FILED

DATE: January 23, 2024

TIME:9:16: 44 AM
MECKLENBURG COUNTY
CLERK OF SUPERIOR COURT
STATE OF NORTH CAROIANG. Potts IN THE GENERAL COURT OF JUSTICE
COUNTY OF MECKLENBURG DISTRICT COURT DIVISION-SMALL CLAIMS
CIVIL ACTION NO.: 24 CVS 110 590

SINK LAW PLLC, Wooolld-570

Plaintiff,

ANSWER AND COUNTERCLAIMS

VOGEL LAW FIRM PLLC and
JONATHAN VOGEL,

Defendants.

NOW COME Defendants VOGEL LAW FIRM PLLC and JJONATHAN VOGEL,

through the undersigned counsel, who submit this ANSWER AND COUNTERCLAIMS and

state as follows:

ANSWER

1. This is a very straightforward and basic breach of contract matter in which Defendant

knows that he (it) breached and is in the wrong.

RESPONSE: Defendants deny this allegation.

2. Sink Law PLLC (Plaintiff) and Vogel Law Firm PLLC (Defendant) have a valid and

binding written contract that Defendant breached on or around December 28, 2022 when

Defendant willfully withheld monies due to Plaintiff- monies that Plaintiff was and continues to

be owedin its entirety.

RESPONSE: Defendants deny this allegation.

3. In short, and per the contract between the Parties, Plaintiffand Defendant split the

monthly income from their shared client New Hanover County Board of Education 50/50 (see

enclosed contract) on a monthly basis.

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 RESPONSE: Defendants deny this allegation.

4, For services rendered throughout the month of October 2023, Plaintiff was owed 50% of

the entire invoice.

RESPONSE: Defendants deny this allegation.

5. The simple math is as follows: the entire invoice from Vogel Law Firm PLLC to the New

Hanover County Board of Education was $27,558.50. Half of said figure is $13,779.25.

Defendant paid Plaintiff only$6,000 -

Defendant thereby breached the contract by withholding

$7,779.25 from and still due Plaintiff.

RESPONSE: Defendants deny this allegation..

6. Jonathan Andrew Vogel is the sole member of the Vogel Law Firm PLLC and is acting

willfully, unilaterally, and deceitfully in his individual capacity,, which is why Plaintiff lists him

as a party in his individual capacity as well -

Defendant's actions serve as the basis by which

Defendant's corporate veil has been pierced.

RESPONSE: Defendants deny this allegation.

7. I demand to recover the total amount listed above, plus interest and reimbursement for
court costs.

RESPONSE: Defendants deny that Plaintiff is entitled to recover any amount of money

or to obtain any other relief.

AFFIRMATIVE DEFENSES
LACK OF PRIVITY
1. There is no written contract between Plaintiff "Sink Law PLLC" and Defendants

Vogel Law Firm PLLC and/or Jonathan Vogel.

LACK OF ALTER EGO

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 1. Vogel Law Firm PLLC respects its corporate formalities and Jonathan Vogel is

otherwise not the alter ego of Vogel Law Firm PLLC.

FRAUD
1. On December 2, 2021, Vogel Law Firm PLLC was fraudulently induced by Leigha

Sink, an organizer/member of Plaintiff, into entering into a written contract with an entity called

"Sink Law Firm PLLC" that she knew at the time did not exist, that does not exist today, and that

never existed at all.

2. Vogel Law Firm PLLC relied upon Ms. Sink's false representation that "Sink Law

Firm PLLC" was a legal entity, and Vogel Law Firm PLLC signed the contract with "Sink Law

Firm PLLC" in reliance upon that false representation.

PAROL EVIDENCE RULE

1. Under the Parol Evidence Rule, the terms of the written contract dated December 2, 2021

between Vogel Law Firm PLLC and "Sink Law Firm PLLC" take priority over any and all

unwritten and unsigned statements that contradict or fall outside the terms of that written

contract.

UNCLEAN HANDS (BREACH OF CONTRACT)

1. Plaintiff "Sink Law PLLC" or "Sink Law Firm PLLC" breached its contract with Vogel

Law Firm PLLC.

2. Paragraph 1 of the contract dated December 2, 2021 between Vogel Law Firm PLLC and

"Sink Law Firm PLLC" -

called "Firm" and "Contract Attorney Provider," respectively, in the

agreement
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provides the following: "Contract Attorney Provider agrees to provide attorneys to

provide legal research, writing and litigation support services to the Firm and its clients, on an at-

will basis, at the request of the Firm and subject to Contract Attorney Provider's availability."

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(Emphasis added).

3. Paragraph 3 provides the following, in relevant part: "The relationship between the Firm

and Contract Attorney Provider is an independent contractor relationship." (Emphasis added).

4, Paragraph 4 provides the following, in relevant part: "Contract Attorney Provider

acknowledges that trust and confidence are important components of any relationship and agrees

to comply with the Firm's policies and procedures for handling and protecting the confidential

information of the Firm's clients. Attorneys of Contract Attorney Provider shall not... use any

confidential information of the Firm's clients for its own benefit or £gain, or for anyy use that is or

becomes adverse to the interests of the Firm, without the Firm's prior written consent."

(Emphasis added).

5. Beginning on or about October 1, 2023, Plaintiff "Sink Law PLLC" and "Sink Law Firm

PLLC" (hereinafter collectively referred to as "Sink") admittedly had multiple, unauthorized

communications and meetings with members of the New Hanover County Board of Education

and New Hanover County Schools staff and admittedly performed unauthorized work for the

school board and school district staff, all in material violation of Paragraph 1 of the contract.

6. Beginning on or about October 1, 2023, Sink used confidential information about New

Hanover County Board of Education, New Hanover County Schools, and Vogel Law Firm

PLLC's representation of the school board and school district for its own benefit or gain and/or

for use that is adverse to the interests of Vogel Law Firm PLLC, in material violation of

Paragraph 4 of the contract. Sink disparaged Vogel Law Firm PLLC and actively attempted to

wrest representation of the New Hanover County Board of Education from Vogel Law Firm

PLLC to Sink, all while Sink was under contract with, and remains under contract with, Vogel

Law Firm PLLC and/or to lay the groundwork to do so, which constitutes a material breach of

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contract of Paragraph 4 of the contract.

BREACH OF IMPLIED WARRANTY OF GOOD FAITH AND FAIR DEALING

1. Plaintiff "Sink Law PLLC" or "Sink Law Firm PLLC" breached its implied warranty of

good faith and fair dealing with Vogel Law Firm PLLC.

2. Paragraph 1 of the contract dated December 2, 2021 between Vogel Law Firm PLLC and

"Sink Law Firm PLLC" -

called "Firm" and "Contract Attorney Provider," respectively, in the

agreement
-

provides the following: "Contract Attorney Provider agrees to provide attorneys to

provide legal research, writing and litigation support services to the Firm and its clients, on an at-

will basis, at the request of the Firm and subject to Contract Attorney Provider's availability."

(Emphasis added).

3. Paragraph 3 provides the following, in relevant part: "The relationship between the Firm

and Contract Attorney Provider is an independent contractor relationship." (Emphasis added).

4. Paragraph 4 provides the following, in relevant part: "Contract Attorney Provider

acknowledges that trust and confidence are important components of any relationship and agrees

to comply with the Firm's policies and procedures for handling and protecting the confidential

information of the Firm's clients. Attorneys of Contract Attorney Provider shall not... use any

confidential information of the Firm's clients for its own benefit or ggain, or for any use that is or

becomes adverse to the interests of the Firm, without the Firm's prior written consent."

(Emphasis added).

5. Beginning on or about October 1, 2023, Plaintiff "Sink Law PLLC" and "Sink Law Firm

PLLC" (hereinafter collectively referred to as "Sink") admittedly had multiple, unauthorized

communications and meetings with members of the New Hanover County Board of Education

and New Hanover County Schools staff and admittedly performed unauthorized work for the

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school board and school district staff, all in material violation of Paragraph 1 of the contract.

6. Beginning on or about October 1, 2023, Sink used confidential information about New

Hanover County Board of Education, New Hanover County Schools, and Vogel Law Firm

PLLC's representation of the school board and school district for its own benefit or gain and/or

for use that is adverse to the interests of Vogel Law Firm PLLC, in material violation of

Paragraph 4 of the contract. Sink disparaged Vogel Law Firm PLLC and actively attempted to

wrest representation of the New Hanover County Board of Education from Vogel Law Firm

PLLC to Sink, all while Sink was under contract with, and remains under contract with, Vogel

Law Firm PLLC and/or to lay the groundwork to do so, which constitutes a material breach of

contract of Paragraph 4 of the contract.

ACCORD AND SATISFACTION

1. On or about December 26, 2023, Vogel Law Firm PLLC, through Managing Attorney
Jonathan Vogel, sent Leigha Sink, on behalf of "Sink Law Firm PLLC" and Plaintiff "Sink Law

PLLC" (hereinafter collectively referred to as "Sink"), an email informing Sink that it will

receive payment of $6,016.00 for work performed by its attorneys in October 2023.

2. Vogel Law Firm PLLC explained in the email that the payment constituted a calculation

based on an hourly rate of $235 at the 25.6 hours billed to Vogel Law Firm PLLC's clients that

month for work performed by Sink's attorneys.

3. Vogel Law Firm PLLC acknowledged that Sink expected additional money for work

performed in October 2023 and therefore disputed the amount paid, but that, since Sink

materially breached the contract with Vogel Law Firm PLLC, the firm, which was justified in

making no payment at all to Sink, was paying the amount of $6,016.00 as the full and final

payment for work performed by Sink for Vogel Law Firm PLLC. Vogel Law Firm PLLC

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described the provisions of the contract that Sink materially breached and the facts constituting a

material breach of contract and tortious interference with a contract.

4. Vogel Law Firm PLLC informed Sink that, by depositing or cashing the check in the

amount of $6,016.00, Sink "agrees that the check represents the full and final payment for work

performed" for Vogel Law Firm PLLC.

5. On or about December 29, 2023, Plaintiff deposited check #995173 for $6,016.00 from

Vogel Law Firm PLLC with the notation on the check reading "Full & Final Payment-October

2023."

FAILURE OF CONDITION PRECEDENT (FAILURE TO MEDIATE)

1. Paragraph 7 of the contract dated December 2, 2021 between Vogel Law Firm PLLC and

"Sink Law Firm PLLC" provides that, as a condition precedent to either party bringing "any

legal action to enforce" the contract, the parties were obligated to "first have their dispute

mediated in non-binding mediation before a neutral mediator."

2. On January 2, 2024, Plaintiff "Sink Law PLLC" brought this legal action to enforce the

contract without first having the dispute mediated in non-binding mediation before a neutral

mediator.

UNJUST ENRICHMENT

1. It would be inequitable for Plaintiff "Sink Law PLLC" to obtain any additional funds

from Vogel Law Firm PLLC because Plaintiff does not have a contract with Vogel Law Firm

PLLC and because Plaintiff was already fully paid for the hours its attorneys worked for Vogel

Law Firm PLLC in October 2023.

COUNTERCLAIMS

BREACH OF CONTRACT

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 1. Plaintiff "Sink Law PLLC" or "Sink Law Firm PLLC" breached its contract with Vogel

Law Firm PLLC.

2. Paragraph 1 of the contract dated December 2, 2021 between Vogel Law Firm PLLC and

"Sink Law Firm PLLC" -

called "Firm" and "Contract Attorney Provider," respectively, in the

agreement -

provides the following: "Contract Attorney Provider agrees to provide attorneys to

provide legal research, writing and litigation support services to the Firm and its clients, on an at-

will basis, at the request of the Firm and subject to Contract Attorney Provider's availability."

(Emphasis added).

3. Paragraph 3 provides the following, in relevant part: "The relationship between the Firm

and Contract Attorney Provider is an independent contractor relationship." (Emphasis added).

4. Paragraph 4 provides the following, in relevant part: "Contract Attorney Provider

acknowledges that trust and confidence are important components of any relationship and agrees

to comply with the Firm's policies and procedures for handling and protecting the confidential

information of the Firm's clients. Attorneys of Contract Attorney Provider shall not... use any
confidential information of the Firm's clients for its own benefit or gain, or for any use that is or

becomes adverse to the interests of the Firm, without the Firm's prior written consent."

(Emphasis added).

5. Beginning on or about October 1, 2023, Plaintiff "Sink Law PLLC" and "Sink Law Firm

PLLC" (hereinafter collectively referred to as "Sink") admittedly had multiple, unauthorized

communications and meetings with members of the New Hanover County Board of Education

and New Hanover County Schools staff and admittedly performed unauthorized work for the

school board and school district staff, all in material violation of Paragraph 1 of the contract.

6. Beginning on or about October 1, 2023, Sink used confidential information about New

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Hanover County Board of Education, New Hanover County Schools, and Vogel Law Firm

PLLC's representation of the school board and school district for its own benefit or gain and/or

for use that is adverse to the interests of Vogel Law Firm PLLC, in material violation of

Paragraph 4 of the contract. Sink disparaged Vogel Law Firm PLLC and actively attempted to

wrest representation of the New Hanover County Board of Education from Vogel Law Firm

PLLC to Sink, all while Sink was under contract with, and remains under contract with, Vogel

Law Firm PLLC and/or to lay the groundwork to do so, which constitutes a material breach of

contract of Paragraph 4 of the contract.

BREACH OF IMPLIED WARRANTY OF GOOD FAITH AND FAIR DEALING

1. Plaintiff "Sink Law PLLC" or "Sink Law Firm PLLC" breached its implied warranty of

good faith and fair dealing with Vogel Law Firm PLLC.

2. Paragraph 1 of the contract dated December 2, 2021 between Vogel Law Firm PLLC and

"Sink Law Firm PLLC" -

called "Firm" and "Contract Attorney Provider," respectively, in the

agreement
-

provides the following: "Contract Attorney Provider agrees to provide attorneys to

provide legal] research, writing and litigation support services to the Firm and its clients, on an at-

will basis, at the request of the Firm and subject to Contract Attorney Provider's availability."

(Emphasis added).

3. Paragraph 3 provides the following, in relevant part: "The relationship between the Firm

and Contract Attorney Provider is an independent contractor relationship." (Emphasis added).

4. Paragraph 4 provides the following, in relevant part: "Contract Attorney Provider

acknowledges that trust and confidence are important components of any relationship and agrees

to comply with the Firm's policies and procedures for handling and protecting the confidential

information of the Firm's clients. Attorneys of Contract Attorney Provider shall not ... use any

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confidential information of the Firm's clients for its own benefit or gain, or for any use that is or

becomes adverse to the interests of the Firm, without the Firm's prior written consent."

(Emphasis added).

5. Beginning on or about October 1, 2023, Plaintiff "Sink Law PLLC" and "Sink Law Firm

PLLC" (hereinafter collectively referred to as "Sink") admittedly had multiple, unauthorized

communications and meetings with members of the New Hanover County Board of Education

and New Hanover County Schools staff and admittedly performed unauthorized work for the

school board and school district staff, all in material violation of Paragraph 1 of the contract.

6. Beginning on or about October 1, 2023, Sink used confidential information about New

Hanover County Board of Education, New Hanover County Schools, and Vogel Law Firm

IPLLC's representation of the school board and school district for its own benefit or gain and/or

for use that is adverse to the interests of. Vogel Law Firm PLLC, in material violation of

Paragraph 4 of the contract. Sink disparaged Vogel Law Firm PLLC and actively attempted to

wrest representation of the New Hanover County Board of Education from Vogel Law Firm

PLLC to Sink, all while Sink was under contract with, and remains under contract with, Vogel

Law Firm PLLC and/or to lay the groundwork to do so, which constitutes a material breach of

contract of Paragraph 4 of the contract.

TORTIOUS INTERFERENCE WITH A CONTRACT

1. Pursuant to a contract effective July 1, 2023 between Vogel Law Firm PLLC and the

New Hanover County Board of Education that was renewed effective January 1, 2024, Vogel

Law Firm PLLC provides legal services to the New Hanover County Board of Education.

2. Plaintiff had knowledge of the facts giving rise to Vogel Law Firm PLLC's contract right

with the New Hanover County Board of Education because Plaintiff's attorneys, Leigha Sink and

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Jonathan Sink, were contracted through Plaintiff "Sink Law PLLC" or "Sink Law Firm PLLC"

(hereinafter collectively referred to as "Sink") to provide support to Vogel Law Firm PLLC to

service Vogel Law Firm PLLC's clients, including, beginning July 1, 2023, the New Hanover

County Boar of Education.

3. Plaintiff intentionally induced and persuaded, and attempted to induce and persuade, the

New Hanover County Board of Education and New Hanover County Schools to adversely alter

the performance of, not to renew, and/or to terminate the contract right with New Hanover

County Board of Education to which Vogel Law Firm PLLC was entitled by, among other

things, beginning on or about October 1, 2023, (a) admittedly having multiple, unauthorized

communications and meetings with members of the New Hanover County Board of Education

and New Hanover County Schools staff, and (b) admittedly performing unauthorized work for

the school board and school district staff.

4, Plaintiff disparaged Vogel Law Firm PLLC to New Hanover County Board of Education

and New Hanover County Schools to wrest representation of the New Hanover County Board of

Education from Vogel Law Firm PLLC to Plaintiff all while Sink was under contract with, and

remains under contract with, Vogel Law Firm PLLC and/or to lay the groundwork to do so.

5. Asan independent contractor for Vogel Law Firm PLLC, Sink acted without justification

when it engaged in these unauthorized communications and meetings and performed

unauthorized work. Sink was contractually required to provide attorneys to provide legal support

services to Vogel Law Firm PLLC and its clients only "at the request of? Vogel Law Firm

PLLC. Moreover, Sink was contractually required to not use any confidential information of the

Vogel Law Firm PLLC's clients for its own benefit or gain, or for any use that is or becomes

adverse to the interests of Vogel Law Firm PLLC without the prior written consent of Vogel Law

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Firm PLLC.

6. Plaintiff's aforementioned actions resulted in actual damages to Vogel Law Firm PLLC

in the form of lost business opportunities with New Hanover County Board of Education.

WHEREFORE, Vogel Law Firm PLLC respectfully requests that the Court find Plaintiff

in breach of contract, in breach of the implied warranty of good faith and fair dealing, and liable

for tortious interference with a contract, and award Vogel Law Firm PLLC actual damages of an

amount to be determined at trial.

Respectfully submitted,

VOGEL LWATIRM PLLC

Jo A. Vogel
Bar No. 34266

6000 Fairview Road

South Park Towers, Suite 1200
Charlotte, NC 28210
Telephone:704.552.3750
jonathan.vogel@vogelplic.com

Counsel for Vogel Law Firm PLLC

and Jonathan Vogel

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 VOGEL LAW FIRM PLLC
Contract Attorney Agreement

This Contract Attorney Agreement ("Agreement") is by and between Vogel Law Firm PLLC, a
North Carolina professional limited liability company with a mailing address of 6000 Fairview Road,
South Park Towers, Suite 1200, Charlotte, North Carolina 28210 ("Firm"), and Sink Law Firm PLLC, a
professional limited liability company with mailing address of 804 Hawthorne Rd., Shelby, NC 28150
("Contract Attorney Provider"), (Firm and Contract Attorney Provider collectively shall be referred to
herein as the "Parties") and is effective as of the latest that all of the Parties have signed this Agreement.

WHEREAS, Vogel Law Firm PLLC is engaged in the private practice of law primarily in the area of
education law and litigation, and seeks legal research, writing and litigation support in furtherance of the
provision of high-quality legal services to the Firm's clients; and

WHEREAS, Contract Attorney Provider is a law firm registered to do business in the state of
North Carolina, and is interested in providing attorneys to provide research, writing and litigation
support services to the Firm and its clients; and

WHEREAS, the Parties have decided that it is in their mutual interest and benefit to enter into
this Agreement, pursuant to the terms and conditions set forth herein;

NOW THEREFORE, for and in consideration of the mutual promises contained in this Agreement,
and other consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties
agree as follows:

1. Services. Contract Attorney Provider agrees to provide attorneys to provide legal

research, writing and litigation support services to the Firm and its clients, on an at-will basis, at the
request of the Firm and subject to Contract Attorney Provider's availability (the "Services").

2. Compensation. In return for providing the Services, the Firm will compensate Contract
Attorney Provider at the rate of $150 per billable hour (the "Compensation"). By the last day of a month
in which Services have been provided, or otherwise as directed by Firm, Contract Attorney Provider will
provide Firm an invoice that provides itemized entries for tasks performed each day of the month,
including the amount of hours incurred by Contract Attorney Provider in providing the Services, the
dates on which the Services were provided, the projects to which those hours are attributable, the
Attorney(s) of Contract Attorney Provider who completed the work, and a description of the work by
each such Attorney on each date. Unless agreed otherwise by the Parties, Contract Attorney Provider
Firm will make payment of the Compensation to Contract Attorney Provider within thirty (30) days
following the end of the month after the Services were provided by mailing payment to Contract
Attorney Provider at the address set forth herein or as otherwise provided by Contract Attorney Provider.

3. Independent Contractor. The relationship between the Firm and Contract Attorney
Provider is an independent contractor relationship. Contract Attorney Provider shall bear Contract
Attorney Provider's expenses incurred in providing the Services, including the expenses associated with
legal research, computer and technology, labor, materials, equipment, taxes, retirement, medical, dental
and benefits, and transportation and telephone expenses, except to the extent the Firm or its client(s)
agree to bear certain expenses or it would be customary for the Firm or its client(s) to bear certain
expenses necessary to the handling of a particular legal matter, which expenses, if assumed by the

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Contract Attorney Provider, shall be charged by Contract Attorney Provider to the Firm. Contract
Attorney Provider shall provide Firm with a fully-executed IRS form W-9 to facilitate Contract Attorney
Provider's provision of Services to Firm on an independent contractor basis.

4. Confidentiality. Contract Attorney Provider acknowledges that trust and confidence are
important components of any relationship and agrees to comply with the Firm's policies and procedures
for handling and protecting the confidential information of the Firm's clients. Attorneys of Contract
Attorney Provider shall not disclose any confidential information of the Firm's clients to any person
(except as may be required by applicable law or in the performance of his or her duties and
responsibilities to the Firm under the terms of this Agreement), or use any confidential information of
the Firm's clients for its own benefit or gain, or for any use that is or becomes adverse to the interests of
the Firm, without the Firm's prior written consent. This Paragraph will survive this Agreement's
termination for the two (2) year period after the date of its termination for any reason, and this
Paragraph otherwise shall survive to the fullest extent allowed by North Carolina law and the North
Carolina Rules of Professional Conduct.

5. Conflicts of Interest. Contract Attorney Provider shall ensure that all matters handied by
attorneys of Contract Attorney Provider, whether for the Firm's clients through the Firm or whether
provided by said attorneys in any other capacity, are in compliance with the conflict-of-interest rules
contained in the North Carolina Rules of Professional Conduct and the rules of any other state in which
Contract Attorney Provider maintains its principal place of business.

6. Warranty Regarding License. Contract Attorney Provider represents and warrants that all
attorneys providing services hereunder are licensed to practice law in the state in which such attorney(s)
reside(s) or maintain(s) his or her principal office, and Contract Attorney Provider represents and
warrants that each of said attorneys is in good standing with the highest court and the bar association in
such jurisdiction. In the event the licensure or bar standing of an attorney of Contract Attorney Provider
is challenged or impaired for any reason, or if said attorney is disbarred, suspended, sanctioned or
reprimanded by any court or bar association, or if Contract Attorney Provider receives any claim alleging
negligence or misconduct pertaining to the services of any said attorney, whether pertaining to Services
provided for Firm or otherwise, Contract Attorney Provider will notify Firm immediately and provide Firm
the details of such occurrence.

7. Governing Law / Venue. This Agreement shall be governed by the laws of the State of
North Carolina, except with respect to its conflict of laws provisions, and any dispute with respect to the
interpretation or enforcement of this Agreement shall be brought only in a court of appropriate
jurisdiction located within Mecklenburg County, North Carolina. Before either of the Parties brings any
legal action to enforce this Agreement, the Parties agree first to have their dispute mediated in
non-binding mediation before a neutral mediator.

8. Notices. All notices, requests, demands and other communications required under this
Agreement must be in writing and will be deemed given if delivered personally or three (3) days after
mailing by certified or registered mail, postage prepaid, return receipt requested, or if sent by reputable
overnight courier service such as Federal Express or the United Parcel Service, to the Party, at the
following addresses, or at such other addresses as the Parties may designate by written notice to the
other in the above-mentioned manner:

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 If to Contract Attorney Provider: Sink Law, PLLC
Attn: Mrs. Leigha Sink
804 Hawthorne Rd.
Shelby, NC 28150

If to the Firm: Vogel Law Firm PLLC

Attn: Mr. Jonathan Vogel
6000 Fairview Road
South Park Towers, Suite 1200
Charlotte, NC 28210

Executed by the Parties on the respective dates set forth below.

VOGEL LAW FIRM PLLC SINK LAW FIRM PLLC

A. Vogel
BB.
Jo than Vogel Leigha Sink

December 2, 2021 December 2, 2021

Date Date

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 CERTIFICATE OF SERVICE
The undersigned counsel certifies that Plaintiff was served on January 23, 2023 with a

copy of ANSWER AND COUNTERCLAIMS by registered mail to the following counsel of

record:

Jonathan Sink
804 Hawthorne Road

ZS
Shelby, NC 28150

an A. Vogel

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