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-1- SUPREME COURT OF THE STATE OF NEW YORK
COUNTY
 OF
NEW YORK
SHAHISTA LALANI, individually and on behalf of other persons similarly situated, Plaintiffs, -against- DUALSTAR ENTERTAINMENT GROUP LLC; or any other related entities, Defendant. Index No.: 158205/2015
DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S AMENDED CLASS ACTION COMPLAINT
Defendant Dualstar Entertainment Group LLC (“Dualstar”), by and through its undersigned attorneys, Sheppard, Mullin, Richter & Hampton LLP, hereby answers the Amended Class Action Complaint, filed August 12, 2015 (the “Amended Class Action Complaint”), by plaintiff Shahista Lalani (“Named Plaintiff”), herein as follows: 1.
 
Dualstar denies each and every allegation set forth in paragraph 1 of the Amended Class Action Complaint and avers that Named Plaintiff purports to bring this action pursuant to the New York Labor Law Article 19 §§ 650
et seq.
, the New York Labor Law Article 6 §§ 190
et seq.
(collectively, the “NYLL”) and 12 New York Codes, Rules and Regulations (“NYCRR”). 2.
 
Dualstar denies each and every allegation set forth in paragraph 2 of the Amended Class Action Complaint. 3.
 
Dualstar denies each and every allegation set forth in paragraph 3 of the Amended Class Action Complaint. 4.
 
The statements set forth in paragraph 4 of the Amended Class Action Complaint constitute a summary of Named Plaintiff’s claims in this action and do not require an answer. However, to the extent a response is required, Dualstar denies each and every allegation set forth in paragraph 4 of the Amended Class Action Complaint.
FILED: NEW YORK COUNTY CLERK 09/14/2015 04:53 PM 
INDEX NO. 158205/2015NYSCEF DOC. NO. 7RECEIVED NYSCEF: 09/14/2015
 
 
-2-
THE PARTIES
5.
 
Dualstar lacks sufficient knowledge or information to form a belief as to the truth of the allegations set forth in paragraph 5 of the Amended Class Action Complaint. 6.
 
Dualstar denies each and every allegation set forth in paragraph 6 of the Amended Class Action Complaint and avers that Named Plaintiff interned at an entity other than Dualstar for limited parts of May, June and July 2012. 7.
 
Dualstar admits the allegations set forth in paragraph 7 of the Amended Class Action Complaint.
CLASS ALLEGATIONS
 8.
 
Dualstar avers that the allegations set forth in paragraph 8 of the Amended Class Action Complaint state a legal conclusion to which no response is required. Notwithstanding the foregoing, to the extent that paragraph 8 of the Amended Class Action Complaint contains factual allegations, Dualstar denies each and every allegation. 9.
 
Dualstar denies each and every allegation set forth in paragraph 9 of the Amended Class Action Complaint and avers that Named Plaintiff purports to bring this action on behalf of herself and other individuals. 10.
 
Dualstar denies each and every allegation set forth in paragraph 10 of the Amended Class Action Complaint. 11.
 
Dualstar denies each and every allegation set forth in paragraph 11 of the Amended Class Action Complaint. 12.
 
Dualstar avers that the allegations set forth in paragraph 12 of the Amended Class Action Complaint state a legal conclusion to which no response is required. Notwithstanding the
 
 
-3- foregoing, to the extent that paragraph 12 of the Amended Class Action Complaint contains factual allegations, Dualstar denies each and every allegation. 13.
 
Dualstar avers that the allegations set forth in paragraph 13 of the Amended Class Action Complaint state a legal conclusion to which no response is required. Notwithstanding the foregoing, to the extent that paragraph 13 of the Amended Class Action Complaint contains factual allegations, Dualstar denies each and every allegation. 14.
 
Dualstar avers that the allegations set forth in paragraph 14 of the Amended Class Action Complaint state a legal conclusion to which no response is required. Notwithstanding the foregoing, to the extent that paragraph 14 of the Amended Class Action Complaint contains factual allegations, Dualstar denies each and every allegation. 15.
 
Dualstar denies each and every allegation set forth in paragraph 15 of the Amended Class Action Complaint with respect to Named Plaintiff and avers that it lacks sufficient knowledge or information to form a belief as to the truth of the allegations set forth in paragraph 15 of the Amended Class Action Complaint with respect to Named Plaintiff’s counsel, and on that basis denies them. 16.
 
Dualstar lacks sufficient knowledge or information to form a belief as to the truth of the allegations set forth in paragraph 16 of the Amended Class Action Complaint, and on that basis denies them. 17.
 
Dualstar avers that the allegations set forth in paragraph 17 of the Amended Class Action Complaint state a legal conclusion to which no response is required. Notwithstanding the foregoing, to the extent that paragraph 17 of the Amended Class Action Complaint contains factual allegations, Dualstar denies each and every allegation.

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