IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF OKLAHOMA 1. NATIONAL ASSOCIATION OF FORENSIC ) COUNSELORS, INC., a Nevada Non-Profit ) Corporation; et al. ) ) Plaintiffs, ) ) v. ) Case No.: 6:14-cv-00187-RAW ) 1. NARCONON INTERNATIONAL, a California ) Non-Profit Corporation; et al. ) ) Defendants. )
ANSWER AND COUNTERCLAIM OF NARCONON OF OKLAHOMA, INC.
The Defendant, Narconon of Oklahoma, Inc. (“NNOK”) hereby answers the
Complaint of Plaintiffs, National Association of Forensic Counselors, Inc. (hereinafter
“NAFC”) and American Academy of Certified Forensic Counselors, Inc. d/b/a American College of Certified Forensic Counselors (hereinafter “ACCFC”), and counterclaims
against NAFC and ACCFC.
ANSWER
COMES NOW NNOK and for its Answer to the Complaint of NAFC and ACCFC, does generally and specifically deny each and every allegation contained in the Plaintiffs' Complaint except those admitted below:
PARTIES JURISDICTION AND VENUE
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1. NNOK is without sufficient knowledge to admit or deny the allegations
contained in paragraph 1 of Plaintiffs’ Complaint and therefore denies them.
2. NNOK is without sufficient knowledge to admit or deny the allegations
contained in paragraph 2 of Plaintiffs’
Complaint and therefore denies them. 3.
The allegations contained in paragraph 3 of Plaintiffs’ Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required, NNOK is without sufficient information to admit or deny those allegations and therefore denies them. 4.
NNOK admits the allegations contained in paragraph 4 of Plaintiffs’
Complaint. 5.
The allegations contained in paragraph 5 of Plaintiffs’ Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required, NNOK is without sufficient knowledge to admit or deny those allegations and therefore denies them. 6.
The allegations contained in paragraph 6 of Plaintiffs’ Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required, NNOK is without sufficient knowledge to admit or deny those allegations and therefore denies them. 7.
The allegations contained in paragraph 7 of Plaintiffs’ Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore denies them. 8.
The allegations contained in paragraph 8 of Plaintiffs’ Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required, NNOK is without sufficient knowledge to admit or deny those allegations and therefore denies them. 9.
The allegations contained in paragraph 9 of Plaintiffs’ Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required, NNOK is without sufficient knowledge to admit or deny those allegations and therefore denies them. 10.
The allegations contained in paragraph 10 of Plaintiffs’ Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required, NNOK is without sufficient knowledge to admit or deny those allegations and therefore denies them. 11.
The allegations contained in paragraph 11 of Plaintiffs’ Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required, NNOK is without sufficient knowledge to admit or deny those allegations and therefore denies them. 12.
The allegations contained in paragraph 12 of Plaintiffs’ Comp
laint are unrelated to and require no answer from NNOK. To the extent that an answer is required, NNOK is without sufficient knowledge to admit or deny those allegations and therefore denies them.
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