METHFESSEL & WERBEL, ESQS. 

450 Seventh Avenue, Suite 1400 

New York, NY 10123 

(212) 947-1999 

Attorneys for BMS Catastrophe, Inc. 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

DAVID REYNOLDS AND KATHERINE 

REYNOLDS, 

Plaintiff, 

-AGAINSTALAN KASMAN DBA KASCO, 

AMERICAN EXPRESS BANK, LTD, 

AMERICAN EXPRESS COMPANY, 

AMERICAN EXPRESS TRAVEL 

RELATED SERVICES COMPANY, 

INC., AMERICAN STOCK EXCHANGE 

CLEARING LLC, AMERICAN STOCK 

EXCHANGE LLC, AMERICAN STOCK 

EXCHANGE REALTY ASSOCIATES 

LLC, AMEXCOMMODITIES 

LLC., AMEX INTERNATIONAL INC., 

AMEX INTERNATIONAL LLC, AMEX 

SEAT OWNERS ASSOCIATION, INC., 

AMEX SPECIALISTS ASSOCIATION, 

INC., ANN TAYLOR STORES 

CORPORATION, BANK TRUST 

COMPANY, BATTERY PARK CITY 

AUTHORITY, BFP TOWER C CO., 

LLC., BFP TOWER C MM LLC., 

BLACKMON-MOORINGSTEAMATIC CATASTROPHE, INC. 

D/B/A BMS CAT., ET AL. 

Defendants. 

INDEX NO.: 07CV3446 

NOTICE OF ADOPTION OF ANSWER 

TO MASTER COMPLAINT 

PLEASE TAKE NOTICE THAT Defendant, BMS Catastrophe, Inc. s/h/a 

Blackmon-Mooring-Steamatic Catastophe, Inc. d/b/a BMS Catastrophe, by 

their attorneys, Methfessel & Werbel, as and for their response to the 

Case 1:07-cv-03446-AKH Document 22 Filed 10/01/2007 Page 1 of 3
allegations set forth in the Complaint by Adoption (Check-Off Complaint) 

Related to the Master Complaint filed in the above referenced action, hereby 

adopts their Answer and defenses to the Master Complaint, dated July 26, 

2007, which was filed in the matter of: In Re World Trade Center Lower 

Manhattan Disaster Site Litigation, 21 MC 102 (AKH). 

 To the extent that Defendant’s Answer to the Master Complaint does not 

comprehensively address any of the specific allegations within the Check-Off 

Complaint in the above captioned matter, Defendant, Defendant, BMS 

Catastrophe, Inc., denies knowledge or information sufficient to form a belief as 

to the truth of such specific allegations. 

 WHEREFORE, the defendant, Defendant, BMS Catastrophe, Inc., 

demands judgment dismissing the above captioned action as against them, 

together with costs, disbursements and such other and further relief as this 

Court deems just and proper. 

DATED: New York, New York 

 October 1, 2007 

METHFESSEL & WERBEL, ESQS. 

Attorneys for BMS Catastrophe 

 

 

By:________________________________ 

Frank J. Keenan (FK 8922) 

450 Seventh Avenue 

Suite 1400 

New York, New York 10123 

(212) 947-1999 

Case 1:07-cv-03446-AKH Document 22 Filed 10/01/2007 Page 2 of 3
Our File No. 67141k 

CERTIFICATE OF MAILING 

The undersigned hereby certifies as follows: 

 l. I am employed by the law firm of Methfessel & Werbel. 

 2. On October 1, 2007 the undersigned prepared and forwarded 

copies of the within correspondence to the following parties: 

 William J. Dubanevich, Esq. 

Worby Groner Edelman & Napoli Bern, LLP 

5 Broadway, 12th Floor 

New York, NY 10006 

Attorneys for: David Reynolds and Katherine 

Reynolds 

All Defense Counsel 

 3. I certify that the foregoing statements made by me are true. I am 

aware that if any of the foregoing statements made by me are wilfully false, I am 

subject to punishment. 

____________________________________ 

Frank J. Keenan 

 

Case 1:07-cv-03446-AKH Document 22 Filed 10/01/2007 Page 3 of 3