Free Answer to Counterclaim - District Court of Delaware - Delaware

Case 1:06-cv-00005-JJF Document 9 Filed O2/28/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JEFFREY M. NORMAN, :
Plaintiff,
V. Z c.A. N6. 06-005-JJF
DAVID W. ELKIN, RICHARD M. SHORIN
and THE ELKIN GROUP, INC. : Jury Trial Demanded 5
Defendants,
and
US MOBILCOMM, INC.,
Nominal Defendant.
PLAINTIFF’S REPLY TO DEFENDANTS’ COUNTERCLAIM
Plaintiff, Jeffrey M. Norman (“Plaintiff") files his reply to the cotmterclaim of q
Defendants David W. Elkin, Richard M. Shorin and U.S. Mobilcomm, Inc. (collectively, Q
"Defendants"). In support of his reply, Plaintiff responds as follows: I
125. Admitted. .
126. Denied. A
127. Admitted.
128. It is denied that Elkin contributed $750,000 to the Company in either cash or
equity. Upon infomation and belief, Plaintiff admits that Elkin purports to have advanced
additional funds to the Company to pay certain operating expenses.
129. Denied. By way of further response, Plaintiff responds by stating that he made a
$250,000 contribution to the Company in both cash and equity, the sufficiency of which was
acknowledged by the Company through both written acknowledgement and performance. It is
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Case 1:06-cv-00005-JJF Document 9 Filed O2/28/2006 Page 2 of 3
denied that Plaintiff withdrew any funds from the Company or otherwise diminished his equity
interest in the Company. 3
130. Denied.
131. Denied.
WHEREFORE, Plaintiff respectfully requests that the Court deny all relief requested 1
under the counterclaim and that Defendants’ counterclaim be dismissed with prejudice, with ip
costs and attomeys’ fees assessed against Defend ts. Q ’
Dated: February 28, 2006
Sean J. Bellew (#4072) o
David A. Felice (#4090)
Cozen O’Connor S
1201 North Market Street, Suite 1400
Wilmington, DE 19801
Telephone: (302) 295-2000
Facsimile: (302) 295-2013 r
Attorneys for PlaintM’Jejj?ey M Norman
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Case 1 :06-cv-00005-JJF Document 9 Filed O2/28/2006 Page 3 of 3
_ CERTIFICATE OF SERVICE i
I, David A. Felice, do hereby certify that on February 28, 2006, I electronically filed the Q
1 foregoing with the Clerk of Court using CM/ECF which will send notification of such filing to
1 the following counsel of record:
A Steven L. Caponi, Esquire
0 Blank Rome LLP
( 1201 N. Market Street, Suite 800 .
1 Wilmington, DE 19801 3
David A. Felice (#4090)
Cozen O’Connor 0
1201 North Market Street, Suite 1400 i
Wilmington, DE 19801 f
Telephone: (302) 295-2000
Facsimile: (302) 295-2013
E-mail: [email protected]
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