Attached files

file filename
EX-31.1 - EXHIBIT 31.1 - Brushy Resources, Inc.star_ex311.htm
EX-3.2 - EXHIBIT 31.2 - Brushy Resources, Inc.star_ex312.htm
EX-32.1 - EXHIBIT 32.1 - Brushy Resources, Inc.star_ex321.htm
10-Q - STARBOARD RESOURCES, INC. 10-Q JUNE 30, 2013 - Brushy Resources, Inc.star_10q.htm
EXHIBIT 99.1.2
 
DN (X08) FST-CV-12-6014987 S
DN (X08) FST-CV-12-5013927 S
 
CHARLES HENRY III, AHMED AMMAR,
)
SUPERIOR COURT
JOHN P. VAILE AS TRUSTEE OF JOHN P.
)
 
VAILE LIVING TRUST, JOHN PAUL OTIENO,
)
COMPLEX LITIGATION
SOSVENTURES LLC, BRADFORD HIGGINS,
)
DOCKET
WILLIAM MAHONEY, ROBERT J. CONRADS,
)
 
EDWARD M. CONRADS, WILLIAM F.
)
AT STAMFORD
PETTINATI, JR., AND ANDY LEE,
)
 
INDIVIDUALLY AND DERIVATIVELY ON
)
 
BEHALF OF GIDDINGS OIL & GAS LP,
)
 
HUNTON OIL PARTNERS LP AND
)
 
ASYM ENERGY FUND III LP
)
 
 
)
 
v.
)
 
 
)
 
GREGORY IMBRUCE, GIDDINGS
)
 
INVESTMENTS LLC, GIDDINGS
)
 
GENPAR LLC,HUNTON OIL GENPAR LLC,
)
 
ASYM CAPITAL III LLC, STARBOARD
)
 
RESOURCES, INC. f/k/a STARBOARD
)
 
RESOURCES, LLC, GLENROSE HOLDINGS
)
 
LLC, AND ASYM ENERGY
)
 
INVESTMENTS LLC
)
August 9, 2013
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
1

 
 
STARBOARD RESOURCES, INC. f/k/a/ STARBOARD RESOURCES, LLC’S
ANSWER TO THIRD AMENDED COMPLAINT
 
1.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
2.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
3.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
4.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
5.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
6.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
7.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
8.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
9.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
10.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
11.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
12.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
13  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
2

 
 
Parties
 
14.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
15.  
The undersigned Defendant does not have enough knowledge to respond to the allegation  and leaves the Plaintiff to their proof.
16.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
17.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiffs to their proof.
18.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
19.  
Admit.
20.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
21.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
22.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
23.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
24.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
25.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
26.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
3

 
 
27.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
28.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
29.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
30.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
31.  
The undersigned Defendant does not respond to the allegations of this count as they are not addressed to it.
32.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
33.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
34.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
35.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
36.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
37.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
4

 
 
38.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
39.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
40.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
41.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiffs to their proof.
42.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
43.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
44.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
45.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
46.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiffs to their proof.
47.  
Admit.
48.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
49.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
5

 
 
FACTS
Hunton LP
 
50.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
51.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it
52.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
53.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
54.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
55.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
56.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
57.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
58.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
59.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
60.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
6

 
 
61.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
62.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
63.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
64.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
65.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
66.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
67.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
68.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
69.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
Giddings LP
 
70.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
71.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
7

 
 
72.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
73.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
74.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
75.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
76.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
77.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
78.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
79.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
80.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
81.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
82.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
8

 
 
83.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
84.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
85.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
86.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
87.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
88.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
89.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
90.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
91.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
92.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
93.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
9

 
 
94.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
95.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
96.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
97.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
98.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
99.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
100.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
101.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
102.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
103.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
104.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
105.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
106.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
107.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
10

 
 
ASYM III LP
 
108.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
109.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
110.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
111.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
112.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
113.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
114.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
115.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
11

 
 
116.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
117.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
118.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
119.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
120.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
121.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
122.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
123.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
124.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
125.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
126.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
12

 
 
127.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
128.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
129.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
130.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
131.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
132.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
133.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
134.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
135.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
136.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
137.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
13

 
 
138.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
139.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
140.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
141.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
142.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
143.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
144.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
145.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
146.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
147.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
148.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
14

 
 
THE STARBOARD ROLL-UP TRANSACTION
 
149.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
150.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
151.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
152.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
153.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
154.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
155.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
156.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
157.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
158.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
159.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
160.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
15

 
 
161.  
The undersigned Defendant does not respond to the allegations of this count as they are not addressed to it.
162.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
163.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
164.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
165.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
166.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
167.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
168.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
169.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
170.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
16

 
 
171.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
172.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
173.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
174.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
175.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
176.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
177.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
178.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
179.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
180.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
181.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
17

 
 
182.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
183.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
184.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
185.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
186.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
187.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
188.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
189.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
190.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
191.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
192.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
18

 
 
193.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
194.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
195.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
196.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
197.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
198.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
199.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
200.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
201.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
202.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
203.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
19

 
 
204.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
205.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
206.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
207.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
208.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
209.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
210.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
211.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
212.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
213.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
214.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
20

 
 
215.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
216.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
217.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
218.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
219.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
220.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
221.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
222.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
223.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
224.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
225.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
21

 
 
226.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
227.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
228.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
229.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
230.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
231.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
232.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
233.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
234.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
235.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
236.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
22

 
 
237.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
238.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
239.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
240.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
241.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
242.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
243.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
244.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
245.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
246.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
247.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
23

 
 
248.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
249.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
250.  
Admit.
251.  
Admit.
252.  
Admit.
253.  
Admit.
254.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
255.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
256.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
257.  
Admit.
258.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
259.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
260.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
24

 
 
261.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
262.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
263.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
264.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
265.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
266.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
267.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
268.  
Admit.
269.  
Admit.
270.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
271.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
272.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
273.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
25

 
 
274.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
275.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
276.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
277.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
278.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
279.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
280.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
281.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
282.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
283.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
284.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
26

 
 
285.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
286.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
287.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
288.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
289.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
290.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
291.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
292.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
293.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
294.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
295.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
27

 
 
296.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
297.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
298.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
299.  
Admit.
300.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
301.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
302.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
303.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
304.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
305.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
306.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
307.  
Admit.
308.  
Admit.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
28

 
 
309.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof..
310.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
311.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
312.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
313.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
314.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
315.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
316.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
317.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
318.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
319.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
29

 
 
320.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
321.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
322.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
323.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
324.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
325.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
326.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
327.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
328.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
329.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
330.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
30

 
 
331.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
332.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
333.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
334.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
335.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
336.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
337.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
338.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
339.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
340.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
341.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
31

 
 
Summary of the Imbruce Defendants’ Wrongful Acts
 
342.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
343.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
344.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
345.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
346.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
347.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
348.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
349.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
350.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
351.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
352.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
32

 
 
353.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
354.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
355.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
356.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
357.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
358.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
359.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
360.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
361.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
362.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
363.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
33

 
 
364.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
365.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
366.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
367.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
368.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
369.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
370.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
371.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
372.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
373.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
374.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
34

 
 
375.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
376.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
377.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
378.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
379.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
380.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
381.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
382.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
383.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
384.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
385.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
35

 
 
386.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
387.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
388.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
389.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
390.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
391.  
The undersigned Defendant does not have enough knowledge to respond to this allegation and leaves the Plaintiff to their proof.
392.  
The undersigned Defendant does not have enough knowledge to respond to this allegation and leaves the Plaintiff to their proof.
393.  
The undersigned Defendant does not have enough knowledge to respond to this allegation and leaves the Plaintiff to their proof.
394.  
The undersigned Defendant does not have enough knowledge to respond to this allegation and leaves the Plaintiff to their proof.
395.  
The undersigned Defendant does not have enough knowledge to respond to this allegation and leaves the Plaintiff to their proof.
396.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
36

 
 
397.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
398.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
399.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
400.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
401.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
402.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
403.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
404.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
405.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
406.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
407.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
37

 
 
408.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
409.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
410.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
411.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
412.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
413.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
414.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
415.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
416.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
417.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
418.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
38

 
 
419.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
420.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
421.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
422.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
423.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
424.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
425.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
426.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
427.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
428.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
429.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
39

 
 
430.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
431.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
432.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
433.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
434.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
435.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
436.  
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
437.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
438.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
439.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
440.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
40

 
 
441.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
442.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
443.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
444.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
445.  
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
First Count:
Injunctive Relief by Hunton Limited Partners and Hunton LP against Imbruce Defendants

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Second count:
Declaratory Judgment by Hunton Limited Partners and Hunton LP Against Imbruce Defendants

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Third Count:
Unjust Enrichment by Hunton Limited Partners and Hunton LP Against Imbruce Defendants

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Fourth Count:
Action for Accounting Against Imbruce Defendants by Hunton Limited Partners and Hunton LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Fifth Count:
Action for Imposition of a Constructive Trust Against Imbruce Defendants by Hunton Limited Partners and Hunton LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
41

 
 
Sixth Count:
Common Law Fraud Against Imbruce Defendants by Hunton Limited Partners and Hunton LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Seventh Count:
Breach of Fiduciary Duties Against Imbruce Defendants by Hunton Limited Partners and Hunton LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Eighth Count:
Conversion Against Imbruce Defendants by Hunton Limited Partners and Hunton LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Ninth Count:
Civil Theft Against Imbruce Defendants by Hunton Limited Partners and Hunton LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Tenth Count:
Civil Conspiracy Against Imbruce Defendants by Hunton Limited Partners and Hunton LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Eleventh Count:
Negligence Against Imbruce Defendants by Hunton Limited Partners and Hunton LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twelfth Count:
Injunctive Relief by SOSv and Higgins Against Imbruce Defendants Re: Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirteenth Count:
Declaratory Judgment by SOSv and Higgins against Imbruce Defendants Re: Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Fourteenth Count:
Unjust Enrichment Against Imbruce Defendants by SOSv and Higgins Re: Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
42

 
 
Fifteenth Count:
Action for Accounting Against Imbruce Defendants by SOSv and Higgins Re: Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Sixteenth Count:
Action for Imposition of a Constructive Trust Against Imbruce Defendants by SOSv and Higgins Re: Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Seventeenth Count:
Injunctive Relief by SOSv and Higgins Against Imbruce Defendants Re: ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Eighteenth Count:
Declaratory Judgment by SOSv and Higgins Against Imbruce Defendants Re: ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Nineteenth Count:
Unjust Enrichment Against Imbruce Defendants by SOSv and Higgins Re: ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twentieth Count:
Action for Accounting Against Imbruce Defendants by SOSv and Higgins Re: ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twenty-First Count:
Action for Imposition of a Constructive Trust Against Imbruce Defendants by SOSv and Higgins Re: ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twenty-Second Count:
Injunctive Relief Against Starboard by all Plaintiffs
 
The undersigned Defendant does not have enough knowledge to respond to the allegation and leaves the Plaintiff to their proof.
 
Twenty-Third Count:
Injunctive Relief by Giddings Limited Partners (Except SOSv and Higgins) and Giddings LP Against Imbruce Defendants

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
43

 
 
Twenty-Fourth Count:
Declaratory Judgment by Giddings Limited Partners (Except SOSv and Higgins) and Giddings LP Against Imbruce Defendants

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twenty-Fifth Count:
Unjust Enrichment Against Imbruce Defendants by Giddings Limited Partners (Except SOSv and Higgins) and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twenty-Sixth Count:
Action for Accounting Against Imbruce Defendants by Giddings Limited Partners (Except SOSv and Higgins) and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twenty-Seventh Count:
Action for Imposition of a Constructive Trust Against Imbruce Defendants by Giddings Limited Partners (Except SOSv and Higgins) and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twenty-Eighth Count:
Common Law Fraud Against Imbruce Defendants by Giddings Limited Partners and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Twenty-Ninth Count:
Breach of Fiduciary Duties Against Imbruce Defendants by Giddings Limited Partners and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirtieth Count:
Conversion Against Imbruce Defendants by Giddings Limited Partners and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirty-First Count:
Civil Theft Against Imbruce Defendants by Giddings Limited Partners and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
44

 
 
Thirty-Second Count:
Civil Conspiracy Against Imbruce Defendants by Giddings Limited Partners and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirty-Third Count:
Negligence Against Imbruce Defendants by Giddings Limited Partners and Giddings LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirty-Fourth Count:
Injunctive Relief by ASYM III Limited Partners (Except SOSv and Higgins) and ASYM III LP Against Imbruce Defendants

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirty-Fifth Count:
Declaratory Judgment by ASYM III Limited Partners (Except SOSv and Higgins) and ASYM III LP Against Imbruce Defendants

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirty-Sixth Count:
Common Law Fraud Against Imbruce Defendants by ASYM III Limited Partners and ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirty-Seventh Count:
Breach of Fiduciary Duties Against Imbruce Defendants by ASYM III Limited Partners and ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirty-Eighth Count:
Conversion Against Imbruce Defendants by ASYM III Limited Partners and ASYM III LP
 
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Thirty-Ninth Count:
Civil Theft Against Imbruce Defendants by ASYM III Limited Partners and ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Fortieth Count:
Unjust Enrichment Against Imbruce Defendants by ASYM III Limited Partners (Except SOSv and Higgins) and ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
45

 
 
Forty-First Count:
Civil Conspiracy Against Imbruce Defendants by ASYM III Limited Partners and ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Forty-Second Count:
Action for Accounting Against Defendants by ASYM III Limited Partners (Except SOSv and Higgins) and ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Forty-Third Count:
Action for Imposition of a Constructive Trust Against Imbruce Defendants by ASYM III Limited Partners (Except SOSv and Higgins) and ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Forty-Fourth Count:
Negligence Against Imbruce Defendants by ASYM III Limited Partners and ASYM III LP

The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
Forty-Fifth Count:
Fraudulent Conveyance as Against Gregory Imbruce
 
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
46

 
 
Forty-Sixth Count:
Action for Breach of Employment Contract by Plaintiff, Andy Lee, Against Imbruce Defendants
 
The undersigned Defendant does not respond to the allegation as it is not addressed to it.
 
 
DEFENDANT,
STARBOARD RESOURCES LLC
 
 
_________________________
Samuel I. Reich, Esq.
Stephen P. Brown, Esq.
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
1010 Washington Blvd.
Stamford, CT 06511
(203) 388-9100
(203) 388-9101 (facsimile)
Juris No: 412712
File No: 14111.00001
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
 
47

 
 
CERTIFICATION
 
The following has been sent on the _____th day of August 2013, to all parties of record:

Jonathon P. Whitcomb
Diserio Martin O’Connor & Castiglioni
One Atlantic Street
Stamford, CT 06901
 
_____________________
Samuel I. Reich, Esq.
Stephen P. Brown, Esq.
 
 
 
Answer of Starboard Resources, Inc. to Third Amended Complaint
48