IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO. Plaintiffs, ) CASE NO. 08 CVH vs- ) JUDGE LYNCH

Size: px
Start display at page:

Download "IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO. Plaintiffs, ) CASE NO. 08 CVH 12 18090. -vs- ) JUDGE LYNCH"

Transcription

1 IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO C. PAUL TIPPS, et al., ) Plaintiffs, ) CASE NO. 08 CVH vs- ) JUDGE LYNCH NEIL S. CLARK, et al., ) Defendants. ) ANSWER OF DEFENDANTS NEIL S. CLARK, NSC, INC. (ACTUALLY NSC CONSULTING CORP.), AND STATE STREET CONSULTING, LLC AND COUNTERCLAIMS OF NEIL S. CLARK, NSC CONSULTING CORP. AND STATE STREET CONSULTING, LLC Now come Defendants Neil S. Clark, NSC, Inc., and State Street Consultants, LLC and for their Answer to the Plaintiffs Complaint state as follows: FIRST DEFENSE: 1. Defendants admit the allegations contained in paragraphs 1, 6, 7, 10, 27, 28, 29, 30, 42, 55, 56, 57, 100 and Defendants deny each and every allegations contained in paragraphs 16, 18, 19, 20, 22, 25, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41,43, 44, 45, 46, 48, 49, 50, 51, 52, 53, 61, 62, 63, 64, 65, 68, 69, 75, 76, 77, 78, 81, 82, 85, 86, 87, 88, 89, 90, 93, 94, 98, 99, 102 and Defendants are without knowledge sufficient to form a belief in the truth of the allegations contained in paragraph 105, and therefore deny the allegation for want of knowledge. 1

2 4. With respect to the allegations contained in paragraphs 59, 60, 66, 67, 70, 71, 79, 80, 83, 84, 91, 92, 95, 96, 103 and 104, Defendants incorporate their admissions, denials and other responses as if fully rewritten herein. 5. With respect to the allegations contained in paragraph 2, Defendants admit that Neil S. Clark is an individual, however, deny that he is a resident of Franklin County, Ohio. 6. With respect to the allegations contained in paragraph 3, Defendants deny that from 1986 through 2005 Mr. Tipps and Mr. Clark were in business together as lobbyists; admit that in 1999 Mr. Tipps and Mr. Clark formed State Street Consultants, LLC and that Mr. Tipps retired in August of 2005; deny that Mr. Tipps remains a member of State Street Consultants, LLC. 7. With respect to the allegations contained in paragraph 4, Defendants admit that State Street Consultants, LLC is an Ohio limited liability company and that it engages in lobbying activities; deny that Mr. Tipps owns fifty percent (50%) of the membership interest in State Street Consultants, LLC, as well as the remaining allegations of paragraph With respect to the allegations contained in paragraph 5, Defendants deny that Mr. Tipps has any authority to participate in the management of State Street Consultants, LLC; admit that since Mr. Tipps retirement in August of 2005, Mr. Tipps has not participated in the day-to-day management of State Street Consultants, LLC; deny the remainder of the allegations of paragraph With respect to the allegations contained in paragraph 8, Defendants admit that Mr. Tipps is designated as the managing partner of State Street Partners in the Partnership 2

3 Agreement; admit that at the time of Mr. Tipps retirement he abandoned his management obligations; admit that in 2008 Mr. Tipps became actively involved in management of the Property; deny that Mr. Clark s behavior was at any time erratic or that Mr. Clark refused to meet with Fifth Third Bank to discuss the maturity date of the Loan; deny the remaining allegations of paragraph With respect to the allegations contained in paragraph 9, Defendants deny that Mr. Tipps has any ownership interest in State Street Consultants, LLC, admit that both Mr. Tipps and Mr. Clark own other businesses and that Mr. Tipps owns Public Policy Consultants, Inc.; deny the remaining allegations of paragraph With respect to the allegations contained in paragraph 11, Defendants are without knowledge sufficient to form a belief as to why Mr. Tipps has brought this action; admit that Mr. Clark was compensated for his services in 2006 and 2007; admit that certain business decisions were made that resulted in a delinquency in the payroll tax liability; deny that any employee 401(K) contributions were misdirected or that State Street Consultants has significant financial problems and deny the remaining allegations of paragraph With respect to the allegations contained in paragraphs 12, 13, 14 and 15, Defendants deny that Mr. Tipps is a member of State Street Consultants, LLC and, further state that the Operating Agreement speaks for itself, but is not relevant to the relationship between Mr. Tipps and Mr. Clark. 13. With respect to the allegations contained in paragraph 17, all reported employees of State Street Consultants, LLC, are actual persons (and not phantoms) that are employed and serve at the discretion of Mr. Clark. 3

4 14. With respect to the allegations contained in paragraph 21, Defendants admit that payroll taxes for December 2006 through December 2007 are delinquent, otherwise Defendants deny all other allegations contained therein. 15. With respect to the allegations contained in paragraph 23, Defendants admit that State Street Consultants, LLC, will move its offices to 495 South Grant Street; deny the remaining allegations of paragraph With respect to the allegations contained in paragraph 24, Defendants admit that Mr. Clark confirmed with The Dispatch the public record regarding the tax liability and liens; deny that confirmation of public information damaged the reputation of State Street Consultants, LLC. 17. With respect to the allegations contained in paragraph 26, Defendants admit that a Lease was entered into in 2001 and expired by its terms, and that State Street Consultants currently operates out of the Building owned by State Street Partners, LLP. 18. With respect to the allegations contained in paragraph 47, Defendants admit that the SERP contains a non-compete clause; however, the SERP does not become effective until February 1, With respect to the allegations contained in paragraph 54, Defendants admit that a Pledge Agreement was entered into, however, deny that the Pledge Agreement applies to the SERP. 20. With respect to the allegations contained in paragraph 58, Defendants admit that Mr. Clark has ceased paying the premiums on the life insurance policy owned by Mr. Tipps. 4

5 21. With respect to the allegations contained in 73 and 74, Defendants admit that Mr. Tipps and Mr. Clark owe reciprocal fiduciary duties to each other as partners in State Street Partners, LLP and deny that Mr. Clark is derelict with regard to any such duties. 22. With respect to the allegations contained in paragraph 97 and 106, Defendants admit that Mr. Tipps and Public Policy Consultants have certain rights, pursuant to the Pledge Agreement, to the assets of State Street Consultants, LLC, however, deny that the Pledge Agreement is applicable to the SERP. 23. Defendants specifically deny each and every allegation not expressly admitted to be true. SECOND DEFENSE: 24. Plaintiffs have failed to state a claim upon which relief can be granted. THIRD DEFENSE: 25. Plaintiffs have failed to join necessary and indispensable parties. FOURTH DEFENSE: 26. Plaintiffs own actions constitute breach of the agreements herein, relieving Defendants duties to perform thereunder. FIFTH DEFENSE: 27. Plaintiffs own actions have caused or contributed to Plaintiffs alleged damages. SIXTH DEFENSE: 28. Plaintiffs are not entitled to invoke the equity of the Court as they do not have clean hands. 5

6 SEVENTH DEFENSE: 29. Plaintiffs have an adequate remedy at law and are not entitled to extraordinary relief. EIGHTH DEFENSE: 30. Defendants reserve the right to add additional affirmative defenses after a reasonable opportunity to discover the full nature of Plaintiffs claims. COUNTERCLAIM OF DEFENDANTS / COUNTERCLAIMANTS NEIL CLARK, NSC CONSULTING CORP., and STATE STREET CONSULTANTS LLC Now come Defendants Neil S. Clark ( Clark ), NSC Consulting Corp. ( NSCCC ) and State Street Consultants, LLC ( SSC ) for their Counterclaims against Plaintiffs and state the following: PRELIMINARY STATEMENTS 1. State Street Consultants, LLC is an Ohio Limited Liability Company, the only active member and the sole Member Manager of which is Defendant-Counterclaimant Clark.Clark, NSCCC and SSC are defendants in the underlying civil actions set forth in the Complaint herein, brought by Plaintiffs C. Paul Tipps and Public Policy Consultants, Inc.. State Street Partners PLL (SSP) is an Ohio partnership with limited liability in which Tipps and Clark are partners and which owns the office building and land at 137 E. State St., in Columbus, Ohio. 2. For background purposes only, Clark incorporates the Plaintiffs Complaint and his Answer thereto as if fully re-written herein. 3. Jurisdiction and venue are appropriate in the Franklin County Court of Common Pleas. 6

7 FIRST COUNT - DEFAMATION 4. Plaintiff Tipps has made statements to various prominent individuals that were untrue and done in an effort to damage the reputation and defame Defendants- Counterclaimants Clark, NSCCC and SSC. 5. Plaintiff Tipp s false and defamatory statements have caused others to question the integrity and the financial stability of the Counterclaimants without basis, directly and proximately causing damages to the Counterclaimants. 6. Counterclaimants have suffered and will continue to suffer irreparable injury and damages for which there is no adequate remedy at law and are therefore entitled to preliminary and permanent injunctions preventing Plaintiff Tipps from making false and defamatory statements about the Counterclaimants. 7. Plaintiff Tipps defamatory statements were made with intent to harm Counterclaimants and were willful and wanton in nature, entitling Counterclaimants to punitive damages. SECOND COUNT - BREACH OF OPERATING AGREEMENT 8. On or about August 1, 1999, Defendants-Counterclaimants SSC, Clark and Plaintiff C. Paul Tipps entered into an Operating Agreement regarding the operation of SSC. 9. At all timers relevant herein, Plaintiff Tipps, as an alleged member of SSC, and pursuant to the Operating Agreement had a fiduciary duty to SSC and its other member, Clark. 10. Plaintiff Tipps has engaged in conduct in 2007 and 2008, that was in breach of said Operating Agreement, to wit: he voted as a member of the State Ballot Board when he should have abstained due to conflicts and potential conflicts of interests with SSC 7

8 and clients of SSC; he attempted to send or steer lobbying business to other enterprises than SSC; he engaged in various activities competitive with and damaging to SSC. 11. Said breaches have directly and proximately caused damages to Defendant- Counterclaimant SSC and require injunctive relief preventing Plaintiff Tipps from engaging in actions harmful to SSC and its operations and clients. THIRD COUNT - BREACH OF ASSET PURCHASE AGREEMENT 12. Plaintiffs Tipps and Public Policy Consultants, Inc. ( PPC ) entered into an Asset Purchase Agreement ( APA ) with SSC, effective January 1, 2006, in which SSC agreed to purchase the assets of PPC, and Tipps and PPC agreed to certain concessions in favor of SSC. A copy of the APA is attached to Plaintiffs Complaint as Exhibit D. 13. Upon information and belief, Plaintiff Tipps has engaged in conduct which has breached the terms of the APA, including specifically its non-competition clause and non-solicitation clause. 14. SSC has provided to Plaintiff Tipps through October 31, 2008, the following: a) chauffer large and exorbitant payments pursuant to the terms of the APA; b) the services of a, bookkeeper and secretary which have never been reimbursed to SSC by Plaintiff Tipps; c) sums paid to and on behalf of SSP over and above SSC s lease obligation which have directly benefited Plaintiff Tipps and PPC and which Plaintiffs have failed to reimburse SSC; all of which have combined to result in overpayments to Plaintiffs which have not been reimbursed to SSC in breach of the APA. 8

9 15. Said breaches have directly and proximately caused damages to Defendant- Counterclaimant SSC. FOURTH COUNT DISSOLUTION OF STATE STREET CONSULTANTS LLC 16. The preceding paragraphs are incorporated as if fully rewritten herein. 17. Plaintiff Tipps has caused the Complaint to be filed herein which contains allegations and requests for relief pursuant to which the enterprise cannot be operated in a practicable fashion by the Plaintiff Tipps and this Applicant/Counterclaimant. 18. Plaintiffs lawsuit and, upon information and belief, public statements unnecessarily disclose confidential information, private agreements and contracts to the detriment of Counterclaimants State Street Consultants, LLC and Clark, which are in violation of such agreements. 19. Plaintiff Tipps has engaged in conduct attempting to divert business away from SSC LLC, has competed with SSC LLC, and had engaged in conduct detrimental to the best interests of Defendant/Counterclaimant Clark and SSC. 20. All of the statements contained in this Count leads to the conclusion that it is no longer reasonably practicable to carry on the business of State Street Consultants, LLC, in conformity with its operating agreement, and, therefore, pursuant to Ohio Revised Code , Counterclaimant Clark hereby applies to this Court to judicially decree the dissolution of the State Street Consultants LLC. WHEREFORE, Defendant-Counterclaimants Clark, SSC and NSCCC demand judgment on its claims as follows: 9

10 On Count I, against Plaintiff Tipps in an amount yet undetermined but in excess of $25,000 in compensatory damages, injunctive relief as set forth herein and an amount in excess of $25,000 in punitive damages; On Count II, against Plaintiff Tipps in an amount yet undetermined but in excess of $25,000; on Count III, against Plaintiffs Tipps and PPC, jointly and severally, in an amount in excess of $25,000; and On Count IV, a judicially granted dissolution of State Street Consultants, LLC; and, Any and all further relief which this court deems fair and just. Respectfully submitted, ROBERT J. BEHAL LAW OFFICES, LLC Robert J. Behal ( ) John M. Gonzales, of Counsel ( ) 501 South High Street Columbus, Ohio Telephone No. (614) Facsimile No. (614) Attorneys for Defendants 10

11 CERTIFICATE OF SERVICE I certify that a copy of the foregoing Answer and Counterclaim was served via regular United States mail this day of, 2009, as follows: Dan L. Cvetanovich Yvette A. Cox Sabrina Haurin BAILEY CAVALIERI LLC One Columbus 10 West Broad Street, 21 st Floor Columbus, Ohio Attorneys for Plaintiffs Robert J. Behal ( ) John M. Gonzales ( ) 11

IN THE COURT OF CHANCERY OF THE STATE OF DELA WARE ANSWER AND AFFIRMATIVE DEFENSES OF DEFENDANT IHOR FIGLUS

IN THE COURT OF CHANCERY OF THE STATE OF DELA WARE ANSWER AND AFFIRMATIVE DEFENSES OF DEFENDANT IHOR FIGLUS EFiled: Oct 31201202:31P Transaction ID 47478356 Case No. 7936-VCP IN THE COURT OF CHANCERY OF THE STATE OF DELA WARE EMERGING EUROPE GROWTH FUND, L.P., and HORIZON CAPITAL GP LLC, a Delaware limited liability

More information

TERRENCE and Marie Domin, Plaintiffs, v. SHELBY INSURANCE COMPANY, a foreign corporation, Defendant.

TERRENCE and Marie Domin, Plaintiffs, v. SHELBY INSURANCE COMPANY, a foreign corporation, Defendant. Circuit Court of Illinois. County Department Chancery Division Cook County TERRENCE and Marie Domin, Plaintiffs, v. SHELBY INSURANCE COMPANY, a foreign corporation, Defendant. No. 00CH08224. 2008. Answer

More information

: : : : : : : : Plaintiffs, HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, and

: : : : : : : : Plaintiffs, HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, and SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------x HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, BRETT HICKEY, AEGIS ALABAMA

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER Case 1:14-cv-05919-JEI-KMW Document 19 Filed 02/13/15 Page 1 of 11 PageID: 84 Frank L. Corrado, Esquire Attorney ID No. 022221983 BARRY, CORRADO & GRASSI, PC 2700 Pacific Avenue Wildwood, NJ 08260 (609)

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. INFANT SWIMMING RESEARCH, INC., v. Plaintiff, FAEGRE & BENSON, LLP, MARK FISCHER, JUDY HEUMANN, NORMAN HEUMANN, BOULDER

More information

Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564

Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564 Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION ESTATE OF FRANK TOWNSEND, (by Fiduciary and Administrator

More information

Case: 1:13-cv-00903-SSB-SKB Doc #: 9 Filed: 03/11/14 Page: 1 of 5 PAGEID #: 31

Case: 1:13-cv-00903-SSB-SKB Doc #: 9 Filed: 03/11/14 Page: 1 of 5 PAGEID #: 31 Case: 1:13-cv-00903-SSB-SKB Doc #: 9 Filed: 03/11/14 Page: 1 of 5 PAGEID #: 31 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI THOMAS E. PEREZ, Secretary

More information

IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO

IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO STATE OF OHIO, ex rel. ) CASE NO. ATTORNEY GENERAL ) MICHAEL DEWINE ) JUDGE 30 E. Broad St., 14 th Floor ) Columbus, Ohio 43215 ) ) PLAINTIFF, ) ) V.

More information

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Calvin L. Keith, OSB No. 814368 CKeith@perkinscoie.com Sarah J. Crooks, OSB No. 971512 SCrooks@perkinscoie.com PERKINS COIE LLP

More information

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13 Case -00-LT Filed 0// Entered 0// :: Doc Pg. of NANCY L. STAGG, CA Bar No. 0 nstagg@foley.com MATTHEW J. RIOPELLE, CA Bar No. 0 mriopelle@foley.com FOLEY & LARDNER LLP VALLEY CENTRE DRIVE, SUITE 00 SAN

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION OHIO REPUBLICAN PARTY, et al. : : Plaintiffs, : : Case No. 2:08CV913 v. : : JUDGE SMITH JENNIFER BRUNNER, : Secretary

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON ) ) ) ) ) ) ) ) ) ) ) ) ) Case :-cv-000-tor Document Filed 0/0/ 0 John T. John, WSBA # Daniel J. Oates, WSBA # 0 Alaskan Way, Suite 00 Seattle, Washington Telephone: ( -00 Email: jjohn@grahamdunn.com doates@grahamdunn.com Attorney

More information

INVESTMENT ADVISER REPRESENTATIVE AGREEMENT

INVESTMENT ADVISER REPRESENTATIVE AGREEMENT INVESTMENT ADVISER REPRESENTATIVE AGREEMENT This investment adviser representative agreement ( Agreement ), made as of, 20, is between Partners for Prosperity, Inc., a Nevada corporation, with the principal

More information

Defendants THE SPARTAN GROUP HOLDING COMPANY, LLC, SPARTAN INVESTMENT PARTNERS LP, SPARTAN INVESTMENT ASSOCIATES LP, SPARTAN

Defendants THE SPARTAN GROUP HOLDING COMPANY, LLC, SPARTAN INVESTMENT PARTNERS LP, SPARTAN INVESTMENT ASSOCIATES LP, SPARTAN Case 1:08-cv-06554-JFK Document 3 Filed 07/25/2008 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x CRIMSON CAPITAL LLC and MICHAEL STAISIL, : Plaintiffs, : v. : 08 Civ. 6554 (JFK)

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION DEFENDANT S COUNTERCLAIM

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION DEFENDANT S COUNTERCLAIM UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION NATIONAL UNION FIRE INSURANCE ) COMPANY OF PITTSBURGH, PA, ) ) Plaintiff, ) Case No. 3:10-cv-00743 ) Judge Campbell v. ) Magistrate

More information

Case 3:06-cv-00701-MJR-DGW Document 526 Filed 07/20/15 Page 1 of 8 Page ID #13631 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ILLINOIS

Case 3:06-cv-00701-MJR-DGW Document 526 Filed 07/20/15 Page 1 of 8 Page ID #13631 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ILLINOIS Case 3:06-cv-00701-MJR-DGW Document 526 Filed 07/20/15 Page 1 of 8 Page ID #13631 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ILLINOIS ANTHONY ABBOTT, et al., ) ) No: 06-701-MJR-DGW Plaintiffs,

More information

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in Weld County, Colorado, District Court, 901 9 th Avenue Greeley, CO 80631 970.351.7300 Plaintiff: vs. Defendants: JENNIFER BELL, individually and on behalf of all others similarly situated, BRADLEY PETROLEUM,

More information

MONTANA EIGHTH JUDICIAL DISTRICT COURT, CASCADE COUNTY. Appearing on behalf of the Named Plaintiff and the Class were attorneys Daniel P.

MONTANA EIGHTH JUDICIAL DISTRICT COURT, CASCADE COUNTY. Appearing on behalf of the Named Plaintiff and the Class were attorneys Daniel P. ,5SEPV Wl0: 3ii /"'LCD JCOURT MONTANA EIGHTH JUDICIAL DISTRICT COURT, CASCADE COUNTY Robert Jacobsen, -vs- Allstate Insurance Company, Plaintiff, Defendant. Cause No.: ADV-03-201(d) Final Order Approving

More information

Defendant, by and through his attorneys LENOIR LAW FIRM, answering the complaint of plaintiff, upon information and belief,

Defendant, by and through his attorneys LENOIR LAW FIRM, answering the complaint of plaintiff, upon information and belief, CIVIL COURT OF THE CITY OF NEW YORK COUNTY OF QUEENS -----------------------------------X Index No. CV-079576-10/QU LR CREDIT 21, LLC ANSWER Plaintiff, Kenneth Chow - against - Defendant. -----------------------------------X

More information

IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division

IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division Document Page 1 of 15 IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division ) In re: ) Case No. 07-11440-RGM Ronald Steven Federici, ) Chapter 7 Debtor. ) ) ) W.

More information

Case 1:13-cv-00345-GK Document 8 Filed 06/24/13 Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:13-cv-00345-GK Document 8 Filed 06/24/13 Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Case 1:13-cv-00345-GK Document 8 Filed 06/24/13 Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ELECTRONIC PRIVACY INFORMATION CENTER 1718 Connecticut Avenue, N.W. Suite 200 Washington,

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 1 1 1 1 Sterling A. Brennan (CA State Bar No. 01) E-Mail: sbrennan@mabr.com Tyson K. Hottinger (CA State Bar No. 1) E-Mail: thottinger@mabr.com MASCHOFF BRENNAN LAYCOCK GILMORE ISRAELSEN & WRIGHT, PLLC

More information

BROKER AGREEMENT. NOW THEREFORE, in consideration of promises, covenants and agreements hereinafter contain, the parties agree as follows:

BROKER AGREEMENT. NOW THEREFORE, in consideration of promises, covenants and agreements hereinafter contain, the parties agree as follows: THIS AGREEMENT is entered into in the State of California this day of 2006, between Crestline Funding Corporation, hereinafter referred to as Crestline Funding, and, hereinafter referred to as Broker.

More information

Case 2:14-cv-00445-CW-BCW Document 62 Filed 10/20/14 Page 1 of 6

Case 2:14-cv-00445-CW-BCW Document 62 Filed 10/20/14 Page 1 of 6 Case 2:14-cv-00445-CW-BCW Document 62 Filed 10/20/14 Page 1 of 6 Karra J. Porter, 5223 Karra.Porter@chrisjen.com David C. Richards, 6023 David.Richards@chrisjen.com CHRISTENSEN & JENSEN, P.C. 15 West South

More information

INSTRUCTIONS TO ANSWER A COMPLAINT

INSTRUCTIONS TO ANSWER A COMPLAINT INSTRUCTIONS TO ANSWER A COMPLAINT Use our forms at your own risk. Any desired outcome from the use of this form cannot be predicted or guaranteed. In no event will the CIU of Legal Aid of North Carolina

More information

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA DEAN KUMANCHIK, vs. Plaintiff, Case No.: UNIVERSAL CITY DEVELOPMENT PARTNERS, LTD d/b/a UNIVERSAL STUDIOS, a Florida

More information

NC General Statutes - Chapter 55 Article 14 1

NC General Statutes - Chapter 55 Article 14 1 Article 14. Dissolution. Part 1. Voluntary Dissolution. 55-14-01. Dissolution by incorporators or directors. (a) The board of directors or, if the corporation has no directors, a majority of the incorporators

More information

CLARK COUNTY, NEVADA. ANSWER ) Defendant. ) )

CLARK COUNTY, NEVADA. ANSWER ) Defendant. ) ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ANS (NAME) (ADDRESS) (CITY, STATE, ZIP) (TELEPHONE) Defendant Pro Se DISTRICT COURT CLARK COUNTY, NEVADA ) ) Case No.: Plaintiff,

More information

COMPLAINT. Plaintiff, Comfort Dental ( Comfort Dental ), by its attorneys, MOYE WHITE LLP, INTRODUCTION

COMPLAINT. Plaintiff, Comfort Dental ( Comfort Dental ), by its attorneys, MOYE WHITE LLP, INTRODUCTION JEFFERSON COUNTY DISTRICT COURT, STATE OF COLORADO Address: 100 Jefferson County Parkway Golden, Colorado 80401 Telephone: (303) 271-6145 Plaintiff: COMFORT DENTAL GROUP, INC., a Colorado Corporation,

More information

Case3:13-cv-02858-JST Document27 Filed11/27/13 Page1 of 14

Case3:13-cv-02858-JST Document27 Filed11/27/13 Page1 of 14 Case:-cv-0-JST Document Filed// Page of 0 Clayeo C. Arnold, California SBN 00 carnold@justiceyou.com Christine M. Doyle, California SBN 0 cdoyle@justiceyou.com CLAYEO C. ARNOLD, A PROFESSIONAL LAW CORPORATION

More information

Case 1:15-cv-23825-KMW Document 11 Entered on FLSD Docket 01/28/2016 Page 1 of 8 UNTIED STATE DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case 1:15-cv-23825-KMW Document 11 Entered on FLSD Docket 01/28/2016 Page 1 of 8 UNTIED STATE DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case 1:15-cv-23825-KMW Document 11 Entered on FLSD Docket 01/28/2016 Page 1 of 8 DAVID BALDWIN, v. Plaintiff, ANTHONY FOXX, in his official capacity as Secretary of The United States Department of Transportation,

More information

AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF SCIENCE APPLICATIONS INTERNATIONAL CORPORATION

AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF SCIENCE APPLICATIONS INTERNATIONAL CORPORATION AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF SCIENCE APPLICATIONS INTERNATIONAL CORPORATION FIRST: NAME. The name of the Corporation is Science Applications International Corporation. SECOND: ADDRESS.

More information

The Honorable Chairman and Members of the Board of County Commissioners

The Honorable Chairman and Members of the Board of County Commissioners TO: FROM: The Honorable Chairman and Members of the Board of County Commissioners James L. Bennett, County Attorney ~ COMMISSION AGENDA,#':.ett~ -:# /H, SUBJECT: DATE: Notice ofnew Lawsuit and Defense

More information

JOHN MURRAY ( Murray ), for his Complaint in this action against Defendant, Crystex Composites LLC ( Crystex ), alleges as follows:

JOHN MURRAY ( Murray ), for his Complaint in this action against Defendant, Crystex Composites LLC ( Crystex ), alleges as follows: Case 2:08-cv-02672-WHW-CCC Document 1 Filed 05/29/08 Page 1 of 10 ROBERT J. BASIL, ESQ. (RB3410) Collier & Basil, P.C. 1270 Broadway, Suite 305 New York, NY 10001 (917) 512-3066 (831) 536-1075 (fax) Attorneys

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION NANCY PRITCHARD, v. Plaintiff, Case No.: KAPLAN HIGHER EDUCATION CORPORATION; KAPLAN HIGHER EDUCATION CORPORATION, as PLAN ADMINISTRATOR;

More information

FILED: NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/17/2014

FILED: NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/17/2014 FILED NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF 01/17/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK - - - - - - - - - - - - - - - - - - -

More information

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION ELECTRONICALLY FILED 5/18/2012 2:30 PM CV-2012-901583.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION ZACHARY

More information

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8 Case :0-cv-0-JCM-LRL Document Filed 0//0 Page of Reno, NV ( -00 Fax ( 0-0 0 Mark R. Thierman, NV# laborlawyer@pacbell.net THIERMAN LAW FIRM, P.C. Reno, Nevada Tel: ( -00 Fax: ( 0-0 David R. Markham, CAL#

More information

SETTLEMENT AGREEMENT AND RELEASE

SETTLEMENT AGREEMENT AND RELEASE SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release ( Agreement ) is made and entered into by and between Cheryl Coryea ( Coryea or Plaintiff ), and Rochester Independent School District

More information

Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 Civil Action No. 12-CV-3270 BALBOA INSURANCE COMPANY, Plaintiff v. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

More information

v. VERIFIED ANSWER TO FORECLOSURE COMPLAINT

v. VERIFIED ANSWER TO FORECLOSURE COMPLAINT SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF v. Plaintiff, Index No. VERIFIED ANSWER TO FORECLOSURE COMPLAINT Defendant(s). Defendant answers as follows: I generally deny each allegation of the Complaint,

More information

Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DESTINY ANNMARIE RIOS Plaintiff VS. CIVIL ACTION NO. 5:14-cv-00590

More information

RESTATED CERTIFICATE OF INCORPORATION CTC MEDIA, INC. (Pursuant to Section 242 and 245 of the General Corporation Law of the State of Delaware)

RESTATED CERTIFICATE OF INCORPORATION CTC MEDIA, INC. (Pursuant to Section 242 and 245 of the General Corporation Law of the State of Delaware) RESTATED CERTIFICATE OF INCORPORATION OF CTC MEDIA, INC (Pursuant to Section 242 and 245 of the General Corporation Law of the State of Delaware) CTC Media, Inc., a corporation organized and existing under

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case :-cv-0 Document Filed 0/0/ Page of 0 0 JANET M. HEROLD Regional Solicitor IAN H. ELIASOPH (CSBN Counsel for ERISA GRACE A. KIM, Trial Attorney (CSBN Office of the Solicitor United States Department

More information

MARC D. LAVIK, : : Plaintiff, : : v. : C.A. No. PC 11- : DIVISION OF MOTOR VEHICLES, : DEPARTMENT OF REVENUE, : STATE OF RHODE ISLAND, : COMPLAINT

MARC D. LAVIK, : : Plaintiff, : : v. : C.A. No. PC 11- : DIVISION OF MOTOR VEHICLES, : DEPARTMENT OF REVENUE, : STATE OF RHODE ISLAND, : COMPLAINT STATE OF RHODE ISLAND PROVIDENCE, SC SUPERIOR COURT MARC D. LAVIK, Plaintiff, v. C.A. No. PC 11- DIVISION OF MOTOR VEHICLES, DEPARTMENT OF REVENUE, STATE OF RHODE ISLAND, Defendant. COMPLAINT Parties and

More information

Case 1:05-cv-03493-JGK Document 1 Filed 04/04/05 Page 1 of 6. Plaintiff, : Civ. No. 05cv3493

Case 1:05-cv-03493-JGK Document 1 Filed 04/04/05 Page 1 of 6. Plaintiff, : Civ. No. 05cv3493 Case 1:05-cv-03493-JGK Document 1 Filed 04/04/05 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X ALEJANDRO

More information

HOW TO FILE AN ANSWER

HOW TO FILE AN ANSWER PRO SE OFFICE UNITED STATES DISTRICT COURT DANIEL PATRICK MOYNIHAN UNITED STATES COURTHOUSE 500 PEARL STREET, ROOM 230 NEW YORK, NEW YORK 10007 Ruby J. Krajick CLERK OF COURT HOW TO FILE AN ANSWER An answer

More information

Case 5:02-cv DDD Document 78 Filed 03/31/2003 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION

Case 5:02-cv DDD Document 78 Filed 03/31/2003 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION Case 5:02-cv-02028-DDD Document 78 Filed 03/31/2003 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION EFFIE STEWART, et al., : : Plaintiffs, : : v. : CASE

More information

IN THE SUPERIOR COURT OF CHATHAM COUNTY STATE OF GEORGIA

IN THE SUPERIOR COURT OF CHATHAM COUNTY STATE OF GEORGIA IN THE SUPERIOR COURT OF CHATHAM COUNTY STATE OF GEORGIA ROBERT DOWSE AND URSULA DOWSE ) ) Plaintiffs, ) v. ) CIVIL ACTION NUMBER: ) CV99-0302-BA ) SOUTHERN GUARANTY INSURANCE ) COMPANY ) ) Defendant,

More information

FIFTH RESTATED CERTIFICATE OF INCORPORATION OF THE CHARLES SCHWAB CORPORATION (Effective May 7, 2001)

FIFTH RESTATED CERTIFICATE OF INCORPORATION OF THE CHARLES SCHWAB CORPORATION (Effective May 7, 2001) FIFTH RESTATED CERTIFICATE OF INCORPORATION OF THE CHARLES SCHWAB CORPORATION (Effective May 7, 2001) (Originally incorporated on November 25, 1986, under the name CL Acquisition Corporation) FIRST. The

More information

COMPLAINT. Plaintiff [PLAINTIFF] hereby sues the Defendants, [DEFENDANT #1], [DEFENDANT INTRODUCTION

COMPLAINT. Plaintiff [PLAINTIFF] hereby sues the Defendants, [DEFENDANT #1], [DEFENDANT INTRODUCTION Form 2:40-2 Complaint Negligence, Motor Vehicle IN THE CIRCUIT COURT OF THE ## JUDICIAL CIRCUIT IN AND FOR [COUNTY], FLORIDA [PLAINTIFF], Plaintiff, CASE NO.: ##-##### ## ## GENERAL JURISDICTION vs. [DEFENDANT

More information

AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF EVERBANK FINANCIAL CORP

AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF EVERBANK FINANCIAL CORP AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF EVERBANK FINANCIAL CORP EverBank Financial Corp, a corporation organized and existing under and by virtue of the provisions of the General Corporation

More information

CUSTOMER LIST PURCHASE AGREEMENT BY AND BETWEEN RICHARD PENNER SELLER. and S&W SEED COMPANY BUYER

CUSTOMER LIST PURCHASE AGREEMENT BY AND BETWEEN RICHARD PENNER SELLER. and S&W SEED COMPANY BUYER EXHIBIT 10.1 CUSTOMER LIST PURCHASE AGREEMENT BY AND BETWEEN RICHARD PENNER as SELLER and S&W SEED COMPANY as BUYER CUSTOMER LIST PURCHASE AGREEMENT THIS CUSTOMER LIST PURCHASE AGREEMENT ( Agreement )

More information

UNITED STATES DISTRICT COURT DISTRICT OF OREGON EUGENE DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF OREGON EUGENE DIVISION Lake James H. Perriguey, OSB No. 983213 lake@law-works.com LAW WORKS LLC 1906 SW Madison Street Portland, OR 97205-1718 Telephone: (503) 227-1928 Facsimile: (503) 334-2340 Lea Ann Easton, OSB No. 881413

More information

INTRODUCTION. States Constitution and 42 U.S.C. 1983 against the State of New Jersey, New Jersey s

INTRODUCTION. States Constitution and 42 U.S.C. 1983 against the State of New Jersey, New Jersey s LAW OFFICES OF WALTER M. LUERS, LLC Suite C203 23 West Main Street Clinton, New Jersey 08809 Telephone: 908.894.5656 Facsimile: 908.894.5729 wluers@luerslaw.com MARK R. BROWN, ESQ. 303 E. Broad Street

More information

Case 6:14-cv-01521-AA Document 14 Filed 01/19/15 Page 1 of 5

Case 6:14-cv-01521-AA Document 14 Filed 01/19/15 Page 1 of 5 Case 6:14-cv-01521-AA Document 14 Filed 01/19/15 Page 1 of 5 Portland, OR 97210-3408 Telephone: (503 299-6116 Facsimile: (503 299-6106 E-mail: rsw@miller-wagner.com sml@miller-wagner.com Of Attorneys for

More information

Case 1:07-cv-00347-B Document 7 Filed 05/30/2007 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA

Case 1:07-cv-00347-B Document 7 Filed 05/30/2007 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA Case 1:07-cv-00347-B Document 7 Filed 05/30/2007 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA TRAVELERS CASUALTY AND SURETY ) COMPANY OF AMERICA, INC. ) ) Plaintiff,

More information

CAUSE NO. PLAINTIFF S ORIGINAL PETITION. Greg Abbott, and complains of OLD UNITED LIFE INSURANCE COMPANY ( Defendant ), and I.

CAUSE NO. PLAINTIFF S ORIGINAL PETITION. Greg Abbott, and complains of OLD UNITED LIFE INSURANCE COMPANY ( Defendant ), and I. CAUSE NO. STATE OF TEXAS, Plaintiff, v. OLD UNITED LIFE INSURANCE COMPANY, Defendant. IN THE DISTRICT COURT OF TRAVIS COUNTY, TEXAS JUDICIAL DISTRICT PLAINTIFF S ORIGINAL PETITION TO THE HONORABLE JUDGE

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION TRADEMARK PROPERTIES, INC., a South Carolina corporation; RICHARD C. DAVIS, an individual, vs. Plaintiffs, A&E

More information

ELECTRONIC INDEPENDENT CONTRACTOR AGREEMENT INTRODUCTION

ELECTRONIC INDEPENDENT CONTRACTOR AGREEMENT INTRODUCTION INTRODUCTION This is an AGREEMENT between you and Field Solutions, LLC ( Field Solutions ) that defines the terms and conditions for Field Solutions to engage you to provide services to our customers as

More information

Case 1:12-cv-01203-VEC Document 206 Filed 10/15/15 Page 1 of 10 USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #:

Case 1:12-cv-01203-VEC Document 206 Filed 10/15/15 Page 1 of 10 USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: Case 1:12-cv-01203-VEC Document 206 Filed 10/15/15 Page 1 of 10 USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 10/15/2015 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CITY OF

More information

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY, UTAH

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY, UTAH Robert G. Gilchrist (3715) Jeff M. Sbaih (14014) EISENBERG GILCHRIST & CUTT 900 Parkside Tower 215 South State Street Salt Lake City, Utah 84111 Phone: (801) 366-9100 Email: rgichrist@egclegal.com Email:

More information

NOTICE OF PROPOSED FINAL SETTLEMENT OF LAWSUIT AND PLANNED SALE OF PARTNERSHIP ASSETS

NOTICE OF PROPOSED FINAL SETTLEMENT OF LAWSUIT AND PLANNED SALE OF PARTNERSHIP ASSETS NOTICE OF PROPOSED FINAL SETTLEMENT OF LAWSUIT AND PLANNED SALE OF PARTNERSHIP ASSETS Please read this Notice carefully. This Notice is solely to inform all current Unit Holders of the Mesa Offshore Trust

More information

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * *

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * * IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA vs. Plaintiffs, CIVIL ACTION NUMBER CV-99-792 Defendants. COMPLAINT 1. Plaintiffs, Bryan K. Bunten and Lisa Bunten, are over the age of nineteen (19) years

More information

Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION SUSAN CARNABY V. C IVIL ACTION NUMBER H-08-1366 C ITY

More information

CERTIFICATE OF INCORPORATION CORE-MARK HOLDING COMPANY, INC. ARTICLE ONE. The name of the Corporation is Core-Mark Holding Company, Inc.

CERTIFICATE OF INCORPORATION CORE-MARK HOLDING COMPANY, INC. ARTICLE ONE. The name of the Corporation is Core-Mark Holding Company, Inc. CERTIFICATE OF INCORPORATION OF CORE-MARK HOLDING COMPANY, INC. ARTICLE ONE The name of the Corporation is Core-Mark Holding Company, Inc. ARTICLE TWO The address of the Corporation s registered office

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their CASE 0:13-cv-00873-RHK-TNL Document 1 Filed 04/15/13 Page 1 of 4 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Michael A. Ofor, Case No: Plaintiff, v. Steven Lecy, and City of Minneapolis, NOTICE

More information

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) )

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) ) CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA File No. Julius Chad Zimmerman, Plaintiff, v. Dave Bellows, in his individual and official

More information

APPROVED Movant shall serve copies of this ORDER on

APPROVED Movant shall serve copies of this ORDER on APPROVED Movant shall serve copies of this ORDER on any pro se parties, pursuant to CRCP 5, and file a certificate of service with the Court within 10 days. Dated: Jul 26, 2010 Catherine A. Lemon District

More information

IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT ST. CLAIR COUNTY, ILLINOIS NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION

IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT ST. CLAIR COUNTY, ILLINOIS NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION If you were injured or provided treatment for an injury and filed a claim under your Allstate Med Pay coverage, and were compensated in an amount

More information

GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent

GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent POMPELIO, FOREMAN & GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent HENRY KENT, vs. Plaintiff, SMILES II RESTAURANT,

More information

Case 2:09-cv WJM-MF Document 46 Filed 07/14/09 Page 1 of 35 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

Case 2:09-cv WJM-MF Document 46 Filed 07/14/09 Page 1 of 35 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY Case 2:09-cv-01643-WJM-MF Document 46 Filed 07/14/09 Page 1 of 35 Williams, Caliri, Miller & Otley, P.C. Burrell Ives Humphreys, Esq. (BH 1351) 1428 Route 23 Wayne, New Jersey 07470 972-694-0800 Attorneys

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Harvey C. Berger (SBN POPE & BERGER 0 West "C" Street, Suite 100 San Diego, California 1 Telephone: (1-1 Facsimile: (1 - Attorneys for Plaintiff PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND

More information

AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF FLUOR CORPORATION

AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF FLUOR CORPORATION AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF Fluor Corporation (the Corporation ), a corporation organized and existing under the General Corporation Law of the State of Delaware (the General Corporation

More information

AMENDED CLASS ACTION COMPLAINT

AMENDED CLASS ACTION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. KIM WALLANT and LOUIS BOREK, on behalf of themselves and all others similarly situated, vs. Plaintiffs, FREEDOM

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL

More information

the seal of the National Archives and Records Administration, that the attached reproduction(s) is TiTLE Regional Administrator, Pacific Alaska Region

the seal of the National Archives and Records Administration, that the attached reproduction(s) is TiTLE Regional Administrator, Pacific Alaska Region 1 k NATIONAL ARCHIVES AND RECORDS ADMINISTRATION ly virtue of the authority vested in me by the Archivist of the United States, I certify on his behalf, the seal of the National Archives and Records Administration,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE AMERICAN NATIONAL PROPERTY AND CASUALTY COMPANY, Plaintiff, Counterclaim-Defendant, v. CAROL ANN STUTTE; LAURA JEAN

More information

Case 3:15-cv-00012-CAR Document 9 Filed 05/08/15 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ATHENS DIVISION

Case 3:15-cv-00012-CAR Document 9 Filed 05/08/15 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ATHENS DIVISION Case 3:15-cv-00012-CAR Document 9 Filed 05/08/15 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ATHENS DIVISION MELISSA BROWN and BEN JENKINS, ) ) Plaintiffs, ) ) vs.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) COMPLAINT

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) COMPLAINT IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE COMMSCOPE, INC. OF NORTH CAROLINA and ADC TELECOMMUNICATIONS, INC., v. Plaintiffs, CORNING OPTICAL COMMUNICATIONS WIRELESS LTD., Defendant.

More information

Case 2:10-cv-02847-IPJ Document 292 Filed 05/27/15 Page 1 of 12 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

Case 2:10-cv-02847-IPJ Document 292 Filed 05/27/15 Page 1 of 12 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION Case 2:10-cv-02847-IPJ Document 292 Filed 05/27/15 Page 1 of 12 FILED 2015 May-27 AM 10:35 U.S. DISTRICT COURT N.D. OF ALABAMA UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

More information

Courthouse News Service

Courthouse News Service Case 3:15-cv-00168-HZ Document 1 Filed 01/30/15 Page 1 of 6 Samuel T. Stanke OSB No. 034631 E-mail: sam@stankelaw.com, LLC 1400 SW Montgomery Street Portland, OR 97201 Telephone: 503-224-1127 Facsimile:

More information

A. For the consideration agreed below to be paid to Contractor by City, Contractor shall provide

A. For the consideration agreed below to be paid to Contractor by City, Contractor shall provide STATE OF TEXAS CONTRACT FOR SERVICES COUNTY OF DALLAS THIS CONTRACT is made and entered into by and between the CITY OF DALLAS, a Texas municipal corporation, located in Dallas County, Texas (hereinafter

More information

Employee Settlement and Release Agreement.

Employee Settlement and Release Agreement. Form: Description: Release: No Disparagement: References: Review by Counsel: Employee Settlement and Release Agreement. This is a sample form agreement for the settlement of any claims by an employee against

More information

Case 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15

Case 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15 Case 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. MAZZONI

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ) ) ) ) ) ) ) ) ) ) ) Case No. 06-3755 CLASS ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ) ) ) ) ) ) ) ) ) ) ) Case No. 06-3755 CLASS ACTION Case 2:06-cv-03755-ER Document 136 Filed 04/25/2008 Page 1 of 26 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA A.D. ALBERTON and MARK C. KESSLER, on behalf of themselves

More information

Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT AND JURY DEMAND

Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT AND JURY DEMAND Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS PRIVATE BUSINESS JETS, L.L.C. Plaintiff, v. Civil Action No. PRVT, Inc. Defendant. COMPLAINT

More information

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND District Court, Denver County, Colorado 1437 Bannock Street Denver, Colorado 80202 GUILLERMO ARTEAGA-GOMEZ, Individually and on behalf of all others similarly situated, DATE FILED: January 22, 2015 6:02

More information

SEPARATION AGREEMENT AND GENERAL RELEASE. into by and between ( Employee ) and ( the

SEPARATION AGREEMENT AND GENERAL RELEASE. into by and between ( Employee ) and ( the SEPARATION AGREEMENT AND GENERAL RELEASE This Separation Agreement and General Release ( this Agreement ) is made and entered into by and between ( Employee ) and ( the Agency ) (collectively, the Parties

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE MOBILE TRANSFORMATION LLC, Plaintiff, v. Civil Case No. A&E TELEVISION NETWORKS, LLC JURY TRIAL DEMANDED Defendant. COMPLAINT Plaintiff

More information

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK KELVIN BLEDSOE, Plaintiff, v. SAAQIN, INC., No. COMPLAINT FOR VIOLATION OF FAIR LABOR STANDARDS ACT JURY TRIAL DEMANDED Defendant. Plaintiff Kelvin

More information

STATE OF NEVADA DEPARTMENT OF BUSINESS AND INDUSTRY DIVISION OF MORTGAGE LENDING * * * STIPULATED SETTLEMENT AGREEMENT

STATE OF NEVADA DEPARTMENT OF BUSINESS AND INDUSTRY DIVISION OF MORTGAGE LENDING * * * STIPULATED SETTLEMENT AGREEMENT STATE OF NEVADA DEPARTMENT OF BUSINESS AND INDUSTRY DIVISION OF MORTGAGE LENDING In re: J.H.S. Moxie Corp., and Jacqueline O Shaughnessy, Respondent. * * * STIPULATED SETTLEMENT AGREEMENT 1 STIPULATED

More information

IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF THE STATE OF IDAHO, IN AND FOR THE COUNTY OF ADA

IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF THE STATE OF IDAHO, IN AND FOR THE COUNTY OF ADA ALAN G. LANCE ATIORNEY GENERAL STATE OF IDAHO MARY E. HUGHES Deputy Attorney General State of Idaho Department of Finance P.O. Box 83720 Boise, Idaho 83720-0031 Telephone: (208) 332-8092 Facsimile: (208)

More information

1 2 3 4 5 [ATTORNEY NAME] (ATTORNEY STATE BAR NUMBER) [ATTORNEY EMAIL ADDRESS] [LAW FIRM NAME] [LAW FIRM STREET ADDRESS] [LAW FIRM CITY/STATE/ZIP CODE] [LAW FIRM TELEPHONE NUMBER] [LAW FIRM FAX NUMBER]

More information

Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY SMART VENT INC., : : Plaintiff, : CIVIL ACTION NO.: : : : USA FLOODAIR VENTS,

More information

SUPERIOR COURT OF WASHINGTON, COUNTY OF KING THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY

SUPERIOR COURT OF WASHINGTON, COUNTY OF KING THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY SUPERIOR COURT OF WASHINGTON, COUNTY OF KING MYSPINE, PS, a Washington professional services corporation; BODY RECOVERY CLINIC LLC, a Washington Limited Liability Company; and YAROSLAV KUTSY, Plaintiffs,

More information

IN THE CIRCUIT COURT OF THE STATE OF OREGON IN AND FOR THE COUNTY OF MULTNOMAH

IN THE CIRCUIT COURT OF THE STATE OF OREGON IN AND FOR THE COUNTY OF MULTNOMAH IN THE CIRCUIT COURT OF THE STATE OF OREGON IN AND FOR THE COUNTY OF MULTNOMAH LAURIE PAUL, individually and on behalf of all other similarly-situated individuals, Plaintiff, vs. PROVIDENCE HEALTH SYSTEMS-

More information

SPECIMEN. (1) advising, counseling or giving notice to employees, participants or beneficiaries with respect to any Plan;

SPECIMEN. (1) advising, counseling or giving notice to employees, participants or beneficiaries with respect to any Plan; In consideration of payment of the premium and subject to the Declarations, limitations, conditions, provisions and other terms of this Policy, the Company and the Insureds agree as follows: I. INSURING

More information