of 2
Document Filed Date
July 25, 2019
Case Filing Date
June 07, 2018
Category
Real Property - Other (Declaratory Judgment/Ease)
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Preview
FILED: JEFFERSON COUNTY CLERK 07/25/2019 08:15 AM INDEX NO. EF2018-00001369 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 07/25/2019 EXHIBIT C EXHIBIT C FILED: JEFFERSON COUNTY CLERK 07/25/2019 08:15 AM INDEX NO. EF2018-00001369 INDEX NO. EF2018-00001369 (FILED DOC. NYSCEF : JE NO.FFERSON 53 COUNTY CLE-RK 07/18/2018 04:22 PM1 RECEIVED NYSCEF: 07/25/2019 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 for a Reply, Plaintiff alleges as follows: 1. The Plaintiff denies the ãllegations ccituhised 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 Complai± ' WHEREFORE, Plaintiff ragmb a Judgment of the Co ing the Counterclaim togetle with such other and further relief as the Court,m y d proper. Dated: July 17, 2018 THO .GIVhaf, tsQ PAP KIMP * ODD & P.C. , COX, LEVlNE, Attorneys for Plaintiff , 614 James Street Syracuse, New York 13203 Tel: (315) 472-4481 Fax: (315) 472-2289 Email· rgivas(à panpmcoxlays.com To: ROBERT J. SLYE, ESQ. SLYE LAWOFFICES, P.C. Attorneys for Defendant- David Strothers 104 Washington Street Watertown, New York 13601 Tel: (315) 786-0266 Pappar, Cox,Khnpet, Dodd & lavine, P.C Syracuse,New York Pase 1 of2 1 of 2 FILED: JEFFERSON COUNTY CLERK 07/25/2019 08:15 AM INDEX NO. EF2018-00001369 FILED DOC. INDEX NO. EF2018-00001369 NYSCEF : JEFFERSON NO. 53 COUNTY CLERK 07/18/2018 04: 2 2 Pld RECEIVED NYSCEF: 07/25/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 07/18/2018 Ve.w herio STATE OF NEW-Y0RK ) Schli 5/# ) SS: COUNTY OF EFFERSON-) KENNETH]WII.T deposes and says that Deponent is the Plaintiff in ER3 being duly sworn, the within action; that Deenett has read the foregoing Answer and knows the contents thereof; that the same is true to Deponent's own knowledge, exceptas to the matter therein stated to be alleged on information and belief, and that as to those matters Deponent believes it to be true; the basis of Plaintiff's knowiêdge is he is the owner of the real property in connection with this action. TH . . Sworn before me this } day of 11 2018. OF FICIAL SEAL Matthew B. Williams NOTARY PUBLIC Notary c STATE OF NEW EX O My Commission Expiress Ppppan Cam Khapel, Dost & Levine,P.C. Syraceae,New York Page2 of2 2 of 2