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 UNITED STATES DISTRICT COURTDISTRICT OF MASSACHUSETTS- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - xMASSACHUSETTS MUSEUM OFCONTEMPORARY ART FOUNDATION,INC.,Plaintiff,v.CHRISTOPH BÜCHEL,Defendant.:::::Civil ActionNo. 3:07-cv-30089-MAP
JURY TRIAL DEMANDED
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PLAINTIFF'S REPLY TO DEFENDANT'S COUNTERCLAIMS
Plaintiff Massachusetts Museum of Contemporary Art Foundation, Inc. ("MASSMoCA") replies to the counterclaims set forth in the Answer And Counterclaims Of ChristophBüchel upon knowledge as to itself and otherwise upon information and belief as follows:("Introduction.") MASS MoCA avers that the three-page portion of the AnswerAnd Counterclaims Of Christoph Büchel that is entitled "Introduction" contains legalconclusions to which no response is required. To the extent that a response is deemed required,MASS MoCA denies each and every allegation contained in the Introduction, except that MASSMoCA admits that it entered into an agreement with Defendant Christoph Büchel ("Büchel")regarding a planned Exhibit to be located in MASS MoCA's football field-sized Building 5gallery, as further described in MASS MoCA's Complaint For Declaratory Relief ("Complaint").1.
 
MASS MoCA admits the allegations of paragraph 1.
1
 
1
References to numbered paragraphs refer to the portion of the Answer AndCounterclaims Of Christoph Büchel that begins on page 9 of that document and is entitled"Büchel's Counterclaims."
Case 3:07-cv-30089-MAP Document 14 Filed 07/12/2007 Page 1 of 19
 
 
22.
 
MASS MoCA admits the allegations of paragraph 2.3.
 
MASS MoCA is without knowledge or information sufficient to admit ordeny the allegations contained in paragraph 3, except that MASS MoCA admits that Büchelresides in Basel, Switzerland.4.
 
MASS MoCA is without knowledge or information sufficient to admit ordeny the allegations contained in paragraph 4, except that MASS MoCA admits that Büchel is anartist who has created large and complex art installations.5.
 
MASS MoCA denies each and every allegation contained in paragraph 5,and by way of further response refers to the allegations of its Complaint that accurately describethe events purportedly described by that paragraph.
 
6.
 
MASS MoCA denies each and every allegation contained in paragraph 6,and by way of further response refers to the allegations of its Complaint that accurately describethe events purportedly described by that paragraph.
 
7.
 
MASS MoCA denies each and every allegation contained in paragraph 7,and by way of further response refers to the allegations of its Complaint that accurately describethe events purportedly described by that paragraph.
 
8.
 
MASS MoCA denies each and every allegation contained in paragraph 8,and by way of further response refers to the allegations of its Complaint that accurately describethe events purportedly described by that paragraph.
 
9.
 
MASS MoCA denies each and every allegation contained in paragraph 9,and by way of further response refers to the allegations of its Complaint that accurately describethe events purportedly described by that paragraph.
Case 3:07-cv-30089-MAP Document 14 Filed 07/12/2007 Page 2 of 19
 
 
310.
 
MASS MoCA avers that the allegations contained in paragraph 10 arelegal conclusions to which no response is required. To the extent that a response is deemedrequired, MASS MoCA denies each and every allegation contained in paragraph 10, and by wayof further response refers to the allegations of its Complaint that accurately describe the eventspurportedly described by that paragraph.
 
11.
 
MASS MoCA denies each and every allegation contained in paragraph 11,and by way of further response refers to the allegations of its Complaint that accurately describethe events purportedly described by that paragraph.12.
 
MASS MoCA denies each and every allegation contained in paragraph 12,except that to the extent that paragraph purports to quote an e-mail and letter from JosephThompson, the Director of MASS MoCA, to Mr. Büchel dated September 16, 2006 (copies of ane-mail chain incorporating that e-mail, and the letter referenced in that e-mail, are attached heretoas Exhibit 1
2
), MASS MoCA refers to that document for its content, and by way of furtherresponse refers to the allegations of its Complaint that accurately describe the events purportedlydescribed by that paragraph.13.
 
MASS MoCA denies each and every allegation contained in paragraph 13,except that to the extent that paragraph purports to quote an e-mail and letter from Mr.Thompson to Mr. Büchel dated September 16, 2006 (copies of an e-mail chain incorporating thate-mail, and the letter referenced in that e-mail, are attached hereto as Exhibit 1), MASS MoCArefers to that document for its content, and by way of further response refers to the allegations of its Complaint that accurately describe the events purportedly described by that paragraph.
2
E-mail addresses and telephone numbers have been redacted from the Exhibits tothis public filing.
Case 3:07-cv-30089-MAP Document 14 Filed 07/12/2007 Page 3 of 19
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