Gordon Stein, CFO of CleanTech Lithium, explains why CTL acquired the 23 Laguna Verde licenses. Watch the video here.
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Ah, started typing and got caught in a call
Thanks for sharing Taffy, cheers
Here snakkkkkkkkkeeeeyyy snake
Sssssss
I'd like to add my thanks too Taffy,
It looks very much the same as the SN response then.
Bezzy
Never fear - if there is the possibility of an opportunity to paint a negative picture they 3 stooges will be along with the docs shortly
Hopefully starage will be back on the team after his failure suspension of yesterday
At least he flags up when they are released
We want star
We want star
We want star
Thanks for posting docs.
Taffy: many thanks for posting.
We didn't see all of Steve's defence a day or two back; are you able to access that?
I am guessing it might be identical to this one?
Thanks Taffy good to know you're looking in
44. Plaintiffâs claims are barred by the passage of time or laches.
4
Case 4:19-cv-02714 Document 20 Filed on 11/20/19 in TXSD Page 5 of 6
45. Plaintiffâs claims are barred for failure to join Frontera Resources Corporation and Frontera International Corporation as indispensable parties.
46. Defendant reserves the right to amend its Answer to Plaintiffâs Complaint, including asserting any other affirmative defenses, after it has had an opportunity to more closely investigate these claims as it is their right and privilege under the Federal Rules of Civil Procedure.
WHEREFORE, PREMISES CONSIDERED, Defendant Zaza Mamulaishvili, respectfully prays that Plaintiff take nothing against Defendant, that Defendant be awarded its costs and attorneyâs fees, and for all such other and further relief, both general and special, at law and in equity, to which Defendant may show himself justly entitled.
OF COUNSEL:
SCHOUEST, BAMDAS, SOSHEA & BENMAIER, PLLC
1001 McKinney Street, Suite 1400 Houston, Texas 77002
Telephone: (713) 588-0446
Fax: (713) 574-2942
5
Respectfully Submitted;
_/s/ Robert P. Vining________ Robert P. Vining Attorney-in-charge
State Bar Number: 24049870 rvining@sbsblaw.com
1001 McKinney Street, Suite 1400 Houston, Texas 77002
Telephone: (713) 588-0446
Fax: (713) 574-2942
ATTORNEYS FOR
ZAZA MAMULAISHVILI
Case 4:19-cv-02714 Document 20 Filed on 11/20/19 in TXSD Page 6 of 6
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has been forwarded to all known counsel of record, in accordance with the Federal Rules of Civil Procedure on this 20th day of November 2019.
/s/ Robert P. Vining Robert P. Vining
6
Paragraph 15 of the Complaint.
16. Defendant admits the allegations contained in Paragraph 16 of the Complaint.
17. Defendant admits the allegations contained in Paragraph 17 of the Complaint.
18. Defendant admits the allegations contained in Paragraph 18 of the Complaint.
19. Defendant denies the allegations contained in Paragraph 19 of the Complaint.
20. Defendant denies the allegations contained in Paragraph 20 of the Complaint.
21. Defendant admits the allegations contained in Paragraph 21 of the Complaint.
22. Defendant denies the allegations contained in Paragraph 22 of the Complaint.
23. Defendant denies the allegations contained in Paragraph 23 of the Complaint.
24. Defendant denies the allegations contained in Paragraph 24 of the Complaint.
25. Defendant admits Frontera has filed suit. Defendant denies the remaining
allegations Contained in Paragraph 25 of the Complaint.
26. Defendant admits the allegations contained in Paragraph 26 of the Complaint.
27. Defendant admits that Frontera filed suit in the Northern District of California.
Defendant denies the remaining allegations contained in Paragraph 27 of the Complaint.
28. Defendant admits the allegations of the procedural posture of the referenced litigation. Defendant denies the remaining allegations contained in Paragraph 28 of the
Complaint.
29. Defendant denies the allegations contained in Paragraph 29 of the Complaint that
Frontera is in default. Defendant admits the remaining allegations contained in Paragraph 29 of the Complaint.
3
Case 4:19-cv-02714 Document 20 Filed on 11/20/19 in TXSD Page 4 of 6
IV.
CAUSE OF ACTION
30. Defendant denies the allegations contained in
31. Defendant denies the allegations contained in
32. Defendant denies the allegations contained in
33. Defendant denies the allegations contained in
34. Defendant denies the allegations contained in
35. Defendant denies the allegations contained in
36. Defendant denies the allegations contained in
37. Defendant denies the allegations contained in
38. Defendant denies the allegations contained in
39. Defendant denies the allegations contained in
Paragraph 30 of the Complaint. Paragraph 31 of the Complaint. Paragraph 32 of the Complaint. Paragraph 33 of the Complaint. Paragraph 34 of the Complaint. Paragraph 35 of the Complaint. Paragraph 36 of the Complaint. Paragraph 37 of the Complaint. Paragraph 38 of the Complaint. Paragraph 39 of the Complaint.
V. CONCLUSION AND PRAYER
40. Defendant denies the allegations contained in the paragraph beginning âWHEREFORE, PREMISES CONSIDEREDâ and all subparts.
41. Defendant denies each and every allegation not otherwise explicitly addressed herein.
VII. AFFIRMATIVE DEFENSES
42. Defendant pleads that Plaintiff has failed to state a Claim against Defendant for which relief can be granted.
43. Plaintiffâs claims are barred by res judicata and collateral estoppel.
44. Plaintiffâs claims are barred by the passage of time or laches.
4
C
Case 4:19-cv-02714 Document 20 Filed on 11/20/19 in TXSD Page 1 of 6
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION
§ OUTRIDER MASTER FUND, LP, §
v.
PLAINTIFF, §
§ CIVIL ACTION NO 4:19-CV-02714
STEVE C. NICANDROS, and § ZAZA MAMULAISHVILI, §
DEFENDANTS. §
DEFENDANT ZAZA MAMULAISHVILIâS ANSWER TO PLAINTIFFâS ORIGINAL COMPLAINT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Zaza Mamulaishvili (âMr. Mamulaishviliâ or âDefendantâ), Defendant
herein, and files this Answer to the Original Complaint (âthe Complaintâ) of Plaintiff Outrider Master Fund, LP, and would respectfully show the Court as follows:
I. PARTIES
1. Defendant is without sufficient information to admit or deny the information regarding Plaintiff Outrider Master Fund, L.P. as alleged in Paragraph 1 of the Complaint.
2. Defendant is without sufficient information to admit or deny the information regarding Steve Nicandros as alleged in Paragraph 2 of the Complaint.
3. sufficient
Complaint.
Defendant admits he is a resident of the country of Georgia. Defendant is without information to admit or deny the remaining allegations in Paragraph 3 of the
Case 4:19-cv-02714 Document 20 Filed on 11/20/19 in TXSD Page 2 of 6
II. JURISDICTION AND VENUE
4. Defendant admits there is a diversity of citizenship between the parties to this civil action, but denies the remaining factual allegations contained in Paragraph 4 of the Complaint.
5. Defendant admits that he is a co-founder of Frontera Resources Corporation (âFRCâ) and serves as its President and Chief Executive Officer, as well as a member of the Board of Directors. Defendant further admits the factual allegations as to FRC. Defendant denies the remaining allegations contained in Paragraph 5 of the Complaint.
6. Defendant admits that venue is proper in the Southern District of Texas, Houston Division, pursuant to 28. U.S.C. § 1391(b)(2) and that a mediation between FRC and Outrider occurred in Houston, Texas in 2016, but denies the remaining factual allegations contained in Paragraph 6 of the Complaint.
III.
FACTUAL BACKGROUND
7. Defendant admits there was a capitalization in 2011. Defendant is without sufficient information to form a belief in the remaining allegations of Paragraph 7 and, as a result, denies same.
8. Defendant denies the allegations contained in Paragraph 8 of the Complaint.
9. Defendant admits the allegations contained in Paragraph 9 of the Complaint.
10. Defendant admits the allegations contained in Paragraph 10 of the Complaint.
11. Defendant admits the allegations contained in Paragraph 11 of the Complaint.
12. Defendant admits the allegations contained in Paragraph 12 of the Complaint.
13. Defendant admits the allegations contained in Paragraph 13 of the Complaint.
14. Defendant admits the allegations contained in Paragraph 14 of the Complaint. 2
Case 4:19-cv-02714 Document 20 Filed on 11/20/19 in TXSD Page 3 of 6
15. Defendant admits the allegatio
Most interesting one would probably be answer to complaint.
I wonder if these relate to Zaza rather than SN? From memory the last set of docs for Texas were for SN only.
Sorry but I donât have access to share anything
20
Nov 20, 2019
Main Doc
Answer to Complaint
19
Nov 20, 2019
Main Doc
Request for Entry of Default
18
Nov 20, 2019
Main Doc
Return of Service Executed