NYC 9/11 Public Portal Document
1. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraph “1” of the complaint.
2. Deny the allegations set forth in paragraph “2” of the complaint, except admit
that records of the City of New York reflect that plaintiff was the owner of the property located
at 527 Page Avenue, Staten Island, New York 10307 (the “subject property”), during the relevant
time periods at issue herein.
3. Admit the allegations set forth in paragraphs “3,” “4,” “5,” “6,” “7,” “8,” “9,”
“10” “11,” “12,” “13,” “14,” “15,” and “16” of the complaint.
4. Deny the allegations set forth in paragraph “17” of the complaint, except
admit that defendant Ignizio is the New York City Council Member for the 5P’ District in Staten
Island, New York and aver that his District Office is located at 3944 Richmond Avenue, Staten
Island, New York 10312.
5. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraph “18” of the complaint.
6. Deny the allegations set forth in paragraph “19” of the complaint, except
admit that defendant Mustaciuolo’s principal place of business is located at 100 Gold Street,
New York, New York 10038, and aver that defendant Mustaciuolo is a Deputy Commissioner of
the New York City Department of Housing Preservation and Development (“HPD”).
7. Admit the allegations set forth in paragraph “20” of the complaint.
8.* Deny the allegations set forth in paragraph “21” of the complaint, and aver
that defendant William Deluca is an employee of the New York City Department of Buildings
(“DOB”) with a principal place of business located at 280 Broadway, New York, New York
10007.
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NYC-WTC_000159401
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