`NYSCEF DOC. NO. 15
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 02/05/2024
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
` X
`
`DENNIS KILKENNY AND PATRICIA KILKENNY,
`
`
`
`
`
`
`
`- against -
`
`
`
`
` Plaintiffs,
`
`
`
` Index No: 190011/2024
`
` ANSWER TO
` VERIFIED
` COMPLAINT
`
`
`
`
`
`
`
`AMTROL INC., F/K/A AII ACQUISITION
`CORP., F/K/A ATHLONE INDUSTRIES, INC., F/K/A
`HOLLAND FURNACE COMPANY, et al.,
`
`
` Defendants.
`
` X
`
`
`
`
`
`Defendant, AMTROL INC., SUCCESSOR TO H.A. THRUSH AND
`
`THRUSH PRODUCTS, INC. incorrectly named as THRUSH Company, Inc. THRUSH
`
`COMPANY, INC., (hereinafter “AMTROL INC.”) by its attorneys McGivney, Kluger,
`
`Clark & Intoccia, P.C. for its Answer to Plaintiffs’ Verified Complaint states as follows:
`
`1.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to each and every allegation contained in Paragraph “1” of Plaintiffs’ Verified Complaint
`
`and leaves Plaintiffs to their proofs.
`
`2.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “2” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, refers
`
`all questions of law to this Court for determination at time of trial, and denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint to this
`
`Court for determination at time of trial.
`
`{N1391513-1}
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`1 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
`
`3.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “3” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, refers
`
`all questions of law to this Court for determination at time of trial, and denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint to this
`
`Court for determination at time of trial.
`
`4.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “4” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, refers
`
`all questions of law to this Court for determination at time of trial, and denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint to this
`
`Court for determination at time of trial.
`
`5.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “5” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, refers
`
`all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint to this
`
`Court for determination at time of trial and leaves Plaintiffs to their proofs.
`
`6.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “6” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, refers
`
`all questions of law to this Court for determination at time of trial, and denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint to this
`
`Court for determination at time of trial.
`
` {N1391513-1}
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`2 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
`
`7.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “7” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, refers
`
`all questions of law to this Court for determination at time of trial, and denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint to this
`
`Court for determination at time of trial.
`
`8.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to each and every allegation contained in Paragraph “8” of Plaintiffs’ Verified Complaint
`
`and leaves Plaintiffs to their proofs.
`
`9.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to each and every allegation contained in Paragraph “9” of Plaintiffs’ Verified Complaint
`
`and leaves Plaintiffs to their proofs.
`
`AS AND FOR AN ANSWER TO THE
`FIRST CAUSE OF ACTION
`
`Defendant, AMTROL INC., herein repeats and reiterates each and every answer heretofore
`
`made to Paragraphs “1” through “9” of Plaintiffs’ Verified Complaint.
`
`10.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to each and every allegation contained in Paragraph “10” of Plaintiffs’ Verified Complaint
`
`and leaves Plaintiffs to their proofs
`
`11.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “11” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
`
`defendant, denies any knowledge or information sufficient to form a belief as to each and every
`
`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
`
`Plaintiffs’ Verified Complaint and leaves Plaintiffs to their proofs.
`
` {N1391513-1}
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`3 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
`
` 12.
`
` Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “12” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
`
`defendant, denies any knowledge or information sufficient to form a belief as to each and every
`
`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
`
`Plaintiffs’ Verified Complaint, and leaves Plaintiffs to their proofs.
`
`13.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “13” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
`
`defendant, denies any knowledge or information sufficient to form a belief as to each and every
`
`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
`
`Plaintiffs’ Verified Complaint, and leaves Plaintiffs to their proofs.
`
`14.
`
`Defendant, AMTROL INC., denies each and every allegation contained in Paragraph
`
`“14” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering defendant and
`
`denies any knowledge or information sufficient to form a belief as to each and every allegation
`
`contained in the aforesaid paragraph as it pertains to the remaining defendants in the Plaintiffs’
`
`Verified Complaint.
`
`15.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “15” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
` {N1391513-1}
`
`4 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
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`16.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “16” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`17.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “17”, and all subparts, of the Plaintiffs’ Verified Complaint as it pertains to this answering
`
`defendant and refers all questions of law to this Court for determination at time of trial, denies any
`
`knowledge or information sufficient to form a belief as to the truth of the allegations contained in the
`
`aforesaid paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint,
`
`and leaves Plaintiffs to their proofs.
`
`18.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “18” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`19.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “19” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
` {N1391513-1}
`
`5 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
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`20.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to each and every allegation contained in Paragraph “20” of the Plaintiffs’ Verified
`
`Complaint and leaves Plaintiffs to their proofs.
`
`21.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to the truth of the allegations contained in Paragraph “21” and leaves Plaintiffs to their
`
`proofs.
`
`22.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to the truth of the allegations contained in Paragraph “22” and leaves Plaintiffs to their
`
`proofs.
`
`23.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “23” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and, denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`24.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “24” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and, denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`25.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “25” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
` {N1391513-1}
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`6 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
`
`26.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “26” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`27.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “27” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`28.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “28” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`29.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “29” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant, and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
` {N1391513-1}
`
`7 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
`
`
`
`30.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “30” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`31.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “31” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`32.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “32” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`33.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraphs “33”, and all subparts, of the Plaintiffs’ Verified Complaint as it pertains to this
`
`answering defendant and refers all questions of law to this Court for determination at time of trial,
`
`and denies any knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in the aforesaid paragraph as it pertains to the remaining defendants in the Plaintiffs’
`
`Verified Complaint.
`
` {N1391513-1}
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`8 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
`
`
`
`34.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “34” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`35.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “35” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`WHEREFORE, defendant denies it is liable for any damages, compensatory, punitive or
`
`otherwise.
`
`
`
`AS AND FOR AN ANSWER
`TO THE SECOND CAUSE OF ACTION
`
`
`Defendant, AMTROL INC., herein repeats and reiterates each and every answer heretofore
`
`made to Paragraphs “1” through “35” of Plaintiffs’ Verified Complaint.
`
`36.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to each and every allegation contained in Paragraph “36” of the Plaintiffs’ Verified
`
`Complaint and leaves Plaintiffs to their proofs.
`
`37.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to each and every allegation contained in Paragraph “37” of the Plaintiffs’ Verified
`
`Complaint and leaves Plaintiffs to their proofs.
`
` {N1391513-1}
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`9 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
`
`38.
`
`Defendant, AMTROL INC., denies each and every allegation contained in Paragraph
`
`“38” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and denies any
`
`knowledge or information sufficient to form a belief as to the truth of the allegations contained in the
`
`aforesaid paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`39.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “39” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`denies any knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in the aforesaid paragraph as it pertains to the remaining defendants in the Plaintiffs’
`
`Verified Complaint.
`
`WHEREFORE, defendant denies it is liable for any damages, compensatory, punitive or
`
`otherwise.
`
`
`
`AS AND FOR AN ANSWER
`TO THE THIRD CAUSE OF ACTION
`
`Defendant, AMTROL INC., herein repeats and reiterates each and every answer heretofore
`
`made to Paragraphs “1” through “39” of Plaintiffs’ Verified Complaint.
`
`40.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “40” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant
`
`and denies any knowledge or information sufficient to form a belief as to the truth of the
`
`allegations contained in the aforesaid paragraph as it pertains to the remaining defendants in the
`
`Plaintiffs’ Verified Complaint.
`
`41.
`
`Defendant, AMTROL INC., denies each and every allegation contained in Paragraph
`
`“41” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and denies any
`
`knowledge or information sufficient to form a belief as to the truth of the allegations contained in the
`
`aforesaid paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
` {N1391513-1}
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`10 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
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`WHEREFORE, defendant denies it is liable for any damages, compensatory, punitive or
`
`otherwise.
`
`
`
`AS AND FOR AN ANSWER
`TO THE FOURTH CAUSE OF ACTION
`
`Defendant, AMTROL INC., herein repeats and reiterates each and every answer heretofore
`
`made to Paragraphs “1” through “41” of Plaintiffs’ Verified Complaint.
`
`42.
`
`Defendant, AMTROL INC., herein repeats and reiterates each and every answer
`
`heretofore made to Paragraphs “1” through “42” of Plaintiffs’ Verified Complaint.
`
`43.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “43” of the Plaintiffs’ Verified Complaint as it pertains to the answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to each and every allegation contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`44. Defendant, AMTROL INC., denies each and every allegation contained in Paragraph
`
`“44” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and refers all
`
`questions of law to this Court for determination at time of trial, denies any knowledge or information
`
`sufficient to form a belief as to the truth of the allegations contained in the aforesaid paragraph as it
`
`pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves Plaintiffs to
`
`their proofs.
`
`45.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to the truth of the allegations contained in Paragraph “45” of the Plaintiff’s Verified
`
`Complaint and leaves Plaintiffs to their proofs.
`
` {N1391513-1}
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`11 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
`
`46.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “46” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`47.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “47” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`48.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “48” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`49.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “49” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
` {N1391513-1}
`
`12 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
`
`50.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “50” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`51.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “52” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, denies any knowledge or
`
`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint, and leaves
`
`Plaintiffs to their proofs.
`
`52.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “52”, and all subparts, of the Plaintiffs’ Verified Complaint as it pertains to this
`
`answering defendant and refers all questions of law to this Court for determination at time of trial,
`
`and denies any knowledge or information sufficient to form a belief as to the truth of the allegations
`
`contained in the aforesaid paragraph as it pertains to the remaining defendants in the Plaintiffs’
`
`Verified Complaint.
`
`53.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to the truth of the allegations contained in Paragraph “53” of the Plaintiff’s Verified
`
`Complaint and leaves Plaintiffs to their proofs.
`
` {N1391513-1}
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`13 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
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`
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`54.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “54” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint
`
`55.
`
`Defendant, AMTROL INC., denies any knowledge or information sufficient to form
`
`a belief as to the truth of the allegations contained in Paragraph “55” of the Plaintiffs’ Verified
`
`Complaint and refers all questions of law to this Court for determination at time of trial.
`
`56.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “56” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint
`
`57.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “57” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`58.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “58” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
` {N1391513-1}
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`14 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
`
`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/05/2024
`
`
`
`59.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “59” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`60.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “60” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`61.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “61” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`62.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “62” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
` {N1391513-1}
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`15 of 39
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`FILED: NEW YORK COUNTY CLERK 02/05/2024 11:17 AM
`NYSCEF DOC. NO. 15
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 02/05/2024
`
`
`
`63.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “63” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`64.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “64” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant and
`
`refers all questions of law to this Court for determination at time of trial, and denies any knowledge
`
`or information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
`
`paragraph as it pertains to the remaining defendants in the Plaintiffs’ Verified Complaint.
`
`65.
`
`Defendant, AMTROL INC., denies each and every allegation contained in
`
`Paragraph “65” of the Plaintiffs’ Ve