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Page 1 Case 1:07-cv-03530-HB Document6 ~~ Filed 06/13/2007 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SHEET METAL WORKERS’ NATIONAL PENSION CIVIL ACTION NO.
FUND; NATIONAL ENERGY MANAGEMENT 07 CV 03530 (HB/DCF)
INSTITUTE COMMITTEE FOR THE
SHEET METAL AND AIR CONDITIONING
INDUSTRY; SHEET METAL OCCUPATIONAL
HEALTH INSTITUTE TRUST; INTERNATIONAL
TRAINING INSTITUTE FOR THE SHEET METAL
AND AIR CONDITIONING INDUSTRY; AND
NATIONAL STABILIZATION AGREEMENT
OF THE SHEET METAL INDUSTRY FUND,
Plaintiffs,
ANSWER
-AGAINST-
PRECISION TESTING & BALANCING, INC., AND
FRED BROMBERG, as an individual, and
LOUIS BROMBERG, as an individual,
Defendants.
Defendants, by their attorney, Howard M. Katz, Esq.,
answering the complaint, allege as follows:
1. Defendants refer to the original documents referred
to in plaintiff’s complaint and designated as paragraphs 6,7, 8, 9,
and 10.
2. Defendants deny each and every allegation marked as
paragraphs 11 and 12 contained in plaintiffs’ complaint.
3. Defendants deny each and every allegation of
plaintiffs’ first claim for relief and marked as paragraphs 13 and
14.
4. Defendants deny each and every allegation of
plaintiffs’ second claim for relief and marked as Paragraph 16.
5. Defendants deny each and every allegation of
plaintiff's third claim for relief and marked as paragraph 18.
6. Defendants deny each and every allegation of
plaintiff's fourth claim for relief and marked as paragraph 20.Page 2 Case 1:07-cv-03530-HB Document6 ~ Filed 06/13/2007 Page 2of2
7. Defendants deny each and every allegation of
plaintiff’s fifth claim for relief and marked as paragraph 22.
8. Defendants deny each and every allegation of
plaintiff's sixth claim for relief and marked as paragraphs 24 and
25).
9. Defendants deny each and every allegation of
plaintiff's seventh claim for relief and marked as paragraphs 27
and 28.
10. Defendants deny each and every allegation of
plaintiff's eighth claim for relief and marked as paragraphs 30, 31
and 32.
11. Defendants deny each and every allegation of
Plaintiff’s ninth claim for relief and marked as paragraphs 34, 25
and 36.
AS AND FOR A FIRST AFFIRMATIVE DEFENSE
I. Defendant sued herein as Fred Bromberg is an
improper party.
AS AND FOR A SECOND AFFIRMATIVE DEFENSE
13:. Defendant sued herein as Louis Bromberg is an
improper party.
WHEREFORE, Defendants’ demand judgment dismissing plaintiff's
complaint in all respects.
Dated: New York, New York
June 12, 2007
s/ Howard M. Katz
Howard M. Katz
HK-8914
Attorney for Defendants
225 Broadway Suite 1203
New York, N.Y. 10007
212-732-3435
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Case 1:07-cv-03530-HB Document6 ~~ Filed 06/13/2007 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SHEET METAL WORKERS’ NATIONAL PENSION CIVIL ACTION NO.
FUND; NATIONAL ENERGY MANAGEMENT 07 CV 03530 (HB/DCF)
INSTITUTE COMMITTEE FOR THE
SHEET METAL AND AIR CONDITIONING
INDUSTRY; SHEET METAL OCCUPATIONAL
HEALTH INSTITUTE TRUST; INTERNATIONAL
TRAINING INSTITUTE FOR THE SHEET METAL
AND AIR CONDITIONING INDUSTRY; AND
NATIONAL STABILIZATION AGREEMENT
OF THE SHEET METAL INDUSTRY FUND,
Plaintiffs,
ANSWER
-AGAINST-
PRECISION TESTING & BALANCING, INC., AND
FRED BROMBERG, as an individual, and
LOUIS BROMBERG, as an individual,
Defendants.
Defendants, by their attorney, Howard M. Katz, Esq.,
answering the complaint, allege as follows:
1. Defendants refer to the original documents referred
to in plaintiff’s complaint and designated as paragraphs 6,7, 8, 9,
and 10.
2. Defendants deny each and every allegation marked as
paragraphs 11 and 12 contained in plaintiffs’ complaint.
3. Defendants deny each and every allegation of
plaintiffs’ first claim for relief and marked as paragraphs 13 and
14.
4. Defendants deny each and every allegation of
plaintiffs’ second claim for relief and marked as Paragraph 16.
5. Defendants deny each and every allegation of
plaintiff's third claim for relief and marked as paragraph 18.
6. Defendants deny each and every allegation of
plaintiff's fourth claim for relief and marked as paragraph 20.
PDF Page 3
Case 1:07-cv-03530-HB Document6 ~ Filed 06/13/2007 Page 2of2
7. Defendants deny each and every allegation of
plaintiff’s fifth claim for relief and marked as paragraph 22.
8. Defendants deny each and every allegation of
plaintiff's sixth claim for relief and marked as paragraphs 24 and
25).
9. Defendants deny each and every allegation of
plaintiff's seventh claim for relief and marked as paragraphs 27
and 28.
10. Defendants deny each and every allegation of
plaintiff's eighth claim for relief and marked as paragraphs 30, 31
and 32.
11. Defendants deny each and every allegation of
Plaintiff’s ninth claim for relief and marked as paragraphs 34, 25
and 36.
AS AND FOR A FIRST AFFIRMATIVE DEFENSE
I. Defendant sued herein as Fred Bromberg is an
improper party.
AS AND FOR A SECOND AFFIRMATIVE DEFENSE
13:. Defendant sued herein as Louis Bromberg is an
improper party.
WHEREFORE, Defendants’ demand judgment dismissing plaintiff's
complaint in all respects.
Dated: New York, New York
June 12, 2007
s/ Howard M. Katz
Howard M. Katz
HK-8914
Attorney for Defendants
225 Broadway Suite 1203
New York, N.Y. 10007
212-732-3435
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