Preview
FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477
NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONTGOMERY
INDEX NO. EF2022-477
FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC
F/K/A REALTYFI REAL ESTATE INVESTMENT TRUST LLC.,
VERIFIED ANSWER and
AFFIRMATIVE
Plaintiff, DEFENSES
-against-
LITTLE FALLS GARDEN APARTMENTS LLC, ROB1NHOOD
PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A
BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC,
DAVID RAVEN, CARL ORSINI A/K/A CARLOS M ORSINI,
NEW YORK STATE DEPARTMENT OF TAXATION AND
FINANCE, GEORGE LUMBER & BUILDING MATERIAL
INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST
NIAGARA BANK, N.A., JOHN DOE CORPORATIONS
NOS.1-100 and JOHN DO COMPANY NOS. 1-100,
Defendants.
C O U N S E L O R S :
The defendants, LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD
PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN
HOUSES LLC and DAVID RAVEN by their attorneys, Ragues, PLLC, as and for their Verified
Answer to the Complaint, respectfully alleges, upon information and belief:
1. Denies each and every allegation contained in paragraph numbered "2", "4", "6",
"9", "11", "44", "46", "49", of the Complaint.
2. Lacks information or knowledge sufficient to form a belief as to the truth or
falsity of the allegations contained in paragraph numbered "1", "8", "13-17", "19-43", "45", "47",
"52" "53"
"48', of the Complaint.
3. Denies each and every allegation contained in paragraph numbered 12 of the
Complaint, except the Defendant Raven has interest in Mortgage Properties.
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4. Lacks information or knowledge sufficient to form a belief as to the truth or
falsity of the allegations contained in paragraph numbered 18, except that Defendants Robinhood
and Brookview gave Financing Statement to the Defendant KeyBank via First Niagara.
AS AND FOR THE FIRST AFFIRMATIVE DEFENSE
5. The complaint herein is fatally defective as it fails to state a cause of action upon
which relief may be granted.
6. RPAPL provisions require specific pleadings, including but not limited to whether
Plaintiff possesses the note allegedly giving rise to this action.
7. Plaintiff's failure to allege anything with requisite specificity destroys its cause of
action without any burden shifting to Defendant at any time.
AS AND FOR THE SECOND AFFIRMATIVE DEFENSE
8. The Plaintiff sustained any damages or losses as alleged in the Complaint, all of
which is expressly denied, then, such damages were caused, either in whole or in part, by the
Plaintiff's or its agents, representative, employers, assignors, and/or assignees, own culpable
conduct, fault, and/or negligence, and any recovery herein shall be diminished accordingly in
whole or in part.
9. Plaintiff failed to take any action or sufficient action, or such action as was
necessary, to mitigate or minimize the damages alleged, or the conditions that allegedly gave rise
to those purported damages.
AS AND FOR THE THIRD AFFIRMATIVE DEFENSE
Plaintiff(s) failed to take any action or sufficient action, or such action as was necessary,
to mitigate or minimize the damages alleged, or the conditions that allegedly gave rise to those
2
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purported damages.
WHEREFORE, the defendants LITTLE FALLS GARDEN APARTMENTS LLC,
ROBINHOOD PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A
BROOKVIEW TOWN HOUSES LLC and DAVID RAVEN respectfully request judgment
dismissing the complaint against answering Defendants, granting the costs and disbursements of
this action, and for such other and further relief as to this Court may seem just and proper.
Dated: Kingston, New York
March 1, 2023
By: Raymond I agues, Esq.
RAGUES, PLLC
Attomeys for Defendants
LITTLE FALLS GARDEN APARTMENTS LLC
ROBINHOOD PROPERTIES LLC
BROOKVIEW TOWN HOUSE LLC A/K/A
BROOKVIEW TOWN HOUSES LLC
And DAVID RAVEN
42 Crown Street
Kingston, New York 12401
(845) 481-0086
Email: ray@ragueslaw.com
Andrew M. Roth, Esq.
SAHN WARD BRAFF KOBLENZ PLLC
Attomeys for Plaintiff
333 Earle Ovington Boulevard Suite 601
Uniondale, New York 11530
(516) 228-1300
COR HOLDINGS, LLC
Defendant
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
3
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NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023
CARL ORSINI A/K/A CARLOS M. ORSINI
Defendant
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE
Defendant
Harriman Campus Rd.
Albany, New York 12226
GEORGE LUMBER & BUILDING MATERIAL INC.
Defendant
525 E. Mill Street
Little Falls, New York 13365
KEY BANK AS SUCCESSOR BY MERGER
TO FIRST NIAGARA BANK, N.A.
Defendant
127 Public Square
Cleveland, OH 44114
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONTGOMERY
FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC INDEX NO. EF2022-477
F/K/A REALTYFI REAL ESTATE INVESTMENT TRUST LLC.,
Plaintiff, ATTORNEY'S
-against- VERIFICATION
LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD
PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A
BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC,
DAVID RAVEN, CARL ORSINI A/K/A CARLOS M ORSINI,
NEW YORK STATE DEPARTMENT OF TAXATION AND
FINANCE, GEORGE LUMBER & BUILDING MATERIAL
INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST
NIAGARA BANK, N.A., JOHN DOE CORPORATIONS
NOS.1-100 and JOHN DO COMPANY NOS. 1-100,
Defendants.
Raymond Ragues, an attorney duly admitted to practice law in the State of New York,
makes the following affirmation under the penalty of pedury:
I am a member of the firm of RAGUES, PLLC, the attorneys of record for the defendant.
I have read the foregoing Answer and know the contents thereof; the same is true to my
own knowledge except as to the matters therein stated to be alleged on information and belief
and that as to those matters, I believe them to be true.
This verification is made by affirmant and not by defendant because defendant does not
maintain its principal place of business within the County of Ulster, which is the County where
your affirmant maintains ofHces.
The grounds of affirmants belief as to all matters not stated upon affinnants knowledge
are correspondence had with the said defendant, information contained in the said defendants
file, which is in affirmants possession, and other pertinent data relating thereto.
Dated: Kingston, New York
March 1, 2023
RAvMONDtAGUES
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NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONTGOMERY
INDEX NO. EF2022-477
FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC
F/K/A REALTYFI REAL ESTATE INVESTMENT TRUST LLC.,
AFFIRMATION OF
Plaintiff, SERVICE
-against-
LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD
PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A
BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC,
DAVID RAVEN, CARL ORSINI A/K/A CARLOS M ORSINI,
NEW YORK STATE DEPARTMENT OF TAXATION AND
FINANCE, GEORGE LUMBER & BUILDING MATERIAL
INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST
NIAGARA BANK, N.A., JOHN DOE CORPORATIONS
NOS.1-100 and JOHN DO COMPANY NOS. 1-100,
Defendants.
STATE OF NEW YORK )
)SS.:
COUNTY OF ULSTER )
Raymond Ragues, an attorney admitted to practice law in the State of New York, affirms
the following under the penalties of perjury:
I am not a party to the action; I reside at Kingston, New York, and I am over 18 years of
age.
On March 1, 2023, I served the within Verified Answer by depositing a true copy thereof,
enclosed in a post-paid wrapper, in an official depository under the exclusive care and custody of
the United States Postal Service within New York State, addressed to the following at the last
known address set forth below:
Andres M. Roth, Esq. ( Via ECF and email)
SAHN WARD BRAFF KOBLENZ PLLC
333 Earle Ovington Boulevard Suite 601
Garden City, New York 11530
Email: aroth@sahnward.com
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COR HOLDINGS, LLC
Defendant
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
CARL ORSINI A/K/A CARLOS M. ORSINI
Defendant
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE
Defendant
Harriman Campus Rd.
Albany, New York 12226
GEORGE LUMBER & BUILDING MATERIAL INC.
Defendant
525 E. Mill Street
Little Falls, New York 13365
KEY BANK AS SUCCESSOR BY MERGER
TO FIRST NIAGARA BANK, N.A.
Defendant
127 Public Square
Cleveland, OH 44114
Dated: Kingston, New York
March 1, 2023
RAYMOND RAGUES
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NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONTGOMERY Index No. EF2022-477
FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC F/K/A REALTYFI REAL
ESTATE INVESTMENT TRUST LLC.,
Plaintiff,
-against-
LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD PROPERTIES LLC,
BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC, COR
HOLDINGS LLC, DAVID RAVEN, CARL ORSINI A/K/A CARLOS M ORSINI, NEW
YORK STATE DEPARTMENT OF TAXATION AND FINANCE, GEORGE LUMBER &
BUILDING MATERIAL INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST
NIAGARA BANK, N.A., JOHN DOE CORPORATIONS NOS.1-100 and JOHN DO
COMPANY NOS. 1-100,
Defendant.
VERIFIED ANSWER
And AFFIRMATIVE DEFENSES
RAGUES, PLLC
Attorneys for Defendants
LITTLE FALLS GARDEN APARTMENTS LLC
ROBINHOOD PROPERTIES LLC
BROOKVIEW TOWN HOUSE LLC A/K/A
BROOKVIEW TOWN HOUSES LLC
And DAVID RAVEN
Of)ìce and Post Office Address and Telephone
42 Crown Street
Kingston, New York 12401
(845) 481-0086
Service of a copy of the within VERIFIED ANSWER is hereby admitted.
Dated,
........................................................
Attorney(s) for
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Preview
FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONTGOMERY INDEX NO. EF2022-477 FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC F/K/A REALTYFI REAL ESTATE INVESTMENT TRUST LLC., VERIFIED ANSWER and AFFIRMATIVE Plaintiff, DEFENSES -against- LITTLE FALLS GARDEN APARTMENTS LLC, ROB1NHOOD PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC, DAVID RAVEN, CARL ORSINI A/K/A CARLOS M ORSINI, NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE, GEORGE LUMBER & BUILDING MATERIAL INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A., JOHN DOE CORPORATIONS NOS.1-100 and JOHN DO COMPANY NOS. 1-100, Defendants. C O U N S E L O R S : The defendants, LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC and DAVID RAVEN by their attorneys, Ragues, PLLC, as and for their Verified Answer to the Complaint, respectfully alleges, upon information and belief: 1. Denies each and every allegation contained in paragraph numbered "2", "4", "6", "9", "11", "44", "46", "49", of the Complaint. 2. Lacks information or knowledge sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph numbered "1", "8", "13-17", "19-43", "45", "47", "52" "53" "48', of the Complaint. 3. Denies each and every allegation contained in paragraph numbered 12 of the Complaint, except the Defendant Raven has interest in Mortgage Properties. 1 of 8 FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023 4. Lacks information or knowledge sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph numbered 18, except that Defendants Robinhood and Brookview gave Financing Statement to the Defendant KeyBank via First Niagara. AS AND FOR THE FIRST AFFIRMATIVE DEFENSE 5. The complaint herein is fatally defective as it fails to state a cause of action upon which relief may be granted. 6. RPAPL provisions require specific pleadings, including but not limited to whether Plaintiff possesses the note allegedly giving rise to this action. 7. Plaintiff's failure to allege anything with requisite specificity destroys its cause of action without any burden shifting to Defendant at any time. AS AND FOR THE SECOND AFFIRMATIVE DEFENSE 8. The Plaintiff sustained any damages or losses as alleged in the Complaint, all of which is expressly denied, then, such damages were caused, either in whole or in part, by the Plaintiff's or its agents, representative, employers, assignors, and/or assignees, own culpable conduct, fault, and/or negligence, and any recovery herein shall be diminished accordingly in whole or in part. 9. Plaintiff failed to take any action or sufficient action, or such action as was necessary, to mitigate or minimize the damages alleged, or the conditions that allegedly gave rise to those purported damages. AS AND FOR THE THIRD AFFIRMATIVE DEFENSE Plaintiff(s) failed to take any action or sufficient action, or such action as was necessary, to mitigate or minimize the damages alleged, or the conditions that allegedly gave rise to those 2 2 of 8 FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023 purported damages. WHEREFORE, the defendants LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC and DAVID RAVEN respectfully request judgment dismissing the complaint against answering Defendants, granting the costs and disbursements of this action, and for such other and further relief as to this Court may seem just and proper. Dated: Kingston, New York March 1, 2023 By: Raymond I agues, Esq. RAGUES, PLLC Attomeys for Defendants LITTLE FALLS GARDEN APARTMENTS LLC ROBINHOOD PROPERTIES LLC BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC And DAVID RAVEN 42 Crown Street Kingston, New York 12401 (845) 481-0086 Email: ray@ragueslaw.com Andrew M. Roth, Esq. SAHN WARD BRAFF KOBLENZ PLLC Attomeys for Plaintiff 333 Earle Ovington Boulevard Suite 601 Uniondale, New York 11530 (516) 228-1300 COR HOLDINGS, LLC Defendant 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 3 3 of 8 FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023 CARL ORSINI A/K/A CARLOS M. ORSINI Defendant 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE Defendant Harriman Campus Rd. Albany, New York 12226 GEORGE LUMBER & BUILDING MATERIAL INC. Defendant 525 E. Mill Street Little Falls, New York 13365 KEY BANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A. Defendant 127 Public Square Cleveland, OH 44114 4 4 of 8 FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONTGOMERY FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC INDEX NO. EF2022-477 F/K/A REALTYFI REAL ESTATE INVESTMENT TRUST LLC., Plaintiff, ATTORNEY'S -against- VERIFICATION LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC, DAVID RAVEN, CARL ORSINI A/K/A CARLOS M ORSINI, NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE, GEORGE LUMBER & BUILDING MATERIAL INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A., JOHN DOE CORPORATIONS NOS.1-100 and JOHN DO COMPANY NOS. 1-100, Defendants. Raymond Ragues, an attorney duly admitted to practice law in the State of New York, makes the following affirmation under the penalty of pedury: I am a member of the firm of RAGUES, PLLC, the attorneys of record for the defendant. I have read the foregoing Answer and know the contents thereof; the same is true to my own knowledge except as to the matters therein stated to be alleged on information and belief and that as to those matters, I believe them to be true. This verification is made by affirmant and not by defendant because defendant does not maintain its principal place of business within the County of Ulster, which is the County where your affirmant maintains ofHces. The grounds of affirmants belief as to all matters not stated upon affinnants knowledge are correspondence had with the said defendant, information contained in the said defendants file, which is in affirmants possession, and other pertinent data relating thereto. Dated: Kingston, New York March 1, 2023 RAvMONDtAGUES 5 5 of 8 FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONTGOMERY INDEX NO. EF2022-477 FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC F/K/A REALTYFI REAL ESTATE INVESTMENT TRUST LLC., AFFIRMATION OF Plaintiff, SERVICE -against- LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC, DAVID RAVEN, CARL ORSINI A/K/A CARLOS M ORSINI, NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE, GEORGE LUMBER & BUILDING MATERIAL INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A., JOHN DOE CORPORATIONS NOS.1-100 and JOHN DO COMPANY NOS. 1-100, Defendants. STATE OF NEW YORK ) )SS.: COUNTY OF ULSTER ) Raymond Ragues, an attorney admitted to practice law in the State of New York, affirms the following under the penalties of perjury: I am not a party to the action; I reside at Kingston, New York, and I am over 18 years of age. On March 1, 2023, I served the within Verified Answer by depositing a true copy thereof, enclosed in a post-paid wrapper, in an official depository under the exclusive care and custody of the United States Postal Service within New York State, addressed to the following at the last known address set forth below: Andres M. Roth, Esq. ( Via ECF and email) SAHN WARD BRAFF KOBLENZ PLLC 333 Earle Ovington Boulevard Suite 601 Garden City, New York 11530 Email: aroth@sahnward.com 6 of 8 FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023 COR HOLDINGS, LLC Defendant 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 CARL ORSINI A/K/A CARLOS M. ORSINI Defendant 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE Defendant Harriman Campus Rd. Albany, New York 12226 GEORGE LUMBER & BUILDING MATERIAL INC. Defendant 525 E. Mill Street Little Falls, New York 13365 KEY BANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A. Defendant 127 Public Square Cleveland, OH 44114 Dated: Kingston, New York March 1, 2023 RAYMOND RAGUES 2 7 of 8 FILED: MONTGOMERY COUNTY CLERK 03/01/2023 06:06 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 161 RECEIVED NYSCEF: 03/01/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONTGOMERY Index No. EF2022-477 FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC F/K/A REALTYFI REAL ESTATE INVESTMENT TRUST LLC., Plaintiff, -against- LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD PROPERTIES LLC, BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC, DAVID RAVEN, CARL ORSINI A/K/A CARLOS M ORSINI, NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE, GEORGE LUMBER & BUILDING MATERIAL INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A., JOHN DOE CORPORATIONS NOS.1-100 and JOHN DO COMPANY NOS. 1-100, Defendant. VERIFIED ANSWER And AFFIRMATIVE DEFENSES RAGUES, PLLC Attorneys for Defendants LITTLE FALLS GARDEN APARTMENTS LLC ROBINHOOD PROPERTIES LLC BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC And DAVID RAVEN Of)ìce and Post Office Address and Telephone 42 Crown Street Kingston, New York 12401 (845) 481-0086 Service of a copy of the within VERIFIED ANSWER is hereby admitted. Dated, ........................................................ Attorney(s) for 8 of 8