Case 3:15-cv-00495-MHL Document 6 Filed 10/16/15 Page 8 of 9 PageID# 32
SEVENTH DEFENSE Defendant is not a proper party to this suit because it does not insure, or otherwise fund, the benefits Plaintiff seeks and is not otherwise liable for such benefits. Matrix has no obligation to fund benefits. EIGHTH DEFENSE Plaintiff has failed to join a necessary or indispensable party. One or more entities within the Federal Reserve System self-fund the benefits Plaintiff seek and is or are necessary and/or indispensable parties to this action. WHEREFORE, having fully answered the Complaint, Defendant requests that the Court dismiss the same and enter an order awarding Defendant’s costs, attorney fees, and such other relief as the Court deems proper. This 16th day of October, 2015. Respectfully submitted, ________/s/ Marianne Roach Casserly Virginia Bar No. 45254 Counsel to Matrix Absence Management, Inc. ALSTON & BIRD LLP 950 F Street, NW Washington, DC 20004 Telephone: (202) 756-3379 Facsimile: (202) 654-4989 marianne.casserly@alston.com
8 LEGAL02/35895648v3
Ex. M, p. 27
