In response to Paragraph 24 of the Complaint, Defendant is without knowledge and

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