Free Answer to Amended Complaint - District Court of Colorado - Colorado

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446.

The document purportedly quoted in paragraph 446 speaks for itself, and

Nacchio respectfully refers the Court to the full documents for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 446. 447. To the extent Plaintiff purports to quote Nacchio from a document, that

document to which Plaintiff refers speaks for itself and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient

knowledge or information to admit or deny the remaining allegations in paragraph 447. 448. The document purportedly quoted in paragraph 448 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 448. 449. The document purportedly quoted in paragraph 449 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 449. 450. The document purportedly quoted in paragraph 450 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 450. 451. The document purportedly quoted in paragraph 451 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its

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contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 451. 452. 453. Nacchio denies the allegations in paragraph 452. The document purportedly quoted in paragraph 453 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 453. 454. To the extent Plaintiff purports to quote Nacchio from a document, that

document to which Plaintiff refers speaks for itself and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient

knowledge or information to admit or deny the remaining allegations in paragraph 454. 455. The document purportedly quoted in paragraph 455 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 455. 456. The document referenced in paragraph 456 speaks for itself, and Nacchio

respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 456. 457. The document purportedly quoted in paragraph 457 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 457.

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458.

The document purportedly quoted in paragraph 458 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 458. 459. 460. Nacchio denies the allegations in paragraph 459. The document purportedly quoted in paragraph 460 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 460. 461. To the extent Plaintiff purports to quote Nacchio from a document, that

document to which Plaintiff refers speaks for itself and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient

knowledge or information to admit or deny the remaining allegations in paragraph 461. 462. The document referred to in paragraph 462 speaks for itself, and Nacchio

respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 462. 463. The document purportedly quoted in paragraph 463 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 463. 464. The document purportedly quoted in paragraph 464 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its

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contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 464. 465. 466. Nacchio denies the allegations in paragraph 465. The document referred to in paragraph 466 speaks for itself, and Nacchio

respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 466. 467. The document purportedly quoted in paragraph 467 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 467. 468. The document purportedly quoted in paragraph 468 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 468. 469. The document purportedly quoted in paragraph 469 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 469. 470. To the extent Plaintiff purports to quote Nacchio from a document, that

document to which Plaintiff refers speaks for itself and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient

knowledge or information to admit or deny the remaining allegations in paragraph 470.

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471.

The document purportedly quoted in paragraph 471 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 471. 472. The document purportedly quoted in paragraph 472 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 472. 473. The document purportedly quoted in paragraph 473 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 473. 474. The document purportedly quoted in paragraph 474 speaks for itself, and

Nacchio respectfully refers the Court to the full documents for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 474. 475. The document referred to in paragraph 475 speaks for itself, and Nacchio

respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 475. 476. 477. Nacchio denies the allegations in paragraph 476. The document referred to in paragraph 477 speaks for itself, and Nacchio

respectfully refers the Court to the full document for a complete understanding of its contents.

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Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 477. 478. The document referred to in paragraph 478 speaks for itself, and Nacchio

respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 478. 479. The document referred to in paragraph 479 speaks for itself, and Nacchio

respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 479. 480. To the extent Plaintiff purports to quote Nacchio from a document, that

document to which Plaintiff refers speaks for itself and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient

knowledge or information to admit or deny the remaining allegations in paragraph 480. 481. The document purportedly quoted in paragraph 481 speaks for itself, and

Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 481. 482. 483. Nacchio denies the allegations in paragraph 482. Insofar as the allegations in the first sentence of paragraph 483 are

directed at him, Nacchio denies them. Insofar as the allegations in the first sentence of paragraph 483 are directed at other Defendants, Nacchio lacks sufficient knowledge or information to admit or deny them. Nacchio denies the remaining allegations in paragraph 483.

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484.

Nacchio denies the allegations in the first sentence of paragraph 484. The

document purportedly quoted in paragraph 484 speaks for itself, and Nacchio respectfully refers the Court to the full press release for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 484. 485. 486. Nacchio denies the allegations in paragraph 485. Nacchio denies the allegations in the first sentence of paragraph 486. The

document purportedly quoted in paragraph 486 speaks for itself, and Nacchio respectfully refers the Court to the full press release for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 486. 487. To the extent Plaintiff purports to quote Nacchio from a document, that

document to which Plaintiff refers speaks for itself and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient

knowledge or information to admit or deny the remaining allegations in paragraph 487. 488. 489. Nacchio denies the allegations in paragraph 488. Nacchio denies the allegations in the first sentence of paragraph 489. The

document purportedly quoted in paragraph 489 speaks for itself, and Nacchio respectfully refers the Court to the full press release for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 489. 490. Nacchio admits that Morgan Stanley issued reports in which Qwest was

discussed, and respectfully refers the Court to the full documents for a complete understanding of their contents. Nacchio denies all other allegations in paragraph 490. 491. Insofar as the allegations in the first sentence of paragraph 491 are

directed at him, Nacchio denies them. Insofar as the allegations in the first sentence of paragraph

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491 are directed at other Defendants, Nacchio lacks sufficient knowledge or information to admit or deny them. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 491. 492. Insofar as the allegations in paragraph 492 are directed at him, Nacchio

denies them. Nacchio lacks sufficient information or knowledge to admit or deny the allegations in paragraph 492 insofar as they are directed at other individuals. 493. The allegations in paragraph 493 are misleading because they incorporate

only select information from multiple public filings by individuals, because "$ value" is vague and unclear, and because they omit other potentially relevant information contained in the same filings and/or other documents, including publicly filed document pertaining to Qwest option grants. Nacchio admits that he exercised certain of his Qwest options and sold the resulting shares on certain dates, and respectfully refers the Court to the complete documents, which speak for themselves. Nacchio denies the remaining allegations in paragraph 493 insofar as they are directed at him. Nacchio lacks sufficient information or knowledge to admit or deny the

allegations in paragraph 493 insofar as they are directed at other individuals. 494. Insofar as the allegations in paragraph 494 are directed at him, Nacchio

denies them. Nacchio lacks sufficient information or knowledge to admit or deny the allegations in paragraph 494 insofar as they are directed at other individuals. 495. Nacchio admits that Business Week published articles in which Qwest is

discussed, and respectfully refers the Court to the full documents for a complete understanding of their contents. Nacchio lacks sufficient information or knowledge to admit or deny the remaining allegations in paragraph 495.

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496.

To the extent Plaintiff refers to a document in paragraph 496, that

document speaks for itself, and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient information or knowledge to admit or deny the remaining allegations in paragraph 496. 497. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 497. 498. 499. Nacchio denies the allegations in paragraph 498. Nacchio admits that he was Qwest's President and CEO from January

1997 to February 1999 and the CEO and Co-Chairman from February 1999 to June 16, 2002. Except as specifically admitted above, Nacchio denies the allegations in paragraph 499. 500. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 500. 501. 502. 503. 504. Nacchio adopts and incorporates Qwest's Answer to paragraph 501. Nacchio adopts and incorporates Qwest's Answer to paragraph 502. Nacchio adopts and incorporates Qwest's Answer to paragraph 503. Nacchio denies the allegations in the first sentence of paragraph 504.

Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 504. 505. Nacchio denies the allegations in the first sentence of paragraph 505.

Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 505. 506. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 506.

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507.

Nacchio denies the first three sentences of paragraph 507. Nacchio admits

that the Denver Post published articles in which Qwest was discussed and published a letter signed by Mr. Tempest, which speak for themselves, and respectfully refers the Court to the full documents for a complete understanding of their contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 507. 508. 509. 510. Nacchio adopts and incorporates Qwest's Answer to paragraph 508. Nacchio denies the allegations in paragraph 509. To the extent the allegations in paragraph 510 are directed at him, Nacchio

denies them. Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 510 insofar as they are directed at other Defendants. 511. Nacchio admits that he, Mr. Anschutz, and Mr. Slater served on Qwest's

Board of Directors. Except as specifically admitted above, Nacchio denies the allegations in paragraph 511. 512. Nacchio admits that the United States House of Representatives

Committee on Energy and Commerce held hearings on September 24 and October 1, 2002 entitled "Capacity Swaps by Global Crossing and Qwest: Sham Transactions Designed to Boost Revenues?" Nacchio admits that he testified at those hearings. His testimony speaks for itself, and Nacchio respectfully refers the Court to the full transcript for a complete understanding of the contents of his testimony. 513. Nacchio lacks sufficient knowledge or information to admit or deny that

Anschutz was informed of an anonymous letter in May 2002 containing the quotes Plaintiff includes in paragraph 513. Nacchio lacks sufficient knowledge or information to admit or deny Plaintiff's purported quotation of the letter, and denies the allegations contained in the letter.

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514.

Nacchio admits that Mr. Slater served on Qwest's Board of Directors and

that Mr. Slater is President of the Anschutz Investment Company. Nacchio further admits that Mr. Slater served as a member of the Executive Committee of Qwest's Board of Directors. The charter for the Executive Committee speaks for itself, and Nacchio respectfully refers the Court to the charter for a full understanding of the authority granted to the Executive Committee. Except as specifically admitted above, Nacchio denies the allegations in paragraph 514. 515. Nacchio admits that Messrs. Khosla and Nelson served on Qwest's Board

of Directors. Except as specifically admitted above, Nacchio denies the allegations in paragraph 515. 516. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 516. 517. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 517. 518. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 518. 519. Nacchio admits that the United States House of Representatives

Committee on Energy and Commerce held hearings on September 24 and October 1, 2002 entitled "Capacity Swaps by Global Crossing and Qwest: Sham Transactions Designed to Boost Revenues?" Nacchio further admits that Ms. Szeliga testified at those hearings. Ms. Szeliga's testimony speaks for itself, and Nacchio respectfully refers the Court to the full transcript for a complete understanding of the contents of Ms. Szeliga's testimony. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 519.

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520.

Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 520. 521. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 521. 522. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 522. 523. Nacchio admits that the United States House of Representatives

Committee on Energy and Commerce held hearings on September 24 and October 1, 2002 entitled "Capacity Swaps by Global Crossing and Qwest: Sham Transactions Designed to Boost Revenues?" Nacchio further admits that Ms. Szeliga testified at those hearings. Ms. Szeliga's testimony speaks for itself, and Nacchio respectfully refers the Court to the full transcript for a complete understanding of the contents of Ms. Szeliga's testimony. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 523. 524. Nacchio lacks sufficient knowledge or information to admit or deny the

remaining allegations in paragraph 524.. 525. 526. Nacchio denies the allegations in paragraph 525. Because the allegations in paragraph 526 are directed at other Defendants

and state legal conclusions, no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 526. 527. Because the allegations in paragraph 527 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 527.

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528.

Because the allegations in paragraph 528 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 528. 529. Because the allegations in paragraph 529 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 529. 530. Because the allegations in paragraph 530 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 530. 531. Because the allegations in paragraph 531 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 531. 532. Because the allegations in paragraph 532 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 532. 533. Because the allegations in paragraph 533 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 533. 534. Because the allegations in paragraph 534 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 534. 535. 536. Nacchio denies the allegations in paragraph 535. Nacchio denies the allegations in paragraph 536.

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537.

Nacchio denies the allegations in the first sentence of paragraph 537.

Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 537. 538. 539. Nacchio adopts and incorporates Qwest's Answer to paragraph 538. Because the allegations in paragraph 539 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 539. 540. Because the allegations in paragraph 540 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 540. 541. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 541. 542. Because the allegations in paragraph 542 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 542. 543. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 543. 544. 545. Nacchio adopts and incorporates Qwest's Answer to paragraph 544. The publicly filed document purportedly quoted in paragraph 545 speaks

for itself, and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 545.

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546.

The publicly filed document purportedly quoted in paragraph 546 speaks

for itself, and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 546. 547. The publicly filed document purportedly quoted in paragraph 547 speaks

for itself, and Nacchio respectfully refers the Court to the full document for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 547. 548. To the extent that Plaintiff refers to various provisions of GAAP, Nacchio

respectfully refers the Court to the full set of GAAP provisions for a complete understanding of the its contents. Nacchio denies the remaining allegations in paragraph 548. 549. Paragraph 549 purports to characterize GAAS. Nacchio respectfully

refers the Court to the full GAAS provisions for a complete understanding of their contents. Because the third and fourth sentences of paragraph 549 are directed at other Defendants, no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in the third and fourth sentences in paragraph 549. 550. Paragraph 550 purports to characterize GAAS Statement of Auditing

Standards Nos. 55 and 78. Those statements speak for themselves, and Nacchio respectfully refers the Court to the full standards for a complete understanding of their contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 550. 551. Nacchio denies the allegations in paragraph 551.

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552.

Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in the first sentence of paragraph 552. Nacchio denies the remaining allegations in paragraph 552. 553. Paragraph 553 purports to characterize SAS standard No. 47. That

statement speaks for itself, and Nacchio respectfully refers the Court to the full standard for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 553. 554. 555. Nacchio denies the allegations in paragraph 554. Paragraph 555 purports to characterize SAS standard No. 82. That

statement speaks for itself, and Nacchio respectfully refers the Court to the full standard for a complete understanding of its contents. Nacchio lacks sufficient knowledge or information to admit or deny the remaining allegations in paragraph 555. 556. 557. Nacchio denies the allegations in paragraph 556. Because the allegations in paragraph 557 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 557. 558. Because the allegations in paragraph 558 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 558. 559. 560. Nacchio denies the allegations in paragraph 559. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 560.

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561.

Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 561. 562. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 562. 563. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 563. 564. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 564. 565. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 565. 566. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 566. 567. Because the allegations in paragraph 567 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio denies the allegations in paragraph 567. 568. Nacchio lacks sufficient information or knowledge to admit or deny the

allegations in the first sentence of paragraph 568. Nacchio denies the remaining allegations in paragraph 568. 569. 570. Nacchio adopts and incorporates Qwest's Answer to paragraph 569. Nacchio lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 570.

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571.

Because the allegations in paragraph 571 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio denies the allegations in paragraph 571. 572. Because the allegations in paragraph 572 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 572. 573. Because the allegations in paragraph 573 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 573. 574. Because the allegations in paragraph 574 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 574. 575. Because the allegations in paragraph 575 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 575. 576. Because the allegations in paragraph 576 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 576. 577. Because the allegations in paragraph 577 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 577.

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578.

Because the allegations in paragraph 578 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 578. 579. Because the allegations in paragraph 579 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 579. 580. Because the allegations in paragraph 580 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 580. 581. Because the allegations in paragraph 581 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 581. 582. Because the allegations in paragraph 582 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 582. 583. Because the allegations in paragraph 583 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 583. 584. Because the allegations in paragraph 584 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 584.

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585.

Because the allegations in paragraph 585 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 585. 586. Because the allegations in paragraph 586 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 586. 587. Because the allegations in paragraph 587 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 587. 588. Because the allegations in paragraph 588 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 588. 589. Because the allegations in paragraph 589 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 589. 590. Because the allegations in paragraph 590 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 590. 591. Because the allegations in paragraph 591 are directed at other Defendants,

no response is required. To the extent that a response is deemed necessary, Nacchio lacks sufficient knowledge or information to admit or deny the allegations in paragraph 591.

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