On September 01, 2016 a
Answer
was filed
involving a dispute between
Joseph Wegzyn,
Sharon Wegzyn,
and
Ford Motor Company,
for Other Matters - Contract Non-Commercial
in the District Court of Cortland County.
Preview
(FILED: CORTLAND COUNTY CLERK 09/22/2016 10:59 AM
NYSCEF DOC. NO. 8
DAVID J. GORBERG & ASSOCIATES, P.C.
By: DAVID J. GORBERG Attorney for Plaintiff
Identification No.: 53084
103 Sibley Avenue
Ardmore, PA 19003
(215) 665-7660
JOSEPH AND SHARON : NEW YORK STATE SUPREME COURT
WEGZYN :
: CORTLAND COUNTY
vs. | INDEX NO.: EF16-529
FORD MOTOR COMPANY : RESPONSE TO AFFIRMATIVE DEFENSES
PLAINTIFF'S ANSWERS TO DEFENDANT'S
AFFIRMATIVE DEFENSES:
FIRST AFFIRMATIVE DEFENSE
Denied. The allegations contained in defendant's First Affirmative Defense are conclusions of law to
which no specific response is required and strict proof thereof is hereby demanded at trial.
SECOND AFFIRMATIVE DEFENSE
Denied. The allegations contained in defendant's Second Affirmative Defense are conclusions of law to
which no specific response is required and strict proof thereof is hereby demanded at trial.
THIRD AFFIRMATIVE DEFENSE
Denied. The allegations contained in defendant's Third Affirmative Defense are conclusions of law to
which no specific response is required and strict proof thereof is hereby demanded at trial.
FOURTH AFFIRMATIVE DEFENSE
Denied. The allegations contained in defendant's Fourth Affirmative Defense are conclusions of law to
which no specific response is required and strict proof thereof is hereby demanded at trial.
EF16-529
09/22/2018 10:59:24 AM
Pages 3
ANSWER
Elizabeth Larkin, County Clerk
INDEX NO. EF16-529
RECEIVED NYSCEF: 09/22/2016FIFTH AFFIRMATIVE DEFENSE
Denied. The allegations contained in defendant's Fifth Affirmative Defense are conclusions of law to
which no specific response is required and strict proof thereof is hereby demanded at trial.
WHEREFORE, plaintiff demands judgment in her favor and against the defendant, Ford Motor Company.
/s/ David J. Gorberg
David J. Gorberg, ESQUIRE
Attorney for Plaintiff
DATED:September 22, 2016
2 of 3DAVID J. GORBERG & ASSOCIATES, P.C.
By: DAVID J. GORBERG Attorney for Plaintiff
Identification No.: 53084
103 Sibley Avenue
Ardmore, PA 19003
(215) 665-7660
JOSEPH AND SHARON : NEW YORK STATE SUPREME COURT
WEGZYN :
: CORTLAND COUNTY
vs. : INDEX NO.: EF16-529
FORD MOTOR COMPANY :CERTIFICATION OF SERVICE
The undersigned certifies that on September 22, 2016 the following documents were filed electronically via New
York State’s Court’s ECF system and that true copies were served upon counsel for the Defendant via ECF
1, Plaintiff's Answers to Defendant’s Affirmative Defenses on behalf of Plaintiff, Joseph & Sharon
Wegzyn.
DATED: September 22, 2016
/s/ David J. Gorberg
David J. Gorberg, Esquire
David J. Gorberg & Associates, P.C.
103 Sibley Avenue
Ardmore, PA 19003
(215) 665-7660
3 of 3
Document Filed Date
September 22, 2016
Case Filing Date
September 01, 2016
Category
Other Matters - Contract Non-Commercial
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(FILED: CORTLAND COUNTY CLERK 09/22/2016 10:59 AM NYSCEF DOC. NO. 8 DAVID J. GORBERG & ASSOCIATES, P.C. By: DAVID J. GORBERG Attorney for Plaintiff Identification No.: 53084 103 Sibley Avenue Ardmore, PA 19003 (215) 665-7660 JOSEPH AND SHARON : NEW YORK STATE SUPREME COURT WEGZYN : : CORTLAND COUNTY vs. | INDEX NO.: EF16-529 FORD MOTOR COMPANY : RESPONSE TO AFFIRMATIVE DEFENSES PLAINTIFF'S ANSWERS TO DEFENDANT'S AFFIRMATIVE DEFENSES: FIRST AFFIRMATIVE DEFENSE Denied. The allegations contained in defendant's First Affirmative Defense are conclusions of law to which no specific response is required and strict proof thereof is hereby demanded at trial. SECOND AFFIRMATIVE DEFENSE Denied. The allegations contained in defendant's Second Affirmative Defense are conclusions of law to which no specific response is required and strict proof thereof is hereby demanded at trial. THIRD AFFIRMATIVE DEFENSE Denied. The allegations contained in defendant's Third Affirmative Defense are conclusions of law to which no specific response is required and strict proof thereof is hereby demanded at trial. FOURTH AFFIRMATIVE DEFENSE Denied. The allegations contained in defendant's Fourth Affirmative Defense are conclusions of law to which no specific response is required and strict proof thereof is hereby demanded at trial. EF16-529 09/22/2018 10:59:24 AM Pages 3 ANSWER Elizabeth Larkin, County Clerk INDEX NO. EF16-529 RECEIVED NYSCEF: 09/22/2016FIFTH AFFIRMATIVE DEFENSE Denied. The allegations contained in defendant's Fifth Affirmative Defense are conclusions of law to which no specific response is required and strict proof thereof is hereby demanded at trial. WHEREFORE, plaintiff demands judgment in her favor and against the defendant, Ford Motor Company. /s/ David J. Gorberg David J. Gorberg, ESQUIRE Attorney for Plaintiff DATED:September 22, 2016 2 of 3DAVID J. GORBERG & ASSOCIATES, P.C. By: DAVID J. GORBERG Attorney for Plaintiff Identification No.: 53084 103 Sibley Avenue Ardmore, PA 19003 (215) 665-7660 JOSEPH AND SHARON : NEW YORK STATE SUPREME COURT WEGZYN : : CORTLAND COUNTY vs. : INDEX NO.: EF16-529 FORD MOTOR COMPANY :CERTIFICATION OF SERVICE The undersigned certifies that on September 22, 2016 the following documents were filed electronically via New York State’s Court’s ECF system and that true copies were served upon counsel for the Defendant via ECF 1, Plaintiff's Answers to Defendant’s Affirmative Defenses on behalf of Plaintiff, Joseph & Sharon Wegzyn. DATED: September 22, 2016 /s/ David J. Gorberg David J. Gorberg, Esquire David J. Gorberg & Associates, P.C. 103 Sibley Avenue Ardmore, PA 19003 (215) 665-7660 3 of 3