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.
- 11 -
i_
NYC-WTC_000159410
OCR can misread numbers and units. Confirm readings against the page image before using them.