DOES 1-50, and XYZ CORP. 1-50, The names of John and Jane Does 1-50 defendants and XYZ Corp. 1-50 defendants being fictitious and unknown to the plaintiff and represent persons or parties, corporations or entities having an interest in or lien against the premises sought to be foreclosed herein, as owner, licensee, occupant or otherwise.
Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraphs 1, 2, 3, 4, 5, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 68, 70, 71,
Plaintiff has failed to perform conditions precedent required by New York law to maintain a priority over Defendants Judgment Lien.
Attorneys for Defendants, Sheryl Hempel, Byron Blount and Alexander Unger By:_____________________________ Damian L. Albergo
: ) SHERYL HEMPEL, being duly sworn, hereby deposes and says: I am one of the defendants in the above-entitled action; I have read the foregoing Verified Answer to the Verified Amended Complaint and know the contents thereof; that the same is true to my knowledge, except as to the matters therein stated to be alleged upon information and belief, and that as to those matters I believe them to be true.