`NYSCEF DOC. NO. 106
`
`INDEX NO. 190007/2020
`
`RECEIVED NYSCEF: 02/05/2020
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`--------------------------------------------------------------------------X
`
`WILLIAM MORELLI JR., as Proposed Executor for the
`Estate of WILLIAM MORELLI, SR.,
`
`Plaintiff(s),
`
`
`
`- against -
`
`
`
`A.O. SMITH WATER PRODUCTS CO., et al.,
`
`Defendants.
`--------------------------------------------------------------------------X
`
`Index No. 190007/2020
`
`ANSWER WITH
`CROSS-CLAIMS
`
`Defendant, BMCE, Inc. by its attorneys, Marshall Dennehey Warner Coleman & Goggin, hereby
`acknowledges receipt of a summons and a copy of plaintiff(s) verified complaint in this action.
`
`Defendant, BMCE, Inc., denies knowledge and information sufficient to form a belief as to
`1.
`the truth of the allegations contained in paragraphs "1" through “3” of the verified complaint.
`
`Defendant, BMCE, Inc., denies knowledge and information sufficient to form a belief as to
`2.
`the truth of the allegations contained in paragraphs "4" through "50" of the verified complaint which
`pertain to other defendants.
`
`Defendant, BMCE, Inc., hereby further answers the verified complaint in this action by reference
`to its corresponding Standard Answer, as supplemented and amended, filed pursuant to NYCAL Case
`Management Order and raises each of the affirmative defenses and cross-claims contained in its
`corresponding Standard Answer.
`
`Dated: Melville, New York
`February 5, 2020
`
`Yours, etc.
`
`MARSHALL DENNEHEY WARNER
`COLEMAN & GOGGIN
`
`By: Anna M. DiLonardo
`Anna M. DiLonardo
`Attorneys for Defendant
`BMCE, Inc.
`105 Maxess Road, Suite 303
`Melville, New York 11747
`(631) 232-6130
`
`1 of 4
`
`
`
`FILED: NEW YORK COUNTY CLERK 02/05/2020 06:38 PM
`NYSCEF DOC. NO. 106
`
`INDEX NO. 190007/2020
`
`RECEIVED NYSCEF: 02/05/2020
`
`TO:
`
`WEITZ & LUXENBERG, P.C.
`Attorneys for Plaintiffs
`
`ALL DEFENSE COUNSEL TO RECORD
`Via the Court's ECF System
`
`~ 2 ~
`
`2 of 4
`
`
`
`FILED: NEW YORK COUNTY CLERK 02/05/2020 06:38 PM
`NYSCEF DOC. NO. 106
`
`INDEX NO. 190007/2020
`
`RECEIVED NYSCEF: 02/05/2020
`
`ATTORNEY VERIFICATION
`
`ANNA M. DILONARDO, the undersigned, an attorney duly admitted to practice law before all the
`
`Courts of the State of New York, a member of the firm, MARSHALL DENNEHEY WARNER COLEMAN
`
`& GOGGIN, attorneys for the defendant, BMCE, Inc., in the within action states that she has read the
`
`contents of the foregoing Answer with Cross-Claims and that the same is true to her knowledge except
`
`as to the matters, stated upon information and belief, she believes them to be true. Deponent further
`
`says that the grounds for her belief, as to all matters therein not stated upon her own knowledge, are
`
`investigations and reports which have been made concerning the subject matter of the within action,
`
`which are in possession of the aforementioned Attorneys-of-Record and with which Deponent is familiar.
`
`The reason this Verification is made by Deponent, instead of by the aforementioned Defendant, is
`
`because said Defendant is not within the County of Suffolk where Deponents and the aforementioned
`
`Attorneys-of-Record have their office. The undersigned affirms that the foregoing statements are true,
`
`under penalties of perjury.
`
`Dated: Melville, New York
`February 5, 2020
`
`Anna M. DiLonardo
`ANNA M. DILONARDO
`
`~ 3 ~
`
`3 of 4
`
`
`
`FILED: NEW YORK COUNTY CLERK 02/05/2020 06:38 PM
`NYSCEF DOC. NO. 106
`
`INDEX NO. 190007/2020
`
`RECEIVED NYSCEF: 02/05/2020
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that on the 5th day of February, 2020, a copy of the foregoing Answer
`with Cross-Claims was filed electronically this day and is available for viewing from the Court’s
`ECF system. Notice of this filing will be sent to all counsel of record via the Court’s ECF system.
`
`Anna M. DiLonardo
`Anna M. DiLonardo
`
`~ 4 ~
`
`4 of 4
`
`
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