Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
Acciona Verified . Answer

Acciona Verified . Answer

Ratings: (0)|Views: 92|Likes:
Published by pandorasboxofrocks
RE: WPEG Article 78
RE: WPEG Article 78

More info:

Published by: pandorasboxofrocks on Jan 10, 2011
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

01/10/2011

pdf

text

original

 
STATE OF NEW YORKSUPREME COURT
OUNTY OF JEFFERSON
WIND POWER ETHICS GROUP,Petitioner-Plaintiff,
- V
S -
PLANNING BOARD OF THE TOWN OF CAPE
VINCENT, and RICHARD EDSALL, TOM RIENBECK,GEORGE MINGLE, ANDREW BINSLEY and KAREN
BOURCY, in their capacities as planning board members
VERIFIED ANSWERAND OBJECTIONSIN POINT OF
LAW/AFFIRMATIVEDEFENSES OF
RESPONDENT-
DEFENDANT ST.
LAWRENCE
WINDPOWER, LLC
Respondents-Defendants,
- and -
ST. LAWRENCE WINDPOWER, LLC,
Respondent-Defendant.
Index No. 10-2882
Respondent-Defendant, St. Lawrence Windpower, LLC (hereinafter
"SLW"), as and for its Verified Answer to the Petition and Complaint, states as follows:
1.
Neither admits nor denies the allegations set forth in paragraph 1
which purports to characterize the nature of this proceeding and do not contain factual
contentions to which a responsive pleading is required.
2.Denies the allegations contained in paragraphs 2, 3, 5, 6 and 7 of the
Petition and Complaint.
3.Denies knowledge or information sufficient to form a belief as to the
allegations contained in paragraph 4 of the Petition and Complaint.
13257148.2
 
- 2
-
PARTIES
4.Denies knowledge or information sufficient to form a belief as to the
allegations contained in paragraph 8 of the Petition and Complaint.
5.
Denies the allegations contained in paragraphs 9 and 12 of the
Petition and Complaint.
6.
Admits the allegations contained in paragraphs 10 and 13.
7.
Admits the allegations contained in paragraph 11 to the extent it
alleges that the listed parties were planning board members at the time of the actions
complained of in the Petition and Complaint, and otherwise denies knowledge or
information sufficient to form a belief as to the remaining allegations contained therein.
VENUE
8.
Neither admits nor denies the allegations contained in paragraph 14
to the extent it attempts to allege the legal basis for the venue of the within combined
Article 78/Declaratory Judgment proceeding.
EXHAUSTION OF ADMINISTRATIVE REMEDIES
9.
Admits the allegations contained in paragraphs 15, 16 and 17 of the
Petition and Complaint.
10.
Admits the allegations contained in paragraph 18 to the extent italleges WPEG and other individuals, agencies and members of the public submittedcomments during the relevant comment periods, and otherwise denies the remaining
allegations contained therein.
13257148.2
 
- 3 -
I I .
dmits the allegations contained in paragraph 19 of the Petition and
Complaint to the extent it alleges that the Cape Vincent Planning board adopted a
Findings Statement pursuant to the provisions of the State Environmental Quality Review
Act ("SEQR"), and otherwise denies the remaining allegations contained therein.
12.Denies knowledge or information sufficient to form a belief as to the
allegations contained in paragraph 20 of the Petition and Complaint.
13.
Neither admits nor denies the allegations contained in paragraph 21
of the Petition and Complaint to the extent it purports to characterize the contents of
documents, and respectfully refers this Court to those documents and/or materials upon
which such allegations are purportedly based for the full terms and effects thereof.
14.
Denies the allegations contained in paragraph 22 of the Petition and
Complaint.
FACTUAL BACKGROUND
15.
Neither admits nor denies the allegations contained in paragraph 23
of the Petition and Complaint, as there are no factual allegations to which a responsive
pleading is required.
16.Denies knowledge or information sufficient to form a belief as to the
allegations contained in paragraphs 24, 25, 28, 30, 34, 38, 39, 40, 53, and 56 of the
Petition and Complaint.
17.
Denies the allegations contained in paragraphs 26, 46 and 50 of the
Petition and Complaint.
13257148.2

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->