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a LANGROCK SPERRY & Woot LLP
U.S. DISTRICT
DISTRICT OF yepuned RE QHP UNITED STATES DISTRICT COURT
FILED
FOR THE
DISTRICT OF VERMONT QMS Oct 9 AM g 39 COERK UNITED STATES EX REL. ROBERT BY_ HARRIS, DEPUTY npr Plaintiff, PUTY CLERK ‘ Civil Action v. Docket No. 2:05-cv-212 EPS, INC., FRED HUTCHINS, AND RICK FLETCHER, Defendant.
ANSWER OF DEFENDANTS EPS, INC., FRED HUTCHINS, AND RICK FLETCHER NOW COMES EPS, Inc., Fred Hutchins, and Rick Fletcher, by and through their attorneys Langrock Sperry & Wool, LLP, and hereby answers the Complaint as follows:
1. Admitted.
2. Admitted that EPS, Inc. is a Vermont corporation with its principal place of business at 687 Marshall Ave., Suite 200, Williston, Vermont; Fred Hutchins is President; and Rick Fletcher is General Manager; otherwise denied.
3. Denied for lack of information sufficient to form a belief that federal jurisdiction exists over the state law claim; otherwise admitted. 4, Admitted that EPS provided compliance and review services to Michigan State Housing Development Authority (“MSHDA”) with respect to MSHDA’s contract administration responsibilities for its Section 236/RAP/Rent Supp rental subsidy programs; otherwise denied.
5. Denied.
6. Denied.
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yt LANGROCK SPERRY & WooLt LLP
Case 2:05-cv-00212-wks Document 11 Filed 10/03/2005 Page 2of4
7. Admitted that Harris sent Rick Fletcher an email on January 12, 2004; otherwise denied.
8. Denied.
9. Admitted that Harris received a written evaluation on February 6, 2004; otherwise denied.
10. Denied for lack of information sufficient to form a belief.
11. Admitted that Harris sent an email on about March 24, 2004; otherwise denied.
12. Denied.
13. Denied for lack of information sufficient to form a belief.
14. Count I has been dismissed with prejudice; therefore no responsive pleading is required.
15. | Count I has been dismissed with prejudice; therefore no responsive pleading is required.
16. Count I has been dismissed with prejudice; therefore no responsive pleading is required.
17. Answer as alleged.
18. Denied.
19. Denied.
Affirmative Defenses
1. Failure to state a claim;
2. After-acquired evidence justified termination;
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LANGROCK SPERRY
& WooLt LLP
Case 2:05-cv-00212-wks Document 11 Filed 10/03/2005 Page 3of4
355716.1
DATED at Burlington, Vermont this 30 day of Septewte- , 2005.
LANGROCK SP Y & WOOL, LLP
Lisa B. Shelkrot
PO Box 721, 210 College Street Burlington, VT 05402
(802) 864-0217
Attorneys for Defendant EPS, Inc., Fred Hutchins, and Rick Fletcher
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LANGROCK SPERRY
& WooL LLP
Case 2:05-cv-00212-wks Document 11 Filed 10/03/2005 Page4of4
UNITED STATES DISTRICT COURT
FOR THE
DISTRICT OF VERMONT
UNITED STATES EX REL. ROBERT
HARRIS,
Plaintiff,
Civil Action
v. Docket No. 2:05-cv-212
EPS, INC., FRED HUTCHINS, AND
RICK FLETCHER,
Defendant.
CERTIFICATE OF SERVICE
This is to certify that on the 30th day of September, 2005, I, Lisa B. Shelkrot, attorney for the Defendant, served a copy of the Answer of Defendants, EPS, Inc., Fred Hutchins and Rick Fletcher by mailing a copy of the same first-class, postage prepaid to the Plaintiff's attorney, John L. Franco, Jr., Esq.
Law Offices of John L. Franco, Jr.
110 Main Street Burlington, VT 05401
DATED at Burlington, Vermont this 30th day of September, 2005.
LANGROCK SPERRY & WOOL, LLP
By: Lisa B. Shelkrot PO Box 721, 210 College Street Burlington, VT 05402
Attorneys for Defendant
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