IN
THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY
DEPARTMENT, CHANCERY DIVISION
| INDEPENDENT TRUST CORP. |
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Plaintiff,
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No. 00 CH 08270
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| LAURENCE W. CAPRIOTTI, et al., |
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Defendants. |
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ANSWER TO COMPLAINT
NOW COMES the
Defendant, ALAN L. HURWICK, by and through his attorney, DENNIS A. BERKSON,
and for his Answer to the Complaint of the Plaintiff, states as follows:
1. Defendant, ALAN L. HURWICK, invokes his Fifth
Amendment privilege against self-incrimination as to each and every allegation
contained in Paragraphs 1 through 75 inclusive.
2. As to Count I, Defendant, ALAN L. HURWICK, makes no
answer, as the allegations contained in Count I are not directed towards
Defendant.
3. As to Count II, Defendant, ALAN L. HURWICK, invokes
his Fifth Amendment privilege against self-incrimination as to each and every
allegation contained in Count II and each subparagraph thereunder.
4. As to Count III, Defendant, ALAN L. HURWICK, makes
no answer, as the allegations contained in Count III are not directed towards
Defendant.
5. As to Count IV, Defendant, ALAN L. HURWICK, invokes
his Fifth Amendment privilege against self-incrimination as to each and every
allegation contained in Count IV and each subparagraph thereunder.
6. As to Count V, Defendant, ALAN L. HURWICK, makes no
answer, as the allegations contained in Count V are not directed towards
Defendant.
7. As to Count VI, Defendant, ALAN L. HURWICK, invokes
his Fifth Amendment privilege against self-incrimination as to each and every
allegation contained in Count VI and each subparagraph thereunder.
WHEREFORE, the Defendant, ALAN L. HURWICK, prays that the Complaint
of the Plantiff be dismissed in its entirety and that no relief be afforded
whatsoever thereunder.
VERIFICATION
Alan L.
Hurwick, being first duly sworn, on oath, deposes and states that he
has read the foregoing Answer to Complaint, and that the contents of
same are true to the best of his knowledge and belief.