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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 (21831)	4/5/2012 7:05:19 PM
From: scion	Respond to of 53574

GENERAL DENIAL All allegations matters or things contained in this Complaint which have not been specifically admitted herein are denied. FIRST DEFENSE This Complaint fails to state a claim against Baldwin upon which relief may be granted. SECOND DEFENSE The Complaint fails to comply with F.R.C.P. 9(b). THIRD DEFENSE Plaintiff’s claims against Baldwin are barred, in whole or in part, due to Baldwin’s good faith reliance on counsel and/or good faith reliance on one or more applicable statutes or rules. FOURTH DEFENSE Any projections or statements relating to future events announced by any of the defendants in this case were made in good faith and had a reasonable basis and are therefore not actionable. FIFTH DEFENSE Baldwin was under no duty to disclose some or all of the matters that Plaintiff claims constituted material omissions. OTHER DEFENSES These defenses are based on the knowledge and information currently possessed by the Baldwin. Baldwin reserves the right to supplement or add additional defenses as he may discover throughout the course of this case. DEMAND FOR JURY TRIAL Baldwin hereby demands a jury trial for all issues so triable. WHEREFORE, Baldwin having fully answered Plaintiff’s Complaint respectfully requests that this Court enter an order dismissing Plaintiff’s Complaint in its entirety and award Baldwin his attorney’s fees and costs for defending this lawsuit and such other relief as the Court may deem appropriate. Dated: April 5, 2012 Respectfully Submitted, Ronald Baldwin, Jr. By his attorneys, /s/ Juan Marcel Marcelino Juan Marcel Marcelino, BBO# 318810 GREENBERG TRAURIG, LLP One International Place Boston, Massachusetts 02110 Tel: (617) 310-6000 Fax: (617) 310-6001 marcelinoj@gtlaw.com Attorney for Ronald Baldwin, Jr. /s/ Ralph V. DeMartino Ralph V. DeMartino (pro hac vice pending) Cozen O’Connor 1627 I Street, NW, Suite 1100 Washington, D.C. 20006 Email: rdemartino@cozen.com Attorney for Ronald Baldwin, Jr.