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.comdenies the State<strong>'s</strong> attempt to summarize or characterize the document<strong>'s</strong> contents <strong>and</strong> states that nofurther response to the allegations in this paragraph is required. <strong>CA</strong> also states that <strong>CA</strong> requestedadditional time from the State to complete its self-audit, which the State granted. Furtheranswering, <strong>CA</strong> denies any <strong>and</strong> all remaining allegations contained in Paragraph 29 of theVerified Amended Complaint.30. Admits in response to the allegations contained in Paragraph 30 of the VerifiedAmended Complaint that <strong>CA</strong> requested additional time from the State to complete its self-audit,which the State granted. Further answering, <strong>CA</strong> states that it is without sufficient knowledge toenable it to respond to the allegation that the State was unaware of the date on which Ernst &Young was retained, <strong>and</strong> denies any <strong>and</strong> all remaining allegations contained in Paragraph 30 ofthe Verified Amended Complaint.31. Admits in response to the allegations set forth in Paragraph 31 of the VerifiedAmended Complaint only that <strong>CA</strong> presented its initial VDA presentation to the State on or aboutJuly 28, 2005, said document speaking for itself. <strong>CA</strong> also states that the document referred to bythe State in Paragraph 31 of the Verified Amended Complaint is the best evidence of its owncontents <strong>and</strong>, therefore, <strong>CA</strong> denies the State<strong>'s</strong> attempt to summarize or characterize thedocument<strong>'s</strong> contents <strong>and</strong> states that no further response to the allegations in this paragraph isrequired. Further answering, <strong>CA</strong> denies any <strong>and</strong> all remaining allegations contained inParagraph 31 of the Verified Amended Complaint.32. Admits in response to the allegations set forth in Paragraph 32 of the VerifiedAmended Complaint only that the State requested that <strong>CA</strong> provide it with additional information,which <strong>CA</strong> provided to the State. Further answering, <strong>CA</strong> denies that it failed to timely providethe documents requested by the State, <strong>and</strong> states that it is without sufficient knowledge to enable- 9 –
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