INDEX NO.

650852/2016

FILED: NEW YORK COUNTY CLERK 03/29/2016 03:59 PM

NYSCEF DOC. NO. 11

RECEIVED NYSCEF: 03/29/2016

Name: Gerard Kelly

Address: is 320 pin oak ave Woodstock Ga 30188
Phone: 4047845003
Defendant In Pro Per
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Vishal Rohit Nathani,
PLAINTIFF, vs.
Gerard Kelly, Maelstrom gaming llc, Martin Shkreli
______________________________
DEFENDANT(S).

Case No.: 650852/2016

DEFENDANTS ANSWER
JURY TRIAL DEMAND Yes X No

Defendant Gerard Kelly hereby answers Plaintiffs complaint as follows:

ANSWER TO COMPLAINT

1.
2.
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5.
6.
7.
8.
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10.
11.
12.
13.

Affirm
Affirm
Lack enough information to respond to Plaintiff's allegations.
Affirm
Denied. Plaintiff was provided contract on 8/2/2015 for review
Agreed
Denied. Plaintiff was previously employed by Odyssey Gaming LLC, which was absorbed by
Maelstrom Gaming LLC, a mutual agreement had not been made
Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Denied. Plantiff was working under previous Odyssey Gaming LLC contract.
Denied. No agreement was made and plaintiff worked as a coach outside of Maelstrom Gaming
LLC during the period

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14.
15.
16.
17.
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22.
23.
24.
25.
26.
27.
28.
29.
30.

Lack enough information to respond to Plaintiff's allegations.

Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Denied. All legal formalities were followed
Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Denied. A mutual agreement was never made
Lack enough information to respond to Plaintiff's allegations.
Denied. No money is due because an agreement was never made
Lack enough information to respond to Plaintiff's allegations.
Lack enough information to respond to Plaintiff's allegations.
Denied. No mutual agreement was made
Denied. No mutual agreement was made
Denied. No mutual agreement was made

REQUEST FOR RELIEF

WHEREFORE, the Defendant requests:
1. Dismissal of the Plaintiffs action with prejudice;
2. An order that Plaintiff shall take no relief from the complaint;
3. Such further relief the Court deems fair and just.
Dated: 3/25/2016________________
Sign: _____________________________
Print Name: Gerard Kelly
Defendant in Pro Per

Name: Gerard Kelly

Address: is 320 pin oak ave Woodstock Ga 30188
Phone: 4047845003
Defendant In Pro Per

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Name: Gerard Kelly

Address: is 320 pin oak ave Woodstock Ga 30188
Phone: 4047845003
Defendant In Pro Per

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

Vishal Rohit Nathani,

PLAINTIFF, vs.
Gerard Kelly
______________________________
DEFENDANT(S).

Case No.: 650852/2016

I, Gerard Kelly , declare as follows: (name of person serving documents) My address is 320 pin oak ave
Woodstock Ga 30188
where the efiling described below took place
On , I served the documents described as: (3/27/2016)

1. DEFENDANTS ANSWER

I declare under penalty of perjury that the foregoing is true and correct.
Executed on 3/26/2016

(sign) ____________
Printed name: Gerard Kelly

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