Michael, I'm sorry I couldn't post PRLN's side before, but there was an awful lot to scan. I just finished the scanning-- it took me most of Sunday to do it. (I didn't think I would get it done Sunday because I had gone out of town Friday. I got back earlier than expected.) As before, I lost some of the formatting and I made some minor changes like inserting page numbers in some documents that weren't numbered. I also took the liberty of crossing out Babish's social security number on his employment agreement because I didn't want to post it on the net. However, I did not tamper with anything of substance in these documents. And now, for your entertainment and pleasure . . .
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
PARACELS1AN, INC., a Delaware
corporation,
Plaintiff,
97-CV-604
(RSP) (GJD)
-v-
JOHN G. BABISH,
Defendant.
ATTORNEY AFFIDAVIT IN SUPPORT OF
PLAINTIFF'S APPLICATION FOR A PRELIMINARY
INJUNCTION
I, MICHAEL D. PINNISI, under penalty of perjury, hereby do
state as follows:
1. I am an attorney duly licensed to practice law in the State of New York and admitted to practice before this Court. I represent Paracelsian, Inc. ("Paracelsian" or "the company") plaintiff in the above-captioned case. I am personally familiar with the facts and circumstances as set forth herein.
2. I submit this Affidavit in support of Paracelsian's
Application for a Preliminary Injunction.
1
3. Attached hereto are true copies of the following
documents:
a. As Exhibit A, the Summons and Complaint in the
above-captioned action dated and filed April 25, 1997;
b. As Exhibit B, the Affidavit of Lee A. Henderson, sworn April 24, 1997;
c. As Exhibit C, a Confidentiality Agreement dated
October 12, 1992 and executed by Babish and Paracelsian;
d. As Exhibit D, Securities and Exchange Commission
Form 4's for the period January and February 1997 regarding
defendant's trading activity in Paracelsian stock;
e. As Exhibit E, defendant's letter of resignation from
Paracelsian dated March 19, 1997;
f. As Exhibit F, a proposed Preliminary Injunction dated
May ___, 1997.
Michael D. Pinnisi
Subscribed and sworn to before
me this 2nd dayof May, 1997.
Notary Public
JOHN R. MAYER
Notary Public State of New York
No. 02MA5072929
Qualified in Tompkins County
Commission Expires February 10. 1999 |
