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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF ORANGENINTH JUDICIAL DISTRICT ENVIORONMENTAL CLAIMS PART- - - - - - - - - - - - - - - - - - - -XVILLAGE OF SOUTH BLOOMING GROVE, et
al. ,
Petitioners,
For a Judgment Pursuant to Article 78of the Civil Practice Law and Rules
- against
VILLAGE OF KIRYAS JOEL BOARD OFTRUSTEES, et al.
Index No. 7410/2015Proceeding No. 1
Hon. Francesca E.Connolly
Respondents,
EMANUEL LEONOROVITZ, et al.
Additional Respondents.
- - - - - - - - - - - - - - - - - - - -XPRESERVE HUDSON VALLEY, et al. Index No. 8118/2015
Proceeding No. 2
Petitioners,
- against
TOWN BOARD OF THE TOWN OF MONROE, et al.
Respondents/Defendants.
- - - - - - - - - - - - - - - - - - - -X
VERIFIED ANSWER TO AMENDED VERIFIED PETITION AND COMPLAINT OF
PETITIONERS/PLAINTIFFS IN PROCEEDING NO. 2
Respondents-Defendants, Town Board of the Town of Monroe and
Town of Monroe, by their attorneys, DICKOVER. DONNELLY &
DONOVAN, LLP, respectfully submit the foregoing Verified Answer
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to the Amended Verified Petition and Complaint filed by
Petitioners-Plaintiffs Preserve Hudson Valley, et al. in
Proceeding No. 2 (the PHV Petitioner):
1.With respect to the allegations set forth in Paragraph 1 of
the PHV Petition, including subparagraphs (i) through (vii)
thereof, the Town admits that Petitioners seek the relief
specified therein, but denies that Petitioners are entitled
thereto.
2.With respect to the allegations set forth in Paragraph 2 of
the PHV Petition, the Town states that such allegations set
forth conclusions of law for which no responsive pleading is
required.
3.The Town admits the allegations set forth in Paragraph 3 of
the PHV Petition, except lacks knowledge or information
sufficient to form a belief 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 annexation
petition.
4.With respect to the allegations set forth in Paragraph 4 of
the PHV Petition, the Town states that such allegations set
forth conclusions of law for which no responsive pleading is
required, but to the extent an answer is made, the Town denies
Petitioners characterization thereof and further states as
follows:
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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 Town 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 Town refers the
Court to 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 Village Board set forth
conclusions of law for which no responsive pleading is
required, but to the extent an answer is made, the Town
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
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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 Town 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, the Town 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 Town 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 extent an
answer is made, the Town lacks knowledge or information
sufficient to form a belief as to the truth of the
allegations set forth.
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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 Town refers the Court
to the statutes and/or regulations referenced therein
for determination of their content, meaning and effect,
and denies Petitioners characterizations thereof.
i.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 Town refers the Court to
the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and
denies Petitioners characterizations thereof.
5.The Town denies the allegations set forth in Paragraph 5 of
the PHV Petition.
6.With respect to the allegations in Paragraph 6 of the PHV
Petition, the Town lacks knowledge or information sufficient to
form a belief as to the truth of the allegations set forth.
7.The Town denies the allegations in Paragraph 7 of the PHV
Petition.
8.The Town denies the allegations in Paragraph 8 of the PHV
Petition.
9.The Town denies the allegations in Paragraph 9 of the PHV
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Petition.
10. With respect to the allegations in Paragraph 10 of the
PHV Petition, the Town 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 Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
11. With respect to the allegations in Paragraph 11 of the
PHV Petition, the Town 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 Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations set forth.
13. The Town denies the allegations in Paragraph 13 of the
PHV Petition.
14. The Town denies the allegations in Paragraph 14 of the
PHV Petition.
15. With respect to the allegations in Paragraph 15 of the
PHV Petition, the Town 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
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PHV Petition, the Town 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 Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations that
Petitioner Convers is in Orange County Sewer District #1, and
otherwise denies the allegations set forth in Paragraph 17.
18. With respect to the allegations in Paragraph 18 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations that
Petitioner Convers has two sons who attend MWCSD public schools,
and otherwise denies the allegations in Paragraph 18.
19. With respect to the allegations in Paragraph 19 of the
PHV Petition, the Town lacks knowledge or information sufficient
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 Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
21. The Town denies the allegations in Paragraph 21 of the
PHV Petition.
22. With respect to the allegations in Paragraph 22 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
23. With respect to the allegations in Paragraph 23 of the
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PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
24. With respect to the allegations in Paragraph 24 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
25. The Town admits the allegations in Paragraph 25 of the
PHV Petition.
26. With respect to the allegations in Paragraph 26 of the
PHV Petition, the Town lacks knowledge or information sufficient
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 Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
28. With respect to the allegations in Paragraph 28 of the
PHV Petition, the Town 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 Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
30. With respect to the allegations set forth in Paragraph 30
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
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sufficient to form a belief as to the truth of the allegations.
31. With respect to the allegations set forth in Paragraph 31
of the PHV Petition, the Town 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.
32. With respect to the allegations set forth in Paragraph 32
of the PHV Petition, the Town 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.
33. With respect to the allegations set forth in Paragraph 33
of the PHV Petition, the Town 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.
34. With respect to the allegations set forth in Paragraph 34
of the PHV Petition, the Town 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.
35. With respect to the allegations set forth in Paragraph 35
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
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and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
36. With respect to the allegations set forth in Paragraph 36
of the PHV Petition, the Town 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 in Paragraph 37
of the PHV Petition, the Town 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.
38. With respect to the allegations set forth in Paragraph 38
of the PHV Petition, the Town 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.
39. With respect to the allegations set forth in Paragraph 39
of the PHV Petition, the Town 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.
40. With respect to the allegations set forth in Paragraph 40
of the PHV Petition, the Town refers the Court to the documents
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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.
41. With respect to the allegations set forth in Paragraph 41
of the PHV Petition, the Town 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.
42. With respect to the allegations set forth in Paragraph 42
of the PHV Petition, the Town 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.
43. With respect to the allegations set forth in Paragraph 43
of the PHV Petition, the Town 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.
44. With respect to the allegations set forth in Paragraph 44
of the PHV Petition, the Town 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.
45. With respect to the allegations set forth in Paragraph 45
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of the PHV Petition, the Town 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.
46. With respect to the allegations set forth in Paragraph 46
of the PHV Petition, the Town 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.
47. With respect to the allegations set forth in Paragraph 47
of the PHV Petition, the Town 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.
48. With respect to the allegations set forth in Paragraph 48
of the PHV Petition, the Town 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.
49. With respect to the allegations set forth in Paragraph 49
of the PHV Petition, the Town 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.
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50. With respect to the allegations set forth in Paragraph 50
of the PHV Petition, the Town 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.
51. With respect to the allegations set forth in Paragraph 51
of the PHV Petition, the Town 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.
52. With respect to the allegations set forth in Paragraph 52
of the PHV Petition, the Town 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.
53. With respect to the allegations set forth in Paragraph 53
of the PHV Petition, the Town 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.
54. With respect to the allegations set forth in Paragraph 54
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
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sufficient to form a belief as to the truth of the allegations.
55. With respect to the allegations set forth in Paragraph 55
of the PHV Petition, the Town 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.
56. With respect to the allegations set forth in Paragraph 56
of the PHV Petition, the Town 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.
57. With respect to the allegations set forth in Paragraph 57
of the PHV Petition, the Town 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.
58. With respect to the allegations set forth in Paragraph 58
of the PHV Petition, the Town 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.
59. With respect to the allegations set forth in Paragraph 59
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
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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 Town 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.
61. With respect to the allegations set forth in Paragraph 61
of the PHV Petition, the Town 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.
62. With respect to the allegations set forth in Paragraph 62
of the PHV Petition, the Town 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.
63. With respect to the allegations set forth in Paragraph 63
of the PHV Petition, the Town 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.
64. With respect to the allegations set forth in Paragraph 64
of the PHV Petition, the Town refers the Court to the documents
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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.
65. With respect to the allegations set forth in Paragraph 65
of the PHV Petition, the Town 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 in Paragraph 66
of the PHV Petition, the Town 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.
67. With respect to the allegations set forth in Paragraph 67
of the PHV Petition, the Town 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.
68. With respect to the allegations set forth in Paragraph 68
of the PHV Petition, the Town 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.
69. With respect to the allegations set forth in Paragraph 69
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of the PHV Petition, the Town 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 Town 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.
71. With respect to the allegations set forth in Paragraph 71
of the PHV Petition, the Town 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 in Paragraph 72
of the PHV Petition, the Town 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.
73. With respect to the allegations set forth in Paragraph 73
of the PHV Petition, the Town 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.
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74. With respect to the allegations set forth in Paragraph 74
of the PHV Petition, the Town 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.
75. With respect to the allegations set forth in Paragraph 75
of the PHV Petition, the Town 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.
76. With respect to the allegations set forth in Paragraph 76
of the PHV Petition, the Town 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.
77. With respect to the allegations set forth in Paragraph 77
of the PHV Petition, the Town 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.
78. With respect to the allegations set forth in Paragraph 78
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
and effect, and otherwise lacks knowledge or information
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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 Town 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.
80. With respect to the allegations set forth in Paragraph 80
of the PHV Petition, the Town 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.
81. With respect to the allegations set forth in Paragraph 81
of the PHV Petition, the Town 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.
82. With respect to the allegations set forth in Paragraph 82
of the PHV Petition, the Town 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.
83. With respect to the allegations set forth in Paragraph 83
of the PHV Petition, the Town refers the Court to the documents
referenced therein for determination of their content, meaning
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and effect, and otherwise lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
84. With respect to the allegations set forth in Paragraph 84
of the PHV Petition, the Town 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.
85. With respect to the allegations set forth in Paragraph 85
of the PHV Petition, the Town 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 Town 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 Town 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.
88. With respect to the allegations set forth in Paragraph 88
of the PHV Petition, the Town refers the Court to the documents
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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.
89. With respect to the allegations set forth in Paragraph 89
of the PHV Petition, the Town 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.
90. With respect to the allegations set forth in Paragraph 90
of the PHV Petition, the Town 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 Town 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.
92. With respect to the allegations set forth in Paragraph 92
of the PHV Petition, the Town 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.
93. With respect to the allegations set forth in Paragraph 93
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of the PHV Petition, the Town 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 Town 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.
95. With respect to the allegations set forth in Paragraph 95
of the PHV Petition, the Town 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 Town 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 Town 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.
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98. With respect to the allegations set forth in Paragraph 98
of the PHV Petition, the Town 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.
99. With respect to the allegations set forth in Paragraph 99
of the PHV Petition, the Town 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 in Paragraph
100 of the PHV Petition, the Town 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.
101.With respect to the allegations set forth in Paragraph
101 of the PHV Petition, the Town 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.
102.With respect to the allegations set forth in Paragraph
102 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, and otherwise lacks knowledge or information
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sufficient to form a belief as to the truth of the allegations.
103.With respect to the allegations set forth in Paragraph
103 of the PHV Petition, the Town 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.
104.With respect to the allegations set forth in Paragraph
104 of the PHV Petition, the Town 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.
105.With respect to the allegations set forth in Paragraph
105 of the PHV Petition, the Town 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.
106.With respect to the allegations set forth in Paragraph
106 of the PHV Petition, the Town 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.
107.With respect to the allegations set forth in Paragraph
107 of the PHV Petition, the Town 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 truth of the allegations.
108.With respect to the allegations set forth in Paragraph
108 of the PHV Petition, the Town 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.
109.With respect to the allegations set forth in Paragraph
109 of the PHV Petition, the Town 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.
110.With respect to the allegations set forth in Paragraph
110 of the PHV Petition, the Town 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.
111.With respect to the allegations set forth in Paragraph
111 of the PHV Petition, the Town 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.
112.With respect to the allegations set forth in Paragraph
112 of the PHV Petition, the Town refers the Court to the
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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.
113.With respect to the allegations set forth in Paragraph
113 of the PHV Petition, the Town 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.
114.With respect to the allegations set forth in Paragraph
114 of the PHV Petition, the Town 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.
115.With respect to the allegations set forth in Paragraph
115 of the PHV Petition, the Town 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.
116.With respect to the allegations set forth in Paragraph
116 of the PHV Petition, the Town 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.
117.With respect to the allegations set forth in Paragraph
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117 of the PHV Petition, the Town 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.
118.With respect to the allegations set forth in Paragraph
118 of the PHV Petition, the Town 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.
119.With respect to the allegations set forth in Paragraph
119 of the PHV Petition, the Town 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.
120.With respect to the allegations set forth in Paragraph
120 of the PHV Petition, the Town 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.
121.With respect to the allegations set forth in Paragraph
121 of the PHV Petition, the Town 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.
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122.With respect to the allegations set forth in Paragraph
122 of the PHV Petition, the Town 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.
123.With respect to the allegations set forth in Paragraph
123 of the PHV Petition, the Town 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.
124.With respect to the allegations set forth in Paragraph
124 of the PHV Petition, the Town 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.
125.With respect to the allegations set forth in Paragraph
125 of the PHV Petition, the Town 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.
126.With respect to the allegations set forth in Paragraph
126 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, and otherwise lacks knowledge or information
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sufficient to form a belief as to the truth of the allegations.
127.With respect to the allegations set forth in Paragraph
127 of the PHV Petition, the Town 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.
128.With respect to the allegations set forth in Paragraph
128 of the PHV Petition, the Town 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.
129.With respect to the allegations set forth in Paragraph
129 of the PHV Petition, the Town 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.
130.With respect to the allegations set forth in Paragraph
130 of the PHV Petition, the Town 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.
131.With respect to the allegations set forth in Paragraph
131 of the PHV Petition, the Town 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 truth of the allegations.
132.With respect to the allegations set forth in Paragraph
132 of the PHV Petition, the Town 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.
133.With respect to the allegations set forth in Paragraph
133 of the PHV Petition, the Town 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.
134.With respect to the allegations set forth in Paragraph
134 of the PHV Petition, the Town 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.
135.With respect to the allegations set forth in Paragraph
135 of the PHV Petition, the Town 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.
136.With respect to the allegations set forth in Paragraph
136 of the PHV Petition, the Town refers the Court to the
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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.
137.With respect to the allegations set forth in Paragraph
137 of the PHV Petition, the Town 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.
138.With respect to the allegations set forth in Paragraph
138 of the PHV Petition, the Town 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.
139.With respect to the allegations set forth in Paragraph
139 of the PHV Petition, the Town 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.
140.With respect to the allegations set forth in Paragraph
140 of the PHV Petition, the Town 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.
141.With respect to the allegations set forth in Paragraph
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141 of the PHV Petition, the Town 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.
142.The allegations in Paragraph 142 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 Town 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 in Paragraph 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 Town refers
the Court to the statutes and/or regulations referenced therein
for determination of their content, meaning and effect, and
denies Petitioners characterizations thereof.
144.The Town denies the allegations set forth in Paragraph
144 of the PHV Petition.
145.The Towndenies the allegations set forth in Paragraph 145
of the PHV Petition.
146.With respect to the allegations in Paragraph 146 of the
PHV Petition, the Town acks knowledge or information sufficient
to form a belief as to the truth of the allegations.
147.With respect to the allegations in Paragraph 147 of the
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PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
148.With respect to the allegations in Paragraph 148 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
149.The Town denies the allegations set forth in Paragraph
149 of the PHV Petition.
150.With respect to the allegations in Paragraph 150 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
151.With respect to the allegations in Paragraph 151 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
152.With respect to the allegations in Paragraph 152 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
153.With respect to the allegations in Paragraph 153 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations.
154.The Town denies the allegations set forth in Paragraph
154 of the PHV Petition.
155.The Town denies the allegations set forth in Paragraph
155 of the PHV Petition.
156.With respect to the allegations set forth in Paragraph
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156 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
157.With respect to the allegations set forth in Paragraph
157 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
158.The Town denies the allegations set forth in Paragraph
158 of the PHV Petition.
159.The Town denies the allegations set forth in Paragraph
159 of the PHV Petition.
160.The Town denies the allegations set forth in Paragraph
160 of the PHV Petition.
161.With respect to the allegations set forth in Paragraph
161 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
162.The Town denies the allegations set forth in Paragraph
162 of the PHV Petition.
163.The Town denies the allegations set forth in Paragraph
163 of the PHV Petition.
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164.The Town denies the allegations set forth in Paragraph
164 of the PHV Petition.
165.The Town denies the allegations set forth in Paragraph
165 of the PHV Petition.
166.The Town denies the allegations set forth in Paragraph
166 of the PHV Petition.
167.The Town denies the allegations set forth in Paragraph
167 of the PHV Petition.
168.With respect to the allegations set forth in Paragraph
168 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
169.The Town denies the allegations set forth in Paragraph
169 of the PHV Petition.
170.With respect to the allegations set forth in Paragraph
170 of the PHV Petition, the Town admits that the Monroe-
Woodbury Central School District submitted comments on the 507
Petition, but denies their validity and any allegations made
therein.
171.The Town denies the allegations set forth in Paragraph
171 of the PHV Petition.
172.The Town denies the allegations set forth in Paragraph
172 of the PHV Petition.
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173.With respect to the allegations set forth in Paragraph
173 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect.
174.The Town denies the allegations set forth in Paragraph
174 of the PHV Petition.
175.The Town denies the allegations set forth in Paragraph
175 of the PHV Petition.
176.The Town denies the allegations set forth in Paragraph
176 of the PHV Petition.
177.The Town denies the allegations set forth in Paragraph
177 of the PHV Petition.
178.The Town denies the allegations set forth in Paragraph
178 of the PHV Petition.
179.The Town denies the allegations set forth in Paragraph
179 of the PHV Petition.
180.The Town admits the allegations set forth in Paragraph
180 of the PHV Petition.
181.The Town admits the allegations set forth in Paragraph
181 of the PHV Petition.
182.The Town admits the allegations set forth in Paragraph
182 of the PHV Petition.
183.The Town denies the allegations set forth in Paragraph
183 of the PHV Petition.
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184.The Town denies the allegations set forth in Paragraph
184 of the PHV Petition.
185.The Town denies the allegations set forth in Paragraph
185 of the PHV Petition.
186.The Town denies the allegations set forth in Paragraph
186 of the PHV Petition.
187.The Town denies the allegations set forth in Paragraph
187 of the PHV Petition.
188.With respect to the allegations set forth in Paragraph
188 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
189.With respect to the allegations set forth in Paragraph
161 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
190.The Town denies the allegations set forth in Paragraph
190 of the PHV Petition.
191.The Town denies the allegations set forth in Paragraph
191 of the PHV Petition.
192.The Town denies the allegations set forth in Paragraph
192 of the PHV Petition.
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193.With respect to the allegations set forth in Paragraph
193 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
194.The Town denies the allegations set forth in Paragraph
194 of the PHV Petition.
195.The Town denies the allegations set forth in Paragraph
195 of the PHV Petition.
196.The Town denies the allegations set forth in Paragraph
196 of the PHV Petition.
197.With respect to the allegations set forth in Paragraph
193 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
198.The Town denies the allegations set forth in Paragraph
198 of the PHV Petition.
199.The Town denies the allegations set forth in Paragraph
199 of the PHV Petition.
200.The Town admits the allegations set forth in Paragraph
200 of the PHV Petition.
201.The Town admits the allegations set forth in Paragraph
201 of the PHV Petition.
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202.With respect to the allegations set forth in Paragraph
202 of the PHV Petition, the Town admits that the 164 Petition
was filed, but lacks knowledge or information sufficient to form
a belief as to the truth of the allegations as to the intent of
the 164 Petition.
203.The Town denies the allegations set forth in Paragraph
203 of the PHV Petition.
204.The Town denies the allegations set forth in Paragraph
204 of the PHV Petition.
205.The Town denies the allegations set forth in Paragraph
205 of the PHV Petition.
206.The Town denies the allegations set forth in Paragraph
206 of the PHV Petition.
207.With respect to the allegations set forth in Paragraph
207 of the PHV Petition, the Town admits that the MWCSD
submitted comments on the 164 Petition, but denies their
validity.
208.The Town denies the allegations set forth in Paragraph
208 of the PHV Petition.
209.The Town denies the allegations set forth in Paragraph
209 of the PHV Petition.
210.With respect to the allegations set forth in Paragraph
210 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
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meaning and effect and denies Petitioners characterization
thereof.
211.The Town denies the allegations set forth in Paragraph
211 of the PHV Petition.
212.The Town denies the allegations set forth in Paragraph
212 of the PHV Petition.
213.The Town denies the allegations set forth in Paragraph
213 of the PHV Petition.
214.The Town denies the allegations set forth in Paragraph
214 of the PHV Petition.
215.With respect to the allegations set forth in Paragraph
215 of the PHV Petition, the Town 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 Town Assessment Roll.
216.With respect to the allegations set forth in Paragraph
216 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
217.With respect to the allegations set forth in Paragraph
217 of the PHV Petition, the Town admits that Bakertown Realty
Equities and the Jacob Bandua Trust do not appear to own SBL 1-
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3-1.3, but denies that their names and signatures should be
stricken from the 164 Petition.
218.The Town admits the allegations set forth in Paragraph
218 of the PHV Petition.
219.The Town admits the allegations set forth in Paragraph
219 of the PHV Petition.
220.The Town denies the allegations set forth in Paragraph
220 of the PHV Petition.
221.The Town denies the allegations set forth in Paragraph
221 of the PHV Petition.
222.The Town denies the allegations set forth in Paragraph
222 of the PHV Petition.
223.The Town denies the allegations set forth in Paragraph
223 of the PHV Petition.
224.The Town denies the allegations set forth in Paragraph
224 of the PHV Petition.
225.With respect to the allegations set forth in Paragraph
225 of the PHV Petition, the Town 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 Town refers the Court to the
documents referenced therein for determination of their content,
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meaning and effect and denies Petitioners characterization
thereof.
227.With respect to the allegations set forth in Paragraph
227 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
228.With respect to the allegations set forth in Paragraph
228 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
229.The Town denies the allegations set forth in Paragraph
229 of the PHV Petition.
230.The Town denies the allegations set forth in Paragraph
230 of the PHV Petition.
231.The Town denies the allegations set forth in Paragraph
231 of the PHV Petition.
232.The Town denies the allegations set forth in Paragraph
232 of the PHV Petition.
233.The Town denies the allegations set forth in Paragraph
233 of the PHV Petition.
234.With respect to the allegations set forth in Paragraph
234 of the PHV Petition, the Town lacks knowledge or information
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sufficient to form a belief as to the truth of the allegations
related to a letter from United Monroe, and denies that the
proposed annexation would violate the Establishment Clause.
235.With respect to the allegations in Paragraph 235 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
236.With respect to the allegations in Paragraph 236 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
237.With respect to the allegations in Paragraph 237 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
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238.With respect to the allegations in Paragraph 238 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
239.With respect to the allegations in Paragraph 239 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
240.With respect to the allegations in Paragraph 240 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
241.With respect to the allegations in Paragraph 241 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
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but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
242.With respect to the allegations in Paragraph 242 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
243.With respect to the allegations in Paragraph 243 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
244.The Town denies the allegations set forth in Paragraph
244 of the PHV Petition.
245.The Town denies the allegations set forth in Paragraph
245 of the PHV Petition.
246.The Town denies the allegations set forth in Paragraph
246 of the PHV Petition.
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247.With respect to the allegations set forth in Paragraph
247 of the PHV Petition, the Town admits that PHV has filed
pending litigation challenging DECs lead agency determination.
248.The Town denies the allegations set forth in Paragraph
248 of the PHV Petition.
249.The Town denies the allegations set forth in Paragraph
249 of the PHV Petition.
250.The Town denies the allegations set forth in Paragraph
250 of the PHV Petition.
251.The Town denies the allegations set forth in Paragraph
251 of the PHV Petition.
252.The Town denies the allegations set forth in Paragraph
252 of the PHV Petition.
253.With respect to the allegations set forth in Paragraph
253 of the PHV Petition, the Town lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
254.With respect to the allegations set forth in Paragraph
254 of the PHV Petition, the Town lacks knowledge or information
sufficient to form a belief as to the truth of the allegations.
255.The Town denies the allegations set forth in Paragraph
255 of the PHV Petition.
256.With respect to the allegations set forth in Paragraph
256 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
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meaning and effect and denies Petitioners characterization
thereof.
257.With respect to the allegations set forth in Paragraph
257 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
258.With respect to the allegations set forth in Paragraph
258 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
259.With respect to the allegations set forth in Paragraph
259 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
260.The Town denies the allegations set forth in Paragraph
260 of the PHV Petition.
261.The Town denies the allegations set forth in Paragraph
261 of the PHV Petition.
262.With respect to the allegations set forth in Paragraph
262 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
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meaning and effect and denies Petitioners characterization
thereof.
263.With respect to the allegations set forth in Paragraph
263 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
264.With respect to the allegations set forth in Paragraph
264 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
265.With respect to the allegations set forth in Paragraph
265 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
266.With respect to the allegations set forth in Paragraph
266 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
267.With respect to the allegations set forth in Paragraph
267 of the PHV Petition, the Town refers the Court to the
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documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
268.With respect to the allegations set forth in Paragraph
268 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
269.With respect to the allegations set forth in Paragraph
269 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
270.With respect to the allegations set forth in Paragraph
270 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
271.With respect to the allegations set forth in Paragraph
271 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
272.With respect to the allegations set forth in Paragraph
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272 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
273.With respect to the allegations set forth in Paragraph
273 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
274.With respect to the allegations set forth in Paragraph
274 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
275.With respect to the allegations set forth in Paragraph
275 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
276.With respect to the allegations set forth in Paragraph
276 of the PHV Petition, the Town 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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277.With respect to the allegations set forth in Paragraph
277 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
278.With respect to the allegations set forth in Paragraph
278 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
279.With respect to the allegations set forth in Paragraph
279 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
280.With respect to the allegations set forth in Paragraph
280 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect, denies Petitioners characterization
thereof, and admits that review was adequate for the 164
Petition.
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AS AND FOR AN ANSWER TO THE FIRST CAUSE OF
ACTION
281.With respect to the allegations incorporated by reference
in Paragraph 281 of the PHV Petition, the Town refers to its
responses to those allegations set forth above.
282.The Town denies the allegations set forth in Paragraph
282 of the PHV Petition.
283.The Town denies the allegations set forth in Paragraph
283 of the PHV Petition.
284.The Town denies the allegations set forth in Paragraph
284 of the PHV Petition.
285.The Town denies the allegations set forth in Paragraph
285 of the PHV Petition.
286.The Town denies the allegations set forth in Paragraph
286 of the PHV Petition.
287.The Town denies the allegations set forth in Paragraph
287 of the PHV Petition.
288.With respect to the allegations set forth in Paragraph
288 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
289.The Town denies the allegations set forth in Paragraph
289 of the PHV Petition.
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290.With respect to the allegations set forth in Paragraph
290 of the PHV Petition, the Town refers the Court to the
documents referenced therein for determination of their content,
meaning and effect and denies Petitioners characterization
thereof.
291.The Town denies the allegations set forth in Paragraph
291 of the PHV Petition.
292.The Town denies the allegations set forth in Paragraph
292 of the PHV Petition.
293.The Town denies the allegations set forth in Paragraph
293 of the PHV Petition.
AS AND FOR AN ANSWER TO THE SECOND CAUSE OF
ACTION
294.With respect to the allegations incorporated by reference
in Paragraph 294 of the PHV Petition, the Town refers to its
responses to those allegations set forth above.
295.With respect to the allegations in Paragraph 295 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect and denies
Petitioners characterization thereof.
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296.With respect to the allegations in Paragraph 296 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
297.The Town denies the allegations set forth in Paragraph
297 of the PHV Petition.
AS AND FOR AN ANSWER TO THE THIRD CAUSE OF
ACTION
298.With respect to the allegations incorporated by reference
in Paragraph 298 of the PHV Petition, the Town refers to its
responses to those allegations set forth above.
299.With respect to the allegations in Paragraph 299 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
300.With respect to the allegations in Paragraph 300 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
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but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
301.With respect to the allegations in Paragraph 301 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
302.With respect to the allegations in Paragraph 302 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
303.With respect to the allegations set forth in Paragraph
303 of the PHV Petition, the Town admits that the Petitioners
have alleged violations of the Establishment Clause but denies
the validity of these allegations.
304.The Town denies the allegations set forth in Paragraph
304 of the PHV Petition.
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305.The Town denies the allegations set forth in Paragraph
305 of the PHV Petition.
306.The Town denies the allegations set forth in Paragraph
306 of the PHV Petition.
307.The Town denies the allegations set forth in Paragraph
307 of the PHV Petition.
308.The Town denies the allegations set forth in Paragraph
308 of the PHV Petition.
309.With respect to the allegations in Paragraph 309 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
310.The Town denies the allegations set forth in Paragraph
310 of the PHV Petition.
311.With respect to the allegations set forth in Paragraph
311 of the PHV Petition, the Town admits Petitioners have made
this request, but denies their entitlement to it and denies
Petitioners characterization thereof
312.With respect to the allegations in Paragraph 312 of the
PHV Petition, the Town states that such allegations set forth
conclusions of law for which no responsive pleading is required,
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but to the extent an answer is made, the Town refers the Court
to the statutes and/or regulations referenced therein for
determination of their content, meaning and effect, and denies
Petitioners characterizations thereof.
AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF
ACTION
313.With respect to the allegations incorporated by reference
in the first sentence of Paragraph 313 of the PHV Petition, the
Town refers to its responses to those allegations set forth
above. With respect to the second sentence of allegations in
Paragraph 313 of the PHV Petition, the Town states that such
allegations set forth conclusions of law for which no responsive
pleading is required, but to the extent an answer is made, the
Town refers the Court to the statutes and/or regulations
referenced therein for determination of their content, meaning
and effect, and denies Petitioners characterizations thereof.
314.The Town denies the allegations set forth in Paragraph
314 of the PHV Petition.
315.With respect to the allegations set forth in Paragraph
315 of the PHV Petition, the Town 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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316.The Town admits the allegations set forth in Paragraph
316 of the PHV Petition.
317.The Town admits the allegations set forth in Paragraph
317 of the PHV Petition.
318.With respect to the allegations in Paragraph 318 of the
PHV Petition, the Town lacks knowledge or information sufficient
to form a belief as to the truth of the allegations set forth.
319.The Town denies the allegations set forth in Paragraph
319 of the PHV Petition.
AS AND FOR AN ANSWER TO THE FOURTH (FIFTH)1
CAUSE OF ACTION
320.With respect to the allegations incorporated by reference
in Paragraph 320 of the PHV Petition, the Town refers to its
responses to those allegations set forth above.
321.With respect to the allegations in Pa