Posted in: commodities-and-mining
RE: Frontera Archive20 Nov 2019 11:21
Posted by Earsbern on the 18th November :-
Docs 15 & 16 in Texas case (the 500m shares)
Doc 15 is 6 pages long and is SN's answer to OMF's 'original complaint' (believed to be doc. 1 - hereinafter OC).
Doc 15 consists of 46 paragraphs. Paras 1-39 answer the corresponding paras 1-39 of the OC, and often consist of a single sentence of admittance, denial or statement of insufficient information available to make a reply. Unfortunately you need to have the OC in front of you to follow the argument, and the OC is 119 pages long - I haven't looked at the OC, much less copied it, and as it is probably legal and technical and beyond my understanding, I don't intend to! (Oh, and copying all that - even for your consumption, dear readers - would, I'm afraid, be more than I could stand!).
If it helps, I made it roughly 13.5 paras which were mainly admittances, 22.5 mainly denials and 3 'insufficient info'.
I'll try and copy paras. 40-46 now (probably 2 fairly small postings).
Doc 16 is an order signed by the judge stating that, as SN has filed an answer, the court denies OMF's earlier motion for a default judgement.
Sorry about this, but I cannot copy paras 40 - 46. I'll keep trying. Don't know why - I'll keep trying.
OK - I give up on the copy.
Very broadly, I believe that 40-46 state that
SN denies all allegations not otherwise explicitly denied, pleads that OMF has failed to state a claim which can be granted, that OMF's claims are barred 'by res judica and collateral estoppel' (?), that OMF's claims are barred by the passage of time or laches' (?) and that OMF's claims are barred 'for failure to join FRC an FIC as indispensable parties'.
SN also reserves the right to amend (his) answers, including any affirmative defences after a close investigation of the claims.
SN also pleads to be awarded costs and legal fees.
That's it.
Sn's attorney is Robert P. Vining of Schouest, Bamdas, Soshea & BenMair, PLLC of Houston.