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1
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ANSWER OF DEFENDANT AUDIO JAM CORP. TO VERIFIED AMENDED COMPLAINT
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EXTRACTED KEY WORDS
PARAGRAPH AVERMENTS DENIES INFORMATION SUFFICIENT TRUTH VERIFIED AMENDED COMPLAINT AGREEMENT DEFENDANT AUDIO JAM COURT DOCUMENT SPEAKS PLAINTIFFS EXHIBIT COMCAST RELIEF PARAGRAPHS SET OMNIPOINT AUDIO JAM CORPORATION DIGITAL AGENCY ADDENDUM TRI-STATE WHEREFORE JAM RESPECTFULLY REQUESTS AWARDED COSTS ATTORNEYS AUDIO JAM INCORPORATES PRECEDING PARAGRAPHS SET GOVERNORS SQUARE SQUARE LOCATION CHANCERY COMCAST METROPHONE |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
AMERICAN CELLULAR NETWORK ..
CORP., d aJ., .... Civil Action No. 17234 (SPL)
Plaintiffs, ....
V . ..
.
OMNIPOINT COMMUNICATIONS ..
SERVICES, LLC, & al., ....
Defendants. : " .
. 1
ANSWER OF DEFENDANT AUDIO JAM CORPORATION -a --
TO VERIFIED AMENDED COMPLAINT .
Defendant Audio Jam Corporation ("Audio Jam"), by an through its
counsel, hereby answers Plaintiffs' Verified Amended Complaint as follows:
1. Audio Jam is without knowledge or information sufficient to form
a belief as to the truth of the averments of this paragraph, and therefore denies the same.
2. Audio Jam is without knowledge or information sufficient to form
a belief as to the truth of the averments of this paragraph, and therefore denies the same.
3. Audio Jam is without knowledge or information sufficient to form
a belief as to the truth of the averments of this paragraph, and therefore denies the same.
4. Audio Jam is without knowledge or information sufficient to form
a belief as to the truth of the averments of this paragraph, and therefore denies the same.
5. Audio Jam i:s without knowledge or information sufficient to form
a belief as to the truth of the averments of this paragraph, and therefore denies the same.
6. Audio Jam is without knowledge or information sufficient to form
a belief as to the truth of the averments of this paragraph, and therefore denies the same.
7. Audio Jam is without knowledge or information sufficient to form
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2
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ANSWER OF DEFENDANT SOUND OF TRI-STATE TO THE AMENDED COMPLAINT
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EXTRACTED KEY WORDS
AVERMENTS DEFENDANT SUFFICIENT INFORMATION TRUTH FALSITY TRI-STATE AGREEMENT PURPORT SPEAKS COMCAST PLAINTIFFS LAW ADDENDUM OMNIPOINT WILMINGTON REFERENCE RESPONSE DELAWARE CELLULAR SOUND AMENDED COMPLAINT TRI-STATE INCORPORATES COMCAST METROPHONE CELL SOUTH DIGITAL AGENCY ADDENDUM PRECEDING PARAGRAPHS SUFFER ESQUIRE COURT |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
AMERICAN CELLULAR NETWORK CORP., :
et al., .
Plaintiffs :.
V. : C.A. No. 17234(SPL)
..
OMNIPOINT COMMUNICATIONS SERVICES, :
LLC, SOUND OF TRI-STATE, INC.,
AUDIO JAM CORPORATION and U.S. PAGE:. .,
Defendants :
ANSWER OF DEFENDANT SOUND OF TRI-STATE INC.
TO THE AMENDED COMPLAINT
1. Defendant is without sufficient information to form a
belief as to the truth or falsity of the averments in this
paragraph.
2. Defendant is without sufficient information to form a
belief as to the truth or falsity of the averments in this
paragraph.
3. Defendant is without sufficient information to form a
belief as to -the truth or falsity of the averments in this
paragraph.
4. Defendant is without sufficient information to form a
belief as to the truth or falsity of the averments in this
paragraph.
5. Defendant is without sufficient information to form a
belief as to the truth or falsity of the averments in this
paragraph.
SNIPPETS:
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3
.
ANSWER OF DEFENDANT OMNIPOINT COMMUNICATIONS SERVICES TO VERIFIED AMENDED COMPLAINT
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EXTRACTED KEY WORDS
PARAGRAPH OMNIPOINT TRUTH INFORMATION SUFFICIENT DEFENDANT OMNIPOINT COMMUNICATIONS PLAINTIFFS VERIFIED AMENDED COMPLAINT AGREEMENT CELLULAR COMMUNICATIONS SERVICES COURT DOCUMENT SPEAKS DELAWARE PURPORT COMCAST TRI-STATE AUDIO JAM DIGITAL AGENCY ADDENDUM WILMINGTON CELLULAR PARAGRAPH SETS WHEREFORE RESPECTFULLY REQUESTS AWARDED COSTS ATTORNEYS CASTLE COUNTY UNDERSIGNED COUNSEL OMNIPOINT INCORPORATES FOREGOING PARAGRAPHS PURPORTED VIOLATION |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
AMERICAN CELLULAR NETWORK :
CORP., et al., ea..
Plaintiffs, ..
-
v. 6B C.A. No. 17234NC 7 ."
OMNIPOINT COMMUNICATIONS :
SERVICES, L.L.C., et al., *aa i .?
0 ?.
Defendants. :
ANSWER OF DEFENDANT OMNIPOINT COMMUNICATIONS
SERVICES, L.L.C. TO VERIFIED AMENDED COMPLAINT
Defendant Ornnipoint Communications Services, L.L.C. 4" Omnipoint"), by and
through its undersigned counsel, hereby answers Plaintiffs' Verified Amended Complaint as
follows:
I. Omnipoint is without knowledge or information sufficient to form a belief
as to the truth of the averments of this paragraph, and they are denied accordingly.
2. Omnipoint is without knowledge or information sufficient to form a belief
as to the truth of the averments of this paragraph, and they are denied accordingly.
-32 a Omnipoint is without knowledge or information sufficient to form a belief
as to the truth of the averments of this paragraph, and they are denied accordingly.
4. Omnipoint is without knowledge or information sufficient to form a belief
as to the truth of the averme:nts of this paragraph, and they are denied accordingly.
5. Omnipoint is without knowledge or information sufficient to form a belief
as to the truth of the averments of this paragraph, and they are denied accordingly.
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4
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PLAINTIFFS OPENING BRIEF IN SUPPORT OF MOTION FOR PRELIM. INJUNCTION
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EXTRACTED KEY WORDS
CELLULAR COUNTY PRELIMINARY INJUNCTION AUDIO JAM COMCAST PLAINTIFFS AGENCY AGREEMENT TRI-STATE PHILADELPHIA VER COMPL DEL AGENTS COMMUNICATIONS SQUARE COMMERCIAL RELATIONSHIPS IRREPARABLE HARM CASTLE COUNTY TORTIOUS INTERFERENCE CELLULAR TELEPHONE COMPANY CELLULAR NETWORK RESTRICTIVE COVENANTS EXCLUSIVELV AMERICAN CELLULAR NETWORK LEXIS WILMINGTON CELLULAR BUSINESS RELATIONS CMRS PENNSYLVANIA |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
AMERICAN CELLULAR NETWORK
CORP., et al.,
Plaintiffs,
. I
.
vs. : C.A. No. / ..-...
C' I
OMNIPOINT COMMUNICATIONS
SERVICES, LLC,
Defendant.
PLAINTIFFS' OPENING BRIEF IN SUPPORT OF
THEIR MOTION FOR PRELIMINARY INJUNCTION
Henry E. Gallagher, Jr.
Samuel D. Brickley II
Connolly, Bove, Lodge & Hutz
1220 Market Street
P.O. Box 2207
Wilmington, DE 19899
(302) 658-9141
Attorneys for Plaintiffs
Of Counsel:
William B. Petersen
Edmond J. Ghisu
Hangley Aronchick Segal & Pudlin
One Logan Square, 12th Floor
Philadelphia, PA 19 103
(215) 568-6200
Dated: June 15, 1999
TABLE OF CONTENTS
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5
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V. OMNIPOINT COMMUNICATIONS SERVICES LLC VERIFIED COMPLAINT
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EXTRACTED KEY WORDS
COMCAST CELLULAR TELEPHONE COMPANY DELAWARE JERSEY COUNTY PENNSYLVANIA WILMINGTON CELLULAR AGENCY AGREEMENT AUDIO JAM PLAINTIFF AMERICAN CELLULAR TRI-STATE EAST SWEDESFORD ROAD WAYNE CELL SOUTH DELAWARE GENERAL PARTNERSHIP COMCAST METROPHONE METROPOLITAN STATISTICAL AREA OMNIPOINT COMMUNICATIONS OCEAN COUNTY LLC COMCAST PCS C-SW CELLULAR PARTNERSHIP WIRELESS TELECOMMUNICATIONS SERVICE COMMERCIAL RELATIONSHIP AMERICAN CELLULAR NETWORK DIGITAL ADDENDUM TELECOMMUNICATIONS SERVICE CMRS BUSINESS RELATIONS |
81 IP m-,' r (f- y
$ ! i i, 1 \,
r5 IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
AMERICAN CELLULAR NETWORK CORP., :
CELL SOUTH OF NEW JERSEY, INC., :
VINELAND CELLULAR TELEPHONE :
COMPANY, INC., COMCAST PCS .B
COMMUNICATIONS, INC., AMCELL OF :
ATLANTIC CITY, INC., OCEAN COUNTY :
CELLULAR TELEPHONE COMPANY, NEW :
BRUNSWICK CELLULAR TELEPHONE :
COMPANY, LONG BRANCH CELLULAR : Civil Action No. flA3hC
TELEPHONE COMPANY, and C-SW 0.
CELLULAR PARTNERSHIP, ..:
Plaintiffs, 0a..
vs. ...
OMNIPOINT COMMUNICATIONS
SERVICES, LLC,
Defendant.
VERIFIED COMPLAINT
Plaintiffs American Cellular Network Corp., Cell SouthofNew Jersey, Inc.,
Cellular Telephone Company, Inc., Comcast PCS Communications, Inc., Amcell of Atlantic
Inc., Ocean County Cellular Telephone Company, New Brunswick Cellular Telephone Company,
Long Branch Cellular Telephone Company and C-SW Cellular Partnership (collectively,
"Corncast"), by and through their undersigned counsel, and for their Complaint in this
state as follows:
PARTIES
1. Plaintiff American Cellular Network Corp. ("Amcell") is a New Jersey
corporation with offices at 480 East Swedesford Road, Wayne, Pennsylvania 19087. Amcell is the
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