leeba merritt lawsuit answer

8/9/2019 Leeba Merritt Lawsuit Answer

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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF SUFFOLKX---------------------------------------------------------------------------XRICHARD MERRITT,

Plaintiff,

-- against –

VERIFIED ANSWERWITH

AFFIRMATIVE DEFENSES

AND

COUNTERCLAIM

Index No. 14-20704KENNETH N. WYNDER, as President of theLAW ENFORCEMENT EMPLOYEESBENEVOLENT ASSOCIATION, KENNETH N.WYNDER, Individually, and LAW ENFORCEMENTEMPLOYEES BENEVOLENT ASSOCIATION (“LEEBA”)

Defendants.X----------------------------------------------------------------------------X

Defendant, KENNETH N. WYNDER, as President of the Law Enforcement Employees

Benevolent Association, and the LAW ENFORCEMENT EMPLOYEES BENEVOLENT

ASSOCIATION (“LEEBA”) , by their attorney Joseph F. Buono, as and for his Answer to the

Verified Complaint (“Complaint”) of the plaintiff herein, respectfully alleges as follows:

1. Deny the allegations set forth in paragraph “1” of the Complaint, except admit that

plaintiff was and still is an attorney admitted to practice law in the State of New York.

2. Admit the allegations set forth in paragraph “2” of the Complaint, except denie s the

characterization of deriving substantial revenue.

3. Admit the allegation set forth in paragraph “3” of the Complaint, but more correctly

asserts that LEEBA is a domestic not-for-profit corporation.


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4. With respect to the allegations in paragraph “4” of the Complaint deny that Wynder

appointed himself president but admit remainder of the paragraph.

5. Admit the allegations in paragraph “5” of the Complaint.

6. Admit the allegations in paragraph “6” of th e Complaint.

7. Admit the allegations in paragraph “7” of the Complaint solely as they relate to

defendant LEEBA and Kenneth N. Wynder as president of LEEBA.

8. Deny the allegations in paragraph “8” of the Complaint since it calls for a legal

conclusion.

9. Deny the allegations in paragraph “9” of the Complaint since it calls for a legal

conclusion.

10. Deny knowledge or information sufficient to form a belief as to the allegations in

paragraph “10” of the Complaint.

11. Admit the allegations in paragraph “11” of the Complaint solely as they relate to

defendant LEEBA and Kenneth N. Wynder as president of LEEBA.

12. With respect to the allegations in paragraph “12” of the Complaint admit sub-paragraph

“a”; admit sub - paragraph “b” to the extent that plaintiff represen ted a member in one disciplinary

case for LEEBA but denies plaintiff represented members in grievances proceedings; deny sub-

paragraph “c” to the extent that it is not specific as to the services alleged to have been provided,

deny sub- paragraphs “d” and “e” in their entirety. Deny characterization of plaintiff being

“hired” by defendants.

13. Deny the allegations in paragraph “13” of the Complaint to the extent it uses the word

“vigorously” and draws a legal conclusion with regard to the remainder of the a llegation.

14. Deny the allegations in paragraph “14” of the Complaint to the extent that plaintiff was

not the exclusive attorney representing defendants.


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15. Deny the allegations in paragraph “15” of the Complaint but admit that LEEBA

collected membership dues out of payroll deductions from designated members of the City of

New York Department of Environmental Protection from October 2005 to the present and from

designated members of the Sea Gate Police Department from 2007 to 2011.

16. Deny the allegations in paragraph “16” of the Complaint to the extent it refers to the

$3,000.00/month payments as installments and deny that defendants entered into an installment

agreement with plaintiff. Admit that plaintiff was compensated for his services as counsel at an

agreed retainer rate of $3,000.00/month. Deny that defendants were supplied office space to

conduct business.

17. Deny the allegations in paragraph “17” of the Complaint that the $3,000.00/month

payments were installment payments. Deny that defendants agreed to pay plaintiff for additional

legal work over a threshold period of legal work performed. Admit that plaintiff was paid

monthly retainer payments of $3,000.00 which were increased in February 2007 to

$3,500.00/month. Deny that plaintiff was last paid in May 2014. Deny that defendants owe a

large unpaid balance to plaintiff.


19. Admit the allegation in paragraph “19” of the Complaint to the extent that LEEBA has a

By-laws and Constitution.

AS TO PLAINTIFF’S FIRST CAUSE OF ACTION

20. In response to paragraph “20” of the Complaint Defendants repeat and reallege each and

every response to paragraphs “1” through “19” of the Complaint.

21. Deny the allegations in paragraph “21” of the Complaint as the y do not pertain to the

corporate defendant LEEBA or Kenneth N. Wynder in his capacity as president of LEEBA.

22. Deny the allegations in paragraph “22” of the Complaint as they do not pertain to the



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24. Deny the allegations in paragraph “24” of the Com plaint as they do not pertain to the


25. Deny the allegations contained in paragraph “25” of the Complaint as they do not

pertain to the corporate defendant LEEBA or Kenneth N. Wynder in his capacity as president of

LEEBA.



LEEBA.



LEEBA.



LEEBA.









33. Deny the allegations in paragraph “33” of the Complaint.


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37. Deny the allegation s in paragraph “37” of the Complaint.

38. Admit the allegations in paragraph “38” of the Complaint except deny knowledge or

information sufficient to form a belief as to the characterization that NYC and Local 300

“vigorously opposed” LEEBA’s representation petition.

39. Admit the allegations in paragraph “39” of the Complaint to the extent that it is alleged

hearings were held at some point in time to determine if EPO members could be removed from

Local 300 representation. Deny that defendants agreed to pay plaintiff $300.00/hour for

representation. Deny knowledge or information sufficient to form a belief as to the remainder of

the paragraph.

40. Admit the allegations in paragraph “40” of the Complaint to the extent that LEEBA won

the representation election, was certified by OCB and entitled to dues check-off. Deny

defendants made “installment payments ” to plaintiff in the amount of $3,000.00/month and

further deny the characterization of those pay ments as “installment payments” but admit plaintiff

received $3,000.00/month retainer payments.

AS TO PLAINTIFF’S SECOND CAUSE OF ACTION

41. In response to paragraph “41” of the Complaint Defendant s repeat and reallege each and

every response to all prior paragraphs of the Complaint.

42. Admit the allegations in paragraph “42” of the Complaint to the extent that this was

work for which plaintiff was compensated as part of his then $3,000.00/month retainer. Deny

being billed $900.00. Deny knowledge or information sufficient to form a belief as to the

amount of legal hours required.


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43. Admit the allegations in paragraph “43” of the Complaint to the extent that collective

bargaining negotiation sessions were scheduled and that plaintiff’s legal services were required

under the terms of his $3,000.00/month retainer.


45. Deny the allegations in paragraph “45” of the Complaint . Deny any agreement to

compensate plaintiff at a rate of $300.00/hour. Deny knowledge or information sufficient to

form a belief as to the remainder of the allegations.



48. Admit the allegations in paragraph “48” of the Complaint to the extent that the re were

eight (8) negotiation sessions, none of which lasted longer than five (5) hours. Deny the

remainder of the allegations in paragraph “48” to the extent that it is inferred plaintiff was

entitled to compensation from defendant for the legal work performed. Deny knowledge and

information sufficient to form a belief as to the amount of hours plaintiff alleges to have

expended on the matter.

49. Admit the allegations in paragraph “49” of the Complaint to the extent that plaintiff had

a monthly retainer payment increased from $3,000.00/month to $3,500.00/month. Deny the

characterization of these payments as “installment payments.”

AS TO PLAINTIFF’S THIRD CAUSE OF ACTION

50. In response to paragraph “50” of the C omplaint Defendants repeat and reallege each and






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54. Deny knowledge or information to form a belief as to the allegations in paragraph “54”

of the Complaint without more specificity as to a date and location.

55. Admit the allegations in paragraph “55” of the Complaint to the extent that plaintiff

represented LEEBA at several contract negotiations for Brink’s guards while being paid

according to his monthly retainer. Otherwise, deny knowledge or information to form a belief as

to the allegations in paragraph “55” of the Complaint without more specificity as to dates and

locations.


paragraph “56” of the Complaint regarding time ex pended. Deny the inference that plaintiff was

entitled to a $300.00/hour fee or that there was an agreement to said fee.

57. Deny the allegations in paragraph “57” of the Complaint that defendants continued to

pay plaintiff $3,500.00/month payment as an installment payment. Admit that plaintiff

continued to receive a $3,500.00/month retainer fee.

AS TO PLAINTIFF’S FOURTH CAUSE OF ACTION

58. In response to paragraph “58” of the Complaint Defendant s repeat and reallege each and





62. Admit the allegations in paragraph “62” of the C omplaint.



64. Admit the allegations in paragraph “64” of the Complaint except deny knowledge or

information sufficient to form a belief as to the allegations that Proskauer & Rose, LLC never

lost an impasse proceeding for the City of New York.


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AS TO PLAINTIFF’S FIFTH CAUSE OF ACTION

68. In response to paragraph “68” of the C omplaint Defendants repeat and reallege each and



paragraph “69” of the Complaint since it call s for a legal conclusion.






paragraph “74” of the Complaint relating to the number of hours of legal time plai ntiff expended.

Deny that $46,200.00 is owed to plaintiff for the legal work and deny that the monthly $3,500.00

payment was an installment payment to plaintiff.

AS TO PLAINTIFF’S SIXTH CAUSE OF ACTION

75. In response to paragraph “75” of the C omplaint Defendants repeat and reallege each

and every response to all prior paragraphs of the Complaint.


77. Admit the allegations in paragraph “77” of the Complaint to the extent that OCB

accepted the petition filed by LEEBA but held a decision in abeyance. Deny that defendants

instructed plaintiff to file an Article 78 petition.


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against a “well staffed NYC legal department.” Deny knowledge or information sufficient to

form a belief as to the number of hours plaintiff allegedly expended on the matter.


paragraph “92” [ sic “88”] of the Complaint.

93. Deny the allegations in paragraph “93” [ sic “89”] of the Complaint to the extent that

Kenneth N. Wynder instructed plaintiff to represent Joseph Andreani. Deny knowledge or

information sufficient to form a belief as to the remaining allegations.


paragraph 94 [ sic “90”] of the Complaint as to plaintiff’s standard charge. Deny that there is any

amount owed to plaintiff for legal work performed for Joseph Andreani. Admit that plaintiff was

paid $3,500.00/month retainer but deny characterization of the payment as an installment

payment.

AS AND FOR PLAINTIFF’S EIGHTH CAUSE OF ACTION

95. In response to paragraph “95” [ sic “91”] of the C omplaint Defendants repeat and

reallege each and every response to all prior paragraphs of the Complaint.

96. Deny the allegations in par agraph “96” [ sic “92”] of the Complaint to the extent that

LEEBA declined to pay. Admit that the impasse arbitrator Viani submitted a bill for $24,000.00.

97. Admit the allegations in paragraph “97” [ sic “93”] of the Complaint to the extent that

Viani commenced a lawsuit against LEEBA and that Kenneth N. Wynder in his capacity as

president of LEEBA instructed plaintiff, as LEEBA counsel, to respond to the lawsuit.

98. Admit the allegations in paragraph “98” [ sic “94”] of the Complaint.

99. Admit the allegatio ns in paragraph “99” [ sic “95”] of the Complaint to the extent that

plaintiff obtained a settlement in the amount of $18,000.00 and that Kenneth N. Wynder signed a

stipulation of settlement in his capacity as president of LEEBA. Deny the remainder of the

allegations.


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AS AND FOR PLAINTIFF’S NINTH CAUSE OF ACTION

100. In response to paragraph “100” [ sic “96”] of the Compl aint Defendants repeat and



paragraph “101” [sic “97”] of the Complaint.

102. Deny the allegations in paragraph 102 [ sic “98”] of the Complaint to the extent that

Kenneth N. Wynder instructed plaintiff to prepare answers to petitions. Deny knowledge or

information sufficient to form a belief as to the allegations in the remainder of the paragraph.


paragraph 103 [sic “99”] of the Complaint as to the amount of legal time plaintiff expended.

Deny that plaintiff was owed $3,500.00 in legal fees but admit that in June 2014 plaintiff’s

services as counsel to LEEBA was terminated.

104. Deny the allegations in paragraph 104 [ sic “100”] of the Complaint to the extent that

it characterizes the monthly $3,500.00 paid to plaintiff as an installment payment. Deny that the

retainer payment of $3,500.00 was made up to May 2014. Admit that plaintiff was paid a

monthly retainer of $3,500.00/month up to and including the month of June 2014.

AS AND FOR PLAINTIFF’S TENTH CAUSE OF ACTION



106. Admit the allegations contained in paragraph “106” [ sic “102”] of the Complaint.

107. Deny knowledge or information sufficient to form a belief as to the allegations

contain ed in paragraph “107” [ sic “103”] of the Complaint.




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110. Admi t the allegations contained in paragraph “110” [ sic “106”] of the Complaint

only to the extent that plaintiff submitted a brief.


112. Admit the allegations co ntained in paragraph “112” [ sic “108”] of the Complaint.


contained in paragraph “113” [ sic “109”] of the Complaint.

114. Deny the allegations contained in paragraph “114” [ sic “110”] of the Complaint.

AS AND FOR PLAINTIFF’S ELEVENTH CAUSE OF ACTION

115. I n response to paragraph “115” [ sic “111”] of the C omplaint Defendants repeat and



contained in paragraph “116” [ sic “112”] of the Complaint as to the date of a conversation with

plaintiff by Kenneth Wynder.

117. Deny the allegati ons contained in paragraph “117” [ sic “113”] of the Complaint.












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contained in paragraph “126” [ sic “122”] of th e Complaint.





130. Deny the allegations contained in paragraph “130” [ sic “129”] of the Complaint. 2

AS AND FOR PLAINTIFF’S TWELFTH CAUSE OF ACTION

131. In response to p aragraph “131” [ sic “130”] of the C omplaint Defendants repeat and



133. Deny the al legations contained in paragraph “133” [ sic “132”] of the Complaint.




contained in the first sentence of paragraph “135” [ sic “134”] of the Complaint. Deny the

allegations contained in the second sentence of the paragraph.

2 The paragraph numbers on the Verified Complaint sequentially change from “125” on page 26 to “129” on page 27 but are correctly reflect above, respectively, as “129” and “130” in their proper sequential order.


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Deny that defendants had plaintiff undertake any work in relation to this alleged representation

petition.

145. Deny the allegations contained in paragraph “145” [ sic “146”] of the Complaint in

that there is a general denial that any money is owed to plaintiff and a specific denial that

plaintiff undertook any alleged work regarding this allegation.

AS AND FOR PLAINTIFF’S FIFTEENTH CAUSE OF ACTION

146. In response to paragraph “146” [ sic “147”] of the Complaint Defendan ts repeat and


147. Deny the allegations in paragraph “147” [ sic “148”] of the Complaint to the extent

that plaintiff is owed money or that his fee remains unpaid. Deny knowledge or information to

form a belief as to the allegations that plaintiff represented two officers without more specificity

as to a date and location. Deny knowledge or information sufficient to form a belief as to the

allegations of time expended in the matter(s).

AS AND FOR PLAINTIFF’S SIXTEENTH CAUSE OF ACTION



149. Deny the allegations contained in p aragraph “149” [ sic “150”] of the Complaint.

AS AND FOR A FIRST AFFIRMATIVE DEFENSE

150. Plaintiff’s Causes of a ction against defendants are barred by the relevant Statutes of

Limitations.

AS AND FOR A SECOND AFFIRMATIVE DEFENSE

151. The Complaint fails to state a claim against defendants upon which relief can be

granted.


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AS AND FOR A THIRD AFFIRMATIVE DEFENSE

152. Any damages that the plaintiff alleges he sustained were caused in whole or in part

by his own culpable conduct.

AS AND FOR A FOURTH AFFIRMATIVE DEFENSE

153. Plaintiff’s claim s are barred by the Statute of Frauds.

AS AND FOR A FIFTH AFFIRMATIVE DEFENSE

154. Plaintiff’s claim has been settled by an accord and satisfaction.

AS AND FOR A SIXTH AFFIRMATIVE DEFENSE

155. Plaintiff has committed acts of professional malpractice which preclude his recovery

against defendants.

AS AND FOR A SEVENTH AFFIRMATIVE DEFENSE

156. Plaintiff was paid in full for his legal services from 2005-2007 pursuant to a

$3,000.00/month retainer ($36,000.00/year), which was subsequently increased to a

$3,500.00/month retainer fee ($42,000.00/year) until June 2014.

AS AND FOR AN EIGHTH AFFIRMATIVE DEFENSE

157. Plaintiff’s claim improperly at tempts to collect damages based on contractual

relationships with other persons upon which plaintiff failed to or was unable to collect payment.

AS AND FOR A NINTH AFFIRMATIVE DEFENSE

158. Plaintiff violated the requirements of 22 NYCRR Part 1215 mandating a letter of

engagement for any representation wherein the fee is over $3,000.00. As a result plaintiff is in

violation of the Code of Professional Responsibility and Rules of Professional Conduct which

adversely reflect upon his fitness as a lawyer.


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AS AND FOR A TENTH AFFIRMATIVE DEFENSE

159. Plaintiff’s alleged time expended on the various legal matters contained in the

Verified Complaint was excessive and outside the standards of practice within the legal

community.

AS AND FOR A COUNTERCLAIM BY DEFENDANT

LAW ENFORCEMENT EMPLOYEES BENEVOLENT ASSOCIATION

160. This counterclaim is an allegation of professional malpractice against Richard Jacob

Merritt--an attorney admitted to practice in the State of New York since 1982, attorney

registration number 1758648--based on his representation of defendant-plaintiff Law

Enforcement Employees Benevolent Association (hereinafter “LEEBA”).

161. That at the times herein mentioned, Law Enforcement Employees Benevolent

Association was a domestic not-for-profit corporation organized under the laws of the State of

New York with offices at 277 Main Street, Catskill, New York 12414.

162. That plaintiff-defendant Richard Merritt, upon information and belief, resides in

Florida and maintains a business address at 2 Birs Avenue, Lindenhurst, New York 11757,

within the County of Suffolk.

163. This Court has personal jurisdiction over plaintiff-defendant based on his presence

in the state as an attorney practicing in Suffolk County.

164. This Court has subject matter jurisdiction over this action by virtue of 22 NYCRR

1200 and other relevant laws of the State of New York.

165. Richard Merritt was retained by LEEBA in October 2005 to provide legal

representation to the organization on a monthly retainer basis of $3,000.00. This amount was

increased, at the request of Merritt, to $3,500.00/month beginning in February 2007. Since

February 2007 LEEBA paid to Merritt $42,000.00/year for his legal services when needed.


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166. As part of his monthly retainer agreement Merritt was paid each month whether or

not he performed work for LEEBA.

167. On or about February 21, 2014 a lawsuit against LEEBA was filed in Suffolk County

Supreme Court by Al Viani for $24,000.00 in fees allegedly owed to him as a result of impasse

arbitration in the City of New York. LEEBA disputed the amount of fees owed and instructed

Merritt to respond to the lawsuit.

168. As part of his legal duties for the $3,500.00/month retainer Merritt represented

LEEBA in the lawsuit filed in Suffolk County Supreme Court as Alan Viani v. Law Enforcement

Employees Benevolent Association, Inc., Index No. 013271/2014.

169. On March 17, 2014 during a hearing at the Brooklyn offices of the New York State

Public Employee Relations Board (hereinafter “PERB”) Merritt represented LEEBA in its bid to

represent peace offi cers employed by the City University of New York (hereinafter “CUNY”).

170. During the course of the hearing at PERB Merritt disagreed with LEEBA board

member Peter Luck’s decision to withdraw the pending petition and re -file at a later date to

include other CUNY peace officer titles in the petition.

171. Merritt refused to follow the wishes of his client LEEBA and walked out of PERB

on LEEBA after Luck asked that the petition be withdrawn.

172. On or about April 17, 2014 the case of Alan Viani v. Law Enforcement Employees

Benevolent Association, Inc. was settled for $18,000.00. A stipulation of settlement was entered

into and LEEBA began to make payments to Viani pursuant to the stipulation agreement.

173. LEEBA made all payments to Viani under the stipulation of settlement including

what was believed to be a last payment on August 12, 2014. However, LEEBA still owed a final

$3,000.00 on the settlement amount.


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174. On July 7, 2014 Merritt represented LEEBA at a contract negotiation session at the

City of New York Office of Labor Relations (hereinafter “OLR”). The contract negotiations

were for Department of Environmental Protection (hereinafter “DEP”) police officers.

175. During a break in the negotiation session a meeting was held among the LEEBA

board members and delegates to decide the next step in negotiations. A vote was taken to re-

schedule another negotiation session and return with a formal proposal for OLR.

176. Merritt was vocal in his disagreement with the vote taken and proceeded to become

agitated and berate union president Kenneth N. Wynder and other members assembled by

alleging they did not know what they were doing and had made a mistake months earlier when

they signed a Memorandum of Agreement (MOA) to resolve part of the contract dispute.

176. Merritt proceeded to gather his belongings and walk out of the room after telling

those assembled in the room that they were on their own.

177. LEEBA was still in the middle of its negotiation session and had to return to the

negotiation table after the break with Merritt visibly absent.

178. On July 21, 2014 a vote of the LEEBA board of directors was taken in which it was

decided to end the use of the legal services of Merritt. His retainer payments were ended as of

July 2014 and a letter was sent to him advising of LEEBA’s decision to end its relationship with

him.

179. On September 19, 2014 a facsimile letter was sent to Merritt by Robert Goldhaber,

Esq., of Rosenthal & Goldhaber, PC, (hereinafter “Goldhaber”) attorney for Al Viani, advising

that LEEBA was in default of its obligation to pay under the terms of the stipulation of

settlement. The letter further provided an opportunity to cure the default within five (5) days,

otherwise legal action would be commenced against LEEBA.


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180. Merritt never responded to the Goldhaber letter nor did he notify LEEBA of its

receipt.

AS AND FOR A FIRST CAUSE OF ACTION IN THE COUNTERCLAIM

181. LEEBA repeats and realleges each and every allegation contained in paragraphs

160-180 as if fully set forth herein.

182. As a result of LEEBA not being aware of the default notice Goldhaber filed a

restraining notice for garnishment with LEEBA’s banker, First Niagara Bank in Catskill, New

York, to enforce the stipulation of settlement. Pursuant to the garnishment notice and the terms

of the stipulation of settlement LEEBA had to pay in excess of $2,000.00 for legal costs and the

balance of the full amount requested under the originally filed lawsuit in addition to the

remaining $3,000.00 payment. The new balance owed was $11,806.38 which resulted from

Merritt’s failure to respond to Goldhaber or to no tify LEEBA.

183. As a result of the restraining notice file with First Niagara Bank LEEBA’s account

was on hold and all checks written were returned as non-payable. This resulted in over

$7,000.00 of checks covering LEEBA members’ health benefi ts being returned and LEEBA

incurring bank penalties.

184. LEEBA was unable to access its account for three (3) days until the lien was released

after negotiations with Goldhaber and the establishment of a new payment schedule for the

$11,806.38.

185. Merritt failed to adhere to the Code of Professional Responsibility as it relates to

attorney competence (Rules 1.1(a), 1.1(c)(1)(2), 1.1(e), 1.3(a)(b)(c), 1.4(a)(1)(iii), 1.4(a)(3),

1.16(e)) and thereby prejudiced the rights of his former client LEEBA.

186. As a result of Merritt’s professional misconduct LEEBA has been damaged in the

amount of $8,806.38, additional bank fees and associated costs.


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WHEREFORE, defendant respectfully requests that this Court grant judgment providing

the following relief:

(a) Dismissing the Summons and Verified Complaint in its entirety, and each and

every Cause of Action set forth therein;

(b) The costs and disbursements of this action;

(c) Judgment on the Counter-claim in the amount of $8,806.38 plus additional

expenses for associated costs and legal fees;

(d) Punitive damages as this Court as to the Court seems just and proper;

(e) Together with such other relief as to the Court seems just and proper.

Dated: Poughkeepsie, New YorkDecember 1, 2014

_____________________________Joseph F. BuonoAttorney for Defendants Kenneth N. Wynder,sued as president of LEEBA, and LawEnforcement Employees Benevolent Assoc.M aili ng Address:Post Office Box 709Poughkeepsie, NY 12602Office Addresses:55 Market StreetPoughkeepsie, NY 12601Tel. No. (914) 200-4365E-Mail [email protected]


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VERIFICATION

STATE OF NEW YORK } } ss.:COUNTY OF DUTCHESS }

KENNETH N. WYNDER, being duly sworn, deposes and says:

I am a defendant in the within action; I have read and know the contents of the foregoingVerified Answer with Affirmative Defenses; and the same is true to my knowledge, except as tothe matters therein stated to be alleged on information and belief; and as to those matters, I

believe it to be true.

________________________KENNETH N. WYNDER

Sworn to before me this ____ day of December 2014.

__________________________ Notary Public


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leeba merritt lawsuit answer

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