Beruflich Dokumente
Kultur Dokumente
.jr
ZUKERMAN GORE BRANDEIS & CROSSMAN, LLP John K. Crossman FrankC. Welzer Florence M. Beauboeuf Eleven Times Square New York, New York 10036 (2 12) 223-6700 Attorneys for Defendant James Stuckey
Plaintiff,
against -
. . . . . . . . . . . . . . . . . . . Defendants.. . . . . . . . . . . . . . . . . X ...............
ANSWER
James Stuckey (Stuckey), by and through his attorneys, hereby answers the Complaint
of plaintiff Stephanie Bonadio (Bonadio), as follows: The unnumbered paragraphs of the complaint are improper and are therefore denied.
conclusions of law to which no responsive pleading is required, and are therefore denied.
2.
conclusions of law to which no responsive pleading is required, except Stuckey is without knowledge or information to form a belief as to where Bonadio resides.
3.
conclusions of law to which no responsive pleading is required, and are therefore denied.
4.
falsity of the allegations contained in paragraph 4 of the Complaint, and on that basis denied,
FACTUAL ALLEGATIONS
5.
falsity of the allegations contained in paragraph 5 of the Complaint, and are therefore denied.
6.
7,
Admitted. Admit that Stuckey became Bonadios supervisor beginning in or around late
8.
Denied. Denied. Admit that in or around Spring of 201 1, Bonadio began performing additional
9.
10.
Admit that Bonadio took steps to move into the position of Director of Corporate
and Executive Education, including drafting an official job description, and deny the remaining allegations in paragraph 1 1.
12.
Admit that Stuckey and Bonadio went to dinner on September 23,201 1, and deny
the remaining allegations in paragraph 12. 13. 14, 15. Denied. Denied.
falsity of the allegations contained in paragraph 15 of the Complaint, and are therefore denied. 16. Is without knowledge or information sufficient to form a belief as to the truth or
falsity of the allegations contained in paragraph 16 of the Complaint, and are therefore denied.
17.
falsity of the allegations contained in paragraph 17 of the Complaint, and are therefore denied. 18. 19. Denied. Denied. Denied.
20.
Defendant repeats and realleges each and every answer set forth in the
2.
3.
Denied. Denied.
Defendant repeats and realleges each and every answer set forth in the
Denied. Denied,
6.
Defendant repeats and realleges each and every answer set forth in the
11.
Denied. Denied.
12,
NYU that Stuckey had placed her hand on his crotch and his erect penis. Plaintiff made such
statements knowing them to be false. Plaintiff also falsely concealed that all conduct on the night in question occurred with plaintiffs consent. To the extent that plaintiff has a claim for damages, it should be setoff by the substantial amount of damages caused to Stuckey by plaintiffs defamatory statements to NYU.
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