SMIGEL, ANDERSON & SACKS, LLP Adam G. Klein, Esquire River Chase Office Center LD. No. 2288 4431 North Front Street, 3rd Floor Randall S. Pajovich, Esquire Harcsbure, PA 17110-1778 1.D. No320821 717) 2542401 Autorneys for Pails MEB PARTNERS, L.P. and BRENNER IN THE COURT OF COMMON PLEAS MOTORS INC., successor in interest to DAUPHIN COUNTY, PENNSYLVANIA BRENSON, INC. Plaintiffs, 8 ; es v. : DOCKET NO. 2018-CV-6929-08 & : 3 CITY OF HARRISBURG, : ie Defendant : CIVIL ACTION - LAW z 9 a e PLAINTIFFS’ RESPONSE TO DEFENDANT’S NEW MATTER 56. Landlord hereby incorporates all facts and allegations as set forth previously. 57. The averment contained in Paragraph 57 is a conclusion of law for which no response is necessary. To the extent a response is necessary, itis specifically denied. 58. The averment contained in Paragraph 58 is a conclusion of law for which no response is necessary. To the extent a response is necessary, itis specifically denied. 59. The averment contained in Paragraph 59 is a conclusion of law for which no response is necessary. To the extent a response is necessary, it is specifically denied. 60. The averment contained in Paragraph 60 is a conclusion of law for which no response is necessary. To the extent a response is necessary, itis specifically denied. 61. The averment contained in Paragraph 61 is a conclusion of law for which no response is necessary. To the extent a response is necessary, itis specifically denied.62. The averment contained in Paragraph 62 is a conclusion of law for response is necessary. To the extent a response is necessary, itis specifically denied. 63. The averment contained in Paragraph 63 is a conclusion of law for response is necessary. To the extent a response is necessary, itis specifically denied. 64, The averment contained in Paragraph 64 is a conclusion of law for response is necessary. To the extent a response is necessary, it is specifically denied, 65. The averment contained in Paragraph 65 is a conclusion of law for response is necessary. ‘To the extent a response is necessary, itis specifically denied. 66. The averment contained in Paragraph 66 is a conclusion of law for response is necessary. To the extent a response is necessary, itis specifically denied. 67. The averment contained in Paragraph 67 is a conclusion of law for response is necessary. To the extent a response is necessary, it is specifically denied. 68. ‘The averment contained in Paragraph 68 is a conclusion of law for response is necessary. To the extent a response is necessary, itis specifically denied. 69. ‘The averment contained in Paragraph 69 is a conclusion of law for response is necessary. To the extent a response is necessary, itis specifically denied. 70. ‘The averment contained in Paragraph 70 is a conclusion of law for response is necessary. To the extent a response is necessary, itis specifically denied. which no which no which no which no which no which no which no which no which noDate: November _Z. 2018 Respectfully Submitted, SMIGEL, ANDERSON & SACKS, LLP ~ Atty. LD. 82283 fandall S. Pajovich, Esq.— Atty. LD. 320821 Smigel, Anderson & Sacks, LLP 4431 North Front St,, 3° Floor Harrisburg, PA 17110 (117) 234-2401 aklein@sasllp.com majovich@sasl!p.com