IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NEW YORK
| ROBERT NOVAK, d/b/a/ Pets Warehouse.com, Plaintiff
v.
ACTIVE WINDOW PRODUCTIONS, INC.,et al., Defendants.
|
Case No: CV 013566
Answer to the Counter Claim |
1. Plaintiff Robert Novak submits this reply in opposition to defendants First Counterclaim.
2. Deny information sufficient to form a belief as to the truth of the claim stated in paragraph 58 and 59 of defendants answer.
3. Defendant fails to cite any relevant law that Plaintiff is allegedly violating. Further, fails to cite any specific violation related to hasassment and intimidation or direct evidence of such claim.
4. Defendant alleges that Robert Novak is libel under a State law theory of civil rights, but fails to state any certain representations regarding it.
5. Both variants fail.
6. Defendant seeks as a result of these unspecified violations by the Plaintiff reimbursement of legal fees and other damages yet to be determined.
7. Defendant again fails to state his basis for entitlement to such fees and damages or any applicable law thereto.
WHEREFORE, the defendant's counterclaim should be dismissed
August 6, 2001
Copiague, NY
Robert Novak
Plaintiff
631.789.5400
To:
Robert Folks
Attorney for defendants
510 Broad Hollow Rd suite 305
Melville NY 11747
|