Beruflich Dokumente
Kultur Dokumente
COUNTY OF ORANGE
NINTH JUDICIAL DISTRICT ENVIORONMENTAL CLAIMS PART
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VILLAGE OF SOUTH BLOOMING GROVE, et
al. ,
Petitioners,
Hon. Francesca E.
Connolly
- against
VILLAGE OF KIRYAS JOEL BOARD OF
TRUSTEES, et al.
Respondents,
EMANUEL LEONOROVITZ, et al.
Additional Respondents.
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PRESERVE HUDSON VALLEY, et al.
Index No. 8118/2015
Proceeding No. 2
Petitioners,
- against
TOWN BOARD OF THE TOWN OF MONROE, et al.
Respondents/Defendants.
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VERIFIED ANSWER TO AMENDED VERIFIED PETITION AND COMPLAINT OF
PETITIONERS/PLAINTIFFS IN PROCEEDING NO. 2
Respondents-Defendants, Town Board of the Town of Monroe and
Town of Monroe, by their attorneys, DICKOVER. DONNELLY &
DONOVAN, LLP, respectfully submit the foregoing Verified Answer
Petition.
10. With respect to the allegations in Paragraph 10 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent and answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
11. With respect to the allegations in Paragraph 11 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations set forth.
12. With respect to the allegations in Paragraph 12 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations set forth.
13. The Town denies the allegations in Paragraph 13 of the
PHV Petition.
14. The Town denies the allegations in Paragraph 14 of the
PHV Petition.
15. With respect to the allegations in Paragraph 15 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations that
Petitioner Allegro has a daughter, and otherwise denies the
allegations in Paragraph 15.
16. With respect to the allegations in Paragraph 16 of the
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
46. With respect to the allegations set forth in Paragraph 46
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
47. With respect to the allegations set forth in Paragraph 47
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
48. With respect to the allegations set forth in Paragraph 48
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
49. With respect to the allegations set forth in Paragraph 49
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
70. With respect to the allegations set forth in Paragraph 70
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
71. With respect to the allegations set forth in Paragraph 71
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
72. With respect to the allegations set forth in Paragraph 72
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
73. With respect to the allegations set forth in Paragraph 73
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
94. With respect to the allegations set forth in Paragraph 94
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
95. With respect to the allegations set forth in Paragraph 95
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
96. With respect to the allegations set forth in Paragraph 96
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
97. With respect to the allegations set forth in Paragraph 97
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
117 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
118. With respect to the allegations set forth in Paragraph
118 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
119. With respect to the allegations set forth in Paragraph
119 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
120. With respect to the allegations set forth in Paragraph
120 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
121. With respect to the allegations set forth in Paragraph
121 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
141 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
142. The allegations in Paragraph 142 of the PHV Petition set
forth conclusions of law for which no responsive pleading is
required, but to the extent an answer is made, the Town refers
the Court to the statutes and/or regulations referenced therein
for determination of their content, meaning and effect, and
denies Petitioners characterizations thereof.
143. The allegations in Paragraph 143 of the PHV Petition set
forth conclusions of law for which no responsive pleading is
required, but to the extent an answer is made, the Town refers
the Court to the statutes and/or regulations referenced therein
for determination of their content, meaning and effect, and
denies Petitioners characterizations thereof.
144. The Town denies the allegations set forth in Paragraph
144 of the PHV Petition.
145. The Towndenies the allegations set forth in Paragraph 145
of the PHV Petition.
146. With respect to the allegations in Paragraph 146 of the
PHV Petition, the Town acks knowledge or information sufficient
to form a belief as to the truth of the allegations.
147. With respect to the allegations in Paragraph 147 of the
156 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
157. With respect to the allegations set forth in Paragraph
157 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
158. The Town denies the allegations set forth in Paragraph
158 of the PHV Petition.
159. The Town denies the allegations set forth in Paragraph
159 of the PHV Petition.
160. The Town denies the allegations set forth in Paragraph
160 of the PHV Petition.
161. With respect to the allegations set forth in Paragraph
161 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
162. The Town denies the allegations set forth in Paragraph
162 of the PHV Petition.
163. The Town denies the allegations set forth in Paragraph
163 of the PHV Petition.
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
242. With respect to the allegations in Paragraph 242 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
243. With respect to the allegations in Paragraph 243 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
244. The Town denies the allegations set forth in Paragraph
244 of the PHV Petition.
245. The Town denies the allegations set forth in Paragraph
245 of the PHV Petition.
246. The Town denies the allegations set forth in Paragraph
246 of the PHV Petition.
272 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
273. With respect to the allegations set forth in Paragraph
273 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
274. With respect to the allegations set forth in Paragraph
274 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
275. With respect to the allegations set forth in Paragraph
275 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
276. With respect to the allegations set forth in Paragraph
276 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
301. With respect to the allegations in Paragraph 301 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
302. With respect to the allegations in Paragraph 302 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
303. With respect to the allegations set forth in Paragraph
303 of the PHV Petition, the Town admits that the Petitioners
have alleged violations of the Establishment Clause but denies
the validity of these allegations.
304. The Town denies the allegations set forth in Paragraph
304 of the PHV Petition.
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
Petitioners appear to have inadvertently mis-numbered their causes of action, setting forth two
Fourth causes of action.
1
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
326. With respect to the allegations in Paragraph 326 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
327. The Town denies the allegations set forth in Paragraph
327 of the PHV Petition.
328. With respect to the allegations in Paragraph 328 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
329. With respect to the allegations in Paragraph 329 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
340. The Town denies the allegations set forth in Paragraph
340 of the PHV Petition.
341. The Town denies the allegations set forth in Paragraph
341 of the PHV Petition.
342. With respect to the allegations set forth in Paragraph
342 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
343. The Town denies the allegations set forth in Paragraph
343 of the PHV Petition.
344. With respect to the allegations set forth in Paragraph
344 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
345. With respect to the allegations set forth in Paragraph
345 of the PHV Petition, the Town refers the Court to the
Paragraph 349 of the PHV Petition, the Town states that such
allegations set forth conclusions of law for which no responsive
pleading is required, but to the extent an answer is made, the
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
367. The Town denies the allegations set forth in Paragraph
367 of the PHV Petition.
368. With respect to the allegations in Paragraph 368 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
369. With respect to the allegations in Paragraph 369 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
370. With respect to the allegations in Paragraph 370 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
378. With respect to the allegations in Paragraph 378 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
379. With respect to the allegations set forth in Paragraph
379 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
380. With respect to the allegations in Paragraph 380 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
389 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
390. With respect to the allegations set forth in Paragraph
390 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
391. With respect to the allegations set forth in Paragraph
391 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
392. With respect to the allegations set forth in Paragraph
392 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
393. With respect to the allegations set forth in Paragraph
393 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
characterizations thereof.
was inadequate.
413. The Town denies the allegations set forth in Paragraph
413 of the PHV Petition.
414. The Town denies the allegations set forth in Paragraph
414 of the PHV Petition.
415. With respect to the allegations set forth in Paragraph
415 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
416. The Town denies the allegations set forth in Paragraph
416 of the PHV Petition.
417. The Town denies the allegations set forth in Paragraph
417 of the PHV Petition.
418. The Town denies the allegations set forth in Paragraph
418 of the PHV Petition.
419. The Town denies the allegations set forth in Paragraph
419 of the PHV Petition.
420. The Town denies the allegations set forth in Paragraph
420 of the PHV Petition.
421. With respect to the allegations set forth in Paragraph
421 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
431 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
432. With respect to the allegations set forth in Paragraph
432 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
433. With respect to the allegations set forth in Paragraph
433 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
434. With respect to the allegations in Paragraph 434 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
435. With respect to the allegations in Paragraph 435 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
436. With respect to the allegations in Paragraph 436 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
437. With respect to the allegations in Paragraph 437 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
438. With respect to the allegations in Paragraph 438 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
443 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
444. With respect to the allegations set forth in Paragraph
444 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
445. With respect to the allegations in Paragraph 445 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
446. With respect to the allegations set forth in Paragraph
446 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
447. With respect to the allegations set forth in Paragraph
447 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
characterizations thereof.
464. With respect to the allegations set forth in Paragraph
464 of the PHV Petition, the allegations set forth conclusions
of law for which no responsive pleading is required, but to the
extent an answer is made, the Town refers the Court to the
statutes and/or regulations referenced therein for determination
of their content, meaning and effect, and denies Petitioners
characterizations thereof.
465. With respect to the allegations set forth in Paragraph
465 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
466. With respect to the allegations set forth in Paragraph
466 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and otherwise lacks sufficient knowledge or
information to form a belief as to the truth of the allegations
set forth and denies Petitioners characterization thereof.
467. With respect to the allegations set forth in Paragraph
467 of the PHV Petition, the allegations set forth conclusions
of law for which no responsive pleading is required, but to the
extent an answer is made, the Town refers the Court to the
statutes and/or regulations referenced therein for determination
thereof.
492. With respect to the allegations set forth in Paragraph
492 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterizations
thereof.
495 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterizations
thereof.
496. The Town denies the allegations set forth in Paragraph
496 of the PHV Petition.
497. The Town denies the allegations set forth in Paragraph
497 of the PHV Petition.
498. The Town denies the allegations set forth in Paragraph
498 of the PHV Petition.
499. With respect to the allegations set forth in Paragraph
499 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations
set forth.
500. With respect to the allegations set forth in Paragraph
500 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations
set forth.
501. With respect to the allegations set forth in Paragraph
501 of the PHV Petition, the allegations set forth conclusions
characterization thereof.
519. With respect to the allegations set forth in Paragraph
519 of the PHV Petition, the allegations set forth conclusions
of law for which no responsive pleading is required, but to the
extent an answer is made, the Town refers the Court to the
statutes and/or regulations referenced therein for determination
of their content, meaning and effect, and otherwise lacks
knowledge or information sufficient to form a belief as to the
truth of the allegations set forth and denies Petitioners
characterization thereof.
520. With respect to the allegations set forth in Paragraph
520 of the PHV Petition, the allegations set forth conclusions
of law for which no responsive pleading is required, but to the
extent an answer is made, the Town refers the Court to the
statutes and/or regulations referenced therein for determination
of their content, meaning and effect, and otherwise lacks
knowledge or information sufficient to form a belief as to the
truth of the allegations set forth and denies Petitioners
characterization thereof.
521. The Town denies the allegations set forth in Paragraph
521 of the PHV Petition.
522. The Town denies the allegations set forth in Paragraph
522 of the PHV Petition.
523. The Town denies the allegations set forth in Paragraph
another action pending between the same parties for the same
cause of action.
documentary evidence.
Dated:
______________________
Michael H. Donnelly
VERIFICATION
STATE OF NEW YORK
COUNTY OF ORANGE
:
:ss.:
:
____________________________
HARLEY DOLES
Sworn to before me this
______ day of January, 2016.
____________________________
MICHAEL H. DONNELLY
Notary Public, State of New York
Qualified in Orange County
Commission Expires on July 12, 2014