Case Document 18 Filed 02/26/20 Page 1 of 14 11.9 01-3712,? ?203? . [7:51 C7 4: Irvin Ebaugh .. 12612 Selsey Road 2020 FEB 2 - . Ocean City, MD 21842 .. 6 PH 33 443-235-0441 if": 1 ?f7?w {kl-V .3 a A). a IN THE UNITED STATES DISTRIC COURT FOR THE DISTRICT (NORTHERN DIVISION) Hardwire, LLC CASE NO.: Plaintiff, vs. Irvin Ebaugh IV, AND INFRASTRUCTURE ARMOR LLC ANSWERS TO COMPLAINT Answers to Complaint a I 1 Case Document 18 Filed 02/26/20 Page 2 of 14 1. Defendant lacks enough information to respond. 2. Defendant denies the allegations in this paragraph of the Complaint. 3. Defendant denies the allegations in this paragraph of the Complaint. AND VENUE 4. Defendant denies the allegations in this paragraph of the Complaint. 5. Defendant denies the allegations in this paragraph of the Complaint. 6. Defendant denies the allegations in this paragraph of the Complaint. 7. Defendant denies the allegations in this paragraph of the Complaint. 8. Defendant denies the allegations in this paragraph of the Complaint. INTRODUCTION 9. Defendant denies the allegations in this paragraph of the Complaint. 10. Defendant denies the allegations in this paragraph of the Complaint. BACKGROUND 11. Defendant denies the allegations in this paragraph of the Complaint. 12. Defendant denies the allegations in this paragraph of the Complaint. 13. Defendant denies the allegations in this paragraph of the Complaint. 14. Defendant denies the allegations in this paragraph of the Complaint. 15. Defendant denies the allegations in this paragraph of the Complaint. 16. Defendant denies the allegations in this paragraph of the Complaint. 17. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a 2 Case Document 18 Filed 02/26/20 Page 3 of 14 18. Defendant denies the allegations in this paragraph of the Complaint. 19. Defendant denies the allegations in this paragraph of the Complaint. 20. Defendant denies the allegations in this paragraph of the Complaint. 21. Defendant denies the allegations in this-paragraph of the Complaint. 22. Defendant denies the allegations in this paragraph of the Complaint. 23. Defendant denies the allegations in this paragraph of the Complaint. 24. Defendant denies the allegations in this paragraph of the Complaint. FACTS 25. Defendant denies the allegations in this paragraph of the Complaint. 26. Defendant denies the allegations in this paragraph of the Complaint. 27. Defendant denies the allegations in this paragraph of the Complaint. 28. Defendant denies the allegations in this paragraph of the Complaint. 29. Defendant denies the allegations in this paragraph of the Complaint. 30. Defendant denies the allegations in this paragraph of the Complaint. 31. Defendant denies the allegations in this paragraph of the Complaint. 32. Defendant denies the allegations in this paragraph of the Complaint. 33. Defendant denies the allegations in this paragraph of the Complaint. 34. Defendant denies the allegations in this paragraph of the Complaint. 35. Defendant denies the allegations in this paragraph of the Complaint. 36. Defendant denies the allegations in this paragraph of the Complaint. 37. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a I 3 Case Document 18 Filed 02/26/20 Page 4 of 14 38. Defendant denies the allegations in this paragraph of the Complaint. 39. Defendant denies the allegations in this paragraph of the Complaint. 40. Defendant denies the allegations in this paragraph of the Complaint. 41. Defendant denies the allegations in this paragraph of the Complaint. RELATIONSHIP WITH EBAUGH 42. Defendant denies the allegations in this paragraph of the Complaint. 43. Defendant denies the allegations in this paragraph of the Complaint. 44. Defendant denies the allegations in this paragraph of the Complaint. 45. Defendant denies the allegations in this paragraph of the Complaint. 46. Defendant denies the allegations in this paragraph of the Complaint. 47. Defendant denies the allegations in this paragraph of the Complaint. 48. Defendant denies the allegations in this paragraph of the Complaint. 49. Defendant denies the allegations in this paragraph of the Complaint. 50. Defendant denies the allegations in this paragraph of the Complaint. 51. Defendant denies the allegations in this paragraph of the Complaint. 52. Defendant denies the allegations in this paragraph of the Complaint. 53. Defendant denies the allegations in this paragraph of the Complaint. 54. Defendant denies the allegations in this paragraph of the Complaint. 55. Defendant denies the allegations in this paragraph of the Complaint. 56. Defendant denies the allegations in this paragraph of the Complaint. 57. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a 4 Case Document 18 Filed 02/26/20 Page 5 of 14 58. 59. 60. 61. 62. 63. 64. 65. 66. 67. 68. 69. 70. 71. 72. 73. 74. 75. 76. 77. Answers to Complaint Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. MISCONDUCT Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Defendant denies the allegations in this paragraph of the Complaint. Page 5 Case Document 18 Filed 02/26/20 Page 6 of 14 78. Defendant denies the allegations in this paragraph of the Complaint. 79. Defendant denies the allegations in this paragraph of the Complaint. 80. Defendant denies the allegations in this paragraph of the Complaint. 81. Defendant denies the allegations in this paragraph of the Complaint. 82. Defendant denies the allegations in this paragraph of the Complaint. 83. Defendant denies the allegations in this paragraph of the Complaint. 84. Defendant denies the allegations in this paragraph of the Complaint. 8S. Defendant denies the allegations in this paragraph of the Complaint. 86. Defendant denies the allegations in this paragraph of the Complaint. 87. Defendant denies the allegations in this paragraph of the Complaint. 88. Defendant denies the allegations in this paragraph of the Complaint. 89. Defendant denies the allegations in this paragraph of the Complaint. 90. Defendantdenies the allegations in this paragraph of the Complaint. 91. Defendant denies the allegations in this paragraph of the Complaint. 92. Defendant denies the allegations in this paragraph of the Complaint. 93. Defendant denies the allegations in this paragraph of the Complaint. 94. Defendant denies the allegations'in this paragraph of the Complaint. 95. Defendant denies the allegations in this paragraph of the Complaint. 96. Defendant denies the allegations in this paragraph of the Complaint. 97. Defendant denies the allegations in this paragraph of the Complaint. 98. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a 6 Case Document 18 Filed 02/26/20 Page 7 of 14 99. Defendant denies the allegations in this paragraph of the Complaint. 100. Defendant denies the allegations in this paragraph of the Complaint. COUNT 1 (VIOLATION OF DEFENSE TRADE SECRETS ACT 18 U.S.C.) 101. Ebaugh and IA repeats and realleges the preceding paragraphs of the Complaint as if fully set forth herein. 102. Defendant denies the allegations in this paragraph of the Complaint. 103. Defendant denies the allegations in this paragraph of the Complaint. 104. Defendant denies the allegations in this paragraph of the Complaint. 105. Defendant denies the allegations in this paragraph of the Complaint. 106. Defendant denies the allegations in this paragraph of the Complaint. 107. Defendant denies the allegations in this paragraph of the Complaint. 108. Defendant denies the allegations in this paragraph of the Complaint. 109. Defendant denies the allegations in this paragraph of the Complaint. 110. Defendant denies the allegations in this paragraph of the Complaint. 111. Defendant denies the allegations in this paragraph of the Complaint. 112. Defendant denies the allegations in this paragraph of the Complaint. 113. Defendant denies the allegations in this paragraph of the Complaint. 114. Defendant denies the allegations in this paragraph of the Complaint. 115. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a 7 Case Document 18 Filed 02/26/20 Page 8 of 14 116. Defendant denies the allegations in this paragraph of the Complaint. 117. Defendant denies the allegations in this paragraph of the Complaint. 118. Defendant denies the allegations in this paragraph of the Complaint. 119. Defendant denies the allegations in this paragraph of the Complaint. WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. COUNT ll (Violation of Maryland Uniform Trade Secrets Act) 120. Ebaugh and IA repeats and realleges the preceding paragraphs of the Complaint as if fully set forth herein. 121. Defendant denies the allegations in this paragraph of the Complaint. 122. Defendant denies the allegations in this paragraph of the Complaint. 123. Defendant denies the allegations in this paragraph of the Complaint. 124. Defendant denies the allegations in this paragraph of the Complaint. 125. Defendant denies the allegations in this paragraph of the Complaint. 126. Defendant denies the allegations in this paragraph of the Complaint. 127. Defendant denies the allegations in this paragraph of the Complaint. 128. Defendant denies the allegations in this paragraph of the Complaint. 129. Defendant denies the allegations in this paragraph of the Complaint. 130. Defendant denies the allegations in this paragraph of the Complaint. 131. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a I 8 Case Document 18 Filed 02/26/20 Page 9 of 14 WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. COUNT (Breach of Contract Against Ebaugh) 132. Ebaugh and IA repeats and realleges the preceding paragraphs of the Complaint as if fully set forth herein. 133. Defendant denies the allegations in this paragraph of the Complaint. 134. Defendant denies the allegations in this paragraph of the Complaint. 135. Defendant denies the allegations in this paragraph of the Complaint. 136. Defendant denies the allegations in this paragraph of the Complaint. 137. Defendant denies the allegations in this paragraph of the Complaint. 138. Defendant denies the allegations in this paragraph of the Complaint. 139. Defendant denies the allegations in this paragraph of the Complaint. 140. Defendant denies the allegations in this paragraph of the Complaint. 141. Defendant denies the allegations in this paragraph of the Complaint. 142. Defendant denies the allegations in this paragraph of the Complaint. WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. COUNT IV (Violation of Racketeer Influenced and Corrupt Organizations Act) 143. Ebaugh and IA repeats and realleges the preceding paragraphs of the Complaint as if fully set forth herein. 144. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a 9 Case Document 18 Filed 02/26/20 Page 10 of 14 145. Defendant denies the allegations in this paragraph of the Complaint. 146. Defendant denies the allegations in this paragraph of the Complaint. 147. Defendant denies the allegations in this paragraph of the Complaint. 148. Defendant denies the allegations in this paragraph of the Complaint. 149. Defendant denies the allegations in this paragraph of the Complaint. 150. Defendant denies the allegations in this paragraph of the Complaint. 151. Defendant denies the allegations in this paragraph of the Complaint. 152. Defendant denies the allegations in this paragraph of the Complaint. 153. Defendant denies the allegations in this paragraph of the Complaint. 154. Defendant denies the allegations in this paragraph of the Complaint. 155. Defendant denies the allegations in this paragraph of the Complaint. 156. Defendant denies the allegations in this paragraph of the Complaint. 157. Defendant denies the allegations in this paragraph of the Complaint. 158. Defendant denies the allegations in this paragraph of the Complaint. 159. Defendant denies the allegations in this paragraph of the Complaint. 160. Defendant denies the allegations in this paragraph of the Complaint. 161. Defendant denies the allegations in this paragraph of the Complaint. WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. COUNT (Conversion Against Ebaugh) Answers to Complaint a I 10 Case Document 18 Filed 02/26/20 Page 11 of 14 162. Ebaugh and IA repeats and realleges the preceding paragraphs of the Complaint as if fully set forth herein. 163. Defendant denies the allegations in this paragraph of the Complaint. 164. Defendant denies the allegations in this paragraph of the Complaint? 165. Defendant denies the allegations in this paragraph of the Complaint. 166. Defendant denies the allegations in this paragraph of the Complaint. 167. Defendant denies the allegations in this paragraph of the Complaint. 168. Defendant denies the allegations in this paragraph of the Complaint. WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. COUNT VI (Tortious Interference with Prospective Advantage and Business Relationships Against Defendants) 169. Ebaugh and IA repeats and realleges the preceding paragraphs ofthe Complaint as if fully set forth herein. 170. Defendant denies the allegations in?this paragraph of the Complaint. 171. Defendant denies the allegations in this paragraph of the Complaint. 172. Defendant denies the allegations in this paragraph of the Complaint. 173. Defendant denies the allegations in this paragraph of the Complaint. 174. Defendant denies the allegations in this paragraph of the Complaint. 175. Defendant denies the allegations in this paragraph of the Complaint. 176. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a 11 Case Document 18 Filed 02/26/20 Page 12 of 14 177. Defendant denies the allegations in this paragraph of the Complaint. 178. Defendant denies the allegations in this paragraph of the Complaint. 179. Defendant denies the allegations in this paragraph of the Complaint. 180. Defendant denies the allegations in this paragraph of the Complaint. 181. Defendant denies the allegations in this paragraph of the Complaint. 182. Defendant denies the allegations in this paragraph of the Complaint. 183. Defendant denies the allegations in this paragraph of the Complaint. WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. COUNT VII (Breach of Duty of Loyalty Negligence Against Ebaugh) 184. Ebaugh and IA repeats and realleges the preceding paragraphs of the Complaint as if fully set forth herein. 185. Defendant denies the allegations in this paragraph of the Complaint. 186. Defendant deniesthe allegations in this paragraph of the Complaint. 187. Defendant denies the allegations in this paragraph of the Complaint. 188. Defendant denies the allegations in this paragraph of the Complaint. WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. (Unfair Competition Against Defendants) 189. Ebaugh and IA repeats and realleges the preceding paragraphs of the Complaint as if fully set forth herein. Answers to Complaint a 12 Case Document 18 Filed 02/26/20 Page 13 of 14 190. Defendant denies the allegations in this paragraph of the Complaint. 191. Defendant denies the allegations in this paragraph of the Complaint. 192. Defendant denies the allegations in this paragraph of the Complaint. 193. Defendant denies the allegations in this paragraph of the Complaint. 194. Defendant denies the allegations in this paragraph of the Complaint. 195. Defendant denies the allegations in this paragraph of the Complaint. 196. Defendant denies the allegations in this paragraph of the Complaint. 197. Defendant denies the allegations in this paragraph of the Complaint. 198. Defendant denies the allegations in this paragraph of the Complaint. 199. Defendant denies the allegations in this paragraph of the Complaint. 200. Defendant denies the allegations in this paragraph of the Complaint. 201. Defendant denies the allegations in this paragraph of the Complaint. 202. Defendant denies the allegations in this paragraph of the Complaint. WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. COUNT iX (Trespass Against Ebaugh) 203. Ebaugh and IA repeats and realleges the preceding paragraphs of the Complaint as if fully set forth herein. 204. Defendant denies the allegations in this paragraph of the Complaint. 205. Defendant denies the allegations in this paragraph of the Complaint. 206. Defendant denies the allegations in this paragraph of the Complaint. Answers to Complaint a 13 Case Document 18 Filed 02/26/20 Page 14 of 14 207. Defendant denies the allegations in this paragraph of the Complaint. 208. Defendant denies the allegations in this paragraph of the Complaint. 209. Defendant denies the allegations in this paragraph of the Complaint. 210. Defendant denies the allegations in this paragraph of the Complaint. WHEREFORE, Infrastructure Armor LLC demands that this Count be dismissed in its entirety. Respectfully submitted, Irvin Ebaugh IV 12612 Selsey Road Ocean City, MD 21842 623?; a (443) 235-0441 Signature . I Irvin Ebaugh IV Answers to Complaint a 14