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Answer

Answer

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Published by Sergio Hernandez

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Published by: Sergio Hernandez on May 03, 2013
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11/21/2013

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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK
----------------------------------------------------------------------X
Application for a Judgment under Article
78
of
the CPLRand other relief,SERGIO HERNANDEZPetitioner-against-OFFICE OF THE MAYOR OF THE CITY OF NEWYORK,Respondent.
----------------------------------------------------------------------x
Index No. 106216/11lAS Part
16
(Schlesinger,
J.)
VERIFIED ANSWER
Respondent, by and through its attorney, Michael
A.
Cardozo, CorporationCounsel for the City
of
New York,
as
and for its Answer to the Verified Petition herein, allegesas follows:
1.
Denies the allegations contained in paragraph 1
of
the Petition, exceptadmits that Petitioner purports to proceed as set forth therein.
2.
Denies the allegations contained in paragraph 2
of
the Petition, exceptadmits that Petitioner purports to proceed
as
set forth therein.
3.
Denies knowledge or information sufficient
to
form a belief
as
to
the truth
of
the allegations contained in paragraph 3
of
the Petition.
4.
Admits the allegations contained in paragraph 4
of
the Petition.
5.
Denies the allegations contained in paragraph 5
of
the Petition, exceptadmits that Petitioner purportedly sent an e-mail on November
19,
2010 to Anthony Crowell
 
requesting certain records, and respectfully refers the Court to the email annexed
to
the Petition
as
Exhibit A, for a complete and accurate statement
of
its contents.
6.
Admits the allegations contained in paragraph 6
of
the Petition.
7.
Denies the allegations contained in paragraph 7
of
the Petition, exceptadmits that Petitioner purportedly sent an e-mail on January
19,
2011
to Deputy Mayor CarolRobles-Roman purportedly appealing the denial
of
is FOIL request, and that Deputy MayorRobles-Roman denied the appeal by letter dated January 26, 2011, and respectfully refers theCourt to the email dated January
19,
2011
and letter dated letter January 26,2011, annexed
to
thePetition as Exhibits C and D, respectively, for a complete and accurate statement
of
theircontents.
8.
Denies the allegations contained in paragraph 8
of
the Petition.
9.
Makes no response
to
the allegations contained in paragraph 9
of
thePetition, insofar they assert legal conclusions. To the extent a response is required, Respondentdenies the allegations contained therein, and respectfully refers the Court to the statutes citedtherein for a complete and accurate statement
of
their provisions.
10.
Make no response
to
the allegations contained in paragraph
10
of
thePetition, insofar they assert legal conclusions. To the extent a response is required, Respondentdenies the allegations contained therein, except admits that Respondent is located within NewYork County, and that New York County is within the county in which the Respondent made thedetermination complained of, and respectfully refers the Court to the statutes cited therein for acomplete and accurate statement
of
their provisions.
11.
Denies the allegations contained in paragraph
11
of
the Petition, exceptadmits that Petitioner purportedly sent an e-mail on November
19,
2010 to Anthony Crowell-
2-
 
requesting certain records, and respectfully refers the Court to the email annexed
to
the Petition
as
Exhibit A, for a complete and accurate statement
of
its contents.
12.
Denies the allegations contained in paragraph
12
of
the Petition, exceptadmits that Anthony Crowell sent a letter to Petitioner dated January
13,
2011, and respectfullyrefers the Court
to
the letter annexed to the Petition as Exhibit
B,
for a complete and accuratestatement
of
its contents.
13.
Denies the allegations contained in paragraph
13
of
the Petition, exceptadmits that Petitioner purportedly sent an e-mail on January
19, 2011 to
Deputy Mayor CarolRobles-Roman, and respectfully refers the Court
to
that letter, annexed to the Petition
as
Exhibit
C,
for a complete and accurate statement
of
its contents.
14.
Denies the allegations contained in paragraph
14
of
the Petition, exceptadmits that Deputy Mayor Robles-Roman sent Petitioner a letter dated January 26, 2011, andrespectfully refers the Court to that letter, annexed to the Petition
as
Exhibit D, for a completeand accurate statement
of
its contents.
15.
Repeats and realleges each and every response set forth in paragraphs 1through
14
above as
if
set forth fully hereat.
16.
Makes no response to the allegations contained in paragraph
16
of
thePetition, insofar they assert legal conclusions. To the extent a response is required, Respondentdenies the allegations contained therein, and respectfully refers the Court
to
New York'sFreedom
of
Information Law, N.Y. Public Officers Law
§
84, et seq. and the interpretive caselaw thereunder, for a complete and accurate statement
of
their requirements.
17.
Denies the allegations contained in paragraph
17
of
the Petition.
18.
Denies the allegations contained in paragraph
18
of
the Petition.
-3 -

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