On its website, in its annual report and in some tax filings, UPMC purports to have employees -- sometimes tens of thousands of them, the city of Pittsburgh's attorneys said in a court filing. The amended complaint, filed Monday, comes in response to arguments made by a UPMC attorney last week that the medical conglomerate employs no one and therefore is not subject to payroll preparation taxes. The city sued UPMC on March 20 to strip it of its purely public charity status, which affords many of its subsidiaries and properties exemptions from taxes, including property and payroll taxes.