Case 5:16-cv-01099-TJM-TWD Document 21 Filed 10/14/16 Page 1 of 4

IN THE UNITED STATES DISRICT COURT

FOR THE NORTHERN DISTRICT OF
NEW YORK

COR DEVELOPMENT COMPANY, LLC,

Civil Action No. 5:16-cv-1099

(TJM/TWD)

Plaintiff,

v.
TODD R. HOWE,
Defendant.

ANSWER OF DEFENDANT TODD R. HOWE

Richard J. Morvillo, Ellen Murphy and Stuart F. Pierson, counsel for defendant Todd
R. Howe, who are admitted to practice in this Court for this case pro hac vice, respectfully
submit this Answer to the Complaint of plaintiff COR Development Company, LLC ("COR"
and "plaintiff").
General Denial
1. The defendant denies each and every factual allegation in the Complaint.
2. The defendant denies each and every claim in the Complaint.
Responses to Paragraphs of the Complaint
1. Defendant lacks knowledge or information sufficient to form a belief about this
allegation; and it is, accordingly, denied.
2. Admitted.
3. As the alleged promissory note was not attached to the Complaint, defendant lacks
ANSWER OF DEFENDANT TODD R. HOWE - 1
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Case 5:16-cv-01099-TJM-TWD Document 21 Filed 10/14/16 Page 2 of 4

knowledge or information sufficient to form a belief about this allegation; and it is,
accordingly, denied.
4. As the alleged amended promissory note was not attached to the Complaint,
defendant lacks knowledge or information sufficient to form a belief about this
allegation; and it is, accordingly, denied.
5. As the alleged amended promissory note was not attached to the Complaint,
defendant lacks knowledge or information sufficient to form a belief about this
allegation; and it is, accordingly, denied.
6. As the alleged amended promissory note was not attached to the Complaint,
defendant lacks knowledge or information sufficient to form a belief about this
allegation; and it is, accordingly, denied.
7. Admitted that Defendant has not made payments pursuant to any obligation to
Plaintiff.
8. Denied.
9. Denied.
Defenses
1. The Court lacks subject matter jurisdiction of this case.
2. The Court lacks personal jurisdiction of the defendant.
3. The complaint fails to state a claim upon which relief can be granted.
4. The complaint fails to attach the alleged notes.
5. Any debt owed by the defendant to the plaintiff was extinguished in an accord and
satisfaction.
6. The plaintiff is estopped to assert the claims set forth in the Complaint.

ANSWER OF DEFENDANT TODD R. HOWE - 2

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7.

The plaintiff has waived any claim against the defendant.

8.

Plaintiff's purported loan was illegal, as it was part of an illegal conspiracy to deprive
the public of its intangible right to honest services of an employee of the State of New
York by soliciting and giving bribes and gratuities.

9. COR's attempt in June 2016 to negotiate a check purportedly issued by the defendant,
dated December 28, 2015, was knowingly and legally a vacant, illegal and ineffective
act, purporting to demand payment for a non-existent debt.
WHEREFORE, Defendants demands judgment in his favor, plus the reasonable costs and
attorneys fees incurred in defending this action.
Jury Demand
10. Defendant demands a jury trial.
Respectfully submitted,

____/s/ Stuart F. Pierson__

Stuart F. Pierson
NY Bar No. 1901388
DC Bar No. 56820
Suite 705
1101 17th Street NW
Washington, DC 20036
202/803-5852
F: 202/609-8044
Richard J. Morvillo
NY Bar No.
Morvillo LLP
500 5th Avenue
43rd Floor
New York, NY 10110
DC Bar No. 219063
Suite 705
1101 17th Street NW
Washington, DC 20036

ANSWER OF DEFENDANT TODD R. HOWE - 3

5666568.1

Case 5:16-cv-01099-TJM-TWD Document 21 Filed 10/14/16 Page 4 of 4

202/803-5858
F: 202/775-5937
Ellen Murphy
Richard J. Morvillo
NY Bar No.
Morvillo LLP
500 5th Avenue
43rd Floor
New York, NY 10110
212/796-6344
F: 212/379-2097

ANSWER OF DEFENDANT TODD R. HOWE - 4

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Case 5:16-cv-01099-TJM-TWD Document 21-1 Filed 10/14/16 Page 1 of 1

IN THE UNITED STATES DISRICT COURT

FOR THE NORTHERN DISTRICT OF
NEW YORK

COR DEVELOPMENT COMPANY, LLC,

Civil Action No. 5:16-cv-1099

(TJM/TWD)

Plaintiff,

v.
TODD R. HOWE,
Defendant.

CERTIFICATE OF SERVICE

I hereby certify that on October 14, 216, I electronically filed the foregoing DEFENDANTS
ANSWER, with the Clerk of the Northern District Court using its CM/ECF system, which would
then electronically notify the following CM/ECF participants on this case:
Anthony F. Copani, Esq.
Mannion, Copani Law Firm
224 Harrison Street
306 Syracuse Building
Syracuse, NY 13202
Tel.: (315) 478-3500
Fax: (315) 478-0204
E-mail: g82afc@aol.com

Scott W. Iseman, Esq.

siseman@oalaw.com

Stephen R. Coffey, Esq.

scoffey@oalaw.com

And, I hereby certify that I have mailed the foregoing by the United States Postal Service, to
the following participants:
N/A
/s/ Carolyn A. Dashnaw
Carolyn A. Dashnaw
Goldberg Segalla, LLP
5786 Widewaters Parkway
Syracuse, New York 13214
(315) 413-5400
1
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