STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND
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1 STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND JEFFREY SAMPSON and WARWICK SMITH, Plaintiffs, Judge Daniel P. O Brien vs. No CZ TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, LARRY PETERSON, DAVID TRITSCH and JIM WARD, Defendants. / JAMES W. ROSE (P66473) JAFFE, RAITT, HEUER & WEISS, P.C. Attorneys for Plaintiffs Franklin Road, Ste Southfield, MI (248) jrose@jaffelaw.com TIMOTHY J. MULLINS (P28021) GIARMARCO, MULLINS & HORTON, P.C. Attorney for Defendants, Tartan 10, Barker, Bratton, Eckstein, Gregory, Irwin, Jacob, Karstrand, Mahoney, Tritsch and Ward 101 W. Big Beaver Road, 10 th Floor Troy, MI (248) tmullins@gmhlaw.com ANSWER TO COMPLAINT NOW COME Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, by and through their attorneys, GIARMARCO, MULLINS & HORTON, P.C., and for their Answer to Plaintiffs Complaint states as follows: Parties and Jurisdictional Allegations 1. In answer to paragraph 1, Defendants neither admit nor deny the
2 2. In answer to paragraph 2, Defendants deny the allegations contained 3. In answer to paragraph 3, Defendants deny the allegations contained 4. In answer to paragraph 4, Defendants deny the allegations contained 5. In answer to paragraph 5 Defendants deny the allegations contained 6. In answer to paragraph 6, Defendants admit that Mike Eckstein resides in Royal Oak, Michigan, but deny any allegation that he conducted any business with Plaintiffs in Oakland County or otherwise. 7. In answer to paragraph 7, Defendants deny the allegations contained 8. In answer to paragraph 8, Defendants deny the allegations contained 9. In answer to paragraph 9, Defendants deny the allegations contained 10. In answer to paragraph 10, Defendants deny the allegations contained 11. In answer to paragraph 11, Defendants deny the allegations contained 2
3 12. In answer to paragraph 12, Defendants deny the allegations contained 13. In answer to paragraph 13, Defendants deny the allegations contained 14. In answer to paragraph 14, Defendants deny the allegations contained 15. In answer to paragraph 15, Defendants neither admit nor deny the 16. In answer to paragraph 16, Defendants deny the allegations contained 17. In answer to paragraph 17, Defendants neither admit nor deny the 18. In answer to paragraph 18, Defendants deny the allegations contained 19. In answer to paragraph 19, Defendants deny the allegations contained 20. In answer to paragraph 20, Defendants neither admit nor deny the 21. In answer to paragraph 21, Defendants neither admit nor deny the 3
4 22. In answer to paragraph 22, Defendants neither admit nor deny the 23. In answer to paragraph 23, Defendants neither admit nor deny the 24. In answer to paragraph 24, Defendants neither admit nor deny the 25. In answer to paragraph 25, Defendants neither admit nor deny the 26. In answer to paragraph 26, Defendants neither admit nor deny the 27. In answer to paragraph 27, Defendants neither admit nor deny the 28. In answer to paragraph 28, Defendants deny the allegations contained 29. In answer to paragraph 29, Defendants admit the allegations contained therein. 4
5 30. In answer to paragraph 30, Defendants deny the allegations contained 31. In answer to paragraph 31, Defendants neither admit nor deny the 32. In answer to paragraph 32, Defendants neither admit nor deny the 33. In answer to paragraph 33, Defendants neither admit nor deny the 34. In answer to paragraph 34, Defendants neither admit nor deny the 35. In answer to paragraph 35, Defendants neither admit nor deny the 36. In answer to paragraph 36, Defendants deny the allegations contained Defendants affirmatively aver that class rules provide that any alteration to the hull or alteration to or replacement of the keel, rudder, and spars invalidates the Measurement Certificate until re-measured. A major repair to any of the foregoing or replacement of an item or equipment may also invalidate the Measurement Certificate. Defendants will show and rely upon at the time of trial that 5
6 Plaintiffs altered the standard profile of the keel and structural aspects of Hull #217, thereby invalidating the Measurement Certificate previously issued. 37. In answer to paragraph 37, Defendants neither admit nor deny the 38. In answer to paragraph 38, Defendants neither admit nor deny the 39. In answer to paragraph 39, Defendants neither admit nor deny the 40. In answer to paragraph 40, Defendants neither admit nor deny the 41. In answer to paragraph 41, Defendants deny the allegations contained 42. In answer to paragraph 42, Defendants deny the allegations contained 43. In answer to paragraph 43, Defendants deny the allegations contained 44. In answer to paragraph 44, Defendants neither admit nor deny the 6
7 45. In answer to paragraph 45, Defendants neither admit nor deny the 46. In answer to paragraph 46 Defendants deny the allegations contained Defendants affirmatively aver that a number of class members witnessed illegal features of Hull 217 and so advised Plaintiffs herein. 47. In answer to paragraph 47, Defendants neither admit nor deny the 48. In answer to paragraph 48, Defendants admit the allegations contained therein. 49. In answer to paragraph 49, Defendants deny the allegations contained 50. In answer to paragraph 50, Defendants deny the allegations contained 51. In answer to paragraph 51, Defendants deny the allegations contained Defendants affirmatively aver that a number of class members observed and witnessed inappropriate modifications to Plaintiffs Hull 217 and witnessed Plaintiffs admissions to such modifications. 52. In answer to paragraph 52, Defendants neither admit nor deny the 53. In answer to paragraph 53, Defendants neither admit nor deny the 7
8 Defendants affirmatively aver that Plaintiff Sampson admitted to the Association Board that he had modified the keel, thereby triggering class rule 2.5.5, which invalidates the certification for Hull 217 until it is remeasured and certified. 54. In answer to paragraph 54, Defendants neither admit nor deny the 55. In answer to paragraph 55, Defendants deny the allegations contained 56. In answer to paragraph 56, Defendants deny the allegations contained 57. In answer to paragraph 57, Defendants deny the allegations contained 58. In answer to paragraph 58, Defendants deny the allegations contained 59. In answer to paragraph 59, Defendants neither admit nor deny the 60. In answer to paragraph 60, Defendants neither admit nor deny the 61. In answer to paragraph 61, Defendants deny the allegations contained 8
9 62. In answer to paragraph 62, Defendants deny the allegations contained 63. In answer to paragraph 63, Defendants deny the allegations contained 64. In answer to paragraph 64, Defendants neither admit nor deny the Defendants affirmatively aver that the Association responded to Plaintiffs by way of notification on May 10, In answer to paragraph 65, Defendants deny the allegations contained Defendants affirmatively aver that Defendants Association responded to Plaintiffs request on May 10, In answer to paragraph 66, Defendants deny the allegations contained Defendants affirmatively aver that the Association Board responded to Plaintiffs request on May 10, In answer to paragraph 67, Defendants neither admit nor deny the 68. In answer to paragraph 68, Defendants neither admit nor deny the 69. In answer to paragraph 69, Defendants neither admit nor deny the 9
10 70. In answer to paragraph 70, Defendants neither admit nor deny the 71. In answer to paragraph 71, Defendants deny the allegations contained 72. In answer to paragraph 72, Defendants deny the allegations contained 73. In answer to paragraph 73, Defendants deny the allegations contained 74. In answer to paragraph 74, Defendants deny the allegations contained 75. In answer to paragraph 75, Defendants deny the allegations contained 76. In answer to paragraph 76, Defendants neither admit nor deny the Count I Breach of Contract 77. In answer to paragraph 77, Defendants incorporate by reference their responses contained in paragraphs 1 through 76 inclusive, as if fully set forth herein. 78. In answer to paragraph 78, Defendants neither admit nor deny the 10
11 79. In answer to paragraph 79, Defendants neither admit nor deny the 80. In answer to paragraph 80, Defendants deny the allegations contained 81. In answer to paragraph 81, Defendants deny the allegations contained 82. In answer to paragraph 82, Defendants deny the allegations contained WHEREFORE, Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, respectfully request that this Honorable Court enter an order of no cause of action as to Defendants, together with costs and attorney fees so wrongfully sustained, and award sanctions. Count II Declaratory Judgment 83. In answer to paragraph 83, Defendants incorporate by reference their responses contained in paragraphs 1 through 82 inclusive, as if fully set forth herein. 84. In answer to paragraph 84, Defendants deny the allegations contained 85. In answer to paragraph 85, Defendants deny the allegations contained Defendants affirmatively aver that this Court lacks jurisdiction of the individuals and subject matter herein. 11
12 86. In answer to paragraph 86, Defendants deny the allegations contained 87. In answer to paragraph 87, Defendants deny the allegations contained 88. In answer to paragraph 88, Defendants deny the allegations contained WHEREFORE, Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, respectfully request that this Honorable Court enter an order of no cause of action as to Defendants, together with costs and attorney fees so wrongfully sustained, and award sanctions. Count III Injunctive Relief 89. In answer to paragraph 89, Defendants incorporates by reference their responses contained in paragraphs 1 through 88 inclusive, as if fully set forth herein. 90. In answer to paragraph 90, Defendants deny the allegations contained Defendants affirmatively aver that to their knowledge, no new rules were ever created or imposed in any way upon Plaintiffs or in relationship to any property owned or operated by Plaintiffs. Further, Plaintiffs own action by improperly modifying Hull 217 resulted in their self-invalidation of the Measurement Certificate and, based upon knowledge and belief, Defendants understand that the Association asked Plaintiffs to remove the invalidating modifications from Hull 217 so that the boat would conform with its original design and construction. 12
13 91. In answer to paragraph 91, Defendants deny the allegations contained 92. In answer to paragraph 92, Defendants deny the allegations contained 93. In answer to paragraph 93, Defendants deny the allegations contained 94. In answer to paragraph 94, Defendants deny the allegations contained 95. In answer to paragraph 95, Defendants deny the allegations contained 96. In answer to paragraph 96, Defendants deny the allegations contained WHEREFORE, Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, respectfully request that this Honorable Court enter an order of no cause of action as to Defendants, together with costs and attorney fees so wrongfully sustained, and award sanctions. Count IV Tortious Interference With Contract (All Defendants Except T-Ten Association) 97. In answer to paragraph 97, Defendants incorporate by reference their responses contained in paragraphs 1 through 96 inclusive, as if fully set forth herein. 98. In answer to paragraph 98, Defendants neither admit nor deny the 13
14 99. In answer to paragraph 99, Defendants deny the allegations contained 100. In answer to paragraph 100, Defendants deny the allegations contained 101. In answer to paragraph 101, Defendants deny the allegations contained WHEREFORE, Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, respectfully request that this Honorable Court enter an order of no cause of action as to Defendants, together with costs and attorney fees so wrongfully sustained, and award sanctions. Count V Intentional Infliction of Emotional Distress 102. In answer to paragraph 102, Defendants incorporate by reference their responses contained in paragraphs 1 through 101 inclusive, as if fully set forth herein In answer to paragraph 103, Defendants deny the allegations contained 104. In answer to paragraph 104, Defendants deny the allegations contained 105. In answer to paragraph 105, Defendants deny the allegations contained 106. In answer to paragraph 106, Defendants deny the allegations contained 14
15 107. In answer to paragraph 107, Defendants deny the allegations contained WHEREFORE, Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, respectfully request that this Honorable Court enter an order of no cause of action as to Defendants, together with costs and attorney fees so wrongfully sustained, and award sanctions. Count VI Statutory Claims (MCL and ; 805 ILCS 105/112.50) 108. In answer to paragraph 108, Defendants incorporate by reference their responses contained in paragraphs 1 through 107 inclusive, as if fully set forth herein. untrue In answer to paragraph 109, Defendants deny the allegations contained 110. In answer to paragraph 110, Defendants deny the allegations contained 111. In answer to paragraph 111, Defendants deny the allegations contained WHEREFORE, Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, respectfully request that this Honorable Court enter an order of no cause of 15
16 action as to Defendants, together with costs and attorney fees so wrongfully sustained, and award sanctions. DATED: January 29, 2013 /s/timothy J. MULLINS GIARMARCO, MULLINS & HORTON, PC Attorney for Defendants, Tartan 10, Barker, Bratton, Eckstein, Gregory, Irwin, Jacob, Karstrand, Mahoney, Tritsch and Ward 101 W. Big Beaver Road, 10th Floor Troy, MI (248) P
17 STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND JEFFREY SAMPSON and WARWICK SMITH, Plaintiffs, Judge Daniel P. O Brien vs. No CZ TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, LARRY PETERSON, DAVID TRITSCH and JIM WARD, Defendants. / JAMES W. ROSE (P66473) JAFFE, RAITT, HEUER & WEISS, P.C. Attorneys for Plaintiffs Franklin Road, Ste Southfield, MI (248) jrose@jaffelaw.com TIMOTHY J. MULLINS (P28021) GIARMARCO, MULLINS & HORTON, P.C. Attorney for Defendants, Tartan 10, Barker, Bratton, Eckstein, Gregory, Irwin, Jacob, Karstrand, Mahoney, Tritsch and Ward 101 W. Big Beaver Road, 10 th Floor Troy, MI (248) tmullins@gmhlaw.com AFFIRMATIVE DEFENSES NOW COME Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, by and through their attorneys, GIARMARCO, MULLINS & HORTON, P.C., and for their Affirmative Defenses state as follows: 1. Defendants will show and rely upon that Plaintiffs and all Defendants herein were participants in sailboat racing activities conducted as an amateur sporting 17
18 activity and that Plaintiffs and all Defendants mutually agreed as a condition precedent to the participation in such activities that they would be governed by and abide by the rules, rulings and determinations of the organizing bodies, including the one named herein, local sailing organizations, state sailing organizations, national sailing organizations and such international sailing organizations as will be shown in the course of the proceedings herein. 2. Defendants will further show that Plaintiffs and all parties herein agreed to abide by the aforesaid rulings and determinations and to forego seeking any further redress in local, state or federal court. As such, Defendants will show that, by operation of consent, contract, prior mutual agreement, condition precedent, and by operation of law, as made and provided by local, state and federal statute, this Court lacks jurisdiction in the matter presented. 3. Defendants will show and rely upon that with Plaintiffs knowing that prior to the institution of the subject litigation, Plaintiffs had agreed to abide by the aforesaid determinations of the appropriate ruling bodies and that the Court herein had no jurisdiction over the matter asserted, that the filing herein is frivolous and that the Court should award interest, costs, attorney fees and sanctions to Defendants for having been subjected to the improper filing of this claim. 4. Plaintiffs lawsuit constitutes an abuse of process and will serve to bar Plaintiffs claims. 5. Plaintiffs lawsuit may be barred by an arbitration agreement. 6. Plaintiffs claims are barred by the business judgment rule. 18
19 7. Plaintiffs claims are barred because they have failed to exhaust their administrative remedies. 8. Plaintiffs claims are barred because they have consented to the harms complained about. 9. This Court lacks subject matter jurisdiction over some of Plaintiffs claims. 10. Plaintiffs claims are barred because they have failed to satisfy conditions precedent. 11. Plaintiffs claims are barred because Defendants acted in good faith. 12. Plaintiffs claims are barred by laches. 13. Plaintiffs claims are barred by the statute of limitations. 14. Plaintiffs lack standing to raise claims made. 15. Plaintiffs claims may be barred by the parol evidence rule. 16. If Plaintiffs establish a contract, Plaintiffs claims are barred by their prior and material breach. 17. Plaintiffs claims are barred by their unclean hands. 18. Plaintiffs claims are barred by their own comparative fault. 19. Plaintiffs damages, if any, were caused by their own actions or actions of third parties. 20. Plaintiffs claims are barred by failure of consideration. 21. Plaintiffs claims are barred because there was no meeting of the minds. 22. Plaintiffs have failed to mitigate their damages, if any. 23. This action was filed in an improper venue. 24. Plaintiffs claims are barred by the doctrine of impossibility of performance. 19
20 25. Plaintiffs claim for injunctive relief is barred because they have not demonstrated that money damages are inadequate. 26. Plaintiffs claim for injunctive relief is barred because they cannot demonstrate irreparable harm. 27. Plaintiffs claim for injunctive relief is barred because they cannot succeed on the merits. 28. Plaintiffs claim for injunctive relief is barred because an injunction would be against the public interest. 29. Plaintiffs IIED claim is barred because they have not pled conduct that is extreme and outrageous. 30. Plaintiffs IIED claim is barred because they have not suffered severe emotional distress. 31. Plaintiffs have failed to join all necessary or interested parties. 32. Plaintiffs tortious interference claim is barred because a party cannot tortiously interfere with their own contract or business relationship/expectancy. 33. Plaintiffs claims may be preempted by state or federal law. 34. Defendants reserve the right to amend their Answer, including additional Affirmative Defenses, upon completion of investigation and discovery of this cause. DATED: January 29, 2013 /s/timothy J. MULLINS GIARMARCO, MULLINS & HORTON, PC Attorney for Defendants, Tartan 10, Barker, Bratton, Eckstein, Gregory, Irwin, Jacob, Karstrand, Mahoney, Tritsch and Ward 20
21 STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND JEFFREY SAMPSON and WARWICK SMITH, Plaintiffs, Judge Daniel P. O Brien vs. No CZ TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, LARRY PETERSON, DAVID TRITSCH and JIM WARD, Defendants. / JURY DEMAND NOW COME Defendants, TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, DAVID TRITSCH and JIM WARD, by and through their attorneys, GIARMARCO, MULLINS & HORTON, P.C., and hereby demand a jury as to all issues of trial. DATED: January 29, 2013 /s/timothy J. MULLINS GIARMARCO, MULLINS & HORTON, PC Attorney for Defendants, Tartan 10, Barker, Bratton, Eckstein, Gregory, Irwin, Jacob, Karstrand, Mahoney, Tritsch and Ward 101 W. Big Beaver Road, 10th Floor Troy, MI (248) tmullins@gmhlaw.com P
22 STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND JEFFREY SAMPSON and WARWICK SMITH, Plaintiffs, Judge Daniel P. O Brien vs. No CZ TARTAN TEN CLASS ASSOCIATION, JOHN E. BARKER, HANSON BRATTON, MIKE ECKSTEIN, STEVE GREGORY, SCOTT IRWIN, LOU JACOB, STEVE KARSTRAND, TED MAHONEY, LARRY PETERSON, DAVID TRITSCH and JIM WARD, Defendants. / CERTIFICATE OF ELECTRONIC SERVICE TIMOTHY J. MULLINS states that on January 29, 2013, he did serve a copy of the ANSWER, AFFIRMATIVE DEFENSES and JURY DEMAND via the Oakland County Circuit Court Wiznet electronic transmission on the aforementioned date. /s/timothy J. MULLINS GIARMARCO, MULLINS & HORTON, PC Attorney for Defendants, Tartan 10, Barker, Bratton, Eckstein, Gregory, Irwin, Jacob, Karstrand, Mahoney, Tritsch and Ward 101 W. Big Beaver Road, 10th Floor Troy, MI (248) tmullins@gmhlaw.com P
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Case :-cv-0 Document Filed // Page of Page ID #: Bobby Saadian, Esq. SBN: 0 Colin M. Jones, Esq. SBN: WILSHIRE LAW FIRM 0 Wilshire Blvd., th Floor Los Angeles, California 000 Tel: () - Fax: () - Attorneys
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FILED: NEW YORK COUNTY CLERK 10/18/2012 INDEX NO /2012 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/18/2012
FILED: NEW YORK COUNTY CLERK 10/18/2012 INDEX NO. 653645/2012 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/18/2012 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION. Civil Action No: HON. COMPLAINT FOR PATENT INFRINGEMENT
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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) Judge:
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STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE. vs.
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STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE
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Page 1 of 8 TO THE DEFENDANT ABOVE-NAMED: SARAH ( SALLY ) WARWICK
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Case :-cv-0-dmr Document Filed 0/0/ Page of THE RESTIS LAW FIRM, P.C. William R. Restis, Esq. (SBN ) william@restislaw.com 0 West C Street, Suite 0 San Diego, California Telephone: +..0. 0 UNITED STATES
IN THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA
IN THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA ELECTRONICALLY FILED 12/17/2012 2:06 PM CV-2012-901531.00 CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA FLORENCE CAUTHEN, CLERK INNOVATION SPORTS & ) ENTERTAINMENT,
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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION. ] Case No.: vs. Defendants. ] $Return Date: VERIFIED COMPLAINT
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IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION
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Defendant: PROGRESSIVE CASUALTY INSURANCE COMPANY COURT USE ONLY Counsel for Plaintiff: Marc R. Levy, #11372
GRANTED 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: May 27, 2010 DISTRICT COURT, CITY AND
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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------------X PRIME HOMES LLC, Plaintiff Index No.: 151308l2016 -against- Verified Answer
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Quentin M. Rhoades State Bar No. 3969 SULLIVAN, TABARACCI & RHOADES, P.C. 1821 South Avenue West, Third Floor Missoula, Montana 59801 Telephone (406) 721-9700 Facsimile (406) 721-5838 qmr@montanalawyer.com
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COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss. SUPERIOR COURT CIVIL ACTION NO:~..~~':; kifi-' "',_,,.;;J. ----------------------0:..'.:..- ~ John Doe No. 14, Plaintiff ROMAN CATHOLIC ARCHBISHOP OF BOSTON,
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~~~~~~~SAS DEC 1 5 ZOOO IN THE UNITED STATES DISTRICT COURT R EASTERN DISTRICT OF ARKANSAS JAMES1P~COR~ CLE WESTERN DIVISION BY:~ bep CCEF EQUAL EMPLOYMENT OPPORTUNITY COMMISSION PLAINTIFF VS. CASE NO.
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