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1
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ANSWER
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EXTRACTED KEY WORDS
PARAGRAPH DEFENDANTS ALLEGATIONS RESPONSE INFORMATION SUFFICIENT LAW TRUTH DEFENDANTS INCORPORATE REFERENCE DEFENDANTS DENY OFTHE COMPLAINT ADMIT COURT MCKAY PLAINTIFF DAMAGES OFFICER DEFENSE JURISDICTION FRIEDLANDER INVESTORS ALLIANCE JOHN COUNSEL HEREBY THEREIN ACCORD AFFAIRS AILEGATIONS ARUTH OFTTHE ALLEGATIONS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
BENEFICIAL, ASSURANCE, LTD.,
F/K'.% IMTEK FUNDING CORPORATION
Plaintiff, 1i
V. C.A. No. 18410 NC
i
CON SERVATIVE INVESTORS ALLIANCE, >
INC. and JOHN P. MCKAY
i
Defendants. 1
Defendants Conservative .Investors Alliance, Inc. ("CIA") and John P. McKay
("McKay"`), through their undersigned counsel, hereby respond to the correspondingly numbered
paragraphs of the plaintiff's Complaint, dated October 11, 2000, as follows:
I. The allegations of paragraph 1 of the Complaint are cc,,nclusions of law to which no
response is required. To the extent that a response is required, defendants deny the allegations
of parag:raph 1, except that they admit mat the plaintiffs Complaint seeks damages based on
theories of recovery asserted therein.
2. Defendants are without knowledge or information sufficient to form a belief as to the
truth of the allegations of paragraph 2 of the Complaint, except that defendants admit that
Bereficlal has traded from time to time as Beneficial Assistance. and has operated as a viatical
settlement company.
3. Admitted
4. Defendants admit the allegations of the first and second sentences of paragraph 4 of
the Complaint. The allegations of the third senrence of paragraph 4 of the Complaint are
conclusions of law to which no response is required. To the extent that a response is required,
SNIPPETS:
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2
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COMPLAINT
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EXTRACTED KEY WORDS
MCKAY FORMER OFFICERS AMOUNT BUSINESS EMBEZZLEMENT CONSPIRACY VIATICAL SETTLEMENTS FIDUCIARY DUTIES FRAUD INTENT COURT ALLEGATIONS SET PRECEDING PARAGRAPHS WHEREFORE EXPENSES LAWSUIT REASONABLE ATTORNEYS COMPENSATORY DAMAGES DEFENDANTS CONVERSION BREACHES COSTS PAYMENTS INCURRED LOSSES FUNDS CONNECTION REPRESENTATIONS PERSONAL GAIN FEES |
I
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
BENEFICIAL ASSURANCE, LTD., >
F/K/A IMTEK FUNDING CORPORATION )
>
Plaintiff, 1
V.
1 i
CONSERVATIVE INVESTORS
ALLIANCE, INC. and JOHN P. ;
MCKAY, .
i
Defendants. >
COMPLAINT
Plaintiff Beneficial Assurance, Ltd. t&la Imtek Funding Corporation, by its
undersigned attorneys, hereby alleges as follows:
Nature of the Action
1. This action arises from a scheme, by Defendants and Plaintiffs former
officers, to embezzle and convert to their own use $7,570,538.00 of Plaintiffs money.
Through this action, Plaintiff seeks compensation for those losses from Defendants for
their acts of fraud, conversion, civil conspiracy, and knowing participation in breaches of
fiduciary duties of Beneficial's former officers, and in order to prevent Defendants'
unjust enrichment.
Parties
2. Plaintiff Beneficial Assurance, Ltd. f/k/a Imtek Funding Corporation
("Beneficial") is a corporation organized under the laws of the State of Maryland with its
principal place of business located at 8003 Corporate Drive, Suite C, Baltimore,
Maryland `21236. Beneficial has traded from time to time as Beneficial Assistance. At
all times relevant hereto, Beneficial has operated as a viatical settlement company.
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