On January 13, 2023 a
EXHIBIT(S) - C (Motion #26) - Answers to Summons and Complaint and Amended Summons and Complaint
was filed
involving a dispute between
Kathleen Spezio,
Roger Paul Spezio Sr.,
and
3M Company,
Individually And As Successor To Minnesota Mining And Manufacturing Company,
Aii Acquisition Corporation, Llc
Individually And As Successor-In-Interest To Athlone Industries, Inc. And Holland Furnace Company,
Air & Liquid Systems Corporation
As Successor By Merger To Buffalo Pumps, Inc.,
Alcoa Inc.,
Individually And As Successor In Interest To Tilo Roofing Co.,
American Optical Corporation,
A.O. Smith Water Products,
Armstrong International, Inc.,
Atwood & Morrill Co., Inc.
D B A Weir Valves & Controls Usa Inc.,
Aurora Pump Company,
Avco Corporation,
A Textron Lycoming Division, Individually And As Successor To Lycoming Engines F K A Lycoming Manufacturing, Spencer Heater Company, And Spencer Heater Division Of Lycoming,
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,
Cleaver-Brooks Company
F K A Aqua-Chem, Inc.,
Columbia Boiler Company Of Pottstown,
Compudyne Corporation,
Individually And As Successor To York-Shipley,
Continental Motors Inc.,
Continental Motors Inc.
F K A Teledyne Continental Motors, Inc., Individually And As Successor To Continental Motors Inc. And Continental Motors Company,
Crown Boiler Co.,
Dean Pump Division,
Eaton Aeroquip, Inc.
F K A Aeroquip Corporation,
Ecr International, Inc.,
Individually And As Successor To Dunkirk, Dunkirk Boilers And Utica Boilers And Pennco, Inc.,
Electrolux Home Products, Inc.,
Individually And As Successor To Tappan And Copes-Vulcan 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,
Gardner Denver, Inc.,
Individually And As Successor To Nash Engineering Company,
Gardner Denver Nash, Llc,
Individually And As Successor To Nash Engineering Company,
General Electric Company,
Goulds Pumps, Inc.,
Grinnell Corporation,
Hoffman New Yorker, 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,
International Comfort Products Llc,
Individually And As Successor To Heil Heating And Cooling,
I.T.T. Industries, Inc.,
Individually And As Successor To Bell & Gossett,
Kohler Co.,
Lennox Industries, Inc.,
Individually And As Successor To Lennox Furnace Company And Ducane,
Mario & Dibono Plastering Co. Inc.,
Metropolitan Life Insurance Company,
New Yorker Boiler Company, Inc.,
Parker Hannifin Corporation,
Individually And As Successor By Merger To Stratoflex, Inc.,
Pratt & Whitney Measurement Systems, Inc.,
Pratt & Whitney Power Systems, Inc.,
Redco Corp.
F K A Crane Co.,
Rheem Manufacturing Company, Inc.,
Rockwell Automation, Inc.,
Individually And As Successor To Allen Bradley, Timken Heating Business And S. Co., Inc. F K A Scaife Company, As Successor In Interest To Rockwell Spring & Axle Companys Timken Silent Automatic Division,
Sid Harvey Industries, Inc.,
Sid Harvey Supply, Inc.,
Spence Engineering Company, Inc.,
Spencer Heater
A Lycoming Division Of Avco Corporation,
Spirax Sarco, Inc.,
Taco, Inc.,
Technify Motor
Individually And As Successor To Teledyne Continental Motors, Inc. F K A Continental Motors, Inc. And Continental Motors Company,
Teledyne Technologies Inc.,
Individually And As Successor To Teledyne Continental Motors, Inc. F K A Continental Motors, Inc., Continental Motors Company,
Texaco, Inc.,
Union Carbide Corporation,
United Technologies Corporation,
Individually And As Successor To Pratt & Whitney,
Velan Valve Corp.,
Warren Pumps Llc,
Individually And As Successor To The Quimby Pump Company,
Weil Mclain,
A Division Of Marley-Wylain Company,
William Powell Company,
York International Corporation,
Individually And As Successor To Frick Company,
for Torts - Asbestos
in the District Court of Ulster County.
Preview
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EXHIBIT C
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
ROGER PAUL SPEZIO, SR. and
Index No.: EF2023-99
KATHLEEN SPEZIO,
Plaintiff(s),
VERIFIED ANSWER
v.
3M COMPANY, Individually and as Successor to
Minnesota Mining and Manufacturing Company.,
et al.,
Defendants.
Defendant TACO, INC., by its attorneys Eckert Seamans Cherin & Mellott, LLC
answering the Verified Complaint, upon information and belief, alleges as follows:
THE PARTIES
1. Defendant TACO, INC. does not answer Paragraph “1” of the Plaintiffs’ Verified
Complaint because there are no allegations directed towards it.
2. Defendant TACO, INC. denies the allegations in Paragraph “2” of the Plaintiffs’
Verified Complaint to the extent they apply to defendant TACO, INC.
3. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of the allegations in Paragraph “3” of the Plaintiffs’ Verified Complaint.
4. Paragraph “4” of the Plaintiffs’ Verified Complaint merely defines the collective
term “Defendants” and contains no factual allegations to which a response would be required. To
the extent Paragraph “4” could be interpreted as an allegation that TACO, INC. is responsible for
any products or services as a predecessor and/or successor-in-interest to any another party to this
case, TACO, INC. denies the allegations contained in Paragraph “4” of the Plaintiffs’ Verified
Complaint.
108863990.1
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5. Defendant TACO, INC. denies the allegations contained in Paragraph “5” of the
Plaintiffs’ Verified Complaint, and Defendant TACO, INC. denies any knowledge or information
sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “5”
of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’
Verified Complaint.
6. Defendant TACO, INC. does not answer the allegations of Paragraphs “6” through
“56” of the Plaintiffs’ Verified Complaint as same do not apply to this defendant.
57. Defendant TACO, INC. denies the allegations contained in Paragraph “57” of the
Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and
Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “57” of the Plaintiffs’ Verified Complaint
as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
58. Defendant TACO, INC. does not answer the allegations of Paragraphs “58”
through “67” of the Plaintiffs’ Verified Complaint as same do not apply to this defendant.
68. Defendant TACO, INC. denies the allegations contained in Paragraph “68” of the
Verified Complaint, to the extent any are directed towards it, and refers all questions of law to this
Court for determination, and Defendant TACO, INC. denies any knowledge or information
sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “68”
of the Verified Complaint as it pertains to remaining defendants in the Plaintiffs’ Verified
Complaint.
69. Defendant TACO, INC. denies the allegations contained in Paragraph “69” of the
Verified Complaint, to the extent any are directed towards it, and refers all questions of law to this
Court for determination, and Defendant TACO, INC. denies any knowledge or information
sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “69”
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of the Verified Complaint as it pertains to remaining defendants in the Plaintiffs’ Verified
Complaint.
70. Defendant TACO, INC. denies the allegations contained in Paragraph “70” of the
Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and
Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “70” of the Plaintiffs’ Verified Complaint
as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
71. Defendant TACO, INC. denies the allegations contained in Paragraph “71” of the
Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and
Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “71” of the Plaintiffs’ Verified Complaint
as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
72. Defendant TACO, INC. denies the allegations contained in Paragraph “72” of the
Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and
Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “72” of the Plaintiffs’ Verified Complaint
as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
73. Defendant TACO, INC. denies the allegations contained in Paragraph “73” of the
Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and
Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “73” of the Plaintiffs’ Verified Complaint
as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
74. Defendant TACO, INC. denies the allegations contained in Paragraph “74” of the
Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and
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Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “74” of the Plaintiffs’ Verified Complaint
as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
75. Defendant TACO, INC. denies the allegations contained in Paragraph “75” of the
Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and
Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “75” of the Plaintiffs’ Verified Complaint
as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
76. Defendant TACO, INC. denies the allegations contained in Paragraph “76” of the
Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and
Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “76” of the Plaintiffs’ Verified Complaint
as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
AS AND FOR AN ANSWER TO THE FIRST CAUSE OF ACTION
77. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every
answer heretofore made to Paragraphs “1” through “76” of Plaintiffs’ Verified Complaint as if set
forth in full herein.
78. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“78” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “78” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
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79. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“79” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “79” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
80. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“80” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “80” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
81. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“81” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “81” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
82. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“82” (a) through “82” (m) of Plaintiffs’ Verified Complaint, and refers all questions of law to this
Court for determination, and Defendant TACO, INC. denies any knowledge or information
sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “82”
(a) through “82” (m) of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants
in the Plaintiffs’ Verified Complaint.
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83. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“83” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “83” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
84. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“84” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “84” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
85. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“85” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “85” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
AS AND FOR AN ANSWER TO THE SECOND CAUSE OF ACTION
86. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every
answer heretofore made to Paragraphs “1” through “85” of Plaintiffs’ Verified Complaint as if set
forth in full herein.
87. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“87” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
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determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “87” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
88. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“88” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “88” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
89. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“89” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “89” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
90. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“90” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “90” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
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AS AND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION
91. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every
answer heretofore made to Paragraphs “1” through “90” of Plaintiffs’ Verified Complaint as if set
forth in full herein.
92. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“92” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “92” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
93. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“93” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “93” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
94. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“94” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “94” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
95. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“95” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
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determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “95” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
96. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“96” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “96” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
97. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“97” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “97” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
98. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“98” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “98” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
99. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“99” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
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determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “99” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
100. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“100” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “100” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION
101. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every
answer heretofore made to Paragraphs “1” through “100” of Plaintiffs’ Verified Complaint as if
set forth in full herein.
102. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“102” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “102” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
103. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“103” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “103” of the
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Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
104. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “104” of Plaintiffs’
Verified Complaint, and refers all questions of law to this Court for determination.
105. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“105” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “105” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
106. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“106” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “106” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
107. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“107” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “107” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
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108. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“108” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “108” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
109. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“109” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph 109” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
110. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“110” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “110” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
111. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“111” (a) through “111” (f) of Plaintiffs’ Verified Complaint, and refers all questions of law to
this Court for determination, and Defendant TACO, INC. denies any knowledge or information
sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “111”
(a) through “111” (f) of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants
in the Plaintiffs’ Verified Complaint.
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112. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“112” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “112” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
113. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“113” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “113” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
114. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“114” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “114” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
115. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“115” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “115” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
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116. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“116” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “116” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
117. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“117” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “117” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
118. Defendant TACO, INC. denies each and every allegation contained in Paragraph
“118” of the Plaintiffs’ Verified Complaint to the extent they apply to defendant TACO, INC.
119. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“119” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “119” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
AS AND FOR AN ANSWER TO THE FIFTH CAUSE OF ACTION
120. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every
answer heretofore made to Paragraphs “1” through “119” of Plaintiffs’ Verified Complaint as if
set forth in full herein.
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121. Defendant TACO, INC. does not answer the allegations contained in Paragraph
“121” of Plaintiffs’ Verified Complaint as same do not apply to this defendant.
122. Defendant TACO, INC. does not answer the allegations contained in Paragraph
“122” of Plaintiffs’ Verified Complaint as same do not apply to this defendant.
123. Defendant TACO, INC. does not answer the allegations contained in Paragraph
“123” of Plaintiffs’ Verified Complaint as same do not apply to this defendant.
124. Defendant TACO, INC. does not answer the allegations contained in Paragraph
“124” of Plaintiffs’ Verified Complaint as same do not apply to this defendant.
125. Defendant TACO, INC. does not answer the allegations contained in Paragraph
“125” of Plaintiffs’ Verified Complaint as same do not apply to this defendant.
126. Defendant TACO, INC. does not answer the allegations contained in Paragraph
“126” of Plaintiffs’ Verified Complaint as same do not apply to this defendant.
127. Defendant TACO, INC. does not answer the allegations contained in Paragraph
“127” of Plaintiffs’ Verified Complaint as same do not apply to this defendant.
AS AND FOR AN ANSWER TO THE SIXTH CAUSE OF ACTION
128. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every
answer heretofore made to Paragraphs “1” through “127” of Plaintiffs’ Verified Complaint as if
set forth in full herein.
129. Defendant TACO, INC. denies each and every allegation contained in Paragraph
“129” of the Plaintiffs’ Verified Complaint as it pertain to this answering defendant and Defendant
TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of
each and every allegation contained in Paragraph “129” of Plaintiffs’ Verified Complaint as it
pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
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130. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“130” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “130” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
131. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“131” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “131” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
132. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“132” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “132” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
133. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“133” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “133” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
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134. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“134” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “134” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
135. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“135” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “135” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
136. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“136” (i) through “136” (iii) of Plaintiffs’ Verified Complaint, and refers all questions of law to
this Court for determination, and Defendant TACO, INC. denies any knowledge or information
sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “136”
(i) through “136” (iii) of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants
in the Plaintiffs’ Verified Complaint.
137. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“137” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “137” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
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138. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“138” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “138” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
139. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“1389 of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “139” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
140. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“140” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “140” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
141. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“141” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “141” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
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142. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“142” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “142” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
143. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“143” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “143” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
AS AND FOR AN ANSWER TO THE SEVENTH CAUSE OF ACTION
144. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every
answer heretofore made to Paragraphs “1” through “143” of Plaintiffs’ Verified Complaint as if
set forth in full herein.
145. Defendant TACO, INC. neither admits nor denies the allegations contained in
Paragraph “145” of Plaintiffs’ Verified Complaint and leaves Plaintiff’s to their proofs, and
Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the
truth of each and every allegation contained in Paragraph “145” of the Plaintiffs’ Verified
Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
146. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “146” of Plaintiffs’
Verified Complaint as these allegations pertain to the Defendant contractor(s).
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147. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “147” of Plaintiffs’
Verified Complaint as these allegations pertain to the Defendant contractor(s).
148. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “148” of Plaintiffs’
Verified Complaint as these allegations pertain to the Defendant contractor(s).
149. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “149” of Plaintiffs’
Verified Complaint as these allegations pertain to the Defendant contractor(s).
150. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “150” of Plaintiffs’
Verified Complaint as these allegations pertain to the Defendant contractor(s).
151. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “151” of Plaintiffs’
Verified Complaint as these allegations pertain to the Defendant contractor(s).
152. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegations contained in Paragraph “152” of Plaintiffs’
Verified Complaint.
153. Defendant TACO, INC. denies each and every allegations contained in Paragraph
“153” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for
determination, and Defendant TACO, INC. denies any knowledge or information sufficient to
form a belief as to the truth of each and every allegation contained in Paragraph “153” of the
Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified
Complaint.
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154. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “154” of Plaintiffs’
Verified Complaint as these allegations pertain to the Defendant contractor(s).
155. Defendant TACO, INC. denies any knowledge or information sufficient to form a
belief as to the truth of each and every allegation contained in Paragraph “155” of Plaintiffs’
Verified
Preview
FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 EXHIBIT C FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER ROGER PAUL SPEZIO, SR. and Index No.: EF2023-99 KATHLEEN SPEZIO, Plaintiff(s), VERIFIED ANSWER v. 3M COMPANY, Individually and as Successor to Minnesota Mining and Manufacturing Company., et al., Defendants. Defendant TACO, INC., by its attorneys Eckert Seamans Cherin & Mellott, LLC answering the Verified Complaint, upon information and belief, alleges as follows: THE PARTIES 1. Defendant TACO, INC. does not answer Paragraph “1” of the Plaintiffs’ Verified Complaint because there are no allegations directed towards it. 2. Defendant TACO, INC. denies the allegations in Paragraph “2” of the Plaintiffs’ Verified Complaint to the extent they apply to defendant TACO, INC. 3. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph “3” of the Plaintiffs’ Verified Complaint. 4. Paragraph “4” of the Plaintiffs’ Verified Complaint merely defines the collective term “Defendants” and contains no factual allegations to which a response would be required. To the extent Paragraph “4” could be interpreted as an allegation that TACO, INC. is responsible for any products or services as a predecessor and/or successor-in-interest to any another party to this case, TACO, INC. denies the allegations contained in Paragraph “4” of the Plaintiffs’ Verified Complaint. 108863990.1 FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 5. Defendant TACO, INC. denies the allegations contained in Paragraph “5” of the Plaintiffs’ Verified Complaint, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “5” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 6. Defendant TACO, INC. does not answer the allegations of Paragraphs “6” through “56” of the Plaintiffs’ Verified Complaint as same do not apply to this defendant. 57. Defendant TACO, INC. denies the allegations contained in Paragraph “57” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “57” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 58. Defendant TACO, INC. does not answer the allegations of Paragraphs “58” through “67” of the Plaintiffs’ Verified Complaint as same do not apply to this defendant. 68. Defendant TACO, INC. denies the allegations contained in Paragraph “68” of the Verified Complaint, to the extent any are directed towards it, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “68” of the Verified Complaint as it pertains to remaining defendants in the Plaintiffs’ Verified Complaint. 69. Defendant TACO, INC. denies the allegations contained in Paragraph “69” of the Verified Complaint, to the extent any are directed towards it, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “69” FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 of the Verified Complaint as it pertains to remaining defendants in the Plaintiffs’ Verified Complaint. 70. Defendant TACO, INC. denies the allegations contained in Paragraph “70” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “70” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 71. Defendant TACO, INC. denies the allegations contained in Paragraph “71” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “71” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 72. Defendant TACO, INC. denies the allegations contained in Paragraph “72” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “72” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 73. Defendant TACO, INC. denies the allegations contained in Paragraph “73” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “73” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 74. Defendant TACO, INC. denies the allegations contained in Paragraph “74” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “74” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 75. Defendant TACO, INC. denies the allegations contained in Paragraph “75” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “75” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 76. Defendant TACO, INC. denies the allegations contained in Paragraph “76” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “76” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. AS AND FOR AN ANSWER TO THE FIRST CAUSE OF ACTION 77. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every answer heretofore made to Paragraphs “1” through “76” of Plaintiffs’ Verified Complaint as if set forth in full herein. 78. Defendant TACO, INC. denies each and every allegations contained in Paragraph “78” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “78” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 79. Defendant TACO, INC. denies each and every allegations contained in Paragraph “79” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “79” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 80. Defendant TACO, INC. denies each and every allegations contained in Paragraph “80” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “80” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 81. Defendant TACO, INC. denies each and every allegations contained in Paragraph “81” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “81” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 82. Defendant TACO, INC. denies each and every allegations contained in Paragraph “82” (a) through “82” (m) of Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “82” (a) through “82” (m) of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 83. Defendant TACO, INC. denies each and every allegations contained in Paragraph “83” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “83” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 84. Defendant TACO, INC. denies each and every allegations contained in Paragraph “84” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “84” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 85. Defendant TACO, INC. denies each and every allegations contained in Paragraph “85” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “85” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. AS AND FOR AN ANSWER TO THE SECOND CAUSE OF ACTION 86. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every answer heretofore made to Paragraphs “1” through “85” of Plaintiffs’ Verified Complaint as if set forth in full herein. 87. Defendant TACO, INC. denies each and every allegations contained in Paragraph “87” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “87” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 88. Defendant TACO, INC. denies each and every allegations contained in Paragraph “88” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “88” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 89. Defendant TACO, INC. denies each and every allegations contained in Paragraph “89” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “89” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 90. Defendant TACO, INC. denies each and every allegations contained in Paragraph “90” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “90” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 AS AND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION 91. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every answer heretofore made to Paragraphs “1” through “90” of Plaintiffs’ Verified Complaint as if set forth in full herein. 92. Defendant TACO, INC. denies each and every allegations contained in Paragraph “92” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “92” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 93. Defendant TACO, INC. denies each and every allegations contained in Paragraph “93” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “93” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 94. Defendant TACO, INC. denies each and every allegations contained in Paragraph “94” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “94” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 95. Defendant TACO, INC. denies each and every allegations contained in Paragraph “95” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “95” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 96. Defendant TACO, INC. denies each and every allegations contained in Paragraph “96” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “96” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 97. Defendant TACO, INC. denies each and every allegations contained in Paragraph “97” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “97” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 98. Defendant TACO, INC. denies each and every allegations contained in Paragraph “98” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “98” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 99. Defendant TACO, INC. denies each and every allegations contained in Paragraph “99” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “99” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 100. Defendant TACO, INC. denies each and every allegations contained in Paragraph “100” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “100” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION 101. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every answer heretofore made to Paragraphs “1” through “100” of Plaintiffs’ Verified Complaint as if set forth in full herein. 102. Defendant TACO, INC. denies each and every allegations contained in Paragraph “102” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “102” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 103. Defendant TACO, INC. denies each and every allegations contained in Paragraph “103” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “103” of the FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 104. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “104” of Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination. 105. Defendant TACO, INC. denies each and every allegations contained in Paragraph “105” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “105” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 106. Defendant TACO, INC. denies each and every allegations contained in Paragraph “106” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “106” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 107. Defendant TACO, INC. denies each and every allegations contained in Paragraph “107” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “107” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 108. Defendant TACO, INC. denies each and every allegations contained in Paragraph “108” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “108” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 109. Defendant TACO, INC. denies each and every allegations contained in Paragraph “109” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph 109” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 110. Defendant TACO, INC. denies each and every allegations contained in Paragraph “110” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “110” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 111. Defendant TACO, INC. denies each and every allegations contained in Paragraph “111” (a) through “111” (f) of Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “111” (a) through “111” (f) of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 112. Defendant TACO, INC. denies each and every allegations contained in Paragraph “112” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “112” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 113. Defendant TACO, INC. denies each and every allegations contained in Paragraph “113” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “113” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 114. Defendant TACO, INC. denies each and every allegations contained in Paragraph “114” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “114” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 115. Defendant TACO, INC. denies each and every allegations contained in Paragraph “115” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “115” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 116. Defendant TACO, INC. denies each and every allegations contained in Paragraph “116” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “116” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 117. Defendant TACO, INC. denies each and every allegations contained in Paragraph “117” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “117” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 118. Defendant TACO, INC. denies each and every allegation contained in Paragraph “118” of the Plaintiffs’ Verified Complaint to the extent they apply to defendant TACO, INC. 119. Defendant TACO, INC. denies each and every allegations contained in Paragraph “119” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “119” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. AS AND FOR AN ANSWER TO THE FIFTH CAUSE OF ACTION 120. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every answer heretofore made to Paragraphs “1” through “119” of Plaintiffs’ Verified Complaint as if set forth in full herein. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 121. Defendant TACO, INC. does not answer the allegations contained in Paragraph “121” of Plaintiffs’ Verified Complaint as same do not apply to this defendant. 122. Defendant TACO, INC. does not answer the allegations contained in Paragraph “122” of Plaintiffs’ Verified Complaint as same do not apply to this defendant. 123. Defendant TACO, INC. does not answer the allegations contained in Paragraph “123” of Plaintiffs’ Verified Complaint as same do not apply to this defendant. 124. Defendant TACO, INC. does not answer the allegations contained in Paragraph “124” of Plaintiffs’ Verified Complaint as same do not apply to this defendant. 125. Defendant TACO, INC. does not answer the allegations contained in Paragraph “125” of Plaintiffs’ Verified Complaint as same do not apply to this defendant. 126. Defendant TACO, INC. does not answer the allegations contained in Paragraph “126” of Plaintiffs’ Verified Complaint as same do not apply to this defendant. 127. Defendant TACO, INC. does not answer the allegations contained in Paragraph “127” of Plaintiffs’ Verified Complaint as same do not apply to this defendant. AS AND FOR AN ANSWER TO THE SIXTH CAUSE OF ACTION 128. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every answer heretofore made to Paragraphs “1” through “127” of Plaintiffs’ Verified Complaint as if set forth in full herein. 129. Defendant TACO, INC. denies each and every allegation contained in Paragraph “129” of the Plaintiffs’ Verified Complaint as it pertain to this answering defendant and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “129” of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 130. Defendant TACO, INC. denies each and every allegations contained in Paragraph “130” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “130” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 131. Defendant TACO, INC. denies each and every allegations contained in Paragraph “131” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “131” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 132. Defendant TACO, INC. denies each and every allegations contained in Paragraph “132” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “132” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 133. Defendant TACO, INC. denies each and every allegations contained in Paragraph “133” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “133” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 134. Defendant TACO, INC. denies each and every allegations contained in Paragraph “134” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “134” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 135. Defendant TACO, INC. denies each and every allegations contained in Paragraph “135” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “135” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 136. Defendant TACO, INC. denies each and every allegations contained in Paragraph “136” (i) through “136” (iii) of Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “136” (i) through “136” (iii) of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 137. Defendant TACO, INC. denies each and every allegations contained in Paragraph “137” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “137” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 138. Defendant TACO, INC. denies each and every allegations contained in Paragraph “138” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “138” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 139. Defendant TACO, INC. denies each and every allegations contained in Paragraph “1389 of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “139” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 140. Defendant TACO, INC. denies each and every allegations contained in Paragraph “140” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “140” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 141. Defendant TACO, INC. denies each and every allegations contained in Paragraph “141” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “141” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 142. Defendant TACO, INC. denies each and every allegations contained in Paragraph “142” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “142” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 143. Defendant TACO, INC. denies each and every allegations contained in Paragraph “143” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “143” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. AS AND FOR AN ANSWER TO THE SEVENTH CAUSE OF ACTION 144. Defendant TACO, INC. herein repeats, reiterates and re-alleges each and every answer heretofore made to Paragraphs “1” through “143” of Plaintiffs’ Verified Complaint as if set forth in full herein. 145. Defendant TACO, INC. neither admits nor denies the allegations contained in Paragraph “145” of Plaintiffs’ Verified Complaint and leaves Plaintiff’s to their proofs, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “145” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. 146. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “146” of Plaintiffs’ Verified Complaint as these allegations pertain to the Defendant contractor(s). FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 147. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “147” of Plaintiffs’ Verified Complaint as these allegations pertain to the Defendant contractor(s). 148. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “148” of Plaintiffs’ Verified Complaint as these allegations pertain to the Defendant contractor(s). 149. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “149” of Plaintiffs’ Verified Complaint as these allegations pertain to the Defendant contractor(s). 150. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “150” of Plaintiffs’ Verified Complaint as these allegations pertain to the Defendant contractor(s). 151. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “151” of Plaintiffs’ Verified Complaint as these allegations pertain to the Defendant contractor(s). 152. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegations contained in Paragraph “152” of Plaintiffs’ Verified Complaint. 153. Defendant TACO, INC. denies each and every allegations contained in Paragraph “153” of the Plaintiffs’ Verified Complaint, and refers all questions of law to this Court for determination, and Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “153” of the Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint. FILED: ULSTER COUNTY CLERK 11/16/2023 04:21 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 259 RECEIVED NYSCEF: 11/16/2023 154. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “154” of Plaintiffs’ Verified Complaint as these allegations pertain to the Defendant contractor(s). 155. Defendant TACO, INC. denies any knowledge or information sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “155” of Plaintiffs’ Verified