Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 9 of 13
40. Paragraph 40 includes statements of law that require no response. Paragraph 40 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.
41. Paragraph 41 includes statements of law that require no response. Paragraph 41 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.
42. As to the first sentence of Paragraph 42, the second refusal letter speaks for itself. To the extent the allegation in the first sentence of Paragraph 42 paraphrases or characterizes the letter, Defendants deny the allegations to the extent they are inconsistent with the letter. The remainder of Paragraph 42 includes statements of law that require no response. The remainder of Paragraph 42 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.
43. Paragraph 43 includes statements of law that require no response. Paragraph 43 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.
44. Paragraph 44 includes statements of law that require no response. Paragraph 44 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.
45. Paragraph 45 includes statements of law that require no response. Paragraph 45 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.
