Newtechbio v Septicleanse Complaint

7/31/2019 Newtechbio v Septicleanse Complaint

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UNITED STATES DISTRICT COURTDISTRICT OF NEW JERSEY

TRENTON VICINAGE

LESSLER & LESSLER

Attorneys for Plaintiff

540 Old Bridge TurnpikeSouth River, New Jersey 08882

Tel. (732) 254-5155

* * * * * * * * * * * * * Hon. , U.S.D.J.

NEWTECHBIO INC.,

Plaintiff

-against-

SEPTICLEANSE, INC.; BRADLEY A. MAR-KIN a/k/a BRAD MARKIN; SABRINA GAR-CIA MARKIN a/k/a SABRINA GARCIA, SAB-

RINA LOAIZA GARCIA, SABRINA G. GAR-

CIA LOAIZA, JORGE RODRIGUEZ, andSABRIGL; LORI BETH KAPLAN MULTZ a/k/aLORI MULTZ, LORI BETH MULTZ, BETHWILSON and LORI KAPLAN; and ROBERTA. MARKIN,

Defendants

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*

*

*

*

*

*

*

*

Hon. , U.S.M.J.

Civ. No.

VERIFIED COMPLAINT FORINJUNCTIVE RELIEF and

DAMAGES FORRACKETEERING, TRADE LIBELAND UNFAIR COMPETITION,

and RELATED CLAIMS

With Jury Demand

* * * * * * * * * * * * *

Case 3:12-cv-05882-MAS-TJB Document 1 Filed 09/19/12 Page 1 of 49 PageID: 1


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Newtechbio Inc. v. Septicleanse, Inc. et al Civ. No.

Verified Complaint

NATURE OF ACTION

1. This is an action for injunctive relief and damages

necessitated by defendants' pattern of racketeering comprising

a deceptive and unlawful Internet marketing scheme in the

septic system chemicals industry, with wire fraud predicate

acts in which they create fictitious disparaging reviews of the

products of plaintiff and its legitimate competitors while

promoting their competing products.

JURISDICTION AND VENUE

2. This Court has original jurisdiction pursuant to 15

U.S.C. 1121(a), 15 U.S.C. 1125(a), 28 U.S.C. 1331 and

1338(b), 18 U.S.C. 1962(c) and (d), and supplemental jurisdic-

tion pursuant to 28 U.S.C. 1367(a).

3. This Court also has original jurisdiction pursuant to

28 U.S.C. 1332, because the plaintiff and the defendants are

citizens of different states and the amount in controversy

exceeds $75,000, exclusive of interest and costs.



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5. Venue is proper in this judicial district pursuant to

28 U.S.C. 1391.

THE PARTIES

6. Plaintiff Newtechbio Inc. is a New Jersey corporation

having its principal place of business at 4301 US Hwy 9 North,

Main Building Rear, Howell, New Jersey 07731.

7. Defendant Septicleanse, Inc. is a Florida corporation

with its principal office at 711 Commerce Way. Suite 5,

Jupiter, Florida 33458.

8. Defendant Bradley A. Markin a/k/a Brad Markin

("Markin") is an individual who is a citizen of the State of

Florida and resides at 103 Beachwalk Lane, Jupiter, Florida

33477.

9. Defendant Sabrina Garcia Markin a/k/a Sabrina Garcia,

Sabrina Loaiza Garcia, Sabrina G. Garcia Loaiza, Jorge Rodri-

guez, and Sabrigl ("Garcia") is an individual who is a citizen

of the State of Florida and resides at 103 Beachwalk Lane,



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resides at 72 Van Houten Fields, West Nyack, New York

10994-2528.

11. Defendant Robert A. Markin ("Markin Sr.") is an

individual who is a citizen of the State of Florida and resides

at 6627 Seven Oaks Lane, Stuart, Florida 34997.

OVERVIEW OF DEFENDANTS' MARKETING SCHEME

12. The individual defendants, acting in concert, (the

unlawful "enterprise"), via Septicleanse, Inc. and the ficti-

tious review websites as their primary instrumentality, use

interactive product marketing websites with fictitious deroga-

tory reviews of competing septic system chemical products

abetted by fictitious derogatory "product review" websites,

which together disparage competing products, namely those of

plaintiff and its legitimate competitors, causing them to have

suffered and continue to suffer substantial losses of sales and

profits.

13. As part of its marketing scheme, the enterprise uses



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do decrease the sales of plaintiffs and their legitimate

competitors and thus increase defendants' sales.

14. Defendants' enterprise search engine techniques

include the purchase of advertisements using the trademarks and

trade names of plaintiff and its legitimate competitors as key

words on various search engines including Google, Yahoo and

Bing; and implanting those trademarks and trade names as

metadata in defendants' websites. As a result, when a consumer

conducts Internet research for plaintiff's trademarks such as

NEWTECHBIO or NT-MAX on a search engine, defendants' advertise-

ments and websites are displayed ahead of plaintiff's adver-

tisements and website.

FACTUAL BACKGROUND

Plaintiff's Business

15. Plaintiff, via its newtechbio.comwebsite, markets

chemicals throughout the United States for use in septic

systems to improve performance and correct certain problems.

http://newtechbio.com/http://newtechbio.com/


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five years and have become associated by consumers with a high

quality line of such products.

17. Plaintiff sells directly to the public via its

website, and does not sell through distributors.

18. Plaintiff and its predecessor have been in business

for more than five years, during which time sales of septic

system chemicals have increased at the rate of approximately

40% per year. That growth came to a screeching halt and

plaintiff's sales dropped precipitously starting on June 14,

2012 when defendants' initial websites and review sites went

online with advertisements on search engines Google, Yahoo and

Bing.

Defendants Opted Not to Exclude New Jersey From Their National Internet Advertising

19. Defendants were at all relevant times aware that

plaintiff was marketing competing products, and that defen-

dants' place of business was in New Jersey, as evidence by

their inclusion of plaintiff's products on their sham review



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them, key words specified by the advertiser, known as "nega-

tive" key words.

21. Defendants could have excluded New Jersey from

search results which would display their advertisements, by (i)

excluding their advertisements from reaching the State of New

Jersey by including that restriction on their Google advertis-

ing request and including all states but New Jersey on their

Yahoo and Bing advertising requests, and/or (ii) opting to

employ such negative key words as "New Jersey", "Jersey" and

"NJ".

22. Defendants did not employ the foregoing state

exclusion options or negative key words to exclude New Jersey

from being targeted by their advertisements, as shown by the

fact that defendants' advertisements appear on Google, Yahoo

and Bing search engine websites when a user enters any of the

search terms "Septic Bacteria NJ", "Newtechbio NJ", "Septic

maintenance NJ", "Septic maintenance NJ Newtechbio", "NT-MAX



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Defenda nts' Marketing and Fictitious Review Web sites

23. On or about June 14, 2012 defendants' enterprise

operates septic system chemicals marketing websites

www.septicleanse.comandwww.bestsepticproducts.com, auxiliary

marketing/fictitious review websiteswww.septictreatments.net,

and fictitious review websiteswww.bestseptictreatments.com,

www.homesepticproducts.com, www.sewertreatment.net, and

www.cloggedsepticsystem.com became active, all at about the

same time.

24. Links to defendants' review websites are provided on

their marketing websites.

25. Prior to June 14, 2012 there were no negative

reviews of any of plaintiff's septic products on the Internet.

26. None of the defendants has ever purchased any of

plaintiff's products under his, her or its own name.

27. Plaintiff has no reason to believe any of defendants

ever purchased any of plaintiff's products indirectly or under

http://www.septicleanse.com/http://www.bestsepticproducts.com/http://www.septictreatments.net/http://www.bestseptictreatments.com/http://www.homesepticproducts.com/http://www.sewertreatment.net/http://www.cloggedsepticsystem.com/http://www.cloggedsepticsystem.com/http://www.sewertreatment.net/http://www.homesepticproducts.com/http://www.bestseptictreatments.com/http://www.septictreatments.net/http://www.bestsepticproducts.com/http://www.septicleanse.com/


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Defenda nts' Fictitious Derogatory and Decep tive Reviews

29. These websites contained and/or still contain inten-

tionally false, disparaging and deceptive information and

rankings concerning the septic chemicals of plaintiff and its

legitimate competitors, examples of which are:

a. "What happened when we tested it? We were

excited to see how it worked. Our tester was not so pleased."

[referring to NT-MAX, Exhibit A].

b. "However, after administering a shock, and

beginning the maintenance treatment, very little improvement

was seen. We had a hard time convincing our tester not to have

his septic system pumped out, and quitting the trial. Luckily,

he was convinced to continue the treatment for 4 weeks. After

the 4 week trial, he admitted he did get an improvement in the

speed at which his drains would flow about 20%. Possible with

continued use, the system would have been restored. However,

after a month of using the NT Max, his system was not at an



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however, was that this product was NOT the best for restoring

a system that is having problems." [Exhibit A].

d. "iiijj I believe our home benefitted from

using this septic treatment. However, it was nowhere near what

we expected, in terms of speed of showing results, and also in

value. We ended up having to pump our system out, in order for

it to get back to normal. However, this product has worked

very well to keep our system maintained. For that purpose, it

is very good." [referring to NT-MAX, Exhibit B].

e. "iijjj I did not get any results on my drain

field from using this septic cleaner. I honestly don't think

it did a thing. However, we dissolved some of it in a cup of

water, and poured it down our kitchen sink. It now seems to

drain much faster. So, as far as a septic treatment, this isn't

good." [referring to NT-MAX, Exhibit B].

f. "iijjj Not a product I would buy again. We

have been using it for 3 weeks, and our yard is still a muddy,



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with this product, but we don't have the money to get our

system replaced. We will just have to stay the course and see

if it improves soon." [Exhibit B].

h. "iiijj We still have a smell, and the drain

is still slow. Hopefully the improvement continues before we

have to buy more." [Exhibit B].

i. "iijjj I think maybe our very cold tempera-

tures have prevented this product from working. We got no

results from pouring it directly into our septic tank. Maybe

the cold kills off this type of bacteria? I don't know, but

nothing has resulted from using this." [Exhibit B].

j. "We would be testing NT Max on a troubled,

backed up and flooded system so we would definitely be needing

both the shock and the monthly packets. We were a bit confused

by the information about whether we should purchase the liquid

shock or if just flushing a couple of the ordinary monthly

packets would do the trick. We decided at long last to use the



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the past, especially when you consider the amount of water

consumption nowadays." [Exhibit C].

k. "In our testing of NT Max we saw those steps

happening, not as fast as our Best Septic Treatment, but they

did happen. In our opinion, it was a bit pricey for the

results we got, but then again we did purchase their most

powerful treatment, so perhaps the price was average as far as

the market goes". [Exhibit C].

l. "While NT Max certainly has a fantastic

reputation online and it does deliver long term results, it

didnt quite work as quickly or completely as our top rated

brands." [Exhibit C].

m. "See How NT Max Compared to Our Top 8 Septic

Treatment Comparison Chart." [Exhibit C].

n. "If there was any drawback to New Tech Bio, it

is the fact that the shock is in liquid form, or at least it

appears to be. Liquid septic treatments just dont work



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o. "Overall, if you are considering NT Max as

your septic option, you have found yourself a leading brand.

While we do not rate it as well as our Best Septic Treatment."

[Exhibit D].

p. "We did have a bit of a concern with the

product options that NT Max offered. The monthly treatments

seemed pretty straightforward and we were happy to see the use

of the easy flushable packets. But the liquid 'shock' treat-

ment troubled us a bit. First of all it is liquid, which

flushes through the system very quickly. But also due to the

size of the treatment, it was somewhat costly, not unfairly so

but significant. This may make it difficult for a homeowner on

a fixed income or ones that have a mild septic problem to get

the extra boost of bacteria from a shock treatment without

significant up front investment. It should be noted that NT

Max may have an alternate treatment designed for these circum-

stances; however we were not able to locate it." [Exhibit E].


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r. "See how New Tech Bio Compared by reading our

Septic Treatments Reviewed." [Exhibit E].

s. "New Tech Bio Testimonials: I used this

product, followed the directions and if I am being honest, I am

not sure if it worked. From reading these other testimonials,

I think maybe I may have been expecting too much, but I dont

think it did a whole lot. Thats my two cents. For what is

worth. Dan, Ontario, CA." [Exhibit F].

t. "For me, I ultimately did not choose to

purchase NT Max because the prices for a shock as well as a

treatment, both of which I needed, was a bit more than I wanted

to spend. Also, the NT Max shock does not come in the same

flushable, granular packages that their monthly treatment does,

instead it is a heavy liquid container. That is just not ideal

for someone in my predicament." [Exhibit G].

u. "Beware - most septic system treatments do NOT

work. If you are thinking of buying a septic system treatment


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31. Even those fictitious reviews that don't specifi-

cally mention plaintiff Newtechbio or its NT-MAX product are

very damaging. For example, providing a purported review list

of "top ten" or "top eight" products not including NT-MAX or

Newtechbio results in loss of sales by plaintiff. Even worse

is the statement that if a product is not on the defendants'

list (which did not include plaintiff's product), one should

reconsider a decision to buy it, since it was tried and does

not work. See Exhibit H in which defendants stated: "If you

are thinking of buying a Septic System Treatment Product that

is NOT carried below, you should Reconsider. We tried it, and

it didn't work."

32. Defendants' paid advertisements that appear when

typing the words "Newtechbio" or "NT-MAX" into search engines

state "Avoid That Septic Product" and "Septic Treatment Scams"

[Exhibit I].

33. Prior to the initial Internet public appearance of




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thousands of negative reviews, all located on defendants'

websites.

34. Using a dash (-) in a search to remove defendants'

sham websites from appearing in search results shows that there

are no true negative reviews of plaintiff's products.

35. The defamatory statements planted by defendants are

intended to artificially elevate their review websites to high

search results rankings. As a result, these fictitious review

sites displace positive commentary about plaintiff and its

septic system products on search engine results pages.

36. Upon seeing the misleading statements in sponsored

advertisements and fictitious reviews, customers and prospec-

tive customers are lured away from plaintiff's website and to

defendants' marketing websites.

37. Although some of the derogatory reviews have been

removed from some of defendants' websites, many still remain.

38. Plaintiff attempted to purchase defendants'


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and the purchase price was credited back to the corresponding

credit card.

Defendants' Purchase of Key Words of the Trademarks and Trade Namesof Plaintiff and Its Legitimate Com petitors

39. Defendants have paid search engines Google, Yahoo

and Bing for prominent advertising locations above and adjacent

to actual search results. By way of example, true and accurate

printouts of Internet key word searches on Google for plain-

tiff's trade name and trademark Newtechbio and its trademark

NT-MAX are provided as Exhibit I.

40. The prominently displayed keyword advertisements of

defendants significantly and adversely affect sales and the

reputation of plaintiff and its NT-MAX brand.

Defenda nts' Display of Plaintiff's Product on Their Website and O ffer to Sell the Same

41. Although none of the defendants is a distributor of

plaintiff's septic products and none of them have purchased

such products, their www.bestsepticproducts.com and

www.homesepticproducts.comwebsites offered plaintiff's NT-MAX


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http://www.septicleanse.com/http://www.homesepticproducts.com/http://www.homesepticproducts.com/http://www.septicleanse.com/


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were accepted but subsequently canceled without explanation,

and the purchase price was credited back to the corresponding

credit card.

43. Defendants have removed display of plaintiff's NT-

MAX product from their www.bestsepticproducts.com and

www.homesepticproducts.comwebsites but continue to include it

on some of their sham review sites.

44. All of the aforementioned activities of defendants

via their websites were conducted for the benefit of, and with

the knowledge and participation of each of the individual

defendants, who exercised control over the aforementioned

websites.

Plaintiff's Continuing Dama ges

45. In the four days after defendants' marketing

websites and fictitious review websites became active on the

Google, Yahoo and Bing search engines, plaintiff's sales of

septic system products dropped about 68% as compared to sales


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http://www.septicleanse.com/http://www.homesepticproducts.com/http://www.homesepticproducts.com/http://www.septicleanse.com/


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of profits; and continues to lose sales and profits on a daily

basis, the full extent of which cannot be predicted.

47. Defendants' unlawful acts via their enterprise have

resulted in the creation of thousands of web pages containing

false derogatory statements concerning plaintiff's septic

system products, resulting in permanent and substantial damage

to plaintiff's reputation and loss of good will.

48. Defendants' unlawful acts have caused confusion

among consumers as to the source of the NT-MAX brand of septic

system products, to the detriment of plaintiff.

49. The wrongful acts of defendants have been willful,

deliberate, intended to benefit defendants at plaintiff's ex-

pense, and without just cause or excuse.

Roles of Defendan ts in Furtherance of the Enterprise

50. Markin is the President and a Director of defendant

Septicleanse, Inc. He manages the associated part of the

enterprise.


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enterprise. She ships its products to customers from her home

in West Nyack, New York.

53. Garcia is the wife of Markin. She registers and

develops the marketing and sham review websites used by the

enterprise and posts its fictitious reviews.

Prior and Current Other Acts of Racketeering by Defendants; Face Creams

54. Defendant Multz has been convicted of criminal RICO

activity, namely racketeering conspiracy under 18 U.S.C.

1962(d), in United States v. Betonsports PLC (U.S.D.C. E.D.Mo.

2006, Closed 2011), Case No. 4:06-cr-00337-CEJ. That activity

involved an online illegal gaming operation.

55. The pattern of racketeering activity of defendants

in the present action is essentially the same as their ongoing

pattern of racketeering activity in the Internet sale of face

cream products. They operate through Dermagist, Inc. (and

formerly operated through Dermajuv, LLC, and Florida Bio Life

Styles Group, LLC) via their marketing website dermagist.com

g g

Newtechbio Inc. v. Septicleanse, Inc. et al Civ. No.Case 3:12-cv-05882-MAS-TJB Document 1 Filed 09/19/12 Page 21 of 49 PageID: 21
http://dermagist.com/http://dermagist.com/


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56. Defendants' www.skinbrighteners.net

(www.dermagist.com) website contains a hidden web page which

(when visible) displays their septic system products. That web

page is linked to theirwww.sewertreatment.net website so that

when a consumer clicks on a corresponding item on the latter

website, the hidden page on thewww.skinbrighteners.net website

is accessed and appears as a page on thewww.sewertreatment.net

website. This makes it easy for defendants to create multiple

septic products websites without having to repeatedly create

the aforementioned web page on each one.

FIRST COUNTParticipation in a RICO Enterprise

through a Pattern of Racketeering Activity

18 U.S.C. 1961(5), 1962(c)

57. Plaintiff repeats the allegations of the preceding

paragraphs as though set forth at length herein.

58. Beginning on or about June 14, 2012 and continuing

to the present time, the individual defendants associated in a

RICO enterprise whose activities affected interstate commerce

g g

http://www.dermagist.com/http://www.dermagist.com/http://www.septicleanse.com/http://www.dermagist.com/http://www.septicleanse.com/http://www.septicleanse.com/http://www.dermagist.com/http://www.septicleanse.com/http://www.dermagist.com/http://www.dermagist.com/


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more of the RICO predicate acts that are itemized at 18

U.S.C.1961(1)(B), including acts of wire fraud (violation of

18 U.S.C. 1343), and did so in violation of 18 U.S.C. 1962(c)

("Prohibited activities").

60. All individual defendants did commit two or more of

the offenses described above and they each continue to engage

in Prohibited Activities via the enterprise. Their aforemen-

tioned respective racketeering activities are continuing, have

caused and are causing damage to plaintiff and its legitimate

competitors and are deceiving consumers, and will continue to

cause such damage and deceive consumers unless and until

stopped by this Court.

61. As a result of the individual defendants' unlawful

activities as described above, plaintiff has suffered and will,

unless defendants are restrained by this Court, continue to

suffer irreparable injury for which there is no adequate remedy

at law.



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63. Defendants' activities constitute defamation of

plaintiff and its business, trade libel, and unfair competi-

tion.

64. Said activities were and are willful, malicious, and

intended to damage plaintiff and its trademarks and trade names

so as to cause enrichment of defendants.

65. As a result of defendants' libelous and unfairly

competitive activities, plaintiff has suffered and will con-

tinue to suffer a loss of sales and profits, for which losses

defendants are liable.

66. As a result of defendants' unlawful activities as

described above, plaintiff has suffered and will, unless defen-

dants are restrained by this Court, continue to suffer irrepa-

rable injury for which there is no adequate remedy at law.

THIRD COUNTIntentional Interference With Prospective Economic Advantage





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customers and prospective customers, and defendants knew such

relationships existed.

69. Through defendants' improper websites and falsified

and untrue content thereon, and their misuse of search engines

as described above, defendants intentionally interfered with

plaintiff's business relationships.

70. Defendants' utilized dishonest, unfair, and improper

means to intentionally interfere with plaintiff's business

relationships in the septic system products market.

71. As a result of defendants' unlawful interference

with plaintiff's business and prospective business relation-

ships, those relationships have been harmed, resulting present

and future losses of sales and profits, for which losses

defendants are liable.






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FOURTH COUNTTrademark Infringement



75. Defendants have used and are using plaintiff's com-

mon law trademark NT-MAX in a manner likely to cause confusion

as to the source of products with which those trademarks are

associated.




77. As a result of defendants' libelous activities,

plaintiff has suffered and will continue to suffer a loss of

sales and profits, for which losses defendants are liable.






V ifi d C l i t



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80. Defendants have misrepresented the nature, charac-

teristics, and qualities of plaintiff's septic system products

in connection with their commercial advertising and promotion

of defendants' competing products.

81. Plaintiff has an interest in being protected against

defendants' false, deceptive and misleading claims, reviews and

statements, and has been and will continue to be damaged by

their aforementioned unlawful activities.

82. Defendants' acts constitute commercial speech made

for the purpose of influencing consumers to buy defendants'

septic system products, which is disseminated to the relevant

purchasing public.

83. Defendants' unlawful conduct constitutes unfair

competition and false designation of origin or sponsorship in

violation of the Lanham Act section 43(a), 15 U.S.C. 1125(a).




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RELIEF REQUESTED

A, On the First Count, a judgment or order:

a. Declaring that all individual defendants,

jointly and severally, acting in concert, have formed and

operated a RICO enterprise, and have engaged and are engaging

in racketeering activities prohibited by 18 U.S.C. 1962(c).

b. Requiring the individual defendants and

Septicleanse, Inc. to immediately shut down all of their

websites that market septic system chemicals or that purport to

review the septic system chemical products of others.

c. Temporarily and permanently enjoining and

restraining defendants and their directors, officers, employ-

ees, agents, servants and all other persons in active concert


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misleading or derogatory information concerning the septic

system products of others, (iii) stating or implying that

listed septic system chemical products of others than plaintiff

are preferred or are superior to those not listed, (iv) stating

or implying that only those septic system products of others

than plaintiff that are listed provide acceptable performance,

or (v) stating or implying that one or more of plaintiff's

septic system products has been tested.

d. Requiring defendants to account for all sales

of septic system products on and after June 14, 2012 and all

resulting gross and net profits, including production of all

order and sales records including invoices, bank statements,

records of products ordered by defendants including invoices,

product order shipping records, and related financial records

of defendants.

e. Requiring defendants, jointly and severally,

to pay plaintiff all gross profits derived by them from their


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by plaintiff as a result of defendants' aforementioned activities.

g. Requiring defendants, jointly and severally,

to pay plaintiff all legal expenses incurred by plaintiff in

the institution and prosecution of this action, as well as

post-judgment legal expenses incurred by plaintiff in collect-

ing the amount awarded by this Court.

h. Granting plaintiff such other or further

relief as may be appropriate under the circumstances.

trial;

B. On the Second, Third, Fourth and Fifth Counts, a

judgment or order:

a. Requiring defendants to immediately shut down

all of their websites that market septic system chemicals or

that purport to review the septic system chemical products of

others.

b. Temporarily and permanently enjoining and

restraining defendants and their directors, officers, employ-


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p

information comprising or containing inaccurate, deceptive,

misleading or derogatory information concerning the septic

system products of others, (iii) stating or implying that

listed septic system chemical products of others are preferred

or are superior to those not listed, (iv) stating or implying

that only those septic system products of others that are

listed provide acceptable performance, or (v) stating or imply-

ing that one or more of plaintiff's septic system products has

been tested.

c. Requiring defendants to account for all sales

of septic system products on and after June 14, 2012 and all

resulting gross and net profits, including production of all

order and sales records including invoices, bank statements,

records of products ordered by defendants including invoices,

product order shipping records, and related financial records

of defendants.

d. Requiring defendants, jointly and severally,


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e. Requiring defendants, jointly and severally,

to pay plaintiff the actual amount of profits lost by plaintiff

as a result of defendants' aforementioned activities.

f. Awarding plaintiff punitive damages against

defendants, jointly and severally.

g. Requiring defendants, jointly and severally,

to pay plaintiff all legal expenses incurred by plaintiff in

the institution and prosecution of this action, as well as

post-judgment legal expenses incurred by plaintiff in collect-

ing the amount awarded by this Court.

h. Granting plaintiff such other or further

relief as may be appropriate under the circumstances.

JURY DEMAND

Plaintiff hereby demands trial by jury as to all issues

now or hereafter involved in the above action.

LESSLER & LESSLERAttorneys for Plaintiff

540 Old Bridge Turnpike



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EXHIBIT A


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EXHIBIT A



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EXHIBIT B


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EXHIBIT C



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Newtechbio v Septicleanse Complaint

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