On March 30, 2022 a
Answer
was filed
involving a dispute between
Frank Mehwald,
Mary Mehwald,
The Atlantic Tool & Die Company,
and
Albert N Salvatore,
Clifford Croley,
Connick Law, Llc,
Croley, Martell & Assoc Ltd,
Daniel Prugar,
Franklin Hickman,
Hickman And Lowder Co., Lpa Registered Agent Franklin Hickman,
Jennifer Dumm,
John Harrison,
John Kim,
Kim & Associates, Llc,
Marvin Sicherman,
Matthew Gomes,
Michael Mehwald,
Patrick Moore,
Robert E Blackham,
Roetzel & Andress, Lpa A Legal Professional Association,
Thomas Connick,
Weinberg, Wheeler, Hudgins, Gunn & Dial, Llc,
for TORT-MISCELLANEOUS
in the District Court of Cuyahoga County.
Preview
NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
ANSWER OF...
October 11,2022 07:40
By: THOMAS A. BARNI0064555
Confirmation Nbr. 2672993
ATLANTIC TOOL & DIE COMPANY, ET AL. CV 22 961394
vs.
Judge: DAVID T.MATIA
MICHAEL MEH WALD, ET AL.
Pages Filed: 25
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in the court of common pleas
cuyahoga county, ohio
The Atlantic Tool & Die Co., et al., : CASE NO. CV 22 961394
Plaintiffs, : JUDGE DAVID T. MATIA
v. :
Michael Mehwald, et al., :
Defendants. :
JOINT ANSWER OF DEFENDANTS,
CROLEY, MARTELL & ASSOC., LTD. AND CLIFFORD CROLEY
TO PLAINTIFFS' FIRST AMENDED COMPLAINT
Defendants, Croley, Martell & Assoc., Ltd. and Clifford Croley (collectively "Croley"), for
their Joint Answer to the First Amended Complaint of Plaintiffs, The Atlantic Tool & Die Co.
("ATD"), Frank Mehwald ("F. Mehwald") and Mary Mehwald ("M. Mehwald", and collectively
"Plaintiffs"), state:
FIRST DEFENSE
1. Admit the allegations contained in Paragraph 1 of Plaintiffs' First Amended
Complaint.
2. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 2 of Plaintiffs' First Amended Complaint.
3. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 3 of Plaintiffs' First Amended Complaint.
4. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 4 of Plaintiffs' First Amended Complaint.
5. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 5 of Plaintiffs' First Amended Complaint.
6. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 6 of Plaintiffs' First Amended Complaint.
7. Admit Defendant Clifford Croley is a resident of the City of Akron, and deny the
remaining allegations contained in Paragraph 7 of Plaintiffs' First Amended Complaint.
8. Admit the allegations contained in Paragraph 8 of Plaintiffs' First Amended
Complaint.
9. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 9 of Plaintiffs' First Amended Complaint.
10. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 10 of Plaintiffs' First Amended Complaint.
11. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 11 of Plaintiffs' First Amended Complaint.
12. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 12 of Plaintiffs' First Amended Complaint.
13. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 13 of Plaintiffs' First Amended Complaint.
14. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 14 of Plaintiffs' First Amended Complaint.
15. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 15 of Plaintiffs' First Amended Complaint.
16. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 16 of Plaintiffs' First Amended Complaint.
17. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 17 of Plaintiffs' First Amended Complaint.
18. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 18 of Plaintiffs' First Amended Complaint.
19. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 19 of Plaintiffs' First Amended Complaint.
20. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 20 of Plaintiffs' First Amended Complaint.
21. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 21 of Plaintiffs' First Amended Complaint.
22. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 22 of Plaintiffs' First Amended Complaint.
23. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 23 of Plaintiffs' First Amended Complaint.
24. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 24 of Plaintiffs' First Amended Complaint.
25. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 25 of Plaintiffs' First Amended Complaint.
26. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 26 of Plaintiffs' First Amended Complaint.
27. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 27 of Plaintiffs' First Amended Complaint.
28. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 28 of Plaintiffs' First Amended Complaint.
29. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 29 of Plaintiffs' First Amended Complaint.
30. Deny the allegations contained in Paragraph 30 of Plaintiffs' First Amended
Complaint.
31. Deny the allegations contained in Paragraph 31 of Plaintiffs' First Amended
Complaint.
32. Deny the allegations contained in Paragraph 32 of Plaintiffs' First Amended
Complaint.
33. Deny the allegations contained in Paragraph 33 of Plaintiffs' First Amended
Complaint.
34. Deny the allegations contained in Paragraph 34 of Plaintiffs' First Amended
Complaint.
35. Deny the allegations contained in Paragraph 35 of Plaintiffs' First Amended
Complaint.
36. Deny the allegations contained in Paragraph 36 of Plaintiffs' First Amended
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Complaint.
37. Admit the allegations contained in Paragraph 37 of Plaintiffs' First Amended
Complaint.
38. Deny the allegations contained in Paragraph 38 of Plaintiffs' First Amended
Complaint.
39. Deny the allegations contained in Paragraph 39 of Plaintiffs' First Amended
Complaint.
40. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 40 of Plaintiffs' First Amended Complaint.
41. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 41 of Plaintiffs' First Amended Complaint.
42. Deny the allegations contained in Paragraph 42 of Plaintiffs' First Amended
Complaint.
43. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 43 of Plaintiffs' First Amended Complaint.
44. Deny the allegations contained in Paragraph 44 of Plaintiffs' First Amended
Complaint.
45. Deny the allegations contained in Paragraph 45 of Plaintiffs' First Amended
Complaint.
46. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 46 of Plaintiffs' First Amended Complaint.
47. Deny the allegations contained in Paragraph 47 of Plaintiffs' First Amended
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Complaint.
48. Deny the allegations contained in Paragraph 48 of Plaintiffs' First Amended
Complaint.
49. Deny the allegations contained in Paragraph 49 of Plaintiffs' First Amended
Complaint.
50. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 50 of Plaintiffs' First Amended Complaint.
51. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 51 of Plaintiffs' First Amended Complaint.
52. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 52 of Plaintiffs' First Amended Complaint.
53. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 53 of Plaintiffs' First Amended Complaint.
54. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 54 of Plaintiffs' First Amended Complaint.
55. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 55 of Plaintiffs' First Amended Complaint.
56. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 56 of Plaintiffs' First Amended Complaint.
57. Deny the allegations contained in Paragraph 57 of Plaintiffs' First Amended
Complaint.
58. Deny the allegations contained in Paragraph 58 of Plaintiffs' First Amended
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Complaint.
59. Admit the allegations contained in Paragraph 59 of Plaintiffs' First Amended
Complaint.
60. Deny the allegations contained in Paragraph 60 of Plaintiffs' First Amended
Complaint.
61. Deny the allegations contained in Paragraph 61 of Plaintiffs' First Amended
Complaint.
62. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 62 of Plaintiffs' First Amended Complaint.
63. Deny the allegations contained in Paragraph 63 of Plaintiffs' First Amended
Complaint.
64. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 64 of Plaintiffs' First Amended Complaint.
65. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 65 of Plaintiffs' First Amended Complaint.
66. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 66 of Plaintiffs' First Amended Complaint.
67. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 67 of Plaintiffs' First Amended Complaint.
68. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 68 of Plaintiffs' First Amended Complaint.
69. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 69 of Plaintiffs' First Amended Complaint.
70. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 70 of Plaintiffs' First Amended Complaint.
71. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 71 of Plaintiffs' First Amended Complaint.
72. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 72 of Plaintiffs' First Amended Complaint.
73. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 73 of Plaintiffs' First Amended Complaint.
74. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 74 of Plaintiffs' First Amended Complaint.
75. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 75 of Plaintiffs' First Amended Complaint.
76. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 76 of Plaintiffs' First Amended Complaint.
77. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 77 of Plaintiffs' First Amended Complaint.
78. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 78 of Plaintiffs' First Amended Complaint.
79. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 79 of Plaintiffs' First Amended Complaint.
80. Admit that I did sign an Affidavit, and deny the remaining allegations contained in
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Paragraph 80 of Plaintiffs' First Amended Complaint.
81. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 81 of Plaintiffs' First Amended Complaint.
82. Admit that I did sign an Affidavit, and deny the remaining allegations contained in
Paragraph 82 of Plaintiffs' First Amended Complaint.
83. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 83 of Plaintiffs' First Amended Complaint.
84. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 84 of Plaintiffs' First Amended Complaint.
85. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 85 of Plaintiffs' First Amended Complaint.
86. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 86 of Plaintiffs' First Amended Complaint.
87. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 87 of Plaintiffs' First Amended Complaint.
88. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 88 of Plaintiffs' First Amended Complaint.
89. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 89 of Plaintiffs' First Amended Complaint.
90. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 90 of Plaintiffs' First Amended Complaint.
91. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 91 of Plaintiffs' First Amended Complaint.
92. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 92 of Plaintiffs' First Amended Complaint.
93. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 93 of Plaintiffs' First Amended Complaint.
94. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 94 of Plaintiffs' First Amended Complaint.
95. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 95 of Plaintiffs' First Amended Complaint.
96. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 96 of Plaintiffs' First Amended Complaint.
97. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 97 of Plaintiffs' First Amended Complaint.
98. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 98 of Plaintiffs' First Amended Complaint.
99. Deny the allegations contained in Paragraph 99 of Plaintiffs' First Amended
Complaint.
100. Deny the allegations contained in Paragraph 100 of Plaintiffs' First Amended
Complaint.
101. Deny the allegations contained in Paragraph 101 of Plaintiffs' First Amended
Complaint.
102. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 102 of Plaintiffs' First Amended Complaint.
103. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 103 of Plaintiffs' First Amended Complaint.
104. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 104 of Plaintiffs' First Amended Complaint.
105. Deny the allegations contained in Paragraph 105 of Plaintiffs' First Amended
Complaint.
106. Deny the allegations contained in Paragraph 106 of Plaintiffs' First Amended
Complaint.
107. Deny the allegations contained in Paragraph 107 of Plaintiffs' First Amended
Complaint.
108. Deny the allegations contained in Paragraph 108 of Plaintiffs' First Amended
Complaint.
109. Deny the allegations contained in Paragraph 109 of Plaintiffs' First Amended
Complaint.
110. Deny the allegations contained in Paragraph 110 of Plaintiffs' First Amended
Complaint.
111. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 111 of Plaintiffs' First Amended Complaint.
112. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 112 of Plaintiffs' First Amended Complaint.
113. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 113 of Plaintiffs' First Amended Complaint.
114. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 114 of Plaintiffs' First Amended Complaint.
115. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 115 of Plaintiffs' First Amended Complaint.
116. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 116 of Plaintiffs' First Amended Complaint.
117. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 117 of Plaintiffs' First Amended Complaint.
118. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 118 of Plaintiffs' First Amended Complaint.
119. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 119 of Plaintiffs' First Amended Complaint.
120. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 120 of Plaintiffs' First Amended Complaint.
121. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 121 of Plaintiffs' First Amended Complaint.
122. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 122 of Plaintiffs' First Amended Complaint.
123. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 123 of Plaintiffs' First Amended Complaint.
124. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 124 of Plaintiffs' First Amended Complaint.
125. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 125 of Plaintiffs' First Amended Complaint.
126. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 126 of Plaintiffs' First Amended Complaint.
127. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 12762 of Plaintiffs' First Amended Complaint.
128. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 128 of Plaintiffs' First Amended Complaint.
129. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 129 of Plaintiffs' First Amended Complaint.
130. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 130 of Plaintiffs' First Amended Complaint.
131. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 131 of Plaintiffs' First Amended Complaint.
132. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 132 of Plaintiffs' First Amended Complaint.
133. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 133 of Plaintiffs' First Amended Complaint.
134. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 134 of Plaintiffs' First Amended Complaint.
135. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 135 of Plaintiffs' First Amended Complaint.
136. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 136 of Plaintiffs' First Amended Complaint.
137. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 137 of Plaintiffs' First Amended Complaint.
138. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 138 of Plaintiffs' First Amended Complaint.
139. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 139 of Plaintiffs' First Amended Complaint.
140. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 140 of Plaintiffs' First Amended Complaint.
141. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 141 of Plaintiffs' First Amended Complaint.
142. Deny the allegations contained in Paragraph 142 of Plaintiffs' First Amended
Complaint.
143. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 143 of Plaintiffs' First Amended Complaint.
144. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 144 of Plaintiffs' First Amended Complaint.
145. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 145 of Plaintiffs' First Amended Complaint.
146. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 146 of Plaintiffs' First Amended Complaint.
147. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 147 of Plaintiffs' First Amended Complaint.
148. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 148 of Plaintiffs' First Amended Complaint.
149. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 149 of Plaintiffs' First Amended Complaint.
150. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 150 of Plaintiffs' First Amended Complaint.
151. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 151 of Plaintiffs' First Amended Complaint.
152. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 152 of Plaintiffs' First Amended Complaint.
153. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 153 of Plaintiffs' First Amended Complaint.
154. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 154 of Plaintiffs' First Amended Complaint.
155. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 155 of Plaintiffs' First Amended Complaint.
156. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 156 of Plaintiffs' First Amended Complaint.
157. Deny for want of knowledge or lack of information sufficient to form a belief as to
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the truth of the allegations contained in Paragraph 157 of Plaintiffs' First Amended Complaint.
158. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 158 of Plaintiffs' First Amended Complaint.
159. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 159 of Plaintiffs' First Amended Complaint.
160. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 160 of Plaintiffs' First Amended Complaint.
161. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 161 of Plaintiffs' First Amended Complaint.
162. Croley restate and reallege all of their responses contained in Paragraphs 1 through
161 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein.
163. Deny the allegations contained in Paragraph 163 of Plaintiffs' First Amended
Complaint.
164. Deny the allegations contained in Paragraph 164 of Plaintiffs' First Amended
Complaint.
165. Deny the allegations contained in Paragraph 165 of Plaintiffs' First Amended
Complaint.
166. Deny the allegations contained in Paragraph 166 of Plaintiffs' First Amended
Complaint.
167. Deny the allegations contained in Paragraph 167 of Plaintiffs' First Amended
Complaint.
168. Deny the allegations contained in Paragraph 168 of Plaintiffs' First Amended
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Complaint.
169. Deny the allegations contained in Paragraph 169 of Plaintiffs' First Amended
Complaint.
170. Deny the allegations contained in Paragraph 170 of Plaintiffs' First Amended
Complaint.
171. Croley restate and reallege all of their responses contained in Paragraphs 1 through
170 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein.
172. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 172 of Plaintiffs' First Amended Complaint.
173. Deny the allegations contained in Paragraph 173 of Plaintiffs' First Amended
Complaint.
174. Deny the allegations contained in Paragraph 174 of Plaintiffs' First Amended
Complaint.
175. Deny the allegations contained in Paragraph 175 of Plaintiffs' First Amended
Complaint.
176. Croley restate and reallege all of their responses contained in Paragraphs 1 through
175 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein.
177. Deny the allegations contained in Paragraph 177 of Plaintiffs' First Amended
Complaint.
178. Deny the allegations contained in Paragraph 178 of Plaintiffs' First Amended
Complaint.
179. Deny the allegations contained in Paragraph 179 of Plaintiffs' First Amended
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Complaint.
180. Deny the allegations contained in Paragraph 180 of Plaintiffs' First Amended
Complaint.
181. Deny the allegations contained in Paragraph 181 of Plaintiffs' First Amended
Complaint.
182. Deny the allegations contained in Paragraph 182 of Plaintiffs' First Amended
Complaint.
183. Croley restate and reallege all of their responses contained in Paragraphs 1 through
182 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein.
184. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 184 of Plaintiffs' First Amended Complaint.
185. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 185 of Plaintiffs' First Amended Complaint.
186. Deny the allegations contained in Paragraph 186 of Plaintiffs' First Amended
Complaint.
187. Deny the allegations contained in Paragraph 187 of Plaintiffs' First Amended
Complaint.
188. Deny the allegations contained in Paragraph 188 of Plaintiffs' First Amended
Complaint.
189. Deny the allegations contained in Paragraph 189 of Plaintiffs' First Amended
Complaint.
190. Deny the allegations contained in Paragraph 190 of Plaintiffs' First Amended
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Complaint.
191. Croley restate and reallege all of their responses contained in Paragraphs 1 through
190 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein.
192. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 192 of Plaintiffs' First Amended Complaint.
193. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 193 of Plaintiffs' First Amended Complaint.
194. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 194 of Plaintiffs' First Amended Complaint.
195. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 195 of Plaintiffs' First Amended Complaint.
196. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 196 of Plaintiffs' First Amended Complaint.
197. Croley restate and reallege all of their responses contained in Paragraphs 1 through
196 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein.
198. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 198 of Plaintiffs' First Amended Complaint.
199. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 199 of Plaintiffs' First Amended Complaint.
200. Deny for want of knowledge or lack of information sufficient to form a belief as to
the truth of the allega
Document Filed Date
October 11, 2022
Case Filing Date
March 30, 2022
Category
TORT-MISCELLANEOUS
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NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas ANSWER OF... October 11,2022 07:40 By: THOMAS A. BARNI0064555 Confirmation Nbr. 2672993 ATLANTIC TOOL & DIE COMPANY, ET AL. CV 22 961394 vs. Judge: DAVID T.MATIA MICHAEL MEH WALD, ET AL. Pages Filed: 25 Electronically Filed 10/11/2022 07:40/ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH in the court of common pleas cuyahoga county, ohio The Atlantic Tool & Die Co., et al., : CASE NO. CV 22 961394 Plaintiffs, : JUDGE DAVID T. MATIA v. : Michael Mehwald, et al., : Defendants. : JOINT ANSWER OF DEFENDANTS, CROLEY, MARTELL & ASSOC., LTD. AND CLIFFORD CROLEY TO PLAINTIFFS' FIRST AMENDED COMPLAINT Defendants, Croley, Martell & Assoc., Ltd. and Clifford Croley (collectively "Croley"), for their Joint Answer to the First Amended Complaint of Plaintiffs, The Atlantic Tool & Die Co. ("ATD"), Frank Mehwald ("F. Mehwald") and Mary Mehwald ("M. Mehwald", and collectively "Plaintiffs"), state: FIRST DEFENSE 1. Admit the allegations contained in Paragraph 1 of Plaintiffs' First Amended Complaint. 2. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 2 of Plaintiffs' First Amended Complaint. 3. Deny for want of knowledge or lack of information sufficient to form a belief as to 1 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 3 of Plaintiffs' First Amended Complaint. 4. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 4 of Plaintiffs' First Amended Complaint. 5. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 5 of Plaintiffs' First Amended Complaint. 6. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 6 of Plaintiffs' First Amended Complaint. 7. Admit Defendant Clifford Croley is a resident of the City of Akron, and deny the remaining allegations contained in Paragraph 7 of Plaintiffs' First Amended Complaint. 8. Admit the allegations contained in Paragraph 8 of Plaintiffs' First Amended Complaint. 9. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 9 of Plaintiffs' First Amended Complaint. 10. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 10 of Plaintiffs' First Amended Complaint. 11. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 11 of Plaintiffs' First Amended Complaint. 12. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 12 of Plaintiffs' First Amended Complaint. 13. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 13 of Plaintiffs' First Amended Complaint. 14. Deny for want of knowledge or lack of information sufficient to form a belief as to 2 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 14 of Plaintiffs' First Amended Complaint. 15. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 15 of Plaintiffs' First Amended Complaint. 16. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 16 of Plaintiffs' First Amended Complaint. 17. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 17 of Plaintiffs' First Amended Complaint. 18. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 18 of Plaintiffs' First Amended Complaint. 19. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 19 of Plaintiffs' First Amended Complaint. 20. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 20 of Plaintiffs' First Amended Complaint. 21. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 21 of Plaintiffs' First Amended Complaint. 22. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 22 of Plaintiffs' First Amended Complaint. 23. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 23 of Plaintiffs' First Amended Complaint. 24. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 24 of Plaintiffs' First Amended Complaint. 25. Deny for want of knowledge or lack of information sufficient to form a belief as to 3 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 25 of Plaintiffs' First Amended Complaint. 26. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 26 of Plaintiffs' First Amended Complaint. 27. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 27 of Plaintiffs' First Amended Complaint. 28. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 28 of Plaintiffs' First Amended Complaint. 29. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 29 of Plaintiffs' First Amended Complaint. 30. Deny the allegations contained in Paragraph 30 of Plaintiffs' First Amended Complaint. 31. Deny the allegations contained in Paragraph 31 of Plaintiffs' First Amended Complaint. 32. Deny the allegations contained in Paragraph 32 of Plaintiffs' First Amended Complaint. 33. Deny the allegations contained in Paragraph 33 of Plaintiffs' First Amended Complaint. 34. Deny the allegations contained in Paragraph 34 of Plaintiffs' First Amended Complaint. 35. Deny the allegations contained in Paragraph 35 of Plaintiffs' First Amended Complaint. 36. Deny the allegations contained in Paragraph 36 of Plaintiffs' First Amended 4 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH Complaint. 37. Admit the allegations contained in Paragraph 37 of Plaintiffs' First Amended Complaint. 38. Deny the allegations contained in Paragraph 38 of Plaintiffs' First Amended Complaint. 39. Deny the allegations contained in Paragraph 39 of Plaintiffs' First Amended Complaint. 40. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 40 of Plaintiffs' First Amended Complaint. 41. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 41 of Plaintiffs' First Amended Complaint. 42. Deny the allegations contained in Paragraph 42 of Plaintiffs' First Amended Complaint. 43. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 43 of Plaintiffs' First Amended Complaint. 44. Deny the allegations contained in Paragraph 44 of Plaintiffs' First Amended Complaint. 45. Deny the allegations contained in Paragraph 45 of Plaintiffs' First Amended Complaint. 46. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 46 of Plaintiffs' First Amended Complaint. 47. Deny the allegations contained in Paragraph 47 of Plaintiffs' First Amended 5 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH Complaint. 48. Deny the allegations contained in Paragraph 48 of Plaintiffs' First Amended Complaint. 49. Deny the allegations contained in Paragraph 49 of Plaintiffs' First Amended Complaint. 50. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 50 of Plaintiffs' First Amended Complaint. 51. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 51 of Plaintiffs' First Amended Complaint. 52. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 52 of Plaintiffs' First Amended Complaint. 53. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 53 of Plaintiffs' First Amended Complaint. 54. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 54 of Plaintiffs' First Amended Complaint. 55. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 55 of Plaintiffs' First Amended Complaint. 56. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 56 of Plaintiffs' First Amended Complaint. 57. Deny the allegations contained in Paragraph 57 of Plaintiffs' First Amended Complaint. 58. Deny the allegations contained in Paragraph 58 of Plaintiffs' First Amended 6 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH Complaint. 59. Admit the allegations contained in Paragraph 59 of Plaintiffs' First Amended Complaint. 60. Deny the allegations contained in Paragraph 60 of Plaintiffs' First Amended Complaint. 61. Deny the allegations contained in Paragraph 61 of Plaintiffs' First Amended Complaint. 62. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 62 of Plaintiffs' First Amended Complaint. 63. Deny the allegations contained in Paragraph 63 of Plaintiffs' First Amended Complaint. 64. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 64 of Plaintiffs' First Amended Complaint. 65. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 65 of Plaintiffs' First Amended Complaint. 66. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 66 of Plaintiffs' First Amended Complaint. 67. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 67 of Plaintiffs' First Amended Complaint. 68. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 68 of Plaintiffs' First Amended Complaint. 69. Deny for want of knowledge or lack of information sufficient to form a belief as to 7 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 69 of Plaintiffs' First Amended Complaint. 70. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 70 of Plaintiffs' First Amended Complaint. 71. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 71 of Plaintiffs' First Amended Complaint. 72. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 72 of Plaintiffs' First Amended Complaint. 73. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 73 of Plaintiffs' First Amended Complaint. 74. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 74 of Plaintiffs' First Amended Complaint. 75. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 75 of Plaintiffs' First Amended Complaint. 76. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 76 of Plaintiffs' First Amended Complaint. 77. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 77 of Plaintiffs' First Amended Complaint. 78. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 78 of Plaintiffs' First Amended Complaint. 79. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 79 of Plaintiffs' First Amended Complaint. 80. Admit that I did sign an Affidavit, and deny the remaining allegations contained in 8 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH Paragraph 80 of Plaintiffs' First Amended Complaint. 81. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 81 of Plaintiffs' First Amended Complaint. 82. Admit that I did sign an Affidavit, and deny the remaining allegations contained in Paragraph 82 of Plaintiffs' First Amended Complaint. 83. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 83 of Plaintiffs' First Amended Complaint. 84. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 84 of Plaintiffs' First Amended Complaint. 85. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 85 of Plaintiffs' First Amended Complaint. 86. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 86 of Plaintiffs' First Amended Complaint. 87. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 87 of Plaintiffs' First Amended Complaint. 88. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 88 of Plaintiffs' First Amended Complaint. 89. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 89 of Plaintiffs' First Amended Complaint. 90. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 90 of Plaintiffs' First Amended Complaint. 91. Deny for want of knowledge or lack of information sufficient to form a belief as to 9 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 91 of Plaintiffs' First Amended Complaint. 92. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 92 of Plaintiffs' First Amended Complaint. 93. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 93 of Plaintiffs' First Amended Complaint. 94. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 94 of Plaintiffs' First Amended Complaint. 95. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 95 of Plaintiffs' First Amended Complaint. 96. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 96 of Plaintiffs' First Amended Complaint. 97. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 97 of Plaintiffs' First Amended Complaint. 98. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 98 of Plaintiffs' First Amended Complaint. 99. Deny the allegations contained in Paragraph 99 of Plaintiffs' First Amended Complaint. 100. Deny the allegations contained in Paragraph 100 of Plaintiffs' First Amended Complaint. 101. Deny the allegations contained in Paragraph 101 of Plaintiffs' First Amended Complaint. 102. Deny for want of knowledge or lack of information sufficient to form a belief as to 10 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 102 of Plaintiffs' First Amended Complaint. 103. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 103 of Plaintiffs' First Amended Complaint. 104. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 104 of Plaintiffs' First Amended Complaint. 105. Deny the allegations contained in Paragraph 105 of Plaintiffs' First Amended Complaint. 106. Deny the allegations contained in Paragraph 106 of Plaintiffs' First Amended Complaint. 107. Deny the allegations contained in Paragraph 107 of Plaintiffs' First Amended Complaint. 108. Deny the allegations contained in Paragraph 108 of Plaintiffs' First Amended Complaint. 109. Deny the allegations contained in Paragraph 109 of Plaintiffs' First Amended Complaint. 110. Deny the allegations contained in Paragraph 110 of Plaintiffs' First Amended Complaint. 111. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 111 of Plaintiffs' First Amended Complaint. 112. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 112 of Plaintiffs' First Amended Complaint. 113. Deny for want of knowledge or lack of information sufficient to form a belief as to 11 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 113 of Plaintiffs' First Amended Complaint. 114. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 114 of Plaintiffs' First Amended Complaint. 115. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 115 of Plaintiffs' First Amended Complaint. 116. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 116 of Plaintiffs' First Amended Complaint. 117. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 117 of Plaintiffs' First Amended Complaint. 118. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 118 of Plaintiffs' First Amended Complaint. 119. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 119 of Plaintiffs' First Amended Complaint. 120. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 120 of Plaintiffs' First Amended Complaint. 121. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 121 of Plaintiffs' First Amended Complaint. 122. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 122 of Plaintiffs' First Amended Complaint. 123. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 123 of Plaintiffs' First Amended Complaint. 124. Deny for want of knowledge or lack of information sufficient to form a belief as to 12 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 124 of Plaintiffs' First Amended Complaint. 125. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 125 of Plaintiffs' First Amended Complaint. 126. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 126 of Plaintiffs' First Amended Complaint. 127. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 12762 of Plaintiffs' First Amended Complaint. 128. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 128 of Plaintiffs' First Amended Complaint. 129. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 129 of Plaintiffs' First Amended Complaint. 130. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 130 of Plaintiffs' First Amended Complaint. 131. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 131 of Plaintiffs' First Amended Complaint. 132. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 132 of Plaintiffs' First Amended Complaint. 133. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 133 of Plaintiffs' First Amended Complaint. 134. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 134 of Plaintiffs' First Amended Complaint. 135. Deny for want of knowledge or lack of information sufficient to form a belief as to 13 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 135 of Plaintiffs' First Amended Complaint. 136. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 136 of Plaintiffs' First Amended Complaint. 137. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 137 of Plaintiffs' First Amended Complaint. 138. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 138 of Plaintiffs' First Amended Complaint. 139. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 139 of Plaintiffs' First Amended Complaint. 140. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 140 of Plaintiffs' First Amended Complaint. 141. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 141 of Plaintiffs' First Amended Complaint. 142. Deny the allegations contained in Paragraph 142 of Plaintiffs' First Amended Complaint. 143. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 143 of Plaintiffs' First Amended Complaint. 144. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 144 of Plaintiffs' First Amended Complaint. 145. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 145 of Plaintiffs' First Amended Complaint. 146. Deny for want of knowledge or lack of information sufficient to form a belief as to 14 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 146 of Plaintiffs' First Amended Complaint. 147. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 147 of Plaintiffs' First Amended Complaint. 148. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 148 of Plaintiffs' First Amended Complaint. 149. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 149 of Plaintiffs' First Amended Complaint. 150. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 150 of Plaintiffs' First Amended Complaint. 151. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 151 of Plaintiffs' First Amended Complaint. 152. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 152 of Plaintiffs' First Amended Complaint. 153. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 153 of Plaintiffs' First Amended Complaint. 154. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 154 of Plaintiffs' First Amended Complaint. 155. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 155 of Plaintiffs' First Amended Complaint. 156. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 156 of Plaintiffs' First Amended Complaint. 157. Deny for want of knowledge or lack of information sufficient to form a belief as to 15 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH the truth of the allegations contained in Paragraph 157 of Plaintiffs' First Amended Complaint. 158. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 158 of Plaintiffs' First Amended Complaint. 159. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 159 of Plaintiffs' First Amended Complaint. 160. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 160 of Plaintiffs' First Amended Complaint. 161. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 161 of Plaintiffs' First Amended Complaint. 162. Croley restate and reallege all of their responses contained in Paragraphs 1 through 161 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein. 163. Deny the allegations contained in Paragraph 163 of Plaintiffs' First Amended Complaint. 164. Deny the allegations contained in Paragraph 164 of Plaintiffs' First Amended Complaint. 165. Deny the allegations contained in Paragraph 165 of Plaintiffs' First Amended Complaint. 166. Deny the allegations contained in Paragraph 166 of Plaintiffs' First Amended Complaint. 167. Deny the allegations contained in Paragraph 167 of Plaintiffs' First Amended Complaint. 168. Deny the allegations contained in Paragraph 168 of Plaintiffs' First Amended 16 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH Complaint. 169. Deny the allegations contained in Paragraph 169 of Plaintiffs' First Amended Complaint. 170. Deny the allegations contained in Paragraph 170 of Plaintiffs' First Amended Complaint. 171. Croley restate and reallege all of their responses contained in Paragraphs 1 through 170 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein. 172. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 172 of Plaintiffs' First Amended Complaint. 173. Deny the allegations contained in Paragraph 173 of Plaintiffs' First Amended Complaint. 174. Deny the allegations contained in Paragraph 174 of Plaintiffs' First Amended Complaint. 175. Deny the allegations contained in Paragraph 175 of Plaintiffs' First Amended Complaint. 176. Croley restate and reallege all of their responses contained in Paragraphs 1 through 175 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein. 177. Deny the allegations contained in Paragraph 177 of Plaintiffs' First Amended Complaint. 178. Deny the allegations contained in Paragraph 178 of Plaintiffs' First Amended Complaint. 179. Deny the allegations contained in Paragraph 179 of Plaintiffs' First Amended 17 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH Complaint. 180. Deny the allegations contained in Paragraph 180 of Plaintiffs' First Amended Complaint. 181. Deny the allegations contained in Paragraph 181 of Plaintiffs' First Amended Complaint. 182. Deny the allegations contained in Paragraph 182 of Plaintiffs' First Amended Complaint. 183. Croley restate and reallege all of their responses contained in Paragraphs 1 through 182 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein. 184. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 184 of Plaintiffs' First Amended Complaint. 185. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 185 of Plaintiffs' First Amended Complaint. 186. Deny the allegations contained in Paragraph 186 of Plaintiffs' First Amended Complaint. 187. Deny the allegations contained in Paragraph 187 of Plaintiffs' First Amended Complaint. 188. Deny the allegations contained in Paragraph 188 of Plaintiffs' First Amended Complaint. 189. Deny the allegations contained in Paragraph 189 of Plaintiffs' First Amended Complaint. 190. Deny the allegations contained in Paragraph 190 of Plaintiffs' First Amended 18 Electronically Filed 10/11/2022 07:40 / ANSWERS / CV 22 961394 / Confirmation Nbr. 2672993 / BATCH Complaint. 191. Croley restate and reallege all of their responses contained in Paragraphs 1 through 190 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein. 192. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 192 of Plaintiffs' First Amended Complaint. 193. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 193 of Plaintiffs' First Amended Complaint. 194. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 194 of Plaintiffs' First Amended Complaint. 195. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 195 of Plaintiffs' First Amended Complaint. 196. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 196 of Plaintiffs' First Amended Complaint. 197. Croley restate and reallege all of their responses contained in Paragraphs 1 through 196 of their Joint Answer to Plaintiffs' First Amended Complaint as if fully rewritten herein. 198. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 198 of Plaintiffs' First Amended Complaint. 199. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allegations contained in Paragraph 199 of Plaintiffs' First Amended Complaint. 200. Deny for want of knowledge or lack of information sufficient to form a belief as to the truth of the allega