IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF WEST VIRGINIA MYLAN PHARMACEUTICALS INC. and MYLAN INC., Plaintiffs, vs. Case No. 1:09-CV-138 Civil Action No. 09-C-592 (Monongalia Co, Circuit Court) PG PUBLISHING COMPANY, d/b/a PITTSBURGH POST-GAZETTE, PATRICIA, SABATINI, LEN BOSELOVIC, JOHN DOE 1, JOHN DOE 2, and JOHN DOE 3, Defendants. ANSWER OF DEFENDANT PG PUBLISHING COMPANY TO COMPLAINT OF PLAINTIFF MYLAN PHARMACEUTICALS. INC. For its Answer to the Complaint filed by Mylan Pharmaceuticals, Inc. (hereinafter the “Plaintiff” OR “MPT"), the Defendant PG Publishing Company, d/b/a Pittsburgh Post-Gazette, (hereinafter the “Defendant”), by and through its undersigned counsel, states as follows: PREFACE Bach and every averment set forth in the Complaint fails to distinguish between the Plaintiff Mylan, Inc. and the Plaintiff Mylan Pharmaceuticals, Inc., which exist and are treated as separate and distinct legal entities, For purposes of this Answer, all averments are answered as to only the Plaintiff Mylan Pharmaceuticals, Inc. The averments of the Plaintiff Mylan, Inc. are the subject of a contemporaneously filed Motion to Dismiss. 1. The Defendant admits the allegations of paragraph 1 of the Plaintiff's Complaint. 2. The Defendant admits the allegations of paragraph 2 of the Plaintiff's Complaint.‘The Defendant is without sufficient information to admit or deny the allegations of paragraph 3 of the Plaintiff's Complaint and therefore denies the same. 4. The Defendant is without sufficient information to admit or deny the allegations of paragraph 4 of the Plaintiff's Complaint and therefore denies the same. 5. The Defendant is without sufficient information to admit or deny the allegations of paragraph 5 of the Plaintiff's Complaint and therefore denies the same. 6. The Defendant admits the allegations of paragraph 6 of the Plaintiff's Complaint. 7. The Defendant is without sufficient information to admit or deny the allegations of paragraph 7 of the Plaintiff's Complaint and therefore denies the same, 8 The Defendant is without sufficient information to admit or deny the allegations of paragraph 8 of the Plaintifi"'s Complaint and therefore denies the same. 9. Paragraph 9 of the Plaintiff's Complaint states a legal conclusion to which no response is required. To the extent that a response is required, the Defendant denies the same. 10, Paragraph 10 of the Plaintiff's Complaint states legal conclusions to which no response is required. To the extent that a response is required, the Defendant denies the same. i. ‘The Defendant is without sufficient information to admit or deny the allegations of paragraph 11 of the Plaintiff's Complaint and therefore denies the same. 12. The Defendant admits the allegations of paragraph 12 of the Plaintiff's Complaint. 13. The Defendant admits the allegations of paragraph 13 of the Plaintifi's Complaint.14, The Defendant admits the allegations of paragraph 14 of the Plaintiff's Complaint with the clarification that the correct mailing address of the Defendant Patricia Sabatini is “Jefferson Hills, Pennsylvania.” 15. The Defendant admits the allegations of paragraph 15 of the Plaintiff's ‘Complaint, 16. The Defendant admits the allegations of paragraph 16 of the Plaintiff's Complaint, 17. The Defendant admits the allegations of paragraph 17 of the Plaintiff's Complaint. 18. Paragraph 18 of the Plaintiff's Complaint contains a definition to which no response is required. However, to the extent a response is required, the Defendant denies the same, 19. The Defendant denies that it received confidential, proprietary or privileged documents and denies that it did anything improper in obtaining documents. ‘The Defendant is without sufficient information to admit or deny the remaining allegations of paragraph 19 of the Plaintiff's Complaint and therefore denies the same. 20, The Defendant admits the allegations of paragraph 20 of the Plaintiff's Complaint. 21. The Defendant denies the allegations of paragraph 21 of the Plaintiff's Complaint. 22, The Defendant is without sufficient information to admit or deny the allegations of paragraph 22 of the Plaintiff's Complaint and therefore denies the same. 23. The Defendant denies the allegations of paragraph 23 of the Plaintiff's Complaint.