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.com2. Admits in response to the allegations contained in Paragraph 2 of the VerifiedAmended Complaint only that <strong>CA</strong> participated in the State<strong>'s</strong> Voluntary Disclosure Program("VDA") <strong>and</strong> that <strong>CA</strong> initiated a lawsuit against the State in the matter captioned <strong>CA</strong>, <strong>Inc</strong>. v.Cordrey, et. al., Civil Action No. 4111-CC. Further answering, <strong>CA</strong> denies any <strong>and</strong> all remainingallegations contained in Paragraph 2 of the Verified Amended Complaint.3. States that the allegations set forth in Paragraph 3 of the Verified AmendedComplaint represent immaterial, impertinent, or sc<strong>and</strong>alous matter that should be stricken fromthe State<strong>'s</strong> pleading pursuant to Court of Chancery Rule 12(f). To the extent an answer isdeemed necessary, <strong>CA</strong> denies the allegations contained in Paragraph 3 of the Verified AmendedComplaint.4. States that the allegations set forth in Paragraph 4 of the Verified AmendedComplaint represent immaterial, impertinent, or sc<strong>and</strong>alous matter that should be stricken fromthe State<strong>'s</strong> pleading pursuant to Court of Chancery Rule 12(f). Further answering, <strong>CA</strong> states thatthe documents referenced in Paragraph 4 of the Verified Amended Complaint speak forthemselves. To the extent an answer is deemed necessary, <strong>CA</strong> denies the allegations containedin Paragraph 4 of the Verified Amended Complaint.5. States that the allegations set forth in Paragraph 5 of the Verified AmendedComplaint represent immaterial, impertinent, or sc<strong>and</strong>alous matter that should be stricken fromthe State<strong>'s</strong> pleading pursuant to Court of Chancery Rule 12(f). To the extent an answer isdeemed necessary, <strong>CA</strong> admits only that <strong>CA</strong> advised the State that its records for accountsreceivable, accounts payable, <strong>and</strong> payroll documentation for the VDA period were complete <strong>and</strong>accurate to the best of <strong>CA</strong><strong>'s</strong> knowledge. <strong>CA</strong> denies the remaining allegations contained inParagraph 5 of the Verified Amended Complaint.- 2 –
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