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The bank added: "The complaint is based on clear and substantial factual errors.
Insofar as the complaint is based on allegations of suppression or failure to disclose, the prosecutor should not, for the reasons set forth above, be absolutely immune.
But it isn't at all obvious that this complaint is based on fact – or quite why, even if it is, it's supposed to matter.
The South Korean complaint is based on a decision by the European Union that enables member countries to assist their shipbuilders in the face of South Korean competition.
Similar cases have failed, but the DoJ's complaint is based on a law passed in 1989 in response to the savings-and-loans crisis.
The plaintiffs' complaint is based on their contention that the exhibition or showing of the video cassettes in the private booths on defendants' premises constitutes an unauthorized public performance in violation of plaintiffs' exclusive rights under the federal copyright laws.
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John Frank, Microsoft's legal director for Europe, said the Sun Microsystems complaint was "based on its desire to gain access to our technical trade secrets".
In a statement released Thursday, the bank said the trustee's complaint was "based on distortions of both the relevant facts and the governing law".
The complaint was based on a report by the inspector general of the Federal Deposit Insurance Corporation focusing on Mrs. Clinton's actions for the savings and loan owned by her Whitewater partners, James and Susan McDougal.
In a statement released Thursday, the bank said the trustee's complaint was "based on distortions of both the relevant facts and the governing law". It denied that it had known about or played any role in Mr. Madoff's fraud and dismissed the claim that it turned a blind eye to his activities to retain income from his business.
Arguing repeatedly before the court that the complaint was based on valid facts when it wasn't, and lawyers should have known that.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com