On June 03, 2021 a
REPLY TO COUNTERCLAIM(S)
was filed
involving a dispute between
Rochester Employment Professionals, Inc. D B A Express Employment Professionals,
Rochester Employment Professionals, Inc.
D B A Express Employment Professionals,
and
Maven Technologies, Llc,
for Commercial - Contract
in the District Court of Monroe County.
Preview
INDEX NO. E2021004988
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 07/09/2021
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 2772459
Book Page CIVIL
Return To: No. Pages: 3
JOHN BRIAN FITZSIMMONS
Instrument: REPLY TO COUNTERCLAIM(S)
Control #: 202107090742
Index #: E2021004988
Date: 07/09/2021
Rochester Employment Professionals, Inc. Time: 2:14:54 PM
Maven Technologies, LLC
Total Fees Paid: $0.00
Employee:
State of New York
MONROE COUNTY CLERK’S OFFICE
WARNING — THIS SHEET CONSTITUTES THE CLERKS
ENDORSEMENT, REQUIRED BY SECTION 317-a(5) &
SECTION 319 OF THE REAL PROPERTY LAW OF THE
STATE OF NEW YORK. DO NOT DETACH OR REMOVE.
JAMIE ROMEO.
MONROE COUNTY CLERK
MO
1 of 3
FELD? HONROE COUNTY CLERK 0770972021 02:13 PM INDE&& NOE 2E210049881988
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 07/09/2021
SUPREME COURT
STATE OF NEW YORK COUNTY OF MONROE
ROCHESTER EMPLOYMENT PROFESSIONALS, INC.
d/b/a EXPRESS EMPLOYMENT PROFESSIONALS
3400 Monroe Avenue Suite 9
Rochester, NY 14618
Index No. E2021004988
Plaintiff,
-Vs- REPLY TO
COUNTERCLAIM
MAVEN TECHNOLOGIES, LLC
1450 Lyell Avenue Suite 5
Rochester, NY 14606
Defendant.
Plaintiff, by and through its attorneys Fitzsimmons, Nunn & Plukas, LLP, John B.
Fitzsimmons, Esq., as and for its Reply to Counterclaims filed by Defendant, hereby replies as
follows:
1 Plaintiff denies the allegations set forth at Paragraphs 24, 25, 28, and 29 of
Defendant’s Answer and Counterclaims.
2. Plaintiff denies knowledge or information sufficient to form a beliefas to the
allegations contained in Paragraphs 26, 27, 30, and 31 of Defendant’s Answer and
Counterclaims.
3. Plaintiff denies each and every other allegation not specifically admitted,
controverted, or denied herein.
2 of 3
FELD? HONROE COUNTY CLERK 0770972021 02:13 PM INDEEXNG E 2820140881988
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 07/09/2021
WHEREFORE, Plaintiff requests judgment dismissing the Counterclaims in their
entirety, and granting Plaintiff the relief requested in the Complaint, together with attorney’s
fees, costs and expenses, and such further and different relief as to this Court may seem just and
proper.
|
Dated: 9] Q Z \
B.: un
F i ns, Esq.
FITZS) NUNN & PLUKAS, LLP
Att forP: iff
Offi e and ‘ost Office Address
16 E| Main Street, Suite 300
Rochester, New York 14614
Telephone: (585) 546-5270
TO Jason S. DiPonzio, Esq.
Attorney for Defendant
950 Reynolds Arcade Building
16E.
1 Ei ast M Aain
fain Str
Street
Rochester, NY 14614
3 of 3
Document Filed Date
July 09, 2021
Case Filing Date
June 03, 2021
Category
Commercial - Contract
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INDEX NO. E2021004988 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 07/09/2021 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 2772459 Book Page CIVIL Return To: No. Pages: 3 JOHN BRIAN FITZSIMMONS Instrument: REPLY TO COUNTERCLAIM(S) Control #: 202107090742 Index #: E2021004988 Date: 07/09/2021 Rochester Employment Professionals, Inc. Time: 2:14:54 PM Maven Technologies, LLC Total Fees Paid: $0.00 Employee: State of New York MONROE COUNTY CLERK’S OFFICE WARNING — THIS SHEET CONSTITUTES THE CLERKS ENDORSEMENT, REQUIRED BY SECTION 317-a(5) & SECTION 319 OF THE REAL PROPERTY LAW OF THE STATE OF NEW YORK. DO NOT DETACH OR REMOVE. JAMIE ROMEO. MONROE COUNTY CLERK MO 1 of 3 FELD? HONROE COUNTY CLERK 0770972021 02:13 PM INDE&& NOE 2E210049881988 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 07/09/2021 SUPREME COURT STATE OF NEW YORK COUNTY OF MONROE ROCHESTER EMPLOYMENT PROFESSIONALS, INC. d/b/a EXPRESS EMPLOYMENT PROFESSIONALS 3400 Monroe Avenue Suite 9 Rochester, NY 14618 Index No. E2021004988 Plaintiff, -Vs- REPLY TO COUNTERCLAIM MAVEN TECHNOLOGIES, LLC 1450 Lyell Avenue Suite 5 Rochester, NY 14606 Defendant. Plaintiff, by and through its attorneys Fitzsimmons, Nunn & Plukas, LLP, John B. Fitzsimmons, Esq., as and for its Reply to Counterclaims filed by Defendant, hereby replies as follows: 1 Plaintiff denies the allegations set forth at Paragraphs 24, 25, 28, and 29 of Defendant’s Answer and Counterclaims. 2. Plaintiff denies knowledge or information sufficient to form a beliefas to the allegations contained in Paragraphs 26, 27, 30, and 31 of Defendant’s Answer and Counterclaims. 3. Plaintiff denies each and every other allegation not specifically admitted, controverted, or denied herein. 2 of 3 FELD? HONROE COUNTY CLERK 0770972021 02:13 PM INDEEXNG E 2820140881988 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 07/09/2021 WHEREFORE, Plaintiff requests judgment dismissing the Counterclaims in their entirety, and granting Plaintiff the relief requested in the Complaint, together with attorney’s fees, costs and expenses, and such further and different relief as to this Court may seem just and proper. | Dated: 9] Q Z \ B.: un F i ns, Esq. FITZS) NUNN & PLUKAS, LLP Att forP: iff Offi e and ‘ost Office Address 16 E| Main Street, Suite 300 Rochester, New York 14614 Telephone: (585) 546-5270 TO Jason S. DiPonzio, Esq. Attorney for Defendant 950 Reynolds Arcade Building 16E. 1 Ei ast M Aain fain Str Street Rochester, NY 14614 3 of 3