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ERIE PAINTING & MAINTENANCE INC. v. ILLINOIS UNION INSURANCE COMPANY Answer to Complaint

ERIE PAINTING & MAINTENANCE INC. v. ILLINOIS UNION INSURANCE COMPANY Answer to Complaint

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Published by: ACELitigationWatch on Aug 06, 2012
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02/02/2013

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UNITED STATES DISTRICT COURTWESTERN DISTRICT OF NEW YORKERIE PAINTING & MAINTENANCE, INC.,Plaintiff,v. Civil No.: 1:09-CV-00940 (WMS)ILLINOIS UNION INSURANCE COMPANY,Defendant.
ANSWER
Defendant, Illinois Union Insurance Company, by its attorneys Hodgson RussLLP, for its answer to plaintiff’s complaint, states as follows:1.
 
Denies knowledge or information sufficient to form a belief as to theallegations contained in paragraph 1 and, therefore, denies the allegations in this paragraph.2.
 
No response is necessary because this paragraph contains a legalconclusion, but to the extent a response is deemed necessary, Illinois Union denies knowledge orinformation sufficient to form a belief as to the allegations contained in paragraph 2.3.
 
Admits that it is domiciled in Illinois, does business in New York, and hasan office at 436 Walnut Street in Philadelphia, Pennsylvania, but denies that 436 Walnut Street,Philadelphia, Pennsylvania is its principal place of business.4.
 
Denies knowledge or information sufficient to form a belief as to theallegations contained in paragraph 4 and, therefore, denies the allegations in this paragraph.5.
 
Denies the allegations contained in paragraph 5.
Case 1:09-cv-00940-WMS-LGF Document 4 Filed 11/09/09 Page 1 of 10
 
- 2 -6.
 
Denies the allegations contained in paragraph 6.7.
 
Denies the allegations contained in paragraph 7.8.
 
No response is necessary because this paragraph contains no factualallegations, but to the extent a response is deemed necessary, denies knowledge or informationsufficient to form a belief as to the allegations contained in paragraph 8.9.
 
No response is necessary because this paragraph contains legalconclusions, but to the extent a response is deemed necessary, Illinois Union denies knowledgeor information sufficient to form a belief as to the allegations contained in paragraph 9.10.
 
Admits that Illinois Union issued a policy bearing number G22066288 04to Plaintiff (the “Illinois Union Policy”), admits that the document speaks for itself, and deniesthe remaining allegations in paragraph 10.11.
 
Denies knowledge or information sufficient to form a belief as to theallegations contained in paragraph 11 and, therefore, denies the allegations in this paragraph.12.
 
Denies knowledge or information sufficient to form a belief as to theallegations contained in paragraph 12 and, therefore, denies the allegations in this paragraph.13.
 
Denies knowledge or information sufficient to form a belief as to theallegations contained in paragraph 13 and, therefore, denies the allegations in this paragraph.14.
 
Denies knowledge or information sufficient to form a belief as to theallegations contained in paragraph 14 and, therefore, denies the allegations in this paragraph.15.
 
Denies knowledge or information sufficient to form a belief as to the
Case 1:09-cv-00940-WMS-LGF Document 4 Filed 11/09/09 Page 2 of 10
 
- 3 -allegations contained in paragraph 15 and, therefore, denies the allegations in this paragraph.16.
 
Admits that the document speaks for itself and denies the remainingallegations in paragraph 16.17.
 
Denies the allegations contained in paragraph 17.18.
 
Denies the allegations contained in paragraph 18.19.
 
Denies the allegations contained in paragraph 19.20.
 
Denies the allegations contained in paragraph 20.21.
 
Denies the allegations contained in paragraph 21.22.
 
Admits that Illinois Union disclaimed coverage for the
 Dovas v. State of  New York 
action (the “Underlying Bodily Injury Action”), admits that the document speaks foritself, and denies the remaining allegations in paragraph 22.23.
 
Admits that the document speaks for itself and denies the remainingallegations in paragraph 23.24.
 
Admits that the document speaks for itself and denies the remainingallegations in paragraph 24.25.
 
Admits that the document speaks for itself and denies the remainingallegations in paragraph 25.26.
 
Admits the allegations contained in paragraph 26.
Case 1:09-cv-00940-WMS-LGF Document 4 Filed 11/09/09 Page 3 of 10

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