UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA 

_________________________________________________ 

 │

LEXINGTON INSURANCE COMPANY, │Civil Action No. 02-CV-4435 

 │ (Hon. Anita B. Brody)

 Plaintiff, │

 │

 - against – │

 │

DAVID FORREST, T. BEAUCLERC ROGERS IV, │

STANLEY MUNSON, MARTIN FINK, all individually, │

and NEW BEGINNINGS ENTERPRISES LLC, a │

California Limited Liability Company, and │

TARLO LYONS, a partnership, │

 │

 Defendants. │

________________________________________________│

ANSWER OF DEFENDANT STANLEY MUNSON TO THE 

SECOND AMENDED AND SUPPLEMENTAL COMPLAINT

 Defendant, Stanley Munson, by and through counsel, hereby responds to the Plaintiff's 

Second Amended and Supplemental Complaint and avers as follows: 

1. Denied. 

2. Denied. 

3. Denied. 

4. - 5. Answering defendant lacks sufficient knowledge or belief as to the allegations 

contained herein and therefore denies them. 

6. – 8. Admitted. 

9. Admitted that Stanley Munson is a solicitor, formerly a salaried partner in Tarlo 

Lyons, an officer of at least one Flashpoint company, a shareholder in a company owning shares 

in a Flashpoint company, and a United Kingdom lawyer for certain Flashpoint companies. 

Otherwise the allegations are denied. 

Case 2:02-cv-04435-AB Document 127 Filed 01/27/2005 Page 1 of 8
10. Answering defendant lacks sufficient knowledge or belief as to the allegations 

contained herein and therefore denies them. 

11. Admitted that New Beginnings Enterprises LLC is connected with Flashpoint. 

Otherwise the allegations are denied. 

12. Admitted that Tarlo Lyons is a firm of solicitors of which Stanley Munson was a 

salaried partner and represented certain Flashpoint companies. Otherwise the allegations are 

denied. 

13. Denied. 

14. Denied. The allegations contained herein are conclusions of law and strict proof 

thereof is demanded at trial. 

15. Answering defendant lacks sufficient knowledge or belief as to the allegations 

contained herein and therefore denies them. 

16. - 17. Admitted. 

18. Answering defendant lacks sufficient knowledge or belief as to the allegations 

contained herein and therefore denies them. 

19. Denied. 

20. - 30. Answering defendant lacks sufficient knowledge or belief as to the allegations 

contained herein and therefore denies them. 

31. – 32. Denied. 

33(a). Denied. 

33(b). Denied. 

33(c) (i)-(ii). Answering defendant lacks sufficient knowledge or belief as to the 

allegations contained herein and therefore denies them. 

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Case 2:02-cv-04435-AB Document 127 Filed 01/27/2005 Page 2 of 8
33(c) (iii)-(v). Denied. 

33(d). Denied. 

33(e) (i)-(ii). Answering defendant lacks sufficient knowledge or belief as to the 

allegations contained herein and therefore denies them. 

33(e) (iii)-(v). Denied. 

33(f). Denied. 

33(g). Answering defendant lacks sufficient knowledge or belief as to the allegations 

contained herein and therefore denies them. 

34. Denied. 

35. The allegations are not directed against answering defendant and therefore no 

response is required. 

36. Admitted that Mr. Justice Steel made a ruling dated January 19, 2001 and Defendant 

Stanley Munson respectfully refers this Court to that decision for a full and accurate statement of 

its terms. Otherwise the allegations are denied. 

37. – 38. Denied. 

39. Defendant Stanley Munson respectfully refers the Court to the documents specified 

for a full and complete statement of their terms. Otherwise the allegations are denied. 

40. – 46. Denied. 

47. Answering defendant lacks sufficient knowledge or belief as to the allegations 

contained herein and therefore denies them. 

48. - 54. Denied. 

55. - 59. The allegations contained herein are not directed at answering defendant and 

therefore no response is required. 

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Case 2:02-cv-04435-AB Document 127 Filed 01/27/2005 Page 3 of 8
60. - 72. Denied. 

73. Denied that the quoted language appears in each separate Collateral Agreement with 

respect to each of the Hollywood Funding Nos. 4, 5 and 6 transactions. Otherwise the allegations 

are admitted.

74. Defendant Stanley Munson admits the first sentence of Paragraph 74 and otherwise 

denies the allegations. 

75. Defendant Stanley Munson denies the first sentence of Paragraph 75 but otherwise 

admits the allegations. 

76. – 87. Denied. 

88. - 92. The allegations contained herein are not directed at answering defendant and 

therefore no response is required. 

93. - 94. Denied. 

95. - 96. Answering defendant lacks sufficient knowledge or belief as to the allegations 

contained herein and therefore denies them. 

97. Defendant Stanley Munson admits the first sentence of Paragraph 97 and otherwise 

denies the allegations. 

AFFIRMATIVE DEFENSES

1. The Court lacks personal jurisdiction over the defendant. 

2. The complaint fails to state a claim upon which relief can be granted. 

3. The claims in the complaint are barred by the statute of limitations. 

4. The claims in the complaint are barred by the law of release. 

5. The claims in the complaint are barred by the doctrine of unclean hands. 

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Case 2:02-cv-04435-AB Document 127 Filed 01/27/2005 Page 4 of 8
 __/s/ Conrad O. Kattner_________ 

 Conrad O. Kattner, Esq. 

 McSHEA TECCE, P.C.

 Bell Atlantic Tower

 1717 Arch Street, 28th Floor 

 Philadelphia, PA 19103 

 215-599-0800 

 215-599-0888 (fax) 

 Attorneys for Defendant, Stanley Munson

Dated: January 27, 2005 

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Case 2:02-cv-04435-AB Document 127 Filed 01/27/2005 Page 5 of 8
IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

LEXINGTON INSURANCE COMPANY CIVIL ACTION 

Plaintiff

v. NO. 02-4435 

DAVID FORREST, 

T BEAUCLERC ROGERS IV, 

STANLEY MUNSON, 

MARTY FINK, 

NEW BEGINNINGS ENTERPRISES LLC, 

and TARLO LYONS 

Defendants

CERTIFICATE OF SERVICE 

 Conrad Kattner, Esquire, attorney for Defendant, Stanley Munson, hereby certify that I 

have caused copies of the foregoing: 

ANSWER OF DEFENDANT STANLEY MUNSON TO THE 

SECOND AMENDED AND SUPPLEMENTAL COMPLAINT 

to be served electronically, and by any additional means shown, upon the following parties or 

their counsel of record on the date below: 

Case 2:02-cv-04435-AB Document 127 Filed 01/27/2005 Page 6 of 8
Via Hand Delivery Jan. 28, 2005

Glenn F. Rosenblum, Esquire 

Jeffrey R. Lennan, Esquire 

Montgomery, McCraken, Walker & 

Rhoads 

123 South Broad Street 

Philadelphia, PA 19 109 

Via Overnight Delivery Sent Jan. 28, 

2005

Edward P. Krugman, Esquire 

Emily A. Poler, Esquire 

Ira J. Dembrow, Esquire

Scott M. Mory, Esquire 

Cahill Gordon & Reindel 

80 Pine Street 

New York, NY 10005 

Counsel for Plaintiff 

Alexander Kerr, Esquire 

Stephen P. McFate 

McCarter & English, LLP 

Mellon Bank Center 

1735 Market Street, Suite 700 

Philadelphia, PA 19 103 

and 

Beverly Y. Lu, Esquire 

Charles A. Adamek 

Lord Bissell & Brook, LLP 

300 South Grand Avenue, Suite 800 

Los Angeles, CA 9007 1 

Counsel for New Beginnings Enterprises 

Edward M. Dunham, Jr., Esquire 

Shannon Hampton Sutherland, Esquire 

Duane Morris LLP 

One Liberty Place 

Philadelphia, PA 19 103 

Counsel for David Forrest 

John D. Gordan, IIII 

Eugene F. Bannigan 

John N. Thomas 

10 1 Park Avenue 

New York, NY 10 178 

Thomas M. Kittredge 

Kenneth L. Racowski 

170 1 Market Street 

Philadelphia, PA 19 103 

Counsel for Tarlo Lyons 

Nicholas M. Centrella, Esquire 

James J. Rohn, Esquire 

Kevin Dooley Kent, Esquire 

Conrad OYBrien Gellman & Rohn, PC 

1 5 1 5 Market Street, 1 6th Floor 

Philadelphia, PA 19 102 

Counsel for T. Beauclerc Rogers, IV

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Case 2:02-cv-04435-AB Document 127 Filed 01/27/2005 Page 7 of 8
Neil G. Epstein, Esquire 

Eckert Seamans Cherin & Mellott, LLC 

15 15 Market Street 

Ninth Floor 

Philadelphia, PA 19 102 

and 

Jeffrey D. Farrow, Esquire 

Mona Z. Hanna, Esquire 

Sanford Louis Michelman, Esquire 

Michelman & Robinson LLP 

4 Hutton Centre, Suite 300 

Santa h a , CA 92707 

Counsel for Martin Fink 

Respectfully submitted, 

BY: /s/ Conrad O. Kattner_____ 

CONRAD O. KATTNER, ESQ. 

Identification No: 035468 

MCSHEA & TECCE, P.C. 

1735 Market Street, 16th Floor 

Philadelphia, PA 19103 

 (215) 599-0800 

Attorney for Defendant, 

 Stanley Munson 

Date: ______January 27, 2005________ 

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