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ACQUINITY 2

ACQUINITY 2

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Published by jas_onstateham
ACQUINITY 2
ACQUINITY 2

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Published by: jas_onstateham on Oct 31, 2012
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07/10/2013

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L
YDECKER
D
IAZ
 
1221 Brickell Avenue
·
19
th
Floor
·
Miami
·
Florida 33131
·
(305) 416-3180
IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF FLORIDACASE NO.: 12-CV-61677NICOLE MORELAND, individually and onBehalf of all others similarly situated,
Plaintiff,
v.ACQUINITY INTERACTIVE, LLC, aDelaware limited liability company, andMODERNAD MEDIA, LLC, a Florida limitedliability company,
 Defendants.
 / 
DEFENDANTS’, ACQUINITY INTERACTIVE, LLC AND MODERNAD MEDIA, LLC’sANSWER AND AFFIRMATIVE DEFENSES TO CLASS ACTION COMPLAINT FORDAMAGES
COMES NOW Defendants, ACQUINITY INTERACTIVE, LLC, a Delaware limitedliability company, and MODERNAD MEDIA, LLC, a Florida limited liability company(hereinafter “Defendants”), by and through their undersigned counsel and in accordance withLocal Rules 2.02 of the United States District Court for the Southern District of Florida, herebyfiles their Answer and Affirmative Defenses to Plaintiff’s Complaint for Damages and demandsa trial by jury, and in response, hereby states as follows:
ANSWER
1. Defendants deny the allegations contained in Paragraph 1 and hereby demandsstrict proof thereof.2. Defendants deny the allegations contained in Paragraph 2 and hereby demandsstrict proof thereof.3. Defendants deny the allegations contained in Paragraph 3 and hereby demandsstrict proof thereof.
Case 0:12-cv-61677-MGC Document 17 Entered on FLSD Docket 10/16/2012 Page 1 of 7
 
 
L
YDECKER
D
IAZ
 
1221 Brickell Avenue
·
19
th
Floor
·
Miami
·
Florida 33131
·
(305) 416-3180
- 2 -
4. Defendants deny the allegations contained in Paragraph 4 and hereby demandsstrict proof thereof.5. The Defendants deny the allegations contained in Paragraph 5 as to “unlawfulconduct,” and admit as to the relief Plaintiff seeks, but deny the paragraph as to entitlement forrelief sought.6. Defendants admit the allegations contained in Paragraph 6 for jurisdictionalpurposes only; denied for any other purpose.7. Defendants admit the allegations contained in Paragraph 7 for jurisdictionalpurposes only; denied for any other purpose.8. Defendants deny the allegations contained in Paragraph 8 and hereby demandsstrict proof thereof.9. Defendants admit the allegations contained in Paragraph 9 for jurisdictionalpurposes only; denied for any other purpose.10. Defendants admit the allegations contained in Paragraph 10 for jurisdictionalpurposes only; denied for any other purpose.11. Defendants are without knowledge as to the allegations contained in Paragraph 11and hereby demand strict proof thereof.12. Defendants are without knowledge as to the allegations contained in Paragraph12 and hereby demand strict proof thereof.13. Defendants deny the allegations contained in Paragraph 13 and hereby demandsstrict proof thereof.14. Defendants are without knowledge as to the allegations contained in Paragraph14 and hereby demand strict proof thereof.
Case 0:12-cv-61677-MGC Document 17 Entered on FLSD Docket 10/16/2012 Page 2 of 7
 
 
L
YDECKER
D
IAZ
 
1221 Brickell Avenue
·
19
th
Floor
·
Miami
·
Florida 33131
·
(305) 416-3180
- 3 -
15. As to the Plaintiff, Defendants are without knowledge as to the allegationscontained in Paragraph 15 and hereby demand strict proof thereof.16. Defendants deny the allegations contained in Paragraph 16. As to footnote 1referenced in this paragraph, this allegation is neither relevant nor admissible and as such shouldbe stricken from the Complaint. As to the footnote 2, the webpage is being misconstrued andspeaks for itself.17. Defendants deny the allegations contained in Paragraph 17 and hereby demandsstrict proof thereof.18. Defendants deny the allegations contained in Paragraph 18 and hereby demandsstrict proof thereof.19. Defendants deny the allegations contained in Paragraph 19 and hereby demandsstrict proof thereof.20. Defendants deny the allegations contained in Paragraph 20 and hereby demandsstrict proof thereof.21. Defendants deny the allegations contained in Paragraph 21 and hereby demandsstrict proof thereof.22. Defendants deny the allegations contained in Paragraph 22 and hereby demandsstrict proof thereof.23. Defendants deny the allegations contained in Paragraph 23 and hereby demandsstrict proof thereof.24. Defendants deny the allegations contained in Paragraph 24, and hereby demandsstrict proof thereof.25. Defendants deny the allegations contained in Paragraph 25, and hereby demands
Case 0:12-cv-61677-MGC Document 17 Entered on FLSD Docket 10/16/2012 Page 3 of 7

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