IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION
JOSEPH C. CANOUSE, an individual
Plaintiff,
v.
AMERICAN PREMIUM WATER CORPORATION, a Nevada Corporation, and ALFRED CULBRETH, an individual,
Defendants.
: : : : : : : : : : : : :
1:14-CV-02474-WSD
ANSWER AND COUNTERCLAIMS OF DEFENDANTS AMERICAN PREMIUM WATER CORPORATION AND ALFERD CULBRETH
American Premium Water Corporation (“American”) and Alferd Culbreth
(“Culbreth”), Defendants, hereby file their Answer and Counterclaims as follows:
1. American and Culbreth admit the first sentence in paragraph 1 for
jurisdictional purposes only. American and Culbreth deny all the remaining
allegations contained in paragraph 1.
2. American and Culbreth are without knowledge as to the allegations in
paragraph 2 of the Complaint, and therefore deny them.
3. American and Culbreth admit the allegations contained in paragraph 3
of the Complaint.
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4. American and Culbreth admit the allegations contained in paragraph 4
of the Complaint.
5. American and Culbreth admit the first sentence in paragraph 5 of the
Complaint. American and Culbreth deny all the remaining allegations contained in
paragraph 5 of the Complaint.
6. American and Culbreth are without knowledge as to the allegations
contained in paragraph 6 of the Complaint and therefore deny them.
7. American and Culbreth admit the allegations contained in paragraph 7
of the Complaint.
8. American states that the Series A Preferred Stock Designation of
Expert Group, Inc. (“Preferred Stock Designation”) speaks for itself and the quoted
language appears in the Preferred Stock Designation. American and Culbreth deny
all the remaining allegations contained in paragraph 8 of the Complaint.
9. American and Culbreth deny the allegations contained in paragraph 9
of the Complaint.
10. American and Culbreth deny the allegations contained in paragraph
10 of the Complaint.
11. American and Culbreth deny the allegations contained in paragraph
11 of the Complaint.
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12. American and Culbreth admit that Plaintiff Joe Canouse (“Canouse”
or “Plaintiff”) entered into a Separation Agreement. American and Culbreth deny
the all the remaining allegations contained in paragraph 12 of the Complaint.
13. American states that the Separation Agreement speaks for itself, and
that a true and correct copy of the Separation Agreement has been attached as
Exhibit B to the Complaint. American and Culbreth deny all the remaining
allegations contained in paragraph 13 of the Complaint are denied.
14. American and Culbreth admit that the Separation Agreement refers to
two convertible notes. American and Culbreth deny all the remaining allegations
contained in paragraph 14 of the Complaint.
15. American and Culbreth deny the allegations contained in paragraph
15 of the Complaint.
16. American and Culbreth deny the allegations contained in paragraph
16 of the Complaint.
17. American and Culbreth deny the allegations contained in paragraph
17 of the Complaint.
18. American and Culbreth deny the allegations contained in paragraph
18 of the Complaint.
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19. American and Culbreth admit the allegations contained in paragraph
19 of the Complaint.
20. American and Culbreth deny the allegations contained in paragraph
20 of the Complaint.
21. American and Culbreth admit the allegations contained in paragraph
21 of the Complaint.
22. American and Culbreth deny the allegations contained in paragraph
22 of the Complaint.
23. American and Culbreth deny the allegations contained in paragraph
23 of the Complaint.
24. American and Culbreth deny the allegations contained in paragraph
24 of the Complaint.
25. American and Culbreth are without knowledge regarding the
allegations contained in paragraph 25 of the Complaint, and therefore deny them.
26. American and Culbreth deny the allegations contained in paragraph
26 of the Complaint.
27. American and Culbreth deny the allegations contained in paragraph
27 of the Complaint.
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28. American and Culbreth admit the allegations contained in paragraph
28 of the Complaint.
29. American and Culbreth deny the allegations contained in paragraph
29 of the Complaint.
30. American and Culbreth admit that Canouse paid an OTC Markets
invoice. American is without knowledge as to the remaining allegations contained
in paragraph 30 of the Complaint, and therefore deny them.
31. American and Culbreth deny that allegations contained in paragraph
31 of the Complaint.
32. American and Culbreth admit the allegations contained in paragraph
32 of the Complaint.
33. American and Culbreth admit the allegations contained in paragraph
33 of the Complaint.
34. American and Culbreth deny the allegations contained in paragraph
34 of the Complaint.
35. American and Culbreth admit that American has not “honored”
certain of Canouse’s conversion notices and denies it has an obligation to do so.
American and Culbreth deny the remaining allegations contained in paragraph 35
of the Complaint.
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36. American and Culbreth deny the allegations contained in paragraph
36 of the Complaint.
37. American and Culbreth deny the allegations contained in paragraph
37 of the Complaint.
38. American and Culbreth are without knowledge as to the allegations
contained in paragraph 38 of the Complaint, and therefore deny them.
39. American and Culbreth are without knowledge regarding the
allegations contained in paragraph 39 of the Complaint, and therefore deny them.
40. American and Culbreth are without knowledge regarding the
allegations contained in paragraph 40 of the Complaint, and therefore deny them.
41. American and Culbreth are without knowledge regarding the
allegations contained in paragraph 41 of the Complaint, and therefore deny them
42. American and Culbreth are without knowledge regarding the
allegations contained in paragraph 42 of the Complaint, and therefore deny them
43. American and Culbreth deny the allegations contained in paragraph
43 of the Complaint.
44. American and Culbreth admit the allegations contained in paragraph
44 of the Complaint.
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45. American and Culbreth deny the allegations contained in paragraph
45 of the Complaint.
46. American and Culbreth admit the allegations contained in paragraph
46 of the Complaint.
47. American and Culbreth deny the allegations contained in paragraph
47 of the Complaint.
48. American and Culbreth deny the allegations contained in paragraph
48 of the Complaint.
49. American and Culbreth admit the allegations contained in paragraph
49 of the Complaint.
50. American and Culbreth admit the allegations contained in paragraph
50 of the Complaint.
51. American and Culbreth deny the allegations contained in paragraph
51 of the Complaint.
52. American and Culbreth deny the allegations contained in paragraph
52 of the Complaint.
53. American and Culbreth deny the allegations contained in paragraph
53 of the Complaint.
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54. American and Culbreth deny the allegations contained in paragraph
54 of the Complaint.
55. American and Culbreth deny the allegations contained in paragraph
55 of the Complaint.
56. American and Culbreth deny the allegations contained in paragraph
56 of the Complaint.
57. American and Culbreth deny the allegations contained in paragraph
57 of the Complaint.
58. American and Culbreth admit that Culbreth is the President of
American. American and Culbreth deny the remaining allegations contained in
paragraph 58 of the Complaint.
59. American and Culbreth admit the allegations contained in paragraph
59 of the Complaint.
60. American and Culbreth deny the allegations contained in paragraph
60 of the Complaint.
61. American and Culbreth deny the allegations contained in paragraph
61 of the Complaint.
62. American and Culbreth deny the allegations contained in paragraph
62 of the Complaint.
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63. American and Culbreth deny the allegations contained in paragraph
63 of the Complaint.
64. American and Culbreth deny the allegations contained in paragraph
64 of the Complaint.
65. American and Culbreth deny the allegations contained in paragraph
65 of the Complaint.
66. American and Culbreth deny the allegations contained in paragraph
66 of the Complaint.
67. American and Culbreth deny the allegations contained in paragraph
67 of the Complaint.
68. American and Culbreth state that the Separation Agreement speaks for
itself. American and Culbreth deny all the remaining allegations contained in
paragraph 68 of the Complaint.
69. American and Culbreth are without knowledge regarding the
allegations contained in paragraph 69 of the Complaint, and therefore deny them.
70. American and Culbreth deny the allegations contained in paragraph
70 of the Complaint.
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71. American and Culbreth state that the letter attached to the Complaint
as Exhibit D speaks for itself. American and Culbreth deny that is has an
obligation to issue 1,175,000 Preferred Shares to Canouse.
COUNT I Breach of Contract
72. American and Culbreth hereby re-allege and re-state their responses
contained in paragraphs 1-71 as if fully restated herein.
73. American states that the contracts to which Canouse refers in
paragraph 73 of the Complaint speak for themselves. American denies all the
remaining allegations contained in paragraph 73 of the Complaint. Count I is not
directed at Culbreth, and thus no response is required from Culbreth.
74. American denies the allegations contained in paragraph 74 of the
Complaint. Count I is not directed at Culbreth, and thus no response is required
from Culbreth.
75. American denies the allegations contained in paragraph 75 of the
Complaint. Count I is not directed at Culbreth, and thus no response is required
from Culbreth.
76. American denies the allegations contained in paragraph 76 of the
Complaint. Count I is not directed at Culbreth, and thus no response is required
from Culbreth.
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77. American denies the allegations contained in paragraph 77 of the
Complaint. Count I is not directed at Culbreth, and thus no response is required
from Culbreth.
COUNT II Conversion 78. American and Culbreth hereby re-allege and re-state their responses
contained in paragraphs 1-71 as if fully restated herein.
79. American denies the allegations contained in paragraph 79 of the
Complaint. Count II is not directed at Culbreth, and thus no response is required
from Culbreth.
80. American denies the allegations contained in paragraph 80 of the
Complaint. Count II is not directed at Culbreth, and thus no response is required
from Culbreth.
81. American deny the allegations contained in paragraph 81 of the
Complaint. Count II is not directed at Culbreth, and thus no response is required
from Culbreth.
82. American deny the allegations contained in paragraph 82 of the
Complaint. Count II is not directed at Culbreth, and thus no response is required
from Culbreth.
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83. American is without knowledge as to the allegations contained in
paragraph 83 of the Complaint, and therefore denies them. Count II is not directed
at Culbreth, and thus no response is required from Culbreth.
84. American denies the allegations contained in paragraph 84 of the
Complaint. Count II is not directed at Culbreth, and thus no response is required
from Culbreth.
85. American deny the allegations contained in paragraph 85 of the
Complaint. Count II is not directed at Culbreth, and thus no response is required
from Culbreth.
86. American denies the allegations contained in paragraph 86 of the
Complaint. Count II is not directed at Culbreth, and thus no response is required
from Culbreth.
COUNT III Culbreth’s Breaches of Duty 87. American and Culbreth hereby re-allege and re-state their responses
contained in paragraphs 1-71 as if fully restated herein.
88. Culbreth admits that he is an officer and director of American. The
remaining allegations contained in paragraph 88 are a legal conclusion, which do
not require a response. Culbreth denies the remaining allegations contained in
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paragraph 88 of the Complaint. Count III is not directed at American, and thus no
response is required from American.
89. Culbreth admits that he is an officer and director of American. The
remaining allegations contained in paragraph 89 are a legal conclusion, which do
not require a response. Culbreth denies the remaining allegations contained in
paragraph 89 of the Complaint. Count III is not directed at American, and thus no
response is required from American.
90. Culbreth denies the allegations of paragraph 90 of the Complaint.
Count III is not directed at American, and thus no response is required from
American.
91. Culbreth denies the allegations contained in paragraph 91 of the
Complaint. Count III is not directed at American, and thus no response is required
from American.
COUNT IV Attorneys’ Fees Pursuant to O.C.G.A. §13-1-11 92. American and Culbreth hereby re-allege and re-state their responses
contained in paragraphs 1-71 as if fully restated herein.
93. American states that the Notes speak for themselves. American
denies the remaining allegations contained in paragraph 93 of the Complaint.
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Count IV is not directed at Culbreth, and thus no response is required from
Culbreth.
94. American denies the allegations contained in paragraph 94 of the
Complaint. Count IV is not directed at Culbreth, and thus no response is required
Culbreth.
95. American admits that it did not pay Canouse, and further than it was
not obligated to do so. Count IV is not directed at Culbreth, and thus no response
is required from Culbreth.
96. American deny the allegations contained in paragraph 96 of the
Complaint. Count IV is not directed at Culbreth, and thus no response is required
from Culbreth.
97. American states that any agreement referred to in paragraph 97 of the
Complaint speaks for itself. American denies the remaining allegations contained
in paragraph 97 of the Complaint. Count IV is not directed at Culbreth, and thus
no response is required from Culbreth.
COUNT V Attorneys’ Fees Pursuant to O.C.G.A. §13-1-11 98. American and Culbreth hereby re-allege and re-state their responses
contained in paragraphs 1-71 as if fully restated herein.
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99. American and Culbreth deny the allegations contained in paragraph
99 of the Complaint.
100. American and Culbreth deny the allegations contained in paragraph
100 of the Complaint
101. American and Culbreth deny the allegations contained in paragraph
101 of the Complaint.
COUNT VI Punitive Damages 102. American and Culbreth hereby re-allege and re-state their responses
contained in paragraphs 1-71 as if fully restated herein.
103. American and Culbreth deny the allegations contained in paragraph
103 of the Complaint.
104. American and Culbreth deny the allegations contained in paragraph
104 of the Complaint.
AFFIRMATIVE DEFENSES
First Defense
Plaintiff fails to state a claim in Count I for Breach of Contract by failing to
allege sufficient facts to support the claim. Plaintiff fails to identify what, if any,
contract or contracts that American has breached and what specific obligations of
those contracts have been breached.
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Second Defense
Count I for Breach of Contract is barred because Plaintiff breached the
contract or contracts prior to any alleged breach by American and therefore
American’s obligations are thereby discharged.
Third Defense
Count I for Breach of Contract is barred because Plaintiff fraudulently
induced American into entering the Plaintiff’s Employment Agreement and/or the
Separation Agreement. Plaintiff had no intention of honoring his obligations under
the contract or contracts at the time they were entered.
Fourth Defense
Count I for Breach of Contract is barred because Plaintiff is not the rightful
owner of the shares which he seeks to convert, and therefore lacks standing to
bring the claim.
Fifth Defense
Plaintiff fails to state a claim in Count II for Conversion by failing to allege
sufficient facts to support the claim. Among other things, Plaintiff breached the
contract which purportedly gives rise to the right to the shares he claims were
converted.
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Sixth Defense
Count II for Conversion is barred because Plaintiff fraudulently induced
American into entering the Plaintiff’s Employment Agreement and/or the
Separation Agreement. The Separation Agreement purportedly gives rise to
Plaintiff’s right to the shares which he claims American converted. Plaintiff had
no intention of honoring his obligations under the contract or contracts at the time
they were entered.
Seventh Defense
Count II for Conversion is barred because Plaintiff breached the Separation
Agreement, which purportedly gives rise to Plaintiff’s right to the shares which he
claims that American has converted, prior to any breach by American.
Eighth Defense
Plaintiff is estopped from bringing Count I for Breach of Contract because
(i) Plaintiff breached the Separation Agreement, which purportedly gives rise to
Plaintiff’s right to the shares which he claims that American has converted, prior to
any breach by American and (ii) because Canouse does not rightfully own the
shares under which Count I is based.
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Ninth Defense
Plaintiff is estopped from bringing Count II for Conversion because Plaintiff
breached the Separation Agreement, which purportedly gives rise to Plaintiff’s
right to the shares which he claims that American has converted, prior to any
breach by American.
Tenth Defense
Plaintiff fails to state a claim in Count III for Breach of Fiduciary Duty
because the fiduciary duty under which Canouse brings his action is not a fiduciary
duty under any applicable law.
Eleventh Defense
Count III for Breach of Fiduciary Duty Count is barred by the business
judgment rule. Culbreth’s decisions, as an officer and director of American, were
deliberate, reasonably informed by due diligence, and were made in good faith.
Furthermore, if any of Culbreth’s decisions were negligent, then his decisions
sound only in ordinary negligence for which there can be no liability.
Twelfth Defense
Plaintiff is estopped from bringing Count III for Breach of Fiduciary Duty
because Plaintiff breached the Separation Agreement, which purportedly gives rise
to Plaintiff’s right to the shares which he claims that Culbreth and American failed
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to convert, prior to any breach by American. Moreover, even if there was no prior
breach, Plaintiff never intended to fulfill his obligations under the Separation
Agreement.
Thirteenth Defense
Plaintiff lacks standing to bring Count III for Breach of Fiduciary Duty
because Plaintiff breached the Separation Agreement, which purportedly gives rise
to Plaintiff’s right to the shares which he claims that Culbreth and American failed
to convert, prior to any breach by American.
COUNTERCLAIM American and Culbreth file their Counterclaim as follows:
1. American, formerly Expert Group, Inc. (“Expert”) sells its artesian
and spring bottled water varieties in the United States. American is unique in that
its artesian waters come from high altitude aquifers which provide natural high
alkaline 9.5 pH water.
2. On September 12, 2012, Canouse and Expert entered an Employment
Agreement. The Employment Agreement is attached as Exhibit A.
3. By board resolution on September 12, 2012, Canouse was appointed
as Chairman of the Board and Director of Expert.
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4. Section 4.6 of the Employment Agreement prohibited Canouse from
disparaging the Company or its officers and directors, which would include
Culbreth.
5. Section 4.2 of the Employment Agreement prohibited Canouse from
becoming a director or officer in a company that competes with Expert.
6. On or before March 21, 2013, Canouse became the Chief Executive
Officer of Stakool, Inc. (“Skatool”), replacing its prior CEO. In a press release
issued by Stakool, Inc., the company stated, “n assuming the position, it is Mr.
Canouse’s intent to pursue the mission of the Corporation by implementing
strategies to greatly increase the distribution of the ‘Natural plus Energy’ health
bars and pursue other opportunities on behalf of the Corporation that are available.
More specifically, Mr. Canouse is entering into negotiations with the licensee of
Pleasant Springs Water to acquire its bottling and license rights. Pleasant Springs is
a bottled water company in Tiger, GA, that bottles and distributes natural spring
water and had sales exceeding four million dollars ($4,000,000).”
7. The press release demonstrates that Canouse, while employed with
Expert, became a director of Skatool and he intended to take Skatool into a line of
business that would compete with Expert.
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8. As a result of these actions, Canouse violated Section 4.2 of his
Employment Agreement.
9. Moreover, Canouse made false statements in a public forum when he
stated that Expert and Skatool were in or would enter into negotiations to sell its
Pleasant Springs licensing rights. No such negotiations existed.
10. That same day Expert issued a press release addressing, correcting,
and denying Canouse’s false statements.
11. In April 2013, Canouse, of behalf of Skatool, made efforts to buy
bottled water companies in Alabama and Georgia, in further violation of Section
4.2 of the Employment Agreement.
12. As a result of these and other circumstances, the parties severed
Employment Agreement. Expert and Canouse entered into a Separation
Agreement that was fully executed on May 23, 2013. A copy of the Separation
Agreement is attached to Canouse’s Complaint as Exhibit B.
13. In paragraph 2 of the Separation Agreement, Canouse agreed not to
“disparage in word, or any communication either of the parties or officers or
directors of the Corporation or any other associations the parties may have.”
14. In August 2013, Canouse interfered with American’s contract
negotiations by contacting Adriana De Mourna, a celebrity, through social media.
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At the time, American was in contract negotiations with her for an endorsement
deal. Canouse told her in words and substance that she should not enter into any
endorsement arrangement with American and avoid the American and Culbreth.
15. Specifically, Canouse sent De Mourna more than twenty Twitter
messages over a two day period. One of these tweets contained information
regarding a lawsuit that Culbreth was involved in more than ten years ago.
Another stated that Culbreth would use De Mourna to pump and dump Expert’s
stock. He also stated that the pH levels of the American’s water were not as high
as American claimed. Another stated that she should beware of Culbreth and
avoid American.
16. Canouse’s disparaging and false remarks directly contributed to the
parties’ failure to reach an Agreement at that time.
17. Expert and American Premium Water Corporation agreed to
consolidate their operations. On October 8, 2013, Expert changed its name to
American Premium Water Corporation.
18. As early as 2013, Canouse began posting about Expert, American, and
Culbreth on a website called Investors Hub (www.iHub.com) (“iHub”) using the
username “joecanouse.” According to the website, Investor’s Hub is a “forum for
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serious investors to gather and share market insights in a dynamic environment
using an advanced discussion platform” and currently has 498,154 members.
19. Eventually Canouse’s posts about American and Culbreth turned
acrid.
20. On June 7, 2014, Canouse posted, “I do think Al needs to clean up his
reporting ...”, insinuating that American and Culbreth’s “reporting” was inaccurate
or sloppy.
21. On June 8, 2014, Canouse posted, “... then the company just blew
$500,000,” thus claiming that American wastes its assets.
22. On June 8, 2014, Mr. Canouse called certain actions of the company
“very suspicious” and asserted that “shares are being passed out pretty liberally.”
He impugned the choices that American made in hiring outside counsel and
Culbreth himself when he said, “what could attorney schectman [sic] know about
running a company or advising one at his age” and “even al has never run a public
company himself.”
23. On June 26, 2014, Mr. Canouse stated that he, “cannot help but think
that there may be something illegal about” certain information contained in a press
release regarding the retirement of shares.
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24. On June 27, 2014, he called certain actions of the company “illegal
and in contravention w. the articles and bylaws … .” Moreover, he said that
American’s actions were “all fraud which like certain std’s follow you
everywhere” and that “what they did was illegal.”
25. On June 30, 2014, he accused members of American of “attempting to
walk away w. assets developed by the corporation thought [sic] the contribution of
its shareholders.”
26. Canouse’s statements are false.
27. All of these statements are found on www.ihub.com for any one of its
498,154 members to view.
28. Canouse made other statements in a public forum and to third parties
disparaging American and Culbreth.
29. Additionally, Canouse has improperly used his past status as an
officer of Expert to obtain information about other shareholders’ shares from First
American Stock Transfer, Inc. and then used that information to further defame
American and Culbreth on iHub.
Count One Breach of Contract
30. Counter-Plaintiffs re-allege and incorporate herein the allegations
contained in Paragraphs 1 through 29 above.
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31. Expert, now American, and Canouse entered into an Employment
Agreement and thereafter a Separation Agreement.
32. Canouse breached Section 4.7 of the Employment Agreement by
disparaging the American by making false remarks in Skatool’s March 21, 2014
press release, which were aimed at and intended to harm Expert and to benefit
Skatool.
33. Canouse breached Section 4.2 of the Employment Agreement by
working for Skatool and then attempting to compete with American.
34. Canouse breached paragraph 2 of the Separation Agreement by
disparaging American on social media and on iHub.
35. American was damaged as a result of Canouse’s breaches.
36. American is entitled to monetary damages and attorneys fees as a
result of Canouse’s breaches, the amount of which will be proven at trial.
Count Two Defamation Per Se 37. American and Culbreth re-allege and incorporate herein the
allegations contained in Paragraphs 1 through 29 above.
38. Canouse made false and malicious statements against both American
and Culbreth, accusing each of illegal and fraudulent acts and compared their acts
to sexually transmitted diseases.
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39. These statements were made in reference to the trade and profession
of American and Culbreth and constitute defamation per se under Georgia law.
O.C.G.A. § 51-5-4 (a)(3).
40. These statements were calculated to injure American and Culbreth.
41. These statements did not constitute privileged communications.
42. As a direct and proximate result of Canouse’s false and malicious
statements, American and Culbreth were injured.
43. Canouse acted willfully, wantonly and with total want of care.
44. Because the statements constitute defamation per se under Georgia
law, no showing of special damages is required. O.C.G.A. § 51-5-4 (b).
45. American is entitled to all financial, compensatory, emotional, and
punitive damages and attorneys fees as a result of Canouse’s defamation, the
amount of which will be proven at trial.
Count Three Attorney Fees Pursuant to O.C.G.A §13-6-11
46. American and Culbreth re-allege and incorporate herein the
allegations contained in Paragraphs 1 through 29 above.
47. Canouse, by and through his conduct described herein, has been
stubbornly litigious, acted in bad faith, and caused American and Culbreth
unnecessary trouble and expense.
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48. Canouse is liable for American and Culbreth’s expenses of litigation,
including reasonable attorney fees, pursuant to O.C.G.A § 13-6-11.
49. American and Culbreth’s attorney fees and expenses will be proven at
trial.
WHEREFORE, American and Culbreth request that they be granted:
(A) trial by jury on all issues so triable;
(B) judgment in their favor and against Plaintiff for all financial,
compensatory, emotional, and punitive damages as determined by a jury at trial;
(C) reasonable attorney fees and expenses; and
(D) all such other relief as the Court may deem just and appropriate. Respectfully submitted this 19th day of September, 2014.
s/ Michael J. King Michael J. King Georgia Bar No. 421160 kingm@gtlaw.com Ashley N. McNair Georgia Bar No. 370553 McNaira@gtlaw.com Attorneys for Defendants American Premium Water Corporation and Alferd Culbreth
Lacey D. Hofmeyer Florida Bar No. 36983 hofmeyerl@gtlaw.com Pro Hac Vice Application Pending
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GREENBERG TRAURIG, LLP Terminus 200 3333 Piedmont Road, NE Suite 2500 Atlanta, Georgia 30305 Tel: (678) 553-2100 Fax: (678) 553-2212
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CERTIFICATE OF SERVICE
I hereby certify that I have this day electronically filed the foregoing
ANSWER AND COUNTERCLAIMS OF DEFENDANTS AMERICAN
PREMIUM WATER CORPORATION AND ALFERD CULBRETH with the
Clerk of Court using the CM/ECF system and have served the same by email and
US Mail to the following counsel:
Scott L. Bonder FRIED & BONDER, LLC White Provision, Suite 305 1170 Howell Mill Road, N.W. Atlanta, Georgia 30318
This 19th day of September, 2014. s/ Michael J. King Counsel for Defendants American Premium Water Corporation and Alferd Culbreth
GREENBERG TRAURIG, LLP Terminus 200 3333 Piedmont Road, NE Suite 2500 Atlanta, Georgia 30305
MIA 184068060v1
Case
