UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACASE NO.: 1:13-CV-20080-JEM
JOEL L. TABAS, in his capacity as both Chapter 7Trustee of Capitol Investments USA, Inc. and asAssignee to the Claims of Bayside CapitalManagement, LLC, et al.,Plaintiff,v.SHOOK, HARDY AND BACON, L.L.P. andMARC LEVINSON, an Individual,Defendants._______________________________________ /
DEFENDANTS’ SHOOK HARDY AND BACON, LLP.’SAND MARC LEVINSON’S ANSWER AND DEFENSES TO COMPLAINT
Defendants, Shook Hardy & Bacon, LLP and Marc R. Levinson respond the Complaintas follows. All allegations not specifically admitted are denied.
I. JURISDICTION AND VENUE
1. Defendants admit that this action purports to be based on Federal statutes, Floridastatutes and the common law and seeks damages in excess of the jurisdictional amount requiredin the Court in which it was filed as well as in this Court. Defendants deny that they committedthe acts, torts or omissions alleged or that they are liable to Plaintiff.2. Defendants admit that venue lies in this District.
II. PARTIES, RELATED PERSONS AND RELATED ENTITIESA. The Debtors
3. On information and belief, Defendants admit that Capitol Investments USA, Inc.was a corporation organized under Florida law and that its principal place of business was in
Case 1:13-cv-20080-JEM Document 12 Entered on FLSD Docket 01/25/2013 Page 1 of 39