FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
` X
`
`DENNIS KILKENNY AND PATRICIA KILKENNY,
`
`
`
`
`
`
`
`
`
`
`
`
`
` - against -
`
`
`
`
`
`
` Plaintiffs,
`
`
`
`
`
` Index No: 190011/2024
`
` VERIFIED
` ANSWER TO SECOND
` AMENDED VERIFIED
` COMPLAINT
`
`
`AII ACQUISITION, LLC, F/K/A AII ACQUISITION CORP.,
`F/K/A ATHLONE INDUSTRIES, INC., F/K/A
`HOLLAND FURNACE COMPANY, et al.,
`
`
` Defendants.
`
` X
`
`
`
`
`
`Defendant, ZENITH ELECTRONICS, LLC by its attorneys McGivney,
`
`Kluger, Clark & Intoccia, P.C. for its Verified Amended Answer to Plaintiffs’ Verified
`
`Complaint states as follows:
`
`1.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
`{N1406053-1}
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`1 of 40
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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`3.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
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`2 of 40
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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`7.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , herein repeats and reiterates each and every
`
`answer heretofore made to Paragraphs “1” through “9” of Plaintiffs’ Verified Complaint.
`
`10.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`3 of 40
`
`

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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
` 12.
`
` Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`4 of 40
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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`16.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`5 of 40
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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`20.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
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`6 of 40
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`

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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`25.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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.
`
`26.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`7 of 40
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`

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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`29.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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.
`
`30.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`8 of 40
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`

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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`33.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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.
`
`34.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , herein repeats and reiterates each and every
`
`answer heretofore made to Paragraphs “1” through “35” of Plaintiffs’ Verified Complaint.
`
` {N1406053-1}
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`9 of 40
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`

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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`36.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
`38.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , herein repeats and reiterates each and every
`
`answer heretofore made to Paragraphs “1” through “39” of Plaintiffs’ Verified Complaint.
`
` {N1406053-1}
`
`10 of 40
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`

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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`40.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
`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, ZENITH ELECTRONICS, LLC , herein repeats and reiterates each and every
`
`answer heretofore made to Paragraphs “1” through “41” of Plaintiffs’ Verified Complaint.
`
`42.
`
`Defendant, ZENITH ELECTRONICS, LLC , herein repeats and reiterates each and
`
`every answer heretofore made to Paragraphs “1” through “41” of Plaintiffs’ Verified Complaint.
`
`43.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`11 of 40
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`

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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`44. Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
`46.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`12 of 40
`
`

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`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`48.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
`50.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , denies each and every allegation
`
`contained in Paragraph “51” 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.
`
` {N1406053-1}
`
`13 of 40
`
`

`

`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`52.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
`54.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`14 of 40
`
`

`

`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`56.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
`59.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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.
`
` {N1406053-1}
`
`15 of 40
`
`

`

`FILED: NEW YORK COUNTY CLERK 03/04/2024 09:39 AM
`NYSCEF DOC. NO. 55
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 03/04/2024
`
`60.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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, ZENITH ELECTRONICS, LLC , 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.
`
`63.
`
`Defendant, ZENITH ELECTRONICS, LLC , 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 inf