FILED: ERIE COUNTY CLERK 12/22/2023 11:28 AM
`NYSCEF DOC. NO. 13
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF ERIE
`----------------------------------------------------------------X
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`TROY SHANE SMITH and ALLYSON JANE
`SMITH,
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` Plaintiffs,
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`- against -
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`84 LUMBER COMPANY., et al.,
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`
` Defendants.
`----------------------------------------------------------------X
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`VERIFIED ANSWER
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`Index No. 814633/2023
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`Defendant DAP, Inc. k/n/a La Mirada Products Co., Inc. (“DAP”), by its attorneys,
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`Landman Corsi Ballaine & Ford P.C., hereby answers Plaintiffs’ Verified Complaint herein as
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`follows:
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`1.
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`DAP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations contained in Paragraph 1.
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`2.
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`DAP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations contained in Paragraph 2.
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`3.
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`DAP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations contained in Paragraph 3.
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`4.
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`DAP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations contained in Paragraph 4.
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`5.
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`DAP denies the allegations contained in Paragraph 5 as they pertain to DAP, except
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`admits that at certain times DAP has conducted business in the State of New York, and lacks
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`knowledge or information sufficient to form a belief as to the truth of the allegations contained in
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`Paragraph 5 as they pertain to other defendants.
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`6.
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`DAP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations contained in Paragraphs 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22
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`and 23.
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`7.
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`DAP denies the allegations contained in Paragraph 24, except admits that at certain
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`times DAP has conducted business in the State of New York.
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`8.
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`DAP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations contained in the Paragraphs 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38,
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`39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60 and 61.
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`9.
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`DAP denies the allegations contained in Paragraph 62 as they pertain to DAP,
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`except admits that at certain times DAP has conducted business in the State of New York, and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 62 as they pertain to other defendants.
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`10.
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`DAP denies the allegations contained in Paragraph 63 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 63 as they pertain to other defendants.
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`11.
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`DAP denies the allegations contained in Paragraph 64 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 64 as they pertain to other defendants.
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`12.
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`DAP denies the allegations contained in Paragraph 65 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 65 as they pertain to the other defendants.
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`13.
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`DAP denies the allegations contained in Paragraph 66 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 66 as they pertain to the other defendants.
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`14.
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`DAP denies the allegations contained in Paragraph 67 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 67 as they pertain to the other defendants.
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`15.
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`DAP denies the allegations contained in Paragraph 68 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 68 as they pertain to the other defendants.
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`16.
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`DAP denies the allegations contained in Paragraph 69 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 69 as they pertain to the other defendants.
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`FIRST CAUSE OF ACTION
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`17.
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`DAP repeats and realleges it answers to the allegations contained in Paragraphs 1
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`through and including 16 as though set forth at length herein.
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`18.
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`DAP denies the allegations contained in Paragraph 71 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 71 as they pertain to the other defendants.
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`19.
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`DAP denies the allegations contained in Paragraph 72 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 72 as they pertain to the other defendants.
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`20.
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`DAP denies the allegations contained in Paragraph 73 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 73 as they pertain to the other defendants.
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`21.
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`DAP denies the allegations contained in Paragraph 74 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 74 as they pertain to the other defendants.
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`22.
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`DAP denies the allegations contained in Paragraph 75, including subparagraphs (a-
`
`m), as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to the
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`truth of the allegations contained in Paragraph 75, including subparagraphs (a-m), as they pertain
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`to the other defendants.
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`23.
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`DAP denies the allegations contained in Paragraph 76 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 76 as they pertain to the other defendants.
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`24.
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`DAP denies the allegations contained in Paragraph 77 as it pertains to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 77 as they pertain to other defendants.
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`25.
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`DAP denies the allegations contained in Paragraph 78 as it pertains to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 78 as they pertain to other defendants.
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`SECOND CAUSE OF ACTION
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`26.
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`DAP repeats and realleges its answers to the allegations contained in Paragraphs 1
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`through and including 25 as though set forth at length herein.
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`27.
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`DAP denies the allegations contained in Paragraph 80 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 80 as they pertain to other defendants.
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`28.
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`DAP denies the allegations contained in Paragraph 81 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 81 as they pertain to other defendants.
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`29.
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`DAP denies the allegations contained in Paragraph 82 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 82 as they pertain to other defendants.
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`30.
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`DAP denies the allegations contained in Paragraph 83 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 83 as they pertain to other defendants.
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`THIRD CAUSE OF ACTION
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`31.
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`DAP repeats and realleges its answers to the allegations contained in Paragraphs 1
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`through and including 30 as through set forth at length herein.
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`32.
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`DAP denies the allegations contained in Paragraph 85 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 85 as they pertain to other defendants.
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`33.
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`DAP denies the allegations contained in Paragraph 86 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 86 as they pertain to other defendants.
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`34.
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`DAP denies the allegations contained in Paragraph 87 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 87 as they pertain to other defendants.
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`35.
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`DAP denies the allegations contained in Paragraph 88 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 88 as they pertain to other defendants.
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`36.
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`DAP denies the allegations contained in Paragraph 89 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 89 as they pertain to other defendants.
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`37.
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`DAP denies the allegations contained in Paragraph 90 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 90 as they pertain to other defendants.
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`38.
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`DAP denies the allegations contained in Paragraph 91 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 91 as they pertain to other defendants.
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`39.
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`DAP denies the allegations contained in Paragraph 92 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 92 as they pertain to other defendants.
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`40.
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`DAP denies the allegations contained in Paragraph 93 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 93 as they pertain to other defendants.
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`FOURTH CAUSE OF ACTION
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`41.
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`DAP repeats and realleges its answers to the allegations contained in Paragraph 1
`
`through and including 40 as though set forth at length herein.
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`42.
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`DAP denies the allegations contained in Paragraph 95 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 95 as they pertain to other defendants.
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`43.
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`DAP denies the allegations contained in Paragraph 96 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 96 as they pertain to other defendants.
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`44.
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`DAP avers that Paragraph 97 contains conclusions of law to which no response is
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`required. To the extent a response is required, DAP denies the allegations contained in Paragraph
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`97 as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to the
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`truth of the allegations contained in Paragraph 97 as they pertain to other defendants.
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`45.
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`DAP denies the allegations contained in Paragraph 98 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 98 as they pertain to other defendants.
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`46.
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`DAP denies the allegations contained in Paragraph 99 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 99 as they pertain to other defendants.
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`47.
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`DAP denies the allegations contained in Paragraph 100 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 100 as they pertain to other defendants.
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`48.
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`DAP denies the allegations contained in Paragraph 101 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 101 as they pertain to other defendants.
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`49.
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`DAP denies the allegations contained in Paragraph 102 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 102 as they pertain to other defendants.
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`50.
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`DAP denies the allegations contained in Paragraph 103 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 103 as they pertain to other defendants.
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`51.
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`DAP denies the allegations contained in Paragraph 104, including subparagraphs
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`(a-f), as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to
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`the truth of the allegations contained in Paragraph 104, including subparagraphs (a-f), as they
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`pertain to other defendants.
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`52.
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`DAP denies the allegations contained in Paragraph 105 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 105 as they pertain to other defendants.
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`53.
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`DAP denies the allegations contained in Paragraph 106 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 106 as they pertain to other defendants.
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`54.
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`DAP denies the allegations contained in Paragraph 107 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 107 as they pertain to other defendants.
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`55.
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`DAP denies the allegations contained in Paragraph 108 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 108 as they pertain to other defendants.
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`56.
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`DAP denies the allegations contained in Paragraph 109 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 109 as they pertain to other defendants.
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`57.
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`DAP denies the allegations contained in Paragraph 110 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 110 as they pertain to other defendants.
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`58.
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`DAP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations contained in paragraph 111.
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`59.
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`DAP denies the allegations contained in Paragraph 112 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 112 as they pertain to other defendants.
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`FIFTH CAUSE OF ACTION
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`60.
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`DAP repeats and realleges its answers to the allegations contained in Paragraph 1
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`through and including 59 as though set forth at length herein.
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`61.
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`DAP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations contained in Paragraph 114, 115,116,117,118,119 and 120.
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`SIXTH CAUSE OF ACTION
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`62.
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`DAP repeats and realleges its answers to the allegations contained in Paragraph 1
`
`through and including 61 as though set forth at length herein.
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`63.
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`DAP denies the allegations contained in Paragraph 122 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 122 as they pertain to other defendants.
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`64.
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`DAP denies the allegations contained in Paragraph 123 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 123 as they pertain to other defendants.
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`65.
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`DAP denies the allegations contained in Paragraph 124 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 124 as they pertain to other defendants.
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`66.
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`DAP denies the allegations contained in Paragraph 125 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 125 as they pertain to other defendants.
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`67.
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`DAP denies the allegations contained in Paragraph 126 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 126 as they pertain to other defendants.
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`68.
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`DAP denies the allegations contained in Paragraph 127 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 127 as they pertain to other defendants.
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`69.
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`DAP denies the allegations contained in Paragraph 128 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 128 as they pertain to other defendants.
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`70.
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`DAP denies the allegations contained in Paragraph 129, including subparagraphs
`
`(i)-(iii), as they pertain to DAP and lacks knowledge or information sufficient to form a belief as
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`to the truth of the allegations contained in Paragraph 129, including subparagraphs (i)-(iii), as they
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`pertain to other defendants.
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`71.
`
`DAP denies the allegations contained in Paragraph 130 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 130 as they pertain to other defendants.
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`72.
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`DAP denies the allegations contained in Paragraph 131 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 131 as they pertain to other defendants.
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`73.
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`DAP denies the allegations contained in Paragraph 132 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 132 as they pertain to other defendants.
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`74.
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`DAP denies the allegations contained in Paragraph 133 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
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`contained in Paragraph 133 as they pertain to other defendants.
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`75.
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`DAP denies the allegations contained in Paragraph 134 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 134 as they pertain to other defendants.
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`76.
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`DAP denies the allegations contained in Paragraph 135 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 135 as they pertain to other defendants.
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`77.
`
`DAP denies the allegations contained in Paragraph 136 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 136 as they pertain to other defendants.
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`SEVENTH CAUSE OF ACTION
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`78.
`
`DAP repeats and realleges its answers to the allegations in Paragraph 1 through and
`
`including 77 as though set forth at length herein.
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`79.
`
`DAP lacks knowledge or information sufficient to form a basis as to the truth of the
`
`allegations contained in Paragraph 138.
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`80.
`
`DAP denies the allegations contained in Paragraph 139 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 139 as they pertain to other defendants.
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`81.
`
`DAP denies the allegations contained in Paragraph 140 as they pertain to DAP and
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 140 as they pertain to other defendants.
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`82.
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`DAP denies the allegations contained in Paragraph 141 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
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`contained in Paragraph 141 as they pertain to other defendants.
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`83.
`
`DAP denies the allegations contained in Paragraph 142 as they pertain to DAP and
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 142 as they pertain to other defendants.
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`84.
`
`DAP denies the allegations contained in Paragraph 143 as they pertain to DAP and
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 143 as they pertain to other defendants.
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`85.
`
`DAP denies the allegations contained in Paragraph 144 as they pertain to DAP and
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 144 as they pertain to other defendants.
`
`86.
`
`DAP avers that Paragraph 145 contains conclusions of law to which no response is
`
`required. To the extent a response is required, DAP denies the allegations contained in Paragraph
`
`145 as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to
`
`the truth of the allegations contained in Paragraph 145 as they pertain to other defendants.
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`87.
`
`DAP denies the allegations contained in Paragraph 146 as they pertain to DAP and
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 146 as they pertain to other defendants.
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`88.
`
`DAP denies the allegations contained in Paragraph 147 as they pertain to DAP and
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 147 as they pertain to other defendants.
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`89.
`
`DAP denies the allegations contained in Paragraph 148 as they pertain to DAP and
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in Paragraph 148 as they pertain to other defendants.
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`FILED: ERIE COUNTY CLERK 12/22/2023 11:28 AM
`NYSCEF DOC. NO. 13
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`90.
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`DAP denies the allegations contained in Paragraph 149 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 149 as they pertain to other defendants.
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`91.
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`DAP denies the allegations contained in Paragraph 150 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 150 as they pertain to other defendants.
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`EIGHT CAUSE OF ACTION
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`92.
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`DAP repeats and realleges its answers to the allegations contained in Paragraph 1
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`through and including 91 as though set forth at length herein.
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`93.
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`DAP denies the allegations contained in Paragraph 152 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 152 as they pertain to other defendants.
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`94.
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`DAP denies the allegations contained in Paragraph 153 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 153 as they pertain to other defendants.
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`95.
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`DAP denies the allegations contained in Paragraph 154 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 154 as they pertain to other defendants.
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`96.
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`DAP denies the allegations contained in Paragraph 155 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 155 as they pertain to other defendants.
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`97.
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`DAP denies the allegations contained in Paragraph 156 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
`
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`contained in Paragraph 156 as they pertain to other defendants.
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`98.
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`DAP denies the allegations contained in Paragraph 157 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 157 as they pertain to other defendants.
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`99.
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`DAP denies the allegations contained in Paragraph 158 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 158 as they pertain to other defendants.
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`100. DAP denies the allegations contained in Paragraph 159 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 159 as they pertain to other defendants.
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`101. DAP denies the allegations contained in Paragraph 160 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 160 as they pertain to other defendants.
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`102. DAP denies the allegations contained in Paragraph 161 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 161 as they pertain to other defendants.
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`103. DAP denies the allegations contained in Paragraph 162 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 162 as they pertain to other defendants.
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`104. DAP denies the allegations contained in Paragraph 163 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 163 as they pertain to other defendants.
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`105. DAP denies the allegations contained in Paragraph 164 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 164 as they pertain to other defendants.
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`106. DAP denies the allegations contained in Paragraph 165 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 165 as they pertain to other defendants.
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`107. DAP denies the allegations contained in Paragraph 166 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 166 as they pertain to other defendants.
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`NINTH CAUSE OF ACTION
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`108. DAP repeats and realleges its answers to the allegations contained in Paragraph 1
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`through and including 107 as set forth at length herein.
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`109. DAP avers that Paragraph 168 contains conclusions of law to which no response is
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`required. To the extent a response is required, DAP denies the allegations contained in Paragraph
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`168 as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to
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`the truth of the allegations contained in Paragraph 168 as they pertain to other defendants.
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`110. DAP denies the allegations contained in Paragraph 169 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 169 as they pertain to other defendants.
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`111. DAP avers that Paragraph 170 contains conclusions of law to which no response is
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`required. To the extent a response is required, DAP denies the allegations contained in Paragraph
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`170 as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to
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`the truth of the allegations contained in Paragraph 170 as they pertain to other defendants.
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`112. DAP avers that Paragraph 171 contains conclusions of law to which no response is
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`required. To the extent a response is required, DAP denies the allegations contained in Paragraph
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`171 as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to
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`the truth of the allegations contained in Paragraph 171 as they pertain to other defendants.
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`113. DAP avers that Paragraph 172 contains conclusions of law to which no response is
`
`required. To the extent a response is required, DAP denies the allegations contained in Paragraph
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`172 as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to
`
`the truth of the allegations contained in Paragraph 172 as they pertain to other defendants.
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`114. DAP avers that Paragraph 173 contains conclusions of law to which no response is
`
`required. To the extent a response is required, DAP denies the allegations contained in Paragraph
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`173 as they pertain to DAP and lacks knowledge or information sufficient to form a belief as to
`
`the truth of the allegations contained in Paragraph 173 as they pertain to other defendants.
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`115. DAP denies the allegations contained in Paragraph 174 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 174 as they pertain to other defendants.
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`116. DAP denies the allegations contained in Paragraph 175 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 175 as they pertain to other defendants.
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`117. DAP denies the allegations contained in Paragraph 176 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 176 as they pertain to other defendants.
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`118. DAP denies the allegations contained in Paragraph 177 as they pertain to DAP and
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in Paragraph 177 as they pertain to other defendants.
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`119. DAP denies the allegations contained in Paragraph 178 as they pertain to DAP and
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`lacks knowledge or information sufficient to