Answer: The Lcf Group, Inc., v. Letzring Inc D/B/A LETZRING, Letz Marine Llc, Northern Alaska Mining Co Llc, Seldovia Bay Waterfront Properties Llc, Port Graham Properties Llc, Lop Llc, Upper Coho Lake Llc, T&L Equipment Inc., Matthew George Letzring

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                                FILED: NASSAU COUNTY CLERK 08/16/2023 06:29 AM                                                  INDEX NO. 612295/2023
NYSCEF DOC. NO. 9                                                                         RECEIVED NYSCEF: 08/16/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NASSAU
          ---------------------------------------------------------------------x
          THE LCF GROUP, INC.,                                                     INDEX NO.: 612295/2023

                                             Plaintiff,

          - against -
                                                                                     VERIFIED ANSWER
          LETZRING INC D/B/A LETZRING,
          LETZ MARINE LLC, NORTHERN ALASKA MINING CO LLC,
          SELDOVIA BAY WATERFRONT PROPERTIES LLC,
          PORT GRAHAM PROPERTIES LLC, LOP LLC,
          UPPER COHO LAKE LLC, T&L EQUIPMENT INC.,
          and MATTHEW GEORGE LETZRING,

                                              Defendants.
          ---------------------------------------------------------------------x


                  Defendants, LETZRING INC D/B/A LETZRING, LETZ MARINE LLC, NORTHERN

          ALASKA MINING CO LLC, SELDOVIA BAY WATERFRONT PROPERTIES LLC, PORT

          GRAHAM PROPERTIES LLC, LOP LLC, UPPER COHO LAKE LLC, T&L EQUIPMENT

          INC., and MATTHEW GEORGE LETZRING, by and through their attorney, Yana

          Chechelnitsky, Esq., answer the Verified Complaint of Plaintiff and say:

                  1.       Defendants are without knowledge or information sufficient to form a belief as to
          the truth of the allegations contained in Paragraph “1”.
                  2.       Defendants are without knowledge or information sufficient to form a belief as to
          the truth of the allegations contained in Paragraph “2”.
                  3.       Defendants admit the allegations contained in Paragraph “3”.
                  4.       Defendants admit the allegations contained in Paragraph “4”.
                  5.       Defendants admit the allegations contained in Paragraph “5”.
                  6.       Defendants admit the allegations contained in Paragraph “6”.
                  7.       Defendants admit the allegations contained in Paragraph “7”.
                  8.       Defendants admit the allegations contained in Paragraph “8”.
                  9.       Defendants admit the allegations contained in Paragraph “9”.




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FILED: NASSAU COUNTY CLERK 08/16/2023 06:29 AM                                                  INDEX NO. 612295/2023
NYSCEF DOC. NO. 9                                                                         RECEIVED NYSCEF: 08/16/2023




                  10.     Defendants admit the allegations contained in Paragraph “10”.
                  11.     Defendants admit the allegations contained in Paragraph “11”.
                  12.     Defendants make no answer to Paragraph “12”.
                  13.     Defendants admit the allegations contained in Paragraph “13” that they signed a
          contract with Plaintiff and deny the remaining allegations of said paragraph.
                  14.     Defendants are without knowledge or information sufficient to form a belief as to
          the truth of the allegations contained in Paragraph “14”.
                  15.     Defendants deny the allegations contained in Paragraph “15”.
                  16.     Defendants admit the allegations contained in Paragraph “16” that they signed a
          contract with Plaintiff and deny the remaining allegations of said paragraph.
                  17.     Defendants admit the allegations contained in Paragraph “17” that they signed a
          contract with Plaintiff and deny the remaining allegations of said paragraph.
                  18.     Defendants admit the allegations contained in Paragraph “18” that they signed a
          contract with Plaintiff and deny the remaining allegations of said paragraph.
                  19.     Defendants admit the allegations contained in Paragraph “19” that they signed a
          contract with Plaintiff and deny the remaining allegations of said paragraph.
                  20.     Defendants admit that they made payments pursuant to the agreement and deny the
          remaining allegations of said paragraph.
                  21.     Defendants neither admit nor admit the allegations in paragraph “21” and leave
          Plaintiff to its proofs.
                  22.     Defendants neither admit nor admit the allegations in paragraph “22” and leave
          Plaintiff to its proofs.
                  23.     Defendants neither admit nor admit the allegations in paragraph “23” and leave
          Plaintiff to its proofs.
                  24      Defendants neither admit nor admit the allegations in paragraph “24” and leave
          Plaintiff to its proofs.
                  25.     Defendants neither admit nor admit the allegations in paragraph “25” and leave
          Plaintiff to its proofs.
                  26.     Defendants neither admit nor admit the allegations in paragraph “26” and leave
          Plaintiff to its proofs.




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FILED: NASSAU COUNTY CLERK 08/16/2023 06:29 AM                                                   INDEX NO. 612295/2023
NYSCEF DOC. NO. 9                                                                        RECEIVED NYSCEF: 08/16/2023




                  27.     Defendants neither admit nor admit the allegations in paragraph “27” and leave
          Plaintiff to its proofs.
                                            AFFIRMATIVE DEFENSES
                  28.     The Complaint fails to state any cause of action upon which relief can be based.
                  29.     Any Agreement attached to and/or referred to in the Complaint is subject to
          rescission because it was entered into by Defendants under economic duress and was not the joint
          product of the parties.
                  30.     Any Agreement attached to and/or referred to in the Complaint is a loan regardless
          of how it is characterized, and the financial terms contained therein are unconscionable and
          therefore unenforceable.
                  31.     Any Agreement attached to and/or referred to in the Complaint is in violation of
          Article 8 of the New York Financial Services Law and, as a consequence, Defendants are entitled
          to restitution of any money paid to Plaintiff.
                  32.     Any Agreement attached to and/or referred to in the Complaint is in violation of
          Article 8 of the New York Financial Services Law and is therefore void ab initio.
                  33.     The financial terms contained in any Agreement attached to and/or referenced in
          the Complaint are criminally usurious and therefore unenforceable.
                  34.     Defendants dispute the validity of the amounts claimed by Plaintiff in its various
          causes of action.
                  35.     Plaintiff is barred from seeking any damages from Defendants as a result of its
          breach of the covenant of good faith and fair dealing.
                  36.     Plaintiff failed to properly obtain personal jurisdiction over Defendants.
                  37.     The alleged debt has been securitized and therefore Plaintiff lacks standing to bring
          this action.


                  WHEREFORE, Defendants demand that the Verified Petition be dismissed with
          prejudice and the costs of this action be assessed against Plaintiff and such further and other relief
          as this Court deems just and equitable.




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FILED: NASSAU COUNTY CLERK 08/16/2023 06:29 AM                                                 INDEX NO. 612295/2023
NYSCEF DOC. NO. 9                                                                       RECEIVED NYSCEF: 08/16/2023




                                                     VERIFICATION
                    Yana Chechelnitsky, being duly sworn, deposes and says:
                    1.     I am the attorney for Defendants in the within action.
                    2.     Defendants are located in a State other than that in which the undersigned has her
          office.
                    3.     I have read the Verified Answer to the Verified Petition and know the contents to
          be true to my knowledge except as to those matters stated on information and belief, and as to
          those matters I believe them to be true.




          Dated: August 16, 2023
          NEW YORK, NY



                                                                  /s/Yana Chechelnitsky
                                                                  Yana Chechelnitsky, Esq.
                                                                  Attorney for Defendants
                                                                  305 Broadway, Suite 727
                                                                  New York, NY 10007
                                                                  (212) 323-7457
                                                                  nynj@yanalawoffice.com



          TO:       Adam J. Feldman, Esq.
                    Attorney for Plaintiff
                    3000 Marcus Avenue, Suite 2W15
                    Lake Success, NY 11042
                    212-244-4422
                    ajf@feldmanlegal.com




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