On February 25, 2014 a
Answer
was filed
involving a dispute between
Thora Claudette Challenger,
and
Charles S Giles,
George J Lamadeleine,
J.B. Hunt Transport, Inc.,,
Zephaniah P Mullin,
for Tort
in the District Court of New York County.
Preview
INDEX NO. 151998/2014
FILED: NEW YORK COUNTY CLERK 12/01/2014 04:38 PM
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 12/01/2014
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
mene n ene nen nnn nn nec ne ene nee nee e eee nnn n nn en ene e een,
THORA CLAUDETTE CHALLENGER, Index No.: 151998/14
Plaintiff,
VERIFIED ANSWER TO
-against- CO-DEFENDANT’S CROSS-
CLAIMS OF ZEPHANIAH P.
GEORGE J. LAMADELEINE, J.B. HUNT MULLIN AND CHARLES GILES
TRANSPORT, INC., ZEPHANIAH P. MULLIN, and
CHARLES S. GILES,
Defendants.
mene nen nnn nn nn eee n ene e neem ee nen anne nen nnn nnn nnn nn enna neta
Defendants, GEORGE J. LAMADELEINE and J.B. HUNT TRANSPORT, INC., by
and through their attorneys, RAWLE & HENDERSON LLP, as and for their verified answer to
co-defendant’s cross-claims of Zephaniah P. Mullin and Charles Giles, allege upon information
and belief as follows:
1 Deny first cross-claim of co-defendant Zephaniah P. Mullin and Charles Giles.
2. Deny second Cross-claim of Zephaniah P, Mullin and Charles Giles.
WHEREFORE, these answering defendants, GEORGE J. LAMADELEINE and J.B.
HUNT TRANSPORT, INC., demand judgment dismissing the plaintiff's first and second cross-
claims herein as to said answering defendants and for such other and further relief as this court
deems just and proper.
Dated: New York, New York
December 1, 2014
7897403-1
Yours, ete.
RAWLE & HENDERSON LLP
Attorneys for Defendants
GEORGE J. LAMADELEINE and
J.B. HUNT TRANSPORT, INC.
<
By
Any ny D, Luis
14 Wall Street -27" Floor
New York, New York 10005-2101
Telephone No.: 1 (212) 323-7070
Our File No.: 803330
TO LAW OFFICES OF ALEKSANDR VAKAREV
Attorneys for Plaintiff
2566 86" Street, Suite 1
Brooklyn, New York 11214
Telephone No.: 1 (718) 368-0690
Your File No.: 8644
ZEPHANIAH P. MULLIN
1901 Madison Avenue, Apt. 212
New York, New York 10035
Richard E. Noll, Esq.
The Noll Law Firm
Attorneys for Co-defendant
116 Jackson Avenue
Syosset, New York 11791
7897403-1
VERIFICATION
STATE OF NEW YORK )
1SS.
COUNTY OF NEW YORK )
ANTHONY D. LUIS, an attorney admitted to practice in the State of New York,
affirms: That the undersigned is a member of the firm of RAWLE & HENDERSON LLP,
attorneys for defendants in the within action; that the undersigned has read the foregoing
VERIFIED ANSWER TO CO-DEFENDANT’S CROSS-CLAIMS OF ZEPHANIAH P.
MULLIN AND CHARLES GILES and knows the contents thereof; that the same are true to
affirmant's own knowledge, except as to the matters therein stated to be alleged on information and
belief; and as to those matters affirmant believes them to be true.
The undersigned further states that the reason this affirmation is made by the
undersigned and not by the defendants is that the defendants reside outside the county where the
undersigned maintains his offices.
The grounds of affirmant's belief as to all matters not stated to be upon affirmant's
knowledge, are as follows: books, records, correspondence, investigation and other documentation
in the possession of the undersigned.
The undersigned affirms that the foregoing statements are true, under the penalty of
perjury.
Dated: New York, New York
December 1, 2014
hb
]
JATHONY D. LUIS
7897403-1
Document Filed Date
December 01, 2014
Case Filing Date
February 25, 2014
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
INDEX NO. 151998/2014 FILED: NEW YORK COUNTY CLERK 12/01/2014 04:38 PM NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 12/01/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK mene n ene nen nnn nn nec ne ene nee nee e eee nnn n nn en ene e een, THORA CLAUDETTE CHALLENGER, Index No.: 151998/14 Plaintiff, VERIFIED ANSWER TO -against- CO-DEFENDANT’S CROSS- CLAIMS OF ZEPHANIAH P. GEORGE J. LAMADELEINE, J.B. HUNT MULLIN AND CHARLES GILES TRANSPORT, INC., ZEPHANIAH P. MULLIN, and CHARLES S. GILES, Defendants. mene nen nnn nn nn eee n ene e neem ee nen anne nen nnn nnn nnn nn enna neta Defendants, GEORGE J. LAMADELEINE and J.B. HUNT TRANSPORT, INC., by and through their attorneys, RAWLE & HENDERSON LLP, as and for their verified answer to co-defendant’s cross-claims of Zephaniah P. Mullin and Charles Giles, allege upon information and belief as follows: 1 Deny first cross-claim of co-defendant Zephaniah P. Mullin and Charles Giles. 2. Deny second Cross-claim of Zephaniah P, Mullin and Charles Giles. WHEREFORE, these answering defendants, GEORGE J. LAMADELEINE and J.B. HUNT TRANSPORT, INC., demand judgment dismissing the plaintiff's first and second cross- claims herein as to said answering defendants and for such other and further relief as this court deems just and proper. Dated: New York, New York December 1, 2014 7897403-1 Yours, ete. RAWLE & HENDERSON LLP Attorneys for Defendants GEORGE J. LAMADELEINE and J.B. HUNT TRANSPORT, INC. < By Any ny D, Luis 14 Wall Street -27" Floor New York, New York 10005-2101 Telephone No.: 1 (212) 323-7070 Our File No.: 803330 TO LAW OFFICES OF ALEKSANDR VAKAREV Attorneys for Plaintiff 2566 86" Street, Suite 1 Brooklyn, New York 11214 Telephone No.: 1 (718) 368-0690 Your File No.: 8644 ZEPHANIAH P. MULLIN 1901 Madison Avenue, Apt. 212 New York, New York 10035 Richard E. Noll, Esq. The Noll Law Firm Attorneys for Co-defendant 116 Jackson Avenue Syosset, New York 11791 7897403-1 VERIFICATION STATE OF NEW YORK ) 1SS. COUNTY OF NEW YORK ) ANTHONY D. LUIS, an attorney admitted to practice in the State of New York, affirms: That the undersigned is a member of the firm of RAWLE & HENDERSON LLP, attorneys for defendants in the within action; that the undersigned has read the foregoing VERIFIED ANSWER TO CO-DEFENDANT’S CROSS-CLAIMS OF ZEPHANIAH P. MULLIN AND CHARLES GILES and knows the contents thereof; that the same are true to affirmant's own knowledge, except as to the matters therein stated to be alleged on information and belief; and as to those matters affirmant believes them to be true. The undersigned further states that the reason this affirmation is made by the undersigned and not by the defendants is that the defendants reside outside the county where the undersigned maintains his offices. The grounds of affirmant's belief as to all matters not stated to be upon affirmant's knowledge, are as follows: books, records, correspondence, investigation and other documentation in the possession of the undersigned. The undersigned affirms that the foregoing statements are true, under the penalty of perjury. Dated: New York, New York December 1, 2014 hb ] JATHONY D. LUIS 7897403-1