MY ANSWERS TO THE “RALEIGH MAFIA” LAWSUIT FILE STAMPED IN COURT 1 JUNE 2017

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As promised I will supply my answers to the lawsuit that has been assessed against me and my company. You can decide what you wish to believe. I will post emails, complaints, and other information here for you to decide for yourselves.

This lawsuit against me should not have happened to begin with if only Shane Guyant, Chief Investigator and Deputy Commissioner. Director of Criminal Investigations and the North Carolina Department of Insurance had actually done there collective jobs on arresting these three individuals for Money Laundering, Fraud, lying and cheating everyone that these people can get there claws into. And these same people are Dallas McClain, Lynette Thompson or one of her aliases and the Godfather of it all Carl Valentine and of course their company’s that they are hiding monies from the NCDOI.

Please let me state the obvious here. Dallas McClain and Lynette Thompson have been and still are in business together with an Revoked Licensed person by the name of Carl Valentine, his license was Revoked in 2012, go ahead and look it up on the NCDOI Website…..People this is illegal. NCGS 58-71. You nor I nor anyone else is allowed to be in business with an unlicensed individual involved in the Bail Bonding Business. There have been numerous complaints “92” filed since 2014 with the NCDOI. There are no excuses allowed here. So why has the NCDOI not performed their job on this matter? Shane Guyant has pushed illegal felony complaints against me with no justification whatsoever. This is called NO PROBABLE CAUSE, 108 of them, and let me tell you what they were……..FOR ME NOT GETTING THE BANKS ENDORSEMENTS ON CHECKS !!!!! Guess what. This is not illegal. The law states whatever my bank accepts for endorsements in their company policy……..  So what excuse does he Shane Guyant and NCDOI have for not locking up these real criminals. Let me answer this for everyone…..NONE!!!!

On an update to this, one of Cannon’s Bail Bond Agents over in the western part of NC. was arrested on 5-11-2017 for several felony’s involving bail bonds and illegal taking of land and property on Indian Land. This agent plus what I here is up to 5 more will be arrested by the FBI. My comment to this is it is about time the FBI got involved.

just remember before you start reading this answer. It’s very dry until you get to my personal answers on what I am to have supposed to have done.

 

OK these are my court filed stamped answers as of June 1st 2017.

STATE OF NORTH CAROLINA                                   IN THE GENERAL COURT OF JUSTICE

COUNTY OF WAKE                                                       SUPERIOR COURT DIVISION

17 CVS 3831

DALLAS MCCLAIN; LYNETTE THOMPSON;

CARL VALENTINE; PREMIER JUDICIAL CONSULTANTS;

NC BAIL ACADEMY LLC; CANNON SURETY LLC.

 

VERSES                                                                                    ANSWER TO COMPLAINT

 

MARK WAYNE CARTRET; NORTH STATE HOLDING GROUP

LLC; RONALD PIERCE; PIEDMONT DISASTER SERVICES LLC;

CLYDE ROBERT BRAWLEY JR; AND KEN ROBOL

 

NOW COME the above-captioned Plaintiffs, Dallas McClain (Mr. McClain) Lynette Thompson (Ms. Thompson), Carl Valentine (Mr. Valentine), Premier Judicial Consultants, LLC (Premier), Cannon Surety LLC, (Cannon), and NC Bail Academy LLC. (Academy) (the foregoing shall be collectively referred to herein as Plaintiffs complaining of the acts of Defendants, and hereby state and allege unto the Court, this Verified Complaint, as follows:

1.)   Mr. McClain is a citizen and resident of Greensboro, Guilford County, North Carolina.       ANSWER:  Defendant lacks information or knowledge to truthfully answer #1. Therefor deny #1.

2.)   Ms. Thompson is a citizen and resident of Franklinton, Franklin County, North Carolina.      ANSWER:   Defendant lacks information of or knowledge to truthfully answer #2. Therefor deny #2.

3.)   Mr. Valentine is a citizen and resident of Greensboro, Guilford County, North Carolina.      ANSWER:   Defendant lacks information of or knowledge to truthfully answer #3. Therefor deny #3.

4.)   Premier is a North Carolina Limited Liability Company duly incorporated and validly existing under the laws of the State of North Carolina, (herein after, State) with its principal office located in Greensboro, Guilford County, North Carolina.    ANSWER:   Defendant lacks information or knowledge to answer #4. Therefor deny #4.

5.)   At all times pertinent to this action, Premier has been engaged in the business of providing surety bail bonding services and bail surety through its wholly owned subsidiary, Cannon.      ANSWER:   Defendant lacks information or knowledge to truthfully answer #5. Therefor deny #5.

6.)   Cannon is a North Carolina Limited Liability Company duly incorporated and validly existing under the laws of the State with its principal office located in Greensboro, Guilford County, North Carolina.     ANSWER: Defendant lacks information or knowledge to truthfully answer #6. Therefor deny #6.

7.)   At all times pertinent to this action, Cannon has been engaged in the business of providing surety bail bonding services and bail surety as a captive entity wholly owned by Premier and approved and duly licensed by the State’s Department of Insurance (DOI).     ANSWER:   Defendant lacks information and or knowledge to truthfully answer #7. Therefor deny #7.

8.)   At all times pertinent to this action, Cannon has been solely owned by Premier.       ANSWER:    Defendant lacks information and or knowledge to truthfully answer #8. Therefor deny #8.

9.)   At all times pertinent to this action, Premier has been the sole owner and parent company of Cannon.        ANSWER:   Defendant lacks information and or knowledge to truthfully answer #9. Therefor deny #9.

10.)   At all times pertinent to this action, the Academy was a limited liability company duly incorporated and validly existing under the laws of the State with its principal office located in Wake Forest, North Carolina, and owned by Ms. Thompson and in the business of providing required educational and licensure classes for bail bonding in the State of North Carolina.      ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 10. Therefor deny # 10.

11.)   On information and belief, Defendant, Mark Wayne Cartret (Cartret), is a citizen and resident of Whiteville, Columbus County, North Carolina.     ANSWER   defendant lacks information and or knowledge to truthfully answer #11.  Therefor deny #11.

12.)   Defendant, Agent Associates Insurance LLC (AAI), is a North Carolina limited liability company, with its principal office located in Wake County, North Carolina with a registered office address of 615 Oberlin Road, Suite 104, Raleigh, North Carolina 27605-3129 (AAI).     ANSWER: Defendant lacks the information and or knowledge to truthfully answer #12. Therefor deny #12.

13.)   Prior to 28 October 2014, AAI’s corporate name was “Cattlemen’s Surety LLC” a North Carolina limited liability company.     ANSWER:   Defendant lacks the information and or knowledge to truthfully answer #13.  Therefor deny #13.

14.)   On or about 28 October 2014, Cattlemen’s name was changed to AAI.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer #14. Therefor deny #14.

15.)   On information and belief and at all times pertinent to this action, Cartret has held himself out as “Chairman”, “CEO”, and or “Managing Member” of AAI.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 15. Therefor deny # 15.

16.)   On information and belief and at all times pertinent to this action, Cartret has also held himself out as owning a majority on interest in AAI or, at the very least, representing that there were no owners in AAI that owned more interest in AAI than he.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 16. Therefor deny #16.

17.)   Defendant North State Holding Group LLC is a North Carolina limited liability company with its principal office in Wake County, North Carolina with a registered office address of 615 Oberlin Road, Suite 104, Raleigh, North Carolina 27605-3129 (North State).   ANSWER:   Defendant lacks information and or knowledge to truthfully answer #17. Therefor deny #17.

18.)   Prior to 2 June 2016, North State’s corporate name was Judicial Associates LLC. a North Carolina limited liability company (JA).      ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 18. Therefor deny # 18.

19.)   On or about 2 June 2016, JA’s name was changed to North State.    ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 19. Therefor deny #19.

20.)   On information and belief and at all times pertinent to this action, Cartret has held himself out as “Chairman”, “CEO”, and or Managing Member of North State.     ANSWER: Defendant lacks information and or knowledge to truthfully answer #21. Therefor deny #21.

22.)   At all times pertinent to this action, North State has been the parent company of and sole owner of AAI.     ANSWER: Defendant lacks information and or knowledge to truthfully answer # 22. Therefor deny #22.

23.)   On information and belief, defendant Ronald Pierce (Pierce), is a citizen and resident of Mecklenburg County, Charlotte, North Carolina.    ANSWER:   ADMITTED

24.)   Defendant Piedmont Disaster Services LLC, is a North Carolina limited liability company with its principal office located in Mecklenburg County, Charlotte, North Carolina with its registered office address of 4917 Cedarforest Drive, Charlotte, North Carolina 28226 (Piedmont).   ANSWER:   ADMITTED

25.)   On information and belief at all times pertinent to this action, Pierce was and remains the President and registered agent of Piedmont and owner of the email address of piedmontdisasterservicesllc@twc.com.     ANSWER   ADMITTED.

26.)   On information and belief, Defendant Clyde Robert Brawley Jr. (Brawley), is a citizen and resident of Mooresville, Iredell County, North Carolina.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 26. Therefor deny # 26.

27.)   On information and belief, Defendant Ken Robol (Robol), is a citizen and resident of Greenville, North Carolina.    ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 27. Therefor deny #27.

28.)   On information and belief and at all times pertinent to this action, Robol was and remains the registrant, Admin, and Tech contact person for the “NCADVOCATE.NET website (Website).       ANSWER:    Denied I alone remain the contact person and owner of NCADVOCATE.NET.

29.)   On information and belief and at all times pertinent to this action, Robol and or Pierce have been and or remain the owners, operators, managers, and or controllers of the aforementioned Website.    ANSWER:   Partial Admitted and Partial Denial, I alone Ronald Pierce, own operate, and control NCADVOCATE.NET.

30.)   References in this Verified Complaint to North State shall mean and include North States previous corporate name of Judicial Associates LLC.     ANSWER: Defendant lacks information and or knowledge to truthfully answer # 30. Therefor deny # 30.

31.)   References in this Verified Complaint to AAI shall mean and include AAI’s previous corporate name of Cattlemen’s Surety LLC.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 31. Therefor deny # 31.

32.)   On 17 October 2013, North State’s Articles of Organization were filed with the State’s Secretary of State’s Office.    ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 32. Therefor dent # 32.

33.)   At the time North State was formed and incorporated, Mr. McClain and Ms. Thompson were owners in North State along with defendant Cartret and others.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 33. Therefor deny # 33.

34.)   On 17 October 2013, the Articles of Organization of AAI were filed with the State’s Secretary of State’s Office.   ANSWER: Defendant lacks information and or knowledge to truthfully answer # 34. Therefor deny # 34.

35.   At the time AAI was formed and incorporated, North State was the parent company and sole owner of AAI, and AAI was a pure captive of North State.    ANSWER:   Defendant lacks information and or knowledge to answer # 35. Therefor deny # 35.

36.)   On or about 29 July 2014, AAI was approved by the DOI as the State’s first ever “special purpose captive insurance company” for bail bonding and surety.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 36. Therefor deny # 36.

37.)   With the DOI’s approval of AAI, bail bondsmen in the State could write bonds with AAI as the insurer of the bonds.    ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 37. Therefor deny # 37.

38.)   Owners of North State (and hence, AAI), such as Mr. McClain and Ms. Thompson and defendant Cartret, were also licensed bail bondsmen and could write bonds that were insured through AAI.    ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 38. Therefor deny # 38.

39.)   Since approximately December 2008, Mr. McClain has been duly licensed bail bondsman in the State of North Carolina (State).    ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 39. Therefor deny # 39.

40.)   Prior to North State and AAI being approved and formed in the manner in which they were in the State, for any bonds that Mr. McClain or Defendant Cartret wrote, they would have to pay a percentage to a surety company to insure the bonds.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 40.  Therefor deny # 40.

41.)   After creation of North State and AAI, AAI would receive the percentage payments to insure the bonds that bail bondsmen wrote rather than an outside or separate surety company.     ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 41. Therefor deny # 41.

42.)   Shortly after the DOI’s approval of AAI, all of Mr. McClain’s and Ms. Thompson’s respective ownership rights and interests in North State (which was also 100% percent owner of AAI), were voluntarily purchased and acquired by North State and or its other members in the total monetary consideration amount of $ 70,000.00    ANSWER: Defendant lacks information and or knowledge to truthfully answer # 42. Therefor deny # 42.

43.)   In November 2014, after all ownership rights and interests in North State and AAI had been purchased and they were no longer part of nor, affiliated with North State and AAI, Mr. McClain and Ms. Thompson incorporated and formed Premier and Cannon under the laws of the State in a similar manner and for similar and competitive business as that which had been done and was being done by North State and AAI.     ANSWER: Defendant lacks information and or knowledge to truthfully answer # 43. Therefor deny # 43.

44.)   At the time Cannon was formed and incorporated, Premier was the parent company and sole owner of cannon, and Cannon was a pure captive of Premier.     ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 44. Therefor deny # 44.

45.)   On or about 22 December 2014, Cannon was approved by the DOI as a special purpose captive insurance company for bail bonding and surety similar to and competitive with that of North State and AAI with similar advantages to the owners of Cannon and its bail bondsmen.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 45. Therefor deny # 45.

46.)   With the DOI’s approval of Cannon, bail bondsmen in the State could write bonds with Cannon as the insurer of the bonds.    ANSWER:    The defendant lacks information and or knowledge to truthfully answer # 46. Therefor deny # 46.

47.)   At all times pertinent hereto, Cartret has also been a licensed bail bondman and , on information and belief, has been writing bonds with the support of and through North State and AAI.     ANSWER:  The Defendant lacks information and or knowledge to truthfully answer # 47. Therefor deny # 47.

48.)   At all times pertinent hereto, Cartret, in the performance of his roles as Chairmen, CEO and or Managing-member of North State and AAI, has been and remains in business competition with Mr. McClain, as well as his Premier and Cannon companies.      ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 48. Therefor deny # 48.

At all times pertinent hereto, Premier has been engaged in the business of providing surety bail bonding services through its wholly owned subsidiary, Cannon.      ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 49. Therefor deny # 49.

50.)   By no later than November 2014, Mr. McClain became a 75% percent owner in Premier ( which was the sole owner of Cannon ) and Defendant Brawley was the other 25% percent owner in Premier.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 50. Therefor deny # 50.

51.)   Brawley is not and never has been a licensed bail bondsman in the State or any other jurisdiction.     ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 51. Therefor deny # 51.

52.)   Brawley has never owned more than his 25% percent ownership in Premier (which includes Cannon).      ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 52. Therefore deny # 52.

53.)   At the time that Premier and Cannon were incorporated and authorized by the DOI to do business, the DOI required Premier to post $1,250,000.00 in reserve and surplus funds under the control of the DOI in to US Bank so as to enable it and Cannon to write and issue bonds.     ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 53. Therefor deny # 53.

54.)   In connection with the creation of Premier and Cannon and in order to satisfy the DOI’s requirement, Brawley (1) contributed the sum of $ 700,000.00 in the form of a letter of Credit pledged by him and his wife: (2) contributed $ 100,000.00 to Cannon’s operating account; and (3) contributed $ 50,000.00 for legal and start-up expenses (collectively, Brawley Loan).    ANSWER”  Defendant lacks information and or knowledge to truthfully answer # 54. Therefor deny # 54.

55.)   To date, Brawley has been repaid the sum of approximately $ 300,000.00, of which the sum of approximately $ 90,000.00 was interest.      ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 55.  Therefor deny # 55.

56.)   In return for his loan, Brawley acquired a 25% percent ownership in Premier.     ANSWER:   Defendant lacks information and or knowledge to truthfully answer # 56. Therefor deny # 56.

57.)   In addition to acquiring a 25% percent ownership in Premier, Brawley also receives 8% percent interest on the outstanding Brawley Loan amount from Cannon.     ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 57.  Therefor deny # 57.

58.)   Cannon’s obligation for repayment of the Brawley Loan are set forth in the Certificate of Contribution numbered 0001 and issued by the DOI, the terms and provisions of which were required to be approved by the DOI and which, in fact, were approved by the DOI on or about 16 December 2015 (hereafter, Certificate) a true and correct copy of the Certificate, with Brawley’s signatures and initials is attached hereto as Exhibit A.    ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 58.  Therefor deny # 58.

59.)   In sum, pursuant to the Certificate, Brawley could only be paid by Cannon on the principal of Brawley Loan, only out of the excess of admitted assets of Cannon, over the sums as calculated in the parties Certificate.     ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 59. Therefor deny # 59.

60.)   The Certificate’s restrictions on payments by Cannon towards the principal sum of the Brawley Loan were required by the DOI to ensure the DOI that Cannon and Premier were adequately solvent in the eyes of the State and DOI to operate Cannon as a captive bail surety.        ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 60. Therefor deny # 60.

61.)   At all times to this action, bail bonding is governed and regulated by the State’s DOI.    ANSWER:  Defendant states as follows It is supposed to be but lacks over site from the Commissioner of Insurance.

62.)   At all times to this action, there have been approximately 1,700 duly licensed bail bondsmen in the State, all of whom are regulated and supervised by the State’s DOI.    ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 62.  Therefor deny # 62.

63.)   Cannon and Premier have had approximately 200 bail bondsmen across the State writing bonds for them.     ANSWER:  I heard it was 258.

64.)   At all pertinent times to this action, AAI and North State have had approximately 60 bail bondsmen across the State writing bonds for them.    ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 64. Therefor deny # 64.

65.)   At all times pertinent to this action, AAI/North State and Cannon/Premier are the only two special captive surety companies authorized by the State’s DOI.     ANSWER: Defendant lacks information and or knowledge to truthfully answer # 65. Therefor deny # 65.

66.)   As a result of the Certificate’s restrictions on Cannon’s payments on the Brawley Loan, Brawley is not receiving the financial returns and frankly, money he believed he would receive in connection with his involvement in Cannon and Premier.     ANSWER: Defendant lacks information and or knowledge to truthfully answer # #66. Therefor deny # 66.

67.)   On information and belief, beginning in or around the Summer of 2015, Brawley, Cartret, and AAI and North State (through the actions and conduct of Cartret) formed an agreement to take unlawful and improper damaging actions against Premier and Cannon that included, inter alia, (1) Brawley providing Cartret and AAI/North State-direct competitors of Cannon and Premier-with sensitive and propriety confidential information about Cannon and Premier, including without limitation, Cannon’s agreements with its bail bondsmen: (2) communicating, orally and or in tangible mediums, directly and or indirectly through Pierce and or Website and possibly others, to third parties, including without limitation to the DOI, defamatory statements about all of the Plaintiffs (as more specifically described below) in an effort to cause uncertainty with Cannon’s bail bondsmen, business, operations, and interaction with the DOI; and or (3) taking additional actions and engaging in additional unfair, deceptive and unscrupulous conduct in a joint effort to devalue and or destroy the business and value of Cannon and Premier so as to either compel and or force a sale by Mr. McClain of all of his interest in Cannon and Premier to Brawley or other third party purchaser, such as Cartret, or to cause Cannon and Premier to go out of business.    ANSWER:   These are outright lies. First, I have never meet Mark Cartret even to this day. The first conversation on the phone was not until May of 2016. I meet Mr. Brawley when and as I was running under the Republican ticket for Commissioner of Insurance for the State of North Carolina in Jan. or Feb. of 2016. My problem is and will all ways be with the people at the Department of Insurance on them not preforming their jobs in accordance with the laws of this State. Also how can this be a Verified Complaint when it is filled with outright lies like this one….?

68.)   In either of the scenarios in Paragraph 67 (3) above, the net effect would be AAI and Cartret having a monopoly in the State as the State’s only remaining bail surety captive enterprise and compelling Cannon’s bail bondsmen to seek surety from AAI or go to other surety companies outside the State, which would generally charge the bondsmen more money to act as the surety on bonds they wrote.     ANSWER:  Denied. Anything and everything would have to go through the North Carolina Department of Insurance.   Again lie # 2.

69.)   As of the filing of this action and at all times pertinent to this action, there have been at least 92 complaints filed with the DOI against Premier and Cannon (collectively, False Complaints).    ANSWER:  Denied. I am sure that there are more. And I personally have never made any complaints to the North Carolina Department of Insurance even to this day. On Cannon, Premier, Mr. Valentine, Mr. McClain nor Ms. Thompson nor any of her illegal entities.  Lie # 3.

70.)   On information and belief, the False Complaints have been pursued by Brawley, Pierce, Piedmont (through the actions and conduct of Pierce), Cartret, and AAI and North State (through the actions and conduct of Cartret).    ANSWER:  Denied. Lie # 4. Same as answer on # 69.

71.)   All of the False Complaints were false, unfounded, malicious, willful, reckless, baseless, abusing, and or otherwise entirely improper and without merit when they were made and they continue to be so to this day.    ANSWER:  Denied.  Lie # 5. I have seen the paperwork and the answers to some of the complaints to prove without any doubt that these individuals have lied completely through the complete process with the North Carolina Department of Insurance, renewal forms, licensing requirement and so on. Same as answer # 69.

72.)   In addition to the False Complaints, and on information and belief, Brawley, Cartret, AAI/North State (by and through the actions of Cartret), have provided false and defamatory information about Plaintiffs to Pierce, which Robol, Pierce and Piedmont (through the actions of Pierce), in turn posted, caused to be posted, and or allow to be posted on the Website, further enhancing and exacerbating the defamation and damage to Plaintiffs.    ANSWER: Denied. Lie # 6. Ken Robol has no control over the Website or me. Admitted that the proof was posted and wrote about, was by me online on the Website.

73.)   In addition to the information they receive from persons and entities for posting on the Website about Plaintiffs, and in addition to the information they allow, enable and or promote to be posted on the Website about Plaintiffs, Robol, Pierce, and Piedmont (through the actions of Pierce), directly post false, unfounded, malicious, willful, reckless, baseless, abusive, and or otherwise entirely improper meritless statements and information about Plaintiffs and or allow and permit the posting of false, unfounded, malicious, willful, reckless, baseless, abusive, and or otherwise entirely improper meritless statements and information about Plaintiffs, and they continue to do so to this day.     ANSWER:  Denied. Piedmont Disaster Service LLC has no bearing what so ever in and on this lawsuit. Please have the Plaintiffs show where one form of indiscretion was taken against the Plaintiffs’ by Piedmont Disaster Services LLC. All information posted online was the truth posted by me personally. If the information was stated as the truth then their never is nor was any meritless statements therefor the Plaintiffs have no reason lawfully for this suit.

74.)   On or about 23 May 2016, one example of a grossly defamatory article (of the numerous other articles and postings) was posted on the Website entitled, “Bail bonds Corruption at its Finest” “Editorial”, a true copy of which is attached hereto as Exhibit B.     ANSWER:  ADMITTED IN PART AND DENIED IN PART.  If someone with even a small amount of intelligence would see from this article that it. THE ARTICLE was directed at the North Carolina department of Insurance and the Deputy Commissioner for not performing their jobs in acting upon those 92 complaints from people other than MYSELF. And yet no action has been taken by the DOI to this day.

75.)   In the 23 May 2016 article, Pierce and Piedmont (through the actions of Pierce), and Robol (by, inter alia, allowing the article to be posted on the Website), lead off in all caps, “CORRUPTION, CORRUPTION, CORRUPTION….” The article make it clear the statements about corruption are specifically targeted at Premier and Cannon. The article then makes statements about Premier’s Operating Agreement, which is a private, non-public record and could not have been obtained by Pierce without having it provided by Brawley directly or through other persons and or entities to which Brawley provided it.     ANSWER: PARTICALLY ADMITTED AND PARTICALLY DENIED. Again if the information stated is and was always correct and true in nature than the Plaintiffs have no bearing for this lawsuit. Please see my Motion to Dismiss.

76.)   On or about 24 May 2016, Pierce and Piedmont (through notice to Pierce) and Robol (as registrant of the Website) received a cease and desist letter from attorney, Mark L. Bibbs, Esquire, on behalf of Plaintiffs Cannon, Mr. McClain, and Mr. Valentine, a true and correct copy of which is attached hereto as Exhibit C (Desist Letter).    ANSWER:  ADMITTED.

77.)   The Desist Letter was emailed in addition to being served by first class, United States Mail, and by certified mail.       ANSWER.   ADMITTED.

78.)   The Desist Letter noted the defamatory and false, damaging information being posted on the Website about Cannon, Mr. McClain and Mr. Valentine and demanded, inter alia, Pierce, Piedmont and Robol immediately cease and desist from making and or allowing further defamatory postings and issue a full and complete retraction of all mention of Cannon, Mr. McClain and Mr. Valentine from the Website.     ANSWER:  PARTICALLY ADMITTED AND PARTICALLY DENIED.  Again if the statements are true then there are no reasons for a lawsuit or complaint. Again see my Motion to Dismiss.

79.)   Instead of following the Desist Letter’s demands, Pierce and Piedmont (through the actions of Pierce), and Robol (through his continued silence and, presumed support) have continued to publish and post and allow to be posted defamatory materials and postings about not only Cannon, Mr. McClain and Mr. Valentine, but also all of the other Plaintiffs on the Website, and Pierce even brags of his ability to do so because his belief and contention he can do so because he is “judgment proof” and or otherwise unreachable by legal process and or the authority of our State’s Courts. True and correct, non-exhaustive of examples of Pierce’s statements that he is untouchable under the law and unaccountable to and or by the State’s Courts for his Website’s postings are collectively attached hereto as Exhibit D (entitled, ” I have a Subpoena from Mark Bibbs for information”) and Exhibit E (notably entitled, “Legal Action Against Me by Corruptors Editorial”0 (emphasis added).     ANSWER:  PARTICALLY ADMITTED AND PARTICALLY DENIED. AGAIN PLEASE SEE MY MOTION TO DISMISS.

80.)   The article in Exhibit E noted it was being posted by Pierce and Piedmont (through the actions of Pierce), and Robol (through his continued silence and presumed, support) after receiving the Desist Letter and states, inter alia, that Mr. McClain is a liar, has made lies, and is upset that Pierce’s efforts and the Website, generally, are exposing Mr. McClain’s corrupt actions and conduct at the DOI.    ANSWER:  ADMITTED. CALLING SOMEONE A LIAR IS NOT GROUNDS FOR A COMPLAINT IN ACCORDANCE WITH THE SUPREME COURT.

81.)   On the same date of receiving the Desist Letter, Pierce and Piedmont (through the actions of Pierce) and Robol (through the continued silence and, presumably, support) posted another article on the Website entitled, “Bail Bonds Corruption at Its Finest Part II Editorial, a true copy of which is attached hereto as Exhibit F.    ANSWER. ADMITTED.

82.)   In this  May 2016 article attached as Exhibit F, Pierce and Piedmont (through the actions of Pierce), and Robol (by, inter alia, allowing the article to be posted on the Website), again lead off in all caps. ” CORRUPTION, CORRUPTION, CORRUPTION….”  The article makes it clear the statements about corruption are specifically targeted at Premier and Cannon, as well as Mr. McClain and Mr. Valentine. The article then makes the additional patently false and defamatory statements that Mr. Valentine is a part owner of 25% percent in Premier, which is not true and was not true at the time of this article, and then contains false statements of violations by said Plaintiffs of the bail bonding statutory law.     ANSWER:  ADMITTED. PLEASE SEE MOTION TO DISMISS.

83.)   At all times pertinent to this action Pierce, Piedmont (through the actions of Pierce), Brawley, Cartret, and AAI/North State (by and through the actions of Cartret) towards Premier and Cannon, Pierce and Brawley discussed possibly purchasing Cannon and Premier.     ANSWER:  ADMITTED.

84.)   In furtherance of their unlawful actions, conduct and defamatory statements made about Plaintiffs, particularly including Cannon and Premier, Brawley has unlawfully provided Pierce, Piedmont, and cartret (as well as, necessarily, AAI and North State) confidential information about Cannon and Premier, including its financial and operational information, and contractual pay rates between Cannon and its Bail bondsmen, all of which enabled and continues to enable AAI/North State and Cartret to unfairly and unlawfully undercut and undermine the viability, credibility, goodwill, and profitability of Cannon and Premier.     ANSWER:  PARTICALLY ADMITTED AND PARTICALLY DENIED. THE QUESTION HERE IS IF THE INFORMATION WAS TRUE WHICH IT IS AS STATED. PLEASE SEE MOTION TO DISMISS.

85.)   In conjunction with the False Complaints, and on information and belief, Brawley has requested the DOI to turn over complete control of Cannon and Premier-which is one of the goals that he and Cartret (including AAI/North State through Cartret) agreed to try to attain to the detriment and substantial damage of Premier, Cannon, and Mr. McClain.    ANSWER:  DENIED. I DO NOT POSSESS ENOUGH KNOWLEDGE TO ANSWER THIS STATEMENT.

86.)   In conjunction with the false Complaints and in furtherance of their concerted efforts to destroy Cannon and Premier, on or about 11 January 2017 Pierce and Piedmont (through the actions of Pierce), posted an article on the Website entitled, “To All Bail Agents in North Carolina”, a true copy of which is attached hereto as Exhibit G.    ANSWER:  PARTICALLY ADMITTED AND PARTICALLY DENIED.

87.)   The article in Exhibit G clearly threatens all of the Bail bondsmen agents working for cannon and Premier of the supposed crimes and other sanctions which they will face by writing bonds for Cannon and Premier in alleged association with Mr. McClain and his association with Mr. Valentine.    ANSWER:  PARICIALLY ADMITTED AND PARTICALLY DENIED.

88.)   The article in Exhibit G further contains express defamatory statements and false innuendo about Cannon, Premier, Mr. McClain and Mr. Valentine, and an alleged Internal Revenue service Investigation and other general, criminal wrongdoing, all of which are false.    ANSWER ALL STATEMENTS POSTED ARE TRUE.

89.)   On information and belief, Robol allowed the article in Exhibit G to be posted on the Website and to remain on the Website and, on information and belief, has never taken any action to thwart, retract, remove or otherwise prevent the false and defamatory, as well as derogatory, posting about the Plaintiffs in this action, including not taking and such actions with the subject article.    ANSWER:  DENIED. SINCE KEN ROBOL HAS NO AUTHORITY OVER ME OR OF WHAT I POST ONLINE. THIS IS LIE # 8.

90.)   At all times pertinent to this action, the term “Internet Protocol Address”, is also known and referred as “IP Address”.    ANSWER: Defendant lacks information and or knowledge to truthfully answer # 90. Therefor deny # 90.

91.)   At all times pertinent to this action, an email user’s email contains and IP Address number specific to each user’s server’s software, and the IP Address number will not change even if the name of the sender of the email changes or even if someone inserts a completely fictitious  “made up” email address.    ANSWER:  Defendant lacks information and or knowledge to truthfully answer # 91. Therefor deny # 91.

92.)   At all times pertinent to this action, Mr. McClain, Ms. Thompson, and Mr. Valentine received emails from Cartret, examples of which include those received on the dates of 11 November 2015; 5 December 2016; and 26 July 2016, a true and correct copies of which are collectively attached hereto as Exhibit H (collectively, Cartret Emails).    ANSWER:   PARTICALLY ADMITTED AND PARTICALLY DENIED. THE EMAILS MAY HAVE BEEN DATED EVEN GOING BACK TO 2008. BUT WERE NEVER RECEIVED BY MYSELF UNTIL 2016. AGAIN ANOTHER FABRICATED LIE #9, BY PLAINTIFFS.

93.)   As shown in the Cartret Emails, the IP Address Number specific to Cartret’s email server’s software is 65.41.161.31. (hereinafter, Cartret IP Number).    ANSWER: Defendant lacks information and or knowledge to truthfully answer # 93. Therefor deny # 93.

94.)  At all times pertinent to this action, there have been dozens of false, derogatory, and defamatory statements posted on the website (and other internet sites) about any one or more of the Plaintiffs from not only Pierce, Piedmont (through the actions of Pierce), Robol, and Brawley, but also specifically from the Cartret IP Number. Attached as Exhibit I, is a spreadsheet compilation showing various IP Address numbers and specifically noting all emails posted to the website from the Cartret IP Number.    ANSWER: PARTICALLY ADMITTED AND MOSTLY DENIED. ALL STATEMENTS STATED ARE TRUE.

95.)  On information and belief, and as evidenced by the Cartret IP Number, Cartret is the actual person that posted the statements (many of which were false and defamatory as to any one or more of the Plaintiffs) in the attached Exhibit I compilation notwithstanding the references of fictitious names and fictitious email addresses.   ANSWER:  defendant lacks information and or knowledge to truthfully answer # 95. Therefor deny # 95.

96.)  In addition to all of the foregoing, the following is a non-exhaustive summary of examples of the false and defamatory statements posted on the website about any one or more of the Plaintiffs;

A.  “Dallas McClain lied” to Agent Services Division of the DOI;

B.  Plaintiffs comprise “a cohesive criminal group running around in the bail industry”;

C.  Plaintiffs comprise the “Raleigh Mafia”;

D.  Premier and Cannon, by and through Mr. McClain, “does not keep proper books” and “operates in the darkroom”;

E.  “Carl the Godfather Valentine” “unlawfully gets a portion of agent’s fees routed to him”;

F.  “Mr. Valentine is still collecting insurance premiums and running his companies”;

G. “Now the trio Dallas, the kingfish, Carl the godfather, and Lynette, ma-barker, needs to go to prison”; and

H.  “Valentine openly worked Bankers Surety and managed many of their agents as an intermediary or MGA. You should be talking about hundreds of thousands, if not millions of dollars”.    ANSWER:  PARTICALLY ADMITTED, PARTICALLY DENIED. just because they were posted by other people other than myself, online does not make me liable for them. I think not.

97. In addition to the foregoing, Defendants have stated and depicted Premier and Cannon as illegal companies operated by crooks – Mr. McClain, Mr. Valentine, and Ms. Thompson. Defendants have stated that Plaintiffs bribe DOI officials, sell pills and drugs to DOI officials, and have stated other outrageous and offensive comments about Plaintiffs too numerous to list in this pleading.   ANSWER:  DENIED.

Ok that’s the answers to all of the statements the rest of the lawsuit you can view on the other post of SUIT BROUGHT AGAINST ME.

 

Next I will post my Motion to Dismiss. Its a nice one and I think you will enjoy the read.

 

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