Free COMPLAINT - District Court of Delaware - Delaware


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Pages: 132
Date: September 6, 2008
File Format: PDF
State: Delaware
Category: District Court of Delaware
Author: unknown
Word Count: 4,865 Words, 29,874 Characters
Page Size: 613.44 x 792 pts
URL

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AO 440 (Rev. 03/08) Civil Summons (Page 1)

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UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

TO:

Summons in a Civil Action ACCORD ENERGY, LLC c/o The Corporation Trust Company CORPORATION TRUST CENTER 1209 ORANGE STREET WILMINGTON, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-5

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-6

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action To: MARK GORTON c/o The Delaware Secretary Of State LIME GROUP 377 BROADWAY, 11TH FL. NEW YORK, NY 10013

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-6

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title ____________________________________ Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-7

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action TO: TOWER RESEARCH CAPITAL INVESTEMENTS, LLC c/o The Corporation Trust Company CORPORATION TRUST CENTER 1209 ORANGE STREET WILMINGTON, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-7

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-8

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action To: TOWER RESEARCH CAPITAL LLC c/o the Delaware Secretary of State CT CORPORATION SYSTEM 111 EIGHTH AVENUE NEW YORK, NEW YORK, 10011

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899

If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-8

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-9

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action TO: GLE TRADING, LLC c/o The Corporation Trust Company CORPORATION TRUST CENTER 1209 ORANGE STREET WILMINGTON, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-9

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-10

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action TO: BJ ENERGY, LLC c/o The Corporation Trust Company CORPORATION TRUST CENTER 1209 ORANGE STREET WILMINGTON, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-10

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-11

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action TO: FRANKLIN POWER, LLC c/o The Corporation Trust Company CORPORATION TRUST CENTER 1209 ORANGE STREET WILMINGTON, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-11

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-12

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action TO: POWER EDGE LLC c/o The Corporation Trust Company CORPORATION TRUST CENTER 1209 ORANGE STREET WILMINGTON, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-12

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-13

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action TO: PILLAR FUND, LLC c/o The Corporation Trust Company CORPORATION TRUST CENTER 1209 ORANGE STREET WILMINGTON, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-13

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 1)

Document 48-14

Filed 04/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
For the District of Delaware PJM INTERCONNECTION, LLC, directly and derivatively on behalf of Power Edge, LLC,
Plaintiff, V.

) ) )
) ) ) ) Civil Action No.:

MARK GORTON; TOWER RESEARCH CAPITAL LLC; TOWER RESEARCH CAPITAL INVESTMENTS, LLC; ACCORD ENERGY, LLC; BJ ENERGY, LLC; FRANKLIN POWER, LLC; GLE TRADING, LLC; OCEAN POWER, LLC; PILLAR FUND, LLC; and POWER EDGE LLC,
Defendants.

) ) ) ) ) ) )
)

Summons in a Civil Action TO: OCEAN POWER, LLC c/o The Corporation Trust Company CORPORATION TRUST CENTER 1209 ORANGE STREET WILMINGTON, DE 19801
YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEYS (name and address)

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not continuing the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are: Collins J. Seitz, Jr. (Bar No. 2237) Max B. Walton (Bar No. 3876) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Name of clerk of court DATE: Deputy clerk's signature

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons (Page 2)

Document 48-14

Filed 04/16/2008

Page 2 of 2

Proof of Service I declare under penalty of perjury that I served the summons and complaint in this case on by: (1) personally delivering a copy of each to the individual at this place, ; or (2) leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3) delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4) returning the summons unexecuted to the court clerk on . ,

My fees are $

for travel and $

for services, for a total of

.

Date:_______________ Signature of Server

Printed name and title

Address of Server