Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 1 of 14 Page ID #:979

1 Jeffrey R. Thomas, Cal Bar. No. 179327

Email: [email protected]
2 Attorney for Defendant Gregg E. Jaclin
Thomas Law LLC
3 50 S. Steele St., Ste. 250
Denver, Colorado 80209
4 Telephone: 720.330.2805
Fax: 720.330.2806
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8
UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
10
11 SECURITIES AND EXCHANGE Case No. 2:16-cv-03250-ODW (Ex)
COMMISSION,
12 ANSWER OF DEFENDANT
Plaintiff, GREGG E. JACLIN; DEMAND
13 FOR JURY TRIAL
vs.
14 IMRAN HUSAIN and GREGG EVAN
15 JACLIN,
16 Defendants.
17
18
19 Defendant Gregg E. Jaclin (Defendant), through his counsel, answers the
20 First Amended Complaint (FAC) as follows:
21 1. Defendant admits that this Court has jurisdiction over this action and
22 denies the remaining allegations in paragraph 1 of the FAC.
23 2. Defendant denies the allegations in paragraph 2 of the FAC.
24 3. Defendant admits that venue is proper in this district and denies the
25 remaining allegations in paragraph 3 of the FAC.
26 4. Defendant denies the allegations in paragraph 4 of the FAC.
27 5. Defendant denies the allegations in paragraph 5 of the FAC.
28 6. Defendant denies the allegations in paragraph 6 of the FAC.

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1 7. Defendant denies the allegations in paragraph 7 of the FAC.

2 8. Defendant denies the allegations in paragraph 8 of the FAC.
3 9. Defendant denies the allegations in paragraph 9 of the FAC.
4 10. Defendant denies the allegations in paragraph 10 of the FAC.
5 11. Defendant denies the allegations in paragraph 11 of the FAC.
6 12. Defendant denies the allegations in paragraph 12 of the FAC.
7 13. Defendant denies the allegations in paragraph 13 of the FAC.
8 14. Defendant denies the allegations in paragraph 14 of the FAC.
9 15. Defendant denies the allegations in paragraph 15 of the FAC.
10 16. Paragraph 16 does not require a response.
11 17. Defendant lacks knowledge or information sufficient to form a belief
12 about the truth of the allegations in paragraph 17 of the FAC.
13 18. Defendant admits that he resides in Princeton Junction, New Jersey; is
14 a lawyer admitted to the bar in New York and New Jersey; and was a partner at
15 Anslow & Jaclin. Defendant denies the remaining allegations in paragraph 18 of
16 the FAC.
17 19. Defendant denies the allegations in paragraph 19 of the FAC.
18 20. Defendant lacks knowledge or information sufficient to form a belief
19 about the truth of the allegations in paragraph 20 of the FAC.
20 21. Defendant lacks knowledge or information sufficient to form a belief
21 about the truth of the allegations in paragraph 21 of the FAC.
22 22. Defendant lacks knowledge or information sufficient to form a belief
23 about the truth of the allegations in paragraph 22 of the FAC.
24 23. Defendant lacks knowledge or information sufficient to form a belief
25 about the truth of the allegations in paragraph 23 of the FAC.
26 24. Defendant lacks knowledge or information sufficient to form a belief
27 about the truth of the allegations in paragraph 24 of the FAC.
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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 3 of 14 Page ID #:981

1 25. Defendant lacks knowledge or information sufficient to form a belief

2 about the truth of the allegations in paragraph 25 of the FAC.
3 26. Defendant lacks knowledge or information sufficient to form a belief
4 about the truth of the allegations in paragraph 26 of the FAC.
5 27. Defendant lacks knowledge or information sufficient to form a belief
6 about the truth of the allegations in paragraph 27 of the FAC.
7 28. Defendant lacks knowledge or information sufficient to form a belief
8 about the truth of the allegations in paragraph 28 of the FAC.
9 29. Defendant denies the allegations in paragraph 29 of the FAC.
10 30. Defendant denies the allegations in paragraph 30 of the FAC.
11 31. Defendant denies the allegations in paragraph 31 of the FAC.
12 32. Defendant denies the allegations in paragraph 32 of the FAC.
13 33. Defendant denies the allegations in paragraph 33 of the FAC.
14 34. Defendant denies the allegations in paragraph 34 of the FAC.
15 35. Defendant denies the allegations in paragraph 35 of the FAC.
16 36. Defendant denies the allegations in paragraph 36 of the FAC.
17 37. Defendant denies the allegations in paragraph 37 of the FAC.
18 38. Defendant denies the allegations in paragraph 38 of the FAC.
19 39. Defendant lacks knowledge or information sufficient to form a belief
20 about the truth of the allegations in in paragraph 39 of the FAC.
21 40. Defendant denies the allegations in paragraph 40 of the FAC.
22 41. Defendant denies the allegations in paragraph 41 of the FAC.
23 42. Defendant lacks knowledge or information sufficient to form a belief
24 about the truth of the allegations in paragraph 42 of the FAC.
25 43. Defendant lacks knowledge or information sufficient to form a belief
26 about the truth of the allegations in paragraph 43 of the FAC.
27 44. Defendant lacks knowledge or information sufficient to form a belief
28 about the truth of the allegations in paragraph 44 of the FAC.

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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 4 of 14 Page ID #:982

1 45. Defendant denies the allegations in paragraph 45 of the FAC.

2 46. Defendant lacks knowledge or information sufficient to form a belief
3 about the truth of the allegations in paragraph 46 of the FAC.
4 47. Defendant denies the allegations in paragraph 47 of the FAC.
5 48. Defendant denies the allegations in paragraph 48 of the FAC.
6 49. Defendant lacks knowledge or information sufficient to form a belief
7 about the truth of the allegations in paragraph 49 of the FAC.
8 50. Defendant denies the allegations in paragraph 50 of the FAC.
9 51. Defendant denies the allegations in paragraph 51 of the FAC.
10 52. Defendant denies the allegations in paragraph 52 of the FAC.
11 53. Defendant lacks knowledge or information sufficient to form a belief
12 about the truth of the allegations in paragraph 53 of the FAC.
13 54. Defendant denies the allegations in paragraph 54 of the FAC.
14 55. Defendant lacks knowledge or information sufficient to form a belief
15 about the truth of the allegations in paragraph 55 of the FAC.
16 56. Defendant lacks knowledge or information sufficient to form a belief
17 about the truth of the allegations in paragraph 56 of the FAC.
18 57. Defendant lacks knowledge or information sufficient to form a belief
19 about the truth of the allegations in paragraph 57 of the FAC.
20 58. Defendant denies the allegations in paragraph 58 of the FAC.
21 59. Defendant lacks knowledge or information sufficient to form a belief
22 about the truth of the allegations in paragraph 59 of the FAC.
23 60. Defendant lacks knowledge or information sufficient to form a belief
24 about the truth of the allegations in paragraph 60 of the FAC.
25 61. Defendant denies the allegations in paragraph 61 of the FAC.
26 62. Defendant lacks knowledge or information sufficient to form a belief
27 about the truth of the allegations in paragraph 62 of the FAC.
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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 5 of 14 Page ID #:983

1 63. Defendant lacks knowledge or information sufficient to form a belief

2 about the truth of the allegations in paragraph 63 of the FAC.
3 64. Defendant denies the allegations in paragraph 64 of the FAC.
4 65. Defendant denies the allegations in paragraph 65 of the FAC.
5 66. Defendant denies the allegations in paragraph 66 of the FAC.
6 67. Defendant denies the allegations in paragraph 67 of the FAC.
7 68. Defendant denies the allegations in paragraph 68 of the FAC.
8 69. Defendant denies the allegations in paragraph 69 of the FAC.
9 70. Defendant denies the allegations in paragraph 70 of the FAC.
10 71. Defendant denies the allegations in paragraph 71 of the FAC.
11 72. Defendant denies the allegations in paragraph 72 of the FAC.
12 73. Defendant denies the allegations in paragraph 73 of the FAC.
13 74. Defendant denies the allegations in paragraph 74 of the FAC.
14 75. Defendant denies the allegations in paragraph 75 of the FAC.
15 76. Defendant denies the allegations in paragraph 76 of the FAC.
16 77. Defendant lacks knowledge or information sufficient to form a belief
17 about the truth of the allegations in paragraph 77 of the FAC.
18 78. Defendant denies the allegations in paragraph 78 of the FAC.
19 79. Defendant denies the allegations in paragraph 79 of the FAC.
20 80. Defendant lacks knowledge or information sufficient to form a belief
21 about the truth of the allegations in paragraph 80 of the FAC.
22 81. Defendant lacks knowledge or information sufficient to form a belief
23 about the truth of the allegations in paragraph 81of the FAC.
24 82. Defendant lacks knowledge or information sufficient to form a belief
25 about the truth of the allegations in paragraph 82 of the FAC.
26 83. Defendant denies the allegations in paragraph 83 the FAC.
27 84. Defendant lacks knowledge or information sufficient to form a belief
28 about the truth of the allegations in paragraph 84 of the FAC.

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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 6 of 14 Page ID #:984

1 85. Defendant lacks knowledge or information sufficient to form a belief

2 about the truth of the allegations in paragraph 85 of the FAC.
3 86. Defendant lacks knowledge or information sufficient to form a belief
4 about the truth of the allegations in paragraph 86 of the FAC.
5 87. Defendant denies the allegations in paragraph 87 of the FAC.
6 88. Defendant denies the allegations in paragraph 88 of the FAC.
7 89. Defendant lacks knowledge or information sufficient to form a belief
8 about the truth of the allegations in paragraph 89 of the FAC.
9 90. Defendant denies the allegations in paragraph 90 of the FAC.
10 91. Defendant denies the allegations in paragraph 91 of the FAC.
11 92. Defendant lacks knowledge or information sufficient to form a belief
12 about the truth of the allegations in paragraph 92 of the FAC.
13 93. Defendant lacks knowledge or information sufficient to form a belief
14 about the truth of the allegations in paragraph 93 of the FAC.
15 94. Defendant denies the allegations in paragraph 94 of the FAC.
16 95. Defendant denies the allegations in paragraph 95 of the FAC.
17 96. Defendant lacks knowledge or information sufficient to form a belief
18 about the truth of the allegations in paragraph 96 of the FAC.
19 97. Defendant lacks knowledge or information sufficient to form a belief
20 about the truth of the allegations in paragraph 97 of the FAC.
21 98. Defendant denies the allegations in paragraph 98 of the FAC.
22 99. Defendant denies the allegations in paragraph 99 of the FAC.
23 100. Defendant denies the allegations in paragraph 100 of the FAC.
24 101. Defendant lacks knowledge or information sufficient to form a belief
25 about the truth of the allegations in paragraph 101 of the FAC.
26 102. Defendant denies the allegations in paragraph 102 of the FAC.
27 103. Defendant denies the allegations in paragraph 103 of the FAC.
28 104. Defendant denies the allegations in paragraph 104 of the FAC.

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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 7 of 14 Page ID #:985

1 105. Defendant denies the allegations in paragraph 105 of the FAC.

2 106. Defendant lacks knowledge or information sufficient to form a belief
3 about the truth of the allegations in paragraph 106 of the FAC.
4 107. Defendant denies the allegations in paragraph 107 of the FAC.
5 108. Defendant lacks knowledge or information sufficient to form a belief
6 about the truth of the allegations in paragraph 108 of the FAC.
7 109. Defendant lacks knowledge or information sufficient to form a belief
8 about the truth of the allegations in paragraph 109 of the FAC.
9 110. Defendant lacks knowledge or information sufficient to form a belief
10 about the truth of the allegations in paragraph 110 of the FAC.
11 111. Defendant lacks knowledge or information sufficient to form a belief
12 about the truth of the allegations in paragraph 111 of the FAC.
13 112. Defendant denies the allegations in paragraph 112 of the FAC.
14 113. Defendant lacks knowledge or information sufficient to form a belief
15 about the truth of the allegations in paragraph 113 of the FAC.
16 114. Defendant lacks knowledge or information sufficient to form a belief
17 about the truth of the allegations in paragraph 114 of the FAC.
18 115. Defendant lacks knowledge or information sufficient to form a belief
19 about the truth of the allegations in paragraph 115 of the FAC.
20 116. Defendant lacks knowledge or information sufficient to form a belief
21 about the truth of the allegations in paragraph 116 of the FAC.
22 117. Defendant lacks knowledge or information sufficient to form a belief
23 about the truth of the allegations in paragraph 117 of the FAC.
24 118. Defendant denies the allegations in paragraph 118 of the FAC.
25 119. Defendant lacks knowledge or information sufficient to form a belief
26 about the truth of the allegations in paragraph 119 of the FAC.
27 120. Defendant lacks knowledge or information sufficient to form a belief
28 about the truth of the allegations in paragraph 120 of the FAC.

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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 8 of 14 Page ID #:986

1 121. Defendant lacks knowledge or information sufficient to form a belief

2 about the truth of the allegations in paragraph 121 of the FAC.
3 122. Defendant lacks knowledge or information sufficient to form a belief
4 about the truth of the allegations in paragraph 122 of the FAC.
5 123. Defendant denies the allegations in paragraph 123 of the FAC.
6 124. Defendant lacks knowledge or information sufficient to form a belief
7 about the truth of the allegations in paragraph 124 of the FAC.
8 125. Defendant lacks knowledge or information sufficient to form a belief
9 about the truth of the allegations in paragraph 125 of the FAC.
10 126. Defendant lacks knowledge or information sufficient to form a belief
11 about the truth of the allegations in paragraph 126 of the FAC.
12 127. Defendant lacks knowledge or information sufficient to form a belief
13 about the truth of the allegations in paragraph 127 of the FAC.
14 128. Defendant lacks knowledge or information sufficient to form a belief
15 about the truth of the allegations in paragraph 128 of the FAC.
16 129. Defendant lacks knowledge or information sufficient to form a belief
17 about the truth of the allegations in paragraph 129 of the FAC.
18 130. Defendant lacks knowledge or information sufficient to form a belief
19 about the truth of the allegations in paragraph 130 of the FAC.
20 131. Defendant lacks knowledge or information sufficient to form a belief
21 about the truth of the allegations in paragraph 131 of the FAC.
22 132. Defendant lacks knowledge or information sufficient to form a belief
23 about the truth of the allegations in paragraph 132 of the FAC.
24 133. Defendant lacks knowledge or information sufficient to form a belief
25 about the truth of the allegations in paragraph 133 of the FAC.
26 134. Defendant denies the allegations in paragraph 134 of the FAC.
27 135. Defendant denies the allegations in paragraph 135 of the FAC.
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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 9 of 14 Page ID #:987

1 136. Defendant lacks knowledge or information sufficient to form a belief

2 about the truth of the allegations in paragraph 136 of the FAC.
3 137. Defendant lacks knowledge or information sufficient to form a belief
4 about the truth of the allegations in paragraph 137 of the FAC.
5 138. Defendant lacks knowledge or information sufficient to form a belief
6 about the truth of the allegations in paragraph 138 of the FAC.
7 139. Defendant denies the allegations in paragraph 139 of the FAC.
8 140. Defendant denies the allegations in paragraph 140 of the FAC.
9 141. Defendant denies the allegations in paragraph 141 of the FAC.
10 142. Defendant denies the allegations in paragraph 142 of the FAC.
11 143. Defendant denies the allegations in paragraph 143 of the FAC.
12 144. Defendant denies the allegations in paragraph 144 of the FAC.
13 145. Defendant denies the allegations in paragraph 145 of the FAC.
14 146. Defendant denies the allegations in paragraph 146 of the FAC.
15 147. Defendant denies the allegations in paragraph 147 of the FAC.
16 148. Defendant lacks knowledge or information sufficient to form a belief
17 about the truth of the allegations in paragraph 148 of the FAC.
18 149. Defendant denies the allegations in paragraph 149 of the FAC.
19 150. Defendant denies the allegations in paragraph 150 of the FAC.
20 151. Defendant lacks knowledge or information sufficient to form a belief
21 about the truth of the allegations in paragraph 151 of the FAC.
22 152. Defendant lacks knowledge or information sufficient to form a belief
23 about the truth of the allegations in paragraph 152 of the FAC.
24 153. Defendant denies the allegations in paragraph 153 of the FAC.
25 154. Defendant denies the allegations in paragraph 154 of the FAC.
26 155. Defendant denies the allegations in paragraph 155 of the FAC.
27 156. Defendant denies the allegations in paragraph 156 of the FAC.
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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 10 of 14 Page ID #:988

1 157. Defendant lacks knowledge or information sufficient to form a belief

2 about the truth of the allegations in paragraph 157 of the FAC.
3 158. Defendant lacks knowledge or information sufficient to form a belief
4 about the truth of the allegations in paragraph 158 of the FAC.
5 159. Defendant denies the allegations that pertain to him and lacks
6 knowledge or information sufficient to form a belief about the truth of the
7 remaining allegations in paragraph 159 of the FAC.
8 160. Defendant denies the allegations that pertain to him and lacks
9 knowledge or information sufficient to form a belief about the truth of the
10 remaining allegations in paragraph 160 of the FAC.
11 161. Defendant denies the allegations that pertain to him and lacks
12 knowledge or information sufficient to form a belief about the truth of the
13 remaining allegations in paragraph 161 of the FAC.
14 162. Defendant denies the allegations that pertain to him and lacks
15 knowledge or information sufficient to form a belief about the truth of the
16 remaining allegations in paragraph 162 of the FAC.
17 163. Defendant denies the allegations that pertain to him and lacks
18 knowledge or information sufficient to form a belief about the truth of the
19 remaining allegations in paragraph 163 of the FAC.
20 164. Defendant denies the allegations that pertain to him and lacks
21 knowledge or information sufficient to form a belief about the truth of the
22 remaining allegations in paragraph 164 of the FAC.
23 165. Defendant denies the allegations that pertain to him and lacks
24 knowledge or information sufficient to form a belief about the truth of the
25 remaining allegations in paragraph 165 of the FAC.
26 166. Defendant denies the allegations in paragraph 166 of the FAC.
27 167. Defendant denies the allegations in paragraph 167 of the FAC.
28 168. Defendant denies the allegations in paragraph 168 of the FAC.

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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 11 of 14 Page ID #:989

1 169. Defendant denies the allegations in paragraph 169 of the FAC.

2 170. Defendant denies the allegations in paragraph 170 of the FAC.
3 171. Defendant admits that he entered into a tolling agreement and lacks
4 knowledge or information sufficient to form a belief about the truth of the
5 remaining allegations in paragraph 171 of the FAC.
6 172. Defendant incorporates his responses to paragraphs 1 171.
7 173. Defendant denies the allegations in paragraph 173 of the FAC.
8 174. Defendant denies the allegations in paragraph 174 of the FAC.
9 175. Defendant denies the allegations in paragraph 175 of the FAC.
10 176. Defendant denies the allegations in paragraph 176 of the FAC.
11 177. Defendant denies the allegations in paragraph 177 of the FAC.
12 178. Defendant denies the allegations in paragraph 178 of the FAC.
13 179. Defendant denies the allegations in paragraph 179 of the FAC.
14 180. Defendant denies the allegations in paragraph 180 of the FAC.
15 181. Defendant incorporates his responses to paragraphs 1 180.
16 182. Defendant denies the allegations in paragraph 182 of the FAC.
17 183. Defendant denies the allegations in paragraph 183 of the FAC.
18 184. Defendant denies the allegations in paragraph 184 of the FAC.
19 185. Defendant denies the allegations in paragraph 185 of the FAC.
20 186. Defendant denies the allegations in paragraph 186 of the FAC.
21 187. Defendant incorporates his responses to paragraphs 1 186.
22 188. Defendant denies the allegations in paragraph 188 of the FAC.
23 189. Defendant denies the allegations in paragraph 189 of the FAC.
24 190. Defendant denies the allegations in paragraph 190 of the FAC.
25 191. Defendant incorporates his responses to paragraphs 1 190.
26 192. Defendant denies the allegations in paragraph 192 of the FAC.
27 193. Defendant denies the allegations in paragraph 193 of the FAC.
28 194. Defendant denies the allegations in paragraph 194 of the FAC.

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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 12 of 14 Page ID #:990

1 195. Defendant incorporates his responses to paragraphs 1 194

2 196. Defendant denies the allegations in paragraph 196 of the FAC.
3 197. Defendant denies the allegations in paragraph 197 of the FAC.
4 198. Defendant denies the allegations in paragraph 198 of the FAC.
5 199. Defendant denies the allegations in paragraph 199 of the FAC.
6 200. Defendant denies the allegations in paragraph 200 of the FAC.
7 201. Defendant incorporates his responses to paragraphs 1 200.
8 202. Defendant denies the allegations in paragraph 202 of the FAC.
9 203. Defendant denies the allegations in paragraph 203 of the FAC.
10 204. Paragraph 204 does not require a response.
11 205. Paragraph 205 does not require a response.
12 206. Paragraph 206 does not require a response.
13 207. Paragraph 207 does not require a response.
14 208. Defendant incorporates his responses to paragraphs 1 207.
15 209. Defendant denies the allegations in paragraph 209 of the FAC.
16 210. Defendant denies the allegations in paragraph 210 of the FAC.
17 211. Defendant denies the allegations in paragraph 211 of the FAC.
18 212. Defendant denies the allegations in paragraph 212 of the FAC.
19 213. Defendant denies the allegations in paragraph 213 of the FAC.
20 214. Defendant incorporates his responses to paragraphs 1 213.
21 215. Defendant denies the allegations in paragraph 215 of the FAC.
22 216. Defendant denies the allegations in paragraph 216 of the FAC.
23 217. Defendant denies the allegations in paragraph 217 of the FAC.
24 218. Defendant denies the allegations in paragraph 218 of the FAC.
25 219. Defendant denies the allegations in paragraph 219 of the FAC.
26 220. Paragraph 220 does not require a response.
27 221. Paragraph 221 does not require a response.
28 222. Paragraph 222 does not require a response.

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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 13 of 14 Page ID #:991

1 GENERAL DENIAL
2 Defendant denies all allegations not specifically admitted.
3 AFFIRMATIVE DEFENSES
4 1. Plaintiff fails to state a claim upon which relief can be granted.
5 2. Plaintiffs claims and requests for relief are barred in whole or part by
6 applicable statutes of limitations.
7 3. Any offers or sales of securities were registered or exempt from
8 registration.
9 4. Plaintiffs claims are barred in whole or part by Plaintiffs failure to
10 plead fraud with particularity.
11 5. Defendant reserves the right to assert additional defenses as more
12 facts become known through investigation and discovery.
13 WHEREFORE, Defendant requests that the Court enter judgment in favor of
14 Defendant and against Plaintiff on each of Plaintiffs claims, award Defendant his
15 costs and expenses, including reasonable attorney fees, and grant such other relief
16 to Defendant as the Court deems just and proper.
17 JURY DEMAND
18 Defendant demands trial by jury on all issues so triable.
19
20 Dated: March 15, 2017 Respectfully Submitted,
21
/s/Jeffrey R. Thomas
22 Jeffrey R. Thomas
23 THOMAS LAW LLC
Attorney for Defendant Gregg E. Jaclin
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 Case 2:16-cv-03250-ODW-E Document 48 Filed 03/15/17 Page 14 of 14 Page ID #:992

1 PROOF OF SERVICE
2 I hereby certify that, on March 15, 2017, I electronically filed the foregoing
3 ANSWER OF DEFENDANT GREGG E. JACLIN; DEMAND FOR JURY
4 TRIAL with the Clerk of Court using the CM/ECF system which will send
5 notification of such filing to the following e-mail address(es):
6 Amy J. Longo
7 [email protected]
8 Roberto A. Tercero
[email protected]
9 George B. Newhouse, Jr.
10 [email protected]
11 Kelly R. Graf
[email protected]
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