"such as making false reports to the NYSDEC to tr

"such as making false reports to the NYSDEC to try to stop a permit (you and your mastmind scion failed) ...... you're only being sued for the facts of your behavior."

I've never made a single phone call in reference to JBII except to the TA regarding share structure (which is actually encouraged on JBI's website www.plastic2oil.com).  The only contact I've ever had with the DEC was a simple FOIL request via fax ( http://www.dec.ny.gov/public/373.html - contact info + one sentence describing the 2011 Plastic Throughput Report required by JBI's permit*).

Those facts? 

*   that would be the same permit that forewarned about unannounced DEC inspections