Motion-Secondary: William Bianchi v. 300 Longbranch Realty, Inc.

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             ONO                    OU                04                                                                     020

NYSCEF   pOC. NO.   25                                                                       RECEIVED     NYSCEF:    04/20/2016




           STATE OF NEW YORK SUPREME COURT
           COUNTY OF ONONDAGA


           Application of William Bianchi
                                                                                    REPLY
                                                            Petitioner,             Index No.: 2015EF5020
                                                                                    RJI No.: 33-15-4290
                              VS.                                                  Judge: Murphy

           For the Judicial Dissolution of 300 Longbranch Realty, Inc.,

                                                            Respondent,



                        Petitioner, William Bianchi, by and through his attorneys, Sugarman Law Firm, LLP, for his

           Reply to Respondent’s First Counterclaim herein states:

                    1         Petitioner admits the allegations contained in paragraph “41” of the Verified Answer.

                    2         Petitioner admits that the Shareholder’s Agreement prohibits the transfer of share of

           stock, except under specific circumstances.      Petitioner denies the remaining allegations contained in

           paragraph “42” of the Verified Answer

                    3         Petitioner admits that the Shareholder’s Agreement provides for a valuation

           procedure for shares of stock.     Petitioner denies the remaining allegations of paragraph “43" of the

           Verified Answer.

                    4         Petitioner admits the allegations contained in paragraph “43” of the Verified Answer.

                    5         Petitioner denies the allegations contained on paragraph “44" of the Verified Answer.




                              Sugarman Law Firm, LLP + 211 West Jefferson
                                                                      Street * Syracuse,
                                                                                      NY 13202-2680

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WHEREFORE, Petitioner prays for an order of this Court dissolving the Corporation, and

for such other and further relief as may be appropriate.


Dated:   April 20, 2016



                                           ‘aul V. Mullin
                                         SUGARMAN LAW FIRM, LLP
                                         Attorneys for William Bianchi
                                         Office and Post Office Address
                                         211 West Jefferson Street
                                         Syracuse, New York 13202
                                         Telephone: (315) 474-2943


TO
         Robert B. Liddell, Esq.
         Hiscock & BARCLAY, LLP
         Attorneys for
         Office and Post Office Address
         One Park Place
         300 South State Street
         Syracuse, New York 13202
         Telephone:   (315) 425-2877




                Sugarman Law Firm, LLP    211 West Jefferson Street   Syracuse, NY   13202-2680


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