ANSWER SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK. Index. VINCENT FORRAS. on behalf of himself and all others #111970/2010

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1 similarly situated, of and in the City of New York. County of New York. VINCENT FORRAS. on behalf of himself and all others #111970/2010 Index Page 1 properly described as defendants. defendants deny that any of the referenced persons and entities are 4. Denies paragraph 5 of Plaintiffs complaint insofar as answering 12, 13, 16, 18, 19, 20, 21, 39, 40, 44, 45, and 47 of Plaintiffs complaint. each and every allegation in paragraphs 6, the second paragraph 9, Denies sufficient knowledge or information so as to form a belief as to complaint. 37, 41, 42, 43, 46, 48, 50, 51, 52, 53, 54, 55, and 56 of Plaintiffs paragraph 9. 10, , 22, , 25, 26, , 31, 32, 34, 35, 36, 2. Denies each and every allegation in paragraphs 2, 3, 4, 8, the first representative. 1. Generally denies that there is a class for which Plaintiff is a proper Plaintiffs complaint, respectfully avers: Defendants, by their attorneys, Adam Leitman Bailey, P.C., answering Defendants. all other aliases known and unknown, 51. CORDOBA INITIATIVE. SOHO PROPERTIES, and FEISAL ABDUL RAUF, and CORDOBA HOUSE/PARK ANSWER -against VERIFIED Plain tiff SUPREME COURT OF THE STATE OF NEW YORK

2 defendants to be able to frame a response. complaint as the matters set forth in that paragraph are too vague to Page 2 $50,000 for the wholly frivolous actions of the Plaintiff herein. 10.By reason of the foregoing, Defendants are entitled to an award of damages shall continue to accrue in a sum not less than $50, Defendants are damaged by the advancement of such claims and such an extension, modification, or reversal of existing law. knowledge that they cannot be supported by good faith argument for advance a claim that is unwarranted under existing law, with 8. The purported causes of action by the Plaintiff in this suit knowingly AS AND FOR A COUNTERCLAIM upon it being a religious institutional building. erection or maintenance of a religious institutional building predicated jurisdiction to grant any relief, whether in law or equity, against the every court in the United States of America lacks the subject matter of the United States of America and 42 U.S.C this court and 7. Pursuant to the First and Fourteenth Amendments of the Constitution AS AND FOR AN AFFIRMATIVE DEFENSE complaint. every allegation of paragraphs 27, and 49 of Plaintiffs 6. Denies and admits as hereinbefore denied and admitted each and 5. Neither denies nor admits the allegations of paragraph 7 of Plaintiffs

3 counterclaim in the sum of $50, together with interest and costs. together with interests and costs and an award of sanctions on the Page 3 (310) Washington. DC Suite Pennsylvania Avenue, N.W. Freedom Watch. Inc. Larry Kiayrnan. Esq. General Counsel Attorney for PIaintiJi pm hac vice (no telephone number designated) I ew York, \y Church Street, Suite 1 ply se Vincent Forras TO: New York, New York Broadway, 17th Floor Adam LeitthanBailey by October (3, 2010 Dated: New York, New York Adam Leitman Bailey, P.C. Yours, etc., WHEREFORE, Defendants demand judgment dismissing the complaint

4 STATE OF NEW YORK Page 1 Verification CommLssion Expires 06/03/2013 OuaIiled in Nassau County No. 01 PE Notary Public, State of New ftdc DIWAPERSHAD A m 1 Jf day of October, 2010 Sworn to before me this SHARI/ EL-GAMAL / /7 Dated: October 6, 2010 he has read the foregoing Answer that he knows the contents thereoc and President of SOHO PROPERTIES, a Defendant in the foregoing Answer; that that, to his knowledge, the Answer is true, except as to matters stated therein to be alleged upon information and belief, and, as to those matters, he SHARIF EL-GAMAL, being duly sworn, deposes and says, that he is believes it to be true. VERIFICATION

5 / similarly situated, Defendants. ANSWER Plaintiff of and in the City of New York, County of New York, Index ADAM LEITMAN BAILEY, P.C. Office and Post Office Address New York, New York (212) Broadway,17t Floor Print Signer s Name: Adam Leitman Bailey Dated: October 6, 2010 Signature: 4* / reasonable inquiry, the contentions contained in the annexed docu9ent are notfrivolous. all other aliases known and unknown, 51, CORDOBA INITIATIVE, SOHO PROPERTIES, and FEISAL ABDUL RAUF, and CORDOBA HOUSE/PARK SUPREME COURT OF THE STATE OF NEW YORK in the courts of New York State, certifies that, upon information and belief and Pursuant to 22 NYCRR ], the undersigned an attorney admitted to practice -against- VERIFIED VINCENT FORRAS, on behalf of himself and all others #111970/2010