Preview
FILED:
FILED : NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
CLERK 04/23/2019
11/02/2018 03:14
03:51 PM
PM|
INDEX
INDEX NO.
NO. 190225/2018
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NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 67
146 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 04/23/2019
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
X
IN RE: NEW YORK CITY ASBESTOS MASTER
ASBESTOS LITIGATION Index No.: 40,000/88
X
This Document Relates To:
STANDARD ANSWER TO
All Cases In Which SIMMONS HANLY CONROY
ASBESTOS STANDARD
IPA SYSTEMS, INC. COMPLAINT
Is Named As A Defendant.
X
Defendant,IPA SYSTEMS, INC. answering NYCAL SIMMONS HANLY CONROY
STANDARD ASBESTOS COMPLAINT ("Complaint"), upon information and belief, alleges
as follows:
THE PARTIES
1. Defendant, IPA SYSTEMS, INC. denies any knowledge or information
"1"
sufficient to form a belief as to each and every allegation contained in Paragraph of the
Standard Complaint.
2. Defendant IPA SYSTEMS, INC. denies any knowledge or information
"2"
sufficient to form a belief as to the truth of the allegations contained in Paragraph of the
Standard Complaint.
3. Defendant, IPA SYSTEMS, INC. denies each and every allegation containedin
"3"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
"4"
4. Defendant,IPA SYSTEMS, INC. in Paragraph of the Standard Complaint is
not an allegation and no responsive pleading is required.
{N0789531-l}
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FILED:
FILED : NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
CLERK 04/23/2019
11/02/2018 03:14
03:51 PM
PM|
INDEX
INDEX NO.
NO. 190225/2018
190225/2018
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 67
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NYSCEF: 04/23/2019
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5. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"S"
Paragraph of the Standard Complaiñt, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as pertain to persons or entities other than IPA INC.
they SYSTEMS,
6. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"6"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
7. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"7"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
8. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"8"
Paragraph of the Standard Complaint, iñsofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as pertain to persons or entities other than IPA SYSTEMS, INC.
they
9. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"9"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
10. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"10"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
(N0789531-1} 2
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FILED:
FILED : NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
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11/02/2018 03:14
03:51 PM
PM|
INDEX
INDEX NO.
NO. 190225/2018
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NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 67
146 RECEIVED
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NYSCEF: 04/23/2019
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denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
11. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"11"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
12. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"12"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
AS AND FOR AN ANSWER TO THE FIRST CAUSE ACTION
13. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every
"1" "12"
answerheretofore made to Paragraphs through of the Standard Complaint.
14. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"14"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
15. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"15"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other thanIPA SYSTEMS, INC.
16. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"16"
Paragraph of the Standard Complaiñt, insofar as they pertain to IPA SYSTEMS, INC. and
{N078953I-1} 3
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COUNTY CLERK
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INDEX
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DOC. NO.
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denies knowledge or information sufficient to form a belief as to the truth of those
any
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
17. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"17"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
18. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"18" "18"
Paragraph (a) through (m) of Plaintiff's Standard Complaint, and refers all questions
of law to this Court for determination at the time of trial,and Defendant, IPA SYSTEMS, INC.
denies any knowledge or information sufficient to form a belief as to the truth of each and every
"18" "18"
allegation contained in Paragraph (a) through (m) of Plaintiff's Stañdard Complaint
as it pertains to the remaining defendañts in the Standard Complaint.
19. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"19"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
AS AND FOR AN ANSWER TO THE SECOND CAUSE ACTION
20. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every
"1" "19" Plaintiffs'
answer heretofore made to Paragraphs through of Standard Complaint.
21. Defendant, IPA SYSTEMS, INC. denies each and every allegation coñtaiñéd in
"21"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to pessus or entities other than IPA SYSTEMS, INC.
(N0789531-1} 4
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FILED::
[FILED NEW
NEW YORK
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INDEX
INDEX NO.
NO. 190225/2018
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NYSCEF DOC.
DOC. NO.
NO. 67
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NYSCEF: 04/23/2019
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22. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"22"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
23. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"23"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertaiñ to persons or entities other than IPA SYSTEMS, INC.
24. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"24"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as pertain to persons or entities other than IPA INC.
they SYSTEMS,
25. Defeñdant, IPA SYSTEMS, INC. denies each and every allegation coñtaiñed in
"25"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertaiñ to persons or entities other than IPA SYSTEMS, INC.
26. Defendant, IPA SYSTEMS, INC. denies each and every allegation contaiñed in
"26"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
AS AND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION
27. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every
"1" "26" Plaintiffs'
answer heretofore made to Paragraphs through of Standard Complaint.
{N0789531-1) 5
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FILED:
FILED : NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
CLERK 04/23/2019
11/02/2018 03:14
03:51 PM
PM1
INDEX
I N DEX NO.
NO. 190225/2018
190225/2018
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 67
146 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 04/23/2019
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28. Defeñdañt, IPA SYSTEMS, INC. does not answer the allegations contained in
"28"
Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant.
29. Defendant, IPA SYSTEMS, INC. does not answer the allegations contained in
"29"
Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant.
30. Defendant, IPA SYSTEMS, INC. does not answer the allegations coñtaiñed in
"30"
Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant
31. Defendant, IPA SYSTEMS, INC. does not answer the allegations contained in
"31"
Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant.
32. Defendant, IPA SYSTEMS, INC. does not answer the allegations contained in
"32"
Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant.
33. Defendant, IPA SYSTEMS, INC. does not answer the allegations contained in
"33"
Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant.
AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION
34. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every
"1" "33" Plaintiffs'
answer heretofore made to Paragraphs through of Standard Complaint.
35. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"35"
Paragraph of the Stañdard Complaiñt, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
36. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"36"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
{N078953 1-1 } 6
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FILED::
[FILED NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
CLERK 04/23/2019
11/02/2018 03:14
03: 51 PM
PM|
INDEX
I NDEX NO.
NO. 190225/2018
190225/2018
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 67
146 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 04/23/2019
11/02/2018
37. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"37"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
38. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"38"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
39. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"39"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
40. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"40"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
41. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"41"
Paragraph of the Standard Coroplaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
42. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"42" "42"
Paragraph (a) through (1) of Plaintiff's Standard Complaint, and refers all questions of
law to this Court for determination at the time of trial,and Defendant IPA SYSTEMS, INC.
(N0789531-l} 7
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FILED:
FILED : NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
CLERK 04/23/2019
11/02/2018 03:14
03:51 PM
PM|
INDEX
INDEX NO.
NO. 190225/2018
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NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 67
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denies any knowledge or information sufficient to form a belief as to the truth of each and every
"42" "42"
allegation contained in Paragraph (a) through (1) of Plaintiff's Stañdard Complaint as
itpertains to the remaining defendants in the Standard Complaint.
43. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"43"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
AS AND FOR AN ANSWER TO THE FIFTH CAUSE ACTION
44. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every
"1" "43" Plaintiffs'
answer heretofore made to Paragraphs through of Standard Complaint.
45. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"45"
Paragraph of the Standard Complaint; insofar as they pertain to IPA SYSTEMS, INC. and
denies any kñ0wledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
46. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"46"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegatinits insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
47. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"47"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
(N0789531-1} 8
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FILED : NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
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11/02/2018 03:14
03:51 PM
PM|
INDEX
INDEX NO.
NO. 190225/2018
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NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 67
146 RECEIVED
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NYSCEF: 04/23/2019
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48. Defendant, IPA SYSTEMS, INC. denies each and every allegation coñtained in
"48"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
49. Defendant, IPA SYSTEMS, INC. denies each and every allegation contaiñed in
"49"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to fonn a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
50. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"50"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or cütities other than IPA SYSTEMS, INC.
51. Defendant, IPA SYSTEMS, INC. denies each and every allegation coñtained in
"51" "51"
Paragraph (a) through (i) of Plaintiff's Standard Complaint, and refers all questions of
law to this Court for determination at the time of trial, and Defendant, IPA SYSTEMS, INC.
denies any knowledge or information sufficient to form a belief as to the truth of each and every
"51" "51"
allegation contained in Paragraph (a) through (i)of Plaintiff's Standard Complaint as
itpertains to the remaining defendants in the Standard Complaint.
52. Defendant, IPA SYSTEMS, INC. denies each and every allegation coñtaiñêd in
"52"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
{N078953I-1} 9
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FILED:
FILED : NEW
NEW YORK
YORK COUNTY
COUNTY CLERK
CLERK 04/23/2019
11/02/2018 03:14
03:51 PM
PM1
INDEX
INDEX NO.
NO. 190225/2018
190225/2018
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 67
146 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 04/23/2019
11/02/2018
53. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in
"53"
Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and
denies any knowledge or information sufficient to form a belief as to the truth of those
allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC.
AS AND FOR AN ANSWER TO THE SIXTH CAUSE OF ACTION
54. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every
"1" "53" Plaintiffs'
answer heretofore made to Paragraphs through of Standard Complaint.
55. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained
Preview
FILED: FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03:51 PM PM| INDEX INDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X IN RE: NEW YORK CITY ASBESTOS MASTER ASBESTOS LITIGATION Index No.: 40,000/88 X This Document Relates To: STANDARD ANSWER TO All Cases In Which SIMMONS HANLY CONROY ASBESTOS STANDARD IPA SYSTEMS, INC. COMPLAINT Is Named As A Defendant. X Defendant,IPA SYSTEMS, INC. answering NYCAL SIMMONS HANLY CONROY STANDARD ASBESTOS COMPLAINT ("Complaint"), upon information and belief, alleges as follows: THE PARTIES 1. Defendant, IPA SYSTEMS, INC. denies any knowledge or information "1" sufficient to form a belief as to each and every allegation contained in Paragraph of the Standard Complaint. 2. Defendant IPA SYSTEMS, INC. denies any knowledge or information "2" sufficient to form a belief as to the truth of the allegations contained in Paragraph of the Standard Complaint. 3. Defendant, IPA SYSTEMS, INC. denies each and every allegation containedin "3" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. "4" 4. Defendant,IPA SYSTEMS, INC. in Paragraph of the Standard Complaint is not an allegation and no responsive pleading is required. {N0789531-l} 1 of 2 6 FILED: FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03:51 PM PM| INDEX INDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 5. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "S" Paragraph of the Standard Complaiñt, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as pertain to persons or entities other than IPA INC. they SYSTEMS, 6. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "6" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 7. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "7" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 8. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "8" Paragraph of the Standard Complaint, iñsofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as pertain to persons or entities other than IPA SYSTEMS, INC. they 9. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "9" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 10. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "10" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and (N0789531-1} 2 2 of 26 FILED: FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03:51 PM PM| INDEX INDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 11. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "11" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 12. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "12" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. AS AND FOR AN ANSWER TO THE FIRST CAUSE ACTION 13. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every "1" "12" answerheretofore made to Paragraphs through of the Standard Complaint. 14. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "14" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 15. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "15" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other thanIPA SYSTEMS, INC. 16. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "16" Paragraph of the Standard Complaiñt, insofar as they pertain to IPA SYSTEMS, INC. and {N078953I-1} 3 3 of 26 FILED: FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02 /2018 03:14 03 :51 PM PM| INDEX INDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 denies knowledge or information sufficient to form a belief as to the truth of those any allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 17. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "17" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 18. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "18" "18" Paragraph (a) through (m) of Plaintiff's Standard Complaint, and refers all questions of law to this Court for determination at the time of trial,and Defendant, IPA SYSTEMS, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every "18" "18" allegation contained in Paragraph (a) through (m) of Plaintiff's Stañdard Complaint as it pertains to the remaining defendañts in the Standard Complaint. 19. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "19" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. AS AND FOR AN ANSWER TO THE SECOND CAUSE ACTION 20. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every "1" "19" Plaintiffs' answer heretofore made to Paragraphs through of Standard Complaint. 21. Defendant, IPA SYSTEMS, INC. denies each and every allegation coñtaiñéd in "21" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to pessus or entities other than IPA SYSTEMS, INC. (N0789531-1} 4 4 of 26 FILED:: [FILED NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03:51 PM PM| INDEX INDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 22. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "22" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 23. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "23" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertaiñ to persons or entities other than IPA SYSTEMS, INC. 24. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "24" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as pertain to persons or entities other than IPA INC. they SYSTEMS, 25. Defeñdant, IPA SYSTEMS, INC. denies each and every allegation coñtaiñed in "25" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertaiñ to persons or entities other than IPA SYSTEMS, INC. 26. Defendant, IPA SYSTEMS, INC. denies each and every allegation contaiñed in "26" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. AS AND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION 27. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every "1" "26" Plaintiffs' answer heretofore made to Paragraphs through of Standard Complaint. {N0789531-1) 5 5 of 26 FILED: FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03:51 PM PM1 INDEX I N DEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 28. Defeñdañt, IPA SYSTEMS, INC. does not answer the allegations contained in "28" Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant. 29. Defendant, IPA SYSTEMS, INC. does not answer the allegations contained in "29" Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant. 30. Defendant, IPA SYSTEMS, INC. does not answer the allegations coñtaiñed in "30" Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant 31. Defendant, IPA SYSTEMS, INC. does not answer the allegations contained in "31" Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant. 32. Defendant, IPA SYSTEMS, INC. does not answer the allegations contained in "32" Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant. 33. Defendant, IPA SYSTEMS, INC. does not answer the allegations contained in "33" Paragraph of Plaintiff's Standard Complaint as same do not apply to this Defendant. AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION 34. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every "1" "33" Plaintiffs' answer heretofore made to Paragraphs through of Standard Complaint. 35. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "35" Paragraph of the Stañdard Complaiñt, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 36. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "36" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. {N078953 1-1 } 6 6 of 26 FILED:: [FILED NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03: 51 PM PM| INDEX I NDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 37. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "37" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 38. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "38" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 39. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "39" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 40. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "40" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 41. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "41" Paragraph of the Standard Coroplaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 42. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "42" "42" Paragraph (a) through (1) of Plaintiff's Standard Complaint, and refers all questions of law to this Court for determination at the time of trial,and Defendant IPA SYSTEMS, INC. (N0789531-l} 7 7 of 26 FILED: FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03:51 PM PM| INDEX INDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 denies any knowledge or information sufficient to form a belief as to the truth of each and every "42" "42" allegation contained in Paragraph (a) through (1) of Plaintiff's Stañdard Complaint as itpertains to the remaining defendants in the Standard Complaint. 43. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "43" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. AS AND FOR AN ANSWER TO THE FIFTH CAUSE ACTION 44. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every "1" "43" Plaintiffs' answer heretofore made to Paragraphs through of Standard Complaint. 45. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "45" Paragraph of the Standard Complaint; insofar as they pertain to IPA SYSTEMS, INC. and denies any kñ0wledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 46. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "46" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegatinits insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 47. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "47" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. (N0789531-1} 8 8 of 26 FILED: FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03:51 PM PM| INDEX INDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 48. Defendant, IPA SYSTEMS, INC. denies each and every allegation coñtained in "48" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 49. Defendant, IPA SYSTEMS, INC. denies each and every allegation contaiñed in "49" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to fonn a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. 50. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "50" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or cütities other than IPA SYSTEMS, INC. 51. Defendant, IPA SYSTEMS, INC. denies each and every allegation coñtained in "51" "51" Paragraph (a) through (i) of Plaintiff's Standard Complaint, and refers all questions of law to this Court for determination at the time of trial, and Defendant, IPA SYSTEMS, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every "51" "51" allegation contained in Paragraph (a) through (i)of Plaintiff's Standard Complaint as itpertains to the remaining defendants in the Standard Complaint. 52. Defendant, IPA SYSTEMS, INC. denies each and every allegation coñtaiñêd in "52" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. {N078953I-1} 9 9 of 26 FILED: FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK CLERK 04/23/2019 11/02/2018 03:14 03:51 PM PM1 INDEX INDEX NO. NO. 190225/2018 190225/2018 NYSCEF NYSCEF DOC. DOC. NO. NO. 67 146 RECEIVED RECEIVED NYSCEF: NYSCEF: 04/23/2019 11/02/2018 53. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained in "53" Paragraph of the Standard Complaint, insofar as they pertain to IPA SYSTEMS, INC. and denies any knowledge or information sufficient to form a belief as to the truth of those allegations insofar as they pertain to persons or entities other than IPA SYSTEMS, INC. AS AND FOR AN ANSWER TO THE SIXTH CAUSE OF ACTION 54. Defendant IPA SYSTEMS, INC. repeats, reiterates and realleges each and every "1" "53" Plaintiffs' answer heretofore made to Paragraphs through of Standard Complaint. 55. Defendant, IPA SYSTEMS, INC. denies each and every allegation contained