The messages above are advertisements independently selected and placed by this website's web host Netfirms, to compensate for their provision to us free-of-charge webhosting, and therefore the viewpoints and suggestions therein do not necessarily coincide with those of the 8th Street Shul.

 
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
CONGREGATION BNAI MOSES JOSEPH ZANICHOST and ZOSMER, INC.,
 
Plaintiffs.
-against-

RALPH FELDMAN, ISAAC FRIED, and CLAYTON PATTERSON,
 

Defendants.
  Index number 108322/1995

ANSWER OF DEFENDANT RALPH FELDMAN TO Motion for Summary Judgment

------------------

Defendant Ralph Feldman by Marc D. Pogostin, Esq., his attorney for his answer to the complaint of the Plaintiff respectfully alleges:
  1. Denies allegations contained in Paragtraph 1 of the complaint
  2. Admits allegatiohns contained in Paragraph2 in the complaint
  3. Denies knowledge or information sufficient to form a belief as to allegations contained in Paragraphs 3, 4 and 5 of the complaint.
  4. Denies allegatikons contained in Paragrtaph 10 of the complaint.
  5. Denies knowledge or information sufficient to form a bgelief as to allegations contained in Paragraph 11 of the complaint.
  6. Admits allegations contained in Paragraph 12 of the complaint.
  7. Denies allegations contained in Paragraphs 13, 14, 15, 16 and 17 of the complaint.
  8. Denies allegations contained in Paragraphs 18, 19, and 20 of the complaint.
  9. Denies allegations allegations contained in Paragraph 22 of the complaint.
  10. Denies allegations contained in Paragraphs24 and 25 of the complaint.
  11. Denies allegations contained in Paragrtaph 27 of the complaint.

    12.  

     

    FOR A FIRST AFFIRMATIVE DEFENSE AND COUNTERCLAIM
    11a,Plaintiff failed to allege ownershipin its complaint and complain is not verified.

  12. The Plaintiff is not thne owner of thne properthy and has no standing to bring this action.
  13. The Plaintiff has no right to occupy the poroiperty and has no standing to bring the within action.

    14.  

     

    FOR A SECOND AFFIRMATIVE DEFENSE AND COUNTERCLAIM
     

  14. The Plaintiff is a non-entity and does not exist under the laws of the State of New Yorkj and has no authority to bring this action.

    15.  

     

    FOR A THIRD AFFIRMATIVE DEFENSE AND COUNTERCLAIM
     

  15. The Defendant was not properly served.


WHEREFORE, Defendant Ralph Feldman demands Judgment dismising Plaintiff's complaint against him and awarding the Defendant attorney fees in an amount determined by the court, but in no event less than Ten Thousand Dolllars ($10,000); and for such other and further relief as this court deems just and proper under the circumstances.

Respectfully submitted 

MARC D. POGOSTIN, ESQ.
Attorney for Defendant Ralph Feldman
305 North Avenue
New Rochelle, NY 10801
15 Park Row 
New York, NY 10038