Preview
FILED: NASSAU COUNTY CLERK 03/01/2024 06:05 PM INDEX NO. 607514/2022
NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 03/01/2024
EXHIBIT H
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
_________________________________________________Ç
VINU JACOB, Index No.: 607516/2022
Plaintiff,
VERIFIED ANSWER
-against-
NORTH MERRICK FIRE DEPARTMENT, NORTH
MERRICK FIRE DISTRICT, MERRICK FIRE
DEPARTMENT, BELLMORE FIRE DEPARTMENT,
BELLMORE FIRE DISTRICT, TOWN OF HEMPSTEAD,
THE NEW YORK STATE VOLUNTEER FIREMEN'S
PARADE AND DRILL TEAM CAPTAINS
ASSOCIATION, INC., NASSAU COUNTY VOLUNTEER
FIREMENS PARADE AND DRILL TEAM CAPTAINS
ASSOCIATION, INC., and PAUL WILDERS,
Defendants.
________________________________________Ç
Defendant, TOWN OF HEMPSTEAD, by its attorneys, BEE READY FISHBEIN
HATTER & DONAVAN, LLP, as and for its Verified Answer to Plaintiff's Verified Complaint,
sets forth as follows:
1. Deny knowledge and information sufficient to form a belief as to the truth of the
"1"
allegations contained in Paragraph of Plaintiff's Verified Complaint.
"2"
2. Deny the truth of the allegations contained in Paragraph of the Verified
Complaint.
"3"
3. Paragraph contains questions of law, which the Defendant respectfully refers
"3"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"4"
4. Paragraph contains questions of law, which the Defendant respectfully refers
"4"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
1
1 of 38
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"S"
5. Paragraph contains questions of law, which the Defendant respectfully refers
"5"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"6"
6. Paragraph contains questions of law, which the Defendant respectfully refers
"6"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"7"
7. Paragraph contains questions of law, which the Defendant respectfully refers
"7"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"8"
8. Paragraph contains questions of law, which the Defendant respectfully refers
"8"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant admits the truth of the allegations.
9. Deny knowledge and information sufficient to form a belief as to the truth of the
"9"
allegations contained in Paragraph of the Verified Complaint.
10. Deny knowledge and information sufficient to form a belief as to the truth of the
"10"
allegations contained in Paragraph of the Verified Complaint.
11. Deny knowledge and information sufficient to form a belief as to the truth of the
"11"
allegations contained in Paragraph of the Verified Complaint.
2
2 of 38
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
12. Deny knowledge and information sufficient to form a belief as to the truth of the
"12"
allegations contained in Paragraph of the Verified Complaint.
13. Deny knowledge and information sufficient to form a belief as to the truth of the
"13"
allegations contained in Paragraph of the Verified Complaint.
14. Deny knowledge and information sufficient to form a belief as to the truth of the
"14"
allegations contained in Paragraph of the Verified Complaint.
15. Deny knowledge and information sufficient to form a belief as to the truth of the
"15"
allegations contained in Paragraph of the Verified Complaint.
16. Deny knowledge and information sufficient to form a belief as to the truth of the
"16"
allegations contained in Paragraph of the Verified Complaint.
17. Deny knowledge and information sufficient to form a belief as to the truth of the
"17"
allegations contained in Paragraph of the Verified Complaint.
18. Deny knowledge and information sufficient to form a belief as to the truth of the
"18"
allegations contained in Paragraph of the Verified Complaint.
"19"
19. Paragraph contains questions of law, which the Defendant respectfully refers
"19"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"20"
20. Paragraph contains questions of law, which the Defendant respectfully refers
"20"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"21"
21. Deny the truth of the allegations contained in Paragraph of the Verified
Complaint.
3
3 of 38
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
"22"
22. Paragraph contains questions of law, which the Defendant respectfully refers
"22"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"23"
23. Paragraph contains questions of law, which the Defendant respectfully refers
"23"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"24"
24. Paragraph contains questions of law, which the Defendant respectfully refers
"24"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"25"
25. Paragraph contains questions of law, which the Defendant respectfully refers
"25"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"26"
26. Paragraph contains questions of law, which the Defendant respectfully refers
"26"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"27"
27. Paragraph contains questions of law, which the Defendant respectfully refers
"27"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
4
4 of 38
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
"28"
28. Paragraph contains questions of law, which the Defendant respectfully refers
"28"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"29"
29. Paragraph contains questions of law, which the Defendant respectfully refers
"29"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"30"
30. Paragraph contains questions of law, which the Defendant respectfully refers
"30"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"31"
31. Paragraph contains questions of law, which the Defendant respectfully refers
"31"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"32"
32. Paragraph contains questions of law, which the Defendant respectfully refers
"32"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"33"
33. Paragraph contains questions of law, which the Defendant respectfully refers
"33"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
5
5 of 38
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
"34"
34. Paragraph contains questions of law, which the Defendant respectfully refers
"34"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to fonn a belief as to
the truth of those allegations.
"35"
35. Paragraph contains questions of law, which the Defendant respectfully refers
"35"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"36"
36. Paragraph contains questions of law, which the Defendant respectfully refers
"36"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"37"
37. Paragraph contains questions of law, which the Defendant respectfully refers
"37"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"38"
38. Paragraph contains questions of law, which the Defendant respectfully refers
"38"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"39"
39. Paragraph contains questions of law, which the Defendant respectfully refers
"39"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
6
6 of 38
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
"40"
40. Paragraph contains questions of law, which the Defendant respectfully refers
"40"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"41"
41. Paragraph contains questions of law, which the Defendant respectfully refers
"41"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"42"
42. Admit the truth of the allegations contained in Paragraph of the Verified
Complaint.
"43"
43. Paragraph contains questions of law, which the Defendant respectfully refers
"43"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"44"
44. Paragraph contains questions of law, which the Defendant respectfully refers
"44"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"45"
45. Paragraph contains questions of law, which the Defendant respectfully refers
"45"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"46"
46. Paragraph contains questions of law, which the Defendant respectfully refers
"46"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
7
7 of 38
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"47"
47. Paragraph contains questions of law, which the Defendant respectfully refers
"47"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"48"
48. Paragraph contains questions of law, which the Defendant respectfully refers
"48"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"49"
49. Paragraph contains questions of law, which the Defendant respectfully refers
"49"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"50"
50. Paragraph contains questions of law, which the Defendant respectfully refers
"50"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"51"
51. Paragraph contains questions of law, which the Defendant respectfully refers
"51"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"52"
52. Admit the truth of the allegations contained in Paragraph of the Verified
Complaint.
8
8 of 38
FILED: NASSAU COUNTY CLERK 03/01/2024
08/03/2022 06:05
03:39 PM INDEX NO. 607514/2022
607516/2022
NYSCEF DOC. NO. 50
11 RECEIVED NYSCEF: 03/01/2024
08/03/2022
"53"
53. Paragraph contains questions of law, which the Defendant respectfully refers
"53"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"54"
54. Paragraph contains questions of law, which the Defendant respectfully refers
"54"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"55"
55. Paragraph contains questions of law, which the Defendant respectfully refers
"55"
to the Court. To the extent that Paragraph contains any allegations that require an answer by
the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to
the truth of those allegations.
"56"
56. Paragraph contains questions of law, which the Defendant respectfully refers
"56"
to the Court. To the extent that Paragraph contains
Preview
FILED: NASSAU COUNTY CLERK 03/01/2024 06:05 PM INDEX NO. 607514/2022 NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 03/01/2024 EXHIBIT H FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU _________________________________________________Ç VINU JACOB, Index No.: 607516/2022 Plaintiff, VERIFIED ANSWER -against- NORTH MERRICK FIRE DEPARTMENT, NORTH MERRICK FIRE DISTRICT, MERRICK FIRE DEPARTMENT, BELLMORE FIRE DEPARTMENT, BELLMORE FIRE DISTRICT, TOWN OF HEMPSTEAD, THE NEW YORK STATE VOLUNTEER FIREMEN'S PARADE AND DRILL TEAM CAPTAINS ASSOCIATION, INC., NASSAU COUNTY VOLUNTEER FIREMENS PARADE AND DRILL TEAM CAPTAINS ASSOCIATION, INC., and PAUL WILDERS, Defendants. ________________________________________Ç Defendant, TOWN OF HEMPSTEAD, by its attorneys, BEE READY FISHBEIN HATTER & DONAVAN, LLP, as and for its Verified Answer to Plaintiff's Verified Complaint, sets forth as follows: 1. Deny knowledge and information sufficient to form a belief as to the truth of the "1" allegations contained in Paragraph of Plaintiff's Verified Complaint. "2" 2. Deny the truth of the allegations contained in Paragraph of the Verified Complaint. "3" 3. Paragraph contains questions of law, which the Defendant respectfully refers "3" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "4" 4. Paragraph contains questions of law, which the Defendant respectfully refers "4" to the Court. To the extent that Paragraph contains any allegations that require an answer by 1 1 of 38 FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "S" 5. Paragraph contains questions of law, which the Defendant respectfully refers "5" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "6" 6. Paragraph contains questions of law, which the Defendant respectfully refers "6" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "7" 7. Paragraph contains questions of law, which the Defendant respectfully refers "7" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "8" 8. Paragraph contains questions of law, which the Defendant respectfully refers "8" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant admits the truth of the allegations. 9. Deny knowledge and information sufficient to form a belief as to the truth of the "9" allegations contained in Paragraph of the Verified Complaint. 10. Deny knowledge and information sufficient to form a belief as to the truth of the "10" allegations contained in Paragraph of the Verified Complaint. 11. Deny knowledge and information sufficient to form a belief as to the truth of the "11" allegations contained in Paragraph of the Verified Complaint. 2 2 of 38 FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 12. Deny knowledge and information sufficient to form a belief as to the truth of the "12" allegations contained in Paragraph of the Verified Complaint. 13. Deny knowledge and information sufficient to form a belief as to the truth of the "13" allegations contained in Paragraph of the Verified Complaint. 14. Deny knowledge and information sufficient to form a belief as to the truth of the "14" allegations contained in Paragraph of the Verified Complaint. 15. Deny knowledge and information sufficient to form a belief as to the truth of the "15" allegations contained in Paragraph of the Verified Complaint. 16. Deny knowledge and information sufficient to form a belief as to the truth of the "16" allegations contained in Paragraph of the Verified Complaint. 17. Deny knowledge and information sufficient to form a belief as to the truth of the "17" allegations contained in Paragraph of the Verified Complaint. 18. Deny knowledge and information sufficient to form a belief as to the truth of the "18" allegations contained in Paragraph of the Verified Complaint. "19" 19. Paragraph contains questions of law, which the Defendant respectfully refers "19" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "20" 20. Paragraph contains questions of law, which the Defendant respectfully refers "20" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "21" 21. Deny the truth of the allegations contained in Paragraph of the Verified Complaint. 3 3 of 38 FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 "22" 22. Paragraph contains questions of law, which the Defendant respectfully refers "22" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "23" 23. Paragraph contains questions of law, which the Defendant respectfully refers "23" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "24" 24. Paragraph contains questions of law, which the Defendant respectfully refers "24" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "25" 25. Paragraph contains questions of law, which the Defendant respectfully refers "25" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "26" 26. Paragraph contains questions of law, which the Defendant respectfully refers "26" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "27" 27. Paragraph contains questions of law, which the Defendant respectfully refers "27" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. 4 4 of 38 FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 "28" 28. Paragraph contains questions of law, which the Defendant respectfully refers "28" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "29" 29. Paragraph contains questions of law, which the Defendant respectfully refers "29" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "30" 30. Paragraph contains questions of law, which the Defendant respectfully refers "30" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "31" 31. Paragraph contains questions of law, which the Defendant respectfully refers "31" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "32" 32. Paragraph contains questions of law, which the Defendant respectfully refers "32" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "33" 33. Paragraph contains questions of law, which the Defendant respectfully refers "33" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. 5 5 of 38 FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 "34" 34. Paragraph contains questions of law, which the Defendant respectfully refers "34" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to fonn a belief as to the truth of those allegations. "35" 35. Paragraph contains questions of law, which the Defendant respectfully refers "35" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "36" 36. Paragraph contains questions of law, which the Defendant respectfully refers "36" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "37" 37. Paragraph contains questions of law, which the Defendant respectfully refers "37" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "38" 38. Paragraph contains questions of law, which the Defendant respectfully refers "38" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "39" 39. Paragraph contains questions of law, which the Defendant respectfully refers "39" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. 6 6 of 38 FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 "40" 40. Paragraph contains questions of law, which the Defendant respectfully refers "40" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "41" 41. Paragraph contains questions of law, which the Defendant respectfully refers "41" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "42" 42. Admit the truth of the allegations contained in Paragraph of the Verified Complaint. "43" 43. Paragraph contains questions of law, which the Defendant respectfully refers "43" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "44" 44. Paragraph contains questions of law, which the Defendant respectfully refers "44" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "45" 45. Paragraph contains questions of law, which the Defendant respectfully refers "45" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "46" 46. Paragraph contains questions of law, which the Defendant respectfully refers "46" to the Court. To the extent that Paragraph contains any allegations that require an answer by 7 7 of 38 FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "47" 47. Paragraph contains questions of law, which the Defendant respectfully refers "47" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "48" 48. Paragraph contains questions of law, which the Defendant respectfully refers "48" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "49" 49. Paragraph contains questions of law, which the Defendant respectfully refers "49" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "50" 50. Paragraph contains questions of law, which the Defendant respectfully refers "50" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "51" 51. Paragraph contains questions of law, which the Defendant respectfully refers "51" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "52" 52. Admit the truth of the allegations contained in Paragraph of the Verified Complaint. 8 8 of 38 FILED: NASSAU COUNTY CLERK 03/01/2024 08/03/2022 06:05 03:39 PM INDEX NO. 607514/2022 607516/2022 NYSCEF DOC. NO. 50 11 RECEIVED NYSCEF: 03/01/2024 08/03/2022 "53" 53. Paragraph contains questions of law, which the Defendant respectfully refers "53" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "54" 54. Paragraph contains questions of law, which the Defendant respectfully refers "54" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "55" 55. Paragraph contains questions of law, which the Defendant respectfully refers "55" to the Court. To the extent that Paragraph contains any allegations that require an answer by the Defendant, the Defendant denies knowledge and information sufficient to form a belief as to the truth of those allegations. "56" 56. Paragraph contains questions of law, which the Defendant respectfully refers "56" to the Court. To the extent that Paragraph contains