CA, Inc.'s Answer and Counterclaim - Reed Smith

From the state tax library of Reed Smith LLPwww.reedsmith.com/DEtaxfor other related documents, please email ksollie@reedsmith.com"extreme" in this case, admits that the State extends time typically in the VDA process, andstates that it is without sufficient knowledge to enable it to respond to the remaining allegationsset forth in Paragraph 23 of the Verified Amended Complaint.24. Admits in response to the allegations contained in Paragraph 24 of the VerifiedAmended Complaint only that on November 17, 2004 that CA and the State entered into a FormAP DE-1, said document speaking for itself. Further answering, CA states that the document andregulations referred to by the State in Paragraph 24 of the Verified Amended Complaint are thebest evidence of their own contents and, therefore, CA denies the State's attempt to summarize orcharacterize the contents of the documents and regulations, and states that no further response tothe allegations in this paragraph is required. To the extent a further answer is deemed necessary,CA states that it is without sufficient knowledge to enable it to respond to the remainingallegations set forth in Paragraph 24 of the Verified Amended Complaint.25. States that the allegations set forth in Paragraph 25 of the Verified AmendedComplaint amount to conclusions of law to which no response is required. To the extent ananswer is deemed necessary, CA admits only that CA entered into a voluntary disclosureagreement with the State in connection with abandoned and unclaimed property, that CAconducted a self-audit and made submissions of voluminous materials to the State pursuant tothat agreement, and has offered to pay millions of dollars to the State in connection with saidagreement. CA also states that the document referenced in Paragraph 25 speaks for itself and isthe best evidence of its own content and, therefore, CA denies the State's attempt to summarizeor characterize the contents of those documents, and states that no further response to theallegations in this paragraph is required. Further answering, CA denies any and all remainingallegations contained in Paragraph 25 of the Verified Amended Complaint.- 7 –