Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 7 of 13
29. Paragraph 29 includes statements of law that require no response. Paragraph 29 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.
30. The first sentence of Paragraph 30 is a conclusory statement made by Plaintiff that requires no response. The remaining sentences of Paragraph 30 are quotations of law that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
31. As to the first sentence of Paragraph 31, denied. The third sentence of Paragraph 31 includes a quotation from the second refusal letter, the letter speaks for itself. To the extent the allegation in the third sentence of Paragraph 31 paraphrases or characterizes the letter, Defendants deny the allegations to the extent they are inconsistent with the letter. The remainder of Paragraph 31 includes conclusory statements made by Plaintiff that require no response. To the extent that an answer is deemed to be required, the allegations are denied.
32. Paragraph 32 is a conclusory statement made by Plaintiff that requires no response. To the extent that an answer is deemed to be required, Defendants lack knowledge and information sufficient to form a belief as to the truth of the allegations, and those allegations are deemed denied.
33. As to the first sentence of Paragraph 33, the second refusal letter speaks for itself. To the extent the allegation in the first sentence of Paragraph 33 paraphrases or characterizes the letter, Defendants deny the allegations to the extent they are inconsistent with the letter. The second and third sentences of Paragraph 33 are conclusory statements made by Plaintiff that require no response. To the extent that an answer is deemed to be required, the allegations are denied.
