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Requests 2012

Label derived from the City's folder field. The City does not supply document titles.NYC-WTC_000159400–000159415
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NYC 9/11 Public Portal Document

78. In response to paragraph “148” of the complaint, defendants repeat the

responses to the cited paragraphs incorporated by reference herein.

79. Neither admit nor. deny the allegations set forth in paragraph “149” of the

complaint insofar as it sets forth legal argument for which no response is required; in the event

that a response is required, deny said allegations; and aver that City defendants did not violate

any of plaintiffs constitutionally-protected rights.

80. Deny the allegations set forth in paragraphs “150,” “151,” “152,” “153,”

and “154” of the complaint.

81. In response to paragraph “155” of the complaint, defendants repeat the

responses to the cited paragraphs by reference herein.

82. Deny the allegations set forth in paragraph “156” of the complaint, except

admit that plaintiff purports to proceed as set forth therein.

83. Deny the allegations set forth in paragraph “157” of the complaint, and

respectfully refer the Court to Article 1, Section 6 of the New York State Constitution for its

complete text and true meaning.

84. Deny- the allegations set forth in paragraphs “158,” “159,” and “160” of

the complaint.

85. In response to paragraph “161” of the complaint, defendants repeat the

responses to the cited paragraphs by reference herein.

86. Deny the allegations set forth in paragraph “162” of the complaint, except

admit that plaintiff purports to proceed as set forth therein.

87. Deny the allegations set forth in paragraph “163” of the complaint, except

admit that plaintiff is the record owner of the subject property.

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