Attached as Exhibit "A" is Plaintiff's declaration authenticating the evidence referenced in this section.
a. Mr. Bordynuik's Securities Promotion
Mr. Bordynuik offered Plaintiff his own "personal stock" in JBI to induce him to work for the company. (See Ex. "A" at ¶ 3). In doing so, Mr. Bordynuik was acting outside of his corporate capacity. Mr. Bordynuik's January 28-31, 2010 emails with Plaintiff state in relevant part as follows:
From: John Bordynuik [mailto:john@johnbordynuik.com] Sent: Sunday, January 31, 2010 11:58 AM To: Michael Kaplanis Cc: Geoffrey C. Weber Subject: Re: Follow up
. . . Please don't trade the stock during the next 3 weeks -- you can expect FINRA to pull all the transactions after this massacre.
Power Plays: There have been a few between Steve Seneca (PakIt) and others who wish control. I know you are moving to Florida but JBI Admin and Executive are being scattered all over North America. I don't believe we need a centralized office other than Accounting Controls (limited to compliance and reporting only -- Florida). . .
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