With no explanation, chose the best option from "A", "B", "C" or "D". premium payments owed to the insurer which the client then paid to the broker. Id. (citing Unified Servs., Inc. v. Home Ins. Co., 218 Ga.App. 85, 460 S.E.2d 545 (Ga.Ct.App.1995)). 24 . In making these determinations, I have not relied on the Expert HR defendants' response to LM’s Rule 56.1 Statement. Under Local Rule 56.1(b), responses must contain "in the case of any disagreement, specific references to the affidavits, parts of the record, and other supporting materials relied upon.” The Expert HR defendants have not done so, but instead have issued unsupported denials for the vast majority of LM's Rule 56.1 Statement. This response is improper, and is therefore stricken. 25 . See, e.g., Am. Home Ins. Co. v. Travelers Indem. Co., 122 Cal.App.3d 951, 966, 175 Cal.Rptr. 826, 834 (1981) (<HOLDING>). 26 . As noted above, even if some other basis

A: recognizing that the corporate entity is disregarded to prevent fraud or an injustice not to inflict an obligation on an innocent corporation and that the fraud or inequity sought to be eliminated must be that of the party against whom the alter ego doctrine is invoked
B: holding jurisdiction over an individual may not usually be predicated on jurisdiction over a corporation unless the corporation is the alter ego of the individual or when the individual perpetrates a fraud
C: recognizing that the alter ego doctrine is an equitable doctrine which should be used to prevent inequitable results
D: holding an alter ego action could be brought by the debtor corporation under texas law
A.