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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF ORANGENINTH JUDICIAL DISTRICT ENVIORONMENTAL CLAIMS PART- - - - - - - - - - - - - - - - - - - -XVILLAGE OF SOUTH BLOOMING GROVE, et

al. ,

Petitioners,

For a Judgment Pursuant to Article 78of the Civil Practice Law and Rules

- against

VILLAGE OF KIRYAS JOEL BOARD OFTRUSTEES, et al.

Index No. 7410/2015Proceeding No. 1

Hon. Francesca E.Connolly

Respondents,

EMANUEL LEONOROVITZ, et al.

Additional Respondents.

- - - - - - - - - - - - - - - - - - - -XPRESERVE HUDSON VALLEY, et al. Index No. 8118/2015

Proceeding No. 2

Petitioners,

- against

TOWN BOARD OF THE TOWN OF MONROE, et al.

Respondents/Defendants.

- - - - - - - - - - - - - - - - - - - -X

VERIFIED ANSWER TO AMENDED VERIFIED PETITION AND COMPLAINT OF

PETITIONERS/PLAINTIFFS IN PROCEEDING NO. 2

Respondents-Defendants, Town Board of the Town of Monroe and

Town of Monroe, by their attorneys, DICKOVER. DONNELLY &

DONOVAN, LLP, respectfully submit the foregoing Verified Answer

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to the Amended Verified Petition and Complaint filed by

Petitioners-Plaintiffs Preserve Hudson Valley, et al. in

Proceeding No. 2 (the PHV Petitioner):

1.With respect to the allegations set forth in Paragraph 1 of

the PHV Petition, including subparagraphs (i) through (vii)

thereof, the Town admits that Petitioners seek the relief

specified therein, but denies that Petitioners are entitled

thereto.

2.With respect to the allegations set forth in Paragraph 2 of

the PHV Petition, the Town states that such allegations set

forth conclusions of law for which no responsive pleading is

required.

3.The Town admits the allegations set forth in Paragraph 3 of

the PHV Petition, except lacks knowledge or information

sufficient to form a belief as to the identity of the Town

Council and denies that the Village sought annexation of any

territory that is the subject of the 164-acre annexation

petition.

4.With respect to the allegations set forth in Paragraph 4 of

the PHV Petition, the Town states that such allegations set

forth conclusions of law for which no responsive pleading is

required, but to the extent an answer is made, the Town denies

Petitioners characterization thereof and further states as

follows:

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a.The allegations entitled Violation of the

Establishment Clause set forth conclusions of law for

which no responsive pleading is required, but to the

extent an answer is made, the Town refers the Court to

the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and

denies Petitioners characterizations thereof.

b.The allegations entitled Arbitrary Designation of

Village Board as Lead Agency set forth conclusions of

law for which no responsive pleading is required, but

to the extent an answer is made, the Town refers the

Court to the statutes and/or regulations referenced

therein for determination of their content, meaning and

effect, and denies Petitioners characterizations

thereof.

c.The allegations entitled Arbitrary and Capricious

SEQRA Determination By Village Board set forth

conclusions of law for which no responsive pleading is

required, but to the extent an answer is made, the Town

refers the Court to the statutes and/or regulations

referenced therein for determination of their content,

meaning and effect, and denies Petitioners

characterizations thereof.

d.The allegations entitled Arbitrary and Capricious

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Determination By Village Board set forth conclusions

of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers

the Court to the statutes and/or regulations referenced

therein for determination of their content, meaning and

effect, and denies Petitioners characterizations

thereof.

e.The allegations entitled Improper Use of Annexation to

Up-Zone set forth conclusions of law for which no

responsive pleading is required, but to the extent an

answer is made, the Town denies the allegations.

f.The allegations entitled Improper Creation of

Baroque Boundaries set forth conclusions of law for

which no responsive pleading is required, but to the

extent an answer is made, the Town refers the Court to

the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and

denies Petitioners characterizations thereof.

g.The allegations entitled Violation of Town Ethics

Code set forth conclusions of law for which no

responsive pleading is required, but to the extent an

answer is made, the Town lacks knowledge or information

sufficient to form a belief as to the truth of the

allegations set forth.

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h.The allegations entitled Insufficient Signatures and

Territorial Description set forth conclusions of law

for which no responsive pleading is required, but to

the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein

for determination of their content, meaning and effect,

and denies Petitioners characterizations thereof.

i.The allegations entitled Violation of Prior

Jurisdiction Rule set forth conclusions of law for

which no responsive pleading is required, but to the

extent any answer is made, the Town refers the Court to

the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and

denies Petitioners characterizations thereof.

5.The Town denies the allegations set forth in Paragraph 5 of

the PHV Petition.

6.With respect to the allegations in Paragraph 6 of the PHV

Petition, the Town lacks knowledge or information sufficient to

form a belief as to the truth of the allegations set forth.

7.The Town denies the allegations in Paragraph 7 of the PHV

Petition.

8.The Town denies the allegations in Paragraph 8 of the PHV

Petition.

9.The Town denies the allegations in Paragraph 9 of the PHV

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Petition.

10. With respect to the allegations in Paragraph 10 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent and answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

11. With respect to the allegations in Paragraph 11 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations set forth.

12. With respect to the allegations in Paragraph 12 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations set forth.

13. The Town denies the allegations in Paragraph 13 of the

PHV Petition.

14. The Town denies the allegations in Paragraph 14 of the

PHV Petition.

15. With respect to the allegations in Paragraph 15 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations that

Petitioner Allegro has a daughter, and otherwise denies the

allegations in Paragraph 15.

16. With respect to the allegations in Paragraph 16 of the

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PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations set forth.

17. With respect to the allegations in Paragraph 17 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations that

Petitioner Convers is in Orange County Sewer District #1, and

otherwise denies the allegations set forth in Paragraph 17.

18. With respect to the allegations in Paragraph 18 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations that

Petitioner Convers has two sons who attend MWCSD public schools,

and otherwise denies the allegations in Paragraph 18.

19. With respect to the allegations in Paragraph 19 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

20. With respect to the allegations in Paragraph 20 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

21. The Town denies the allegations in Paragraph 21 of the

PHV Petition.

22. With respect to the allegations in Paragraph 22 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

23. With respect to the allegations in Paragraph 23 of the

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PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

24. With respect to the allegations in Paragraph 24 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

25. The Town admits the allegations in Paragraph 25 of the

PHV Petition.

26. With respect to the allegations in Paragraph 26 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

27. With respect to the allegations in Paragraph 27 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

28. With respect to the allegations in Paragraph 28 of the

PHV Petition, the Town admits that the DEC Commissioner

designated the Village as lead agency for the 507-acre

annexation petition.

29. With respect to the allegations in Paragraph 29 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

30. With respect to the allegations set forth in Paragraph 30

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

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sufficient to form a belief as to the truth of the allegations.

31. With respect to the allegations set forth in Paragraph 31

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

32. With respect to the allegations set forth in Paragraph 32

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

33. With respect to the allegations set forth in Paragraph 33

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

34. With respect to the allegations set forth in Paragraph 34

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

35. With respect to the allegations set forth in Paragraph 35

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

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and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

36. With respect to the allegations set forth in Paragraph 36

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

37. With respect to the allegations set forth in Paragraph 37

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

38. With respect to the allegations set forth in Paragraph 38

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

39. With respect to the allegations set forth in Paragraph 39

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

40. With respect to the allegations set forth in Paragraph 40

of the PHV Petition, the Town refers the Court to the documents

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referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

41. With respect to the allegations set forth in Paragraph 41

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

42. With respect to the allegations set forth in Paragraph 42

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

43. With respect to the allegations set forth in Paragraph 43

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

44. With respect to the allegations set forth in Paragraph 44

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

45. With respect to the allegations set forth in Paragraph 45

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of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

46. With respect to the allegations set forth in Paragraph 46

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

47. With respect to the allegations set forth in Paragraph 47

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

48. With respect to the allegations set forth in Paragraph 48

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

49. With respect to the allegations set forth in Paragraph 49

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

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50. With respect to the allegations set forth in Paragraph 50

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

51. With respect to the allegations set forth in Paragraph 51

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

52. With respect to the allegations set forth in Paragraph 52

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

53. With respect to the allegations set forth in Paragraph 53

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

54. With respect to the allegations set forth in Paragraph 54

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

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sufficient to form a belief as to the truth of the allegations.

55. With respect to the allegations set forth in Paragraph 55

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

56. With respect to the allegations set forth in Paragraph 56

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

57. With respect to the allegations set forth in Paragraph 57

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

58. With respect to the allegations set forth in Paragraph 58

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

59. With respect to the allegations set forth in Paragraph 59

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

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and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

60. With respect to the allegations set forth in Paragraph 60

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

61. With respect to the allegations set forth in Paragraph 61

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

62. With respect to the allegations set forth in Paragraph 62

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

63. With respect to the allegations set forth in Paragraph 63

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

64. With respect to the allegations set forth in Paragraph 64

of the PHV Petition, the Town refers the Court to the documents

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referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

65. With respect to the allegations set forth in Paragraph 65

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

66. With respect to the allegations set forth in Paragraph 66

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

67. With respect to the allegations set forth in Paragraph 67

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

68. With respect to the allegations set forth in Paragraph 68

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

69. With respect to the allegations set forth in Paragraph 69

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of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

70. With respect to the allegations set forth in Paragraph 70

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

71. With respect to the allegations set forth in Paragraph 71

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

72. With respect to the allegations set forth in Paragraph 72

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

73. With respect to the allegations set forth in Paragraph 73

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

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74. With respect to the allegations set forth in Paragraph 74

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

75. With respect to the allegations set forth in Paragraph 75

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

76. With respect to the allegations set forth in Paragraph 76

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

77. With respect to the allegations set forth in Paragraph 77

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

78. With respect to the allegations set forth in Paragraph 78

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

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sufficient to form a belief as to the truth of the allegations.

79. With respect to the allegations set forth in Paragraph 79

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

80. With respect to the allegations set forth in Paragraph 80

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

81. With respect to the allegations set forth in Paragraph 81

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

82. With respect to the allegations set forth in Paragraph 82

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

83. With respect to the allegations set forth in Paragraph 83

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

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and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

84. With respect to the allegations set forth in Paragraph 84

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

85. With respect to the allegations set forth in Paragraph 85

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

86. With respect to the allegations set forth in Paragraph 86

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

87. With respect to the allegations set forth in Paragraph 87

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

88. With respect to the allegations set forth in Paragraph 88

of the PHV Petition, the Town refers the Court to the documents

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referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

89. With respect to the allegations set forth in Paragraph 89

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

90. With respect to the allegations set forth in Paragraph 90

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

91. With respect to the allegations set forth in Paragraph 91

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

92. With respect to the allegations set forth in Paragraph 92

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

93. With respect to the allegations set forth in Paragraph 93

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of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

94. With respect to the allegations set forth in Paragraph 94

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

95. With respect to the allegations set forth in Paragraph 95

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

96. With respect to the allegations set forth in Paragraph 96

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

97. With respect to the allegations set forth in Paragraph 97

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

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98. With respect to the allegations set forth in Paragraph 98

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

99. With respect to the allegations set forth in Paragraph 99

of the PHV Petition, the Town refers the Court to the documents

referenced therein for determination of their content, meaning

and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

100.With respect to the allegations set forth in Paragraph

100 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

101.With respect to the allegations set forth in Paragraph

101 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

102.With respect to the allegations set forth in Paragraph

102 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

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sufficient to form a belief as to the truth of the allegations.

103.With respect to the allegations set forth in Paragraph

103 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

104.With respect to the allegations set forth in Paragraph

104 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

105.With respect to the allegations set forth in Paragraph

105 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

106.With respect to the allegations set forth in Paragraph

106 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

107.With respect to the allegations set forth in Paragraph

107 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

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meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

108.With respect to the allegations set forth in Paragraph

108 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

109.With respect to the allegations set forth in Paragraph

109 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

110.With respect to the allegations set forth in Paragraph

110 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

111.With respect to the allegations set forth in Paragraph

111 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

112.With respect to the allegations set forth in Paragraph

112 of the PHV Petition, the Town refers the Court to the

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documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

113.With respect to the allegations set forth in Paragraph

113 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

114.With respect to the allegations set forth in Paragraph

114 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

115.With respect to the allegations set forth in Paragraph

115 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

116.With respect to the allegations set forth in Paragraph

116 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

117.With respect to the allegations set forth in Paragraph

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117 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

118.With respect to the allegations set forth in Paragraph

118 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

119.With respect to the allegations set forth in Paragraph

119 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

120.With respect to the allegations set forth in Paragraph

120 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

121.With respect to the allegations set forth in Paragraph

121 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

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122.With respect to the allegations set forth in Paragraph

122 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

123.With respect to the allegations set forth in Paragraph

123 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

124.With respect to the allegations set forth in Paragraph

124 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

125.With respect to the allegations set forth in Paragraph

125 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

126.With respect to the allegations set forth in Paragraph

126 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

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sufficient to form a belief as to the truth of the allegations.

127.With respect to the allegations set forth in Paragraph

127 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

128.With respect to the allegations set forth in Paragraph

128 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

129.With respect to the allegations set forth in Paragraph

129 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

130.With respect to the allegations set forth in Paragraph

130 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

131.With respect to the allegations set forth in Paragraph

131 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

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meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

132.With respect to the allegations set forth in Paragraph

132 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

133.With respect to the allegations set forth in Paragraph

133 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

134.With respect to the allegations set forth in Paragraph

134 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

135.With respect to the allegations set forth in Paragraph

135 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

136.With respect to the allegations set forth in Paragraph

136 of the PHV Petition, the Town refers the Court to the

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documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

137.With respect to the allegations set forth in Paragraph

137 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

138.With respect to the allegations set forth in Paragraph

138 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

139.With respect to the allegations set forth in Paragraph

139 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

140.With respect to the allegations set forth in Paragraph

140 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

141.With respect to the allegations set forth in Paragraph

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141 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

142.The allegations in Paragraph 142 of the PHV Petition set

forth conclusions of law for which no responsive pleading is

required, but to the extent an answer is made, the Town refers

the Court to the statutes and/or regulations referenced therein

for determination of their content, meaning and effect, and

denies Petitioners characterizations thereof.

143.The allegations in Paragraph 143 of the PHV Petition set

forth conclusions of law for which no responsive pleading is

required, but to the extent an answer is made, the Town refers

the Court to the statutes and/or regulations referenced therein

for determination of their content, meaning and effect, and

denies Petitioners characterizations thereof.

144.The Town denies the allegations set forth in Paragraph

144 of the PHV Petition.

145.The Towndenies the allegations set forth in Paragraph 145

of the PHV Petition.

146.With respect to the allegations in Paragraph 146 of the

PHV Petition, the Town acks knowledge or information sufficient

to form a belief as to the truth of the allegations.

147.With respect to the allegations in Paragraph 147 of the

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PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

148.With respect to the allegations in Paragraph 148 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

149.The Town denies the allegations set forth in Paragraph

149 of the PHV Petition.

150.With respect to the allegations in Paragraph 150 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

151.With respect to the allegations in Paragraph 151 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

152.With respect to the allegations in Paragraph 152 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

153.With respect to the allegations in Paragraph 153 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations.

154.The Town denies the allegations set forth in Paragraph

154 of the PHV Petition.

155.The Town denies the allegations set forth in Paragraph

155 of the PHV Petition.

156.With respect to the allegations set forth in Paragraph

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156 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

157.With respect to the allegations set forth in Paragraph

157 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

158.The Town denies the allegations set forth in Paragraph

158 of the PHV Petition.

159.The Town denies the allegations set forth in Paragraph

159 of the PHV Petition.

160.The Town denies the allegations set forth in Paragraph

160 of the PHV Petition.

161.With respect to the allegations set forth in Paragraph

161 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

162.The Town denies the allegations set forth in Paragraph

162 of the PHV Petition.

163.The Town denies the allegations set forth in Paragraph

163 of the PHV Petition.

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164.The Town denies the allegations set forth in Paragraph

164 of the PHV Petition.

165.The Town denies the allegations set forth in Paragraph

165 of the PHV Petition.

166.The Town denies the allegations set forth in Paragraph

166 of the PHV Petition.

167.The Town denies the allegations set forth in Paragraph

167 of the PHV Petition.

168.With respect to the allegations set forth in Paragraph

168 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

169.The Town denies the allegations set forth in Paragraph

169 of the PHV Petition.

170.With respect to the allegations set forth in Paragraph

170 of the PHV Petition, the Town admits that the Monroe-

Woodbury Central School District submitted comments on the 507

Petition, but denies their validity and any allegations made

therein.

171.The Town denies the allegations set forth in Paragraph

171 of the PHV Petition.

172.The Town denies the allegations set forth in Paragraph

172 of the PHV Petition.

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173.With respect to the allegations set forth in Paragraph

173 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect.

174.The Town denies the allegations set forth in Paragraph

174 of the PHV Petition.

175.The Town denies the allegations set forth in Paragraph

175 of the PHV Petition.

176.The Town denies the allegations set forth in Paragraph

176 of the PHV Petition.

177.The Town denies the allegations set forth in Paragraph

177 of the PHV Petition.

178.The Town denies the allegations set forth in Paragraph

178 of the PHV Petition.

179.The Town denies the allegations set forth in Paragraph

179 of the PHV Petition.

180.The Town admits the allegations set forth in Paragraph

180 of the PHV Petition.

181.The Town admits the allegations set forth in Paragraph

181 of the PHV Petition.

182.The Town admits the allegations set forth in Paragraph

182 of the PHV Petition.

183.The Town denies the allegations set forth in Paragraph

183 of the PHV Petition.

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184.The Town denies the allegations set forth in Paragraph

184 of the PHV Petition.

185.The Town denies the allegations set forth in Paragraph

185 of the PHV Petition.

186.The Town denies the allegations set forth in Paragraph

186 of the PHV Petition.

187.The Town denies the allegations set forth in Paragraph

187 of the PHV Petition.

188.With respect to the allegations set forth in Paragraph

188 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

189.With respect to the allegations set forth in Paragraph

161 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

190.The Town denies the allegations set forth in Paragraph

190 of the PHV Petition.

191.The Town denies the allegations set forth in Paragraph

191 of the PHV Petition.

192.The Town denies the allegations set forth in Paragraph

192 of the PHV Petition.

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193.With respect to the allegations set forth in Paragraph

193 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

194.The Town denies the allegations set forth in Paragraph

194 of the PHV Petition.

195.The Town denies the allegations set forth in Paragraph

195 of the PHV Petition.

196.The Town denies the allegations set forth in Paragraph

196 of the PHV Petition.

197.With respect to the allegations set forth in Paragraph

193 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

198.The Town denies the allegations set forth in Paragraph

198 of the PHV Petition.

199.The Town denies the allegations set forth in Paragraph

199 of the PHV Petition.

200.The Town admits the allegations set forth in Paragraph

200 of the PHV Petition.

201.The Town admits the allegations set forth in Paragraph

201 of the PHV Petition.

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202.With respect to the allegations set forth in Paragraph

202 of the PHV Petition, the Town admits that the 164 Petition

was filed, but lacks knowledge or information sufficient to form

a belief as to the truth of the allegations as to the intent of

the 164 Petition.

203.The Town denies the allegations set forth in Paragraph

203 of the PHV Petition.

204.The Town denies the allegations set forth in Paragraph

204 of the PHV Petition.

205.The Town denies the allegations set forth in Paragraph

205 of the PHV Petition.

206.The Town denies the allegations set forth in Paragraph

206 of the PHV Petition.

207.With respect to the allegations set forth in Paragraph

207 of the PHV Petition, the Town admits that the MWCSD

submitted comments on the 164 Petition, but denies their

validity.

208.The Town denies the allegations set forth in Paragraph

208 of the PHV Petition.

209.The Town denies the allegations set forth in Paragraph

209 of the PHV Petition.

210.With respect to the allegations set forth in Paragraph

210 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

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meaning and effect and denies Petitioners characterization

thereof.

211.The Town denies the allegations set forth in Paragraph

211 of the PHV Petition.

212.The Town denies the allegations set forth in Paragraph

212 of the PHV Petition.

213.The Town denies the allegations set forth in Paragraph

213 of the PHV Petition.

214.The Town denies the allegations set forth in Paragraph

214 of the PHV Petition.

215.With respect to the allegations set forth in Paragraph

215 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and otherwise lacks knowledge or information

sufficient to form a belief as to the truth of the allegations

related to the content of the 2014 Final Town Assessment Roll.

216.With respect to the allegations set forth in Paragraph

216 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

217.With respect to the allegations set forth in Paragraph

217 of the PHV Petition, the Town admits that Bakertown Realty

Equities and the Jacob Bandua Trust do not appear to own SBL 1-

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3-1.3, but denies that their names and signatures should be

stricken from the 164 Petition.

218.The Town admits the allegations set forth in Paragraph

218 of the PHV Petition.

219.The Town admits the allegations set forth in Paragraph

219 of the PHV Petition.

220.The Town denies the allegations set forth in Paragraph

220 of the PHV Petition.

221.The Town denies the allegations set forth in Paragraph

221 of the PHV Petition.

222.The Town denies the allegations set forth in Paragraph

222 of the PHV Petition.

223.The Town denies the allegations set forth in Paragraph

223 of the PHV Petition.

224.The Town denies the allegations set forth in Paragraph

224 of the PHV Petition.

225.With respect to the allegations set forth in Paragraph

225 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

226.With respect to the allegations set forth in Paragraph

226 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

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meaning and effect and denies Petitioners characterization

thereof.

227.With respect to the allegations set forth in Paragraph

227 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

228.With respect to the allegations set forth in Paragraph

228 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

229.The Town denies the allegations set forth in Paragraph

229 of the PHV Petition.

230.The Town denies the allegations set forth in Paragraph

230 of the PHV Petition.

231.The Town denies the allegations set forth in Paragraph

231 of the PHV Petition.

232.The Town denies the allegations set forth in Paragraph

232 of the PHV Petition.

233.The Town denies the allegations set forth in Paragraph

233 of the PHV Petition.

234.With respect to the allegations set forth in Paragraph

234 of the PHV Petition, the Town lacks knowledge or information

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sufficient to form a belief as to the truth of the allegations

related to a letter from United Monroe, and denies that the

proposed annexation would violate the Establishment Clause.

235.With respect to the allegations in Paragraph 235 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

236.With respect to the allegations in Paragraph 236 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

237.With respect to the allegations in Paragraph 237 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

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238.With respect to the allegations in Paragraph 238 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

239.With respect to the allegations in Paragraph 239 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

240.With respect to the allegations in Paragraph 240 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

241.With respect to the allegations in Paragraph 241 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

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but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

242.With respect to the allegations in Paragraph 242 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

243.With respect to the allegations in Paragraph 243 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

244.The Town denies the allegations set forth in Paragraph

244 of the PHV Petition.

245.The Town denies the allegations set forth in Paragraph

245 of the PHV Petition.

246.The Town denies the allegations set forth in Paragraph

246 of the PHV Petition.

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247.With respect to the allegations set forth in Paragraph

247 of the PHV Petition, the Town admits that PHV has filed

pending litigation challenging DECs lead agency determination.

248.The Town denies the allegations set forth in Paragraph

248 of the PHV Petition.

249.The Town denies the allegations set forth in Paragraph

249 of the PHV Petition.

250.The Town denies the allegations set forth in Paragraph

250 of the PHV Petition.

251.The Town denies the allegations set forth in Paragraph

251 of the PHV Petition.

252.The Town denies the allegations set forth in Paragraph

252 of the PHV Petition.

253.With respect to the allegations set forth in Paragraph

253 of the PHV Petition, the Town lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

254.With respect to the allegations set forth in Paragraph

254 of the PHV Petition, the Town lacks knowledge or information

sufficient to form a belief as to the truth of the allegations.

255.The Town denies the allegations set forth in Paragraph

255 of the PHV Petition.

256.With respect to the allegations set forth in Paragraph

256 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

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meaning and effect and denies Petitioners characterization

thereof.

257.With respect to the allegations set forth in Paragraph

257 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

258.With respect to the allegations set forth in Paragraph

258 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

259.With respect to the allegations set forth in Paragraph

259 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

260.The Town denies the allegations set forth in Paragraph

260 of the PHV Petition.

261.The Town denies the allegations set forth in Paragraph

261 of the PHV Petition.

262.With respect to the allegations set forth in Paragraph

262 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

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meaning and effect and denies Petitioners characterization

thereof.

263.With respect to the allegations set forth in Paragraph

263 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

264.With respect to the allegations set forth in Paragraph

264 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

265.With respect to the allegations set forth in Paragraph

265 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

266.With respect to the allegations set forth in Paragraph

266 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

267.With respect to the allegations set forth in Paragraph

267 of the PHV Petition, the Town refers the Court to the

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documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

268.With respect to the allegations set forth in Paragraph

268 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

269.With respect to the allegations set forth in Paragraph

269 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

270.With respect to the allegations set forth in Paragraph

270 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

271.With respect to the allegations set forth in Paragraph

271 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

272.With respect to the allegations set forth in Paragraph

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272 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

273.With respect to the allegations set forth in Paragraph

273 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

274.With respect to the allegations set forth in Paragraph

274 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

275.With respect to the allegations set forth in Paragraph

275 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

276.With respect to the allegations set forth in Paragraph

276 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

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277.With respect to the allegations set forth in Paragraph

277 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

278.With respect to the allegations set forth in Paragraph

278 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

279.With respect to the allegations set forth in Paragraph

279 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

280.With respect to the allegations set forth in Paragraph

280 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect, denies Petitioners characterization

thereof, and admits that review was adequate for the 164

Petition.

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AS AND FOR AN ANSWER TO THE FIRST CAUSE OF

ACTION

281.With respect to the allegations incorporated by reference

in Paragraph 281 of the PHV Petition, the Town refers to its

responses to those allegations set forth above.

282.The Town denies the allegations set forth in Paragraph

282 of the PHV Petition.

283.The Town denies the allegations set forth in Paragraph

283 of the PHV Petition.

284.The Town denies the allegations set forth in Paragraph

284 of the PHV Petition.

285.The Town denies the allegations set forth in Paragraph

285 of the PHV Petition.

286.The Town denies the allegations set forth in Paragraph

286 of the PHV Petition.

287.The Town denies the allegations set forth in Paragraph

287 of the PHV Petition.

288.With respect to the allegations set forth in Paragraph

288 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

289.The Town denies the allegations set forth in Paragraph

289 of the PHV Petition.

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290.With respect to the allegations set forth in Paragraph

290 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

291.The Town denies the allegations set forth in Paragraph

291 of the PHV Petition.

292.The Town denies the allegations set forth in Paragraph

292 of the PHV Petition.

293.The Town denies the allegations set forth in Paragraph

293 of the PHV Petition.

AS AND FOR AN ANSWER TO THE SECOND CAUSE OF

ACTION

294.With respect to the allegations incorporated by reference

in Paragraph 294 of the PHV Petition, the Town refers to its

responses to those allegations set forth above.

295.With respect to the allegations in Paragraph 295 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect and denies

Petitioners characterization thereof.

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296.With respect to the allegations in Paragraph 296 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

297.The Town denies the allegations set forth in Paragraph

297 of the PHV Petition.

AS AND FOR AN ANSWER TO THE THIRD CAUSE OF

ACTION

298.With respect to the allegations incorporated by reference

in Paragraph 298 of the PHV Petition, the Town refers to its

responses to those allegations set forth above.

299.With respect to the allegations in Paragraph 299 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

300.With respect to the allegations in Paragraph 300 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

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but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

301.With respect to the allegations in Paragraph 301 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

302.With respect to the allegations in Paragraph 302 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

303.With respect to the allegations set forth in Paragraph

303 of the PHV Petition, the Town admits that the Petitioners

have alleged violations of the Establishment Clause but denies

the validity of these allegations.

304.The Town denies the allegations set forth in Paragraph

304 of the PHV Petition.

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305.The Town denies the allegations set forth in Paragraph

305 of the PHV Petition.

306.The Town denies the allegations set forth in Paragraph

306 of the PHV Petition.

307.The Town denies the allegations set forth in Paragraph

307 of the PHV Petition.

308.The Town denies the allegations set forth in Paragraph

308 of the PHV Petition.

309.With respect to the allegations in Paragraph 309 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

310.The Town denies the allegations set forth in Paragraph

310 of the PHV Petition.

311.With respect to the allegations set forth in Paragraph

311 of the PHV Petition, the Town admits Petitioners have made

this request, but denies their entitlement to it and denies

Petitioners characterization thereof

312.With respect to the allegations in Paragraph 312 of the

PHV Petition, the Town states that such allegations set forth

conclusions of law for which no responsive pleading is required,

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but to the extent an answer is made, the Town refers the Court

to the statutes and/or regulations referenced therein for

determination of their content, meaning and effect, and denies

Petitioners characterizations thereof.

AS AND FOR AN ANSWER TO THE FOURTH CAUSE OF

ACTION

313.With respect to the allegations incorporated by reference

in the first sentence of Paragraph 313 of the PHV Petition, the

Town refers to its responses to those allegations set forth

above. With respect to the second sentence of allegations in

Paragraph 313 of the PHV Petition, the Town states that such

allegations set forth conclusions of law for which no responsive

pleading is required, but to the extent an answer is made, the

Town refers the Court to the statutes and/or regulations

referenced therein for determination of their content, meaning

and effect, and denies Petitioners characterizations thereof.

314.The Town denies the allegations set forth in Paragraph

314 of the PHV Petition.

315.With respect to the allegations set forth in Paragraph

315 of the PHV Petition, the Town refers the Court to the

documents referenced therein for determination of their content,

meaning and effect and denies Petitioners characterization

thereof.

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316.The Town admits the allegations set forth in Paragraph

316 of the PHV Petition.

317.The Town admits the allegations set forth in Paragraph

317 of the PHV Petition.

318.With respect to the allegations in Paragraph 318 of the

PHV Petition, the Town lacks knowledge or information sufficient

to form a belief as to the truth of the allegations set forth.

319.The Town denies the allegations set forth in Paragraph

319 of the PHV Petition.

AS AND FOR AN ANSWER TO THE FOURTH (FIFTH)1

CAUSE OF ACTION

320.With respect to the allegations incorporated by reference

in Paragraph 320 of the PHV Petition, the Town refers to its

responses to those allegations set forth above.

321.With respect to the allegations in Pa