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Pastimes : Plastics to Oil - Pyrolysis and Secret Catalysts and Alterna -- Ignore unavailable to you. Want to Upgrade?

To: scion who wrote (3275)	11/23/2010 4:32:22 PM
From: scion	Read Replies (1) \| Respond to of 53574

As evidenced by the above, Mr. Bordynuik engaged in the business of stock promotion in Florida pursuant to Section 48.193(1)(a). He basically offered to devise his own personal stock in order to induce Plaintiff to work for the company. Further, because the Plaintiff did not receive the promised stock from Mr. Bordynuik, Mr. Bordynuik's representations regarding the same constitute fraud or another tortious act pursuant to Section 48.193(1)(b). Additionally, pleading in the alternative, Mr. Bordynuik's breach of his oral promise to devise his personal stock to the Plaintiff constitutes breach of contract pursuant to Section 48.193(1)(g). b. Mr. Bordynuik's Other Inducement Of Plaintiff Geoff Weber was formerly the Assistant Secretary for JBI and was engaged by JBI as a consultant to launch the "Plastic2Oil" ("P2O") concept. (Ex. "A" at ¶ 5). Mr. Weber is based in Florida and worked extensively with Mr. Bordynuik. (Id.). Mr. Bordynuik clearly availed himself of Florida and its benefits through this relationship. For example, a January 31, 2010 email chain includes emails authored by Plaintiff, Mr. Weber and Mr. Bordynuik which extensively discusses the work that Plaintiff was to do in Florida. (Ex. "A" at ¶ 6). As stated, Mr. Bordynuik wrote another email to Plaintiff where he stated that “I know you are moving to Florida but JBI Admin and Executive are being scattered all over North America. I don?t believe we need a centralized office other than Accounting Controls (limited to compliance and reporting only -- Florida).” (Ex. "A" ¶ 7). Mr. Bordynuik went on to state that Linda Burr “can support you in FL.” (Id.). Clearly, Mr. Bordynuik was aware that Mr. Kaplanis is working for him out of Florida, he wants him to work there, and knows Mr. Kaplanis is moving there at Mr. Bordynuik’s direction to complete the goals of the company due to Mr. Bordynuik?s negligent misrepresentations about the work. Further, Mr. Bordynuik has sent hundreds of emails directed to the Plaintiff and to the Florida based Plastic2Oil Consulting Team regarding work for a global launch of the Plastic2Oil concept. (Ex. "A" ¶ 8). Mr. Bordynuik induced Plaintiff to work for JBI in Florida based on representations that Plaintiff would be working closely with JBI's "Florida Team," which consisted primarily of Florida-based consultants. (Id. at ¶ 9). Separately, JBI entered into an Area Development Agreement with AS PTO, LLC with the purpose of establishing forty-five Plastic2Oil sites to be located within Florida. (Id. at ¶ 10). The signed letter of intent of the establishment of the Area Development Agreement was announced by the company on December 22, 2010, and the contact person on the press release is John Bordynuik. (Id.). The company stated that “Mr. Sousa?s company will begin to quickly cultivate supply chains and sites for installation of P2O sites throughout Florida concentrating first on large metropolitan areas and expanding outwards.” (Id.). Clearly, Mr. Bordynuik initiated a global launch of his flagship business venture known as Plastic2Oil from Florida. (Id.). In a press release, the company said that it is “pleased to announce that on February 12, 2010, JBI consummated an Area Development Agreement (ADA for 45 P2O sites in the State of Florida with a newly formed entity (AS PTO, LLC) controlled by Al Sousa of Largo, Florida.” (Id.). Mr. Bordynuik signed this agreement (Id.). This evidence further establishes contacts sufficient for this Court to exercise personal jurisdiction over Mr. Bordynuik pursuant to Section 48.193(1)(b) and 1(f)(1). This evidence corroborates that Mr. Bordynuik fraudulently induced Plaintiff to work for the company pursuant to sub-section 1(b), and also engaged in the business of soliciting Plaintiff pursuant to sub-section 1(f)(1). Doc 15 PDF file viewer.zoho.com