Tuesday, March 27, 2012 8:25:29 AM
https://viewer.zoho.com/docs/yebYdd
ERWIN GRAMPP, derivatively on behalf of JBI, Inc. Plaintiff
v
John Bordynuik, et al
WHEREFORE, Plaintiff demands judgment as follows:
A. Against all of the Individual Defendants and in favor of the Company for the amount of damages sustained by the Company as a result of the Individual Defendants’ breaches of fiduciary duties;
B. Awarding to JBI restitution from the Individual Defendants, and each of them, and ordering disgorgement of all profits, benefits and other compensation obtained by the Individual Defendants;
C. Awarding to Plaintiff the costs and disbursements of the action, includingreasonable attorneys’ fees, accountants’ and experts’ fees, costs, and expenses; and
D. Granting such other and further relief as the Court deems just and proper.
JURY TRIAL DEMANDED
Plaintiff hereby demands a trial by jury.
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