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 58 of the Verified Amended Complaint.59. States that the documents referred to by the State in Paragraph 59 of the VerifiedAmended Complaint are the best evidence of their own content <strong>and</strong>, therefore, <strong>CA</strong> denies theState<strong>'s</strong> attempt to summarize or characterize the documents' purpose or contents <strong>and</strong> states thatno further response to the allegations in this paragraph regarding the documents is required.Further answering, <strong>CA</strong> denies any <strong>and</strong> all remaining allegations contained in Paragraph 59 of theVerified Amended Complaint.60. Admits only that the acquisition referenced in Paragraph 60 of the VerifiedAmended Complaint does not form the basis for any portion of the unclaimed property liabilitythat <strong>CA</strong> owes to the State. Further answering, <strong>CA</strong> states that the documents referred to by theState in Paragraph 60 of the Verified Amended Complaint are the best evidence of their owncontent <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong> attempt to summarize or characterize thedocuments' purpose or contents <strong>and</strong> states that no further response to the allegations in thisparagraph regarding the documents is required. Further answering, <strong>CA</strong> denies any <strong>and</strong> allremaining allegations contained in Paragraph 60 of the Verified Amended Complaint.61. Admits only that the acquisition referenced in Paragraph 61 of the VerifiedAmended Complaint does not form the basis for any portion of the unclaimed property liabilitythat <strong>CA</strong> owes to the State. Further answering, <strong>CA</strong> states that it is without sufficient informationto enable it to respond to the allegations regarding the date on which the State became aware ofthe acquisition referenced in Paragraph 61 of the Verified Amended Complaint, <strong>and</strong> states thatthe documents referred to by the State in Paragraph 61 of the Verified Amended Complaint arethe best evidence of their own content <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong> attempt to summarizeor characterize the documents' purpose or contents <strong>and</strong> states that no further response to the- 18 –
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