16. Baldwin admits the allegations in the first sentence of paragraph 16.
Regarding the second sentence, Baldwin admits that Javaco was in the business of selling used cable television equipment, including amplifiers and converters, to Columbia, Venezuela and Mexico, but deny that such business was merely “purported.” Baldwin admits that 310 Holdings reported in its Form 8-K filed on August 28, 2009 that Javaco was acquired to operate and manage 310 Holdings’ planned Plastic2Oil sites in Mexico, but otherwise deny the allegations in the third sentence of this paragraph.
Baldwin admits that Domark International, Inc. (“Domark”) assigned the referenced media credits to JBI and that in making such assignment, Domark’s CEO represented that such credits were worth $9,997,134 in print and radio ads, but otherwise deny the allegations in the fourth sentence of this paragraph.
Baldwin admits that 310 Holdings issued 1,000,000 shares of common stock on August 24, 2009 as consideration for assignment of the media credits, and further admit that JBI’s amended Form 10-K for the year ended December 31, 2009 disclosed that these shares were valued at $1,000,000. Baldwin otherwise denies the allegations in the last sentence of this paragraph.
Ronald Baldwin, Jr.'s ANSWER to 1 Complaint
Doc 13 PDF file
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Paragraph 16
First sentence
16. On August 24, 2009, 310 Holdings purchased 100% of the outstanding shares of Javaco, Inc. (“Javaco), a wholly owned subsidiary of Domark International (“Domark”), in exchange for $150,000 and the issuance of 2,500,000 shares of 310 Holding’s common stock to Domark.
Second sentence
Javaco purportedly was in the business of selling used cable television equipment, including amplifiers and converters to Colombia, Venezuela and Mexico.
Third sentence
310 Holdings publicly reported that Javaco was acquired to operate and manage the company’s Plastic2Oil sites in Mexico.
Fourth sentence
Pursuant to a separate agreement, Domark’s CEO also assigned media credits (“the media credits”) purportedly representing $9,997,134 worth of prepaid print and radio ads to 310 Holdings to be used for marketing and advertising.
Last sentence
As consideration for the assignment of the media credits, 310 Holdings issued 1,000,000 shares of common stock valued at $1,000,000 ($1.00 per share market price) on August 24, 2009.
Doc 1 PDF file SEC Complaint.
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