Preview
FILED: KINGS COUNTY CLERK 03/09/2017 07:45 PM INDEX NO. 509700/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/09/2017
UPREME C()URT OF THE STATE OF NEWYORK
OUNTY OF KINGS
Index No.:5o97oolr5
Plaintiff,
AMENDEDANSWER
-against -
WITH COUNTERCLAIMS
UGIINE TUI,MAN, BORIS TULMAN,
TIKFIAIL TULMAN, COOLTECH MECHANICAL
)RP., COOLTECII MECHANICAL GROUP, INC.,
ILMAR LLC, MII,MAR FOOD GROUP, LLC.
LMAR FOOD GROUP II, LLC and
R HOLDING COMPANY, LLC.
Defendants.
Defendants EUGENE TULMAN and MIKAIL TULMAN,
by their
rneys, The Law offices of Hayes young, p.A., upon
information and belief.
reby interpose this Amended Answer to the plaintiffs
Amended Complaint as
lows:
1' These Answening Defendants/Counterclaim Plaintiff
repeat, reiterate and
incorporate by reference the entire Answer with Counterclaims
dated
october 29,2o:.s and duly filed on october 26, 2ot5,as such
the said
Answer with counterclaims shall remain in full force
and effect and the
below shall correspond to the novel allegations set forth
in the indicated
paragraphs from the plaintiffs Amended Complaint.
2' R'epeats and reiterates the denials set forth as
to those allegations repeated
1 of 4
FILED: KINGS COUNTY CLERK 03/09/2017 07:45 PM INDEX NO. 509700/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/09/2017
and realleged in paragraphs designated .,39,,
and.,,46,,.
3' Deny possessing knowledge or information sufficient to form a belief
as to
the truth of the allegations contained in paragraph
designated ,,4o,, ,,,4r,, ,
"42"r"4s"r"44"r"4s"r"47,,rrr4}rrr,,4orrrrrsorrrrrsrrrrors2,,rand.,,53,,.
WHEREFORE, Defendants EUGENE TULMAN
and MIKFIAIL TULMAN
and judgment dismissing the complaint
in its entirety and counterclaim
ntiff EUGENE TULMAN further demands judgment
on the First counterclaim:
Awardi'g actual damages n the sum of oNE
MILLION (gr,ooo,ooo.oo)
DOLI/,RS with appropriate interest;
Declaring counterclaim plaintiffs eleven
ur%)percent membership
interest:in Crepini to be valid and effective;
Awarding attorneys fees incurred by counterclaim plaintiff;
and
Awarding costs and disbursements incurred
by counterclaim plaintiff in
the pursuit of this Counterclaim:
further demands judgment on the second countercraim:
a' Awarding actual damages in the sum of oNE
MILLION (gr,ooo,ooo.oo)
DOLIARS with appropriate interest therein;
' Declaring counterclaim Plaintiffs eleven (tt%)percent
interest in crepini
LLC to be valid and effective;
Awarding attorneys fees incurred by counterclaim plaintiff;
and
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FILED: KINGS COUNTY CLERK 03/09/2017 07:45 PM INDEX NO. 509700/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/09/2017
l' Awardlng costs and disbursements incurred
by counterclaim .plaintiff in
the pursuit of this counterclaim, together
with such other and further
relief as this Honorable Court may deem just
and proper.
further demands judgment on the Third Counterclaim:
. Awarding actual damages in the sume of oNE MILLION (gr,ooo,ooo.oo)
DOLLARS with appropriate interest therein;
' Awarding punitive and exemplary damages in
the su'n of TWo MILLI'N
($z,ooct,ooo.oo) DOLLARS;
Awarding attorney fees incurred by counterclaim plaintiff;
and
Awarding costs and disbursements incurred
by counterclaim plaintiff in
the pursuit of this Counterclaim;
her with such other and further rerief as this
Honorabre court may d.eem
and proper..
ed: New York, New york
IVIarch B, zotT
MIKHAIL TU
233 Broadway, Suite 2305
NewYork, Newyork Lo27g
(ztz)766-ooo6
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FILED: KINGS COUNTY CLERK 03/09/2017 07:45 PM INDEX NO. 509700/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/09/2017
Patrick McPartland, Esq.
LaRocca Hornik Rosen
Greenburg & Blaha, LLC
4o Wall Street, 3znd Floor
New York, Ny rooo5
Andrew Muchmore, Esq.
Law Office of Andrew Muchmore
zr7 Havemeyer Street,4th Floor
Brookllm, Newyork tL2r7
4
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Preview
FILED: KINGS COUNTY CLERK 03/09/2017 07:45 PM INDEX NO. 509700/2015 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/09/2017 UPREME C()URT OF THE STATE OF NEWYORK OUNTY OF KINGS Index No.:5o97oolr5 Plaintiff, AMENDEDANSWER -against - WITH COUNTERCLAIMS UGIINE TUI,MAN, BORIS TULMAN, TIKFIAIL TULMAN, COOLTECH MECHANICAL )RP., COOLTECII MECHANICAL GROUP, INC., ILMAR LLC, MII,MAR FOOD GROUP, LLC. LMAR FOOD GROUP II, LLC and R HOLDING COMPANY, LLC. Defendants. Defendants EUGENE TULMAN and MIKAIL TULMAN, by their rneys, The Law offices of Hayes young, p.A., upon information and belief. reby interpose this Amended Answer to the plaintiffs Amended Complaint as lows: 1' These Answening Defendants/Counterclaim Plaintiff repeat, reiterate and incorporate by reference the entire Answer with Counterclaims dated october 29,2o:.s and duly filed on october 26, 2ot5,as such the said Answer with counterclaims shall remain in full force and effect and the below shall correspond to the novel allegations set forth in the indicated paragraphs from the plaintiffs Amended Complaint. 2' R'epeats and reiterates the denials set forth as to those allegations repeated 1 of 4 FILED: KINGS COUNTY CLERK 03/09/2017 07:45 PM INDEX NO. 509700/2015 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/09/2017 and realleged in paragraphs designated .,39,, and.,,46,,. 3' Deny possessing knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph designated ,,4o,, ,,,4r,, , "42"r"4s"r"44"r"4s"r"47,,rrr4}rrr,,4orrrrrsorrrrrsrrrrors2,,rand.,,53,,. WHEREFORE, Defendants EUGENE TULMAN and MIKFIAIL TULMAN and judgment dismissing the complaint in its entirety and counterclaim ntiff EUGENE TULMAN further demands judgment on the First counterclaim: Awardi'g actual damages n the sum of oNE MILLION (gr,ooo,ooo.oo) DOLI/,RS with appropriate interest; Declaring counterclaim plaintiffs eleven ur%)percent membership interest:in Crepini to be valid and effective; Awarding attorneys fees incurred by counterclaim plaintiff; and Awarding costs and disbursements incurred by counterclaim plaintiff in the pursuit of this Counterclaim: further demands judgment on the second countercraim: a' Awarding actual damages in the sum of oNE MILLION (gr,ooo,ooo.oo) DOLIARS with appropriate interest therein; ' Declaring counterclaim Plaintiffs eleven (tt%)percent interest in crepini LLC to be valid and effective; Awarding attorneys fees incurred by counterclaim plaintiff; and 2 of 4 FILED: KINGS COUNTY CLERK 03/09/2017 07:45 PM INDEX NO. 509700/2015 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/09/2017 l' Awardlng costs and disbursements incurred by counterclaim .plaintiff in the pursuit of this counterclaim, together with such other and further relief as this Honorable Court may deem just and proper. further demands judgment on the Third Counterclaim: . Awarding actual damages in the sume of oNE MILLION (gr,ooo,ooo.oo) DOLLARS with appropriate interest therein; ' Awarding punitive and exemplary damages in the su'n of TWo MILLI'N ($z,ooct,ooo.oo) DOLLARS; Awarding attorney fees incurred by counterclaim plaintiff; and Awarding costs and disbursements incurred by counterclaim plaintiff in the pursuit of this Counterclaim; her with such other and further rerief as this Honorabre court may d.eem and proper.. ed: New York, New york IVIarch B, zotT MIKHAIL TU 233 Broadway, Suite 2305 NewYork, Newyork Lo27g (ztz)766-ooo6 3 of 4 FILED: KINGS COUNTY CLERK 03/09/2017 07:45 PM INDEX NO. 509700/2015 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/09/2017 Patrick McPartland, Esq. LaRocca Hornik Rosen Greenburg & Blaha, LLC 4o Wall Street, 3znd Floor New York, Ny rooo5 Andrew Muchmore, Esq. Law Office of Andrew Muchmore zr7 Havemeyer Street,4th Floor Brookllm, Newyork tL2r7 4 4 of 4