Replies to post #135583 on Plastic2Oil Inc (PTOI)

[XenaLives]

Rookie attorney assigned to case? Maybe they don't think the case is very winnable or won't yield much money. Give the new guy a chance to practice. The lead plaintiff stinks.

Robert V. Prongay: top

ROBERT V. PRONGAY is an associate in the Firm’s Los Angeles office, where he focuses on the investigation, initiation, and litigation, of complex securities cases brought on behalf of institutional and individual investors.

Mr. Prongay earned his Bachelor of Arts degree in Economics from the University of Southern California in 2005 and earned his Juris Doctor degree from Seton Hall University School of Law in 2008. While attending law school, Mr. Prongay worked as a summer associate at the Firm, and interned for a federal magistrate judge for the United States District Court for the District of New Jersey. Mr. Prongay is admitted to the State Bar of California, as well as the United States District Courts for the Central and Southern Districts of California.

http://www.glancylaw.com/about_our_firm.php#32

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09/26/2011 13 MEMORANDUM filed by Plaintiff Howard L. Howell re 12 MOTION Appointment as Lead Plaintiff and Approval of Lead Counsel. (OMara, David) (Entered: 09/26/2011)

Doc 13 PDF file
https://viewer.zoho.com/docs/gbYaadj

Extract -

2. Movant Has The Largest Financial Interest In This Action

The PSLRA requires a court to adopt the rebuttable presumption that “the most adequate plaintiff . . . is the person or group of persons that . . . has the largest financial interest in the relief sought by the class.” 15 U.S.C. §78u-4(a)(3)(B); Cavanaugh, 306 F.3d at 730.

Here, Movant purchased 25,300 shares of JBI during the Class Period, and has suffered financial losses of $37,067 as a result of his transactions. See Goldberg Declaration, Exhibit C. To the best of his knowledge, Movant believes he has the largest financial interest in this case among Class members who filed timely applications for appointment as lead plaintiff, and accordingly is presumed to be the “most adequate plaintiff.” See Cavanaugh, 306 F.3d at 730.

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09/26/2011 14 DECLARATION of Michael Goldberg re 12 MOTION Appointment as Lead Plaintiff and Approval of Lead Counsel ; filed by Plaintiff Howard L. Howell. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(OMara, David) (Entered: 09/26/2011)

Doc 14 PDF file
https://viewer.zoho.com/docs/pc1EG

Document Number: 14 2 pages 172 kb

Attachment Description
1 Exhibit A 3 pages 30 kb
2 Exhibit B 4 pages 317 kb
3 Exhibit C 3 pages 17 kb
4 Exhibit D 16 pages 48 kb

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09/26/2011 16 MOTION FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF CHOICE OF COUNSEL; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF by Movant Tim Amos. Responses due by 10/13/2011. (Attachments: # 1 Declaration Laurence Rosen, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Proposed Order)(Leverty, Patrick) (Entered: 09/26/2011)

Doc 16 PDF file
https://viewer.zoho.com/docs/idlb9c

Extract -

MOTION OF TIM AMOS FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF CHOICE OF COUNSEL; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF


Document Number: 16 11 pages 170 kb

Attachment Description
1 Declaration Laurence Rosen 3 pages 69 kb
2 Exhibit 1 3 pages 85 kb
3 Exhibit 2 3 pages 264 kb
4 Exhibit 3 2 pages 94 kb
5 Exhibit 4 17 pages 129 kb
6 Exhibit 5 4 pages 99 kb
7 Proposed Order 2 pages 69 kb

or 45 pages 1.0 mb

[scion]

Docket update 27 SDep 11 CIVIL DOCKET FOR CASE #: 3:11-cv-00545-RCJ -WGC

United States District Court

District of Nevada (Reno)
CIVIL DOCKET FOR CASE #: 3:11-cv-00545-RCJ -WGC
Pancoe v. JBI, Inc. et al

Assigned to: Chief Judge Robert C. Jones
Referred to: Magistrate Judge William G. Cobb
Cause: 15:78m(a) Securities Exchange Act

Date Filed: 07/28/2011
Jury Demand: Plaintiff
Nature of Suit: 850 Securities/Commodities
Jurisdiction: Federal Question


Plaintiff
Howard L. Howell

represented by David C OMara
The OMara Law Firm, P.C.
311 E. Liberty Street
Reno, NV 89501
775-323-1321
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED

Plaintiff
Ellisa Pancoe

represented by David C OMara
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Lionel Z. Glancy
GLANCY BINKOW & GOLDBERG LLP
1801 Avenue of the Stars
Suite 311
Los Angeles, CA 90067
310-201-9150
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED

Michael M. Goldberg
Glancy Binkow & Goldberg LLP
1801 Avenue Of The Stars
Suite 311
Los Angeles, CA 90067-
[phone]
Fax: [phone]
Email: [e-mail]
PRO HAC VICE
ATTORNEY TO BE NOTICED

Robert V. Prongay
Glancy Binkow & Goldberg LLP
1801 Avenue of the Stars
Los Angeles, CA 90067
[phone]
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED


V.
Movant
Tim Amos

represented by Patrick R. Leverty
Leverty & Associates, Chtd.
832 Willow St.
Reno, NV 89502
775-322-6636
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED


V.

Defendant
JBI, Inc.
formerly known as
310 Holdings, Inc.

represented by Richard G. Campbell , Jr.
Armstrong Teasdale, LLP
50 W. Liberty Street, Suite 950
Reno, NV 89501
775-322-7400
Fax: [phone]
Email: [e-mail]
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Bret F Meich
Armstrong Teasdale, LLP
50 W. Liberty St., Ste. 950
Reno, NV 89501
775-322-7400
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED

David C OMara
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
John Bordynuik

represented by Richard G. Campbell , Jr.
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

David C OMara
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
Ronald Baldwin, Jr.


Date Filed # Docket Text

09/27/2011 17 VERIFIED PETITION for Permission to Practice Pro Hac Vice by Robert V. Prongay and DESIGNATION of Local Counsel David C. O'Mara (Filing fee $ 175 receipt number 0978-2128664) filed by Plaintiff Ellisa Pancoe. Motion ripe 9/27/2011. (OMara, David) (Entered: 09/27/2011)

09/26/2011 16 MOTION FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF CHOICE OF COUNSEL; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF by Movant Tim Amos. Responses due by 10/13/2011. (Attachments: # 1 Declaration Laurence Rosen, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Proposed Order)(Leverty, Patrick) (Entered: 09/26/2011)

09/26/2011 15 Submission of PROPOSED ORDER on 12 MOTION Appointment as Lead Plaintiff and Approval of Lead Counsel ; filed by Plaintiff Howard L. Howell. (OMara, David) (Entered: 09/26/2011)
09/26/2011 14 DECLARATION of Michael Goldberg re 12 MOTION Appointment as Lead Plaintiff and Approval of Lead Counsel ; filed by Plaintiff Howard L. Howell. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(OMara, David) (Entered: 09/26/2011)

09/26/2011 13 MEMORANDUM filed by Plaintiff Howard L. Howell re 12 MOTION Appointment as Lead Plaintiff and Approval of Lead Counsel. (OMara, David) (Entered: 09/26/2011)

09/26/2011 12 MOTION Appointment as Lead Plaintiff and Approval of Lead Counsel by Plaintiff Howard L. Howell. Responses due by 10/13/2011. (OMara, David) (Entered: 09/26/2011)

09/26/2011 11 VERIFIED PETITION for Permission to Practice Pro Hac Vice by Lionel Z. Glancy and DESIGNATION of Local Counsel David C. O'Mara (Filing fee $ 175 receipt number 0978-2127785) filed by Plaintiff Ellisa Pancoe. Motion ripe 9/26/2011. (OMara, David) (Entered: 09/26/2011)

09/26/2011 10 VERIFIED PETITION for Permission to Practice Pro Hac Vice by Michael Goldberg and DESIGNATION of Local Counsel David C. O'Mara (Filing fee $ 175 receipt number 0978-2127771) filed by Plaintiff Ellisa Pancoe. Motion ripe 9/26/2011. (OMara, David) (Entered: 09/26/2011)

09/20/2011 9 ORDER ON 7 STIPULATION : Ds' answer to Complaint not due until Court's appointment of lead plaintiff and designation of operative complaint. Designation of operative complaint due 60 days after appointment of lead plaintiff. ( see pdf order for additional specifics ) Signed by Chief Judge Robert C. Jones on 9/16/2011. (Copies have been distributed pursuant to the NEF - DRM) (Entered: 09/20/2011)

09/14/2011 8 NOTICE of Appearance by attorney Richard G. Campbell, Jr on behalf of Defendants John Bordynuik, JBI, Inc.. (Campbell, Richard) (Entered: 09/14/2011)

09/13/2011 7 STIPULATION FOR EXTENSION OF TIME (First Request) by Defendants John Bordynuik, JBI, Inc., Plaintiff Ellisa Pancoe. (OMara, David) (Entered: 09/13/2011)

09/08/2011 6 MINUTE ORDER IN CHAMBERS of the Honorable Chief Judge Robert C. Jones, on 9/8/2011. IT IS ORDERED that this case is reassigned to Magistrate Judge William G. Cobb for all further proceedings. Magistrate Judge Robert A. McQuaid, Jr no longer assigned to case. All further documents must bear the correct case number 3:11-cv-00545-RCJ-WGC. (no image attached) (Copies have been distributed pursuant to the NEF - PM) (Entered: 09/08/2011)

09/02/2011 5 SUMMONS Returned Executed by Ellisa Pancoe re 1 Complaint, 3 Summons Issued. JBI, Inc. served on 8/21/2011, answer due 9/11/2011. (OMara, David) (Entered: 09/02/2011)

08/16/2011 4 CERTIFICATE of Interested Parties filed by Ellisa Pancoe. There are no known interested parties other than those participating in the case. (OMara, David) (Entered: 08/16/2011)

07/29/2011 3 Summons Issued as to Ronald Baldwin, Jr, John Bordynuik, JBI, Inc.. (PM) (Entered: 07/29/2011)

07/29/2011 2 NOTICE TO COUNSEL PURSUANT TO LOCAL RULE IA 10-2. Counsel Lionel Z. Glancy, Michael Goldberg and Robert V. Prongay to comply with completion and electronic filing of the Designation of Local Counsel and Verified Petition. For your convenience, click on the following link to obtain the form from the Court's website - www.nvd.uscourts.gov/Forms.aspx. Counsel is also required to register for the Court's Case Management and Electronic Case Filing (CM/ECF) system and the electronic service of pleadings. Please visit the Court's website www.nvd.uscourts.gov to register Attorney(s). Verified Petition due by 9/12/2011.(no image attached) (WJ) (Entered: 07/29/2011)

07/29/2011 Case assigned to Chief Judge Robert C. Jones and Magistrate Judge Robert A. McQuaid, Jr. (WJ) (Entered: 07/29/2011)

07/28/2011 1 COMPLAINT (Class Action Complaint for Violations of the Federal Securities Laws) against RONALD BALDWIN, JR, JOHN BORDYNUIK, JBI, Inc., f/k/a 310 Holdings, Inc. (Filing fee $ 350 receipt number 0978-2066855), filed by ELLISA PANCOE. Certificate of Interested Parties due by 8/7/2011. Proof of service due by 11/25/2011. (Attachments: # 1 Civil Cover Sheet, # 2 Summons) (OMara, David) Modified on 7/29/2011 to note Summonses Issued on 7/29/2011(PM). (Entered: 07/28/2011)

https://ecf.nvd.uscourts.gov/cgi-bin/iquery.pl

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09/26/2011 16 MOTION FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF CHOICE OF COUNSEL; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF by Movant Tim Amos. Responses due by 10/13/2011. (Attachments: # 1 Declaration Laurence Rosen, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Proposed Order)(Leverty, Patrick) (Entered: 09/26/2011)

Doc 16-3 PDF file
https://viewer.zoho.com/docs/vdabbbG

OR

http://www.docstoc.com/docs/96851949/Pancoe-v-JBI-Inc-et-al-Doc-16-3-filed-26-Sep-11


Mr. Amos lost a total of $55,515.90 in connection with his purchases of JBI stock.1 See Rosen Decl., Ex. 3 (Movant’s Loss Chart).

Extract -page 5
Doc 16 PDF file
https://viewer.zoho.com/docs/idlb9c

[scion]

09/26/2011 16 MOTION FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF CHOICE OF COUNSEL; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF by Movant Tim Amos. Responses due by 10/13/2011. (Attachments: # 1 Declaration Laurence Rosen, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Proposed Order)(Leverty, Patrick) (Entered: 09/26/2011)


Doc 16-4 PDF file
https://viewer.zoho.com/docs/dacdYh

[scion]

Pacer update 30 Sep 11 PANCOE v. JBI, Inc. et al CIVIL DOCKET FOR CASE #: 3:11-cv-00545

https://ecf.nvd.uscourts.gov/cgi-bin/iquery.pl

Date Filed # Docket Text

09/30/2011 18 CERTIFICATE OF SERVICE for Motion Appoint Lead Plaintiff and Approval of Lead Counsel, Memorandum, Declaration of Michael Goldberg and proposed Order by Plaintiff Howard L. Howell re 15 Proposed Order Submission, 12 MOTION Appointment as Lead Plaintiff and Approval of Lead Counsel, 14 Declaration, 13 Memorandum. (OMara, David) (Entered: 09/30/2011)


United States District Court
District of Nevada (Reno)
CIVIL DOCKET FOR CASE #: 3:11-cv-00545-RCJ -RAM

Pancoe v. JBI, Inc. et al
Assigned to: Chief Judge Robert C. Jones
Referred to: Magistrate Judge Robert A. McQuaid, Jr
Cause: 15:78m(a) Securities Exchange Act

Date Filed: 07/28/2011
Jury Demand: Plaintiff
Nature of Suit: 850 Securities/Commodities
Jurisdiction: Federal Question

Plaintiff
Ellisa Pancoe

represented by David C OMara
The OMara Law Firm, P.C.
311 E. Liberty Street
Reno, NV 89501
775-323-1321
Fax: [phone]
Email: [e-mail]
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Lionel Z. Glancy
GLANCY BINKOW & GOLDBERG LLP
1801 Avenue of the Stars
Suite 311
Los Angeles, CA 90067
310-201-9150
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED

Michael M. Goldberg
Glancy Binkow & Goldberg LLP
1801 Avenue Of The Stars
Suite 311
Los Angeles, CA 90067-
[phone]
Fax: [phone]
Email: [e-mail]
PRO HAC VICE
ATTORNEY TO BE NOTICED

Robert V. Prongay
Glancy Binkow & Goldberg LLP
1801 Avenue of the Stars
Los Angeles, CA 90067
[phone]
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED


V.
Defendant
JBI, Inc.
formerly known as
310 Holdings, Inc.

Defendant
John Bordynuik

Defendant
Ronald Baldwin, Jr.

https://ecf.nvd.uscourts.gov/cgi-bin/iquery.pl