1. IN THE FIRST CIRCUIT COURT FOR SENECA COUNTY, NEW YORK
SANDRA VENSA JANDRESKI, )
)
Complainant, )
)
vs. ) No. 93-D-2665
)
ROLFE ERNEST JANDRESKI, )
)
Defendant. )
ANSWER TO COMPLAINT AND COUNTERCLAIM FOR ABSOLUTE DIVORCE
ANSWER TO COMPLAINT
COMES NOW the Defendant-Husband, Rolfe Ernest Jandreski, and in answer to the
Complaint for Absolute Divorce filed against him states as follows:
1. Defendant admits all of the statistical data in paragraph 1 of the Complaint for Absolute
Divorce but would specifically deny that he has been guilty of any of the three grounds for
divorce listed at the end of paragraph 1.
2. Defendant specifically denies each and every allegation in paragraph 2 and demands specific
proof thereof.
3. Defendant admits that there have arisen certain irreconcilable differences between the parties
as stated in paragraph 3.
4. Defendant denies that he has been guilty of the grounds for divorce set out in paragraph 4
and demands strictest proof thereof.
5. Defendant denies that he has been guilty of the grounds for divorce set out in paragraph 5
and demands strictest proof thereof.

2. 6. Defendant denies that he has been guilty of the grounds for divorce set out in paragraph 6
and demands strictest proof thereof and would specifically deny that a show cause hearing
should be set in this matter.
7. Defendant denies that the Complainant should be awarded those items set out in the Prayer of
her Complaint and would show that he should be awarded a divorce and those items set out
herein in the Counterclaim.
8. The Defendant having answered the Complaint for Absolute Divorce filed against him
specifically denies each and every other allegation in the Complaint and demands strictest
proof thereof.
WHEREFORE, the Defendant-Husband, Rolfe Ernest Jandreski, would pray that the
Complaint for an Absolute Divorce filed against him be dismissed and that the costs be adjudged
against the Complainant.
COUNTERCLAIM FOR ABSOLUTE DIVORCE
COMES NOW the Defendant and assumes the role of a Countercomplainant and states as
follows:
I.
Your Countercomplainant would charge that the Counterdefendant, Sandra Vensa
Jandreski, has been guilty of cruel and inhuman treatment or conduct toward the
Countercomplainant as to render further cohabitation unsafe and/or improper.
II.
Countercomplainant would further show that the parties have experienced such
irreconcilable differences as to allow the Countercomplainant to obtain an Absolute Divorce.

3. III.
Countercomplainant would show that he is the fit and proper person to have the custody
and care of the parties’ two minor children.
PREMISES CONSIDERED, THE COUNTERCOMPLAINANT PRAYS:
1. That service of process be issued on the Counterdefendant by sending a copy of this Answer
and Counterclaim to her attorney, Evelyn A. Lefkovitz, 101 North 3rd Street, Seneca Falls,
New York 10020 requiring the Counterdefendant to answer but her oath is hereby expressly
waived.
2. That upon the hearing of this cause, the Countercomplainant, Rolfe Ernest Jandreski, be
awarded an Absolute Divorce with all the rights and privileges of an unmarried person
restored.
3. That in lieu of a written Marital Dissolution Agreement between the parties, the Court,
considering the entire record and the best interest of the parties hereto determine a fair and
equitable distribution of the parties’ marital property.
4. That the Countercomplainant be awarded the custody of the parties’ two minor children and
that the Counterdefendant be required to pay a reasonable amount of child support.
5. Such other and further relief as the Court deems proper.
Carlton A. Levy (No. 45633)
Attorney for Countercomplainant
231 North 8th Street
Seneca Falls, NY 10020
(315) 555-4321

4. STATE OF NEW YORK)
COUNTY OF SENECA )
COMES the Countercomplainant, Rolfe Ernest Jandreski, and makes oath that the
foregoing statements in the Counterclaim are true to the best of his knowledge, information, and
belief that his counterclaim is not made out of levity nor in collusion with the Counterdefendant
but in sincerity and truth and for the causes mentioned therein. Further, that owing to his poverty,
he is unable to bear the expense of this suit but he is justly entitled to the redress sought to the
best of his knowledge, information, and belief.
Rolf Ernest Jandreski
CERTIFICATE
I, Carlton A. Levy, attorney for Defendant-Husband, hereby certify that I have mailed a
copy of this Answer to Complaint and Counterclaim for Absolute Divorce to Evelyn A.
Lefkovitz, attorney for the Complainant-Wife, 101 North 3rd Street, Seneca Falls, NY 10020 on
the ________ day of May, 2016.
Carlton A. Levy
Sworn to and subscribed before me
this the _____ day of May, 2016.
Notary Public
My commission expires:
_________________________________