FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
`NYSCEF DOC. NO. 4
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 01/22/2024
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`-against-
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`Index No.: 190011/2024
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`VERIFIED ANSWER TO
`VERIFIED COMPLAINT
`
`Plaintiffs,
`
`SUPREME COURT OF THE STATE OF
`NEW YORK
`COUNTY OF NEW YORK
`
`DENNIS KILKENNY and PATRICIA
`KILKENNY,
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`
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`AII ACQUISITION, LLC, F/K/A AII
`ACQUISITION CORP., F/K/A ATHLONE
`INDUSTRIES, INC., F/K/A HOLLAND
`FURNACE COMPANY, ET AL.,
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`Defendants,
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`Defendant, CROWN BOILER CO., improperly named in the complaint as “CROWN
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`BOILER COMPANY,” hereinafter referred to as “CROWN BOILER CO.,” by its attorneys
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`The Cook Group, PLLC, answering Plaintiffs’ Summons and Verified Complaint and in this
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`action, hereby states upon information and belief as follows:
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`
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`1.
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`Defendant, CROWN BOILER CO., denies any knowledge or information
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`sufficient to form a belief as to the truth of the allegations in Paragraph “1” of the Plaintiffs’
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`Verified Complaint.
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`2.
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`Defendant, CROWN BOILER CO., denies the allegations in Paragraph “2”
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`related to the alleged commission of tortious acts and/or acts giving rise to injuries and losses and
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`denies knowledge or information sufficient to form a belief as to the truth of the remaining
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`allegations. CROWN BOILER CO. denies knowledge or information sufficient to form a belief
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`as to the truth of allegations contained in this paragraph pertaining to the remaining Defendants.
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`3.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “3” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant,
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`{C0216263.1}
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
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`and refers all questions of law to this Court for determination at time of trial, and denies any
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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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`the aforesaid paragraph as it pertains to the remaining defendants in the Verified Complaint.
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`4.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “4” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant,
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`and refers all questions of law to this Court for determination at time of trial, and denies any
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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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`the aforesaid paragraph as it pertains to the remaining defendants in the Verified Complaint.
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`5.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “5” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant,
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`and refers all questions of law to this Court for determination at time of trial, and denies any
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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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`the aforesaid paragraph as it pertains to the remaining defendants in the Verified Complaint.
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`6.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “6” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant,
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`and refers all questions of law to this Court for determination at time of trial, and denies any
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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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`the aforesaid paragraph as it pertains to the remaining defendants in the Verified Complaint.
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`7.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “7” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant,
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`and refers all questions of law to this Court for determination at time of trial, and denies any
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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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`the aforesaid paragraph as it pertains to the remaining defendants in the Verified Complaint.
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`{C0216263.1}
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
`NYSCEF DOC. NO. 4
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 01/22/2024
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`8.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “8” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant,
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`and refers all questions of law to this Court for determination at time of trial, and denies any
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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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`the aforesaid paragraph as it pertains to the remaining defendants in the Verified Complaint.
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`9.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “9” of the Plaintiffs’ Verified Complaint as it pertains to this answering defendant,
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`and refers all questions of law to this Court for determination at time of trial, and denies any
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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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`the aforesaid paragraph as it pertains to the remaining defendants in the Verified Complaint.
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`AS AND FOR AN ANSWER TO THE FIRST CAUSE OF ACTION
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`10.
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`Defendant, CROWN BOILER CO., herein repeats, reiterates, and re-alleges each
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`and every answer heretofore made to Paragraphs “1” through “9” of Plaintiffs’ Verified Complaint
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`as if set forth in full herein.
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`11.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “10” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`12.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “11” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`{C0216263.1}
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
`NYSCEF DOC. NO. 4
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 01/22/2024
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`13.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “12” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`14.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “13” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`15.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “14” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`16.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “15” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`17.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “16” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`{C0216263.1}
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
`NYSCEF DOC. NO. 4
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`RECEIVED NYSCEF: 01/22/2024
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`18.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “17,” “17(a),” “17(b),” “17(c),” “17(d),” “17(e),” “17(f),” 17(g),” and “17(h)” of the
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`Plaintiffs’ Verified Complaint insofar as it pertains to the answering defendant and denies any
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`knowledge or information sufficient to form a belief as to each and every allegation contained in
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`the aforesaid paragraph as it pertains to the remaining defendants in the Verified Complaint.
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`19.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “18” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`20.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “19” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`21.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “20” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`{C0216263.1}
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
`NYSCEF DOC. NO. 4
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 01/22/2024
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`22.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “21” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`23.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “22” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`24.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “23” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`25.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “24” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`26.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “25” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`{C0216263.1}
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`RECEIVED NYSCEF: 01/22/2024
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`27.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “26” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`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
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`Verified Complaint.
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`28.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “27” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`29.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “28” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`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
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`Verified Complaint.
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`30.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “29” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`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
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`Verified Complaint.
`
`{C0216263.1}
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`RECEIVED NYSCEF: 01/22/2024
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`31.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “30” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`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
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`Verified Complaint.
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`32.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “31” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`33.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “32” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`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
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`Verified Complaint.
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`34.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “33,” “33(a),” “33(b),” “33(c),” “33(d),” “33(e),” “33(f),” “33(g),” “33(h),” “33(i),”
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`and “33(j)” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering defendant
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`and denies any knowledge or information sufficient to form a belief as to each and every allegation
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`contained in the aforesaid paragraph as it pertains to the remaining defendants in the Verified
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`Complaint.
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`35.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “34” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`{C0216263.1}
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`RECEIVED NYSCEF: 01/22/2024
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`defendant and denies any knowledge or information sufficient to form a belief as to each and every
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`allegation contained in the aforesaid paragraph as it pertains to the remaining defendants in the
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`Verified Complaint.
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`36.
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`Defendant, CROWN BOILER CO., denies each and every allegation contained
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`in Paragraph “35” of the Plaintiffs’ Verified Complaint insofar as it pertains to the answering
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`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
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`Verified Complaint.
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`WHEREFORE, Defendant, CROWN BOILER CO., denies it is liable for any damages,
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`compensatory, punitive or otherwise.
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`AS AND FOR AN ANSWER TO THE SECOND CAUSE OF ACTION
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`37.
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`CROWN BOILER CO., repeats, reiterates, and re-alleges each and every answer
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`heretofore made to Paragraphs “1” through “35,” inclusive, of Plaintiffs’ Verified Complaint, as
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`if set forth in full herein.
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`38.
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`CROWN BOILER CO. denies the allegations contained in Paragraph “36” of the
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`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
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`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
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`allegations contained in this paragraph pertaining to the remaining Defendants.
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`39.
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`CROWN BOILER CO. denies the allegations contained in Paragraph “37” of the
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`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
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`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
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`allegations contained in this paragraph pertaining to the remaining Defendants.
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`40.
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`CROWN BOILER CO. denies the allegations contained in Paragraph “38” of the
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`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`{C0216263.1}
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`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
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`allegations contained in this paragraph pertaining to the remaining Defendants.
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`41.
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`CROWN BOILER CO. denies the allegations contained in Paragraph “39” of the
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`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
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`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
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`WHEREFORE, Defendant, CROWN BOILER CO., denies it is liable for any damages,
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`compensatory, punitive or otherwise.
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`AS AND FOR AN ANSWER TO THE THIRD CAUSE OF ACTION
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`42.
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`CROWN BOILER CO., herein repeats, reiterates, and re-alleges each and every
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`answer heretofore made to Paragraphs “1” through “39,” inclusive, of Plaintiffs’ Verified
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`Complaint, as if set forth in full herein.
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`43.
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`CROWN BOILER CO. denies the allegations contained in Paragraph “40” of the
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`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
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`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
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`44.
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`CROWN BOILER CO. denies the allegations contained in Paragraph “41” of the
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`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
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`WHEREFORE, Defendant, CROWN BOILER CO., denies it is liable for any damages,
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`compensatory, punitive or otherwise.
`
`{C0216263.1}
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`AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF ACTION
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`45.
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`CROWN BOILER CO., herein repeats, reiterates, and re-alleges each and every
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`answer heretofore made to Paragraphs “1” through “41,” inclusive, of Plaintiffs’ Verified
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`Complaint as if set forth in full herein.
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`46.
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`CROWN BOILER CO. denies the allegations contained in Paragraph “43” of the
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`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
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`47. CROWN BOILER CO. denies the allegations contained in Paragraph “44” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
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`48. CROWN BOILER CO. denies the allegations contained in Paragraph “45” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
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`49. CROWN BOILER CO. denies the allegations contained in Paragraph “46” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
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`50. CROWN BOILER CO. denies the allegations contained in Paragraph “47” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`{C0216263.1}
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`RECEIVED NYSCEF: 01/22/2024
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`51. CROWN BOILER CO. denies the allegations contained in Paragraph “48” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`52. CROWN BOILER CO. denies the allegations contained in Paragraph “49” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
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`53. CROWN BOILER CO. denies the allegations contained in Paragraph “50” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`54. CROWN BOILER CO. denies the allegations contained in Paragraph “51” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`55. CROWN BOILER CO. denies the allegations contained in Paragraph “52,”
`
`52(a),” “52(b),” “52(c),” “52(d),” “52(e),” “52(f),” “52(g),” “52(h),” “52(i),” “52(j),” “52(k),” and
`
`“52(l)” of the Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all
`
`question of law to the Court, and denies knowledge or information sufficient to form a belief as to
`
`the truth of allegations contained in this paragraph pertaining to the remaining Defendants.
`
`56. CROWN BOILER CO. denies the allegations contained in Paragraph “53” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`{C0216263.1}
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
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`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`57. CROWN BOILER CO. denies the allegations contained in Paragraph “54” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`58. CROWN BOILER CO. denies the allegations contained in Paragraph “55” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`59. CROWN BOILER CO. denies the allegations contained in Paragraph “56” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`60. CROWN BOILER CO. denies the allegations contained in Paragraph “57” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`61. CROWN BOILER CO. denies the allegations contained in Paragraph “58” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`{C0216263.1}
`
`
`13
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`13 of 35
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
`NYSCEF DOC. NO. 4
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 01/22/2024
`
`
`
`62. CROWN BOILER CO. denies the allegations contained in Paragraph “59” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`63. CROWN BOILER CO. denies the allegations contained in Paragraph “60” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`64. CROWN BOILER CO. denies the allegations contained in Paragraph “61” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`65. CROWN BOILER CO. denies the allegations contained in Paragraph “62” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`66. CROWN BOILER CO. denies the allegations contained in Paragraph “63” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`67. CROWN BOILER CO. denies the allegations contained in Paragraph “64” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`{C0216263.1}
`
`
`14
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
`NYSCEF DOC. NO. 4
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`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 01/22/2024
`
`
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`68. CROWN BOILER CO. denies the allegations contained in Paragraph “65” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`69. CROWN BOILER CO. denies the allegations contained in Paragraph “66” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`70. CROWN BOILER CO. denies the allegations contained in Paragraph “67” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`71. CROWN BOILER CO. denies the allegations contained in Paragraph “68” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`WHEREFORE, Defendant, CROWN BOILER CO., denies it is liable for any damages,
`
`compensatory, punitive or otherwise.
`
`AS AND FOR AN ANSWER TO THE FIFTH CAUSE OF ACTION
`
`72.
`
`CROWN BOILER CO., herein repeats, reiterates, and re-alleges each and every
`
`answer heretofore made to Paragraphs “1” through “68,” inclusive, of Plaintiffs’ Verified
`
`Complaint as if set forth in full herein.
`
`{C0216263.1}
`
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`FILED: NEW YORK COUNTY CLERK 01/22/2024 03:52 PM
`NYSCEF DOC. NO. 4
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 01/22/2024
`
`
`
`73.
`
`CROWN BOILER CO. denies the allegations contained in Paragraph “70” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`74.
`
`CROWN BOILER CO. denies the allegations contained in Paragraph “71” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`75.
`
`CROWN BOILER CO. denies the allegations contained in Paragraph “72” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`76.
`
`CROWN BOILER CO. denies the allegations contained in Paragraph “73” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denies knowledge or information sufficient to form a belief as to the truth of
`
`allegations contained in this paragraph pertaining to the remaining Defendants.
`
`77.
`
`CROWN BOILER CO. denies the allegations contained in Paragraph “74” of the
`
`Plaintiffs’ Verified Complaint pertaining to CROWN BOILER CO., refers all question of law to
`
`the Court, and denie