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

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521.

Tempest lacks sufficient knowledge or information to admit or deny the

allegations of paragraph 521, and therefore denies them. 522. Tempest lacks sufficient knowledge or information to admit or deny the

allegations of paragraph 522, and therefore denies them. 523. 524. Tempest adopts and incorporates Qwest's Answer to paragraph 523. Tempest lacks sufficient knowledge or information to admit or deny any

remaining allegations in paragraph 524, and therefore denies them. 525. B. Tempest denies the allegations in paragraph 525. Andersen's Knowledge and Scienter 1. 526. Andersen Abandoned Its Auditing Responsibilities as it Attempted to Build a Consulting Practice

Because the allegations in paragraph 526 are directed at other Defendants and To the extent that a response is deemed

state legal conclusions, no response is required.

necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 526 and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 527 and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 528 and therefore denies them.

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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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 529 and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 530 and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 531 and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 532 and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 533 and therefore denies them. 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, Tempest lacks sufficient

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knowledge or information to admit or deny the allegations in paragraph 534 and therefore denies them. 535. 536. Tempest denies the allegations in paragraph 535. Tempest denies the allegations in paragraph 536. 2. 537. Andersen Was the Architect of Qwest's Fraudulent Accounting

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

lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 537, and therefore denies them. 538. 539. Tempest adopts and incorporates Qwest's response 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 539 and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 540 and therefore denies them. 541. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 541, and therefore denies them. 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, Tempest lacks sufficient

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knowledge or information to admit or deny the allegations in paragraph 542 and therefore denies them. 543. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 543, and therefore denies them. 3. 544. 545. Andersen's Audits of Qwest Failed to Comply With GAAP

Tempest adopts and incorporates Qwest's Answer to paragraph 544. Tempest admits that Qwest filed a Form 10-K405 on March 17, 2000. That

public filing speaks for itself, and Tempest respectfully refers the Court to the full document for a complete understanding of its contents. Tempest lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 545 and therefore denies them. 546. Tempest admits that Qwest filed a Form 10-K on March 16, 2001. That public

filing speaks for itself, and Tempest respectfully refers the Court to the full document for a complete understanding of its contents. Tempest lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 546, and therefore denies them. 547. Tempest admits that Qwest filed a Form 10-K405 on April 1, 2002. That public

filing speaks for itself, and Tempest respectfully refers the Court to the full document for a complete understanding of its contents. Tempest lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 547, and therefore denies them. 548. Tempest denies the allegations in paragraph 548. 4. 549. Andersen's Audits of Qwest Failed to Comply With GAAS

Paragraph 549 purports to characterize GAAS. Tempest respectfully refers the

Court to the full GAAS provisions for a complete understanding of their contents. Because the

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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, Tempest lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 549 and therefore denies them. 550. Paragraph 550 purports to characterize GAAS Statement of Auditing Standards

Nos. 55 and 78. Those statements speak for themselves, and Tempest respectfully refers the Court to the full standards for a complete understanding of their contents. Tempest lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 550, and therefore denies them. 551. 552. Tempest denies the allegations in paragraph 551. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in the first sentence of paragraph 552, and therefore denies them. Tempest denies all other allegations in paragraph 552. 553. Paragraph 553 purports to characterize GAAS Statement of Auditing Standards

No. 47. That statement speaks for itself, and Tempest respectfully refers the Court to the full standard for a complete understanding of its contents. Tempest lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 553, and therefore denies them. 554. 555. Tempest denies the allegations in paragraph 554. Paragraph 555 purports to characterize GAAS Statement of Auditing Standards

No. 82. That statement speaks for itself, and Tempest respectfully refers the Court to the full standard for a complete understanding of its contents. Tempest lacks sufficient knowledge or

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information to admit or deny any remaining allegations in paragraph 555, and therefore denies them. 556. 557. Tempest 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 557 and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 558, and therefore denies them. 5. 559. 560. Andersen Approved and Promoted Qwest's Accounting Practices

Tempest denies the allegations in paragraph 559. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 560, and therefore denies them. 561. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 561, and therefore denies them. 562. 563. 564. Tempest adopts and incorporates Qwest's Answer to paragraph 562. Tempest adopts and incorporates Qwest's Answer to paragraph 563. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 564, and therefore denies them.

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565.

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 565, and therefore denies them. 566. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 566, and therefore denies them. C. 567. The Citigroup Defendants' Knowledge and Scienter Because the allegations in paragraph 567 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest denies the allegations in the first two sentences of paragraph 567. Tempest lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 567, and therefore denies them. 568. Tempest lacks sufficient information or knowledge to admit or deny the

allegations in paragraph 568, and therefore denies them. 569. 570. Tempest adopts and incorporates Qwest's Answer to paragraph 569. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 570, and therefore denies them. 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, Tempest denies the allegations in paragraph 571. 1. 572. SSB Issued False and Misleading Analyst Research Reports to Further Its Investment Banking Business

Because the allegations in paragraph 572 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient

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knowledge or information to admit or deny the allegations in paragraph 572, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 573, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 574, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 575, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 576, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 577, and therefore denies them.

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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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 578, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 579, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 580, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 581, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 582, and therefore denies them. 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, Tempest lacks sufficient

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knowledge or information to admit or deny the allegations in paragraph 583, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 584, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 585, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 586, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 587, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 588, and therefore denies them.

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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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 589, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 590, and therefore denies them. 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, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 591, and therefore denies them. 592. Because the allegations in paragraph 592 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 592, and therefore denies them. 593. Because the allegations in paragraph 593 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 593, and therefore denies them. 594. Because the allegations in paragraph 594 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient

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knowledge or information to admit or deny the allegations in paragraph 594, and therefore denies them. 595. Because the allegations in paragraph 595 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 595, and therefore denies them. 596. Because the allegations in paragraph 596 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 596, and therefore denies them. 597. Because the allegations in paragraph 597 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 597, and therefore denies them. 598. Because the allegations in paragraph 598 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 598, and therefore denies them. 599. Because the allegations in paragraph 599 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 599, and therefore denies them.

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600.

Because the allegations in paragraph 600 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 600, and therefore denies them. 601. Because the allegations in paragraph 601 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 601, and therefore denies them. 602. Because the allegations in paragraph 602 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 602, and therefore denies them. 603. Because the allegations in paragraph 603 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 603, and therefore denies them. 604. Because the allegations in paragraph 604 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 604, and therefore denies them. 605. Because the allegations in paragraph 605 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient

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knowledge or information to admit or deny the allegations in paragraph 605, and therefore denies them. 2. Grubman's Supervisors and Superiors Knew and Approved of Grubman's Overly Optimistic, False and Misleading Research Reports

606.

Because the allegations in paragraph 606 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 606, and therefore denies them. 607. Because the allegations in paragraph 607 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 607, and therefore denies them. 608. Because the allegations in paragraph 608 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 608, and therefore denies them. 609. Because the allegations in paragraph 609 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 609, and therefore denies them. 610. Because the allegations in paragraph 610 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient

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knowledge or information to admit or deny the allegations in paragraph 610, and therefore denies them. 3. 611. SSB Created a Compensation System That Specifically Motivated Grubman to Falsify His Research Reports

Because the allegations in paragraph 611 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 611, and therefore denies them. 612. Because the allegations in paragraph 612 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 612, and therefore denies them. 613. Because the allegations in paragraph 613 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 613, and therefore denies them. 614. Because the allegations in paragraph 614 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 614, and therefore denies them. 615. Because the allegations in paragraph 615 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient

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knowledge or information to admit or deny the allegations in paragraph 615, and therefore denies them. 616. Because the allegations in paragraph 616 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 616, and therefore denies them. 617. Because the allegations in paragraph 617 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 617, and therefore denies them. 618. Because the allegations in paragraph 618 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 618, and therefore denies them. 619. Because the allegations in paragraph 619 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 619, and therefore denies them. 4. 620. 621. SSB and Grubman Had Undisclosed Conflicts With Qwest

Tempest adopts and incorporates Qwest's Answer to paragraph 620. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 621, and therefore denies them.

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622. 623.

Tempest adopts and incorporates Qwest's Answer to Paragraph 622. Because the allegations in paragraph 623 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 623, and therefore denies them. 624. Because the allegations in paragraph 624 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 624, and therefore denies them. 625. Because the allegations in paragraph 625 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 625, and therefore denies them. 626. Because the allegations in paragraph 626 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 626, and therefore denies them. 627. Because the allegations in paragraph 627 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 627, and therefore denies them.

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5. 628.

Grubman's Research Reports Were Knowingly False and Misleading and Failed to Disclose Qwest's Accounting Improprieties

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 628, and therefore denies them. 629. 630. 631. Tempest denies the allegations in paragraph 629. Tempest denies the allegations in paragraph 630. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in the second sentence of paragraph 631, and therefore denies them. Tempest denies all other allegations in paragraph 631. 632. Because the allegations in paragraph 632 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 632 and therefore denies them. 633. 634. Tempest denies the allegations in paragraph 633. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in the last two sentences of paragraph 634, and therefore denies them. Tempest denies all other allegations in paragraph 634. a. 635. April 25, 2000 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 635, and therefore denies them. 636. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 636, and therefore denies them.

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637.

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 637, and therefore denies them. 638. Tempest denies the allegations in paragraph 638. b. 639. July 13, 2000 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 639, and therefore denies them. 640. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 640, and therefore denies them. 641. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 641, and therefore denies them. 642. Tempest denies the allegations in paragraph 642. c. 643. July 19, 2000 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 643, and therefore denies them. 644. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 644, and therefore denies them. 645. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 645, and therefore denies them. 646. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 646, and therefore denies them. 647. Tempest denies the allegations in paragraph 647.

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d. 648.

October 24, 2000 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 648, and therefore denies them. 649. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 649, and therefore denies them. 650. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 650, and therefore denies them. 651. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 651, and therefore denies them. 652. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 652, and therefore denies them. 653. Tempest denies the allegations in paragraph 653. e. 654. January 24, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 654, and therefore denies them. 655. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 655, and therefore denies them. 656. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 656, and therefore denies them. 657. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 657, and therefore denies them. 658. Tempest denies the allegations in paragraph 658.

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f. 659.

April 24, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 659, and therefore denies them. 660. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 660, and therefore denies them. 661. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 661, and therefore denies them. 662. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 662, and therefore denies them. 663. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 663, and therefore denies them. 664. Tempest denies the allegations in paragraph 664. g. 665. June 20, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 665, and therefore denies them. 666. Tempest admits that Morgan Stanley issued a report on June 20, 2001 in which

Qwest is discussed. Tempest lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 666, and therefore denies them. 667. Tempest denies the allegations in the first sentence of paragraph 667. Tempest

lacks sufficient knowledge or information to admit or deny any remaining allegations in paragraph 667, and therefore denies them.

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668.

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 668, and therefore denies them. 669. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 669, and therefore denies them. 670. Tempest denies the allegations in paragraph 670. h. 671. June 25, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 671, and therefore denies them. 672. 673. Tempest adopts and incorporates Qwest's Answer to paragraph 672. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 673, and therefore denies them. 674. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 674, and therefore denies them. 675. Tempest denies the allegations in paragraph 675. i. 676. July 24, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 676, and therefore denies them. 677. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 677, and therefore denies them. 678. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 678, and therefore denies them.

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679.

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 679, and therefore denies them. 680. Tempest denies the allegations in paragraph 680. j. 681. August 3, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 681, and therefore denies them. 682. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 682, and therefore denies them. 683. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 683, and therefore denies them. 684. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 684, and therefore denies them. 685. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 685, and therefore denies them. 686. Tempest denies the allegations in paragraph 686. k. 687. September 10, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 687, and therefore denies them. 688. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 688, and therefore denies them. 689. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 689, and therefore denies them.

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690.

Tempest denies the allegations in paragraph 690. l. September 27, 2001 SSB Analyst Report

691.

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 691, and therefore denies them. 692. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 692, and therefore denies them. 693. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 693, and therefore denies them. 694. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 694, and therefore denies them. 695. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 695, and therefore denies them. 696. Tempest denies the allegations in paragraph 696. m. 697. October 31, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 697, and therefore denies them. 698. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 698, and therefore denies them. 699. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 699, and therefore denies them. 700. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 700, and therefore denies them.

99

Case 1:01-cv-01451-REB-KLM

Document 835-4

Filed 10/04/2005

Page 25 of 25

701. 702.

Tempest denies the allegations in paragraph 701. Because the allegations in paragraph 702 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 702 and therefore denies them. 703. Because the allegations in paragraph 703 are directed at other Defendants, no

response is required. To the extent that a response is deemed necessary, Tempest lacks sufficient knowledge or information to admit or deny the allegations in paragraph 703 and therefore denies them. n. 704. December 10, 2001 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 704, and therefore denies them. 705. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 705, and therefore denies them. 706. Tempest denies the allegations in paragraph 706. o. 707. January 30, 2002 SSB Analyst Report

Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 707, and therefore denies them. 708. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 708, and therefore denies them. 709. Tempest lacks sufficient knowledge or information to admit or deny the

allegations in paragraph 709, and therefore denies them.

100