Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 8 of 13
34. Paragraph 34 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.
35. Paragraph 35 includes statements of law that require no response. Paragraph 35 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.
36. Paragraph 36 includes statements of law that require no response. Paragraph 36 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.
37. Paragraph 37 includes statements of law that require no response. Paragraph 37 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.
38. Paragraph 38 includes statements of law that require no response. Paragraph 38 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.
39. As to the first sentence of Paragraph 39, the second refusal letter speaks for itself. To the extent the allegation in the first sentences of Paragraph 39 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 39 are 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.
