To: scion who wrote (22061 ) 4/8/2012 2:11:57 PM From: scion Read Replies (1) | Respond to of 53574 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. Ronald Baldwin, Jr.'s ANSWER to 1 Complaint Doc 13 PDF file viewer.zoho.com or tinyurl.com SEC COMPLAINT 4. By engaging in the conduct alleged herein, JBI violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) and Sections 10(b), 13(a), 13(b)(2)(A), 13(b)(2)(B) and 13(b)(5) of the Securities Exchange Act of 1934 (“Exchange Act”) and Rules 10b-5, 12b-20, 13a-1, 13a-11 and 13a-13 thereunder. 5. By engaging in the conduct alleged herein, Bordynuik violated Sections 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5, and Section 13(b)(5) of the Exchange Act and Rules 13b2-1 and 13b2-2 thereunder, and Rule 13a-14. In addition, by engaging in the conduct alleged herein, Baldwin violated Sections 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5, and Section 13(b)(5) of the Exchange Act and Rule 13b2-1 thereunder, and Rule 13a-14. Furthermore, Bordynuik and Baldwin aided and abetted JBI’s violations of Sections 10(b), 13(a), 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act and Rules 10b-5, 12b-20 and 13a-1, thereunder, and, as to Bordynuik only, Rule 13a-11 thereunder. 6. Based on these violations, the Commission seeks the following relief against the Defendants: (i) entry of permanent injunctions prohibiting all Defendants from engaging in future violations of the sections of the securities laws that they have violated in connection with the conduct described herein; (ii) an order requiring all Defendants to disgorge their ill-gotten gains and pay pre-judgment interest; (iii) an order requiring all Defendants to pay appropriate civil monetary penalties; and, (iv) an order barring Bordynuik and Baldwin, respectively, from serving as officers or directors of a public company. Doc 1 PDF file SEC COMPLAINT sec.gov