NYC 9/11 Public Portal Document
29. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraph “50” of the complaint.
30. Deny the allegations set forth in paragraph “51 ” of the complaint.
31. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraphs “52,” “53,” “54,” and “55” of the complaint.
32. Deny the allegations set forth in paragraph “56” of the complaint.
33. Deny the allegations set forth in paragraph “57” of the complaint, and aver
that in 2004, the New York State Supreme Court, Richmond County, issued a precept against the
subject property upon the request of DOB, ordering the plaintiff to perform certain repairs of the
subject property.
34. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraph “58” of the complaint.
35. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraph “59” of the complaint, except admit that at some point in
time, plaintiff met with the then-Staten Island Borough Commissioner for the New York City
Department of Transportation (“DOT”).
36. Deny the allegations set forth in paragraph “60” of the complaint.
37. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraph “61” of the complaint.
38. Deny the allegations set forth in paragraphs “62,” “63,” and “64” of the
complaint.
39. Deny knowledge or information sufficient to form a belief as to the truth of
the allegations set forth in paragraphs “65,” “66,” “67,” “68,” and “69” of the complaint.
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NYC-WTC_000159404
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