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DOCKET NO.: FST-CV21-6050815-S : SUPERIOR COURT
:
PETER LAURIDSEN : J. D. OF STAMFORD
:
V. : AT STAMFORD
:
ARTHUR TUROVETS, D.C., ET AL : OCTOBER 20, 2021
DEFENDANTS’ ANSWER TO PLAINTIFF’S AMENDED COMPLAINT
The undersigned Defendants, Arthur Turovets, D.C. and Nuvo Health & Wellness Co.,
by and through their undersigned counsel, hereby answer the Plaintiff’s Amended
Complaint as follows:
FIRST COUNT: (PETER LAURIDSEN v. ARTHUR TUROVETS, D.C.)
1. The allegations at paragraph 1 set forth legal conclusions as to which no response is
required.
2. The allegations at paragraph 2 set forth legal conclusions as to which no response is
required.
3. The allegations set forth at paragraph 3 are admitted upon information and belief.
4. Denied in part. At all relevant times, Arthur Turovets, D.C., was licensed to practice in
the State of New York and the State of New Jersey.
5. The allegations at paragraph 5 set forth legal conclusions as to which no response is
required.
6. The allegations set forth at paragraph 6 are denied.
7. The allegations set forth at paragraph 7, without reference to a specific advertisement
for the NJ Diet, can neither be admitted nor denied with any specificity. That issue
notwithstanding, the advertisements for the NJ Diet speak for themselves.
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8. The allegations set froth at paragraph 8 are denied.
9. Admitted that Plaintiff started the diet plan on or about May 12, 2019.
10. Defendant can neither admit nor deny that Plaintiff followed the diet plan between May
12, 2019 and June 14, 2019, except to note that Plaintiff seemingly acknowledged
some deviation(s) therefrom on June 5, 2019. Defendant further denies that Plaintiff
returned for all periodic weigh-ins.
11. The allegations set forth at paragraph 11 are admitted to the extent that office visits
were with employees of Nuvo Health & Wellness Co. and that Defendant Turovets did
not meet and/or examine Plaintiff.
12. Defendant denies knowledge and information sufficient to form a belief as to the
allegations set forth in paragraph 12 and therefore leaves Plaintiff to his proof.
13. The allegations set forth at paragraph 13 are denied.
14. The allegations set forth at paragraph 14 are denied as alleged. After receiving an
email from Plaintiff advising “I feel lethargic, my stomach feels sour/slightly upset. I feel
like I need to get back to the gym. And I feel like I have lost enough weight”, Defendant
Turovets responded with the recommendation that he “[h]ave a half of a banana as one
of your fruit for the 3 days of phase 3. Then go next phases”.
15. Defendant denies knowledge and information sufficient to form a belief as to the
allegations set forth in paragraph 15 and therefore leaves Plaintiff to his proof.
16. Defendant denies knowledge and information sufficient to form a belief as to the
allegations set forth in paragraph 16 and therefore leaves Plaintiff to his proof.
17. The allegations set forth at paragraph 17, inclusive of all subparts (a) through (m)
thereof, are denied.
18. The allegations set forth at paragraph 18, inclusive of all subparts (a) through (i)
thereof, are denied.
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19. The allegations set forth in Paragraph 19 are denied to the extent that they presume,
allege and/or are intended to allege any negligence and/or liabilityof the part of the
Defendants. As to the losses, damages, and/or injuries set forth therein, these
Defendants lack sufficient knowledge and/or information upon which to form a belief
and therefore leave the Plaintiff to his proof.
20. The allegations set forth in Paragraph 20 are denied to the extent that they presume,
allege and/or are intended to allege any negligence and/or liabilityof the part of the
Defendants. As to the losses, damages, and/or injuries set forth therein, these
Defendants lack sufficient knowledge and/or information upon which to form a belief
and therefore leave the Plaintiff to his proof.
21. The allegations set forth in Paragraph 21 are denied to the extent that they presume,
allege and/or are intended to allege any negligence and/or liabilityof the part of the
Defendants. As to the losses, damages, and/or injuries set forth therein, these
Defendants lack sufficient knowledge and/or information upon which to form a belief
and therefore leave the Plaintiff to his proof.
22. The allegations set forth in Paragraph 22 are denied to the extent that they presume,
allege and/or are intended to allege any negligence and/or liabilityof the part of the
Defendants. As to the losses, damages, and/or injuries set forth therein, these
Defendants lack sufficient knowledge and/or information upon which to form a belief
and therefore leave the Plaintiff to his proof.
23. The allegations set forth in Paragraph 23 are denied to the extent that they presume,
allege and/or are intended to allege any negligence and/or liabilityof the part of the
Defendants. As to the losses, damages, and/or injuries set forth therein, these
Defendants lack sufficient knowledge and/or information upon which to form a belief
and therefore leave the Plaintiff to his proof.
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24. The allegations set forth in Paragraph 24 are denied to the extent that they presume,
allege and/or are intended to allege any negligence and/or liabilityof the part of the
Defendants. As to the losses, damages, and/or injuries set forth therein, these
Defendants lack sufficient knowledge and/or information upon which to form a belief
and therefore leave the Plaintiff to his proof.
SECOND COUNT: (PETER LAURIDSEN v. BEHZAD HAKAKIAN, D.C.)
This Second Count was withdrawn by Plaintiff on August 2, 2021 (Docket Entry No.
115.00) such that no response is required hereto.
THIRD COUNT: (PETER LAURIDSEN v. KIRSTEN REINEKE)
This Third Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
FOURTH COUNT: (PETER LAURIDSEN v. NJDIET PROFESSIONAL CORPORATION
– ARTHUR TUROVETS, D.C.)
This Fourth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
FIFTH COUNT: (PETER LAURIDSEN v. NJDIET PROFESSIONAL CORPORATION
– BEHZAD HAKAKIAN, D.C.)
This Fifth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
SIXTH COUNT: (PETER LAURIDSEN v. NJDIET PROFESSIONAL CORPORATION
– KIRSTEN REINEKE)
This Sixth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
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SEVENTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS OF CT,
INC. – ARTHUR TUROVETS, D.C.)
This Seventh Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
EIGHTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS OF CT, INC. –
BEHZAD HAKAKIAN, D.C.)
This Eighth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
NINTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS OF CT, INC. –
KIRSTEN REINEKE)
This Ninth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
TENTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS CO. –
ARTHUR TUROVETS, D.C.)
1.-24. Defendants’ responses to Plaintiff’s allegations as set forth at paragraph 1-24 of the
First Count are hereby incorporated herein by reference and made the corresponding
responses to paragraphs 1-24 of this Tenth Count, as though more fully set forth
herein.
25. The allegations set forth at paragraph 25 are denied.
26. Admitted that, at all relevant times, Defendant Turovets was an owner and employee of
Nuvo Health & Wellness Co.
27. Admitted that, at all relevant times, Defendant Turovets was an employee of Nuvo
Health & Wellness Co. and acting within the course and scope of said employment.
28. The allegations set forth at paragraph 28 are denied.
29. The allegations at paragraph 29 set forth legal conclusions as to which no response is
required. To the extent the allegations set forth at paragraph 29 presume, allege and/or
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are intended to allege any negligence and/or liability of the part of the Defendants, they
are denied.
ELEVENTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS CO. –
BEHZAD HAKAKIAN, D.C.)
This Eleventh Count was withdrawn by Plaintiff on August 2, 2021 (Docket Entry
No. 115.00) such that no response is required hereto.
TWELFTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS CO. –
KIRSTEN REINEKE)
This Twelfth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
THIRTEENTH COUNT: (PETER LAURIDSEN v. BROAD STREET WELLNESS CENER,
PC – ARTHUR TUROVETS, D.C.)
This Thirteenth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
FOURTEENTH COUNT: (PETER LAURIDSEN v. BROAD STREET WELLNESS
CENER, PC – BEHZAD HAKAKIAN, D.C.)
This Fourteenth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
FIFTEENTH COUNT: (PETER LAURIDSEN v. BROAD STREET WELLNESS CENER,
PC – KIRSTEN REINEKE)
This Fifteenth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No.
103.00) such that no response is required hereto.
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THE DEFENDANTS,
ARTHUR TUROVETS, D.C. and NUVO HEALTH &
WELLNESS CO.
By: ______ __________________
Megan E. Bryson (Juris No. 427539)
KAUFMAN, BORGEEST & RYAN, LLP
1010 Washington Blvd., 7th Floor
Stamford, CT 06901
T: (203) 557-5700/ F: (203) 557-5777
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CERTIFICATION
I certify that a copy of this document was mailed or delivered electronically or non-
electronically on October 20, 2021 to all attorneys and self-represented parties of record
and to all parties who have not appeared in this matter and that written consent for all
electronic delivery was received from all attorneys and self-represented parties receiving
electronic delivery.
Joseph R. Rossetti, Esq.
Moore, O’Brien & Foti
891 Straits Turnpike
Middlebury, CT 06762
_______ ________________
Megan E. Bryson
Commissioner of the Superior Court
Juris No.: 427539
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Preview
DOCKET NO.: FST-CV21-6050815-S : SUPERIOR COURT : PETER LAURIDSEN : J. D. OF STAMFORD : V. : AT STAMFORD : ARTHUR TUROVETS, D.C., ET AL : OCTOBER 20, 2021 DEFENDANTS’ ANSWER TO PLAINTIFF’S AMENDED COMPLAINT The undersigned Defendants, Arthur Turovets, D.C. and Nuvo Health & Wellness Co., by and through their undersigned counsel, hereby answer the Plaintiff’s Amended Complaint as follows: FIRST COUNT: (PETER LAURIDSEN v. ARTHUR TUROVETS, D.C.) 1. The allegations at paragraph 1 set forth legal conclusions as to which no response is required. 2. The allegations at paragraph 2 set forth legal conclusions as to which no response is required. 3. The allegations set forth at paragraph 3 are admitted upon information and belief. 4. Denied in part. At all relevant times, Arthur Turovets, D.C., was licensed to practice in the State of New York and the State of New Jersey. 5. The allegations at paragraph 5 set forth legal conclusions as to which no response is required. 6. The allegations set forth at paragraph 6 are denied. 7. The allegations set forth at paragraph 7, without reference to a specific advertisement for the NJ Diet, can neither be admitted nor denied with any specificity. That issue notwithstanding, the advertisements for the NJ Diet speak for themselves. 1 7686398 8. The allegations set froth at paragraph 8 are denied. 9. Admitted that Plaintiff started the diet plan on or about May 12, 2019. 10. Defendant can neither admit nor deny that Plaintiff followed the diet plan between May 12, 2019 and June 14, 2019, except to note that Plaintiff seemingly acknowledged some deviation(s) therefrom on June 5, 2019. Defendant further denies that Plaintiff returned for all periodic weigh-ins. 11. The allegations set forth at paragraph 11 are admitted to the extent that office visits were with employees of Nuvo Health & Wellness Co. and that Defendant Turovets did not meet and/or examine Plaintiff. 12. Defendant denies knowledge and information sufficient to form a belief as to the allegations set forth in paragraph 12 and therefore leaves Plaintiff to his proof. 13. The allegations set forth at paragraph 13 are denied. 14. The allegations set forth at paragraph 14 are denied as alleged. After receiving an email from Plaintiff advising “I feel lethargic, my stomach feels sour/slightly upset. I feel like I need to get back to the gym. And I feel like I have lost enough weight”, Defendant Turovets responded with the recommendation that he “[h]ave a half of a banana as one of your fruit for the 3 days of phase 3. Then go next phases”. 15. Defendant denies knowledge and information sufficient to form a belief as to the allegations set forth in paragraph 15 and therefore leaves Plaintiff to his proof. 16. Defendant denies knowledge and information sufficient to form a belief as to the allegations set forth in paragraph 16 and therefore leaves Plaintiff to his proof. 17. The allegations set forth at paragraph 17, inclusive of all subparts (a) through (m) thereof, are denied. 18. The allegations set forth at paragraph 18, inclusive of all subparts (a) through (i) thereof, are denied. 2 7686398 19. The allegations set forth in Paragraph 19 are denied to the extent that they presume, allege and/or are intended to allege any negligence and/or liabilityof the part of the Defendants. As to the losses, damages, and/or injuries set forth therein, these Defendants lack sufficient knowledge and/or information upon which to form a belief and therefore leave the Plaintiff to his proof. 20. The allegations set forth in Paragraph 20 are denied to the extent that they presume, allege and/or are intended to allege any negligence and/or liabilityof the part of the Defendants. As to the losses, damages, and/or injuries set forth therein, these Defendants lack sufficient knowledge and/or information upon which to form a belief and therefore leave the Plaintiff to his proof. 21. The allegations set forth in Paragraph 21 are denied to the extent that they presume, allege and/or are intended to allege any negligence and/or liabilityof the part of the Defendants. As to the losses, damages, and/or injuries set forth therein, these Defendants lack sufficient knowledge and/or information upon which to form a belief and therefore leave the Plaintiff to his proof. 22. The allegations set forth in Paragraph 22 are denied to the extent that they presume, allege and/or are intended to allege any negligence and/or liabilityof the part of the Defendants. As to the losses, damages, and/or injuries set forth therein, these Defendants lack sufficient knowledge and/or information upon which to form a belief and therefore leave the Plaintiff to his proof. 23. The allegations set forth in Paragraph 23 are denied to the extent that they presume, allege and/or are intended to allege any negligence and/or liabilityof the part of the Defendants. As to the losses, damages, and/or injuries set forth therein, these Defendants lack sufficient knowledge and/or information upon which to form a belief and therefore leave the Plaintiff to his proof. 3 7686398 24. The allegations set forth in Paragraph 24 are denied to the extent that they presume, allege and/or are intended to allege any negligence and/or liabilityof the part of the Defendants. As to the losses, damages, and/or injuries set forth therein, these Defendants lack sufficient knowledge and/or information upon which to form a belief and therefore leave the Plaintiff to his proof. SECOND COUNT: (PETER LAURIDSEN v. BEHZAD HAKAKIAN, D.C.) This Second Count was withdrawn by Plaintiff on August 2, 2021 (Docket Entry No. 115.00) such that no response is required hereto. THIRD COUNT: (PETER LAURIDSEN v. KIRSTEN REINEKE) This Third Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. FOURTH COUNT: (PETER LAURIDSEN v. NJDIET PROFESSIONAL CORPORATION – ARTHUR TUROVETS, D.C.) This Fourth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. FIFTH COUNT: (PETER LAURIDSEN v. NJDIET PROFESSIONAL CORPORATION – BEHZAD HAKAKIAN, D.C.) This Fifth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. SIXTH COUNT: (PETER LAURIDSEN v. NJDIET PROFESSIONAL CORPORATION – KIRSTEN REINEKE) This Sixth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. 4 7686398 SEVENTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS OF CT, INC. – ARTHUR TUROVETS, D.C.) This Seventh Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. EIGHTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS OF CT, INC. – BEHZAD HAKAKIAN, D.C.) This Eighth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. NINTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS OF CT, INC. – KIRSTEN REINEKE) This Ninth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. TENTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS CO. – ARTHUR TUROVETS, D.C.) 1.-24. Defendants’ responses to Plaintiff’s allegations as set forth at paragraph 1-24 of the First Count are hereby incorporated herein by reference and made the corresponding responses to paragraphs 1-24 of this Tenth Count, as though more fully set forth herein. 25. The allegations set forth at paragraph 25 are denied. 26. Admitted that, at all relevant times, Defendant Turovets was an owner and employee of Nuvo Health & Wellness Co. 27. Admitted that, at all relevant times, Defendant Turovets was an employee of Nuvo Health & Wellness Co. and acting within the course and scope of said employment. 28. The allegations set forth at paragraph 28 are denied. 29. The allegations at paragraph 29 set forth legal conclusions as to which no response is required. To the extent the allegations set forth at paragraph 29 presume, allege and/or 5 7686398 are intended to allege any negligence and/or liability of the part of the Defendants, they are denied. ELEVENTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS CO. – BEHZAD HAKAKIAN, D.C.) This Eleventh Count was withdrawn by Plaintiff on August 2, 2021 (Docket Entry No. 115.00) such that no response is required hereto. TWELFTH COUNT: (PETER LAURIDSEN v. NUVO HEALTH & WELLNESS CO. – KIRSTEN REINEKE) This Twelfth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. THIRTEENTH COUNT: (PETER LAURIDSEN v. BROAD STREET WELLNESS CENER, PC – ARTHUR TUROVETS, D.C.) This Thirteenth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. FOURTEENTH COUNT: (PETER LAURIDSEN v. BROAD STREET WELLNESS CENER, PC – BEHZAD HAKAKIAN, D.C.) This Fourteenth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. FIFTEENTH COUNT: (PETER LAURIDSEN v. BROAD STREET WELLNESS CENER, PC – KIRSTEN REINEKE) This Fifteenth Count was withdrawn by Plaintiff on April 21, 2021 (Docket Entry No. 103.00) such that no response is required hereto. 6 7686398 THE DEFENDANTS, ARTHUR TUROVETS, D.C. and NUVO HEALTH & WELLNESS CO. By: ______ __________________ Megan E. Bryson (Juris No. 427539) KAUFMAN, BORGEEST & RYAN, LLP 1010 Washington Blvd., 7th Floor Stamford, CT 06901 T: (203) 557-5700/ F: (203) 557-5777 7 7686398 CERTIFICATION I certify that a copy of this document was mailed or delivered electronically or non- electronically on October 20, 2021 to all attorneys and self-represented parties of record and to all parties who have not appeared in this matter and that written consent for all electronic delivery was received from all attorneys and self-represented parties receiving electronic delivery. Joseph R. Rossetti, Esq. Moore, O’Brien & Foti 891 Straits Turnpike Middlebury, CT 06762 _______ ________________ Megan E. Bryson Commissioner of the Superior Court Juris No.: 427539 8 7686398