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Ramos, Rivera & Rodriguez, Inc. (RRR Inc.) constructs, owns and manages 30 shopping malls in 12 states of the U.S. RRR Inc. has offices only

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Ramos, Rivera & Rodriguez, Inc. (RRR Inc.) constructs, owns and manages 30 shopping malls in 12 states of the U.S. RRR Inc. has offices only in California. In each of the other 11 states, RRR Inc. created a different subsidiary corporation, e.g. "RRR Colorado Inc." The sole shareholder of each of the subsidiary companies is RRR Inc. Each of the eleven subsidiary corporations has separate financial accounts, however often rely on loans from RRR Inc. and pay out all dividends to the sole shareholder, RRR Inc. Each of the 11 subsidiary corporations has the same board of directors as does RRR Inc., i.e. Ramos, Rivera & Rodriguez. Mirji, Inc. entered a construction contract with RRR Colorado Inc. and alleges that RRR Colorado Inc. has wrongfully failed to pay them. Mirji, Inc. seeks to sue RRR Inc. in addition to RRR Colorado Inc. The strongest argument supporting Mirji in its suit against RRR Inc. is that RRR Inc's best argument that they cannot be sued for RRR Colorado Inc.'s conduct is that: Creating separate corporations to avoid liability is not an improper purpose and the separate funding accounts show separateness, Creating separate corporations to avoid liability is not an improper purpose and the overlapping directorate shows separateness Creating separate corporations to avoid liability is an improper purpose, however it is mitigated by the fact that there were separate financial accounts. O Creating separate corporations to avoid liability is an improper purpose, however it is mitigated by the fact that there was an overlapping directorate

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