DEFENDANT RONALD BALDWIN, JR’S ANSWER TO COMPLAINT AND JURY DEMAND
Defendant Ronald Baldwin, Jr. (“Baldwin”) by and through undersigned counsel, hereby answers Plaintiff’s Complaint and Jury Demand (“Complaint”) as follows:
SUMMARY
1. Baldwin denies the allegations contained in paragraph 1 of the Complaint.
2. Baldwin admits that JBI, Inc. (“JBI”) is a technology company focused on data restoration and recovery, and further admits that it is engaged in developing products with the goal of environmental sustainability. Baldwin denies that such development is merely “purported.” Baldwin admits that JBI is involved in the research and development of a process designed to convert plastic waste into oil, known as “Plastic2Oil”or “P2O,” but denies that such involvement is merely “purported.” Baldwin admits the allegations in the third sentence, but denies the allegations in the fourth sentence of this paragraph. With respect to sentence five of this paragraph, Baldwin states that JBI’s financial statements speak for themselves and deny any allegations inconsistent therewith.
3. Baldwin denies the first, second, and third sentences of this paragraph. Baldwin asserts that the “public statement” referenced in the last sentence of this paragraph speaks for itself and denies any allegations inconsistent therewith; Baldwin admits, however, that JBI stated in a Form 8-K filed on or about May 19, 2010, that JBI’s previously filed financial statements for the year ended December 31, 2009 “should no longer be relied upon due to questions regarding,” among other things, the valuation of certain media credits.
4. Baldwin denies the allegations contained in paragraph 4 of the Complaint.
5. Baldwin denies the allegations contained in paragraph 5 of the Complaint.
6. Baldwin states that paragraph 6 is a description of the relief sought by Plaintiff to which no response is required. To the extent a response is required, Baldwin denies the allegations contained in this paragraph.
JURISDICTION AND VENUE
7. The first sentence of paragraph 7 is a description of the statutory basis for the SEC’s authority to which no response is required. The allegation of jurisdiction in this Court is admitted, but Baldwin denies any characterization of his alleged conduct as unlawful.
8. The allegation of proper venue in this District is admitted. Baldwin further admits that Defendant JBI had a principal executive office in the District of Massachusetts from approximately 2009 until the summer of 2010, but denies any characterization of his alleged conduct as unlawful.
9. Baldwin states that paragraph 9 contains legal conclusions to which no response is required. To the extent a response is required, Baldwin denies the allegations contained in paragraph 9.
10. Baldwin denies the allegations in paragraph 10.
Ronald Baldwin, Jr.'s ANSWER to 1 Complaint
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