Tuesday, October 12, 2010 4:49:27 PM
I just read the complaint line-by-line, and nowhere does Kaplanis assert any entitlement to millions of dollars in damages against JBI. He seeks damages based on an alleged breach of an employment contract. The specific damages identified in the complaint are: unpaid salary or severance, work-related expenses for which he asserts the right to reimbursement, and loss of health insurance and other employment benefits and incentives. Kaplanis has also requested an assessment of litigation costs and reasonable attorney’s fees in the event he prevails in the action. According to the complaint, Kaplanis's base salary was set at $120,000. Although there is some reference to unspecified incentive compensation in addition to the base salary, it is unreasonable to inflate the “value” of the damages sought in the complaint into the millions.
Kaplanis's company (Revma) does not have the same address as Pak-It. The 221 Turner Street address appears to be Geoffrey Weber's address. Look at the numerous companies for which Geoffrey Weber is the registered agent and you will see that same address show up time and again. Here are just two examples from a long list:
Tony's Roasted Pepper, LLC: http://www.sunbiz.org/pdf/69463067.pdf
West Hampton, LLC: http://www.sunbiz.org/pdf/69472501.pdf
Once JBI purchased Pak-It, J.P. Raymond replaced Geoffrey Weber as registered agent of Pak-It, and the company's mailing address moved from 221 Turner Street to 311 Park Place.
http://www.sunbiz.org/pdf/70146060.pdf
The assertion that John Bordynuik and Ron Kurp incorporated Pak-It together with Geoffrey Weber back in 2007 simply is not supported by the filings. Neither Bordynuik's nor Kurp's names appear in any of the Pak-It filings until after JBI purchased the company. Nor do their names appear on the list of Pak-It members on the Unit Purchase and Exchange Agreement filed with the SEC.
Pak-It Articles of Organization: http://www.sunbiz.org/pdf/03585559.pdf
JBI Unit Purchase and Exchange Agreement RE Pak-It: http://www.sec.gov/Archives/edgar/data/1381105/000121390009002695/f8k093009ex10i_310hold.htm
As a side note, observe that Kaplanis first formed Revma Investment Group, LLC in early August 2010, around the same time that (according to the complaint) he was terminated from employment with JBI.
Revma Articles: http://www.sunbiz.org/pdf/30911173.pdf
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