On January 10, 2017 a
Answer
was filed
involving a dispute between
Stacey Lynn Brown As Administratrix Of The Estate Of Steven L. Hall, Deceased,
and
Ace Hardware,
Ace Hardware Corporation,
Air & Liquid Systems Corporation, As Successor By Merger To Buffalo Pumps, Inc.,
Alfa Laval, Inc.,
Allegheny Teledyne Incorporated, Individually And As Successor To Allegheny Technologies Incorporated And Farris Valves And Or Sprague Pumps,
Amec Construction Management, Inc.,
American Biltrite, Inc., Individually And Successor To Amtico Floors,
Amtrol, Inc., Individually And As Successor To Thrush Products, Inc.,
A.O. Smith Water Products,
Armstrong International, Inc.,
Atwood & Morrill Co., Inc. D B A Weir Valves & Controls Usa Inc.,
Auburn Technology, Inc. F K A Alco Power, Inc.,
Aurora Pump Company,
Bechtel Corporation,
Blackmer Pump,
Borgwarner Morse Tec Llc,
Bw Ip International Co., Formerly Known As Borg Warner Industrial Products Inc., A Former Subsidiary Of And Successor To Borg Warner Corp. And Byron Jackson Pumps,
Carrier Corporation,
Cbs Corporation, A Delaware Corporation, F K A Viacom Inc, Successor By Merger To Cbs Corporation, A Pennsylvania Corporation, F K A Westinghouse Electric Corporation,
Certain-Teed Corporation,
Clark-Reliance Corporation, Individually And As Successor To Jerguson,
Cleaver-Brooks Company F K A Aqua-Chem, Inc.,
Courter & Company, Inc.,
Crane Co., Individually And As Successor To Cochrane,
Croll-Reynolds Engineering Company, Inc.,
Crosby Valve And Gage Company,
Crosby Valve, Inc.,
Cytec Engineered Materials, Inc. F K A Fiberite Corporation And A K A Ici Composites, Inc.,
Cytec Industries Inc., Individually And As Successor To American Cyanamid Company,
Dap, Inc. K N A La Mirada Products Co., Inc.,
Dean Pump Division,
Dezurik, Inc.,
Durez Corporation,
Duro Dyne Corporation,
E.I. Team, Inc. F K A J.L. Murphy, Inc.,
Electrolux Home Products, Inc., Individually And As Successor To Tappan And Copes-Vulcan,
Elliott Turbomachinery Co., Inc.,
Fairbanks Company,
Flowserve Us, Inc., Solely As Successor To Rockwell Manufacturing Company, Edward Valves, Inc., Nordstrom Valves, Inc. And Edward Vogt Valve Company,
Fmc Corporation, Individually And As Successor To Northern Pump Company, Coffin And Peerless Pump Company,
Foster Wheeler, Llc,
Gardner Denver, Inc.,
General Electric Company,
Genuine Partscompany,
George A. Fuller Company,
Georgia-Pacific Corporation, Individually And As Successor To Bestwall Gypsum Company,
Gg Of Florida, Inc., F K A Higbee, Inc.,
Goodall Rubber Co.,
Goulds Pumps, Inc.,
Greene, Tweed & Co., Llp, Individually And As Successor To Palmetto Packings,
Grinnell Corporation,
Henry Technologies, Inc.,
Hexion Specialty Chemicals, Inc. F K A Borden Chemical, Inc.,
Honeywell International, Inc., Individually And F K A Alliedsignal, Inc., And As Successor-In-Interest To The Bendix Corp.,
Howden Buffalo, Inc., Individually And As Successor-In-Interest To Fb Sturtevant, The Howden Buffalo Group And Buffalo Fan,
Imo Industries, Inc. F K A Delaval, Inc., Individually And As Successor To Turbine Equipment Company,
I.T.T. Industries, Inc., Individually And As Successor To Bell & Gossett,
I.T.T. Industries, Inc., Individually And As Successor To Hoffman Specialty, Bell & Gossett, And Foster Engineering,
Jenkins Bros.,
John Crane, Inc.,
Kaiser Gypsum Company, Inc.,
Koppers Company, Inc.,
Koppers Industries, Inc.,
Lighttolier Incorporated,
Maremont Corporation, Individually And As Successor To Grizzly,
Metropolitan Life Insurance Co.,
Morse Diesel, Inc.,
Morse Diesel International, Inc.,
Napa Auto Parts A K A National Automotive Parts Association,
Nash Engineering Company,
Northrop Grumman Corporation, Individually And As Successor To George A. Fuller Company,
Occidental Chemical Corporation, Individually And As Successor To Durez Corporation,
Owens-Illinois, Inc.,
Patterson Pump Company, A Subsidiary Of The Gorman-Rupp Company And Individually And As Successor To C.H. Wheeler Manufacturing And Griscom Russell,
Plastics Engineering Company, Individually And As Successor To Plenco,
Pneumo Abex Corporation,
Pneumo-Abex Llc, Individually And As Successor To Abex Corporation, A Delaware Corporation,
Progress Lighting, Inc.,
Research-Cottrell, Inc. N K A Awt Air Company, Inc.,
Riley Power, Inc. F K A Babcock Borsig Power, Inc. And F K A Riley Stoker Corporation D B A Db Riley, Inc.,
Rogers Corporation,
R.T Vanderbilt Company, Inc., Individually And As Successor To International Tale Co., International Pulp Co., And Governeur Tale Co., Inc.,
Sid Harvey Industries, Inc.,
Sid Harvey Supply, Inc.,
Spence Engineering Company, Inc.,
Spirax Sarco, Inc.,
Spx Cooling Technologies, Inc., Individually As Successor To Marley Cooling Technologies And Marley Cooling Towers,
Superior Lidgerwood Mundy Corp., A K A Lidgerwood Manufacturing Co., Individually And As Successor To M.T. Davidson Co.,
Thomas O'Connor & Company, Inc., Currently Known As O'Connor Constructors, Inc.,
Thrush Co., Inc.,
Treadwell Corporation,
Turner Construction Company,
Tuthill Corporation, Individually And As Successor To Kinney Vacuum Pump Company, Kinney Pump Company And Murray Turbine,
Tyco Flow Control, Inc., Individually And As Successor To Keystone And Grinnell Corporation,
Tyco International,
Union Carbide Corporation,
Union Pumps, As A Textron Company,
United Conveyor Corporation,
Velan Valve Corp.,
Warren Pumps, Llc, Individually And As Successor To The Quimby Pump Company,
William Powell Company,
Wolff & Munier, Inc.,
York International Corporation, Individually And As Successor To Frick Company,
Yuba Heat Transfer, A Division Of Connell Limited Partnership N K A Spx Heat Transfer Llc,
Zurn Industries, Inc. A K A And Successor-In-Interest To Erie City Iron Works,
for Torts - Asbestos
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------- xX
This Document Relates To: :
: Index No.: 190012/2017
STEVEN LEROY HALL, :
:
Plaintiff, :
: VERIFIED ANSWER
- against - :
:
A.0
A.O SMITH WATER PRODUCTS., and :
HEXION SPECIALTY CHEMICALS, INC. et al. :
:
Defendants. :
:
:
--
-------------------------------------------------------------------- xX
Defendant HEXION INC. (hereinafter “Hexion”),
"Hexion"), incorrectly sued herein as HEXION
SPECIALTY CHEMICALS, INC. f/k/a Borden Chemical, Inc., by its attorneys, HARRIS
BEACH PLLC,PLLC, by way of a Verified Answer to plaintiff's
plaintiff’s Second Amended Verified Complaint
(“Amended Complaint")
("Amended Complaint”) and Verified Initial Complaint ("Verified(“Verified Complaint")
Complaint”) states as follows:
AMENDED COMPLAINT
1.
1. Hexion denies any knowledge or information sufficient to form a belief as to the
allegations contained in paragraphs of the Amended Complaint numbered "1",“1”, "2"
“2” and "3",
“3”, and
respectfully refers all questions of law to this honorable Court.
2.
2. To the extent that "Defendants"
“Defendants” refers to parties other than Hexion, Hexion denies
any knowledge or information sufficient to form a belief as to the allegations contained in
paragraphs of the Amended Complaint numbered "4" “4” and "5."
“5.”
3.
3. To the extent “Defendants”
that "Defendants" refers to Hexion, Hexion denies the allegations
contained in paragraphs of the Amended Complaint numbered "4" “4” and "5"“5” except to admit that
“done business in"
Hexion has "done in” and "conducted
“conducted or transacted business in" in” the State of New York,
and respectfully refers all questions of law to this honorable Court.
1 of 25
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
4. Hexion denies any knowledge or information sufficient to form a belief as to the
allegations contained in paragraphs of the Amended Verified Complaint numbered "6", “6”, "7",
“7”, "8",
“8”,
"10",
“10”, "11",
“11”, "12"
“12” ,"13",
,“13”, "14"
“14” and "15",
“15”, and begs leave to refer all questions of law to this
honorable Court.
5. Hexion denies the allegations contained in paragraph "9"
“9” of the Amended
Verified Complaint, except to admit that Hexion has "done
“done business in"
in” and "conducted
“conducted or
transacted business in" in” the State of New York, and begs leave to refer all questions of law to this
honorable Court.
VERIFIED COMPLAINT
6. Hexion denies any knowledge or information sufficient to form a belief as to the
allegations contained in paragraphs of the Verified Complaint numbered "1",“1”, "2"
“2” and "3"
“3” and
begs leave to refer all questions of law to this honorable Court.
7. As "Defendants"
“Defendants” refers to parties other than Hexion, Hexion denies any
knowledge or information sufficient to form a belief as to the allegations contained in paragraphs
of the Verified Complaint numbered "4" “4” and "5."
“5.”
8. As "Defendants"
“Defendants” refers to Hexion, Hexion denies the allegations contained in
paragraphs of the Verified Complaint numbered "4" “4” and "5"
“5” except to admit that Hexion has
"done
“done business in"
in” and "conducted
“conducted or transacted business in"
in” the State of New York, and begs
leave to refer all questions of law to this honorable Court.
9. Hexion denies any knowledge or information sufficient to form a belief as to the
allegations contained in paragraphs of the Verified Complaint numbered "6", “6”, "7",
“7”, "8",
“8”, "9",
“9”, "10",
“10”,
"11",
“11”, "12",
“12”, "13",
“13”, "14",
“14”, "15",
“15”, "16",
“16”, "17",
“17”, "18",
“18”, "19",
“19”, "20",
“20”, "21",
“21”, "22",
“22”, "23",
“23”, "24",
“24”, "25",
“25”, "26",
“26”,
"27",
“27”, "28",
“28”, "29",
“29”, "30",
“30”, "31",
“31”, "32",
“32”, "33",
“33”, "34",
“34”, "35",
“35”, "36",
“36”, "37",
“37”, "38",
“38”, "39",
“39”, "40",
“40”, "41",
“41”, "42",
“42”,
"43",
“43”, "44",
“44”, "45",
“45”, "46",
“46”, "47",
“47”, "48",
“48”, "49",
“49”, "50",
“50”, "51",
“51”, "52",
“52”, "53",
“53”, "54",
“54”, "55",
“55”, "56",
“56”, "57",
“57”, "58",
“58”,
2 of 25
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
"59",
“59”, "60",
“60”, "61",
“61”, "62",
“62”, "63",
“63”, "64",
“64”, "65",
“65”, "66",
“66”, "67",
“67”, "68",
“68”, "69",
“69”, "70",
“70”, "71",
“71”, "72",
“72”, "73",
“73”, "74",
“74”,
"75",
“75”, "76",
“76”, "77",
“77”, "78",
“78”, "79",
“79”, "80",
“80”, "81",
“81”, "82",
“82”, "83",
“83”, "84",
“84”, "85",
“85”, "86",
“86”, "87",
“87”, "88",
“88”, "89",
“89”, "90",
“90”,
"91",
“91”, "92",
“92”, "93",
“93”, "94",
“94”, "95",
“95”, "96"
“96” and "97."
“97.”
10.
10. As "Defendants"
“Defendants” refers to parties other than Hexion, Hexion denies any
knowledge or information sufficient to form a belief as to the allegations contained in paragraphs
of the Verified Complaint numbered "98", “98”, "99",
“99”, "100",
“100”, "101",
“101”, "102",
“102”, "103",
“103”, "104",
“104”, and "105."
“105.”
11.
11. As "Defendants"
“Defendants” refers to Hexion, Hexion denies the allegations contained in
paragraph of the Verified Complaint numbered "98"
“98” except to admit that Hexion has "done
“done
business in"
in” and "conducted
“conducted or transacted business in" in” the State of New York, and begs leave to
refer all questions of law to this honorable Court.
12.
12. As "Defendants"
“Defendants” refers to Hexion, Hexion denies the allegations contained in
paragraphs of the Verified Complaint numbered "99",
“99”, "100",
“100”, "101",
“101”, "102",
“102”, "103",
“103”, "104",
“104”, and
"105"
“105” and begs leave to refer all questions of law to this honorable Court.
AS AND FOR A FIRST CAUSE OF ACTION SOUNDING IN NEGLIGENCE,
HEXION ANSWERS AS FOLLOWS:
13.
13. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "106" “106” of
the Verified Complaint.
14.
14. Hexion denies each and every allegation contained in paragraphs "107" “107” through
"114"
“114” of the Verified Complaint to the extent that such allegations are directed toward Hexion,
and begs leave to refer all questions of law to this honorable Court.
15.
15. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "107" “107” through "114"“114” of the Verified
Complaint as they relate to other defendants and therefore denies them, and begs leave to refer
all questions of law to this honorable Court.
3 of 25
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
AS AND FOR A SECOND CAUSE OF ACTION SOUNDING IN BREACH OF
WARRANTY, HEXION ANSWERS AS FOLLOWS:
16.
16. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "115" “115” of
the Verified Complaint.
17.
17. Hexion denies each and every allegation contained in paragraphs "116" “116” through
“119” of the Verified Complaint to the extent that such allegations are directed toward Hexion,
"119"
and begs leave to refer all questions of law to this honorable Court.
18.
18. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "116" “116” through "119"“119” of the Verified
Complaint as they relate to other defendants and therefore denies them, and begs leave to refer
all questions of law to this honorable Court.
AS AND FOR A THIRD CAUSE OF ACTION SOUNDING IN STRICT LIABILITY,
HEXION ANSWERS AS FOLLOWS:
19.
19. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "120" “120” of
the Verified Complaint.
20. Hexion denies each and every allegation contained in paragraphs "121" “121” through
“129” of the Verified Complaint to the extent that such allegations are directed toward Hexion,
"129"
and begs leave to refer all questions of law to this honorable Court.
21. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "121" “121” through "129"“129” of the Verified
Complaint as they relate to other defendants and therefore denies them, and begs leave to refer
all questions of law to this honorable Court.
4 of 25
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
AS AND FOR A FOURTH CAUSE OF ACTION LABOR LAW VIOLATIONS,
HEXION ANSWERS AS FOLLOWS:
22.
22. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "130" “130” of
the Verified Complaint.
23.
23. Hexion denies each and every allegation contained in paragraphs "131",
“131”, "132",
“132”,
"134",
“134”, "135", “136”, "137",
“135”, "136", “137”, "138",
“138”, "139",
“139”, "140",
“140”, "141",
“141”, "142",
“142”, "143",
“143”, "144",
“144”, "145",
“145”, "146"
“146” and
"148"
“148” of the Verified Complaint to the extent that such allegations are directed toward Hexion,
and begs leave to refer all questions of law to this honorable Court.
24.
24. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "131",
“131”, "132",
“132”, "134",
“134”, “135”, "136",
"135", “136”,
"137",
“137”, "138",
“138”, "139",
“139”, "140",
“140”, "141",
“141”, "142",
“142”, "143",
“143”, "144",
“144”, "145",
“145”, "146"
“146” and "148"
“148” of the Verified
Complaint as they relate to other defendants and therefore denies them, and begs leave to refer
all questions of law to this honorable Court.
25.
25. Hexion denies any knowledge or information sufficient to form a belief as to the
allegations contained in paragraphs "133" “133” and "147"
“147” of the Verified Complaint and begs leave to
refer all questions of law to this honorable Court.
AS AND FOR A FIFTH CAUSE OF ACTION AGAINST DEFENDANT
METROPOLITAN LIFE INSURANCE COMPANY, HEXION ANSWERS AS
FOLLOWS:
26.
26. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "149" “149” of
the Verified Complaint.
27.
27. Hexion denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "150" “150” through "156"“156” of the Verified
Complaint as they relate to other defendants and therefore denies them.
5 of 25
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
AS AND FOR A SIXTH CAUSE OF ACTION SOUNDING IN CONSPIRACY AND
COLLECTIVE LIABILITY/CONCERT OF ACTION, HEXION ANSWERS AS
FOLLOWS:
28.
28. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "157" “157” of
the Verified Complaint.
29.
29. Hexion denies each and every allegation contained in paragraphs "158",
“158”, "159",
“159”,
"160",
“160”, "161",
“161”, "162",
“162”, "163",
“163”, "164",
“164”, "165",
“165”, "166",
“166”, "168",
“168”, "169",
“169”, "170",
“170”, "171"
“171” and "172"
“172” of the
Verified Complaint to the extent that such allegations are directed toward Hexion, and begs leave
to refer all questions of law to this honorable Court.
30.
30. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "158",
“158”, "159",
“159”, "160",
“160”, "161",
“161”, "162",
“162”,
"163",
“163”, "164",
“164”, "165",
“165”, "166",
“166”, "168",
“168”, "169",
“169”, "170",
“170”, "171" “172” of the Verified Complaint as
“171” and "172"
they relate to other defendants and therefore denies them, and begs leave to refer all questions of
law to this honorable Court.
31.
31. Hexion denies each and every allegation contained in paragraphs "167" “167” and of the
Verified Complaint and begs leave to refer all questions of law to this honorable Court.
AS AND FOR A SEVENTH CAUSE OF ACTION AGAINST DEFENDANT
CONTRACTORS, HEXION ANSWERS AS FOLLOWS:
32.
32. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "173" “173” of
the Verified Complaint.
33.
33. Hexion denies that the term "contractor(s)"
“contractor(s)” as defined in paragraph of the
Verified Complaint numbered "174" “174” applies to Hexion in this action.
34.
34. Hexion denies each and every allegation contained in paragraphs "175",
“175”, "176",
“176”,
"177",
“177”, "178",
“178”, "179",
“179”, "180",
“180”, "183",
“183”, "184",
“184”, "185",
“185”, and "186"
“186” of the Verified Complaint to the
6 of 25
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
extent that such allegations are directed toward Hexion, and begs leave to refer all questions of
law to this honorable Court.
35.
35. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "175",
“175”, "176",
“176”, "177",
“177”, "178",
“178”, "179",
“179”,
"180",
“180”, "183",
“183”, "184",
“184”, "185",
“185”, and "186"
“186” of the Verified Complaint as they relate to other
defendants and therefore denies them, and begs leave to refer all questions of law to this
honorable Court.
36.
36. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "181"
“181” and "182"
“182” of the Verified
Complaint and therefore denies them, and begs leave to refer all questions of law to this
honorable Court.
AS AND FOR A [sic] [sicl EIGHTH CAUSE OF ACTION FOR PREMISES LIABILITY
AGAINST CERTAIN DEFENDANTS, HEXION ANSWERS AS FOLLOWS:
37.
37. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "187" “187” of
the Verified Complaint.
38.
38. Hexion denies each and every allegation contained in paragraphs "188",
“188”, "189",
“189”,
"190",
“190”, "191",
“191”, "192",
“192”, "193",
“193”, "194",
“194”, "195",
“195”, "199",
“199”, "200"
“200” and "201"
“201” of the Verified Complaint to
the extent that such allegations are directed toward Hexion, and begs leave to refer all questions
of law to this honorable Court.
39.
39. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs "188",
“188”, "189",
“189”, "190",
“190”, "191",
“191”, "192",
“192”,
"193",
“193”, "194",
“194”, "195",
“195”, "199",
“199”, "200"
“200” and "201"
“201” of the Verified Complaint as they relate to other
defendants and therefore denies them, and begs leave to refer all questions of law to this
honorable Court.
7 of 25
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
40. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs “196”,
"196", “197”,
"197", and “198”
"198" of the
Verified Complaint and therefore denies them, and begs leave to refer all questions of law to this
honorable Court.
41. With regard to the allegations contained in paragraph “202”
"202" of the Verified
Complaint, Hexion admits that this case is governed by the "Substantive “Substantive Law of Admiralty"
Admiralty” but
denies that, as such, this case is “nonremovable,”
therefore "nonremovable," and further begs leave to refer all
questions of law to this honorable Court.
AS AND FOR AN [sic] [sicl NINTH CAUSE OF ACTION FOR JOINT AND SEVERAL
LIABILITY, HEXION ANSWERS AS FOLLOWS:
42. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "203" “203” of
the Verified Complaint.
43. Hexion denies each and every allegation contained “204”,
in paragraphs "204", “205”,
"205",
"206",
“206”, "209",
“209”, "210",
“210”, "211",
“211”, "212",
“212”, "214"
“214” and "215"
“215” of the Verified Complaint to the extent that
such allegations are directed toward Hexion, and begs leave to refer all questions of law to this
honorable Court.
44. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in “204”,
paragraphs "204", “205”, "206",
"205", “206”, “209”, "210",
"209", “210”,
"211",
“211”, "212",
“212”, "214"
“214” and "215"
“215” of the Verified Complaint as they relate to other defendants and
therefore denies them, and begs leave to refer all questions of law to this honorable Court.
45. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in paragraphs “207”,
"207", “208”
"208" and “213”
"213" of the
Verified Complaint and therefore denies them, and begs leave to refer all questions of law to this
honorable Court.
8 of 25
FILED: NEW YORK COUNTY CLERK 03/01/2017 04:17 PM INDEX NO. 190012/2017
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/01/2017
AS AND FOR AN [sic] [sicl TENTH CAUSE OF ACTION FOR PUNITIVE DAMAGES,
HEXIONANSWERS AS FOLLOWS:
46. Repeats and reiterates each and every denial hereinbefore made with the same
force and effect as though the same were set forth at length herein in answer paragraph "216" “216” of
the Verified Complaint.
47. Hexion denies each and every allegation contained in paragraph “217”
"217" of the
Verified Complaint to the extent that such allegations are directed toward Hexion, and begs leave
to refer all questions of law to this honorable Court.
48. Hexion is without knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in “217”
paragraph "217" of the Verified Complaint as
they relate to other defendants and therefore denies them, and begs leave to refer all questions of
law to this honorable Court.