Motion for Summary Judgment in Nancy Lauricella v. D'Arcangelo & Co., Llp, Michael C Betros Cpa Pfs, Arlington Professional Suites, Llc| Trellis.Law

On December 20, 2021 a Exhibit,Appendix was filed involving a dispute between Nancy Lauricella, and Arlington Professional Suites, Llc, D'Arcangelo & Co., Llp, Michael C Betros Cpa Pfs, for Torts - Other (NEGLIGENCE) in the District Court of Dutchess County.

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FILED: DUTCHESS COUNTY CLERK 02/20/2024
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STATE OF NEW YORK
SUPREME COURT COUNTY OF DUTCHESS
______________________________________________________________________________

NANCY LAURICELLA,
NOTICE OF MOTION

Plaintiff, Index No.: 2021-55036
-against-

D’ARCANGELO & CO., LLP,
and MICHAEL C. BETROS, CPA, PFS,
and ARLINGTON PROFESSIONAL SUITES, LLC,

Defendants.

______________________________________________________________________________

PLEASE TAKE NOTICE, that upon the annexed affirmation of Bridget M. Schultz, Esq.,

affirmed the 18th day of October, 2023, together with the exhibits thereto, and upon the affidavit

of Michael Betros, sworn to the 17th day of October, 2023, together with the exhibits annexed

thereto, and upon all prior pleading and proceedings in this action, the undersigned, attorneys for

Defendants, will move at a term of the Supreme Court, to be held in and for the County of

Dutchess, State of New York, at a motion term to be held on the 24th day of November, 2023 at

9:30 a.m., or as soon thereafter as counsel can be heard, for an Order pursuant to CPLR 3212,

granting Defendants, D’Arcangelo & Co., LLP and Michael C. Betros, CPA, PFS, summary

judgment, together with such other and further relief as this Court deems appropriate.

PLEASE TAKE FURTHER NOTICE, that answering affidavits, if any, must be served

no later than seven (7) days prior to the return date of this motion pursuant to CPLR § 2214(b).

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Dated: October 18, 2023

MAYNARD, O’CONNOR, SMITH
& CATALINOTTO, LLP

Bridget M. Schultz
____________________________________
/s/
Bridget M. Schultz
Attorneys for Defendants
6 Tower Place
Albany, New York 12203
(518) 465-3553

TO: Pamela J. Gabiger, Esq.
P.O. Box 2952
Poughkeepsie, NY 12603

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STATE OF NEW YORK
SUPREME COURT COUNTY OF DUTCHESS
______________________________________________________________________________

NANCY LAURICELLA,
ATTORNEY AFFIRMATION

Plaintiff, Index No.: 2021-55036
-against-

D’ARCANGELO & CO., LLP,
and MICHAEL C. BETROS, CPA, PFS,
and ARLINGTON PROFESSIONAL SUITES, LLC,

Defendants.

______________________________________________________________________________

BRIDGET M. SCHULTZ, an attorney duly admitted to practice law before the Courts

of the State of New York, affirms the following upon information and belief under penalty of

perjury:

1. I am an attorney at law duly admitted to practice in the Courts of the State of New

York, and am a partner with the law firm of Maynard, O’Connor, Smith & Catalinotto, LLP,

attorneys for the defendants, Arlington Professional Suites, LLC (hereinafter “Arlington”),

D’Arcangelo & Co., LLP (hereinafter “D’Arcangelo”) and Michael C. Betros, CPA, PFS [sic]1

(hereinafter “Michael Betros”) in the above-referenced matter. As such, I am fully familiar with

the pleadings and proceedings heretofore and herein.

2. I submit this Affirmation in support of the motion for summary judgment

submitted on behalf of D’Arcangelo and Michael Betros (hereinafter collectively “Moving

Defendants”) pursuant to CPLR 32122.

1
The title is technically CPA/PFS.
2
On or about August 23, 2023, the Parties appeared in Court for a status conference where the Moving Defendants
were granted leave to move for summary judgment before the conclusion of discovery, without prejudice to any
dispositive motion Arlington may submit after the Note of Issue is filed.

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3. As discussed in more detail infra, summary judgment is warranted in favor of the

Moving Defendants because they had no contractual duty to maintain and/or repair the parking

lot where the subject accident occurred.

4. Furthermore, the Moving Defendants have no statutory or common law duty to

maintain and/or repair the parking lot because they never held an ownership interest in the real

property where the subject incident occurred.

5. Summary judgment is also warranted in favor of Michael Betros because

Plaintiff’s Complaint is devoid of any allegations and/or requests to “pierce” the corporate veil to

hold Mr. Betros liable for the acts of Arlington or D’Arcangelo in his individual capacity.

However, even if this had been alleged, no grounds exist to hold Mr. Betros personally liable for

the acts of each corporation3.

6. Finally, summary judgment is warranted because the Moving Defendants did not

‘create’ the alleged dangerous condition made subject of the Complaint, nor did they have actual

or constructive notice of it.

7. Moving Defendants submit the following exhibits in support of their motion:

Exhibit “A”: Summons and Complaint dated December 20, 2021

Exhibit “B”: Answers filed by Defendants

Exhibit “C”: Plaintiff’s Deposition Transcript dated March 27, 20234

Exhibit “D”: Plaintiff’s Bill of Particulars

Exhibit “E”: Affidavit of Michael Betros dated October 17, 2023, with
Exhibits

Exhibit “F”: Photographs of Ice

3
Plaintiff has not specifically alleged a cause of action to pierce the corporate veil, but Mr. Betros is named in his
individual capacity.
4
Your undersigned does not have a copy of Defendant’s deposition transcript, as the transcript was never served
upon your undersigned in violation of CPLR 3116(b) despite multiple attempts to obtain from Plaintiff’s counsel.

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STATEMENT OF FACTS

8. At all times material hereto, Arlington was the owner of real property commonly

known as 510 W Haight Ave, Poughkeepsie, NY 12603 (hereinafter the “Property”) (Exhibit E).

9. On January 7, 2019, Nancy Lauricella (hereinafter “Plaintiff”) alleges that she

tripped and fell on a patch of ice located in the parking lot of the Property (Exhibit A; Exhibit C,

pg. 89; Exhibit F).

10. Plaintiff’s intent was to visit non-party Rehabilitation Support Services Inc.

(hereinafter “RSS”), which was a commercial tenant at the Property (Exhibit C, p. 10).

11. At the time of her fall, Defendant D’Arcangelo was also a commercial tenant of the

Property (Exhibit E).

12. D’Arcangelo and RSS were both commercial tenants at the Property at the time of

Plaintiff’s fall (Exhibit E). There were also 5-6 other commercial tenants at the Property as well

(Exhibit E).

13. Section 38 of D’Arcangelo’s lease agreement specifically requires the

landlord/property owner to “maintain the exterior of the office building which houses the

demised premises, make structural repairs, and be responsible for the removal of ice and snow

from the sidewalks and parking lot” (Exhibit E, ex. c).

14. Michael Betros, who is a certified public accountant, was both a member of

Arlington (i.e., the building owner/landlord) and a partner with D’Arcangelo (a tenant/an

accounting firm) at the time of Plaintiff’s fall (Exhibit E).

15. Michael Betros has never had an ownership interest in the Property in his individual

capacity, and has never leased space at the Property in his individual capacity (Exhibit E).

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16. Michael Betros has never had any contractual duty to maintain the Property

(including the parking lot) in his individual capacity (Exhibit E).

17. Plaintiff reported her alleged fall to an employee at RSS, who allegedly suggested

that Plaintiff report her fall to Michael Betros (i.e. an authorized representative of the Landlord)

(Exhibit C, pg. 87; Exhibit E).

18. Michael Betros was working in the D’Arcangelo suite at the time of Plaintiff’s

alleged fall (Exhibit E).

19. It is assumed that plaintiff wrongly believes D’Arcangelo and/or Michael Betros had

a duty to maintain the parking lot and/or clear ice and snow from the parking lot simply because

RSS told her to report her fall to Mr. Betros (who has authority to act on behalf of Arlington, the

Property owner).

20. Outside of this assumption, however, the case record is devoid of any evidence

whatsoever that would impose a duty of care upon the Moving Defendants. To the extent a duty

was owed to Plaintiff, the duty was owed by Arlington, not the Moving Defendants 5. Thus,

Moving Defendants should be dismissed from the case.

LEGAL ARGUMENT

POINT I
MOVING DEFENDANTS OWE NO DUTY TO PLAINTIFF

21. As a general rule, a landowner (i.e., Arlington) has a duty to keep his/her property in

a reasonably safe condition (Basso v Miller, 40 NY2d 233 [1976]).

22. An exception to this general rule, which is not applicable here, exists if a landowner

is deemed to be an “out of possession landlord” (see e.g., Mehl v Fleisher, 234 AD2d 274 [2d

5
Arlington adamantly denies that it was negligent in this case, however.

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Dept 1996]). A landlord cannot be considered “out of possession” if the landlord does not

surrender “possession and control” to a tenant (Mehl, 234 AD2d 274 [2d Dept 1996]).

23. Though Arlington adamantly denies that it was negligent, for purposes of this

motion, D’Arcangelo should be dismissed from this case because it had no common law duty to

maintain the Property (as D’Arcangelo was a tenant), and had no contractual obligation to

maintain the Property (per its lease agreement with Arlington) (Exhibit E, ex. c).

24. Similarly, summary judgment should be granted in favor of Michael Betros because

he does not have any ownership or possessory interest to the Property in his individual capacity

(Exhibit E). Thus, Mr. Betros had no common law or contractual obligation to maintain the

Property, either.

25. This case is similar to Hernandez v. Dunkin Brands Acquisition, Inc., wherein the

Appellate Division, Second Department, affirmed a dismissal against a tenant where their lease

provided that the tenant had no obligation for the exterior maintenance of the property, and that

the landlord was responsible the exterior premises (Hernandez v Dunkin Brands Acquisition,

Inc., 136 AD3d 980 [2d Dept 2016]). The Court held that “a written agreement that is complete,

clear, and unambiguous on its face must be enforced according to the plain meaning of its

terms.” Id.

26. Here, the lease agreement between Arlington and D’Arcangelo requires Arlington to

maintain the exterior property, and to remove ice and snow (Exhibit E, ex. c)6.

27. Accordingly, summary judgment is warranted in favor of Moving Defendants

because 1) D’Arcangelo has no contractual obligation or common law duty to maintain the

parking lot where Plaintiff alleges she fell, and 2) because Michael Betros has no personal

ownership or possessory interest in the Property.
6
Again, Arlington denies any negligence in this case.

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POINT II
MICHAEL BETROS SHOULD BE DISMISSED IN HIS INDIVIDUAL CAPACITY

28. Michael Betros should be also dismissed from this case because Plaintiff’s

Complaint fails to allege that the corporate veil should be “pierced” to hold him liable for the

acts of Arlington and/or D’Arcangelo (Exhibit E, Exhibit A).

29. Plaintiff’s Complaint alleges that Michael Betros is liable for Plaintiff’s alleged

injuries because he owned, controlled, and maintained the Property in his individual capacity

(Exhibit A, ¶ 4-6). As stated in Point I supra, these allegations are rebutted by the public record,

and by the discovery exchanged in this case (Exhibit E).

30. Plaintiff’s Complaint does not allege that Mr. Betros should be liable for the acts of

either Arlington or D’Arcangelo in his individual capacity (Exhibit A). However, even if it had,

there are simply no grounds to “pierce the corporate veil.”

31. As a general rule, “a member of a limited liability company cannot personally be

held liable for any debts, obligations or liabilities of the limited liability company, whether

arising in tort, contract or otherwise” (DePetris v Traina, 211 AD3d 939 [2d Dept 2022],

quoting Limited Liability Company Law § 609[a]).

32. Members of limited liability companies generally cannot be held personally liable

for the obligations of the limited corporation unless the concept of piercing the corporate veil

applies Id.

33. To pierce the corporate veil, the plaintiff must show that the owners exercised

complete domination of the corporation, and that such domination was used to commit fraud or

wrong against the party seeking to pierce the corporate veil (Matter of Morris v New York State

Dept. of Taxation and Fin., 82 NY2d 135 [1993]).

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34. The Plaintiff has yet to allege any facts that, if proven, would pierce Arlington’s

corporate veil to hold Michael Betros personally liable for the obligations of either defendant.

35. Accordingly, summary judgment is warranted in favor of Michael Betros in his

individual capacity, as the Plaintiff has failed to allege any facts or circumstances that would

support piercing the corporate veil.

POINT III
MOVING DEFENDANTS DID NOT CREATE, CONTRIBUTE, OR KNOW OF
ANY ICY CONDITIONS ON THE PROPERTY

36. Even if this Court were to find a question of fact as to whether Moving Defendants

owed Plaintiff a duty, which they submit is not the case, summary judgment is still warranted in

favor of Moving Defendants because Moving Defendants did not create the alleged ice patch,

nor did they have actual or constructive knowledge of the ice patch.

37. A party in possession or control will be held liable for injuries sustained in a slip-

and-fall accidents involving snow and ice “only when it created the alleged dangerous condition

or had actual or constructive notice of it” (see e.g., Casson v McConnell, 148 AD3d 863 [2d

Dept 2017]).

38. “A defendant has constructive notice of a hazardous condition on property when the

condition is visible and apparent, and has existed for a sufficient length of time to afford the

defendant a reasonable opportunity to discover and remedy it” (Zimmer v County of Suffolk, 190

AD3d 898 [2d Dept 2021]).

39. Black ice is a transient condition that is “difficult to see or recognize as ice”

(Golonka v Saratoga Teen and Recreation of Saratoga Springs Inc., 249 AD2d 854 [3d Dept

1998]).

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40. “If the slippery condition is not readily visible and apparent, then, by definition,

actual or constructive notice of it to the property owner is unlikely and perhaps impossible,

depending on the circumstances of the case” (Steffens v Sachem Cent. School Dist., 190 AD3d

1003 [2d Dept 2021]).

41. Here, Plaintiff claims that the patch of ice was “black ice” (Exhibit C, pg. 65).

42. The Moving Defendants were never aware of the ice patch prior to the Plaintiff’s fall

(Exhibit E).

43. The Moving Defendants are not aware of any prior complaints or injuries from icy

and snow conditions in the parking lot prior to this accident (Exhibit E).

44. The Moving Defendants did not create the ice patch (Exhibit E).

45. Accordingly, summary judgment is further warranted on behalf of the Defendants, as

the Plaintiff has failed to establish any facts that show the Defendants contributed, created, or

were aware of icy conditions on the day of the slip and fall.

WHEREFORE, Moving Defendants request an Order granting summary judgment

in their favor pursuant to CPLR 3212 dismissing Plaintiff’s Complaint against them in its

entirety, and for such other and further relief as to this Court may deem just and proper.

Dated: October 18, 2023

Bridget M. Schultz
____________________________________
/s/
Bridget M. Schultz

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WORD COUNT CERTIFICATION

I hereby certify that the Attorney Affirmation contains 2,055 words based on the word
count of Microsoft Word, the word-processing system used to prepare the document, and is in
conformity with Rule 202.8-b of the Uniform Rules for the Supreme and the County Court.

Dated: October 18, 2023
Bridget M. Schultz
/s/
_____________________________________
Bridget M. Schultz

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Exhibit A
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STATE OF NEW YORK Index No.:
SUPREME COURT COUNTY OF DUTCHESS Date Summons Filed:
------------------------------------------------------------------- Plaintiff designates Dutchess
NANCY LAURICELLA,
County as the place of trial

Plaintiff, The basis of venue is:
DEFENDANTS ARE SITUATED
IN THE COUNTY OF DUTCHESS
AND THE CAUSE OF ACTION
-against- ACCRUED IN THE COUNTY OF
DUTCHESS AND PLAINTIFF
RESIDES AT 53 NASSAU ROAD
POUGHKEEPSIE, NY 12601
D’ARCANGELO & CO., LLP,
AND MICHAEL C. BETROS, CPA, PFS, AND
ARLINGTON PROFESSIONAL SUITES, LLC, SUMMONS

Defendant.
------------------------------------------------------------------

To the above named Defendants:

YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer on the Plaintiff’s Attorney within twenty (20) days after the service of this
summons, exclusive of the day of service, where service is made by delivery upon you
personally within the state, or within thirty (30) days after completion of service where service is
made in any other manner. In case of your failure to appear or answer, judgment will be taken
against you by default for the relief demanded in the complaint.

Dated: December 20, 2021

PAMELA J. GABIGER
Attorney for Plaintiff
PO BOX 2952
Poughkeepsie, New York 12603
(845) 471-2447
D’ARCANGELO & CO., LLP
510 HAIGHT AVE. SUITE 201
POUGHEEPSIE, NY 12601

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STATE OF NEW YORK SUPREME COURT

COUNTY OF DUTCHESS

-----------------------------------------------------------------

NANCY LAURICELLA,

PLAINTIFF, COMPLAINT

-AGAINST-

D’ARCANGELO & CO., LLP,

AND MICHAEL C. BETROS, CPA, PFS, AND

ARLINGTON PROFESSIONAL SUITES, LLC,

DEFENDANTS.

------------------------------------------------------------------

PLAINTIFF, THROUGH ATTORNEY PAMELA GABIGER,

COMPLAINING OF DEFENDANTS, STATES:

1. PLAINTIFF NANCY LAURICELLA IS A RESIDENT OF POUGHKEEPSIE,

COUNTY OF DUTCHESS, STATE OF NEW YORK.

2. ON AND BEFORE JANUARY 7, 2019 DEFENDANTS D’ARCANGELO &

CO., LLP AND MICHAEL BETROS, CPA, PFS WERE A REGISTERED

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DOMESTIC LIMITED LIABILITY PARTNERSHIP AND MAINTAINED AN

OFFICE AT 510 HAIGHT AVENUE, POUGHKEEPSIE, NY.

3. ON AND BEFORE JANUARY 7, 2019 DEFENDANT ARLINGTON

PROFESSIONAL SUITES, LLC WAS A LIMITED LIABILITY COMPANY

DULY ORGANIZED AND EXISTING UNDER AND BY VIRTUE OF THE

LAWS OF THE STATE OF NEW YORK.

4. ON AND BEFORE JANUARY 7, 2019 DEFENDANTS OWNED THE

PROPERTY AT 510 WEST HAIGHT AVENUE POUGHKEEPSIE,

COUNTY OF DUTCHESS, STATE OF NEW YORK.

5. ON AND BEFORE JANUARY 7, 2019 DEFENDANTS CONTROLLED

THE PROPERTY AT 510 WEST HAIGHT AVENUE IN POUGHKEEPSIE,

COUNTY OF DUTCHESS, STATE OF NEW YORK.

6. ON AND BEFORE JANUARY 7, 2019 DEFENDANTS MAINTAINED

THE PROPERTY AT 510 WEST HAIGHT AVENUE IN POUGHKEEPSIE,

COUNTY OF DUTCHESS, STATE OF NEW YORK.

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7. ON AND BEFORE JANUARY 7, 2019 DEFENDANTS INSPECTED THE

PROPERTY AT 510 WEST HAIGHT AVENUE IN POUGHKEEPSIE,

COUNTY OF DUTCHESS, STATE OF NEW YORK.

8. ON AND BEFORE JANUARY 7, 2019 DEFENDANTS REPAIRED THE

PROPERTY AT 510 W. HAIGHT AVENUE IN POUGHKEEPSIE,

COUNTY OF DUTCHESS, STATE OF NEW YORK.

9. ON AND BEFORE JANUARY 7, 2019 PLAINTIFF WAS LAWFULLY ON

THE PROPERTY AT 510 WEST HAIGHT AVENUE IN POUGHKEEPSIE,

COUNTY OF DUTCHESS, STATE OF NEW YORK.

10. ON JANUARY 7, 2019 PLAINTIFF WAS CAUSED TO BE

PRECIPITATED TO THE GROUND AT 510 WEST HAIGHT AVENUE,

POUGHKEEPSIE, COUNTY OF DUTCHESS, STATE OF NEW YORK.

11. SAID INCIDENT AND RESULTING INJURIES AND DAMAGES

WERE CAUSED SOLELY AS A RESULT OF THE NEGLIGENCE OF THE

DEFENDANTS, THEIR OFFICERS, DIRECTORS, AGENTS, SERVANTS

AND EMPLOYEES IN CREATING, CAUSING, ALLOWING AND

PERMITTING SNOW AND ICE TO FORM AND REMAIN ON THE

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PAVEMENT, IN ATTEMPTING TO CLEAR OR SAND OR SALT THE

AREA AND DOING SO IN A NEGLIGENT, DANGEROUS,

HAZARDOUS, INCOMPLETE AND HAPHAZARD MANNER, IN

FAILING TO PROPERLY AND ADEQUATELY SALT AND SAND THE

PREMISES, IN FAILING TO TAKE ADEQUATE PRECAUTIONS AND

MEASURES TO PREVENT THE HAZARDOUS SNOWY AND ICY

CONDITIONS, IN FAILING TO PERFORM ALL THE ACTS NECESSARY

TO PREVENT SNOW AND ICE FROM DEVELOPING AND REMAINING

ON THE PREMISES, IN ALLOWING SNOW AND ICE TO DEVELOP

AND REMAIN ON THE PREMISES, IN FAILING TO PROPERLY SALT

AND SAND THE AREAS, IN FAILING TO ERECT BARRICADES AND

WARNINGS, AND IN BEING OTHERWISE NEGLIGENT.

12. AS A RESULT OF THE NEGLIGENCE OF THE DEFENDANTS,

THEIR OFFICERS, DIRECTORS, AGENTS, SERVANTS AND

EMPLOYEES, PLAINTIFF SUFFERED PERSONAL INJURIES,

EMOTIONAL DISTRESS, LOST EARNINGS AND INCURRED EXPENSES

FOR MEDICAL TREATMENT.

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13. THE INJURIES SUSTAINED BY PLAINTIFF WERE CAUSED

SOLELY AS A RESULT OF THE NEGLIGENCE OF THE DEFENDANTS,

THEIR OFFICERS, DIRECTORS, AGENTS, SERVANTS AND

EMPLOYEES WITHOUT ANY NEGLIGENCE OF THE PLAINTIFF

CONTRIBUTING THERETO.

14. BY REASON OF THE NEGLIGENCE OF DEFENDANTS, THEIR

OFFICERS, DIRECTORS, AGENTS, SERVANTS AND EMPLOYEES,

PLAINTIFF HAS BEEN DAMAGED IN THE SUM OF TWENTY MILLION

AND NO/100 ($20,000,000.00) DOLLARS.

15. WHEREFORE, PLAINTIFF DEMANDS JUDGMENT AGAINST

DEFENDANTS FOR GENERAL RELIEF IN ACCORDANCE WITH CPLR

3017 C TOGETHER WITH INTEREST, COSTS AND DISBURSEMENTS

OF THIS ACTION AND FOR SUCH OTHER AND FURTHER RELIEF AS

TO THIS COURT MAY SEEM JUST AND PROPER.

DATED:DECEMBER 20, 2021_/S/PAMELA GABIGER___________
PAMELA GABIGER
ATTORNEY FOR PLAINTIFF
PO BOX 2952 POUGHKEEPSIE, NY 12603
(845) 471-2447 OR 867-8815

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ATTORNEY CERTIFICATION

Pursuant to NYCRR Section 130-1.1-a (b), I certify that

to the best of my knowledge, information and belief, formed

after an inquiry reasonable under the circumstances, the

presentation of the paper or the contentions therein are not

frivolous as defined in subsection (c) of section 130-1.1.

Dated: December 20, 2021

/s/PAMELA J. GABIGER
__________________________
PAMELA J. GABIGER

7 of 8
FILED: DUTCHESS COUNTY CLERK 02/20/2024 05:18 PM INDEX NO. 2021-55036
NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 02/20/2024

Exhibit B
FILED: DUTCHESS
FILED:
[FILED: DUTCHESS COUNTY
COUNTY CLERK
CLERK 02/03/2022
02/20/2024 03:29
02/03/2022 05:18 PM
03:29 PM
PM| INDEX
INDEX NO.
INDEX NO. 2021-55036
NO. 2021-55036
2021-55036

NYSCEF
NYSCEF DOC.
NYSCEF DOC. NO.
DOC. NO. 2
NO. 58
2 RECEIVED NYSCEF:
RECEIVED NYSCEF: 02/03/2022
NYSCEF: 02/20/2024
02/03/2022

SUPREME
SUPREME COURT
COURT OF
OF THE
THE STATE NEW YORK
OF NEW
STATE OF YORK
COUNTY
COUNTY OF DUTCHESS
OF DUTCHESS
...... _.._________________..__ X
X Index
Index ##2021-55036
2021-55036

NANCY
NANCY LAUR1CELLA,
LAURICELLA,

Plaintiff,
Plaintiff,
Against
Against Verified
Verified Answer
Answer

D'ARCANGELO & CO.,
D’ ARCANGELO & CO., LLP,
LLP,
and MICHAEL
and MICHAEL C.C. BETROS,
BETROS, CPA,
CPA, PFS,
PFS,
and ARLINGTON
and ARLINGTON PROFESSIONAL
PROFESSIONAL SUITES,
SUITES, LLC
LLC

Defendants
Defendants
------------------------ X
X

Defendants, MICHAEL
Defendants, C. BETROS,
MICHAEL C. BETROS, CPA,
CPA, PFS and, ARLINGTON
PFS and, ARLINGTON PROFESSIONAL
PROFESSIONAL
SUITES,
SUITES, LLC by
LLC by their attorneys, LaRose
their attomeys, & LaRose,
LaRose & LaRose, as and
as and for
for their
their Answer
Answer to
to the
the Plaintiff
Plaintiff’ss
Complaint,
Complaint, respectfully
respectfully state
state and
and allege
allege as follows:
as follows:

"3" plaintiffs'
1.
1. Admits
Admits the allegations
the allegations in
in paragraphs
paragraphs numbered
numbered and
and designated,
desigñated, “3” of
of the
the plaintiffs’

complaint.
complaint.

2.
2. Denies
Denies knowledge
knowledge or
or information
information sufficient
sufficient to
to form
form aa belief
belief as
as to
to each
each and
and every
every

"9" "10" plaintiffs'
allegatión
allegation contained
contained in
in paragraphs
paragraphs numbered
numbered and
and designated

Case Info

Judge

Thomas R. Davis Track Judge’s New Case

Case No.

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Document Filed Date

February 20, 2024

Case Filing Date

December 20, 2021

County

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Exhibit,Appendix: Nancy Lauricella v. D'Arcangelo & Co., Llp, Michael C Betros Cpa Pfs, Arlington Professional Suites, Llc

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