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 61 of the Verified Amended Complaint.62. States that the documents referred to by the State in Paragraph 62 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 62 of theVerified Amended Complaint.63. Denies the allegations contained in Paragraph 63 of the Verified AmendedComplaint.64. Denies the allegations contained in Paragraph 64 of the Verified AmendedComplaint.65. Admits only that the some of the spreadsheets produced by <strong>CA</strong> to the State werecreated by running electronic queries within <strong>CA</strong><strong>'s</strong> computer system, <strong>and</strong> states that thedocuments referred to by the State in Paragraph 65 of the Verified Amended Complaint are thebest evidence of their own content <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong> attempt to summarize orcharacterize the documents' purpose or contents <strong>and</strong> states that no further response to theallegations in this paragraph regarding the documents is required. Further answering, <strong>CA</strong> deniesany <strong>and</strong> all remaining allegations contained in Paragraph 65 of the Verified Amended Complaint.66. Admits only that the some of the spreadsheets produced by <strong>CA</strong> to the State werecreated by running electronic queries within <strong>CA</strong><strong>'s</strong> "TOPS" computer system, <strong>and</strong> states that thedocuments referred to by the State in Paragraph 66 of the Verified Amended Complaint are thebest evidence of their own content <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong> attempt to summarize orcharacterize the documents' purpose or contents <strong>and</strong> states that no further response to the- 19 –
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