Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 11 of 13
51. Paragraph 51 includes statements of law that require no response. Paragraph 51 also includes conclusory statements made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
52. Paragraph 52 includes statements of law that require no response. Paragraph 52 also includes conclusory statements made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
53. The first and second sentences of Paragraph 53 include statements of law that require no response and conclusory statements made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied. As to the third sentence of Paragraph 53, Defendants lack knowledge and information sufficient to form a belief as to the truth of the allegations and the same are deemed denied.
54. Paragraph 54 includes statements of law that require no response. Paragraph 54 also includes conclusory statements made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
55. Paragraph 55 includes statements of law that require no response. Paragraph 55 also includes conclusory statements made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
56. Paragraph 56 is a conclusory statement made by Plaintiff that requires no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
57. Paragraph 57 includes statements of law that require no response. Paragraph 57 also includes conclusory statements made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
