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S
UPREME COURT
OF THE STAT
E
OF
NEW
YORK
COUNT
Y OF OR
ANGE
NINTHJUDICIA
LDIST
RICTENVIRONM
ENTAL
CLAIMS
PART
VILL
AGE
OF
SO
UTH
BLOOM
INGGR
OVE et
al.,
Peti
tioners,
IndexN
o. 7410/2015
Proceedi
ng
N
o.
For
a
Ju
dgment Pursuant
to
Article
78 ofthe
Civil
Practice Law
and
Rules
against
VILLAG
E
OF KIRYAS
JOEL BOARDOF
TRUSTEE
S
et al.,
Hon
.
Franc
esca
E.
Connolly
Respondents
,
EMANUELLEONOROVITZ
et al.,
dditional
Res
pondents.
PRESE
RVE
HUDSONVA
LLEY
et al.,
Pe
titioners/Plaint
iffs,
Index
No.: 8118/2015
Proceeding
N
o, 2
-
agains
t
-
TOWNB
OARDOF THETOWN
OF MON
ROE et al.,
Resp
ondents/Defen
dants.
VERIF
IEDANSWE
R
TO
AMENDEDVER
IFIEDPE
TITIONAND
COMPL
AINT OFPETITION
ERS/PLAINT
IFFS INPROCEEDIN
GN
O. 2
Respondents-
Defendants Village
Board of
the
V
illage o
fKiryas J
oel
and
t
he
Village of
Kirya
s Joel
collectively
the
V
illage or K
iryas
Joel ), by an
d through their
att
orneys,
Whiteman Osterman
Han
na LLP,
respectfully submit the
foreg
oing
Veri
fied
Answer to the
Amended
Verified
Petitio
n and
Complaint filed
by
Pe
titionersPlain
tiffs Pre
serve
Huds
on
Va
lley
e
t al. in
Proce
edingNo. 2 the PHVPeti
tion ):
7/21/2019 Verified Answer (Pro 2 8110-2015) 012216
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With
respect
to
the allegations
set
forth in Paragraph
of
the
PHV Petition,
including subparagraphs
(i)
through
(vii) thereof, the Village admits that Petitioners
seek
the
relief specified
therein, but denies
that
Petitioners are
entitled
thereto.
With
respect
to
the
allegations
set
forth in
Paragraph
2
of
the PHV Petition, the
.
Village
states
that
such
allegations set
forth conclusions of law
for
which
no responsive pleading
is required.
3.
The
Village admits the allegations
set
forth
in
Paragraph 3
of
the
PHV Petition,
except lacks
knowledge or information sufficient
to
form
abelief
as
to the
identity of
the Town
Council
and denies
that
the
Village sought annexation
of
any territory
that
is
the
subject of the
164-acre annexationpetition.
With respect to
the
allegations
set
forth in Paragraph
4 of the
PHV
Petition, the
.
Village
states
that such allegations
set
forth
conclusions of
lawforwhichno responsive pleading
is
required, but
to the extent
an answer is made,
the
Village denies
Petitioners'
characterization
thereofand
further
states as follows:
a
The
allegations
entitled Violation
of
the Establishment Clause set forth
conclusions
of
law
for
which
no
responsive pleading is
required,
but to the
extent
an answer
is made,
the Village refers the
Court to
the statutes
and/or
regulations
referenced therein for determination
of their
content, meaning
and
effect,
and denies
Petitioners' characterizations thereof.
b.
The
allegations entitled
Arbitrary
Designation
of
Village
Board
as
Lead
Agency set forth conclusions
of
law for
which
no responsive pleading
is
required,
but
to
the extent an
answer is
made, the
Village refers
the Court
to
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the statutes and/or regulations referenced therein
for
determination of their
content, meaning and effect, and denies Petitioners' characterizations thereof.
c.
The
allegations entitled
Arbitrary and Capricious
SEQRA
Determination
By
TownBoard set
forth conclusions
of law
for which
no responsive pleading is
required,
but
to the extent an answer
is
made, the Village refers the Court to
the statutes
and/or
regulations referenced
therein for
determination
of
their
content,
meaning
and effect, and denies Petitioners' characterizations thereof.
d. The allegations entitled Arbitrary and
Capricious
Determination By Village
Board set
forth conclusions
of
law for which no
responsive pleading is
required,
but to the extent
an
answer is made, the Village
refers
the Court to
the
statutes
and/or
regulations
referenced therein
for determination of their
content,
meaning
and
effect,
and
denies Petitioners'
characterizations thereof.
e The
allegations entitled
Improper Use of
Annexation to Up-Zone
set
forth
conclusions
of
law for
which no
responsive pleading is required, but to the
extent an
answer
is
made, theVillage denies the allegations.
f.
The allegations entitled
Improper Creation of 'Baroque'
Boundaries
set
forth conclusions
of law
for which no responsive pleading is required,
but
to
the extent an
answer is made,
the
Village
refers the
Court
to
the statutes
and/or regulations referenced therein for determination of
their
content,
meaning
and
effect,
and denies
Petitioners'
characterizations thereof.
g. The
allegations entitled Violation of Town Ethics Code set forth
conclusions
of
law for which no responsive pleading is required, but to the
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extent an answer is made, the Village lacks knowledge or
information
sufficient to
formabelief
as to
the truth
of
the allegations
set forth.
h. The
allegations
entitled Insufficient Signatures and Territorial
Description
set
forth conclusions of
law for
which
no responsive pleading is required,
but
to
the
extent
an
answer is
made, the Village
refers the Court
to the statutes
and/or regulations referenced therein for determination of their content,
meaning
and
effect,
and denies
Petitioners' characterizations thereof.
The
allegations
entitled
Violation
of Prior Jurisdiction Rule set forth
conclusions of law for which no
responsive
pleading
is
required, but to
the
extent any answer is
made,
the
Village
refers
the
Court to the
statutes
and/or
regulations
referenced
therein for determination
of
their content,
meaning
and
effect, and deniesPetitioners'
characterizations thereof.
TheVillage
denies
the
allegations set forth inParagraph 5
of
thePHVPetition.
.
6.
With
respect
to the
allegations
in
Paragraph
6
of
the
PHV Petition, the
Village
lacks knowledge or information sufficient to
form
a belief as to
the
truth
of
the allegations set
forth.
The Village denies the allegations in
Paragraph
7 ofthe
PHV
Petition.
.
The Village
denies
the allegations
in
Paragraph
8 of
the
PHV
Petition..
The Village denies
the
allegations
in
Paragraph
9
of
the
PHV
Petition..
10.
With
respect to the
allegations
in
Paragraph
10
of the
PHV
Petition,
the
Village
states that
such
allegations
set
forth
conclusions of law
for
which no
responsive pleading
is
required, but to
the
extent and
answer
is made,
the
Village
refers the
Court to the statutes and/or
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regulations
referenced therein for determination of their content, meaning and effect,
and
denies
Petitioners' characterizations thereof.
With
respect
to the
allegations in Paragraph
of
the
PHY
Petition,
the Village
lacks knowledge or
information sufficient
to form
a
belief as to the
truth of the
allegations set
forth.
12. With
respect
to
the
allegations
in Paragraph
12 of
the
PHV Petition,
the
Village
lacks knowledge
or
information sufficient
to
form a belief as to the truth
of
the allegations set
forth.
13.
The
Villagedenies
the
allegations in
Paragraph
13
ofthePHV
Petition.
14.
TheVillage denies
the
allegations
in
Paragraph
14
of
the
PHVPetition.
15.
With
respect to the allegations in Paragraph
15
of the PHV Petition, the Village
lacks knowledge
or information sufficient
to form
a
belief as to the
truth of the
allegations
that
Petitioner
Allegro has
a
daughter, and otherwise
denies
the
allegations
in
Paragraph
15.
16. With respect to the allegations
in
Paragraph 16
of
the PHV Petition, the Village
the
Village
lacks knowledge or
information
sufficient to
form a
belief as to the truth of
the
allegations
set
forth.
17. With respect to the allegations
in
Paragraph 17
of
the PHV
Petition,
the Village
lacks knowledge or information
sufficient
to form
a belief
as to the
truth
of
the
allegations
that
Petitioner Convers is in
Orange County
SewerDistrict
1, andotherwise
denies the allegations
set
forth in
Paragraph
17.
18. With respect to the allegations
in
Paragraph
18
of
the PHV Petition, the Village
lacks knowledge
or information sufficient
to
form a
belief
as
to
the truth of the
allegations that
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Petitioner Convers
has
two
sons
who
attendMWCSD
public
schools,
and
otherwise
denies the
allegations in
Paragraph 18.
19.
With
respect to
the
allegations in Paragraph 19
of
the PHV
Petition,
the Village
lacks knowledge or informationsufficient to form a
belief
as to the truth
of
the allegations.
20. With respect to the allegations in Paragraph 20
of
the PHV
Petition,
the Village
lacks knowledge or
information
sufficient to
forma
beliefas to the truth ofthe allegations.
21 The Village denies the allegations
in
Paragraph 21 ofthePHVPetition.
22. With respect to the
allegations
in
Paragraph 22 of the PHV
Petition,
the
Village
lacks knowledge or informationsufficient to form a
belief
as to the truthofthe
allegations.
23.
With
respect to the allegations in Paragraph 23 of the PHV Petition, the Village
lacks
knowledge or
information
sufficient to
forma
beliefas to the truth of
the
allegations.
24. With
respect
to the allegations in
Paragraph
24 of the
PHV
Petition, the
Village
lacks
knowledge or information
sufficient to
formabelief as
to the
truth
ofthe allegations.
25.
The Village admits the allegations inParagraph
25
ofthePHV Petition.
26. With
respect
to the
allegations
in Paragraph
26 of the
PHV Petition,
the
Village
lacks knowledge or informationsufficient to form a
belief
as to the truth
of
the allegations.
27. With respect to the allegations in Paragraph 27 of the PHV Petition, the Village
lacks
knowledge
or information
sufficient to
formabelief
as to the
truth
ofthe allegations.
28.
With
respect to the allegations
in Paragraph
28 of the
PHV
Petition, the
Village
admits
that
the
DEC
Commissioner
designated the
Village
as
lead
agency
for
the
507-acre
annexation
petition.
29.
With
respect to the allegations in Paragraph 29 of the PHV Petition, the Village
lacks
knowledge
or informationsufficient
to
form a
belief
as
to
the truthof the allegations.
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30.
ithrespect to th
e
alleg
ations set
forth inPa
ragraph
30
o
f
the PHY
Petition, the
Village refers
the Court to
the documen
ts
refer
enced therein
for determinati
onof
their
conten
t,
meaning
and effect, and othe
rwise
la
cks knowledge
or info
rmation suffi
cient
to
form
a
beliefs
to the truthof
the allegations.
ith
respect to the allegations
set
forth
in
Paragraph
of the
PHV
Petitio
n, the
Village refers
the Court to the
documents referenced
therein for de
termination
of the
ir
content,
me
aning and effect
,
and
otherwise lacks know
ledge
or informat
ion sufficient
to
form
a
be
lief
s
t
o
the
truth ofthe allega
tions.
32.
ith
respect
to
the allegations
set
forth in
Paragraph
32 of
the
PHV
Petition,
the
Villa
ge
refers
the Cou
rt to the documen
ts
ref
erenced there
in for determina
tionof
their
cont
ent,
meaning and
effect, and othe
rwise lacks knowledge
or in
formation sufficie
nt
to
form abeliefas
to the truthofthe
allegations.
33. ith
respect to the allegation
s set
forth inParagra
ph 33 of the
PHV
Peti
tion, the
illager
efers
the
ou
rt to the
documents referenced th
erein for determina
tionof their
content,
meaning
and
effect, and otherwis
e
lacks k
nowledge
or infor
mation sufficien
t
to
form abelief s
to the truth ofthe
allegations.
34. ith
respect to the allegations
set for
th
in
Paragrap
h 34 of the P
HV
Petition,
the
Village
r
efers the
Court to the
documents referenced
therein for det
ermination o
f the
ir
content,
m
eaning and effe
ct, and otherwise lacks kn
owledge
or inform
ation sufficient to form abel
iefas
to
the
truth
of
the allegations.
35. ith
respect to the allegati
ons set forth
inPara
graph 35
of
the PHV Petition
the
Village
refe
rs t
he
C
ourt to the docum
ents referenced th
erein for determ
ination of
their
co
ntent,
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meaning
and
effect,
and
otherwise
lacks
knowledge
or information sufficient
to
form a
belief
as
to the
truthofthe
allegations.
36.
With
respect
to
the allegations
set
forth
in
Paragraph 36 of
the
PHV
Petition, the
Village refers the Court to the documents referenced therein
for
determination of their content,
meaning
and
effect,
and otherwise
lacks
knowledge or
information
sufficient
to form a belief
as
to the truth
of
the
allegations.
37. With respect
to
the allegations
set
forth inParagraph 37 of the PHV
Petition,
the
Village refers the
Court to
the
documents referenced therein for determination
of their
content,
meaning and effect, and
otherwise
lacks
knowledge
or
information sufficient
to
form
a
belief as
to the truth
ofthe allegations.
38.
With
respect to the allegations
set
forth
in
Paragraph
38
of the PHV
Petition, the
Village
refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and
effect,
and otherwise
lacks
knowledge or information sufficient
to
form a
belief
as
to the truth
ofthe
allegations.
39.
With
respect
to
the allegations
set
forth
in
Paragraph 39 of the PHV
Petition, the
Village
refers the Court to the
documents
referenced therein
for
determination of their
content,
meaning
and
effect,
and otherwise
lacks
knowledge or information sufficient
to
form a
belief as
to
the truth
ofthe
allegations.
40.
With
respect
to
the allegations
set forth in
Paragraph 40 of the PHV
Petition, the
Village
refers
the
Court to
the documents referenced
therein
for
determination
of
their
content,
meaning
and effect,
and
otherwise lacks knowledge
or information sufficient
to
form
a
belief
as
to the
truthofthe
allegations.
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41.
With
respect to the allegations set forth
in
Paragraph 41 of the PHV Petition, the
Village refers
the Court
to the documents referenced therein for determination of their content,
meaning
and effect, and
otherwise lacks knowledge
or information sufficient
to
form a
belief as
to the
truthofthe
allegations.
42. With
respect
to the
allegations
set
forth
in
Paragraph 42 of the PHV
Petition, the
Village
refers
the
Court to the documents referenced therein
for
determination of their content,
meaning and effect, and otherwise lacks knowledge
or
information sufficient to form abelief as
to the truth
ofthe allegations.
43.
With
respect to the allegations set forth in Paragraph 43
of
the PHV Petition, the
Village refers the Court
to the documents referenced
therein for
determination of their
content,
meaning
and
effect,
and
otherwise
lacks knowledge or information
sufficient
to form a
belief
as
to the truth
ofthe
allegations.
44.
With
respect to the allegations set forth
in
Paragraph 44
of
the PHV Petition, the
Village refers the Court to the documents referenced
therein
for determination of
their
content,
meaning
and
effect,
and
otherwise
lacks knowledge or
information
sufficient to
form a
belief as
to the
truthofthe
allegations.
45.
With
respect
to
the allegations set forth
in
Paragraph 45 of the PHV
Petition, the
Village refers the Court to the documents referenced therein
for
determination
of their
content,
meaning
and
effect,
and
otherwise lacks knowledge
or information sufficient to
form
a
belief
as
to
the
truth
ofthe allegations.
46. With respect to the allegations set
forth
in
Paragraph
46 of
the PHV Petition, the
Village refers the Court to the documents referenced therein for determination of their content,
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meaning and effect,
and
otherwise lacks knowledge
or
information
sufficient
to form a
belief
as
to the
truthofthe
allegations.
47.
With
respect
to
the allegations set forth
in
Paragraph 47 of the PHV
Petition,
the
Village
refers the Court to the documents referenced
therein
for determination
of their
content,
meaning
and
effect,
and
otherwise
lacks
knowledge or
information
sufficient
to
form a
belief as
to the
truth
ofthe
allegations.
48. With
respect
to
the allegations
set
forth
in
Paragraph 48 of
the
PHV
Petition,
the
Village refers the Court to the documents referenced therein for determination
of
their content,
meaning and effect, and otherwise
lacks knowledge
or
information sufficient to
form
a
belief as
to the
truthofthe allegations.
49. With respect to the allegations set forth inParagraph 49
of
the PHV Petition, the
Village
refers
the
Court to the documents referenced
therein for
determination of
their content,
meaning and effect,
and
otherwise
lacks knowledge
or
information
sufficient
to form a
belief
as
to the
truthof the allegations.
50.
With
respect to the allegations set forth
in
Paragraph 50
of
the PHV
Petition,
the
Village
refers
the
Court to the documents referenced
therein
for determination
of their
content,
meaning
and effect, and otherwise
lacks
knowledge or information sufficient
to
form
a belief
as
to the
truth
ofthe allegations.
51.
With
respect
to
the allegations
set
forth
in
Paragraph
51
of
the
PHV
Petition,
the
Village
refers the
Court to
the documents referenced
therein
for
determination
of
their
content,
meaning
and
effect,
and otherwise
lacks knowledge
or information sufficient
to
form
a belief
as
to
the truthof the
allegations.
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52.
With
respect
to the allegations set
forth
inParagraph 52
of
the
PHY
Petition, the
Village
refers
the Court
to the
documents
referenced therein
for determination of their
content,
meaning
and
effect,
and
otherwise lacks knowledge
or
information
sufficient
to form a belief as
to the
truthofthe
allegations.
53.
With
respect to the allegations set forth in Paragraph 53
of
the
PHV
Petition,
the
Village refers the Court to the documents referenced therein for determination
of their
content,
meaning
and effect, and otherwise
lacks knowledge
or informationsufficient
to
form a
belief
as
to the truthofthe allegations.
54.
With
respect
to
the allegations
set
forth in
Paragraph
54
of the
PHV
Petition,
the
Village refers the Court to the
documents
referenced therein
for
determination of their content,
meaning and effect, and
otherwise
lacks knowledge or information sufficient to form a belief as
to the
truthofthe
allegations.
55.
With
respect to the
allegations
set forth
in
Paragraph 55
of
the PHV Petition, the
Village refers the
Court to the documents referenced
therein
for determination
of their
content,
meaning and effect,
and
otherwise lacks knowledge or information sufficient
to
form a
belief
as
to the truth
ofthe
allegations.
56.
With
respect to the
allegations
set forth
in
Paragraph 56
of
the PHV
Petition,
the
Village refers the Court to the documents referenced therein for determination
of
their content,
meaning
and effect,
and
otherwise lacks knowledge or information sufficient
to
form
a belief
as
to
the
truth
ofthe allegations.
57.
With respect
to the
allegations set forth in Paragraph
57 of the PHV Petition,
the
Village
refers
the
Court to the documents referenced therein for determination of their content,
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meaning
and
effect,
and
otherwise lacks knowledge or
information sufficient
to form abelief as
to the truth
of
the allegations.
58.
With respect to
the
allegations
set
forth in Paragraph
58
of
the PHV Petition,
the
Village refers the Court to the documents referenced therein for determination of
their
content,
meaning
and
effect,
and
otherwise
lacks knowledge or information sufficient
to
form
abelief
as
to
the truth ofthe
allegations.
59. With respect to the allegations se t forth
in
Paragraph 59
of
the PHV
Petition,
the
Village
refers
the
Court
to the documents
referenced therein
for
determination
of their
content,
meaning and
effect,
and otherwise lacks knowledge or
information sufficient to
form a
belief as
to the truth
of
the allegations.
60.
With
respect to the allegations set forth in Paragraph
60 of
the
PHV Petition,
the
Village
refers
the Court to the documents
referenced
therein for determination of their
content,
meaning and effect, and otherwise
lacks knowledge or information sufficient
to
form
abelief
as
to the truth
of
the
allegations.
61.
With respect
to the
allegations
set
forth in Paragraph 61
of the PHV Petition, the
Village refers the Court to
the documents
referenced therein for determination of
their
content,
meaning and effect, and otherwise lacks
knowledge or
information sufficient
to
form abelief as
to the
truth
of
the
allegations.
62. With respect
to
the allegations
set
forth
in Paragraph
62 of
the PHV
Petition,
the
Village
refers
the
Court to
the documents
referenced
therein
for
determination
of
their
content,
meaning and
effect,
and
otherwise lacks knowledge or information sufficient
to
form a belief
as
to
the truthofthe
allegations.
63. With respect to
the
allegations set forth inParagraph 63 of
the PHV
Petition, the
12
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Village refers the Court
to
the
documents referenced therein
for
determination of their
content,
meaning and
effect,
and
otherwise
lacks knowledge or information sufficient to form
a belief
as
to
the
truthofthe allegations.
64.
With respect
to the
allegations
set
forth inParagraph
64 of
the
PHY Petition, the
Village
refers the Court to the documents referenced therein for determination
of
their content,
meaning and effect, and otherwise lacks
knowledge
or information
sufficient
to form abelief as
to the truth
of
the allegations.
65.
With
respect
to the allegations set forth inParagraph 65 of the PHV Petition, the
Village
refers
the
Court to
the documents referenced
therein
for
determination
of
their
content,
meaning and effect, and otherwise lacks knowledge or information sufficient to form a belief as
to the truth
of
the allegations.
66.
With
respect to the
allegations
set forth inParagraph 66 of the
PHV
Petition,
the
Village refers
the Court
to the documents referenced therein for determination
of their
content,
meaning and
effect,
and
otherwise
lacks knowledge or information sufficient to form
a belief
as
to the truth ofthe allegations.
67.
With respect
to
the allegations
set
forth in
Paragraph 67 of the
PHV Petition,
the
Village refers
the
Court to the documents referenced therein for determination of
their
content,
meaning
and
effect,
and otherwise
lacks knowledge
or information sufficient
to
form
a belief as
to the truthofthe
allegations.
68.
With
respect
to
the allegations
set
forth in
Paragraph
68
of
the
PHV
Petition,
the
Village
refers
the
Court to
the
documents referenced therein for determination
of their
content,
meaning and effect, and otherwise lacks knowledge or information sufficient to form a belief
as
to
the
truth
ofthe allegations.
13
7/21/2019 Verified Answer (Pro 2 8110-2015) 012216
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69.
With
respect
to the
allegations
set
forth
in
Paragraph 69 of the PHV
Petition,
the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and
effect, and
otherwise lacks knowledge
or information sufficient
to form a belief as
to the
truth
of
the
allegations.
70.
With respect to
the
allegations
set forth
in Paragraph
70 of the PHV
Petition, the
Village
refers
the Court to the documents
referenced
therein
for
determination
of
their content,
meaning
and
effect,
and
otherwise lacks knowledge
or information
sufficient to form a
belief
as
to
the truthofthe
allegations.
71. With
respect
to
the allegations
set
forth
in
Paragraph 71
of
the
PHV Petition, the
Village
refers
the Court
to the documents referenced therein for determination
of their
content,
meaning
and
effect, and
otherwise
lacks knowledge or information
sufficient
to
form a
belief
as
to
the truth
of
the allegations.
72. With
respect
to the allegations set forth inParagraph 72 of the
PHV
Petition,
the
Village
refers the Court to the documents referenced therein for determination
of their
content,
meaning
and
effect,
and otherwise
lacks knowledge
or information sufficient
to form
a
belief as
to the
truthofthe
allegations.
73.
With respect to
the allegations
set forth in
Paragraph
73 of
the
PHV
Petition, the
Village
refers the Court to
the
documents referenced therein for determination of their content,
meaning
and effect, and
otherwise
lacks
knowledge
or information
sufficient to form a belief
as
to the
truth
of
the
allegations.
74. With respect to the allegations set forth
in
Paragraph
74 of the
PHV Petition, the
Village
refers
the Court
to
the
documents referenced therein for determination
of their
content,
meaning
and
effect,
and
otherwise
lacks
knowledge or information
sufficient
to form
a belief
as
14
7/21/2019 Verified Answer (Pro 2 8110-2015) 012216
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to the truth
of
the
allegations.
75. With respect to the
allegations
set forth
in
Paragraph 75 of the
PHV
Petition,
the
Village
refers
the
Court to
the
documents referenced
therein
for determination
of their
content,
meaning
and
effect,
and
otherwise
lacks knowledge
or
information
sufficient
to
form a
belief
as
to the
truthof
the
allegations.
76.
With
respect
to
the
allegations set
forth
in
Paragraph 76 of the PHV
Petition,
the
Village
refers
the
Court
to the documents referenced
therein
for determination of their content,
meaning
and effect, and otherwise
lacks knowledge
or information sufficient
to
form
a belief as
to the truthofthe allegations.
77. With respect to the allegations set forth in Paragraph 77
of
the
PHV
Petition, the
Village refers
the Court to the documents referenced therein for determination
of
their content,
meaning and
effect, and
otherwise lacks knowledge
or information sufficient
to form
a
belief as
to
the truthofthe allegations.
78.
With
respect to the
allegations
set forth in Paragraph 78 of the PHV Petition, the
Village
refers
the
Court to the documents referenced
therein
for determination
of their
content,
meaning
and
effect,
and
otherwise
lacks knowledge
or information sufficient
to form a
belief
as
to the truth
of
the allegations.
79.
With respect
to the allegations set
forth in Paragraph
79 of
the
PHV Petition,
the
Village
refers
the
Court to the documents referenced therein for determination
of their
content,
meaning and
effect,
and
otherwise
lacks
knowledge
or
information sufficient
to
form a belief
as
to the
truthofthe
allegations.
80.
With
respect
to
the
allegations
set forth
in Paragraph 80 of
the PHV
Petition,
the
Village refers
the
Court to
the
documents referenced therein for determination of their
content,
15
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meaning
and
effect,
and otherwise lacks knowledge or
information
sufficient to form
a belief
as
to the
truthofthe
allegations.
81.
With respect
to
the allegations
set
forth inParagraph
81 of
the
PHY Petition, the
Village refers
the
Court to
the
documents referenced therein for determination
of their
content,
meaning and effect,
and
otherwise
lacks knowledge
or
information
sufficient to form abelief
as
to
the truth
of
the
allegations.
82. With
respect
to the allegations set forth inParagraph 82
of
the
PHV
Petition, the
Village
refers
the
Court to the
documents
referenced therein for determination
of their
content,
meaning
and
effect,
and
otherwise lacks knowledge
or information
sufficient to form
a belief
as
to
the truthofthe
allegations.
83.
With respect to the
allegations
set
forth
in
Paragraph
83
of
the PHV Petition, the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and
effect,
and otherwise
lacks knowledge
or information sufficient
to
form a
belief as
to the truthofthe allegations.
84.
With
respect
to the
allegations
set
forth
in
Paragraph
84
of
the
PHV
Petition,
the
Village refers the Court to the documents referenced therein
for
determination of their content,
meaning
and
effect,
and otherwise
lacks knowledge
or informationsufficient
to
form a
belief as
to
the
truthofthe allegations.
85.
With
respect
to the
allegations set
forth in
Paragraph
85
of
the
PHV
Petition, the
Village
refers the
Court to
the documents referenced
therein
for
determination
of
their
content,
meaning
and
effect,
and
otherwise lacks knowledge
or information sufficient
to form
a
belief as
to the truth
of
the allegations.
86. With respect to the allegations set forth
in
Paragraph 86 of the
PHV
Petition, the
16
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Village refers
the Court
to the
documents
referenced therein for determination
of their
content,
meaning and
effect,
and
otherwise
lacks
knowledge or information sufficient
to
form a
belief
as
to
the truth
of
the allegations.
87. With
respect
to the allegations set forth in
Paragraph
87
of
the
PHV
Petition, the
Village
refers the Court to the
documents
referenced therein
for
determination
of
their content,
meaning and
effect,
and
otherwise
lacks
knowledge or information sufficient to form abelief
as
to
the
truthof
the
allegations.
88. With respect to the allegations set
forth
inParagraph 88
of
the PHV Petition, the
Village refers the
Court to
the documents
referenced
therein for
determination of their content,
meaning and effect, and otherwise lacks knowledge or information sufficient to form abelief
as
to
the truth
of
the allegations.
89. With
respect
to the allegations set
forth inParagraph
89 of the PHV Petition, the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning and effect,
and
otherwise
lacks
knowledge or information sufficient to form
a belief as
to the truthofthe allegations.
90.
With
respect
to
the
allegations
set forth in Paragraph 90 of the PHV
Petition,
the
Village refers the Court to the documents referenced therein for determination
of their
content,
meaning and
effect,
and otherwise
lacks knowledge
or information sufficient
to
form
a belief
as
to the
truth
of
the
allegations.
91.
With
respect
to
the
allegations
set
forth in
Paragraph
91
of
the
PHV
Petition,
the
Village refers the Court to the documents
referenced
therein for determination of their content,
meaning
and
effect,
and
otherwise lacks knowledge
or information sufficient
to
form a
belief as
to the
truthofthe
allegations.
17
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92. With respect to the
allegations
set forth in Paragraph 92
of
the
PHY
Petition, the
Village refers
the
Court
to
the
documents referenced therein
for
determination of their content,
meaning
and effect, and otherwise lacks knowledge or information
sufficient
to
form abelief as
to
the truth
of
the allegations.
93.
With
respect
to the allegations set
forth
in
Paragraph
93
of the PHV
Petition,
the
Village refers the Court to the documents referenced therein for determination of their content,
meaning
and
effect,
and otherwise
lacks knowledge
or information sufficient
to
form a
belief as
to
the
truth
of
the
allegations.
94.
With
respect
to
the allegations
set forth in
Paragraph 94 of the
PHV
Petition,
the
Village refers
the
Court
to
the
documents referenced therein for determination
of
their content,
meaning and effect, and otherwise lacks knowledge or information sufficient to form a belief as
to
the truthofthe
allegations.
95. With respect to the
allegations
set forth
in
Paragraph 95
of
the
PHV
Petition, the
Village refers the Court
to
the
documents
referenced
therein
for
determination of
their
content,
meaning and effect, and otherwise lacks
knowledge
or information sufficient
to
form a
belief
as
to the truth
of
the allegations.
96.
With
respect to the
allegations
set forth
in
Paragraph 96
of
the PHV
Petition,
the
Village refers
the Court
to the documents referenced therein for determination
of
their content,
meaning and
effect,
and otherwise lacks
knowledge
or information sufficient
to
form
a belief
as
to
the
truth
of
the allegations.
97.
With
respect
to the allegations set
forth
in
Paragraph 97 of
the
PHV
Petition,
the
Village
refers the Court to
the
documents referenced therein
for
determination
of
their content,
meaning
and effect, and
otherwise
lacks
knowledge or information
sufficient to
form a belief
as
18
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to
the truthofthe
allegations.
98.
With respect to the
allegations
set
forth
inParagraph 98
of
the
PHY
Petition, the
Village
refers
the
Court to
the documents
referenced
therein for
determination
of their
content,
meaning
and
effect,
and
otherwise lacks knowledge
or
information
sufficient
to form a
belief
as
to
the truthofthe
allegations.
99.
With
respect to the allegations set forth inParagraph 99 of the PHV Petition, the
Village
refers the
Court
to the documents referenced
therein
for determination
of their
content,
meaning
and
effect,
and
otherwise lacks knowledge
or information sufficient
to
form a
belief as
to the truth
of
the
allegations.
100.
With
respect
to the
allegations set
forth inParagraph
100 of the PHV
Petition,
the
Village
refers
the
Court to the documents referenced
therein
for determination
of
their content,
meaning
and
effect,
and otherwise
lacks knowledge
or information sufficient
to form
a
belief as
to
the truth
ofthe
allegations.
101.
With respect to the allegations set forth
in
Paragraph 101
of
the
PHV
Petition, the
Village refers the
Court to the documents referenced therein
for
determination of their content,
meaning
and
effect,
and
otherwise lacks knowledge or
information sufficient
to form abelief as
to
the truthofthe allegations.
102. With respect to the allegations set forth inParagraph 102 ofthe PHV Petition, the
Village
refers
the
Court to
the
documents referenced therein for determination
of their
content,
meaning and effect, and otherwise
lacks knowledge or
information sufficient
to
form
a
belief as
to the truthofthe allegations.
103.
With respect
to
the allegations set forth
in
Paragraph
103
of thePHV
Petition,
the
Village
refers
the Court
to the documents referenced therein
for
determination
of their
content,
19
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meaning and effect,
and otherwise
lacks know
ledge or informat
ion sufficient to form a
belief
s
to the truthofthe
allegations.
104. With
respect to the
allegations set fo
rth
in
Paragraph
104 ofthePH
YPetition,
the
Village refers
the
ourt
to th
e
docum
ents referenced therein
for determinati
on of their
content,
meanin
g
and
effect,
and
ot
herwise lacks
knowledge or in
formation sufficie
nt to form a
belief s
to
the
truth ofthe alle
gations.
105. With re
spect
to
the allegatio
ns
se
t forth inPa
ragraph 105
of
the
PHVPetition,
the
Village
refers
the
Co
urt to the document
s referenced there
in for determinat
ion of
their content,
meaning and effect, and otherwise lacks
knowledge
or
information
sufficient to form
a
belief s
to
the truthof
the alle
gations.
106. W
ith
re
spect to the
allegatio
ns
se
t
forth inPa
ragraph
106 ofthePHVP
etition, the
Villa
ge
refers
the Court to
the documents
referenced therein
for determination
of
their
co
ntent,
meaning
and effect,
and other
wise
lacks
knowledge
or info
rmation sufficie
nt
to fo
rm a
belie
f s
to
th
e truth ofthe
allegations.
107
.
With respect
to the allegations
se
t
forth inParagraph
107
ofthePHVPetitio
n,
the
Village
refers the Court to the
documents ref
erenced therein for
determination
of the
ir
conte
nt,
meaning
and effect,
and
otherw
ise lacks
knowledge
or inform
ation sufficient to form
a
belie
f
a
s
to
the
truthofthe
allegations.
108.
With
respect to the allega
tions set for
th
in
Paragraph 108
of
the
PHVPetition,
the
Village
refers
the
Court to
the documents referenced
therein
for
determination
of
their
content,
meaning
and
eff
ect, and otherwise
lacks kno
wledge
or informati
on sufficient to form a belief s
to the
truth of
t
he allegatio
ns.
109. W
ith res
pect
to
the allegations set
forth inParagra
ph 109 ofthe PHV
Petitio
n,
th
e
20
7/21/2019 Verified Answer (Pro 2 8110-2015) 012216
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Villag
e
re
fers the
Court to
the
docume
nts referen
ced
therein for
determina
tion of
their content
meanin
g
and
effe
ct and
otherwise lac
ks knowled
ge
or
inf
ormation su
fficient to
form abelief
as
to th
e tru
th
of
the
allega
tions
110
With
respect
to the allegation
s
set
fo
rth
inPa
ragraph
10 of
the PHY
Petition the
Village refers
the Cou
rt to the
d
ocuments r
eferenced
the
rein for dete
rmination of
their cont
ent
meaning
a
nd
effect
and oth
erwise lacks k
nowledge
or informat
ion sufficie
nt
to
form
a
belief a
s
to
the
truthof
the allegation
s
111 With respec
t
to the
all
egations
set forth inParagra
ph of
the
PHV Petition
the
Village
refers the
Court to
the documents referenced
therein
for
determination
of
their
content
mea
ning
and
eff
ect
and otherwi
se
lack
s know
ledge
or
in
formation su
fficient to
fo
rm
a
belie
f
as
to t
he tr
uth
of
the
alleg
ations
12.
With respe
ct to the all
egations
set
f
orth inParagra
ph 12 of
the
P
HV
Petition
the
Villag
e refers the
Court to th
e
docume
nts
reference
d therein for d
eterminatio
n
of
their content
meanin
g and effec
t and
otherwise lacks
knowle
dge or in
formation s
ufficient to form abel
ief a
s
to
the
trut
h
ofthe allegatio
ns
113 With
respect
to the allegati
ons se
t
for
th
inP
aragraph
of
the
VPetition t
he
Vil
lage
refers
the
Cou
rt to the doc
uments refe
renced therein
fo
r
determ
ination
of their conte
nt
meaning
and effec
t and otherwise
lac
ks knowledg
e
o
r info
rmation suf
ficient to for
m
a
belief as
to
the
truth of
the allegatio
ns
14
With
respect
to
the allegations
set
forth in
Paragraph
14
of
the
V
Petition
the
Villag
e
refers
the Court to
the docum
ents refere
nced therein
for determina
tion
of their content
m
eaning
and effect a
nd otherw
ise
la
cks kno
wledge
or informatio
n sufficient to
form
a be
lief
as
to
the truthof
the
all
egations
21
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115. With
respect
to the
allegations set
forth in
Paragraph
15
of
the
PHYPetition,
the
Village refers the Court to the documents referenced therein for determination
of
their content,
meaning
and
effect,
and
otherwise lacks knowledge
or information sufficient
to
form a
belief as
to the
truthofthe
allegations.
116.
With
respect to the allegations set forth inParagraph 16 of
the
PHV
Petition, the
Village refers
the
Court to
the
documents referenced therein for determination
of their
content,
meaning
and
effect,
and
otherwise lacks knowledge or information sufficient
to
form abelief as
to the
truthofthe
allegations.
117.
With
respect to the
allegations
set
forth in
Paragraph
17
of
the
PHV
Petition,
the
Village
refers the Court to the documents referenced therein
for
determination of their content,
meaning
and effect,
and
otherwise lacks
knowledge
or information sufficient to form abelief
as
to the truth
of
the allegations.
118. With
respect
to the
allegations set
forth inParagraph
8
of
the
PHVPetition,
the
Village
refers
the
Court
to the documents
referenced
therein
for
determination
of
their
content,
meaning
and
effect,
and
otherwise lacks knowledge
or information sufficient
to
form
a
belief
as
to the
truthofthe
allegations.
119.
With
respect to the allegations set
forth
in
Paragraph
19
of
thePHV
Petition,
the
Village refers
the
Court to
the
documents referenced therein
for
determination
of their
content,
meaning
and
effect,
and
otherwise lacks knowledge
or
information
sufficient
to
form
a
belief as
to
the
truth
ofthe allegations.
120. With
respect
to
the allegations set forth inParagraph 120 ofthe PHVPetition, the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and
effect,
and
otherwise
lacks
knowledge
or information sufficient to form
a
belief as
22
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to
the truth
ofthe allegations.
121.
With
respect to the
allegations set forth in
Paragraph 121
ofthe
PHV
Petition
the
V
illage
ref
ers
the
Co
urt to th
e
do
cuments referenced
therein for dete
rmination o
f their content,
meanin
g and
ef
fect,
and
otherwise
lacks know
ledge
or information
sufficient to form
a
belief
to th
e
truth
ofthe allegat
ions.
122.
With
respe
ct
to the
allegati
ons
set
forth inPara
graph 1
22of
the
PHVPetition the
Village refers
the Court
to
the documents r
eferenced the
rein
fo
r determinati
on of
their
co
ntent,
meaning and effect,
and
oth
erwise la
cks knowledge
or i
nformation suffic
ient
to
form abelief
to
the
truth
of
the
allegations.
123. With
respect to the
allegations set fo
rth inParagraph
123 ofthe
PHVPetition the
Village refers
the Cour
t
to the doc
uments reference
d therein for de
termination
of t
heir
content,
meaning
and effect,
and
otherw
ise lacks k
nowledge
or info
rmation sufficien
t
to
forma
b
elief
to
the
truthof
the
all
egations.
124. With re
spect to the alle
gations set forth inP
aragraph
124 of
the
P
HVPetition the
V
illage
refe
rs
the Court to the docu
ments referenced
therein for determ
ination of
thei
r
content,
m
eaning
and effect,
and
otherwise
lacks kno
wledge
or informat
ion sufficient to fo
rma
beli
ef
to the tr
uthof
the
allega
tions.
125.
Wi
th res
pect
to
the alleg
ations
se
t forth inPara
graph 125 ofthe P
HV
Petition the
Villa
ge
refers
the Court
to
the docume
nts referenced
therein for determi
nation
of their content,
meaning
and effect, and otherwise lacks
knowledge
or
information sufficient
to
form abelief
to the truthof
the allegations
.
126. With
respect to the
allegations set
forth inParagraph
126 ofthe
PHV
Peti
tion the
Village
r
efers the ourt
to t
he
do
cuments referenc
ed
t
herein for determin
ation o
f
the
ir content,
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meaning
and
effect
and
othe
rwise
lacks knowledge
or inform
ation sufficient to form a belief as
to the
truthof the allegations
127
With
respect
to
the allega
tions
set
forth
in
Parag
raph
127
of
the
PHY
P
etition the
Village refers
the
C
ourt to th
e
docum
ents referenced
therein for deter
mination
of their content
meaning
and
effe
ct n otherwise
lac
ks
knowled
ge
or informationsu
fficient
to
form a
beli
ef as
to
the tru
thof
t
he
allegat
ions
128 Wit
h resp
ect
to the
allegation
s
set
forth inParagrap
h
12
8 of the
PHV
Pe
tition the
V
illage refers
the
Court to
the documents re
ferenced therei
n
for
determination
of their
content
meaning and effect
n
otherwise
lacks knowledge or
infor
mation sufficient to
form a
belief a
s
to the
truth
of
th
e
allegations
129
With
respect to the
allegations set forth in
Paragraph 129
of
t
hePHVPetition t
he
Vil
lage refe
rs
th
e Court to
the documents refe
renced therein for
determination
of their content
meaning a
nd effect a
nd
ot
herwise lacks
knowledge or inform
ation sufficien
t to
for
m a belief
s
to
the
truthof the allegations
13
With
respect
to
the allega
tions
set
forth inPa
ragraph
13
of
the
PHVPetition
the
Village refers
the
Co
urt to the documen
ts referenced
therein for determina
tion
of their
c
ontent
meaning and
effect and otherw
ise lacks k
nowledge or informa
tion sufficient
to
form a
belief
s
to the
truthof the
allegations
131
With
respect
to
the allegation
s
set
forth
in
Para
graph
of
the
PHV
Pe
tition the
Village
refers the
Court
to the documents referenced
therein
for
determination
of
their
content
me
aning n effect
n otherwise
lacks knowledge
or
information sufficie
nt
to
form a
belief
s
to the
truth of the allegatio
ns
132 With
respe
ct
to the
allegations set f
orth inParagraph 132
o
f
the PHVPetition
the
24
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Vi
llage
refers
the Co
urt
to
th
e
do
cuments ref
erenced th
erein
for
de
termination
their content
meaning
a
nd effect and otherwise
lacks
knowledge
or inform
ation suffici
ent to
form belief
to
the tru
th
the allegation
s
1
33 With re
spect to the alle
gations
set fo
rth
in
Paragr
aph
1
33
the Y Pet
ition the
Village
re
fers
the Court to
the docum
ents referen
ced therein
for determin
ation
their cont
ent
mea
ning
and
eff
ect an
d
othe
rwise lac
ks know
ledge
or informati
on sufficient to
form
b
elief
to the
truth
the alleg
ations
134
With
respect to the
allegation
s
set
forth
inP
aragraph
134 th
e
V Petition
the
Village
refers
the
Court to
the documents referenced
therein
for
determination
their
content
meani
ng and effec
t an
d
othe
rwise
lacks know
ledge or
informatio
n sufficient to
form abelief
to the
truth
the alle
gations
135 With
respect to
the allegations
set f
orth
inP
aragraph
1
35
the
V Petition th
e
V
illage refer
s the Cou
rt to the do
cuments re
ferenced th
erein
fo
r d
eterminatio
n
their
content
meaning
and e
ffect and otherwise
lacks
knowledge or
inform
ation suff
icient to form abelie
f
to
the t
ruth
the allegations
136 With res
pect to
the
a
llegations
set forth
inPar
agraph
136
the PHV P
etition the
Vi
llage refers the
Cou
rt to
the doc
uments
refe
renced there
in for de
termination
their
c
ontent
mea
ning
and effe
ct and
ot
herwise
lacks kno
wledge
or inform
ation sufficie
nt to form
belief
to the
tru
th
the
a
llegations
137
With
respect
to
the
allegations
set
forth in
Paragraph 137
the
V
Petition
the
V
illage
refers
t
he
Co
urt to the
documents
reference
d therein
for
d
eterminatio
n
their content
meanin
g
and effect and other
wise lacks
knowled
ge
or
infor
mation su
fficient to
fo
rm
beli
ef
to the
truth
t
he
a
llegations
25
7/21/2019 Verified Answer (Pro 2 8110-2015) 012216
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138. With
respect
to the
allegations set
forth inParagraph 138
of
the
PHVPetition, the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and
effect,
and otherwise
lacks knowledge
or information sufficient to form
a
belief
as
to
the truth
ofthe
allegations.
139.
With
respect to the allegations
set
forth inParagraph 139 ofthe PHV Petition, the
Village
refers
the Court to the
documents
referenced therein
for determination
of their
content,
meaning and effect, and otherwise lacks knowledge
or informationsufficient
to form abelief as
to
the truthofthe
allegations.
140.
With
respect
to
the allegations
set
forth
in
Paragraph
140
of
the
PHV
Petition,
the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and
effect,
and
otherwise
lacks
knowledge or information sufficient to form a
belief as
to the
truthof
the allegations.
141
With
respect
to the
allegations
set forth inParagraph 141
of
the
PHV Petition,
the
Village refers the Court to the documents referenced therein for determination of their content,
meaning
and effect, and otherwise
lacks knowledge
or information sufficient
to
form
a belief as
to
the truth
ofthe
allegations.
142.
The
allegations inParagraph 142
of
the PHVPetition set forth conclusions
of law
for which no responsive
pleading
is required, but to the
extent
an answer is made, the Village
refers the
Court
to the statutes and/or regulations referenced therein for determination
of their
content, meaning and effect, and denies
Petitioners'
characterizations
thereof.
143. The allegations inParagraph 143 of
the
PHV Petition set
forth
conclusions of law
for
which
no
responsive
pleading is
required, but
to
the
extent
an
answer
is made, the
Village
refers the Court
to
the
statutes
and/or regulations referenced therein for determination
of
their
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7/21/2019 Verified Answer (Pro 2 8110-2015) 012216
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content,
meaning
and
effect, and denies
Petitioners' characterizations thereof.
144. TheVillage
denies
the allegations set forth
in
Paragraph 144 of
the PHY
Petition.
145.
The Village denies the allegations
set
forth
inParagraph
145 ofthe PHV
Petition.
146.
With
respect to the allegations
in
Paragraph 146 of the PHV Petition, the Village
lacks knowledge
or informationsufficient
to
form
abeliefas to the
truthof
the allegations.
147.
With respect
to the
allegations
in
Paragraph
147 of the
PHV
Petition,
theVillage
lacks knowledge
or informationsufficient
to form abeliefas to the truth
of
the allegations.
148. With
respect
to the
allegations
inParagraph 148
of
the PHV Petition,
the
Village
lacks
knowledge
or
informationsufficient
to
form abeliefas
to
the
truth
ofthe allegations.
149. TheVillagedenies the allegations set forth in
Paragraph
149 of
thePHVPetition.
150. With
respect
to the
allegations
in
Paragraph 150 of
the
PHV
Petition,
the
Village
lacks knowledge or information sufficient to formabelief as to the truthofthe allegations.
151. With
respect
to the
allegations inParagraph
151 of the
PHV
Petition,
the Village
lacks knowledge or information sufficient to formabelief
as
to
the
truthofthe allegations.
152. With
respect
to the
allegations
in
Paragraph 152 of
the
PHV
Petition,
the
Village
lacks
knowledge or informationsufficient
to
form a
belief
as to the truth
of
the
allegations.
153. With respect to the allegations inParagraph 153
of
the PHV Petition, the Village
lacks knowledge or information sufficient to
forma
belief as to
the truthofthe
allegations.
154.
The Village denies
the allegations set
forth
inParagraph
154 of
the
PHVPetition.
155.
The
Village
denies the
allegations
set
forth in
Paragraph
155
of
the
PHV
Petition.
156. With respect to the allegations set forth inParagraph 156 of the
PHV
Petition, the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and effect
and
denies
Petitioners'
characterization
thereof.
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57. With respect to the allegations set forth inParagraph
57
of
the
PHYPetition,
the
Village
refers
the
Court to
the
documents referenced therein for determination
of
their content,
meaning and effect and denies Petitioners'
characterization
thereof.
158. TheVillage
denies
the
allegations set forth
inParagraph 158
of
the
PHV
Petition.
159. TheVillage denies
the
allegations set forth inParagraph 59
of
the PHV
Petition.
160. The Village
denies
the allegations set
forth
inParagraph
160 ofthe
PHV Petition.
161. With
respect
to the
allegations set forth
in
Paragraph 161 of
the
PHVPetition,
the
Village refers the Court to the documents referenced therein for determination
of their
content,
meaning
and
effect
and denies
Petitioners' characterization
thereof.
162. TheVillage denies
the
allegations set forth inParagraph 162
of
thePHV
Petition.
163. The Village
denies
the allegations set
forth
inParagraph 163
ofthe
PHVPetition.
164.
TheVillage denies the allegations set forth inParagraph 164 of the
PHV
Petition.
65.
TheVillage
denies
the allegations set forth inParagraph
65
of
thePHV
Petition.
166. TheVillage denies
the
allegations
set
forth
inParagraph
166 ofthePHV
Petition.
167. The Village
denies
the
allegations set forth inParagraph 167
ofthe
PHVPetition.
168.
With respect to
the allegations set
forth in
Paragraph 168 of
the
PHV
Petition,
the
Village refers
the
Court to the documents referenced therein
for
determination
of
their
content,
meaning
and effect and denies Petitioners'
characterization
thereof.
69. TheVillage
denies
the
allegations set forth inParagraph 69
of
the PHV
Petition.
170.
With
respect
to
the
allegations
set
forth in
Paragraph
170 of
the
PHV
Petition,
the
Village
admits that the Monroe-Woodbury
Central
School District submitted
comments
on the
507
Petition,
but
denies
their
validity
and
any
allegations
made therein.
171
TheVillage
denies
the
allegations set forth
inParagraph 171
of
the
PHV
Petition.
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172.
The
Village denies the
allegations
set
forth in
Paragraph
172 of
thePHY
Petition.
173. With
respect
to
the allegations set forth
inParagraph
173 of thePHYPetition, the
Village refers the Court to the documents referenced therein for determination of
their
content,
meaning
and
effect.
174. The Village
denies
the allegations set forth
in
Paragraph 174 ofthePHV
Petition.
175.
The
Village
denies
the
allegations
set forth inParagraph 175
of
the
PHV
Petition.
176.
The Village denies
the
allegations set forth
inParagraph
176 ofthePHV
Petition.
177. The
Village
denies the allegations set
forth
inParagraph
177 of
the
PHV
Petition.
178.
The
Village
denies the allegations
set forth
in
Paragraph
178 of
the
PHV
Petition.
179. The Village
denies
the
allegations set forth
in
Paragraph 179 ofthePHV
Petition.
180. The Village admits the
allegations
set
forth
inParagraph
80
of
thePHVPetition.
181. The Village
admits the
allegations
set
forth
inParagraph
8
of
the
PHV
Petition.
82. The Village admits the allegations set forth
in
Paragraph 82
of
thePHVPetition.
83. The Village denies
the allegations set
forth
inParagraph
83
ofthePHV
Petition.
84. The Village
denies
the
allegations set forth inParagraph 84 ofthePHVPetition.
85. TheVillage
denies
the allegations set
forth
inParagraph 185
of
thePHVPetition.
86. TheVillage
denies
the allegations set forth
in
Paragraph 86 ofthePHV
Petition.
87. TheVillage
denies
the
allegations
set forth
in
Paragraph
87
of
the
PHV
Petition.
88. With respect to the allegations set forth
in
Paragraph 88 ofthe PHV Petition, the
Village
refers the
Court to
the documents referenced
therein
for
determination
of
their
content,
meaning
and
effect
and
denies Petitioners' characterization thereof.
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89.
With
respect
to
the
allegations
set
forth inParagraph
61
of
the
PHV Petition,
the
Village
refers
the Court to the documents
referenced
therein for
determination
of their
content,
meaning
and
effect
and denies
Petitioners' characterization thereof.
190. The
Village denies
the
allegations
set forth in
Paragraph 190 ofthePHV
Petition.
191
The Village
denies
the
allegations set
forth
inParagraph
191
ofthePHV
Petition.
192. The Village
denies
the
allegations
set forth inParagraph
192 of
thePHV Petition.
193. With
respect
to
the allegations
set
forth
in
Paragraph 193 of the PHV Petition,
the
Village refers the Court to the documents referenced
therein
for determination of their content,
meaning and
effect
and denies
Petitioners' characterization
thereof.
194. The Village
denies
the allegations set forth
in
Paragraph 194
of
thePHV
Petition.
195. The Village denies the
allegations
set forth inParagraph
195 of
thePHV Petition.
196.
TheVillage
denies
the allegations
set
forth inParagraph
196
of
the PHV
Petition.
197. With respect to the allegations set forth in
Paragraph
193
of
the PHV
Petition,
the
Village
refers
the Court
to
the documents
referenced
therein for
determination
of their
content,
meaning
and
effect
and denies
Petitioners' characterization thereof.
198.
TheVillage
denies
the allegations
set
forth inParagraph 198
of
the PHVPetition.
199.
The
Villagedenies the allegations set forth in
Paragraph
199
of
thePHV
Petition.
200.
The
Village
admits
the allegations set
forth inParagraph
200 of
thePHV Petition.
201 The Village admits the allegations set forth
in
Paragraph 201 ofthePHV Petition.
202.
With
respect
to
the
allegations
set
forth in
Paragraph 202
of
the
PHV
Petition,
the
Village
admits that
the 164 Petition was filed, but
lacks knowledge
or information sufficient
to
form
a
belief as to the truthofthe allegations as to the intent ofthe
64
Petition.
203. The Village
denies the
allegations
set
forth inParagraph
203 of
thePHVPetition.
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204.
TheVillagedenies
the
allegations
set
forth inParagraph 204
of
thePHV
Petition.
205.
The Village denies the
allegations
set forth in
Paragraph 205
of
the
PHVPetition.
206. TheVillagedenies the allegations
set
forth inParagraph 206 ofthePHVPetition.
207.
With
respect
to
the allegations
set
forth inParagraph 207
ofthe
PHV
Petition,
the
Village admits that the MWCSD submitted comments on the 164 Petition,
but
denies their
validity.
208.
The
Village
denies the
allegations
set
forth
in
Paragraph
208 ofthePHVPetition.
209. TheVillagedenies the allegations set
forth
inParagraph 209 ofthe PHVPetition.
210.
With
respect
to the
allegations
set
forth inParagraph 210
ofthe PHVPetition,
the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and
effect
and denies
Petitioners'
characterization
thereof.
211. The Village
denies
the allegations set forth inParagraph 2
of
thePHVPetition.
212. The
Village
denies
the
allegations
set forth inParagraph212
ofthePHV
Petition.
213. TheVillage
denies the
allegations
set
forth
in
Paragraph213
of
the
PHVPetition.
214. The Villagedenies the allegations
set
forth inParagraph 214
of
thePHVPetition.
215. With respect
to
the allegations
set
forth in
Paragraph
215
of the PHV Petition, the
Village refers
the
Court to the documents referenced therein for determination
of their
content,
meaning
and effect and otherwise
lacks knowledge
or information sufficient
to
form a
belief as
to
the
truth
of
the
allegations related to
the
content
of
the 2014 Final TownAssessmentRoll.
216.
With
respect
to
the
allegations
set
forth in
Paragraph 216 of the
PHV
Petition,
the
Village
refers
the
Court to the
documents
referenced therein for determination
of their content,
meaning and effect and denies Petitioners'
characterization
thereof.
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217. With respect
to
the allegations
set
forth inParagraph
217 ofthe
PHYPetition,
the
Village admits thatBakertownRealty Equities and the
Jacob
Bandua
Trust do
not
appear
to own
SBL 1-3-1.3, but denies that their names
and
signatures should
be
stricken from the 164 Petition.
218.
TheVillageadmits the allegations
set
forth inParagraph 218
ofthe
PHV
Petition.
219. The Villageadmits the allegations
set
forth inParagraph 219 ofthePHVPetition.
220. TheVillage
denies the
allegations
set
forthinParagraph
220 of
thePHVPetition.
221
The
Village
denies the allegations set
forth
in
Paragraph
221 of
the
PHVPetition.
222. TheVillagedenies the allegations set forth inParagraph 222 ofthePHVPetition.
223. TheVillage
denies the
allegations
set
forth inParagraph
223 ofthe
PHVPetition.
224. The Village
denies
the allegations set forth inParagraph224
of
thePHV
Petition.
225.
With
respect
to the
allegations
set forth in
Paragraph 225 of
the
PHVPetition,
the
Village
refers the Court to the documents referenced therein
for
determination of their content,
meaning and
effect and
denies Petitioners'
characterization
thereof.
226. With
respect to the
allegations
set
forth
in
Paragraph
226
of
the PHV Petition, the
Village refers
the
Court to
the
documents referenced therein for determination
of their
content,
meaning
and
effect
and
denies
Petitioners'
characterization
thereof.
227. With
respect
to the allegations set forth
in
Paragraph 227
of
thePHV
Petition,
the
Village
refers the
Court
to
the documents referenced
therein
for determinatio