CA, Inc.'s Answer and Counterclaim - Reed Smith
CA, Inc.'s Answer and Counterclaim - Reed Smith
CA, Inc.'s Answer and Counterclaim - Reed Smith
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From the state tax library of <strong>Reed</strong> <strong>Smith</strong> LLPwww.reedsmith.com/DEtaxfor other related documents, please email ksollie@reedsmith.comparagraph regarding the document is required. Further answering, <strong>CA</strong> denies any <strong>and</strong> allremaining allegations contained in Paragraph 36 of the Verified Amended Complaint.37. Admits in response to the allegations set forth in Paragraph 37 of the VerifiedAmended Complaint only that the State sent an e-mail communication to APS on January 20,2006 said document speaking for itself. Further answering, <strong>CA</strong> states that the document referredto by the State in Paragraph 37 of the Verified Amended Complaint is the best evidence of itsown content <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong> attempt to summarize or characterize thedocument<strong>'s</strong> purpose or contents <strong>and</strong> states that no further response to the allegations in thisparagraph regarding the document is required. Further answering, <strong>CA</strong> denies any <strong>and</strong> allremaining allegations contained in Paragraph 37 of the Verified Amended Complaint.38. Denies the allegations contained in Paragraph 38 of the Verified AmendedComplaint.39. States that <strong>CA</strong> is without sufficient knowledge to enable it to respond to theallegations contained in Paragraph 39 of the Verified Amended Complaint concerning the State<strong>'s</strong>alleged state of mind. Further answering, <strong>CA</strong> admits in response to the allegations set forth inParagraph 39 of the Verified Amended Complaint only that the State sent an e-mailcommunication to APS on March 21, 2006, said document speaking for itself. <strong>CA</strong> also statesthat the document referred to by the State in Paragraph 39 of the Verified Amended Complaint isthe best evidence of its own content <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong> attempt to summarizeor characterize the document<strong>'s</strong> purpose or contents <strong>and</strong> states that no further response to theallegations in this paragraph regarding the document is required. Further answering, <strong>CA</strong> deniesany <strong>and</strong> all remaining allegations contained in Paragraph 39 of the Verified Amended Complaint.40. Admits in response to the allegations set forth in Paragraph 40 of the VerifiedAmended Complaint only that the State requested a statement from <strong>CA</strong> regarding the records in- 11 –
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