Verified Answer (Pro 2 8110-2015) 012216

7/21/2019 Verified Answer (Pro 2 8110-2015) 012216

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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 ):


2/78

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

2


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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


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


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'


g. The

allegations entitled Violation of Town Ethics Code set forth

conclusions

of

law for which no responsive pleading is required, but to the

3


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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


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'


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

4


5/78

regulations

referenced therein for determination of their content, meaning and effect,

and

denies


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


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.


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.


in

Paragraph

18

of


lacks knowledge


to

form a

belief

as

to

the truth of the

allegations that

5


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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


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


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.

6


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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


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


set for

th

in

Paragrap

h 34 of the P

HV

Petition,

the

Village

r

efers the

Court to the


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,

7


8/78

meaning

and

effect,

and

otherwise

lacks

knowledge


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


to

form

a

belief as

to the truth

ofthe allegations.

38.

With


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


to

form a

belief

as

to the truth

ofthe

allegations.

39.

With

respect

to

the allegations

set

forth

in


Petition, the

Village

refers the Court to the

documents

referenced therein

for


content,

meaning

and

effect,

and otherwise

lacks


to

form a

belief as

to

the truth

ofthe

allegations.

40.

With

respect

to

the allegations

set forth in


Petition, the

Village

refers

the

Court to

the documents referenced

therein

for

determination

of

their

content,

meaning

and effect,

and

otherwise lacks knowledge


to

form

a

belief

as

to the

truthofthe

allegations.

8


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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



to

form a

belief as

to the

truthofthe

allegations.

42. With

respect

to the

allegations

set

forth

in


Petition, the

Village

refers

the

Court to the documents referenced therein

for


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


Village refers the Court

to the documents referenced

therein for


content,

meaning

and

effect,

and

otherwise


sufficient

to form a

belief

as

to the truth

ofthe

allegations.

44.

With


in

Paragraph 44

of


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


Petition, the


for

determination

of their

content,

meaning

and

effect,

and


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


Village refers the Court to the documents referenced therein for determination of their content,

9


10/78

meaning and effect,

and


or

information

sufficient

to form a

belief

as

to the

truthofthe

allegations.

47.

With

respect

to


in


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


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


in

Paragraph 50

of

the PHV

Petition,

the

Village

refers

the


therein

for determination

of their

content,

meaning

and effect, and otherwise

lacks


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


therein

for

determination

of

their

content,

meaning

and

effect,

and otherwise

lacks knowledge


to

form

a belief

as

to

the truthof the

allegations.

10


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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


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


of their

content,

meaning


lacks knowledge


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


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


Village refers the


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


of

their content,

meaning

and effect,

and


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,

11


12/78

meaning

and

effect,

and

otherwise lacks knowledge or


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,


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


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


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


13/78


to

the

documents referenced therein

for


content,

meaning and

effect,

and

otherwise

lacks knowledge or information sufficient to form

a belief

as

to

the


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,


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


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


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


of their

content,

meaning and effect, and otherwise lacks knowledge or information sufficient to form a belief

as

to

the

truth

ofthe allegations.

13


14/78

69.

With

respect

to the

allegations

set

forth

in


Petition,

the

Village refers

the


of their

content,

meaning

and

effect, and



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


referenced

therein

for

determination

of

their content,

meaning

and

effect,

and


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


of their

content,

meaning

and

effect, and

otherwise


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


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


of their

content,

meaning

and

effect,

and

otherwise

lacks


sufficient

to form

a belief

as

14


15/78

to the truth

of

the

allegations.


allegations

set forth

in

Paragraph 75 of the

PHV

Petition,

the

Village

refers

the

Court to

the


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


Petition,

the

Village

refers

the

Court


therein

for determination of their content,

meaning


lacks knowledge


to

form

a belief as


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



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


therein

for determination

of their

content,

meaning

and

effect,

and

otherwise

lacks knowledge


to form a

belief

as

to the truth

of

the allegations.

79.

With respect


forth in Paragraph

79 of

the

PHV Petition,

the

Village

refers

the


of their

content,

meaning and

effect,

and

otherwise

lacks

knowledge

or


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


16/78

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


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


of their

content,

meaning

and

effect,

and


or information

sufficient to form

a belief

as

to

the truthofthe

allegations.

83.

With respect to the

allegations

set

forth

in

Paragraph

83

of


Village refers

the


of their

content,

meaning

and

effect,

and otherwise

lacks knowledge


to

form a

belief as


84.

With

respect

to the

allegations

set

forth

in

Paragraph

84

of

the

PHV

Petition,

the


for


meaning

and

effect,

and otherwise

lacks knowledge


to

form a

belief as

to

the


85.

With

respect

to the

allegations set

forth in

Paragraph

85

of

the

PHV

Petition, the

Village

refers the

Court to


therein

for

determination

of

their

content,

meaning

and

effect,

and



to form

a

belief as

to the truth

of

the allegations.


in

Paragraph 86 of the

PHV

Petition, the

16


17/78

Village refers

the Court

to the

documents


of their

content,

meaning and

effect,

and

otherwise

lacks


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


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


Village refers the

Court to

the documents

referenced

therein for


meaning and effect, and otherwise lacks knowledge or information sufficient to form abelief

as

to

the truth

of

the allegations.

89. With

respect


forth inParagraph

89 of the PHV Petition, the

Village refers

the


of their

content,

meaning and effect,

and

otherwise

lacks

knowledge or information sufficient to form

a belief as


90.

With

respect

to

the

allegations

set forth in Paragraph 90 of the PHV

Petition,

the


of their

content,

meaning and

effect,

and otherwise

lacks knowledge


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



to

form a

belief as

to the

truthofthe

allegations.

17


18/78


allegations

set forth in Paragraph 92

of

the

PHY

Petition, the

Village refers

the

Court

to

the


for


meaning

and effect, and otherwise lacks knowledge or information

sufficient

to

form abelief as

to

the truth

of

the allegations.

93.

With

respect


forth

in

Paragraph

93

of the PHV

Petition,

the


meaning

and

effect,

and otherwise

lacks knowledge


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


of

their content,

meaning and effect, and otherwise lacks knowledge or information sufficient to form a belief as

to

the truthofthe

allegations.


allegations

set forth

in

Paragraph 95

of

the

PHV

Petition, the


to

the

documents

referenced

therein

for

determination of

their

content,


knowledge


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


of

their content,

meaning and

effect,

and otherwise lacks

knowledge


to

form

a belief

as

to

the

truth

of

the allegations.

97.

With

respect


forth

in

Paragraph 97 of

the

PHV

Petition,

the

Village

refers the Court to

the


for

determination

of

their content,

meaning

and effect, and

otherwise

lacks


sufficient to

form a belief

as

18


19/78

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


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


therein

for determination

of their

content,

meaning

and

effect,

and



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


therein

for determination

of

their content,

meaning

and

effect,

and otherwise

lacks knowledge


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


for


meaning

and

effect,

and

otherwise lacks knowledge or


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


of their

content,


lacks knowledge or


to

form

a

belief as


103.

With respect

to


in

Paragraph

103

of thePHV

Petition,

the

Village

refers

the Court

to the documents referenced therein

for

determination

of their

content,

19


20/78

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,


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


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


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


21/78

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


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


22/78

115. With

respect

to the

allegations set

forth in

Paragraph

15

of

the

PHYPetition,

the


of

their content,

meaning

and

effect,

and



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


of their

content,

meaning

and

effect,

and


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


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



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


for

determination

of their

content,

meaning

and

effect,

and


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


of their

content,

meaning

and

effect,

and

otherwise

lacks

knowledge

or information sufficient to form

a

belief as

22


23/78

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


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,

23


24/78

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


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


25/78

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


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


26/78

138. With

respect

to the

allegations set

forth inParagraph 138

of

the

PHVPetition, the

Village refers

the


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


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


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


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


meaning


lacks knowledge


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

26


27/78

content,

meaning

and

effect, and denies


144. TheVillage

denies


in

Paragraph 144 of

the PHY

Petition.

145.

The Village denies the allegations

set

forth

inParagraph

145 ofthe PHV

Petition.

146.

With


in

Paragraph 146 of the PHV Petition, the Village

lacks knowledge


to

form

abeliefas to the

truthof

the allegations.

147.

With respect

to the

allegations

in

Paragraph

147 of the

PHV

Petition,

theVillage

lacks knowledge


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


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


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


of their

content,

meaning

and effect

and

denies

Petitioners'

characterization

thereof.

27


28/78

57. With respect to the allegations set forth inParagraph

57

of

the

PHYPetition,

the

Village

refers

the

Court to

the


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


of

the PHV

Petition.

160. The Village

denies

the allegations set

forth

inParagraph

160 ofthe

PHV Petition.

161. With

respect

to the


in

Paragraph 161 of

the

PHVPetition,

the


of their

content,

meaning

and

effect

and denies

Petitioners' characterization

thereof.


the


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.


the

allegations

set

forth

inParagraph

166 ofthePHV

Petition.

167. The Village

denies

the


ofthe

PHVPetition.

168.

With respect to

the allegations set

forth in

Paragraph 168 of

the

PHV

Petition,

the

Village refers

the


for

determination

of

their

content,

meaning

and effect and denies Petitioners'

characterization

thereof.

69. TheVillage

denies

the


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


inParagraph 171

of

the

PHV

Petition.

28


29/78

172.

The

Village denies the

allegations

set

forth in

Paragraph

172 of

thePHY

Petition.

173. With

respect

to


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


in

Paragraph 174 ofthePHV

Petition.

175.

The

Village

denies

the

allegations

set forth inParagraph 175

of

the

PHV

Petition.

176.

The Village denies

the


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


in


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


in


Petition.

87. TheVillage

denies

the

allegations

set forth

in

Paragraph

87

of

the

PHV

Petition.


in

Paragraph 88 ofthe PHV Petition, the

Village

refers the

Court to


therein

for

determination

of

their

content,

meaning

and

effect

and

denies Petitioners' characterization thereof.

29


30/78

89.

With

respect

to

the

allegations

set

forth inParagraph

61

of

the

PHV Petition,

the

Village

refers


referenced

therein for

determination

of their

content,

meaning

and

effect

and denies

Petitioners' characterization thereof.

190. The

Village denies

the

allegations

set forth in


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


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


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


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.

30


31/78

204.

TheVillagedenies

the

allegations

set


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


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


ofthe PHVPetition,

the

Village refers

the


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


of

thePHVPetition.

215. With respect

to

the allegations

set

forth in

Paragraph

215

of the PHV Petition, the

Village refers

the


of their

content,

meaning

and effect and otherwise

lacks knowledge


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


of their content,

meaning and effect and denies Petitioners'

characterization

thereof.

31


32/78

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


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


meaning and

effect and

denies Petitioners'

characterization

thereof.

226. With

respect to the

allegations

set

forth

in

Paragraph

226

of


Village refers

the

Court to

the


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


therein

for determinatio

Verified Answer (Pro 2 8110-2015) 012216

Documents

verified answer pro

paragraph ofthephv petition

meaningand effect

thecourt tothe

determinationof theircontent

paragraph4 of thephvpetition

whiteman ostermanhanna

townboardof thetownof