YOUNGSTOWN — Window World Inc. filed a response Tuesday to the wrongful death lawsuit filed against the company in the Oct. 5 explosion at a Huxley Road home in Ellsworth Township that killed residents Jeff Kocanyar, 69, and JoAnn Kocanyar, 67, and their daughter and son-in-law.

The lawsuit, filed in Mahoning County Common Pleas Court, alleges that workers for Window World of Youngstown broke a water pipe in the Kocanyar home Oct. 4 and also damaged the propane lines “and / or failed to recognize that the propane gas lines at the Kocanyar home had been damaged.”

The Window World response denies “for lack of knowledge” the first allegation regarding the waterline and directly denies the second allegation regarding the propane lines.

The lawsuit alleges in one paragraph that the damaged propane line was the reason for the 7:19 a.m. Oct. 5 explosion that “caused the entire structure to be destroyed and blown away in all directions, leaving nothing but debris and personal belongings scattered across the property and a hole from the foundation of the home.”

The Window World response denies the allegations in that paragraph.

The Kocanyars’ daughter, Julie Lubic, 33, and son-in-law, Adam Lubic, 33, were visiting for the weekend from Chicago at the time of the explosion, and all four people were killed. The suit was filed by family members of the Kocanyars and Lubics.

In January, the Ohio State Fire Marshal’s Office ruled the cause of the explosion “undetermined,” but said a propane leak was the “most probable cause.”

Another paragraph of the lawsuit alleges that the explosion was “a direct and proximate result of the negligence, recklessness, carelessness, malfeasance and nonfeasance” of the work crew while they were replacing siding on the home.

The Window World response denies those allegations.

Window World PennOhio LLC, doing business as Window World of Youngstown, gave several defenses to the lawsuit, stating that the suit “fails to state a claim against (Window World) upon which relief can be granted.”

It also alleges that the “negligence of other individuals and / or companies caused and / or contributed to cause the damages and injuries alleged,” and that the “cause of the damages remains ‘undetermined.'”

The Window World response denies “for lack of knowledge” about 30 paragraphs of allegations and directly denies allegations in about 35 other paragraphs.

The response denies a long paragraph that lists allegations such as Window World failed to “exercise reasonable and proper care in the replacement and installation of siding” on the home, that caused “damage to the propane gas line(s)” and that the company failed “to identify and / or remedy the propane gas leak and / or damage to the propane gas lines.”

That paragraph also alleged several other things, including that Window World failed to conduct an adequate and proper inspection of the property before starting on the work, such as “locating and marking the location of any and all propane gas lines,” “failing to disconnect and shut off all propane gas lines prior to performing work,” “failing to properly train, monitor and / or supervise its employees, agents and / or independent contractors regarding work in the area of propane gas lines.”

Window World’s response was a blanket denial of “each and every allegation against it” in that paragraph.

Attorney Jordan Lebovitz filed the Window World response.

The Ohio State Fire Marshal’s Office investigation indicated that the explosion happened the day after a crew from Window World had worked at the home.

It states that the propane line entered the home at the northeast corner. The conclusion section stated that firefighters reported seeing fire coming from the copper tubing in the northeast corner of the basement. The tubing was “from the 500-gallon propane tank,” it stated. That corner of the house also is where fire crews saw flames when they first arrived at the scene. Fire crews found the propane regulator in the debris on the east side of the home.

The report states that the Window World crews worked primarily on the north side of the home, where they used pump-jack scaffolding. One of the jacks was installed at the northeast corner where the propane line enters the home.

The report’s findings noted several possible “ignition sources” for the explosion, including the furnace, a hot water tank, refrigerator or “source unknown,” the report states. None of the four people in the home smoked or “would have been smoking in the residence at the time of the explosion,” family members said.

The debris from the explosion broke or damaged most of the windows on the front of a neighbor’s house about 400 feet away on the other side of the street. The neighbor, Tracey Beardsley, told The Vindicator the explosion “blew me right out of the chair.”

Kala Christy, a next-door neighbor who was close with the Kocanyars, told investigators that the day before the explosion she talked to JoAnn Kocanyar, who told her that Jeff had gone to the store that day to buy parts because the workers removing the wood siding from the exterior of the Kocanyars’ house “were banging on the house so hard that they broke a waterline somewhere, and the basement was flooding.”

The workers were removing wood siding on the house and were hired to replace it with vinyl siding. The 44-page investigative report contained a section written by investigator Kurt Wright in which he reported that he spoke with representatives of the company at their Boardman offices.

One representative told Wright he received a text message and photos at 4:26 p.m. Oct. 4 from JoAnn stating that the workers “had accidentally broken a water pipe within the basement of the residence.” Kocanyar shared seven photographs of the broken pipe, which “was utilized for an outdoor water spigot on the outside of the residence,” the report states.

JoAnn indicated that Jeff “was going to the hardware store to purchase the materials to fix the pipe and that she was just bringing it to (the company’s) attention,” the report states.

The company’s project manager explained that crews typically work until 5 p.m. But with the permission of the owners, they continued to work until 7 p.m. the night before the explosion.

State Fire Marshal’s investigator Donald Illig went to the home the day of the explosion. He described checking the propane tank and a line that led from the tank to where it entered the home at the home’s northeast corner, which is the back, left corner.

The line “ended a short distance into the basement,” Illig’s report states. The conclusions part of the report written by investigator Todd Stitt states that among the areas where firefighters saw fire when they arrived after the explosion was the northeast corner of the basement where the copper tubing that carried propane from the propane tank entered the home.

Firefighters also said they observed fire on the south side of the home near the chimney, east side by the wooden patio, and “the north side area had debris burning. An area of origin could not be determined due to the lack of identifiable burn patterns,” the report states.

The Kocanyar property is about 7 miles southwest of the Canfield Fairgrounds.