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.comallegations in this paragraph regarding the documents is required. Further answering, <strong>CA</strong> deniesany <strong>and</strong> all remaining allegations contained in Paragraph 50 of the Verified Amended Complaint.51. Admits in response to the allegations set forth in Paragraph 51 of the VerifiedAmended Complaint only that <strong>CA</strong> disputed the amount dem<strong>and</strong>ed by the State, but continued towork with the State over the course of the next several months in good faith in an attempt tocome to a resolution of this matter. Further answering, <strong>CA</strong> denies any <strong>and</strong> all remainingallegations contained in Paragraph 51 of the Verified Amended Complaint.52. Admits in response to the allegations set forth in Paragraph 52 of the VerifiedAmended Complaint only that <strong>CA</strong> disputed the amount dem<strong>and</strong>ed by the State, but continued towork with the State over the course of the next several months in good faith in an attempt tocome to a resolution of this matter. <strong>CA</strong> also admits in response to the allegations set forth inParagraph 52 of the Verified Amended Complaint only that the State sent <strong>CA</strong><strong>'s</strong> counsel an e-mailcommunication on April 8, 2008, said document speaking for itself. Further answering, <strong>CA</strong>states that the documents referred to by the State in Paragraph 52 of the Verified AmendedComplaint are the best evidence of their own content <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong>attempt to summarize or characterize the documents' purpose or contents <strong>and</strong> states that nofurther response to the allegations in this paragraph regarding the documents is required. Furtheranswering, <strong>CA</strong> denies any <strong>and</strong> all remaining allegations contained in Paragraph 52 of theVerified Amended Complaint.53. States that <strong>CA</strong> is without sufficient knowledge to enable it to respond to theallegations contained in Paragraph 53 of the Verified Amended Complaint as to the State<strong>'s</strong>alleged expenditure of time <strong>and</strong> resources. Further answering, <strong>CA</strong> admits in response to theallegations set forth in Paragraph 53 of the Verified Amended Complaint only that <strong>CA</strong> disputedthe amount dem<strong>and</strong>ed by the State, but continued to work with the State over the course of the- 15 –
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