Answer: Kroll Commercial Rea Lty, Llc Vs Star X, Inc.

On September 23, 2022 a Answer was filed involving a dispute between Kroll Commercial Realty, Llc, and Chris Murray, Star X, Inc., for Book Account (Debt Collection Matters Only) in the District Court of Middlesex County.

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MID-L-004791-22 12/05/2022 3:21:06 PM Pglof6 Trans ID: LCV20224136849

MALCOLM J. McPHERSON, JR., P.C.
Attorney ID #019441982
20 Park Avenue, Suite 2B
P.O. BOX 206
Lyndhurst, NJ 07071
(201) 939-0011
Attorney for Defendants

}SUPERIOR COURT OF NEW JERSEY
KROLL COMMERCIAL REALTY, LLC, }LAW DIVISION
}MIDDLESEX COUNTY
Plaintiff
Vv. } DOCKET NO, MID-L-4791-22

STAR X, INC AND CHRISTOPHER MURRAY, } CIVIL ACTION

Defendants } ANSWER
}
}

The Defendants, Star X, Inc. and Christopher Murray, by way of Answer to Plaintiff's

Amended Complaint says:

FACTS COMMON TO ALL COUNTS

1 Defendants lack sufficient knowledge of the allegations contained in paragraph 1

and leaves the Plaintiff to its proofs.

2 Defendants lack sufficient knowledge of the allegations contained in paragraph 2

and leaves the Plaintiff to its proofs.

3 Defendants admit the allegations contained in paragraph 3.

4. Defendants admit the allegations contained in paragraph 4.

5 Defendants admit the property is commercial property however denies remaining

allegations and leave the Plaintiff to its proofs.

6 Defendants admit the allegations contained in paragraph 6.

7. Defendants admit the allegations contained in paragraph 7.
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8 Defendants deny the allegations contained in paragraph 8 and leave the Plaintiff

to its proofs

9 Defendants deny the allegations contained in paragraph 9 and leave the Plaintiff

to its proofs.

10. Defendants admit the allegations contained in paragraph 10.

il. Defendants deny the allegations contained in paragraph 11 and leave the Plaintiff

to its proofs.

12. Defendants deny the allegations contained in paragraph 12 and leave the Plaintiff

to its proofs.

13, Defendants deny the allegations contained in paragraph 13 and leave the Plaintiff

to its proofs.

COUNT 1

14, Defendants repeat and re-allege all of the responses contained in paragraph 1 to

13 as if set forth at length herein.

15. Defendants deny the allegations contained in paragraph 15 and leave the Plaintiff

to its proofs.

16. Defendants deny the allegations contained in paragraph 16 and leave the Plaintiff

to its proofs.

17. Defendants deny the allegations contained in paragraph 17 and leave the Plaintiff

to its proofs.

18. Defendants deny the allegations contained in paragraph 18 and leave the Plaintiff

to its proofs.
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19, Defendants deny the allegations contained in paragraph 19 and leave the Plaintiff

to its proofs

20. Defendants deny the allegations contained in paragraph 20 and leave the Plaintiff

to its proofs

COUNT II

21. Defendants repeat and re-allege all of the responses contained in paragraph 1 to

20 as if set forth at length herein.

22, Defendants admit the allegations contained in paragraph 22.

23. Defendants deny the allegations contained in paragraph 23 and leave the Plaintiff

to its proofs.

24. Defendants deny the allegations contained in paragraph 24 and leave the Plaintiff

to its proofs.

25. Defendants deny the allegations contained in paragraph 25 and leave the Plaintiff

to its proofs.

COUNT IIT

26. Defendants repeat and re-allege all of the responses contained in paragraph 1 to

25 as if set forth at length herein.

27. Defendant admits the allegations contained in paragraph 27 and leaves the

Plaintiff to its proofs.

28. Defendant admits the allegations contained in paragraph 28 and leaves the

Plaintiff to its proofs,

29, Defendant denies the allegations contained in paragraph 29 and leave the Plaintiff

to its proofs.
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WHEREFORE, the Defendants demand a Judgment dismissing the Plaintiffs

Complaint and requesting a Judgment awarding counsel fees to the Defendants and any other

relief as the Court may deem just and proper.

Malcolm J. McPherson, Jr., P.C.

enw
ce oo
ae
wea M icPhe eI
An Attorney at Law of New Ji ersey..<”
Attorney for Defendants

AFFIRMATIVE DEFENSES

1 The Complaint fails to state a course of action upon which relief may be granted.

2 The Defendant, Christopher Murray did not personally guarantee the obligations

of the Defendant, Star X, Inc.

3 AJA Restaurant, LLA a tenant at 28 Route 1, New Brunswick, New Jersey

defaulted under the terms of the Lease Agreement dated May 25, 2011 with the Defendant, Star

X, Inc.

4. Plaintiff claims are barred by virtue of the fact that Plaintiff's damages if any,

were caused by its own acts and/or omissions and/or the acts and/or omissions of its agents,

servants, employees or representatives, to which acts and/or omissions Defendants did not

contribute, in which Defendants played no part and for which Defendants not be held liable.

5 Any recovery by Plaintiff in this action would result in unjust enrichment to

Plaintiff.
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6 Plaintiff's claims are barred and limited as the result of the acts, omissions or

negligence of third parties over whom the Defendants had no control.

Malcolm J. McPherson, Jr., P.C.

a
colm J. McPhersoh™ Tr, P.C.
An Attorney at Law of New Jersey
Attomey for Defendants

CERTIFICATION

Thereby certify, pursuant to Rule 4:5-1(b)(2), that the matter in controversy herein is not

the subject of other pending legal proceeding or arbitration, nor is any other legal proceeding

contemplated to the best of my information and belief. Further, | presently know of no other

party who should be joined in this lawsuit.

CERTIFICATION

Jherby certify, pursuant to Rule 4:5-1(b)(3), that confidential personal identifiers have

been redacted from documents now submitted to the Court, and will be redacted from afl

documents submitted in the future in accordance with Rule 1:38-7(b).

CERTIFICATION

Thereby certify that this pleading was filed within the time provided by Rule 4:6-1{a) and

served upon all counsel of record.
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DEMAND FOR STATEMENT OF DAMAGES

Pursuant to Rule 4:5-2, Defendant Star X, Inc, and Christopher Murray, hereby

demands from Plaintiff, within 5 days after service hereof, a written statement of the amount of

damages claimed in its Complaint. paren ener
lee
a enn
Byz anon
“MalcolnrS. McPhgrsom, Jr., P.C.
An Attorney at Law of New Jersey
Attorney for Defendants
MID-L-004791-22 12/05/2022 3:21:06 PM Pglof1 Trans ID: LCV20224136849

Civil Case Information Statement
Yd
(CIs) Chg/Ck Number:
aoc Use for initial Law Division Amount:
oso
ogg Civil Part pleadings (not motions) under Rule Ase
Ss Pleading will be rejected for filing, under Rule 1:5-6(c), Overpayment:
ais
if information above the black bar is not completed
or attorney’s signature is not affixed Batch Number:

Attormey/Pro Se Name Telephone Number County of Venue
Malcolm J. McPherson, Jr., Esq. (201) 939-0011 Bergen
Firm Name (if applicable) Docket Number (when available)
Maicolm J. McPherson, Jr., Esq. MID-L-4791-22
Office Address Document Type.
PO Box 206, Lyndhurst, New Jersey 07071 Answer
Jury Demand O ves HINo
Namo of Party (e.g., John Doe, Plaintiff) Caption
Star X Inc. and Christopher Murray Kroll Commercial Realty, LLC v. StarX Inc. and Christopher Murray

Case Type Number Are sexual abuse claims
(See reverse side for listing) alleged
Is this a professional malpractice case? O Yes BI No
599 O Yes WIN If you have checked “Yes," seo N.J.S.A. 2A:53A-27 and applicable case law
regarding your obligation to file an affidavit of merit
Related Cases Pending? If Yes,” list docket numbers
O Yes HENo

Do you anticipate adding any parties Name of defendant's primary Insurance company (If known)
(arising out of same transaction or occurrence)? Mi None
D1 Yes HINo 11 Unknown

Case Characteristics for Purposes of Determining if Case is Appropriate for Mediation
Do parties have a current, past or recurrent relationship? If Yes,” is that relationship:
DlEmployer/Employee [1] Friend/Neighbor O Other (explain)
yes Ono O Familial Mi Business

Does the statute governing this case provide for payment of fees by the fosing party? OYes HENo

Use this space to alert the court to any special case characteristics that may warrant individual management or accelerated disposition

& Do you or your client need any disabiliy accommodations?
O Yes HINo
Will an interproter be needed?
If yes, please identify the requested accommodation:

If yes, for what language?
OD Yes No

| certify that confidential personal identifiers have been redacted from documents now submitted to the court and will be
redacted from all documents submitted in the future in accordance with Rule 1:38-7(b).

Attorney See 2A
———— —
a
Revised Form Promulgated by 01/31/2020 Notice to the Bar, CN 10517 (Appendix XII-B1) page 4 of 2
MID-L-004791-22 12/05/2022 3:21:06 PM Pglof2 Trans ID: LCV20224136849

Civil Case Information Statement

Case Details: MIDDLESEX | Civil Part Docket# L-004791-22

Case Caption: KROLL COMMERCIAL REALTY, LLC VS Case Type: BOOK ACCOUNT (DEBT COLLECTION MATTERS.
STAR X, INC. ONLY)
Case Initiation Date: 09/23/2022 Document Type: Answer
Attorney Name: MALCOLM, J MC PHERSON Jury Demand: NONE
Firm Name: MALCOLM MCPHERSON, JR., PC Is this a professional malpractice case? NO
Address: 20 PARK AVENUE STE 2B PO BOX 206 Related cases pending: NO
LYNDHURST NJ 07071 If yes, list docket numbers:
Phone: 2019390011 Do you anticipate adding any parties (arising out of same
Name of Party: DEFENDANT : STAR X, INC. transaction or occurrence)? NO
Name of Defendant's Primary Insurance Company Does this case involve claims related to COVID-19? NO
(if known): None
Are sexual abuse claims alleged by: KROLL COMMERCIAL
REALTY, LLC? NO

THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION

Do parties have a current, past, or recurrent relationship? YES

If yes, is that relationship: Business

Does the statute governing this case provide for payment of fees by the losing party? NO

Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:

Do you or your client need any disability accommodations? NO
If yes, please identify the requested accommodation:

Will an interpreter be needed? NO
If yes, for what language:

Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO

| certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)

12/05/2022 /s/ MALCOLM, J MC PHERSON
Dated Signed
MID-L-004791-22 12/05/2022 3:21:06 PM Pg2of2 Trans ID: LCV20224136849

Case Info

Judge

Laurence J Bravman Track Judge’s New Case

Case No.

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Document Filed Date

December 05, 2022

Case Filing Date

September 23, 2022

County

Parties

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