On April 19, 2006 a
Answer
was filed
involving a dispute between
Taub, Pamela,
Taub , Robert,
and
Blackburn , Theodore,
Tzavaras , Alex,
for DECLARATORY JUDGMENT
in the District Court of Summit County.
Preview
a
2nd JUL 12 PMI2: 52
crema ur CUuimIS
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
ROBERT TAUB ) CASE NO. CV-2006-04-2563
dba MLM PROPERTIES, )
dba WMLM PROPERTIES, AND ) JUDGE BRENDA BURNHAM-UNRUH
PAMELA TAUB, )
)
Plaintiffs, )
)
-v- )
) ANSWER OF ROBERT AND
ALEX TZAVARAS ) PAMELA TAUB TO COUNTERCLAIM
DBA ALEXANDER CON- ) OF THEODORE E. BLACKBURN
STRUCTION COMPANY, et al, )
)
—____________Defendants. _)
1. Now come Plaintiffs and, for their Answer to the Counterclaim of Defendant,
Theodore E. Blackburn, admit the allegations of paragraphs 4, 5 and 6 of said Counterclaim.
2. Plaintiffs deny the allegations of paragraph 7 of the Counterclaim.
3. Plaintiffs are without knowledge or information sufficient to form a belief as to the
truth of the allegations of paragraphs 8 and 9 of the Counterclaim.
4. Plaintiffs deny the allegations of paragraph 10 of the Counterclaim,
5. Plaintiffs admit that Defendant Blackburn filed an invalid Mechanic's Lien upon
Plaintiffs’ property. but Plaintiffs deny all other allegations of paragraph 11 of the Counterclaim.COPY
6. Plaintiffs hereby incorporate their Tesponses to paragraphs 4 through 11 in response
to paragraph 12 of the Counterclaim.
7. Plaintiffs deny the allegations of paragraphs 13, 14 and 15 of the Counterclaim.
8. Plaintiffs hereby incorporate their Tesponses to paragraphs 4 through 11 for their
reply to paragraph 16 of the Counterclaim.
9. Plaintiffs deny the allegations of paragraph 17 of the Counterclaim.
WHEREFORE, Plaintiffs respectfully request that Defendant Blackburn's Counter-
claim be dismissed at said Defendant’s cost, and that Plaintiffs be awarded their costs and
attorncy’s fees herein and any further relief to which they may be entitled.
Yew ‘
MARK C. CAVANAUGH/ (0020557)
Attorney for Plaintiffs
755 White Pond Drive, Suite 403
Akron, OH 44320
Telephone: 330-864-7155
CERTIFICATION OF SERVICE
The undersigned hereby certifies that a true copy of the foregoing Answer of Robert
and Pamela Taub to Counterclaim of Theodore E. Blackburn was sent by First Class United
States Mail to Dick W. Mount, Jr., Attorney for Theodore E. Blackburn, P.O. Box 182,
Minerva, Ohio 44657. on the piv day of July, 2006.
MARK C. CAVANAUG
Attorney for Plaintiffs
Category
DECLARATORY JUDGMENT
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a 2nd JUL 12 PMI2: 52 crema ur CUuimIS IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO ROBERT TAUB ) CASE NO. CV-2006-04-2563 dba MLM PROPERTIES, ) dba WMLM PROPERTIES, AND ) JUDGE BRENDA BURNHAM-UNRUH PAMELA TAUB, ) ) Plaintiffs, ) ) -v- ) ) ANSWER OF ROBERT AND ALEX TZAVARAS ) PAMELA TAUB TO COUNTERCLAIM DBA ALEXANDER CON- ) OF THEODORE E. BLACKBURN STRUCTION COMPANY, et al, ) ) —____________Defendants. _) 1. Now come Plaintiffs and, for their Answer to the Counterclaim of Defendant, Theodore E. Blackburn, admit the allegations of paragraphs 4, 5 and 6 of said Counterclaim. 2. Plaintiffs deny the allegations of paragraph 7 of the Counterclaim. 3. Plaintiffs are without knowledge or information sufficient to form a belief as to the truth of the allegations of paragraphs 8 and 9 of the Counterclaim. 4. Plaintiffs deny the allegations of paragraph 10 of the Counterclaim, 5. Plaintiffs admit that Defendant Blackburn filed an invalid Mechanic's Lien upon Plaintiffs’ property. but Plaintiffs deny all other allegations of paragraph 11 of the Counterclaim.COPY 6. Plaintiffs hereby incorporate their Tesponses to paragraphs 4 through 11 in response to paragraph 12 of the Counterclaim. 7. Plaintiffs deny the allegations of paragraphs 13, 14 and 15 of the Counterclaim. 8. Plaintiffs hereby incorporate their Tesponses to paragraphs 4 through 11 for their reply to paragraph 16 of the Counterclaim. 9. Plaintiffs deny the allegations of paragraph 17 of the Counterclaim. WHEREFORE, Plaintiffs respectfully request that Defendant Blackburn's Counter- claim be dismissed at said Defendant’s cost, and that Plaintiffs be awarded their costs and attorncy’s fees herein and any further relief to which they may be entitled. Yew ‘ MARK C. CAVANAUGH/ (0020557) Attorney for Plaintiffs 755 White Pond Drive, Suite 403 Akron, OH 44320 Telephone: 330-864-7155 CERTIFICATION OF SERVICE The undersigned hereby certifies that a true copy of the foregoing Answer of Robert and Pamela Taub to Counterclaim of Theodore E. Blackburn was sent by First Class United States Mail to Dick W. Mount, Jr., Attorney for Theodore E. Blackburn, P.O. Box 182, Minerva, Ohio 44657. on the piv day of July, 2006. MARK C. CAVANAUG Attorney for Plaintiffs