Denies knowledge and information sufficient to form a belief as to the truth of the allegations set forth in paragraphs 1, 3, 5, 6, 9, 10, 11, 15, 16, 17, 18, 20, 21, 22, 24, 25, 26, 29, 30, 31, 32 and 33 of the Plaintiff’s Verified Complaint.
With regard to the allegations set forth in paragraph 28, USFIC admits that it issued the Bond which, as a written document, is the best evidence of its terms and conditions.
The claims against the Defendants are barred, in whole or in part, to the extent that Plaintiff has failed to mitigate, minimize or avoid any damage it allegedly sustained.
WHEREFORE, Defendant, United States Fire Insurance Company demands that the Plaintiff’s Verified Complaint be dismissed in its entirety, together with such other and further relief as this Honorable Court deems just and proper.
Box 586, Liverpool, NewYork 13088, County of Onondaga; I have read the foregoing AmendedVerified Answer and know the contents thereof and the same is true of myown knowledge except as to matters ss.