The complaint is totally devoid of factual, or even conclusory, allegations tending to show defendant parent's liability for the subject transactions. This pleading defect is not remedied by either the documents that plaintiff submitted in opposition to the motion, which nowhere mention the parent, or plaintiff's affidavit, which contains no evidence of self-dealing, commingling of funds, lack of corporate formalities or other veilpiercing indicia (see, International...
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