Case 1:16-cv-00654-CMH-TCB Document 14 Filed 10/05/16 Page 1 of 4 PageID# 73

RrCEiVFD

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

OCT - 5 20IR

ALEXANDRIA DIVISION
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JOHN BOAL PHOTOGRAPHY, LLC

Plaintiff,
V.

HANNOVER HOUSE, INC.,

ERIC PARKINSON, In his Individual capacity,

Civil No. l:l6-W-654

SPECIAL APPEARANCE
OBJECTING TO
JURISDICTION AND IN
THE ALTERNATIVE

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Defendants.

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Defendant Eric Parkinson hereby makes a special appearance and challenges the
personal and subject matter jurisdiction of this Court and in the alternative answers the

Complaint of Plaintiff John Boal Photography, LLC as follows:

1. Defendant has insufficient information or belief to allow Defendant to answer the

allegations of paragraph 1, and on that basisdenies each and everyallegation of

paragraph 1.

2. Defendant has insufficient information or belief to allow Defendant to answer the

allegations of paragraph 2, and on that basis denies eachand every allegation of

paragraph 2.

3.

Defendant has insufficient Information or belief to allow Defendant to answer the

allegations of paragraph 3, and onthat basis denies each and every allegation of
paragraph 3.

4. Defendant has insufficient Information or beliefto allow Defendant to answer the

allegations of paragraph 4, andonthat basis denies each and every allegation of

paragraph 4

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5. Answeringthe allegations of Paragraph of Plaintiffs Complaint, Defendant denies

DefendantHannover House, Inc. is an Arkansas corporation,specifically alleges that
Hannover House, Inc. is a corporation in good standing under the laws of Wyoming,
admits Defendant Hannover House's principal place of business is at 1428 Chester
Street, Springdale, Arkansas 72764 and that Hannover operates such business as
alleged, includingthe release of The Algerian. As Hannover House, Inc. is not an
Arkansas corporation, but a Wyoming corporation. Defendant denies each and every
allegation of paragraph 5.

6. Defendant denies each and every allegation of Paragraph6.

7. Defendant has insufficient information or belief to allow Defendant to answer the

allegations of paragraph 7, and on that basisdenies each and every allegation of

paragraph 7.
8. Defendant has insufficient information or belief to allow Defendant to answer the

allegations of paragraph 8, and on that basis denies each and every allegation of
paragraph 8. Defendant specifically denies there is any copyright issue involved in
this matter or that this Court has subject matter jurisdiction over Plaint'ifTs alleged
breach of contract as the contract was not entered into in Virginia and non of the
alleged acts occurred in Virginia.
9. Defendant denies each and every allegation of paragraph 9 and specifically denies
this Court has personal jurisdiction over Defendant and specifically denies that
either Hannover or Parkinson transacted any business within the Commonwealth.

10. Defendant denies each and every allegation of Paragraph 10.

11. Defendant admits the allegations of paragraph 11.

12. Defendant admits the allegations of paragraph 12.

13. Defendant admits the allegations of paragraph 13.

14. Defendant admits the allegations of paragraph 14.
15. Defendant admits the allegations of paragraph 15.

16. Defendant admits the allegations of paragraph 16.

17. Defendant admits the allegations of paragraph 17.
18. Defendant admits the allegations of paragraph 18.

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19. Defendantadmitsthe allegations of paragraph 19.

20. Defendant admits the allegations of paragraph 20.

21. Defendant admits the allegationsof paragraph 21.

22. Defendant hereby incorporates its answers to the allegations of paragraphs 1

through 21, inclusiveas though fully set forth herein.

23. Defendant admits the allegation of paragraph 23.

24. Answering the allegations of Paragraph 24, Defendant admits Plaintiff provided
photography services to andforthe producers ofthe film the Algerian and that
Plaintiff invoiced Hannover House. Except as specifically admitted. Defendant
denies each and every allegation of Paragraph 24.

25. Defendantadmitsthe allegations of Plaintiff in paragraph 25 as to Defendant

Hannover House, Inc., and except as specifically admitted, denies each and every
allegation of Paragraph 25. Defendant specifically alleges that with PlaintifPs
knowledge and agreement. Defendant Hannover House, inc. published the
photographs on its blog site, which blog citesincludes a copyright inthe name of
Defendant.

26. Defendantadmitsthe allegations of Paragraph 26.

27. Defendant denieseach and every allegation of Paragraph 27.

28. Defendant admits the allegation of Paragraph 28.
29. Answering the allegations of Paragraph 29, Defendant alleges that Hannover House,
Inc. is a Wyoming corporation in good standing. Is not an Arkansas corporation, and

except as specifically alleged. Defendant denies each and every allegationof

paragraph 29.

30. Defendant herebyincorporates its answers to the allegations of paragraphs 1

through 29, inclusiveas though fullyset forth herein.

31. Defendantdenies each and every allegation of Paragraph 31.

32. Defendantdenies each and everyallegation of paragraph32.
33. Defendant denies each and every allegation of paragraph 33.

34. Defendant denieseach and everyallegation of paragraph 34.

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35. Answeringthe allegations of Paragraph 35, Defendant alleges that Hannover House,
Inc. is a Wyomingcorporation in good standing, is not an Arkansas corporation, and
except as specifically alleged. Defendant denies each and every allegation of
paragraph 35.

WHEREFORE, Defendant prays:

A. Plaintiff take nothing by his Complaint.
B. For costs of suit and attorney's fees,

C. Forsuch other relief as the Court deems just and proper.

Dated: October 4,2016

Springdale^ashington County, Arkansas

Eric Parkinson

1428 Chester

Springdale, Arkansas 72764

479-751-4500

eric@hannoverhouse.com
Defendant