Requests 2012

NYC 9/11 Public Portal Document

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

the allegations set forth in paragraph “112” of the complaint.

62. Deny the allegations set forth in paragraph “113” of the complaint, and aver

that the demolition of the subject proper was lawful and authorized by City defendants.

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

the allegations set forth in paragraph “114” of the complaint, and aver that there was no Stop

Work Order contained in the Order to Show Cause to enforce.

64. Deny the allegations set forth in paragraph “115” and respectfully refer the

Court to Chapter 18 of the New York City Charter for a full description of the powers and duties

of the NYPD and its force.

65. Deny the allegations set forth in paragraphs “116,” “117,” “118,” “119,” and

“120” of the complaint.

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

the allegations set forth in paragraph “121” of the complaint.

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

the allegations set forth in paragraph “122” of the complaint, except admit that NYPD Lt.

Falcone spoke to plaintiff at some point in time and that the NYPD did not issue a police report

for the December 2007 demolition complained of by plaintiff.

68. Deny the allegations set forth in paragraph “123” of the complaint, except

admit that the NYPD did not issue a police report for the December 2007 demolition complained

of by plaintiff.

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

the allegations set forth in paragraphs “124” and “125” of the complaint.

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