Answer: Shirley Jo Godfrey as Executrix of the Estate of Robert C. Godfrey, Shirley Godfrey v. A.O. Smith Water Products, Algoma Hardwoods, Inc., American Biltrite, Inc., Individually and as Successor to Amtico Floors, Basic, Inc., Bird Incorporated f/k/a Bird & Son, Inc., Borg Warner Corporation, by its Successor In Interest, Borg Warner Morse TEC Inc., Burnham Corporation, Carrier Corporation, Cbs Corporation, a Delaware Corporation, f/k/a Viacom Inc, Successor by merger to CBS Corporation, a Pennsylvania Corporation, f/k/a Westinghouse Electric Corporation, Certain-Teed Corporation, Cleaver Brooks Company f/k/a Aqua Chem, Inc., Conwed Corporation f/k/a Wood Conversion Company, Crane Co., Crown Boiler Co., Dap, Inc., k/n/a La Mirada Products Co., Inc., Domco Products Texas, Inc., d/b/a Tarkett Inc., Individually and as successor to Azrock Industries, Inc., Ecr International, Inc., Individually and as Successor to Dunkirk, Dunkirk Boilers, and Utica Boilers, General Electric Company, Georgia-Pacific Corporation, Individually and as successor to Bestwall Gypsum Company, Homasote Company, Inc., Honeywell International, Inc., Individually and f/k/a AlliedSignal, Inc., and as Successor in interest to The Bendix Corp., International Paper Company, f/k/a Hammermill Paper Co. and Individually and as Successor to US Plywood, Kaiser Gypsum Company, Inc., Lehrer Mcgovern/Lehrer Llc, Mannington Mills, Inc., Metropolitan Life Insurance Company, New Yorker Boiler Company, Inc., Peerless Industries, Inc., Pfizer, Inc., Rheem Manufacturing Corp., Strober Organization, Inc., Turner Construction Company, Union Carbide Corporation, Weil Mclain, A Division of Marley Wylain Company, Weyerhauser Corporation, Whiting Turner, York International Corporation, Individually and as Successor to Frick Company

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                                (FILED: NEW YORK COUNTY CLERK 1070572015 05:13 PM                                                              INDEX   NO.     190280/2015
NYSCEF   DOC.     NO.       12                                                                         RECEIVED    NYSCEF          10/05/2015




                SUPREME COURT OF THE STATE OF NEW YORK
                COUNTY OF NEW YORK


                ROBERT GODFREY and SHIRLEY GODFREY,
                                                                                               Index No.: 190280/15
                                Plaintiffs,

                                                       - against -                             VERIFIED ANSWER


                A.O. SMITH WATER PRODUCTS, et al,

                            Defendants,
                                                                                       x

                                        Defendant, PEERLESS INDUSTRIES, INC., by its attorneys LEWIS BRISBOIS

                BISGAARD & SMITH LLP answering the Plaintiffs’ Verified Complaint upon information and

                belief, alleges as follows:

                                                                     THE PARTIES


                            1           Defendant, PEERLESS           INDUSTRIES,    INC., neither admits nor denies the

             allegations of Paragraph “1” and leaves Plaintiffs’ to their proofs.

                        2.              Defendant,   PEERLESS        INDUSTRIES,     INC.,   neither admits   nor denies     the

            allegations of Paragraph “2” and leaves Plaintiffs’ to their proofs.

                        3.             Defendant, PEERLESS INDUSTRIES, 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 as it pertains to the remaining defendants in the Verified Complaint.

                        4              Defendant, PEERLESS           INDUSTRIES, INC., denies the remaining allegations

            contained in Paragraph “4” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

            Court for determination at the time of trial, and Defendant, PEERLESS                    INDUSTRIES, INC.,




            4831-1993-5273.1
denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “4” of Plaintiffs’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint

           5-31.   Defendant, PEERLESS INDUSTRIES, INC., denies any knowledge or information

 sufficient to form a belief as to the truth of each and every allegation contained in Paragraphs “5”,
 $6, #7, “8, “9”, 10", “11, “12”, “13”, “14”, $15", “16”, “17”, “18”, “19”, “20”, “21, 22”,


 “23”, “24”, “25”, “26”, “27”, “28”, “29”, “30” and “31”      of Plaintiffs’ Verified Complaint as it

pertains to the remaining defendants in the Verified Complaint.

           32,     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “32” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial.

          33-41, Defendant, PEERLESS INDUSTRIES, INC., denies any knowledge or information

sufficient to form a belief as to the truth of each and every allegation contained in Paragraphs “33”,

“34”, “35”, “36”, “37”, “38”, “39”, “40” and “41” of Plaintiffs’ Verified Complaint as it pertains to

the remaining defendants in the Verified Complaint.

          42.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “42” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “42” of Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.




4831-1993-5273.1
43.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “43” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “43” of Plaintiffs’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

          44,      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “44” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “44” of Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          45.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “45” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “45” of Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.




4831-1993-5273.1
46.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “46” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “46” of Plaintiffs’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

           47.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “47” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS         INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “47” of Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          48.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “48” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of cach and every

allegation contained in Paragraph “48” of Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.




4831-1993-5273.1
49.      Defendant, PEERLESS    INDUSTRIES,      INC., denies each and every allegation

 contained in Paragraph “49” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “49” of Plaintiffs’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            50.      Defendant, PEERLESS    INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “50” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “SO” of Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

                   AS AND FOR AN ANSWER TO THE FIRST CAUSE OF ACTION

           51.      Defendant, PEERLESS INDUSTRIES, INC., herein repeats, reiterates and re-

alleges each and every answer heretofore made to Paragraphs “1” through “50” of Plaintiff's

Verified Complaint as if set forth in full herein.

           52.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “52” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “52” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           53.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “53” of Plaintiff's Verified Complaint, and refers all questions of law to this
4831-1993-5273.1                                     5
Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “53” of Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

           54.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “54” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “54” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           55.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “55” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “55” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          56.      Defendant, PEERLESS     INDUSTRIES,      INC., denies each and every allegation

contained in Paragraph “56(a) through 56(m)” of Plaintiff's Verified Complaint, and refers all

questions of law to this Court for determination at the time of trial, and Defendant, PEERLESS

INDUSTRIES, INC., denies any knowledge or information sufficient to form a belief as to the truth

of each and every allegation contained in Paragraph “56(a) through 56(m)” of Plaintiff's Verified

Complaint as it pertains to the remaining defendants in the Verified Complaint.




4831-1993-5273.1
57.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “57” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiffs Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

           58.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “58” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “58” of Plaintiff's Verified Complaint as it pertains to the

temaining defendants in the Verified Complaint.

          59.      Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “59” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “59” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

                   AS AND FOR AN ANSWER TO THE SECOND CAUSE OF ACTION

          60       Defendant, PEERLESS     INDUSTRIES,       INC., herein repeats, reiterates and re-

alleges each and every answer heretofore made to Paragraphs “1” through “59” of Plaintiff's

Verified Complaint as if set forth in full herein.




4831-1993-5273.1
61      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “61” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “61” of Plaintiff's Verified Complaint as it pertains to the

 temaining defendants in the Verified Complaint.

           62.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “62” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS         INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “62” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          63.      Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “63” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “63” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          64.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “64” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every




4831-1993-5273,1
allegation contained in Paragraph “64” of Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

                    AS AND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION

           65.     Defendant, PEERLESS      INDUSTRIES,      INC., herein repeats, reiterates and re-

 alleges each and every answer heretofore made to Paragraphs “1” through “64” of Plaintiff's

 Verified Complaint as if set forth in full herein.

           66.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “66” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “66” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          67.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “67” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “67” of Plaintiffs Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          68.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “68” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS         INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every




4831-1993-5273.1
allegation contained in Paragraph “68” of Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            69.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “69” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “69” of Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

           70.     Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “70” of Plaintiff’s Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           71.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “71” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           72.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “72” of Plaintiffs Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,



4831-1993-5273.1                                  10
denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “72” of Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            73.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “73” of Plaintiff’s Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

           74.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “74” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

                   AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION

           75.     Defendant, PEERLESS INDUSTRIES, INC., herein repeats, reiterates and re-

alleges each and every answer heretofore made to Paragraphs “1” through “74” of Plaintiff's

Verified Complaint as if set forth in full herein.

           76.     Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “76” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every



4831-1993-5273.1                                     i
allegation contained in Paragraph “76” of Plaintiffs’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            77.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “77” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “77” of Plaintiffs’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

           78.     Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “78” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS         INDUSTRIES, 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 Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           79.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “79” of Plaintiffs* Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           80.     Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “80” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,



4831-1993-5273.1                                  12
denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “80” of Plaintiffs’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            81.    Defendant, PEERLESS      INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “81” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, 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 Plaintiffs’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

           82.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “82” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “82” of Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           83.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “83” of Plaintiffs’ Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, 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 Plaintiffs’ Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          84.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “84” of Plaintiffs’ Verified Complaint, and refers all questions of law to this



4831-1993-5273.1                                  13
Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Piaintifis’ Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            85.    Defendant, PEERLESS INDUSTRIES, INC., denies cach and every allegation

 contained in Paragraph “85(a) through 85(f)” of Plaintiff's Verified Complaint, and refers all

 questions of law to this Court for determination at the time of trial, and Defendant, PEERLESS

 INDUSTRIES, INC., denies any knowledge or information sufficient to form a belief as to the truth

 of each and every allegation contained in Paragraph “85(a) through 85(f)” of Plaintiff's Verified

 Complaint as it pertains to the remaining defendants in the Verified Complaint.

           86.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “86” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “86” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           87.     Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “87” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.




4831-1993-5273.1                                  14
88.    Defendant, PEERLESS      INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “88” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            89.    Defendant, PEERLESS      INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “89” of Plaintiff’ s Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           90.     Defendant, PEERLESS     INDUSTRIES,       INC., denies each and every allegation

contained in Paragraph “90” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           91,     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “91”   of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every




4831-1993-5273.1                                  15
allegation contained in Paragraph “91” of Plaintiff's Verified Complaint as it pertains to the

  remaining defendants in the Verified Complaint.

             92.    Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint.

            93.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “93” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PRERLESS           INDUSTRIES, 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 Plaintiffs Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

                    AS AND FOR AN ANSWER TO THE FIFTH CAUSE OF ACTION

            94,    Defendant, PEERLESS      INDUSTRIES,       INC., herein repeats, reiterates and re-

 alleges each and every answer heretofore made to Paragraphs “1” through “93” of Plaintiff's

Verified Complaint as if set forth in full herein,

           95.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “95” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           96.     Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “96” of Plaintiff's Verified Complaint, and refers all questions of law to this



4831-1993-5273.1                                     16
Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, 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 Plaintiffs Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            97.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “97” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiffs Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           98.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “98” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES,                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 Plaintiffs Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           99.     Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “99” of Plaintiff’s Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.




4831-1993-5273.1                                  17
100.     Defendant, PEERLESS   INDUSTRIES,       INC., denies each and every allegation

 contained in Paragraph “100” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            101.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “101” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “101” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

                    AS AND FOR AN ANSWER TO THE SIXTH CAUSE OF ACTION

           102.      Defendant, PEERLESS INDUSTRIES, INC., herein repeats, reiterates and re-

alleges each and every answer heretofore made to Paragraphs “1” through “101” of Plaintiff's

Verified Complaint as if set forth in full herein.

           103.      Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “103” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PRERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.




4831-1993-5273.1                                     18
104.   Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “104” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            105.   Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “105” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, 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 Plaintiffs Verified Complaint as it pertains to the

temaining defendants in the Verified Complaint.

           106,    Defendant, PEERLESS     INDUSTRIES,       INC., denies each and every allegation

contained in Paragraph “106” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           107.    Defendant, PEERLESS     INDUSTRIES,       INC., denies each and every allegation

contained in Paragraph “107” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every




4831-1993-5273.1                                  19
allegation contained in Paragraph “107” of Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            108.   Defendant, PEERLESS      INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “108” of Plaintiff’s Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            109.   Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “109” of Plaintiff's Verified Complaint, and refers all questions oflaw to this

Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           110.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “110(i) through 110(ii)” of Plaintiff's Verified Complaint, and refers all

questions of law to this Court for determination at the time of trial, and Defendant, PEERLESS

INDUSTRIES, INC., denies any knowledge or information sufficient to form a belief as to the truth

of each and every allegation contained in Paragraph “1 10(i) through 1 10(iii)” of Plaintiff's Verified

Complaint as it pertains to the remaining defendants in the Verified Complaint.

           111.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “111” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,



4831-1993-5273.1                                  20
denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “111” of Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            112.   Defendant, PEERLESS      INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “112” of Plaintiffs Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            113.   Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “113” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           114.    Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “114” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           115.    Defendant, PEERLESS     INDUSTRIES,       INC., denies each and every allegation

contained in Paragraph “115” of Plaintiff's Verified Complaint, and refers all questions of law to this



4831-1993-5273.1                                  21
Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            116.   Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “116” of Plaintiffs Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            117.   Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “117” of Plaintiff’ s Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

              AS AND FOR AN ANSWER TO THE SEVENTH CAUSE OF ACTION

           118.    Defendant, PEERLESS INDUSTRIES, INC., herein repeats, reiterates and re-

alleges each and every answer heretofore made to Paragraphs “1” through “117” of Plaintiff's

Verified Complaint as if set forth in full herein.

           119.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “119” of Plaintiffs’ Verified Complaint as it pertains to this answering

defendant and Defendant, PEERLESS INDUSTRIES, INC., denies any knowledge or information



4831-1993-5273.1                                     22
sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “119”

 of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Verified

 Complaint.

            120.   Defendant, PEERLESS      INDUSTRIES,       INC., denies each and every allegation

 contained in Paragraph “120” of Plaintiffs’ Verified Complaint as it pertains to this answering

 defendant and Defendant, PEERLESS INDUSTRIES, INC., denies any knowledge or information

 sufficient to form a belief as to the truth of each and every allegation contained in Paragraph “120”

 of Plaintiffs’ Verified Complaint as it pertains to the remaining defendants in the Verified

 Complaint.

            121.   Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “121” of Plaintiff’s Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “121” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           122.    Defendant, PEERLESS     INDUSTRIES,       INC., denies each and every allegation

contained in Paragraph “122” of Plaintiff’s Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “122” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           123.    Defendant, PEERLESS     INDUSTRIES,       INC., denies each and every allegation

contained in Paragraph “123” of Plaintiffs Verified Complaint, and refers all questions of law to this



4831-1993-5273.1                                  23
Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “123” of Plaintiffs Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

           124,    Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “124” of Plaintiffs Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “124” of Plaintiffs Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

           125.    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “125” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “125” of Plaintiffs Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

          126.     Defendant, PEERLESS INDUSTRIES, INC., denies cach and every allegation

contained in Paragraph “126” of Plaintiffs Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

denies any knowledge or information sufficient to form a belief as to the truth of each and every

allegation contained in Paragraph “126” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.




4831-1993-5273.1
127.   Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “127” of Plaintiff's Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “127” of Plaintiff's Verified Complaint as it pertains to the

 remaining defendants in the Verified Complaint.

            128.    Defendant, PEERLESS     INDUSTRIES, INC., denies each and every allegation

 contained in Paragraph “128” of Plaintiff’s Verified Complaint, and refers all questions of law to this

 Court for determination at the time of trial, and Defendant, PEERLESS          INDUSTRIES, INC.,

 denies any knowledge or information sufficient to form a belief as to the truth of each and every

 allegation contained in Paragraph “128” of Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.

            129,    Defendant, PEERLESS INDUSTRIES, INC., denies each and every allegation

contained in Paragraph “129” of Plaintiff's Verified Complaint, and refers all questions of law to this

Court for determination at the time of trial, and Defendant, PEERLESS           INDUSTRIES, 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 Plaintiff's Verified Complaint as it pertains to the

remaining defendants in the Verified Complaint.