Peter L. Skolnik, Landmark Education v. Rick Ross answer (2004)
“ Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegation that “defendants’ web sites have even greater reach,” but admit that a search for “Landmark Education” under the Internet search engine “Google” produces defendants’ websites as an internet portal. ”
Peter L. Skolnik, Landmark Education v. Rick Ross answer (2004)
“ Defendants maintain that each of plaintiffs’ claims is legally insufficient, is not supported by fact, is entirely lacking in merit, and that the Complaint as a whole constitutes an egregious example of a so-called “SLAPP” suit (“strategic lawsuit against public participation”) under the law of many jurisdictions. Moreover, as a matter of law, defendants assert the following technical defenses, and reserve their right to assert additional defenses not specifically pleaded herein. ”
Peter L. Skolnik, Landmark Education v. Rick Ross answer (2004)
“ Defendants deny the allegations of the second sentence of paragraph 4 of the Complaint, and state that The Ross Institute was incorporated as a nonprofit organization in July 2002, and obtained Internal Revenue Service recognition as a 501 (c) (3) educational charity in December 2002. Defendants admit that Rick Ross (“Ross”) is an individual who resides in Jersey City, New Jersey and state that although “Ricky Ross” is Ross’s legally-given name inscribed on his birth certificate, he has since his teenage years referred to himself as Rick Ross, Rick Alan Ross, or Rick A. Ross. ”
