On January 11, 2023 a
Answer
was filed
involving a dispute between
Louann Associates Llc
And All Other Plaintiffs Similarly Situated Identified In The Annexed Exhibit A Affecting The Parcels Listed Therein By Section, Block, And Lot Description,
and
Albertson Fire Company,,
Albertson Water District,,
Amityville School District,,
Baldwin School District,,
Barnum Island Fire District,,
Bay Park Fire District,,
Bayville Fire Company No. 1,,
Belgrave Water Pollution Control District,,
Bellerose Fire District,,
Bellerose Terrace Fire Department,,
Bellmore School District,,
Bethpage Water District,,
Bruce A. Blakeman,
In His Official Capacity As Nassau County Executive,,
Carle Place Water District,,
Cathedral Gardens Water District,,
City Of Glen Cove,,
City Of Long Beach,,
City Of Long Beach Public Works Division Of Sewer Maintenance,,
County Of Nassau,,
David Y. Chiang,
In His Official Capacity As Nassau County Treasurer,,
East Williston Fire District,,
Elmont Fire District,,
Farmingdale School District,,
Floral Park-Bellerose Fire District,,
Flower Hill Hose Company No. 1,,
Franklin Square-Munson Fire District,,
Freeport School District,,
Freeport Village,
Garden City School District,,
Garden City Water And Sewer Department,,
Glen Cove School District,,
Glen Cove Water Department,,
Glenwood Landing Fire Department,,
Glenwood Water District,,
Greater Atlantic Beach Water Reclamation District,,
Great Neck Water Pollution Control District,,
Hempstead School District,,
Herricks School District,,
Hewlett Fire District,,
Hewlett-Woodmere School District,,
Hicksville Water District,,
Incorporated Village Of Bayville School District,,
Incorporated Village Of Williston Park Water Department,,
Inwood Fire District,,
Island Trees School District,,
Jericho Water District,,
Lake Success Village,
Lakeview School District,,
Lawrence-Cedarhurst Fire District,,
Lawrence Union Free School District,,
Levittown School District,,
Locust Valley Water District,,
Long Beach School District,,
Lynbrook Water District,,
Malverne School District,,
Manhasset-Lakeville Water District,,
Manhasset School District,,
Manorhaven Village,
Massapequa Water District,,
Matthew R. Cronin,
In His Official Capacity As Assessor Of The County Of Nassau,,
Meadowmere Park Fire District,,
Merrick Union Free School District,,
Mineola School District,,
Mineola Village,
Nassau County Department Of Assessment,,
Nassau County Department Of Public Works,,
Nassau County Legislature,,
Nassau County Police Department,,
New Hyde Park-Garden City Park School District,,
New Hyde Park-Garden City Ufsd,,
New York American Water-Merrick,,
New York American Water-Sea Cliff,,
North Shore School District,,
Oceanside School District,,
Oyster Bay-East Norwich Central School District,,
Plainedge Public Schools,,
Plainview-Old Bethpage School District,,
Plainview Water District,,
Plandome Fire Department,,
Point Lookout-Lido Fire District,,
Port Washington Water Pollution Control District,,
Rockville Centre School District,,
Rockville Centre Village,
Roosevelt School District,,
Roslyn Village,
Roslyn Water District,,
Sanitary District 6,,
Sanitary District No. 2,,
Sea Cliff Fire District,,
Seaford School District,,
South Floral Park Fire Department,,
South Hempstead Fire District,,
Stewart Manor Fire District,,
Syosset School District,
Town Of Hempstead,,
Town Of Hempstead Water Department,,
Town Of North Hempstead,,
Town Of Oyster Bay,,
Uniondale School District,,
Valley Stream Fire District,,
Valley Stream School District 13,,
Valley Stream School District 24,,
Valley Stream School District 30,,
Village Of Hempstead Water Department,,
Village Of Mineola Water Department,,
Village Of Old Westbury Water Department,,
Village Of Rockville Centre Water Department,,
Village Of Sands Point Water Department,,
Wantagh School District,,
Water Authority Of Great Neck North,,
Westbury Water District,,
West Hempstead Water District,,
Williston Park Fire District,,
Woodbury Fire Company No. 1,,
Woodmere Fire District,,
for Real Property - Tax Certiorari
in the District Court of Nassau County.
Preview
FILED: NASSAU COUNTY CLERK 05/24/2023 11:07 AM INDEX NO. 600700/2023
NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
------------------------------------------------------------------Ç
LOUANN ASSOCIATES LLC, Index No.: 600700/2023
and all other Plaintiffs similarly situated identified
"A"
in the annexed Exhibit affecting the parcels listed
therein by Section, Block and Lot description, ANSWER
Plaintiffs,
-against-
BRUCE A. BLAKEMAN, in his official capacity as
NASSAU COUNTY EXECUTIVE ...
BETHPAGE SCHOOL DISTRICT, et. al.,
Defendants.
------------------------------------------------------------------X
Defendant, Bethpage Union Free School District s/h/a Bethpage School District, by its
attorneys, Jaspan Schlesinger Narendran LLP, as and for its answer to the summons and complaint,
dated January 11, 2023, responds to the allegations of the complaint, and alleges, upon information
and belief, as follows:
1. Denies having knowledge or information sufficient to form a belief as to the truth
of the allegations contained in paragraphs of the complaint numbered 1, 2, 3, 4, 5, 6, 7, 8, 9, 10,
11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37,
38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63,
64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89,
90, 91, 92, 93, 94, 95, 96, 97, 98, 99, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111,
112, 113, 114, 115, 116, 117, 118, 119, 120, 121, 122, 123, 124, 125, 126, 127, 128, 129, 130,
131, 132, 133, 134, 135, 136, 137, 138, 139, 140, 141, 142, 143, 144, 145, 146, 147, 148, 149,
150, 151, 152, 153, 154, 155, 156, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, 168,
1
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169, 170, 171, 172, 173, 174, 175, 176, 177, 178, 179, 180, 181, 182, 183, 184, 185, 186, 187,
188, 189, 190, 191, 192, 193, 194, 195, 196, 197, 198, 199, 200, 201 and 202.
2. Admits the truth of allegations contained in paragraph 22.
3. The contents of the paragraphs of the complaint numbered 203, 204, 205, 206, 207,
208, 209, 210, 211, 212, 213, 214, 215, 216, 217, 218, 219, 220, 221, 222, 223, 224, 225, 226,
227, 228, 229, 230, 231, 232, 233, 234, 235, 236, 237, 238, 239, 240, 241, 242, 243 and 244 do
not contain factual allegations but rather are legal conclusions to which no response is required,
and which are referred to the Court for resolution. To the extent a response is required, defendant
denies knowledge and information sufficient to form a belief as to the allegations.
ANSWERING THE FIRST CAUSE OF ACTION
4. In response to paragraph 245, defendant repeats, reiterates, and realleges each and
every response to the proceeding paragraphs as if fully set forth herein.
5. The contents of the paragraphs of the complaint numbered 246, 247, 249, and 250
do not contain factual allegations but rather are legal conclusions to which no response is required,
and which are referred to the Court for resolution. To the extent a response is required, defendant
denies knowledge and information sufficient to form a belief as to the allegations.
6. Denies knowledge and information sufficient to form a belief as to the allegations
contained in paragraph 248 of the complaint, but avers that plaintiffs did not provide defendant
with notice that the disputed payments were paid under protest.
ANSWERING THE SECOND CAUSE OF ACTION
7. In response to paragraph 251, defendant repeats, reiterates, and realleges each and
every response to the proceeding paragraphs as if fully set forth herein.
2
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8. The contents of the paragraphs of the complaint numbered 252, 253, 254, 255, 256,
257, 258, 259, 261, 262, 263, and 264 do not contain factual allegations but rather are legal
conclusions to which no response is required, and which are referred to the Court for resolution.
To the extent a response is required, defendant denies knowledge and information sufficient to
form a belief as to the allegations.
9. Denies knowledge and information sufficient to form a belief as to the allegations
contained in paragraph 260 of the complaint except denies that the answering defendant is in
plaintiffs'
possession of any monies in excess of what was necessary to pay some refunds.
10. Denies the allegations contained in paragraph 265 of the complaint.
ANSWERING THE THIRD CAUSE OF ACTION
11. In response to paragraph 266, defendant repeats, reiterates, and realleges each and
every response to the preceding paragraphs of the complaint as if fully set forth herein.
12. The contents of the paragraphs of the complaint numbered 267, 268, 269, 270, 271,
272, 273, 274, 275, 276, 277, 278, 279, and 280 do not contain factual allegations but rather are
legal conclusions to which no response is required, which are referred to the Court for resolution.
To the extent a response is required, defendant denies knowledge and information sufficient to
form a belief as to the allegations.
13. Denies the allegations contained in paragraph 281 of the complaint.
ANSWERING THE FOURTH CAUSE OF ACTION
14. In response to paragraph 282, defendant repeats, reiterates, and realleges each and
every response to the preceding paragraphs of the complaint as if fully set forth herein.
15. The contents of the paragraphs of the complaint numbered 283, 284, 285 and 286
of the complaint do not contain factual allegations but rather are legal conclusions to which no
3
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response is required, and which are referred to the Court for resolution. To the extent a response
is required, defendant denies knowledge and information sufficient to form a belief as to the
allegations.
16. Denies the allegations contained in paragraph 287 of the complaint.
ANSWERING THE FIFTH CAUSE OF ACTION
17. In response to paragraph 288 of the complaint, defendant repeats, reiterates, and
realleges each and every response to the preceding paragraphs of the complaint as if fully set forth
herein.
18. The contents of the paragraphs of the complaint numbered 289, 290, 291, 292, 293,
and 294 of the complaint do not contain factual allegations but rather are legal conclusions to
which no response is required, and which are referred to the Court for resolution. To the extent a
response is required, defendant denies knowledge and information sufficient to form a belief as to
the allegations.
19. Denies the allegations contained in paragraph 295 of the complaint.
ANSWERING THE SIXTH CAUSE OF ACTION
20. In response to paragraph 296, defendant repeats, reiterates, and realleges each and
every response to the preceding paragraphs of the complaint as if fully set forth herein.
21. The contents of the paragraphs of the complaint numbered 297, 298, 299, 301, 302,
303, 304, 305, 306, 307, 309, 310 and 311 of the complaint do not contain factual allegations but
rather are legal conclusions to which no response is required, which are referred to the Court for
resolution. To the extent a response is required, defendant denies knowledge and information
sufficient to form a belief as to the allegations.
4
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22. Denies knowledge or information sufficient to form a belief as to the truth of the
allegations contained in paragraph 300 of the complaint except admits that defendant received
proceeds from real property taxes necessary to fund its budget for the years at issue.
23. Denies knowledge or information sufficient to form a belief as to the truth of the
allegations contained in paragraph 308 of the complaint, except denies that defendant is in
possession of any such alleged funds.
24. Denies the allegations contained in paragraphs 312 and 313 of the complaint.
ANSWERING THE SEVENTH CAUSE OF ACTION
25. In response to paragraph 314, defendant repeats, reiterates, and realleges each and
every denial in response to the preceding paragraphs of the complaint as if fully set forth herein.
26. The contents of the paragraphs of the complaint numbered 315, 316, and 317 do
not contain factual allegations but rather are legal conclusions to which no response is required,
which are referred to the Court for resolution. To the extent a response is required, defendant
denies knowledge and information sufficient to form a belief as to the allegations.
27. Denies the allegations contained in paragraph 318 of the complaint.
AS AND FOR A FIRST AFFIRMATIVE DEFENSE
28. That the Complaint fails to state a cause of action against the answering defendant.
AS AND FOR A SECOND AFFIRMATIVE DEFENSE
29. Plaintiffs are barred from bringing this action against the answering defendant
insofar as plaintiffs failed to comply with the requirements of Education Law §3813 to serve a
notice of claim upon the answering defendant.
5
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AS AND FOR A THIRD AFFIRMATIVE DEFENSE
30. Plaintiffs are barred from recovering any funds from the answering defendant
insofar as plaintiffs failed to timely notify the answering defendant that any payments of the
disputed funds were made under protest and in derogation of the answering defendant's rights.
AS AND FOR A FOURTH AFFIRMATIVE DEFENSE
Plaintiffs'
31. claims are barred by the statute of limitations.
AS AND FOR A FIFTH AFFIRMATIVE DEFENSE
Plaintiffs'
32. claims for unjust enrichment are barred and are not ripe for review as the
answering defendant is not in possession of any proceeds from the Disputed Assessment Fund
which, upon information and belief, is in the custody and control of the County of Nassau.
AS AND FOR A SIXTH AFFIRMATIVE DEFENSE
Plaintiffs'
33. claims are barred by res judicata and/or collateral estoppel.
AS AND FOR A SEVENTH AFFIRMATIVE DEFENSE
Plaintiffs'
34. claims are barred by the doctrine of laches, waiver and estoppel.
WHEREFORE, the answering defendant demands judgment dismissing the complaint in
attorneys'
its entirety together with the costs, disbursements and expenses of this action including
fees, and granting such other and further relief as this Court deems just and proper.
Dated: Garden City, New York
May 23, 2023
JASPAN SCHLESINGER NARENDRAN LLP
Attorneys for Defendant
Bethpage Union Free School District
By:
C RISTOPHER E. VATTER, ESQ.
ANDREW M. MAHONY, ESQ.
5th
300 Garden City Plaza, PlOOr
Garden City, New York 11530
(516) 746-8000
6
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NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023
VIA NYSCEF
To: ALL APPEARING PARTIES
7
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Preview
FILED: NASSAU COUNTY CLERK 05/24/2023 11:07 AM INDEX NO. 600700/2023 NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ------------------------------------------------------------------Ç LOUANN ASSOCIATES LLC, Index No.: 600700/2023 and all other Plaintiffs similarly situated identified "A" in the annexed Exhibit affecting the parcels listed therein by Section, Block and Lot description, ANSWER Plaintiffs, -against- BRUCE A. BLAKEMAN, in his official capacity as NASSAU COUNTY EXECUTIVE ... BETHPAGE SCHOOL DISTRICT, et. al., Defendants. ------------------------------------------------------------------X Defendant, Bethpage Union Free School District s/h/a Bethpage School District, by its attorneys, Jaspan Schlesinger Narendran LLP, as and for its answer to the summons and complaint, dated January 11, 2023, responds to the allegations of the complaint, and alleges, upon information and belief, as follows: 1. Denies having knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraphs of the complaint numbered 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 90, 91, 92, 93, 94, 95, 96, 97, 98, 99, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, 116, 117, 118, 119, 120, 121, 122, 123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 134, 135, 136, 137, 138, 139, 140, 141, 142, 143, 144, 145, 146, 147, 148, 149, 150, 151, 152, 153, 154, 155, 156, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, 168, 1 LRK / #1703295v2 / 0020071 - 000500 1 of 7 FILED: NASSAU COUNTY CLERK 05/24/2023 11:07 AM INDEX NO. 600700/2023 NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023 169, 170, 171, 172, 173, 174, 175, 176, 177, 178, 179, 180, 181, 182, 183, 184, 185, 186, 187, 188, 189, 190, 191, 192, 193, 194, 195, 196, 197, 198, 199, 200, 201 and 202. 2. Admits the truth of allegations contained in paragraph 22. 3. The contents of the paragraphs of the complaint numbered 203, 204, 205, 206, 207, 208, 209, 210, 211, 212, 213, 214, 215, 216, 217, 218, 219, 220, 221, 222, 223, 224, 225, 226, 227, 228, 229, 230, 231, 232, 233, 234, 235, 236, 237, 238, 239, 240, 241, 242, 243 and 244 do not contain factual allegations but rather are legal conclusions to which no response is required, and which are referred to the Court for resolution. To the extent a response is required, defendant denies knowledge and information sufficient to form a belief as to the allegations. ANSWERING THE FIRST CAUSE OF ACTION 4. In response to paragraph 245, defendant repeats, reiterates, and realleges each and every response to the proceeding paragraphs as if fully set forth herein. 5. The contents of the paragraphs of the complaint numbered 246, 247, 249, and 250 do not contain factual allegations but rather are legal conclusions to which no response is required, and which are referred to the Court for resolution. To the extent a response is required, defendant denies knowledge and information sufficient to form a belief as to the allegations. 6. Denies knowledge and information sufficient to form a belief as to the allegations contained in paragraph 248 of the complaint, but avers that plaintiffs did not provide defendant with notice that the disputed payments were paid under protest. ANSWERING THE SECOND CAUSE OF ACTION 7. In response to paragraph 251, defendant repeats, reiterates, and realleges each and every response to the proceeding paragraphs as if fully set forth herein. 2 LRK / #1703295v2 / 0020071 - 000500 2 of 7 FILED: NASSAU COUNTY CLERK 05/24/2023 11:07 AM INDEX NO. 600700/2023 NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023 8. The contents of the paragraphs of the complaint numbered 252, 253, 254, 255, 256, 257, 258, 259, 261, 262, 263, and 264 do not contain factual allegations but rather are legal conclusions to which no response is required, and which are referred to the Court for resolution. To the extent a response is required, defendant denies knowledge and information sufficient to form a belief as to the allegations. 9. Denies knowledge and information sufficient to form a belief as to the allegations contained in paragraph 260 of the complaint except denies that the answering defendant is in plaintiffs' possession of any monies in excess of what was necessary to pay some refunds. 10. Denies the allegations contained in paragraph 265 of the complaint. ANSWERING THE THIRD CAUSE OF ACTION 11. In response to paragraph 266, defendant repeats, reiterates, and realleges each and every response to the preceding paragraphs of the complaint as if fully set forth herein. 12. The contents of the paragraphs of the complaint numbered 267, 268, 269, 270, 271, 272, 273, 274, 275, 276, 277, 278, 279, and 280 do not contain factual allegations but rather are legal conclusions to which no response is required, which are referred to the Court for resolution. To the extent a response is required, defendant denies knowledge and information sufficient to form a belief as to the allegations. 13. Denies the allegations contained in paragraph 281 of the complaint. ANSWERING THE FOURTH CAUSE OF ACTION 14. In response to paragraph 282, defendant repeats, reiterates, and realleges each and every response to the preceding paragraphs of the complaint as if fully set forth herein. 15. The contents of the paragraphs of the complaint numbered 283, 284, 285 and 286 of the complaint do not contain factual allegations but rather are legal conclusions to which no 3 LRK / #1703295v2 / 002007 1 - 000500 3 of 7 FILED: NASSAU COUNTY CLERK 05/24/2023 11:07 AM INDEX NO. 600700/2023 NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023 response is required, and which are referred to the Court for resolution. To the extent a response is required, defendant denies knowledge and information sufficient to form a belief as to the allegations. 16. Denies the allegations contained in paragraph 287 of the complaint. ANSWERING THE FIFTH CAUSE OF ACTION 17. In response to paragraph 288 of the complaint, defendant repeats, reiterates, and realleges each and every response to the preceding paragraphs of the complaint as if fully set forth herein. 18. The contents of the paragraphs of the complaint numbered 289, 290, 291, 292, 293, and 294 of the complaint do not contain factual allegations but rather are legal conclusions to which no response is required, and which are referred to the Court for resolution. To the extent a response is required, defendant denies knowledge and information sufficient to form a belief as to the allegations. 19. Denies the allegations contained in paragraph 295 of the complaint. ANSWERING THE SIXTH CAUSE OF ACTION 20. In response to paragraph 296, defendant repeats, reiterates, and realleges each and every response to the preceding paragraphs of the complaint as if fully set forth herein. 21. The contents of the paragraphs of the complaint numbered 297, 298, 299, 301, 302, 303, 304, 305, 306, 307, 309, 310 and 311 of the complaint do not contain factual allegations but rather are legal conclusions to which no response is required, which are referred to the Court for resolution. To the extent a response is required, defendant denies knowledge and information sufficient to form a belief as to the allegations. 4 LRK/#1703295v2 / 0020071 - 000500 4 of 7 FILED: NASSAU COUNTY CLERK 05/24/2023 11:07 AM INDEX NO. 600700/2023 NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023 22. Denies knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 300 of the complaint except admits that defendant received proceeds from real property taxes necessary to fund its budget for the years at issue. 23. Denies knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 308 of the complaint, except denies that defendant is in possession of any such alleged funds. 24. Denies the allegations contained in paragraphs 312 and 313 of the complaint. ANSWERING THE SEVENTH CAUSE OF ACTION 25. In response to paragraph 314, defendant repeats, reiterates, and realleges each and every denial in response to the preceding paragraphs of the complaint as if fully set forth herein. 26. The contents of the paragraphs of the complaint numbered 315, 316, and 317 do not contain factual allegations but rather are legal conclusions to which no response is required, which are referred to the Court for resolution. To the extent a response is required, defendant denies knowledge and information sufficient to form a belief as to the allegations. 27. Denies the allegations contained in paragraph 318 of the complaint. AS AND FOR A FIRST AFFIRMATIVE DEFENSE 28. That the Complaint fails to state a cause of action against the answering defendant. AS AND FOR A SECOND AFFIRMATIVE DEFENSE 29. Plaintiffs are barred from bringing this action against the answering defendant insofar as plaintiffs failed to comply with the requirements of Education Law §3813 to serve a notice of claim upon the answering defendant. 5 LRK / #1703295v2 / 0020071 - 000500 5 of 7 FILED: NASSAU COUNTY CLERK 05/24/2023 11:07 AM INDEX NO. 600700/2023 NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023 AS AND FOR A THIRD AFFIRMATIVE DEFENSE 30. Plaintiffs are barred from recovering any funds from the answering defendant insofar as plaintiffs failed to timely notify the answering defendant that any payments of the disputed funds were made under protest and in derogation of the answering defendant's rights. AS AND FOR A FOURTH AFFIRMATIVE DEFENSE Plaintiffs' 31. claims are barred by the statute of limitations. AS AND FOR A FIFTH AFFIRMATIVE DEFENSE Plaintiffs' 32. claims for unjust enrichment are barred and are not ripe for review as the answering defendant is not in possession of any proceeds from the Disputed Assessment Fund which, upon information and belief, is in the custody and control of the County of Nassau. AS AND FOR A SIXTH AFFIRMATIVE DEFENSE Plaintiffs' 33. claims are barred by res judicata and/or collateral estoppel. AS AND FOR A SEVENTH AFFIRMATIVE DEFENSE Plaintiffs' 34. claims are barred by the doctrine of laches, waiver and estoppel. WHEREFORE, the answering defendant demands judgment dismissing the complaint in attorneys' its entirety together with the costs, disbursements and expenses of this action including fees, and granting such other and further relief as this Court deems just and proper. Dated: Garden City, New York May 23, 2023 JASPAN SCHLESINGER NARENDRAN LLP Attorneys for Defendant Bethpage Union Free School District By: C RISTOPHER E. VATTER, ESQ. ANDREW M. MAHONY, ESQ. 5th 300 Garden City Plaza, PlOOr Garden City, New York 11530 (516) 746-8000 6 LRK / #1703295v2 / 0020071 - 000500 6 of 7 FILED: NASSAU COUNTY CLERK 05/24/2023 11:07 AM INDEX NO. 600700/2023 NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/24/2023 VIA NYSCEF To: ALL APPEARING PARTIES 7 LRK /#1703295v2 /0020071 - 000500 7 of 7