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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

9. Admit the allegations set forth in paragraph “22” of the complaint.

10. Deny the allegations set forth in paragraph “23” of the complaint, and aver

that defendant Stephen Coyle is an employee of DOB with a principal place of business located

at 280 Broadway, New York, New York 10007.

11. Deny knowledge or information sufficient to form a belief as to the truth of

the allegations set forth in paragraph “24” of the complaint.

12. Deny the allegations set forth in paragraph “25” of the complaint, and aver

that defendant Girimonte was an Assistant Chief with the Staten Island 123^'* Precinct of the New

York City Police Department (“NYPD”) and is now retired.

13. Admit the allegations set forth in paragraphs “26,” “27,” “28,” and “29” of

the complaint.

14. Deny the allegations set forth in paragraph “30” of the complaint, and aver

that defendant Eugene McArdle was formerly the Director of Demolition of HPD and is

currently an employee at HPD, with a principal place of business located at 100 Gold Street,

New York, New York 10038.

15. Deny knowledge or information sufficient to form a belief as to the truth of

the allegations set forth in paragraph “31 ” of the complaint.

16. Deny the allegations set forth in paragraph “32” and “33” of the complaint.

except admit that plaintiff purports to proceed as set forth therein.

17. Deny the allegations set forth in paragraph “34” of the complaint, except

admit that venue properly lies in this judicial district.

18. Deny the allegations set forth in paragraph “35” of the complaint, except

admit that plaintiff served a Notice of Claim upon the City of New York, dated March 3, 2008,

-3-

I

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