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 66 of the Verified Amended Complaint.67. Admits only that the unclaimed property analysis set forth in the spreadsheetsproduced by <strong>CA</strong> to the State is accurate <strong>and</strong> complete. Further answering, <strong>CA</strong> states that thedocuments referred to by the State in Paragraph 67 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 67 of the Verified Amended Complaint.68. States that the allegations set forth in Paragraph 68 of the Verified AmendedComplaint regarding purported accounting fraud <strong>and</strong> criminal activity represent immaterial,impertinent, or sc<strong>and</strong>alous matter that should be stricken from the State<strong>'s</strong> pleading pursuant toCourt of Chancery Rule 12(f). Further answering, <strong>CA</strong> states that it is without sufficientinformation to enable it to respond to the allegations regarding the State<strong>'s</strong> alleged state of mind,<strong>and</strong> states that the documents referred to by the State in Paragraph 68 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 68 of theVerified Amended Complaint.69. States that the allegations set forth in Paragraph 69 of the Verified AmendedComplaint regarding purported accounting fraud <strong>and</strong> criminal activity represent immaterial,impertinent, or sc<strong>and</strong>alous matter that should be stricken from the State<strong>'s</strong> pleading pursuant to- 20 –
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