The latest Investing Matters Podcast episode featuring Jeremy Skillington, CEO of Poolbeg Pharma has just been released. Listen here.
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Quite a load of docs to go through.
Some of the standouts:
Prove of FRGC transfer to FRUS
Credit Loan Facilities
Prove of link between ZZ and GC
Here goes the summary - apologies for formatting:
118225056\V-6
CAUSE NO. 2021-03816
ZAZA MAMULAISHVILI, individually § IN THE DISTRICT COURT OF
And derivatively on behalf of Frontera §
Resources Corporation §
§
Plaintiff, §
§
v. §
§
STEVE NICANDROS, LUIS GIUSTI and § HARRIS COUNTY, TEXAS
TYLER NELSON §
§
Defendants, §
§
And §
§
FRONTERA RESOURCES CORPORATION §
§
Nominal Defendant § 281st JUDICIAL DISTRICT
COUNTER-PLAINTIFF FRONTERA RESOURCE CORPORATION’S RESPONSE TO
COUNTER-DEFENDANT ZAZA MAMULAISHVILI’S MOTION TO DISMISS FIRST
AMENDED COUNTERCLAIMS FOR LACK OF SUBJECT MATTER JURISDICTION
TO THE HONORABLE JUDGE CHRISTINE WEEMS:
Counter-Plaintiff Frontera Resource Corporation (“Frontera’) files this Response (the
“Response”) to Counter-Defendant Zaza Mamulaishvili’s (“ZM”) Motion to Dismiss the First
Amended Counterclaim of Frontera for lack of subject matter jurisdiction (the “Motion to
Dismiss”), and as grounds for denying this motion would show the following:
I. SUMMARY OF ARGUMENT
Frontera clearly has standing to pursue injunctive relief against the plaintiff, ZM,1
including the TRO that necessarily found both personal and subject matter jurisdiction over ZM
1
Plaintiff ZM has appeared both individually and derivatively and thus has waived any special appearance as stated
by Judge Roth on April 30, 2021. See, Hearing Transcript attached as Exhibit 1, at p. 8 (“He has submitted himself
to the jurisdiction of this Court. That is without doubt.”).
5/14/2021 10:36 AM
Marilyn Burgess - District Clerk Harris County
Envelope No. 53446551
By: Bonnie Lugo
Filed: 5/14/2021 10:36 AM
118225056\V-6 2
before it was granted,2
and the Application for Temporary Injunction to prevent this terminated
employee from competing in violation of the Employment Agreement he signed with Frontera.
The Motion to Dismiss should be denied on this basis alone since ZM signed the Employment
Agreement submitting himself to this Court’s jurisdiction, paid himself under this Agreement at
his discretion, and agreed in this document to the injunctive relief issued by the Court. Frontera
also has standing as it has spent more than $550,000,000 acquiring assets that ZM is in the
process of stealing, all of which are owned by Frontera.
II. FACTS SUPPORTING DENIAL OF MOTION TO DISMISS
1. ZM’s Motion to Dismiss is preposterous as it is based on numerous false premises
and must be denied. The first premise that Frontera is not the owner of its assets is entirely false
as all such assets and money consolidate up into the parent company, Frontera, as the beneficial
owner. Frontera’s wholly owned subsidiaries have had only operating responsibilities over time,
and are not the ultimate owners of any of the assets of Frontera.3