NYC 9/11 Public Portal Document
and aver that some of the causes of action alleged herein occurred well before the 90- day period
alleged in the complaint.
19. Deny the allegations set forth in paragraph “36” of the complaint, except
admit that as of the present date, the City of New York has not offered a settlement in response
to the Notice of Claim.
20. Deny the allegations set forth in paragraph “37” of the complaint, except
admit that an examination of plaintiffs claim pursuant to New York General Municipal Law §
50-h has not been conducted.
21. Deny the allegations set forth in paragraphs “38” and “39” of the complaint.
22. Deny the allegations set forth in paragraph “40” of the complaint, except
admit that plaintiff purports to proceed as set forth therein.
23. Deny the allegations set forth in paragraph “41” of the complaint, except
admit that plaintiff became the record owner of the subject property in 1995.
24. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraphs “42,” “43,” and “44” of the complaint.
25. Deny the allegations set forth in paragraph “45” of the complaint.
26. Deny the allegations set forth in paragraph “46” of the complaint, except
admit that Staten Island Public School 6 is located at 555 Page Avenue, Staten Island, New
York.
27. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraphs “47” and “48” of the complaint.
28. Deny the allegations set forth in paragraph “49” of the complaint.
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NYC-WTC_000159403
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