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Sony VS Moursy Amended Answer With Counterclaims

Sony VS Moursy Amended Answer With Counterclaims - IN THE...

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA Civil Action No. 5:08-CV-00131-D SONY BMG MUSIC ENTERTAINMENT, Inc., UMG RECORDINGS Inc., ELECTRA ENTERTAINMENT GROUP, Inc., BMG MUSIC, and MOTOWN RECORD COMPANY, L.P., Plaintiffs/Counterclaim Defendants, vs. SHAHANDA MOELLE MOURSY, Defendant/ Counterclaim Plaintiff/Third-party Plaintiff, vs. RIAA, and SAFENET, Inc. f/k/a MEDIASENTRY, Inc., a Delaware corporation, , Third-party Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) FIRST AMENDED ANSWER, DEFENSES, COUNTERCLAIM, AND THIRD PARTY COMPLAINT DEFENDANT, Shahanda Noelle Moursy, answering the Complaint of the Plaintiffs, avers: 1. Paragraph 1 of the First Amended Complaint (“Complaint”) states a conclusion of law which the responding Defendant believes requires no answer; to the extent a response is required, Defendant denies the allegations in Paragraph 1 of the Complaint.
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2. Paragraph 2 of the Complaint states a conclusion of law which the responding Defendant believes requires no answer; to the extent a response is required, Defendant denies the allegations in Paragraph 2 of the Complaint. Moreover, this Defendant denies that any acts of infringement occurred. 3. Defendant admits that she resides within the judicial district. Defendant denies that any acts of infringement occurred. Except as herein admitted, Paragraph 3 of the Complaint states a conclusion of law which the responding Defendant believes requires no answer; to the extent a response is required, Defendant denies the remaining allegations in Paragraph 3 of the Complaint. 4. Defendant lacks information sufficient to admit or deny the allegations in Paragraph 4 of the Complaint and therefore denies same. 5. Defendant lacks information sufficient to admit or deny the allegations in Paragraph 5 of the Complaint and therefore denies same. 6. Defendant lacks information sufficient to admit or deny the allegations in Paragraph 6 of the Complaint and therefore denies same. 7. Defendant lacks information sufficient to admit or deny the allegations in Paragraph 7 of the Complaint and therefore denies same. 8. Defendant lacks information sufficient to admit or deny the allegations in Paragraph 8 of the Complaint and therefore denies same. 9. Defendant admits that she resides within this judicial district. Except as herein admitted, the allegations of Paragraph 9 of the Complaint are denied. 10. Defendant reasserts and realleges the responses in Paragraph 1 through 9 above.
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11. Defendant admits that a document purporting to be a copy of Certificate of Copyright Registration is attached to the Complaint as Exhibit A. Defendant lacks information sufficient to admit or deny the remaining allegations in Paragraph 11 of the Complaint and therefore denies same. 12. Paragraph 12 of the Complaint states a conclusion of law which the responding Defendant believes requires no answer; to the extent a response is required, Defendant denies the allegations in Paragraph 12 of the Complaint.
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