MEMORANDUM
MOTZ, District Judge.
This action arises from a stock purchase agreement (and related tax agreement) under which plaintiff, American Health and Life Insurance Company, sold the stock of one of its subsidiaries, American Health and Life Insurance Company of New York ("AHL-NY") to American Family Life Assurance Company of Columbus ("AFLAC"). Plaintiff asserts a claim against its former subsidiary, now named American Family Life Assurance Company...
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