YA Global has been informed by the CEO of JBI, Inc., John Bordynuik, that Kidd has been selling his JBI shares though his brokerage account maintained at Maxim.
Request No.7. All communications and correspondence, inclusive of letters, faxes and emails, either sent to or received from JBI, Inc., John Borynuik, Ronald Baldwin, Jr., Jacob Smith, John M. Wesson, Robin Bagai, and/or Gregory Goldberg, or anyone purporting to act as his or her agent from January 1, 2008 until the petition date.
Response: Responsive documents in Respondent's possession, custody or control are being produced herewith.
Extract
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Pursuant to Rule 4:52, Defendants now seek to enjoin Kidd from engaging in any activities that would allow Kidd to sell the JBI stock, or any other assets in his Maxim account(s)....YA Global has been informed by the CEO of JBI, Inc., John Bordynuik, that Kidd has been selling his JBI shares though his brokerage account maintained at Maxim.
Exhibit A - OCR extract:
In addition, pursuant to paragraph 3 of the Settlement Agreement, YA Global has the right to "exercise all remedies available to it under law to collect the Final Judgment." See Gonzalez Aff., ~ 3 and Exhibit "B." As a result, YA Global is in the process of enforcing the Final Judgment. In those efforts, YA Global has discovered that Kidd became the owner of a significant amount of shares of stock in JBI, Inc. (uJBI") in 2009. YA Global has been informed by the CEO of JBI, Inc., John Bordynuik, that Kidd has been selling his JBI shares though his brokerage account maintained at Maxim. See Gonzalez Aff., 9. Maxim maintains an office at 246 Maple Avenue in Red Bank, NJ. See Gonzalez Aff., 9.
Pursuant to Rule 4:52, Defendants now seek to enjoin Kidd from engaging in any activities that would allow Kidd to sell the JBI stock, or any other assets in his Maxim account(s). Kidd is wrongfully refusing to honor the Final Judgment and Settlement Agreement by not making payments to YA Global. Further, he is selling and may continue to sell assets that should be used to satisfy the Final Judgment against him. Should the Court not prevent him from doing so, he will continue to avoid his obligations to YA Global.
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