To: scion who wrote (21830 ) 4/5/2012 7:01:00 PM From: scion Read Replies (1) | Respond to of 53574 FIRST CLAIM Violation of Section 17(a) of the Securities Act by All Defendants [15 U.S.C. § 77q(a)] 38. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1- 37 of the Complaint. 39. Baldwin denies the allegations contained in paragraph 39 of the Complaint. 40. Baldwin denies the allegations contained in paragraph 40 of the Complaint. SECOND CLAIM Violation of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 Thereunder [17 C.F.R. §240.10b-5] by All Defendants 41. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-40 of the Complaint. 42. Baldwin denies the allegations contained in paragraph 42 of the Complaint. 43. Baldwin denies the allegations contained in paragraph 43 of the Complaint. THIRD CLAIM Aiding and Abetting Violations of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 Thereunder [17 C.F.R. §240.10b-5] by Bordynuik and Baldwin 44. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-43 of the Complaint. 45. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 46. Baldwin denies the allegations contained in paragraph 46 of the Complaint. 47. Baldwin denies the allegations contained in paragraph 47 of the Complaint. 48. Baldwin denies the allegations contained in paragraph 48 of the Complaint. FOURTH CLAIM Violations of Sections 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Rules 12b-20, 13a-1, 13a-11 and 13a-13 Thereunder [17 C.F.R. §§240.12b-20, 240.13a-1, 240.13a-11, 240.13a-13] by JBI 49. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-48 of the Complaint. 50. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 51. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 52. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. FIFTH CLAIM Aiding and Abetting Violation of Sections 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Rules 12b-20, 13a-1 and 13a-11 Thereunder [17 C.F.R. §240.12b-20, 240.13a-1, 240.13a-11] by Bordynuik 53. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-52 of the Complaint. 54. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 55. The allegations contained in this paragraph pertain to defendants other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 56. The allegations contained in this paragraph pertain to defendants other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 57. The allegations contained in this paragraph pertain to defendants other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. SIXTH CLAIM Aiding and Abetting Violation of Section 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Rules 12b-20 and 13a-1 Thereunder [17 C.F.R. §§240.12b-20, 240.13a-1] by Baldwin 58. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-57 of the Complaint. 59. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 60. Baldwin denies the allegations contained in paragraph 60 of the Complaint. 61. Baldwin denies the allegations contained in paragraph 61 of the Complaint. 62. Baldwin denies the allegations contained in paragraph 62 of the Complaint. SEVENTH CLAIM Violation of Section 13(b)(2)(A) of the Exchange Act [15 U.S.C. §78m(b)(2)(A)] by JBI 63. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-62 of the Complaint. 64. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 65. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. EIGHTH CLAIM Aiding and Abetting Violation of Section 13(b)(2)(A) of the Exchange Act [15 U.S.C. §78m(b)(2)(A)] by Bordynuik and Baldwin 66. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1- 65 of the Complaint. 67. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 68. Baldwin denies the allegations contained in paragraph 68 of the Complaint. 69. Baldwin denies the allegations contained in paragraph 69 of the Complaint. 70. Baldwin denies the allegations contained in paragraph 70 of the Complaint. NINTH CLAIM Violation of Section 13(b)(2)(B) of the Exchange Act [15 U.S.C. §78m(b)(2)(B)] by JBI 71. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-70 of the Complaint. 72. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 73. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. TENTH CLAIM Aiding and Abetting Violation of Section 13(b)(2)(B) of the Exchange Act [15 U.S.C. §78m(b)(2)(B)] by Bordynuik and Baldwin 74. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1- 73 of the Complaint. 75. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 76. Baldwin denies the allegations contained in paragraph 76 of the Complaint. 77. Baldwin denies the allegations contained in paragraph 77 of the Complaint. 78. Baldwin denies the allegations contained in paragraph 78 of the Complaint. ELEVENTH CLAIM Violation of Section 13(b)(5) of the Exchange Act [15 U.S.C. §78m(b)(5] by All Defendants 79. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-78 of the Complaint. 80. Baldwin denies the allegations contained in paragraph 80 of the Complaint. 81. Baldwin denies the allegations contained in paragraph 81 of the Complaint. 82. Baldwin denies the allegations contained in paragraph 82 of the Complaint TWELFTH CLAIM Violation of Exchange Act Rule 13b2-1 [17 C.F.R. §240.13b2-1] by Bordynuik and Baldwin 83. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-82 of the Complaint. 84. Baldwin denies the allegations contained in paragraph 84 of the Complaint. 85. Baldwin denies the allegations contained in paragraph 85 of the Complaint THIRTEENTH CLAIM Violation of Exchange Act Rule 13b2-2 [17 C.F.R. §240.13b2-2] by Bordynuik 86. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-85 of the Complaint. 87. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to bedirected at Baldwin, said allegations are denied. 88. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. 89. The allegations contained in this paragraph pertain to a defendant other than Baldwin and no response is required. To the extent any of the allegations are deemed to be directed at Baldwin, said allegations are denied. FOURTEENTH CLAIM Violation of Exchange Act Rule 13a-14 [[17 C.F.R. §240.13A-14] by Bordynuik and Baldwin 90. Baldwin incorporates by reference as if stated herein his answers to paragraphs 1-89 of the Complaint. 91. Baldwin denies the allegations contained in paragraph 91 of the Complaint. 92. Baldwin denies the allegations contained in paragraph 92 of the Complaint. Ronald Baldwin, Jr.'s ANSWER to 1 Complaint Doc 13 PDF file viewer.zoho.com or tinyurl.com