----- Original Message -----

From: Bob Colvin

To: GEET-Paul-Pantone-Problems@yahoogroups.com

Sent: Thursday, February 15, 2001 12:54

Subject: [GEET-Paul-Pantone-Problems] Bashers

Lessons for company bashing;

Lesson 1: Remember, BASHERS NEVER Bash A BAD Person or Company.
Check the websites for People or companies with no potential. They never
have
any Bashers. Bashers only go after People or companies that are moving up or
have excellent potential to do so. Bashers work to bring the person or
company values down to either increase their position at the expense of
others or help others to steal the identity or company.  Sometimes they bash
because they are jealous of the other persons success.

(Bottom of GEET.com website)




To unsubscribe from this group, send an email to:
GEET-Paul-Pantone-Problems-unsubscribe@yahoogroups.com

----- Original Message -----

From: Del Christensen

To: GEET-Paul-Pantone-Problems@yahoogroups.com

Sent: Monday, February 19, 2001 19:51

Subject: Re: [GEET-Paul-Pantone-Problems] Re: Blaming the Victims

First of all I don't consider myself a victim, & as  all ready stated I take
the responsibility for all my actions. But to ask what good has come from
all this-- one hell of a lot. I have gather to gether some very wonderful
people with the same hope & dreams as me.   We don't live in your world, we
see a world that has been damaged by people who demand to live in the real
world. We are sad at what happens when people in the real world need  some
comfort, some larger happiness, something that tears the real world apart.
Now if you insist on living in your real world be my guess, it is your
right. My group will be here every day 12-16 hours in our world doing
something to make your world better. And if you are saying what have you
done??? Just look at the web site at EPRLLC.org. and again as always thanks
for your time  Del

First of all I don't consider myself a victim, & as  all ready stated I take
the responsibility for all my actions. But to ask what good has come from
all this-- one hell of a lot. I have gather to gether some very wonderful
people with the same hope & dreams as me.   We don't live in your world, we
see a world that has been damaged by people who demand to live in the real
world. We are sad at what happens when people in the real world need  some
comfort, some larger happiness, something that tears the real world apart.
Now if you insist on living in your real world be my guess, it is your
right. My group will be here every day 12-16 hours in our world doing
something to make your world better. And if you are saying what have you
done??? Just look at the web site at EPRLLC.org. and again as always thanks
for your time  Del
----- Original Message -----
From: <octogonzo@...>
To: <GEET-Paul-Pantone-Problems@yahoogroups.com>
Sent: Monday, February 19, 2001 6:01 PM
Subject: [GEET-Paul-Pantone-Problems] Re: Blaming the Victims


> --- In GEET-Paul-Pantone-Problems@y..., "Bob Dierking"
> <bdierking@y...> wrote:
> > Hi Del and all...
> >
> > I just got back from a few days out of town on family business, and
> found this group alive! I'm thrilled. Actually, this is my "bulk
> mail" address, so I don't check it too often. I'll share some
> thoughts I've had about this whole situation:
> >
> > One of the saddest phenomena in our culture today is that we tend
> to blame the victim of criminals, and pity the criminals in the same
> breath.
>      What's really weird is how people turn victims into heroes. I'm
> not saying that applies to this situation, but that's another weird
> thing that happens.
>
> Furthermore, we try to make the victim feel responsible for the
> criminal having the opportunity to take advantage of us.
>
> > "She dresses provocatively. No wonder she was raped." "They left
> their garage door open. No wonder somebody pulled in with a truck and
> emptied the house." "She talks back to him. No wonder he beats
> her." "He extended credit. No wonder he went out of business."
>     Credit cards have credit limits. They don't go out of business.
> >
> > The issue is not whether or not we make choices that allow us to be
> victimized. In my opionion, a woman should be able to dress anyway
> she pleases without worrying that some sick individual will rape her;
>
>     The woman didn't rape herself. Paul Pantone, as far as I've
> heard, doesn't break into houses. A victim is someone who is
> victimized by someone else, not someone victimized by him/herself.
>
> we should be able to leave our doors open without a predator taking
> our every possession. Women should be able to speak with confidence
>     We should, but we can't yet. We live in a world mixed with good
> and bad. Faith/hope is a general principal, not an action plan. This
> may sound pessimistic, but it's not. It's realistic. We live in a
> real world. There are challenges in this world. If nothing were wrong
> with the world, there would be nothing to do and we'd all get sick of
> it.
>
> to their mates, to share their opinions and be full partners without
> being beaten.
>    Likewise, she didn't beat herself.
>
> In business, we should be able to extend credit with a reasonable
> expectation of getting what is promised us -- and thus be able to pay
> our own bills.
>     Justice is the function of the government in our imperfect
> society. In the future we will move in the direction of more perfect
> capitalism and anarchism, reducing the need for government. This
> trend has already started. Perhaps Mr. Christensen will get his money
> back with interest, and I hope he does. But nobody made him lay it
> all down next to the roulette wheel.
> >
> > The fact is that victims are easy marks simply because they are
> people who believe in the innate goodness of humanity. They are
>     The problem is that many people don't take life seriously. They
> have no faith in anything. We're all gonna die, and we'll all be
> forgotten. Therefore our actions have no real consequences. Life only
> matters if we pretend it does, either through religion or through
> some type of philosophy. I pretend that life does matter. It's the
> only way to make it exciting.
>
> people who truly give a damn about others and the world. They are
> people who choose to seek out goodness. As many words of faith say,
> they believe that they will find what they seek, and thus do not look
> for ill in others.
> >
> > Thank God for these victims; for these people who have erred on the
> side of faith. They give me hope that, if enough good people come
> together and set aside the divergencies of their faith and center
> upon the common and our desire to create a better world, we will
> eventually overcome the anger, hate, crime and evil that walks in
> this world.
> >
> > Paul and Molley took advantage of us all. It wasn't because we are
> weak nor stupid. He took advantage of us because we are people of
> great love; most of us profess some level of spirituality in our
> respective faiths. To a one, all of us believe in making this a
> better world.
>     Yeah. I've fallen for a lot of hoaxes. Some people hope for a
> better world. I do. But you've got to be realistic in your hope. A
> better world is achieved by working in the real one, not by
> pretending you've already arrived.
> >
> > Let's stop pointing fingers at one-another, and realize that Paul
> Pantone took advantage of what is our best quality to his own selfish
> ideals.
>      I agree.
> Let's stop blaming victims for the crimes. It is the very
> quality that allowed us to become victims that will, in time, make
> this world a better place.
>    Hoping for a better world without trying to create it is like
> hoping you'll get a bicycle for Christmas without telling your
> parents or Santa at the mall. You've got to work at it. I fail to see
> how losing thousands of dollars makes the world a better place. What
> was accomplished? After the first few thousand, yes, that exposed
> Pantone's greed. But after a while it no longer serves a purpose.
>
>
> >
> > Be well! I'll check in now and again.
> >
> > Bob Dierking
> >
> > ----- Original Message -----
> >   From: Del Christensen
> >   To: GEET-Paul-Pantone-Problems@y...
> >   Sent: Tuesday, February 20, 2001 01:44
> >   Subject: Re: [GEET-Paul-Pantone-Problems] Re: EPRLLC.org
> Countersuit to GEET
> >
> >
> >   Hey all & for you new ones that have just joined. I never started
> this fight with Paul P, but sense he wants it then lets give the guy
> what he wants.
> >
> >   I understand that I haven't always done everything the right way.
> Looking back I am ashamed of myself. I have said that before & still
> believe it now.
> >
> >   I don't want anyone to feel sorry for me, or help me get out of
> my financial problems, they are all mine, as I was told when growing
> up, you made it now sleep in it.
> >
> >   But I would love to stop Paul if possible? So any help in that
> direction will be greatly appreciated. And if I have, or can help in
> anyway to stop Paul please let me know.
> >
> >   Del Christensen e-mail  Del@ erpllc.org  or Ph# (801) 973-4391
> cell # (801) 243-2964   thanks for your time;
> >     ----- Original Message -----
> >     From: octogonzo@h...
> >     To: GEET-Paul-Pantone-Problems@y...
> >     Sent: Monday, February 19, 2001 1:47 AM
> >     Subject: [GEET-Paul-Pantone-Problems] Re: EPRLLC.org
> Countersuit to GEET
> >
> >
> >        WTF?!
> >
> >     I find it rather difficult to see Pantone as a villain because
> of his
> >     sheer stupidity. But this Mr. Christensen takes the cake! I
> find it
> >     impossible to find Mr. Christensen as the good guy in this out
> of his
> >     even greater stupidity. Lending money to someone who already
> owes you
> >     money is something you Just Don't Do. And gambling one's money
> on a
> >     technology sight unseen is similarly dumb. You guys belong on
> Judge Judy.
>
>
> To unsubscribe from this group, send an email to:
> GEET-Paul-Pantone-Problems-unsubscribe@yahoogroups.com
>
>
>

--- In GEET-Paul-Pantone-Problems@y..., "Bob Dierking"
<bdierking@y...> wrote:
> Hi Del and all...
>
> I just got back from a few days out of town on family business, and
found this group alive! I'm thrilled. Actually, this is my "bulk
mail" address, so I don't check it too often. I'll share some
thoughts I've had about this whole situation:
>
> One of the saddest phenomena in our culture today is that we tend
to blame the victim of criminals, and pity the criminals in the same
breath.
      What's really weird is how people turn victims into heroes. I'm
not saying that applies to this situation, but that's another weird
thing that happens.

Furthermore, we try to make the victim feel responsible for the
criminal having the opportunity to take advantage of us.

> "She dresses provocatively. No wonder she was raped." "They left
their garage door open. No wonder somebody pulled in with a truck and
emptied the house." "She talks back to him. No wonder he beats
her." "He extended credit. No wonder he went out of business."
     Credit cards have credit limits. They don't go out of business.
>
> The issue is not whether or not we make choices that allow us to be
victimized. In my opionion, a woman should be able to dress anyway
she pleases without worrying that some sick individual will rape her;

     The woman didn't rape herself. Paul Pantone, as far as I've
heard, doesn't break into houses. A victim is someone who is
victimized by someone else, not someone victimized by him/herself.

we should be able to leave our doors open without a predator taking
our every possession. Women should be able to speak with confidence
     We should, but we can't yet. We live in a world mixed with good
and bad. Faith/hope is a general principal, not an action plan. This
may sound pessimistic, but it's not. It's realistic. We live in a
real world. There are challenges in this world. If nothing were wrong
with the world, there would be nothing to do and we'd all get sick of
it.

to their mates, to share their opinions and be full partners without
being beaten.
    Likewise, she didn't beat herself.

In business, we should be able to extend credit with a reasonable
expectation of getting what is promised us -- and thus be able to pay
our own bills.
     Justice is the function of the government in our imperfect
society. In the future we will move in the direction of more perfect
capitalism and anarchism, reducing the need for government. This
trend has already started. Perhaps Mr. Christensen will get his money
back with interest, and I hope he does. But nobody made him lay it
all down next to the roulette wheel.
>
> The fact is that victims are easy marks simply because they are
people who believe in the innate goodness of humanity. They are
     The problem is that many people don't take life seriously. They
have no faith in anything. We're all gonna die, and we'll all be
forgotten. Therefore our actions have no real consequences. Life only
matters if we pretend it does, either through religion or through
some type of philosophy. I pretend that life does matter. It's the
only way to make it exciting.

people who truly give a damn about others and the world. They are
people who choose to seek out goodness. As many words of faith say,
they believe that they will find what they seek, and thus do not look
for ill in others.
>
> Thank God for these victims; for these people who have erred on the
side of faith. They give me hope that, if enough good people come
together and set aside the divergencies of their faith and center
upon the common and our desire to create a better world, we will
eventually overcome the anger, hate, crime and evil that walks in
this world.
>
> Paul and Molley took advantage of us all. It wasn't because we are
weak nor stupid. He took advantage of us because we are people of
great love; most of us profess some level of spirituality in our
respective faiths. To a one, all of us believe in making this a
better world.
     Yeah. I've fallen for a lot of hoaxes. Some people hope for a
better world. I do. But you've got to be realistic in your hope. A
better world is achieved by working in the real one, not by
pretending you've already arrived.
>
> Let's stop pointing fingers at one-another, and realize that Paul
Pantone took advantage of what is our best quality to his own selfish
ideals.
      I agree.
Let's stop blaming victims for the crimes. It is the very
quality that allowed us to become victims that will, in time, make
this world a better place.
    Hoping for a better world without trying to create it is like
hoping you'll get a bicycle for Christmas without telling your
parents or Santa at the mall. You've got to work at it. I fail to see
how losing thousands of dollars makes the world a better place. What
was accomplished? After the first few thousand, yes, that exposed
Pantone's greed. But after a while it no longer serves a purpose.


>
> Be well! I'll check in now and again.
>
> Bob Dierking
>
> ----- Original Message -----
>   From: Del Christensen
>   To: GEET-Paul-Pantone-Problems@y...
>   Sent: Tuesday, February 20, 2001 01:44
>   Subject: Re: [GEET-Paul-Pantone-Problems] Re: EPRLLC.org
Countersuit to GEET
>
>
>   Hey all & for you new ones that have just joined. I never started
this fight with Paul P, but sense he wants it then lets give the guy
what he wants.
>
>   I understand that I haven't always done everything the right way.
Looking back I am ashamed of myself. I have said that before & still
believe it now.
>
>   I don't want anyone to feel sorry for me, or help me get out of
my financial problems, they are all mine, as I was told when growing
up, you made it now sleep in it.
>
>   But I would love to stop Paul if possible? So any help in that
direction will be greatly appreciated. And if I have, or can help in
anyway to stop Paul please let me know.
>
>   Del Christensen e-mail  Del@ erpllc.org  or Ph# (801) 973-4391
cell # (801) 243-2964   thanks for your time;
>     ----- Original Message -----
>     From: octogonzo@h...
>     To: GEET-Paul-Pantone-Problems@y...
>     Sent: Monday, February 19, 2001 1:47 AM
>     Subject: [GEET-Paul-Pantone-Problems] Re: EPRLLC.org
Countersuit to GEET
>
>
>        WTF?!
>
>     I find it rather difficult to see Pantone as a villain because
of his
>     sheer stupidity. But this Mr. Christensen takes the cake! I
find it
>     impossible to find Mr. Christensen as the good guy in this out
of his
>     even greater stupidity. Lending money to someone who already
owes you
>     money is something you Just Don't Do. And gambling one's money
on a
>     technology sight unseen is similarly dumb. You guys belong on
Judge Judy.

Sorry if that was a little harsh. I wrote that at 4 am. I see
that your attitude, if not your business sense, is superior to
Pantone's. I agree; Pantone must be stopped. If this technology is
real, he's a menace to progress. If not, he's a con man. I think if
revenge is accomplished, it should involve developing the geet
technology for the good of mankind.
      Does anyone in this newsgroup have evidence that geet really
works? If so, is there some way of developing the technology despite
his patent? Like in other countries? Mexico City isn't all that far
away, and has smog thick enough to use as fuel. :)



--- In GEET-Paul-Pantone-Problems@y..., "Del Christensen"
<mercec@p...> wrote:
> Hey all & for you new ones that have just joined. I never started
this fight with Paul P, but sense he wants it then lets give the guy
what he wants.
>
> I understand that I haven't always done everything the right way.
Looking back I am ashamed of myself. I have said that before & still
believe it now.
>
> I don't want anyone to feel sorry for me, or help me get out of my
financial problems, they are all mine, as I was told when growing up,
you made it now sleep in it.
>
> But I would love to stop Paul if possible? So any help in that
direction will be greatly appreciated. And if I have, or can help in
anyway to stop Paul please let me know.
>
> Del Christensen e-mail  Del@ erpllc.org  or Ph# (801) 973-4391 cell
# (801) 243-2964   thanks for your time;
>   ----- Original Message -----
>   From: octogonzo@h...
>   To: GEET-Paul-Pantone-Problems@y...
>   Sent: Monday, February 19, 2001 1:47 AM
>   Subject: [GEET-Paul-Pantone-Problems] Re: EPRLLC.org Countersuit
to GEET
>
>
>      WTF?!
>
>   I find it rather difficult to see Pantone as a villain because of
his
>   sheer stupidity. But this Mr. Christensen takes the cake! I find
it
>   impossible to find Mr. Christensen as the good guy in this out of
his
>   even greater stupidity. Lending money to someone who already owes
you
>   money is something you Just Don't Do. And gambling one's money on
a
>   technology sight unseen is similarly dumb. You guys belong on
Judge Judy.

From: Del Christensen

To: GEET-Paul-Pantone-Problems@yahoogroups.com

Sent: Tuesday, February 20, 2001 01:44

Subject: Re: [GEET-Paul-Pantone-Problems] Re: EPRLLC.org Countersuit to GEET

Hey all & for you new ones that have just joined. I never started this fight with Paul P, but sense he wants it then lets give the guy what he wants.

 

I understand that I haven't always done everything the right way. Looking back I am ashamed of myself. I have said that before & still believe it now.

 

I don't want anyone to feel sorry for me, or help me get out of my financial problems, they are all mine, as I was told when growing up, you made it now sleep in it.

 

But I would love to stop Paul if possible? So any help in that direction will be greatly appreciated. And if I have, or can help in anyway to stop Paul please let me know.

 

Del Christensen e-mail  Del@ erpllc.org  or Ph# (801) 973-4391 cell # (801) 243-2964   thanks for your time;

----- Original Message -----

From: octogonzo@...

To: GEET-Paul-Pantone-Problems@yahoogroups.com

Sent: Monday, February 19, 2001 1:47 AM

Subject: [GEET-Paul-Pantone-Problems] Re: EPRLLC.org Countersuit to GEET

   WTF?!

I find it rather difficult to see Pantone as a villain because of his
sheer stupidity. But this Mr. Christensen takes the cake! I find it
impossible to find Mr. Christensen as the good guy in this out of his
even greater stupidity. Lending money to someone who already owes you
money is something you Just Don't Do. And gambling one's money on a
technology sight unseen is similarly dumb. You guys belong on Judge Judy.



--- In GEET-Paul-Pantone-Problems@y..., "Bob Colvin" <bps@f...> wrote:
> M. Del Christensen
> 3270 South 1100 West # 400
> Salt Lake City, Utah 84119
> Tele: (801) 973-4391
>
> In Propria Persona
>
>
>  IN THE UNITED STATES DISTRICT COURT
> FOR THE STATE OF UTAH
> CENTRAL DIVISION
>
_____________________________________________________________________________________
> )
> GEET INTERNATIONAL INC., a Nevada )
> Corporation, PAUL PANTONE, an              ) DEFENDANT M. DEL
> individual, MOLLEY PANTONE, an            ) CHRISTENSEN ANSWER
> individual,                                                     ) TO
PLAINTIFF'S COMPLAINT
> Plaintiffs )
>                        ) CASE NO: 2:01CV0014 B
> vs.                                                               
)    
> ) Judge Benson
> M. DEL CHRISTENSEN, an individual,       )
> PAUL  NOBEL, an individual, KERRY        )
>  MCMULLAN an individual, MICHELLE    )MCMULLAN, an individual, JASON
KIM )
> an individual, STEVEN L. MITCHELL, an  )
> individual, D.L. HOLDER, an individual, AL )
> AL TOTH, an individual, BOB COLVIN, an)    
> individual, G.E.E.T. of UTAH LLC, a Utah  )
> Limited Liability Company, GEET OF  )
> MARYLAND, a Maryland Corporation,  )
> GEET OF COLORADO, a Colorado   )
> Corporation, JAY MCMULLAN, an  )
> individual, TOM BERRY, an individual,  )
> WENDY COLLARD, an individual, and  )
> GEET INTERNATIONAL INSTITUTE  a )
> dba of GEET of Utah, LLC )
> )
> Defendants )
>
__________________________________________________________________________
> )
> M. DEL CHRISTENSEN, an individual        ) COUNTER-COMPLAINT
> )
> Cross-complainant )
> vs. )
> )
> PAUL PANTONE, an individual, MOLLEY )
> PANTONE, an individual, G.E.E.T.  )
> INTERNATIONAL, INC., a Nevada  )
> Corporation, GEET BUSINESS TRUST,  )
> PAUL PANTONE TRUST, PANTONE )
> FAMILY TRUST, and DOES I through X )
> inclusive, )
> )
> Cross-defendants )
>
__________________________________________________________________________
>
> Comes now defendant M. Del Christensen (defendant), on his own
behalf and answers plaintiffs' complaint as follows:
> PARTIES, JURISDICTION AND VENUE
> 1.  Defendant admits the allegations set forth in paragraphs 3, 19,
20 and 21 of plaintiff's complaint.
> 2.  Due to a lack of sufficient information defendant denies the
allegations set forth 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15,
and 16 of plaintiff's complaint.
> 3.  As to the allegations set forth in paragraph 17 of plaintiff
complaint, defendant admits that GEET of Utah LLC has its principle
place of business in Salt Lake City, and is a registered limited
liability company in Utah.  Defendant denies all other allegations set
forth in this paragraph.
> 4. As to the allegations set forth in paragraph 18 of plaintiff
complaint, defendant admits that GEET international Institute had its
principle place of business in Salt Lake City.  Defendant denies all
other allegations set forth in this paragraph.
> //
> GENERAL ALLEGATIONS
> 5.   Defendant admits the allegations set forth in paragraphs 25,
31, 38, 43, 51, 65, and 67 of plaintiff's complaint.
> 6.  Due to a lack of sufficient information defendant denies the
allegations set forth 23, 24, 26, 27, 28, 34, 47, 58 and 72 of
plaintiff's complaint.
> 7.  Defendants deny the allegations set forth in paragraphs 22, 29,
30, 32, 33, 35, 36, 37, 39, 40, 41, 42, 44, 45, 46, 48, 49, 50, 52,
53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 66, 68, 69, 70, 71,
73, 74, 75, and 76 of plaintiff's complaint.
> FIRST CAUSE OF ACTION
> 8.  Defendant incorporates by reference paragraphs 1 through 7 of
his Answer as if set forth in full herein.
> 9.  Due to a lack of sufficient information, defendant denies the
allegations set forth in paragraphs 77, 78, and 79 of plaintiff's
complaint.
> 10.  Defendant denies the allegations set forth in paragraphs 80,
81, 82, 83, 84 and 85 of plaintiff's complaint.
> SECOND CAUSE OF ACTION
> 11.  Defendant incorporates by reference paragraphs 1 through 10 of
his Answer as if set forth in full herein.
> 12.  Defendant denies the allegations set forth in paragraphs 86,
87, 88, 89, 90, 91, and 92 of plaintiff's complaint.
> THIRD CAUSE OF ACTION
> 11.  Defendant incorporates by reference paragraphs 1 through 12 of
his Answer as if set forth in full herein.
> 13.  Defendant denies the allegations set forth in paragraphs 93,
94, 95, 96, 97, and 98 of
>
> plaintiff's complaint.
>
> FOURTH CAUSE OF ACTION
> 14.  Defendant incorporates by reference paragraphs 1 through 13 of
his Answer as if set forth in full herein.
> 15.  Defendant denies the allegations set forth in paragraphs 99.
100, 101, 102, 103, 104, and  105 of plaintiff's complaint.
> FIFTH CAUSE OF ACTION
> 16.  Defendant incorporates by reference paragraphs 1 through 15 of
his Answer as if set forth in full herein.
> 17.  Defendant admits the allegations in paragraph 110, that he
currently possesses property belonging to plaintiff, defendant further
states that he has requested that plaintiff remove said property but
has failed to do so.
> 18.  Defendant denies the allegations set forth in paragraphs 106,
107, 108, 109, 111, and 112  of plaintiff's complaint.
> SIXTH CAUSE OF ACTION
> 19.  Defendant incorporates by reference paragraphs 1 through 18 of
his Answer as if set forth in full herein.
> 20.  Defendant denies the allegations set forth in paragraphs 113,
114, 115, 116, 117, 118, and 119 of plaintiff's complaint.
> SEVENTH CAUSE OF ACTION
> 21.  Defendant incorporates by reference paragraphs 1 through 20 of
his Answer as if set forth in full herein.
> 22.  Defendant denies the allegations set forth in paragraphs 120,
121, 122, and 123 of
>
> plaintiff's complaint.
> EIGHTH CAUSE OF ACTION
> 23.  Defendant incorporates by reference paragraphs 1 through 22 of
his Answer as if set forth in full herein.
> 24.  Defendant denies the allegations set forth in paragraphs 124,
125, 126, 127, 128, and 129 of plaintiff's complaint.
> NINTH CAUSE OF ACTION
> 25.  Defendant incorporates by reference paragraphs 1 through 24 of
his Answer as if set forth in full herein.
> 26.  Defendant denies the allegations set forth in paragraphs 130,
131, 132, 133, and 134 of plaintiff's complaint.
> TENTH CAUSE OF ACTION
> 27.  Defendant incorporates by reference paragraphs 1 through 26 of
his Answer as if set forth in full herein.
> 28.  Defendant denies the allegations set forth in paragraphs 135,
136, 137, 138, and 139 of plaintiff's complaint.
> ELEVENTH CAUSE OF ACTION
> 29.  Defendant incorporates by reference paragraphs 1 through 28 of
his Answer as if set forth in full herein.
> 30.  Defendant denies the allegations set forth in paragraphs 140,
141, 142, and 143 of plaintiff's complaint.
> TWELFTH CAUSE OF ACTION
> 31.  Defendant incorporates by reference paragraphs 1 through 30 of
his Answer as if set forth in full herein.
> 32.  Defendant denies the allegations set forth in paragraphs 144,
145, 146, 147, 148, 149, 150 and 151 of plaintiff's complaint.
> THIRTEENTH CAUSE OF ACTION
> 33.  Defendant incorporates by reference paragraphs 1 through 32 of
his Answer as if set forth in full herein.
> 34.  Defendant denies the allegations set forth in paragraphs 152,
153, 154 and 155 of plaintiff's complaint.
> FOURTEENTH CAUSE OF ACTION
> 35.  Defendant incorporates by reference paragraphs 1 through 34 of
his Answer as if set forth in full herein.
> 36.  Defendant denies the allegations set forth in paragraphs 157,
158 and 159 of plaintiff's complaint.
> THEREFORE this answering defendant prays for judgment as follows:
> 1. That plaintiffs receive nothing by way of their complaint,
> 2. For cost of suit herein;
> //
> 3. For such other and further relief as the Court may deem proper.
>
> Dated: February  ____, 2001                      
______________________________
> M. Del Christensen
>
> FIRST AFFIRMATIVE DEFENSE
> As for a  FIRST SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, this answering defendant alleges that the alleged Causes of
Actions as set forth in plaintiffs' Complaint fail to state facts
sufficient to constitute any cause of action against this answering
defendant.
>      SECOND AFFIRMATIVE DEFENSE
> As a SECOND SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs  have failed to
mitigate their damages, if any have in fact been suffered.
>      THIRD AFFIRMATIVE DEFENSE
> As a THIRD SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to plaintiffs EIGHTH Cause of Action set forth therein,
this answering defendant alleges and avers that Truth is an absolute
defense.
> FOURTH AFFIRMATIVE DEFENSE
> As a FOURTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs  claims are
barred by the plaintiffs breaches of the covenant of good faith and
fair dealing.             
> FIFTH AFFIRMATIVE DEFENSE
> As a FIFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiff breached the
contract alleged within the complaint, and plaintiffs claims are
therefore barred.
> SIXTH AFFIRMATIVE DEFENSE
> As a SIXTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that to the extent plaintiffs
have any claims for damages, which claim is expressly denied,
defendant is entitled to an offset against plaintiff in the amount of
damages incurred by defendant as a result of plaintiffs' breaches of
duty, failure to perform as promised and other wrongful acts as set
forth in the Counter-claim herein.
> SEVENTH AFFIRMATIVE DEFENSE
> As a SEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs claims are
barred by the doctrine of unclean hands.
> EIGHTH AFFIRMATIVE DEFENSE
> As an EIGHTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs damages, if any,
were proximately caused by third parties over whom defendant had no
control, and defendant cannot be held liable for such damages.
> NINTH AFFIRMATIVE DEFENSE
> As a NINTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that defendant is entitled to
his reasonable attorney's fees and cost incurred herein because
plaintiff's claims against defendant were filed in bad faith, are
without merit.
> TENTH AFFIRMATIVE DEFENSE
> As a TENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs complaint is
barred in whole or in part by the negligent and/or other wrongful
conduct of plaintiff and/or its agents.
> ELEVENTH AFFIRMATIVE DEFENSE
> As an ELEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiff's damage, if any,
were proximately and solely caused by plaintiff.
> TWELFTH AFFIRMATIVE DEFENSE
> As a TWELFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs claim is barred
by the fact that plaintiff's patent is defective, as is defendants
alleged technology as plaintiffs are unable to produce an effective
devise that will produce the results as promised by plaintiffs.
> COUNTER CLAIM
> Cross-Complainant M. Del Christensen (Christensen), complains
against plaintiff and each of them as follows:
> BACKGROUND AND HISTORY
> 1. In October 1999, Christensen received information in regards to
the development of an energy saving technology, to which
cross-complainant investigated and met with cross-defendant Paul
Pantone (Pantone).  Christensen was allowed to observe some of the
devises created under the direction of Pantone at the then business
location for GEET Management LLC located in Salt Lake City, Utah.
> 2. Christensen expressed an interest in the technology, and Pantone
requested that Christensen prepare prototype "reaction chambers" based
on specifications provided by Pantone. Christensen
>  3.  Christensen quoted a price to prepare said prototypes for
$1,500.00, which amount was agreed to be acceptable by Pantone.
>  4.  Within 2 weeks of this agreement, on or about the end of
October, Christensen delivered 7 prototype reaction chambers, to
Pantone, which Pantone accepted as satisfactory.  Pantone was only
able to pay $1,000.00 but promised the remainder shortly.
>  5.  Pantone was satisfied with the product, so much so that Pantone
ordered an additional 500 of the units, to be at various sizes,
stating that Pantone needed these to sell at a show in Idaho that
Pantone was to attend. Pantone agreed to an estimated price of $14,000.00
>  6.  Within 5 weeks of receiving this order, and within the time
frame as required by Pantone, Christensen delivered the 500 units to
Pantone, and provided an invoice for $14,000.00.
>  7.  Pantone had some concerns over some of the units provided, so
Christensen had some of his employees of his make the necessary
revisions, and produced the units to Pantone's satisfaction.
>  8.  These prototypes were specially manufactured, to the
specifications provided by Pantone, and were not useable in any other
application except as to meet Pantone's purposes.
>  9.  Pantone did not have the storage facilities at his residence,
to store all units provided by Christensen.  Pantone took
approximately 230 of the units and requested that Christensen store
the remainder, until Pantone returned from the Idaho show.
>  10.  Pantone promised to pay for the production in full upon his
return from Idaho, claiming that he would be able to sell or take
orders at the show sufficient to pay for the manufactured units.
>  11.  Upon Pantone's return, Pantone explained that he was only able
to sell 4 or 5 of the units, and tried to return them to Christensen.
 Christensen had no use for the units, but offered to store them until
Pantone was able to sell them. 
>  12. Commencing in February, 2000, Pantone explained that his
company was undergoing some management changes, and that his wife
Molley had just left him, which made it difficult to concentrate on
his work. Pantone requested that Christensen have patience and
continue to work with Pantone, and that Christensen would be more then
compensated as soon as these problems were resolved.
>  13.  Pantone requested that Christensen continue to store the
reaction chambers all ready manufactured, but also requested other
product and asked that Christensen ship them to designated customers
as provided by Pantone. These products were to be shipped under the
GEET logo, and  Christensen would be paid upon receipt of funds.
>  14.  Christensen complied with Pantone's request, providing Pantone
with invoices for all product produced and shipped.
>  15.  Shortly thereafter Pantone moved his operations to Colorado to
attempt to reconcile with his wife.  Pantone requested that
Christensen continue to manufacture and ship product as ordered.
>  16.  Christensen produced and shipped approximately $50,000.00 in
product of which $15,000.00 has been received.
>  17.  In May of 2000, Christensen received a telephone call from
Pantone claiming that he was at the Exotic Research Conference being
held in Arizona. Pantone explained that the promoter of the conference
had disappeared and was not honoring his guarantee to make payment to
the Hotel causing Pantone and his group to be locked out of their
Hotel rooms and the Exhibit Hall.
>  18.  Pantone requested that Christensen let Pantone use his credit
card in order to get his belongings, and promised repayment within 3
days, and Christensen agreed.
>  19.  Pantone used Christensen's credit card, taking care of his
bill, to which Christensen agreed to, but then Pantone also used the
credit card to pay the bills of several others that were in the same
situation at the conference, but without the permission of Christensen.
>  20.  Pantone placed about $5,000.00 on the credit card, but has yet
to reimburse Christensen for that amount.
>  21.  During the summer of 2000, Christensen received a telephone
call from Pantone claiming that he was in jail again, in Colorado, for
violating a court order relating to domestic violence charges, and
that he needed assistance in posting the bail of $1,000.00.
>  22.  Pantone promised that if Christensen would post the bail it
would be paid back within 1 week.
>  23.  Christensen used one of his credit cards, and had the bail
posted, but has not been reimbursed.
>  24. A few weeks later, Christensen received another similar
telephone call, Pantone was again in jail, for violating a court order
and needed bail posted in the amount of $1,500.00, and would reimburse
Christensen as soon as possible.
>  25.  Christensen again posted bail, but has not been reimbursed.
>  26.  A few weeks after being arrested, Pantone again contacts
Christensen by way of telephone, and requests that Christensen assist
him to getting out of Colorado, as Pantone claimed he was allowed to
leave the state, but was afraid that the authorities were after him,
and needed to get away. Pantone promised to reimburse Christensen for
all costs incurred to get him out of Colorado.
>  27.  Christensen made the necessary arrangements, renting a moving
van, obtaining and paying the wages of two men to drive to Pantone's
location and return him to Salt Lake. Christensen incurred a cost in
excess of $2,000.00 which remains unpaid.
>  28.  Upon Pantone's return to Utah, Pantone approached Christensen
and offered Christensen the GEET distributorship for Utah as partial
compensation for Christensen's assistance.
>  29.  Christensen subsequently discovered that Pantone had all ready
sold the distributorship rights to Utah to 2 other individuals whose
distributorship rights were never taken away.
>  30.  When Pantone returned he approached Christensen and produced
information that Pantone had received requests from over 250
individuals that wanted training in the GEET technology, and that he
had several that were ready to start immediately, at a suggested
training price of $1,500.00.
>  31.  Pantone suggested that Christensen could run the school to be
called GEET International Institute, and that Christensen would be
reimbursed out of the tuition, so long as a portion would go to
Pantone.  The parties agreed to initially charge $1,200.00 as the tuition.
>  32.  Pantone stated that he had confirmation of 30 students, but
needed the school ready by August 7, 2000.
>  33. Christensen borrowed the funds necessary to obtain a suitable
place for the school, to obtain the necessary school supplies and have
the needed support staff in order to run the school. Christensen
incurred a debt of approximately $26,000.00 to have the school ready
by August 7, 2000 as demanded by Pantone.
>  34.  On August 7, 2000, no student showed up.
>  35.  Since that date, the GEET International Institute has had 12
students.
>  36.  Of these 12 students only 3 paid tuition, 8 of the remainder
were students that agreed to attend the school as a set off for monies
previously given to Pantone for product that was not received.
>  37. The school was shut down in December 2000, as there were no
students, no monies were raised to support the school, and the
promises of students did not materialize.
> 38.  As part of the instruction, it was the intent to demonstrate to
the students how the GEET technology worked.  Christensen on several
occasions requested that Pantone come to the school to implement the
technology on some of the engines there that would meet the claims as
made by Pantone.
> 39. A demo engine was provided, but did not burn all the fuel as
promised, likewise a genset was provided, but this was not able to run
at full power.
> 40. When asked to remedy the problem, Pantone explained that it had
been sabotaged by previous employees, and recommended that Christensen
make the repairs. 
> 41.  While at the school. Pantone made several purchases on behalf
of the school that were charged to Christensen.  These included
without limitation costs for parts and equipment, acquired under the
guise of testing the technology, but did not produce anything noteworthy.
> 42.  Christensen subsequently was introduced to other individuals
who were in the process of developing energy reduction processes that
were significantly different that that of Pantone, and appears to have
a future. Christensen is presently working with this group.   
> 43.  Christensen has since entered into a business relationship with
these other individuals, but has not made any development on the
ineffective GEET technology.
> FIRST CAUSE OF ACTION
> Breach of Contract - Reaction Chambers
> 44.  Christensen incorporates by this reference paragraphs 1 through
43 of this complaint as if set forth in full herein.
> 45.  In February 2000, Pantone contracted with Christensen for the
delivery of 500 specially made reaction chambers for $14,000.00.
>  46.  Christensen delivered said reaction chambers, and after making
some minor changes were approved and accepted by Pantone.
>  47.  Demand for payment on these reaction chambers has been made,
but defendants and each of them refuse to pay as agreed.
> 48. These reaction chambers have no value to Christensen, except as
scrap.
> 49. Christensen has been damaged in an amount in excess of $14,000.00.
> SECOND CAUSE OF ACTION
> Breach of Contract - Shipping
>  50.  Christensen incorporates by this reference paragraphs 1
through 50 of this complaint as if set forth in full herein
>  51.  In February and thereafter Pantone contracted with Christensen
to provide the shipping of GEET products.  Pantone agreed to reimburse
Christensen for all costs involved.
>  52.  Christensen incurred costs, including but not limited to
storage fees, supplies, outside labor, materials etc., in an amount in
excess of $50,000, or which $15,000.00 has been paid. 
>  53.  Christensen has made demand for payment of the remainder, but
such demand has not been met.
> 54.  Christensen has been damaged by way of this breach of contract
in an amount top be proven at time of trial.
> THIRD CAUSE OF ACTION
> Breach of Contract - Conference Loan
>
> 55.  Christensen incorporates by this reference paragraphs 1 through
54 of this complaint as if set forth in full herein.  
>  56.  In  May Pantone requested that Christensen loan Pantone
sufficient funds so that Pantone and other of the defendants would be
able to retrieve their belongings and finish the exhibit at the Exotic
Research Conference in Arizona.
> 57.  Christensen allowed Pantone to use Christensen's credit card
upon Pantone's promise to repay the amount needed within 3 days.
>  58.  Pantone charged approximately $ 5,000.00 on Christensen's
credit card.
>  59.  Christensen has demanded payment as agreed, but Pantone
continues to refuse to make payment.
>  60.  Christensen's credit card carries a monthly interest rate, and
Christensen has been damaged in an amount to be proven at time of trial.
> //
> //
>
> FOURTH CAUSE OF ACTION
> Breach of Contract - First Bail
>  61. Christensen incorporates by this reference paragraphs 1 through
60 of this complaint as if set forth in full herein.   
>  62.  In the summer of 2000, Pantone contacted Christensen and
requested a loan in the amount of $1,000.00 in order to bail Pantone
out of jail. Pantone promised payment within 2 weeks.
>  63.  Christensen made the arrangements and had $ 1,000.00 bail
posted on Pantone's account.
>  64.  Christensen has made demand for reimbursement for the
$1,000.00. but payment has not been received.
> 65. Christensen has been damaged in the amount of $1,000.
> FIFTH CAUSE OF ACTION
> Breach of Contract - Second Bail
>  66. Christensen incorporates by this reference paragraphs 1 through
65 of this complaint as if set forth in full herein.   
>  67.  In the summer of 2000, Pantone contacted Christensen and
requested a loan in the amount of $1,500.00 in order to bail Pantone
out of jail another time. Pantone promised payment as soon as he got out.
>  68.  Christensen made the arrangements and had $ 1,500.00 bail
posted on Pantone's account.
>  69.  Christensen has made demand for reimbursement for the
$1,500.00. but payment has not been received.
>  70.  Christensen has been damaged in the amount of $1,500.00.
> SIXTH CAUSE OF ACTION
> Breach of Contract - Loan for Utilities
>  71. Christensen incorporates by this reference paragraphs 1 through
70 of this complaint as if set forth in full herein.   
>  72.  During the summer of 2000, Christensen received a telephone
call from Pantone who stated that his utilities, telephone and
satellite usage was about to be cut-off because of non-payment.
>  73.  Pantone requested a loan for $1,600.00 which Pantone promised
to pay within 1 week.
>  74.  Based on Pantone's promise to pay, Christensen arranged to
have these bills paid for on behalf of Pantone.
>  75.  Christensen has made demand for reimbursement, but has not
received repayment for this loan.
> 76.  Christensen has been damaged in an amount to be shown at time
of trial, but ion excess of $1,600.00.
> SEVENTH CAUSE OF ACTION
> Breach of Contract - Moving Expense
>
>  77.  Christensen incorporates by this reference paragraphs 1
through 76 of this complaint as if set forth in full herein.   
>  78.  At the end of the summer of 2000, Pantone contacted
Christensen by telephone, stating that he needed to get out of
Colorado, and requested Christensen's financial assistance.
>  79.  Pantone represented that there was nothing requiring him to
remain, that he had cleared it with Teller County to be allowed to
leave, but needed his assistance.
>  80.  Christensen arranged to have a moving van rented, acquired
that services of 2 men to drive to Pantone's location, assist in
bringing Pantone's belongings back to Utah, and paid for food and gas
for the trip.
>  81.  Pantone promised to reimburse Christensen for all costs
incurred, which expenses were in excess of $2,000.00.
> 82.  Christensen has made demand for reimbursement of these
expenses, but has not been paid.
>  83.  Christensen has been damaged in the amount to be proven at
time of trial.
> EIGHTH CAUSE OF ACTION
> Fraud
>
>  84.  Christensen incorporates by this reference paragraphs 1
through 83 of this complaint as if set forth in full herein.   
>  85.  Pantone represented to Christensen that he had 250 students
that had confirmed their interest in being trained in GEET technology.
>  86.  Pantone requested that Christensen run the school and be
compensated through the tuition that was received.
>  87.  At the time Pantone made these representations Pantone knew
that he did not have 250 students that had confirmed their interest.
>  88.  Pantone also knew that Christensen would rely on Pantone's
representations and incur substantial debt in order to prepare the school.
> 89.Christensen did rely on Pantone's representations, to
Christensen's detriment, incurring substantial costs in excess of
$26,000.00.
>  90.  As a direct and proximate cause of Pantone's fraudulent
statement Christensen has been damaged in an amount to be proven at
time of trial.
> 91.  Pantone's and cross-defendants conduct was willful, malicious
and in reckless disregard of Christensen's rights.  Christensen is
there entitled to punitive damages in an amount to be proven at time
of trial.
> NINTH CAUSE OF ACTION
> Misrepresentation
>
>  92.  Christensen incorporates by this reference paragraphs 1
through 91 of this complaint as if set forth in full herein.   
>  93.  Pantone on several occasions described his technology as
effective and functioning.
> 94.  Pantone and the other defendants made several representations
as to the increased fuel efficiency and reduction in pollution.
> 95.  Representations were made by cross-defendants and each of them
that this technology was developed by Pantone, and that he was
experienced in its implementation.
>  96. Pantone intentionally and knowingly represented that the GEET
device was close to complete and ready for full-scale production.
>  97.  Pantone represented that the GEET device worked in many
applications when Pantone knew that these applications had not been
completed.
> 98.  Pantone made these representations, with the intent to induce
Christensen to rely on Pantone's assurances and invest funds to
Pantone's scheme, with the Pantone promise that the devise would, with
a minimal amount of effort, be ready for production.
>
>  99.  Pantone failed to inform Christensen of Pantone's lack of
knowledge of how to complete the device, and how Pantone required the
assistance of others to complete the process.
>  100. As a direct and proximate result of Pantone's
misrepresentation, Christensen did invest substantial time of funds to
Pantone's scheme.
>  101. As a direct and proximate result of Pantone's
misrepresentation, Christensen has been damaged in an amount to be
proven at time of trial.
> 102.  Pantone's conduct was willful, malicious, and in reckless
disregard of Christensen's rights.  Christensen is therefore entitled
to punitive damages in an amount to be proven at time of trial.
> PRAYER FOR RELIEF
>  WHEREFORE, Christensen demands judgment against plaintiffs and
cross-defendants as follows:
>  A.  Judgment in favor of Christensen in an amount to be proven at
time of trial on the First, Second, Third, Fourth Fifth, Sixth,
Seventh, Eighth and Ninth Causes of Action, together with interest at
the statutory rate.
>  B.  Punitive Damages in Christensen's Eighth and Ninth Causes of
Action, in an amount to be determined at trial, and
>  C.  Interest, reasonable attorney fees, and such other relief as
the Court deems appropriate
>  Dated: this ____ day of February, 2001.
>
>  _____________________________
>  M. Del Christensen
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>    CERTIFICATE OF SERVICE
> I hereby certify that I am a not a party to this action.  My
business address is:  3270 South 11 West, Building 400 salt Lake City,
Utah 84119 .  A true and correct copy of the above and foregoing:
>   ANSWER TO COMPLAINT AND CROSS-COMPLAINT
> was mailed via United States Mail, postage prepaid. to the following
at their address as shown below,
> Robert E. Mansfield
> Todd D. Weiler
> Parry, Anderson & Mansfield
> 1270 Eagle Gate Tower
> 60 East South Temple
> Salt Lake City, Utah 84111
>
>  this ___ of ______, 2001.
>
>
> _____________________________________


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----- Original Message -----

From: octogonzo@...

To: GEET-Paul-Pantone-Problems@yahoogroups.com

Sent: Monday, February 19, 2001 1:47 AM

Subject: [GEET-Paul-Pantone-Problems] Re: EPRLLC.org Countersuit to GEET

   WTF?!

I find it rather difficult to see Pantone as a villain because of his
sheer stupidity. But this Mr. Christensen takes the cake! I find it
impossible to find Mr. Christensen as the good guy in this out of his
even greater stupidity. Lending money to someone who already owes you
money is something you Just Don't Do. And gambling one's money on a
technology sight unseen is similarly dumb. You guys belong on Judge Judy.



--- In GEET-Paul-Pantone-Problems@y..., "Bob Colvin" <bps@f...> wrote:
> M. Del Christensen
> 3270 South 1100 West # 400
> Salt Lake City, Utah 84119
> Tele: (801) 973-4391
>
> In Propria Persona
>
>
>  IN THE UNITED STATES DISTRICT COURT
> FOR THE STATE OF UTAH
> CENTRAL DIVISION
>
_____________________________________________________________________________________
> )
> GEET INTERNATIONAL INC., a Nevada )
> Corporation, PAUL PANTONE, an              ) DEFENDANT M. DEL
> individual, MOLLEY PANTONE, an            ) CHRISTENSEN ANSWER
> individual,                                                     ) TO
PLAINTIFF'S COMPLAINT
> Plaintiffs )
>                        ) CASE NO: 2:01CV0014 B
> vs.                                                               
)    
> ) Judge Benson
> M. DEL CHRISTENSEN, an individual,       )
> PAUL  NOBEL, an individual, KERRY        )
>  MCMULLAN an individual, MICHELLE    )MCMULLAN, an individual, JASON
KIM )
> an individual, STEVEN L. MITCHELL, an  )
> individual, D.L. HOLDER, an individual, AL )
> AL TOTH, an individual, BOB COLVIN, an)    
> individual, G.E.E.T. of UTAH LLC, a Utah  )
> Limited Liability Company, GEET OF  )
> MARYLAND, a Maryland Corporation,  )
> GEET OF COLORADO, a Colorado   )
> Corporation, JAY MCMULLAN, an  )
> individual, TOM BERRY, an individual,  )
> WENDY COLLARD, an individual, and  )
> GEET INTERNATIONAL INSTITUTE  a )
> dba of GEET of Utah, LLC )
> )
> Defendants )
>
__________________________________________________________________________
> )
> M. DEL CHRISTENSEN, an individual        ) COUNTER-COMPLAINT
> )
> Cross-complainant )
> vs. )
> )
> PAUL PANTONE, an individual, MOLLEY )
> PANTONE, an individual, G.E.E.T.  )
> INTERNATIONAL, INC., a Nevada  )
> Corporation, GEET BUSINESS TRUST,  )
> PAUL PANTONE TRUST, PANTONE )
> FAMILY TRUST, and DOES I through X )
> inclusive, )
> )
> Cross-defendants )
>
__________________________________________________________________________
>
> Comes now defendant M. Del Christensen (defendant), on his own
behalf and answers plaintiffs' complaint as follows:
> PARTIES, JURISDICTION AND VENUE
> 1.  Defendant admits the allegations set forth in paragraphs 3, 19,
20 and 21 of plaintiff's complaint.
> 2.  Due to a lack of sufficient information defendant denies the
allegations set forth 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15,
and 16 of plaintiff's complaint.
> 3.  As to the allegations set forth in paragraph 17 of plaintiff
complaint, defendant admits that GEET of Utah LLC has its principle
place of business in Salt Lake City, and is a registered limited
liability company in Utah.  Defendant denies all other allegations set
forth in this paragraph.
> 4. As to the allegations set forth in paragraph 18 of plaintiff
complaint, defendant admits that GEET international Institute had its
principle place of business in Salt Lake City.  Defendant denies all
other allegations set forth in this paragraph.
> //
> GENERAL ALLEGATIONS
> 5.   Defendant admits the allegations set forth in paragraphs 25,
31, 38, 43, 51, 65, and 67 of plaintiff's complaint.
> 6.  Due to a lack of sufficient information defendant denies the
allegations set forth 23, 24, 26, 27, 28, 34, 47, 58 and 72 of
plaintiff's complaint.
> 7.  Defendants deny the allegations set forth in paragraphs 22, 29,
30, 32, 33, 35, 36, 37, 39, 40, 41, 42, 44, 45, 46, 48, 49, 50, 52,
53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 66, 68, 69, 70, 71,
73, 74, 75, and 76 of plaintiff's complaint.
> FIRST CAUSE OF ACTION
> 8.  Defendant incorporates by reference paragraphs 1 through 7 of
his Answer as if set forth in full herein.
> 9.  Due to a lack of sufficient information, defendant denies the
allegations set forth in paragraphs 77, 78, and 79 of plaintiff's
complaint.
> 10.  Defendant denies the allegations set forth in paragraphs 80,
81, 82, 83, 84 and 85 of plaintiff's complaint.
> SECOND CAUSE OF ACTION
> 11.  Defendant incorporates by reference paragraphs 1 through 10 of
his Answer as if set forth in full herein.
> 12.  Defendant denies the allegations set forth in paragraphs 86,
87, 88, 89, 90, 91, and 92 of plaintiff's complaint.
> THIRD CAUSE OF ACTION
> 11.  Defendant incorporates by reference paragraphs 1 through 12 of
his Answer as if set forth in full herein.
> 13.  Defendant denies the allegations set forth in paragraphs 93,
94, 95, 96, 97, and 98 of
>
> plaintiff's complaint.
>
> FOURTH CAUSE OF ACTION
> 14.  Defendant incorporates by reference paragraphs 1 through 13 of
his Answer as if set forth in full herein.
> 15.  Defendant denies the allegations set forth in paragraphs 99.
100, 101, 102, 103, 104, and  105 of plaintiff's complaint.
> FIFTH CAUSE OF ACTION
> 16.  Defendant incorporates by reference paragraphs 1 through 15 of
his Answer as if set forth in full herein.
> 17.  Defendant admits the allegations in paragraph 110, that he
currently possesses property belonging to plaintiff, defendant further
states that he has requested that plaintiff remove said property but
has failed to do so.
> 18.  Defendant denies the allegations set forth in paragraphs 106,
107, 108, 109, 111, and 112  of plaintiff's complaint.
> SIXTH CAUSE OF ACTION
> 19.  Defendant incorporates by reference paragraphs 1 through 18 of
his Answer as if set forth in full herein.
> 20.  Defendant denies the allegations set forth in paragraphs 113,
114, 115, 116, 117, 118, and 119 of plaintiff's complaint.
> SEVENTH CAUSE OF ACTION
> 21.  Defendant incorporates by reference paragraphs 1 through 20 of
his Answer as if set forth in full herein.
> 22.  Defendant denies the allegations set forth in paragraphs 120,
121, 122, and 123 of
>
> plaintiff's complaint.
> EIGHTH CAUSE OF ACTION
> 23.  Defendant incorporates by reference paragraphs 1 through 22 of
his Answer as if set forth in full herein.
> 24.  Defendant denies the allegations set forth in paragraphs 124,
125, 126, 127, 128, and 129 of plaintiff's complaint.
> NINTH CAUSE OF ACTION
> 25.  Defendant incorporates by reference paragraphs 1 through 24 of
his Answer as if set forth in full herein.
> 26.  Defendant denies the allegations set forth in paragraphs 130,
131, 132, 133, and 134 of plaintiff's complaint.
> TENTH CAUSE OF ACTION
> 27.  Defendant incorporates by reference paragraphs 1 through 26 of
his Answer as if set forth in full herein.
> 28.  Defendant denies the allegations set forth in paragraphs 135,
136, 137, 138, and 139 of plaintiff's complaint.
> ELEVENTH CAUSE OF ACTION
> 29.  Defendant incorporates by reference paragraphs 1 through 28 of
his Answer as if set forth in full herein.
> 30.  Defendant denies the allegations set forth in paragraphs 140,
141, 142, and 143 of plaintiff's complaint.
> TWELFTH CAUSE OF ACTION
> 31.  Defendant incorporates by reference paragraphs 1 through 30 of
his Answer as if set forth in full herein.
> 32.  Defendant denies the allegations set forth in paragraphs 144,
145, 146, 147, 148, 149, 150 and 151 of plaintiff's complaint.
> THIRTEENTH CAUSE OF ACTION
> 33.  Defendant incorporates by reference paragraphs 1 through 32 of
his Answer as if set forth in full herein.
> 34.  Defendant denies the allegations set forth in paragraphs 152,
153, 154 and 155 of plaintiff's complaint.
> FOURTEENTH CAUSE OF ACTION
> 35.  Defendant incorporates by reference paragraphs 1 through 34 of
his Answer as if set forth in full herein.
> 36.  Defendant denies the allegations set forth in paragraphs 157,
158 and 159 of plaintiff's complaint.
> THEREFORE this answering defendant prays for judgment as follows:
> 1. That plaintiffs receive nothing by way of their complaint,
> 2. For cost of suit herein;
> //
> 3. For such other and further relief as the Court may deem proper.
>
> Dated: February  ____, 2001                      
______________________________
> M. Del Christensen
>
> FIRST AFFIRMATIVE DEFENSE
> As for a  FIRST SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, this answering defendant alleges that the alleged Causes of
Actions as set forth in plaintiffs' Complaint fail to state facts
sufficient to constitute any cause of action against this answering
defendant.
>      SECOND AFFIRMATIVE DEFENSE
> As a SECOND SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs  have failed to
mitigate their damages, if any have in fact been suffered.
>      THIRD AFFIRMATIVE DEFENSE
> As a THIRD SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to plaintiffs EIGHTH Cause of Action set forth therein,
this answering defendant alleges and avers that Truth is an absolute
defense.
> FOURTH AFFIRMATIVE DEFENSE
> As a FOURTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs  claims are
barred by the plaintiffs breaches of the covenant of good faith and
fair dealing.             
> FIFTH AFFIRMATIVE DEFENSE
> As a FIFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiff breached the
contract alleged within the complaint, and plaintiffs claims are
therefore barred.
> SIXTH AFFIRMATIVE DEFENSE
> As a SIXTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that to the extent plaintiffs
have any claims for damages, which claim is expressly denied,
defendant is entitled to an offset against plaintiff in the amount of
damages incurred by defendant as a result of plaintiffs' breaches of
duty, failure to perform as promised and other wrongful acts as set
forth in the Counter-claim herein.
> SEVENTH AFFIRMATIVE DEFENSE
> As a SEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs claims are
barred by the doctrine of unclean hands.
> EIGHTH AFFIRMATIVE DEFENSE
> As an EIGHTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs damages, if any,
were proximately caused by third parties over whom defendant had no
control, and defendant cannot be held liable for such damages.
> NINTH AFFIRMATIVE DEFENSE
> As a NINTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that defendant is entitled to
his reasonable attorney's fees and cost incurred herein because
plaintiff's claims against defendant were filed in bad faith, are
without merit.
> TENTH AFFIRMATIVE DEFENSE
> As a TENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs complaint is
barred in whole or in part by the negligent and/or other wrongful
conduct of plaintiff and/or its agents.
> ELEVENTH AFFIRMATIVE DEFENSE
> As an ELEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiff's damage, if any,
were proximately and solely caused by plaintiff.
> TWELFTH AFFIRMATIVE DEFENSE
> As a TWELFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs claim is barred
by the fact that plaintiff's patent is defective, as is defendants
alleged technology as plaintiffs are unable to produce an effective
devise that will produce the results as promised by plaintiffs.
> COUNTER CLAIM
> Cross-Complainant M. Del Christensen (Christensen), complains
against plaintiff and each of them as follows:
> BACKGROUND AND HISTORY
> 1. In October 1999, Christensen received information in regards to
the development of an energy saving technology, to which
cross-complainant investigated and met with cross-defendant Paul
Pantone (Pantone).  Christensen was allowed to observe some of the
devises created under the direction of Pantone at the then business
location for GEET Management LLC located in Salt Lake City, Utah.
> 2. Christensen expressed an interest in the technology, and Pantone
requested that Christensen prepare prototype "reaction chambers" based
on specifications provided by Pantone. Christensen
>  3.  Christensen quoted a price to prepare said prototypes for
$1,500.00, which amount was agreed to be acceptable by Pantone.
>  4.  Within 2 weeks of this agreement, on or about the end of
October, Christensen delivered 7 prototype reaction chambers, to
Pantone, which Pantone accepted as satisfactory.  Pantone was only
able to pay $1,000.00 but promised the remainder shortly.
>  5.  Pantone was satisfied with the product, so much so that Pantone
ordered an additional 500 of the units, to be at various sizes,
stating that Pantone needed these to sell at a show in Idaho that
Pantone was to attend. Pantone agreed to an estimated price of $14,000.00
>  6.  Within 5 weeks of receiving this order, and within the time
frame as required by Pantone, Christensen delivered the 500 units to
Pantone, and provided an invoice for $14,000.00.
>  7.  Pantone had some concerns over some of the units provided, so
Christensen had some of his employees of his make the necessary
revisions, and produced the units to Pantone's satisfaction.
>  8.  These prototypes were specially manufactured, to the
specifications provided by Pantone, and were not useable in any other
application except as to meet Pantone's purposes.
>  9.  Pantone did not have the storage facilities at his residence,
to store all units provided by Christensen.  Pantone took
approximately 230 of the units and requested that Christensen store
the remainder, until Pantone returned from the Idaho show.
>  10.  Pantone promised to pay for the production in full upon his
return from Idaho, claiming that he would be able to sell or take
orders at the show sufficient to pay for the manufactured units.
>  11.  Upon Pantone's return, Pantone explained that he was only able
to sell 4 or 5 of the units, and tried to return them to Christensen.
 Christensen had no use for the units, but offered to store them until
Pantone was able to sell them. 
>  12. Commencing in February, 2000, Pantone explained that his
company was undergoing some management changes, and that his wife
Molley had just left him, which made it difficult to concentrate on
his work. Pantone requested that Christensen have patience and
continue to work with Pantone, and that Christensen would be more then
compensated as soon as these problems were resolved.
>  13.  Pantone requested that Christensen continue to store the
reaction chambers all ready manufactured, but also requested other
product and asked that Christensen ship them to designated customers
as provided by Pantone. These products were to be shipped under the
GEET logo, and  Christensen would be paid upon receipt of funds.
>  14.  Christensen complied with Pantone's request, providing Pantone
with invoices for all product produced and shipped.
>  15.  Shortly thereafter Pantone moved his operations to Colorado to
attempt to reconcile with his wife.  Pantone requested that
Christensen continue to manufacture and ship product as ordered.
>  16.  Christensen produced and shipped approximately $50,000.00 in
product of which $15,000.00 has been received.
>  17.  In May of 2000, Christensen received a telephone call from
Pantone claiming that he was at the Exotic Research Conference being
held in Arizona. Pantone explained that the promoter of the conference
had disappeared and was not honoring his guarantee to make payment to
the Hotel causing Pantone and his group to be locked out of their
Hotel rooms and the Exhibit Hall.
>  18.  Pantone requested that Christensen let Pantone use his credit
card in order to get his belongings, and promised repayment within 3
days, and Christensen agreed.
>  19.  Pantone used Christensen's credit card, taking care of his
bill, to which Christensen agreed to, but then Pantone also used the
credit card to pay the bills of several others that were in the same
situation at the conference, but without the permission of Christensen.
>  20.  Pantone placed about $5,000.00 on the credit card, but has yet
to reimburse Christensen for that amount.
>  21.  During the summer of 2000, Christensen received a telephone
call from Pantone claiming that he was in jail again, in Colorado, for
violating a court order relating to domestic violence charges, and
that he needed assistance in posting the bail of $1,000.00.
>  22.  Pantone promised that if Christensen would post the bail it
would be paid back within 1 week.
>  23.  Christensen used one of his credit cards, and had the bail
posted, but has not been reimbursed.
>  24. A few weeks later, Christensen received another similar
telephone call, Pantone was again in jail, for violating a court order
and needed bail posted in the amount of $1,500.00, and would reimburse
Christensen as soon as possible.
>  25.  Christensen again posted bail, but has not been reimbursed.
>  26.  A few weeks after being arrested, Pantone again contacts
Christensen by way of telephone, and requests that Christensen assist
him to getting out of Colorado, as Pantone claimed he was allowed to
leave the state, but was afraid that the authorities were after him,
and needed to get away. Pantone promised to reimburse Christensen for
all costs incurred to get him out of Colorado.
>  27.  Christensen made the necessary arrangements, renting a moving
van, obtaining and paying the wages of two men to drive to Pantone's
location and return him to Salt Lake. Christensen incurred a cost in
excess of $2,000.00 which remains unpaid.
>  28.  Upon Pantone's return to Utah, Pantone approached Christensen
and offered Christensen the GEET distributorship for Utah as partial
compensation for Christensen's assistance.
>  29.  Christensen subsequently discovered that Pantone had all ready
sold the distributorship rights to Utah to 2 other individuals whose
distributorship rights were never taken away.
>  30.  When Pantone returned he approached Christensen and produced
information that Pantone had received requests from over 250
individuals that wanted training in the GEET technology, and that he
had several that were ready to start immediately, at a suggested
training price of $1,500.00.
>  31.  Pantone suggested that Christensen could run the school to be
called GEET International Institute, and that Christensen would be
reimbursed out of the tuition, so long as a portion would go to
Pantone.  The parties agreed to initially charge $1,200.00 as the tuition.
>  32.  Pantone stated that he had confirmation of 30 students, but
needed the school ready by August 7, 2000.
>  33. Christensen borrowed the funds necessary to obtain a suitable
place for the school, to obtain the necessary school supplies and have
the needed support staff in order to run the school. Christensen
incurred a debt of approximately $26,000.00 to have the school ready
by August 7, 2000 as demanded by Pantone.
>  34.  On August 7, 2000, no student showed up.
>  35.  Since that date, the GEET International Institute has had 12
students.
>  36.  Of these 12 students only 3 paid tuition, 8 of the remainder
were students that agreed to attend the school as a set off for monies
previously given to Pantone for product that was not received.
>  37. The school was shut down in December 2000, as there were no
students, no monies were raised to support the school, and the
promises of students did not materialize.
> 38.  As part of the instruction, it was the intent to demonstrate to
the students how the GEET technology worked.  Christensen on several
occasions requested that Pantone come to the school to implement the
technology on some of the engines there that would meet the claims as
made by Pantone.
> 39. A demo engine was provided, but did not burn all the fuel as
promised, likewise a genset was provided, but this was not able to run
at full power.
> 40. When asked to remedy the problem, Pantone explained that it had
been sabotaged by previous employees, and recommended that Christensen
make the repairs. 
> 41.  While at the school. Pantone made several purchases on behalf
of the school that were charged to Christensen.  These included
without limitation costs for parts and equipment, acquired under the
guise of testing the technology, but did not produce anything noteworthy.
> 42.  Christensen subsequently was introduced to other individuals
who were in the process of developing energy reduction processes that
were significantly different that that of Pantone, and appears to have
a future. Christensen is presently working with this group.   
> 43.  Christensen has since entered into a business relationship with
these other individuals, but has not made any development on the
ineffective GEET technology.
> FIRST CAUSE OF ACTION
> Breach of Contract - Reaction Chambers
> 44.  Christensen incorporates by this reference paragraphs 1 through
43 of this complaint as if set forth in full herein.
> 45.  In February 2000, Pantone contracted with Christensen for the
delivery of 500 specially made reaction chambers for $14,000.00.
>  46.  Christensen delivered said reaction chambers, and after making
some minor changes were approved and accepted by Pantone.
>  47.  Demand for payment on these reaction chambers has been made,
but defendants and each of them refuse to pay as agreed.
> 48. These reaction chambers have no value to Christensen, except as
scrap.
> 49. Christensen has been damaged in an amount in excess of $14,000.00.
> SECOND CAUSE OF ACTION
> Breach of Contract - Shipping
>  50.  Christensen incorporates by this reference paragraphs 1
through 50 of this complaint as if set forth in full herein
>  51.  In February and thereafter Pantone contracted with Christensen
to provide the shipping of GEET products.  Pantone agreed to reimburse
Christensen for all costs involved.
>  52.  Christensen incurred costs, including but not limited to
storage fees, supplies, outside labor, materials etc., in an amount in
excess of $50,000, or which $15,000.00 has been paid. 
>  53.  Christensen has made demand for payment of the remainder, but
such demand has not been met.
> 54.  Christensen has been damaged by way of this breach of contract
in an amount top be proven at time of trial.
> THIRD CAUSE OF ACTION
> Breach of Contract - Conference Loan
>
> 55.  Christensen incorporates by this reference paragraphs 1 through
54 of this complaint as if set forth in full herein.  
>  56.  In  May Pantone requested that Christensen loan Pantone
sufficient funds so that Pantone and other of the defendants would be
able to retrieve their belongings and finish the exhibit at the Exotic
Research Conference in Arizona.
> 57.  Christensen allowed Pantone to use Christensen's credit card
upon Pantone's promise to repay the amount needed within 3 days.
>  58.  Pantone charged approximately $ 5,000.00 on Christensen's
credit card.
>  59.  Christensen has demanded payment as agreed, but Pantone
continues to refuse to make payment.
>  60.  Christensen's credit card carries a monthly interest rate, and
Christensen has been damaged in an amount to be proven at time of trial.
> //
> //
>
> FOURTH CAUSE OF ACTION
> Breach of Contract - First Bail
>  61. Christensen incorporates by this reference paragraphs 1 through
60 of this complaint as if set forth in full herein.   
>  62.  In the summer of 2000, Pantone contacted Christensen and
requested a loan in the amount of $1,000.00 in order to bail Pantone
out of jail. Pantone promised payment within 2 weeks.
>  63.  Christensen made the arrangements and had $ 1,000.00 bail
posted on Pantone's account.
>  64.  Christensen has made demand for reimbursement for the
$1,000.00. but payment has not been received.
> 65. Christensen has been damaged in the amount of $1,000.
> FIFTH CAUSE OF ACTION
> Breach of Contract - Second Bail
>  66. Christensen incorporates by this reference paragraphs 1 through
65 of this complaint as if set forth in full herein.   
>  67.  In the summer of 2000, Pantone contacted Christensen and
requested a loan in the amount of $1,500.00 in order to bail Pantone
out of jail another time. Pantone promised payment as soon as he got out.
>  68.  Christensen made the arrangements and had $ 1,500.00 bail
posted on Pantone's account.
>  69.  Christensen has made demand for reimbursement for the
$1,500.00. but payment has not been received.
>  70.  Christensen has been damaged in the amount of $1,500.00.
> SIXTH CAUSE OF ACTION
> Breach of Contract - Loan for Utilities
>  71. Christensen incorporates by this reference paragraphs 1 through
70 of this complaint as if set forth in full herein.   
>  72.  During the summer of 2000, Christensen received a telephone
call from Pantone who stated that his utilities, telephone and
satellite usage was about to be cut-off because of non-payment.
>  73.  Pantone requested a loan for $1,600.00 which Pantone promised
to pay within 1 week.
>  74.  Based on Pantone's promise to pay, Christensen arranged to
have these bills paid for on behalf of Pantone.
>  75.  Christensen has made demand for reimbursement, but has not
received repayment for this loan.
> 76.  Christensen has been damaged in an amount to be shown at time
of trial, but ion excess of $1,600.00.
> SEVENTH CAUSE OF ACTION
> Breach of Contract - Moving Expense
>
>  77.  Christensen incorporates by this reference paragraphs 1
through 76 of this complaint as if set forth in full herein.   
>  78.  At the end of the summer of 2000, Pantone contacted
Christensen by telephone, stating that he needed to get out of
Colorado, and requested Christensen's financial assistance.
>  79.  Pantone represented that there was nothing requiring him to
remain, that he had cleared it with Teller County to be allowed to
leave, but needed his assistance.
>  80.  Christensen arranged to have a moving van rented, acquired
that services of 2 men to drive to Pantone's location, assist in
bringing Pantone's belongings back to Utah, and paid for food and gas
for the trip.
>  81.  Pantone promised to reimburse Christensen for all costs
incurred, which expenses were in excess of $2,000.00.
> 82.  Christensen has made demand for reimbursement of these
expenses, but has not been paid.
>  83.  Christensen has been damaged in the amount to be proven at
time of trial.
> EIGHTH CAUSE OF ACTION
> Fraud
>
>  84.  Christensen incorporates by this reference paragraphs 1
through 83 of this complaint as if set forth in full herein.   
>  85.  Pantone represented to Christensen that he had 250 students
that had confirmed their interest in being trained in GEET technology.
>  86.  Pantone requested that Christensen run the school and be
compensated through the tuition that was received.
>  87.  At the time Pantone made these representations Pantone knew
that he did not have 250 students that had confirmed their interest.
>  88.  Pantone also knew that Christensen would rely on Pantone's
representations and incur substantial debt in order to prepare the school.
> 89.Christensen did rely on Pantone's representations, to
Christensen's detriment, incurring substantial costs in excess of
$26,000.00.
>  90.  As a direct and proximate cause of Pantone's fraudulent
statement Christensen has been damaged in an amount to be proven at
time of trial.
> 91.  Pantone's and cross-defendants conduct was willful, malicious
and in reckless disregard of Christensen's rights.  Christensen is
there entitled to punitive damages in an amount to be proven at time
of trial.
> NINTH CAUSE OF ACTION
> Misrepresentation
>
>  92.  Christensen incorporates by this reference paragraphs 1
through 91 of this complaint as if set forth in full herein.   
>  93.  Pantone on several occasions described his technology as
effective and functioning.
> 94.  Pantone and the other defendants made several representations
as to the increased fuel efficiency and reduction in pollution.
> 95.  Representations were made by cross-defendants and each of them
that this technology was developed by Pantone, and that he was
experienced in its implementation.
>  96. Pantone intentionally and knowingly represented that the GEET
device was close to complete and ready for full-scale production.
>  97.  Pantone represented that the GEET device worked in many
applications when Pantone knew that these applications had not been
completed.
> 98.  Pantone made these representations, with the intent to induce
Christensen to rely on Pantone's assurances and invest funds to
Pantone's scheme, with the Pantone promise that the devise would, with
a minimal amount of effort, be ready for production.
>
>  99.  Pantone failed to inform Christensen of Pantone's lack of
knowledge of how to complete the device, and how Pantone required the
assistance of others to complete the process.
>  100. As a direct and proximate result of Pantone's
misrepresentation, Christensen did invest substantial time of funds to
Pantone's scheme.
>  101. As a direct and proximate result of Pantone's
misrepresentation, Christensen has been damaged in an amount to be
proven at time of trial.
> 102.  Pantone's conduct was willful, malicious, and in reckless
disregard of Christensen's rights.  Christensen is therefore entitled
to punitive damages in an amount to be proven at time of trial.
> PRAYER FOR RELIEF
>  WHEREFORE, Christensen demands judgment against plaintiffs and
cross-defendants as follows:
>  A.  Judgment in favor of Christensen in an amount to be proven at
time of trial on the First, Second, Third, Fourth Fifth, Sixth,
Seventh, Eighth and Ninth Causes of Action, together with interest at
the statutory rate.
>  B.  Punitive Damages in Christensen's Eighth and Ninth Causes of
Action, in an amount to be determined at trial, and
>  C.  Interest, reasonable attorney fees, and such other relief as
the Court deems appropriate
>  Dated: this ____ day of February, 2001.
>
>  _____________________________
>  M. Del Christensen
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>    CERTIFICATE OF SERVICE
> I hereby certify that I am a not a party to this action.  My
business address is:  3270 South 11 West, Building 400 salt Lake City,
Utah 84119 .  A true and correct copy of the above and foregoing:
>   ANSWER TO COMPLAINT AND CROSS-COMPLAINT
> was mailed via United States Mail, postage prepaid. to the following
at their address as shown below,
> Robert E. Mansfield
> Todd D. Weiler
> Parry, Anderson & Mansfield
> 1270 Eagle Gate Tower
> 60 East South Temple
> Salt Lake City, Utah 84111
>
>  this ___ of ______, 2001.
>
>
> _____________________________________


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WTF?!

I find it rather difficult to see Pantone as a villain because of his
sheer stupidity. But this Mr. Christensen takes the cake! I find it
impossible to find Mr. Christensen as the good guy in this out of his
even greater stupidity. Lending money to someone who already owes you
money is something you Just Don't Do. And gambling one's money on a
technology sight unseen is similarly dumb. You guys belong on Judge Judy.



--- In GEET-Paul-Pantone-Problems@y..., "Bob Colvin" <bps@f...> wrote:
> M. Del Christensen
> 3270 South 1100 West # 400
> Salt Lake City, Utah 84119
> Tele: (801) 973-4391
>
> In Propria Persona
>
>
>  IN THE UNITED STATES DISTRICT COURT
> FOR THE STATE OF UTAH
> CENTRAL DIVISION
>
________________________________________________________________________________\
_____
> )
> GEET INTERNATIONAL INC., a Nevada )
> Corporation, PAUL PANTONE, an              ) DEFENDANT M. DEL
> individual, MOLLEY PANTONE, an            ) CHRISTENSEN ANSWER
> individual,                                                     ) TO
PLAINTIFF'S COMPLAINT
> Plaintiffs )
>                        ) CASE NO: 2:01CV0014 B
> vs.
)
> ) Judge Benson
> M. DEL CHRISTENSEN, an individual,       )
> PAUL  NOBEL, an individual, KERRY        )
>  MCMULLAN an individual, MICHELLE    )MCMULLAN, an individual, JASON
KIM )
> an individual, STEVEN L. MITCHELL, an  )
> individual, D.L. HOLDER, an individual, AL )
> AL TOTH, an individual, BOB COLVIN, an)
> individual, G.E.E.T. of UTAH LLC, a Utah  )
> Limited Liability Company, GEET OF  )
> MARYLAND, a Maryland Corporation,  )
> GEET OF COLORADO, a Colorado   )
> Corporation, JAY MCMULLAN, an  )
> individual, TOM BERRY, an individual,  )
> WENDY COLLARD, an individual, and  )
> GEET INTERNATIONAL INSTITUTE  a )
> dba of GEET of Utah, LLC )
> )
> Defendants )
>
__________________________________________________________________________
> )
> M. DEL CHRISTENSEN, an individual        ) COUNTER-COMPLAINT
> )
> Cross-complainant )
> vs. )
> )
> PAUL PANTONE, an individual, MOLLEY )
> PANTONE, an individual, G.E.E.T.  )
> INTERNATIONAL, INC., a Nevada  )
> Corporation, GEET BUSINESS TRUST,  )
> PAUL PANTONE TRUST, PANTONE )
> FAMILY TRUST, and DOES I through X )
> inclusive, )
> )
> Cross-defendants )
>
__________________________________________________________________________
>
> Comes now defendant M. Del Christensen (defendant), on his own
behalf and answers plaintiffs' complaint as follows:
> PARTIES, JURISDICTION AND VENUE
> 1.  Defendant admits the allegations set forth in paragraphs 3, 19,
20 and 21 of plaintiff's complaint.
> 2.  Due to a lack of sufficient information defendant denies the
allegations set forth 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15,
and 16 of plaintiff's complaint.
> 3.  As to the allegations set forth in paragraph 17 of plaintiff
complaint, defendant admits that GEET of Utah LLC has its principle
place of business in Salt Lake City, and is a registered limited
liability company in Utah.  Defendant denies all other allegations set
forth in this paragraph.
> 4. As to the allegations set forth in paragraph 18 of plaintiff
complaint, defendant admits that GEET international Institute had its
principle place of business in Salt Lake City.  Defendant denies all
other allegations set forth in this paragraph.
> //
> GENERAL ALLEGATIONS
> 5.   Defendant admits the allegations set forth in paragraphs 25,
31, 38, 43, 51, 65, and 67 of plaintiff's complaint.
> 6.  Due to a lack of sufficient information defendant denies the
allegations set forth 23, 24, 26, 27, 28, 34, 47, 58 and 72 of
plaintiff's complaint.
> 7.  Defendants deny the allegations set forth in paragraphs 22, 29,
30, 32, 33, 35, 36, 37, 39, 40, 41, 42, 44, 45, 46, 48, 49, 50, 52,
53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 66, 68, 69, 70, 71,
73, 74, 75, and 76 of plaintiff's complaint.
> FIRST CAUSE OF ACTION
> 8.  Defendant incorporates by reference paragraphs 1 through 7 of
his Answer as if set forth in full herein.
> 9.  Due to a lack of sufficient information, defendant denies the
allegations set forth in paragraphs 77, 78, and 79 of plaintiff's
complaint.
> 10.  Defendant denies the allegations set forth in paragraphs 80,
81, 82, 83, 84 and 85 of plaintiff's complaint.
> SECOND CAUSE OF ACTION
> 11.  Defendant incorporates by reference paragraphs 1 through 10 of
his Answer as if set forth in full herein.
> 12.  Defendant denies the allegations set forth in paragraphs 86,
87, 88, 89, 90, 91, and 92 of plaintiff's complaint.
> THIRD CAUSE OF ACTION
> 11.  Defendant incorporates by reference paragraphs 1 through 12 of
his Answer as if set forth in full herein.
> 13.  Defendant denies the allegations set forth in paragraphs 93,
94, 95, 96, 97, and 98 of
>
> plaintiff's complaint.
>
> FOURTH CAUSE OF ACTION
> 14.  Defendant incorporates by reference paragraphs 1 through 13 of
his Answer as if set forth in full herein.
> 15.  Defendant denies the allegations set forth in paragraphs 99.
100, 101, 102, 103, 104, and  105 of plaintiff's complaint.
> FIFTH CAUSE OF ACTION
> 16.  Defendant incorporates by reference paragraphs 1 through 15 of
his Answer as if set forth in full herein.
> 17.  Defendant admits the allegations in paragraph 110, that he
currently possesses property belonging to plaintiff, defendant further
states that he has requested that plaintiff remove said property but
has failed to do so.
> 18.  Defendant denies the allegations set forth in paragraphs 106,
107, 108, 109, 111, and 112  of plaintiff's complaint.
> SIXTH CAUSE OF ACTION
> 19.  Defendant incorporates by reference paragraphs 1 through 18 of
his Answer as if set forth in full herein.
> 20.  Defendant denies the allegations set forth in paragraphs 113,
114, 115, 116, 117, 118, and 119 of plaintiff's complaint.
> SEVENTH CAUSE OF ACTION
> 21.  Defendant incorporates by reference paragraphs 1 through 20 of
his Answer as if set forth in full herein.
> 22.  Defendant denies the allegations set forth in paragraphs 120,
121, 122, and 123 of
>
> plaintiff's complaint.
> EIGHTH CAUSE OF ACTION
> 23.  Defendant incorporates by reference paragraphs 1 through 22 of
his Answer as if set forth in full herein.
> 24.  Defendant denies the allegations set forth in paragraphs 124,
125, 126, 127, 128, and 129 of plaintiff's complaint.
> NINTH CAUSE OF ACTION
> 25.  Defendant incorporates by reference paragraphs 1 through 24 of
his Answer as if set forth in full herein.
> 26.  Defendant denies the allegations set forth in paragraphs 130,
131, 132, 133, and 134 of plaintiff's complaint.
> TENTH CAUSE OF ACTION
> 27.  Defendant incorporates by reference paragraphs 1 through 26 of
his Answer as if set forth in full herein.
> 28.  Defendant denies the allegations set forth in paragraphs 135,
136, 137, 138, and 139 of plaintiff's complaint.
> ELEVENTH CAUSE OF ACTION
> 29.  Defendant incorporates by reference paragraphs 1 through 28 of
his Answer as if set forth in full herein.
> 30.  Defendant denies the allegations set forth in paragraphs 140,
141, 142, and 143 of plaintiff's complaint.
> TWELFTH CAUSE OF ACTION
> 31.  Defendant incorporates by reference paragraphs 1 through 30 of
his Answer as if set forth in full herein.
> 32.  Defendant denies the allegations set forth in paragraphs 144,
145, 146, 147, 148, 149, 150 and 151 of plaintiff's complaint.
> THIRTEENTH CAUSE OF ACTION
> 33.  Defendant incorporates by reference paragraphs 1 through 32 of
his Answer as if set forth in full herein.
> 34.  Defendant denies the allegations set forth in paragraphs 152,
153, 154 and 155 of plaintiff's complaint.
> FOURTEENTH CAUSE OF ACTION
> 35.  Defendant incorporates by reference paragraphs 1 through 34 of
his Answer as if set forth in full herein.
> 36.  Defendant denies the allegations set forth in paragraphs 157,
158 and 159 of plaintiff's complaint.
> THEREFORE this answering defendant prays for judgment as follows:
> 1. That plaintiffs receive nothing by way of their complaint,
> 2. For cost of suit herein;
> //
> 3. For such other and further relief as the Court may deem proper.
>
> Dated: February  ____, 2001
______________________________
> M. Del Christensen
>
> FIRST AFFIRMATIVE DEFENSE
> As for a  FIRST SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, this answering defendant alleges that the alleged Causes of
Actions as set forth in plaintiffs' Complaint fail to state facts
sufficient to constitute any cause of action against this answering
defendant.
>      SECOND AFFIRMATIVE DEFENSE
> As a SECOND SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs  have failed to
mitigate their damages, if any have in fact been suffered.
>      THIRD AFFIRMATIVE DEFENSE
> As a THIRD SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to plaintiffs EIGHTH Cause of Action set forth therein,
this answering defendant alleges and avers that Truth is an absolute
defense.
> FOURTH AFFIRMATIVE DEFENSE
> As a FOURTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs  claims are
barred by the plaintiffs breaches of the covenant of good faith and
fair dealing.
> FIFTH AFFIRMATIVE DEFENSE
> As a FIFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiff breached the
contract alleged within the complaint, and plaintiffs claims are
therefore barred.
> SIXTH AFFIRMATIVE DEFENSE
> As a SIXTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that to the extent plaintiffs
have any claims for damages, which claim is expressly denied,
defendant is entitled to an offset against plaintiff in the amount of
damages incurred by defendant as a result of plaintiffs' breaches of
duty, failure to perform as promised and other wrongful acts as set
forth in the Counter-claim herein.
> SEVENTH AFFIRMATIVE DEFENSE
> As a SEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs claims are
barred by the doctrine of unclean hands.
> EIGHTH AFFIRMATIVE DEFENSE
> As an EIGHTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs damages, if any,
were proximately caused by third parties over whom defendant had no
control, and defendant cannot be held liable for such damages.
> NINTH AFFIRMATIVE DEFENSE
> As a NINTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that defendant is entitled to
his reasonable attorney's fees and cost incurred herein because
plaintiff's claims against defendant were filed in bad faith, are
without merit.
> TENTH AFFIRMATIVE DEFENSE
> As a TENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs complaint is
barred in whole or in part by the negligent and/or other wrongful
conduct of plaintiff and/or its agents.
> ELEVENTH AFFIRMATIVE DEFENSE
> As an ELEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiff's damage, if any,
were proximately and solely caused by plaintiff.
> TWELFTH AFFIRMATIVE DEFENSE
> As a TWELFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs claim is barred
by the fact that plaintiff's patent is defective, as is defendants
alleged technology as plaintiffs are unable to produce an effective
devise that will produce the results as promised by plaintiffs.
> COUNTER CLAIM
> Cross-Complainant M. Del Christensen (Christensen), complains
against plaintiff and each of them as follows:
> BACKGROUND AND HISTORY
> 1. In October 1999, Christensen received information in regards to
the development of an energy saving technology, to which
cross-complainant investigated and met with cross-defendant Paul
Pantone (Pantone).  Christensen was allowed to observe some of the
devises created under the direction of Pantone at the then business
location for GEET Management LLC located in Salt Lake City, Utah.
> 2. Christensen expressed an interest in the technology, and Pantone
requested that Christensen prepare prototype "reaction chambers" based
on specifications provided by Pantone. Christensen
>  3.  Christensen quoted a price to prepare said prototypes for
$1,500.00, which amount was agreed to be acceptable by Pantone.
>  4.  Within 2 weeks of this agreement, on or about the end of
October, Christensen delivered 7 prototype reaction chambers, to
Pantone, which Pantone accepted as satisfactory.  Pantone was only
able to pay $1,000.00 but promised the remainder shortly.
>  5.  Pantone was satisfied with the product, so much so that Pantone
ordered an additional 500 of the units, to be at various sizes,
stating that Pantone needed these to sell at a show in Idaho that
Pantone was to attend. Pantone agreed to an estimated price of $14,000.00
>  6.  Within 5 weeks of receiving this order, and within the time
frame as required by Pantone, Christensen delivered the 500 units to
Pantone, and provided an invoice for $14,000.00.
>  7.  Pantone had some concerns over some of the units provided, so
Christensen had some of his employees of his make the necessary
revisions, and produced the units to Pantone's satisfaction.
>  8.  These prototypes were specially manufactured, to the
specifications provided by Pantone, and were not useable in any other
application except as to meet Pantone's purposes.
>  9.  Pantone did not have the storage facilities at his residence,
to store all units provided by Christensen.  Pantone took
approximately 230 of the units and requested that Christensen store
the remainder, until Pantone returned from the Idaho show.
>  10.  Pantone promised to pay for the production in full upon his
return from Idaho, claiming that he would be able to sell or take
orders at the show sufficient to pay for the manufactured units.
>  11.  Upon Pantone's return, Pantone explained that he was only able
to sell 4 or 5 of the units, and tried to return them to Christensen.
  Christensen had no use for the units, but offered to store them until
Pantone was able to sell them.
>  12. Commencing in February, 2000, Pantone explained that his
company was undergoing some management changes, and that his wife
Molley had just left him, which made it difficult to concentrate on
his work. Pantone requested that Christensen have patience and
continue to work with Pantone, and that Christensen would be more then
compensated as soon as these problems were resolved.
>  13.  Pantone requested that Christensen continue to store the
reaction chambers all ready manufactured, but also requested other
product and asked that Christensen ship them to designated customers
as provided by Pantone. These products were to be shipped under the
GEET logo, and  Christensen would be paid upon receipt of funds.
>  14.  Christensen complied with Pantone's request, providing Pantone
with invoices for all product produced and shipped.
>  15.  Shortly thereafter Pantone moved his operations to Colorado to
attempt to reconcile with his wife.  Pantone requested that
Christensen continue to manufacture and ship product as ordered.
>  16.  Christensen produced and shipped approximately $50,000.00 in
product of which $15,000.00 has been received.
>  17.  In May of 2000, Christensen received a telephone call from
Pantone claiming that he was at the Exotic Research Conference being
held in Arizona. Pantone explained that the promoter of the conference
had disappeared and was not honoring his guarantee to make payment to
the Hotel causing Pantone and his group to be locked out of their
Hotel rooms and the Exhibit Hall.
>  18.  Pantone requested that Christensen let Pantone use his credit
card in order to get his belongings, and promised repayment within 3
days, and Christensen agreed.
>  19.  Pantone used Christensen's credit card, taking care of his
bill, to which Christensen agreed to, but then Pantone also used the
credit card to pay the bills of several others that were in the same
situation at the conference, but without the permission of Christensen.
>  20.  Pantone placed about $5,000.00 on the credit card, but has yet
to reimburse Christensen for that amount.
>  21.  During the summer of 2000, Christensen received a telephone
call from Pantone claiming that he was in jail again, in Colorado, for
violating a court order relating to domestic violence charges, and
that he needed assistance in posting the bail of $1,000.00.
>  22.  Pantone promised that if Christensen would post the bail it
would be paid back within 1 week.
>  23.  Christensen used one of his credit cards, and had the bail
posted, but has not been reimbursed.
>  24. A few weeks later, Christensen received another similar
telephone call, Pantone was again in jail, for violating a court order
and needed bail posted in the amount of $1,500.00, and would reimburse
Christensen as soon as possible.
>  25.  Christensen again posted bail, but has not been reimbursed.
>  26.  A few weeks after being arrested, Pantone again contacts
Christensen by way of telephone, and requests that Christensen assist
him to getting out of Colorado, as Pantone claimed he was allowed to
leave the state, but was afraid that the authorities were after him,
and needed to get away. Pantone promised to reimburse Christensen for
all costs incurred to get him out of Colorado.
>  27.  Christensen made the necessary arrangements, renting a moving
van, obtaining and paying the wages of two men to drive to Pantone's
location and return him to Salt Lake. Christensen incurred a cost in
excess of $2,000.00 which remains unpaid.
>  28.  Upon Pantone's return to Utah, Pantone approached Christensen
and offered Christensen the GEET distributorship for Utah as partial
compensation for Christensen's assistance.
>  29.  Christensen subsequently discovered that Pantone had all ready
sold the distributorship rights to Utah to 2 other individuals whose
distributorship rights were never taken away.
>  30.  When Pantone returned he approached Christensen and produced
information that Pantone had received requests from over 250
individuals that wanted training in the GEET technology, and that he
had several that were ready to start immediately, at a suggested
training price of $1,500.00.
>  31.  Pantone suggested that Christensen could run the school to be
called GEET International Institute, and that Christensen would be
reimbursed out of the tuition, so long as a portion would go to
Pantone.  The parties agreed to initially charge $1,200.00 as the tuition.
>  32.  Pantone stated that he had confirmation of 30 students, but
needed the school ready by August 7, 2000.
>  33. Christensen borrowed the funds necessary to obtain a suitable
place for the school, to obtain the necessary school supplies and have
the needed support staff in order to run the school. Christensen
incurred a debt of approximately $26,000.00 to have the school ready
by August 7, 2000 as demanded by Pantone.
>  34.  On August 7, 2000, no student showed up.
>  35.  Since that date, the GEET International Institute has had 12
students.
>  36.  Of these 12 students only 3 paid tuition, 8 of the remainder
were students that agreed to attend the school as a set off for monies
previously given to Pantone for product that was not received.
>  37. The school was shut down in December 2000, as there were no
students, no monies were raised to support the school, and the
promises of students did not materialize.
> 38.  As part of the instruction, it was the intent to demonstrate to
the students how the GEET technology worked.  Christensen on several
occasions requested that Pantone come to the school to implement the
technology on some of the engines there that would meet the claims as
made by Pantone.
> 39. A demo engine was provided, but did not burn all the fuel as
promised, likewise a genset was provided, but this was not able to run
at full power.
> 40. When asked to remedy the problem, Pantone explained that it had
been sabotaged by previous employees, and recommended that Christensen
make the repairs.
> 41.  While at the school. Pantone made several purchases on behalf
of the school that were charged to Christensen.  These included
without limitation costs for parts and equipment, acquired under the
guise of testing the technology, but did not produce anything noteworthy.
> 42.  Christensen subsequently was introduced to other individuals
who were in the process of developing energy reduction processes that
were significantly different that that of Pantone, and appears to have
a future. Christensen is presently working with this group.
> 43.  Christensen has since entered into a business relationship with
these other individuals, but has not made any development on the
ineffective GEET technology.
> FIRST CAUSE OF ACTION
> Breach of Contract - Reaction Chambers
> 44.  Christensen incorporates by this reference paragraphs 1 through
43 of this complaint as if set forth in full herein.
> 45.  In February 2000, Pantone contracted with Christensen for the
delivery of 500 specially made reaction chambers for $14,000.00.
>  46.  Christensen delivered said reaction chambers, and after making
some minor changes were approved and accepted by Pantone.
>  47.  Demand for payment on these reaction chambers has been made,
but defendants and each of them refuse to pay as agreed.
> 48. These reaction chambers have no value to Christensen, except as
scrap.
> 49. Christensen has been damaged in an amount in excess of $14,000.00.
> SECOND CAUSE OF ACTION
> Breach of Contract - Shipping
>  50.  Christensen incorporates by this reference paragraphs 1
through 50 of this complaint as if set forth in full herein
>  51.  In February and thereafter Pantone contracted with Christensen
to provide the shipping of GEET products.  Pantone agreed to reimburse
Christensen for all costs involved.
>  52.  Christensen incurred costs, including but not limited to
storage fees, supplies, outside labor, materials etc., in an amount in
excess of $50,000, or which $15,000.00 has been paid.
>  53.  Christensen has made demand for payment of the remainder, but
such demand has not been met.
> 54.  Christensen has been damaged by way of this breach of contract
in an amount top be proven at time of trial.
> THIRD CAUSE OF ACTION
> Breach of Contract - Conference Loan
>
> 55.  Christensen incorporates by this reference paragraphs 1 through
54 of this complaint as if set forth in full herein.
>  56.  In  May Pantone requested that Christensen loan Pantone
sufficient funds so that Pantone and other of the defendants would be
able to retrieve their belongings and finish the exhibit at the Exotic
Research Conference in Arizona.
> 57.  Christensen allowed Pantone to use Christensen's credit card
upon Pantone's promise to repay the amount needed within 3 days.
>  58.  Pantone charged approximately $ 5,000.00 on Christensen's
credit card.
>  59.  Christensen has demanded payment as agreed, but Pantone
continues to refuse to make payment.
>  60.  Christensen's credit card carries a monthly interest rate, and
Christensen has been damaged in an amount to be proven at time of trial.
> //
> //
>
> FOURTH CAUSE OF ACTION
> Breach of Contract - First Bail
>  61. Christensen incorporates by this reference paragraphs 1 through
60 of this complaint as if set forth in full herein.
>  62.  In the summer of 2000, Pantone contacted Christensen and
requested a loan in the amount of $1,000.00 in order to bail Pantone
out of jail. Pantone promised payment within 2 weeks.
>  63.  Christensen made the arrangements and had $ 1,000.00 bail
posted on Pantone's account.
>  64.  Christensen has made demand for reimbursement for the
$1,000.00. but payment has not been received.
> 65. Christensen has been damaged in the amount of $1,000.
> FIFTH CAUSE OF ACTION
> Breach of Contract - Second Bail
>  66. Christensen incorporates by this reference paragraphs 1 through
65 of this complaint as if set forth in full herein.
>  67.  In the summer of 2000, Pantone contacted Christensen and
requested a loan in the amount of $1,500.00 in order to bail Pantone
out of jail another time. Pantone promised payment as soon as he got out.
>  68.  Christensen made the arrangements and had $ 1,500.00 bail
posted on Pantone's account.
>  69.  Christensen has made demand for reimbursement for the
$1,500.00. but payment has not been received.
>  70.  Christensen has been damaged in the amount of $1,500.00.
> SIXTH CAUSE OF ACTION
> Breach of Contract - Loan for Utilities
>  71. Christensen incorporates by this reference paragraphs 1 through
70 of this complaint as if set forth in full herein.
>  72.  During the summer of 2000, Christensen received a telephone
call from Pantone who stated that his utilities, telephone and
satellite usage was about to be cut-off because of non-payment.
>  73.  Pantone requested a loan for $1,600.00 which Pantone promised
to pay within 1 week.
>  74.  Based on Pantone's promise to pay, Christensen arranged to
have these bills paid for on behalf of Pantone.
>  75.  Christensen has made demand for reimbursement, but has not
received repayment for this loan.
> 76.  Christensen has been damaged in an amount to be shown at time
of trial, but ion excess of $1,600.00.
> SEVENTH CAUSE OF ACTION
> Breach of Contract - Moving Expense
>
>  77.  Christensen incorporates by this reference paragraphs 1
through 76 of this complaint as if set forth in full herein.
>  78.  At the end of the summer of 2000, Pantone contacted
Christensen by telephone, stating that he needed to get out of
Colorado, and requested Christensen's financial assistance.
>  79.  Pantone represented that there was nothing requiring him to
remain, that he had cleared it with Teller County to be allowed to
leave, but needed his assistance.
>  80.  Christensen arranged to have a moving van rented, acquired
that services of 2 men to drive to Pantone's location, assist in
bringing Pantone's belongings back to Utah, and paid for food and gas
for the trip.
>  81.  Pantone promised to reimburse Christensen for all costs
incurred, which expenses were in excess of $2,000.00.
> 82.  Christensen has made demand for reimbursement of these
expenses, but has not been paid.
>  83.  Christensen has been damaged in the amount to be proven at
time of trial.
> EIGHTH CAUSE OF ACTION
> Fraud
>
>  84.  Christensen incorporates by this reference paragraphs 1
through 83 of this complaint as if set forth in full herein.
>  85.  Pantone represented to Christensen that he had 250 students
that had confirmed their interest in being trained in GEET technology.
>  86.  Pantone requested that Christensen run the school and be
compensated through the tuition that was received.
>  87.  At the time Pantone made these representations Pantone knew
that he did not have 250 students that had confirmed their interest.
>  88.  Pantone also knew that Christensen would rely on Pantone's
representations and incur substantial debt in order to prepare the school.
> 89.Christensen did rely on Pantone's representations, to
Christensen's detriment, incurring substantial costs in excess of
$26,000.00.
>  90.  As a direct and proximate cause of Pantone's fraudulent
statement Christensen has been damaged in an amount to be proven at
time of trial.
> 91.  Pantone's and cross-defendants conduct was willful, malicious
and in reckless disregard of Christensen's rights.  Christensen is
there entitled to punitive damages in an amount to be proven at time
of trial.
> NINTH CAUSE OF ACTION
> Misrepresentation
>
>  92.  Christensen incorporates by this reference paragraphs 1
through 91 of this complaint as if set forth in full herein.
>  93.  Pantone on several occasions described his technology as
effective and functioning.
> 94.  Pantone and the other defendants made several representations
as to the increased fuel efficiency and reduction in pollution.
> 95.  Representations were made by cross-defendants and each of them
that this technology was developed by Pantone, and that he was
experienced in its implementation.
>  96. Pantone intentionally and knowingly represented that the GEET
device was close to complete and ready for full-scale production.
>  97.  Pantone represented that the GEET device worked in many
applications when Pantone knew that these applications had not been
completed.
> 98.  Pantone made these representations, with the intent to induce
Christensen to rely on Pantone's assurances and invest funds to
Pantone's scheme, with the Pantone promise that the devise would, with
a minimal amount of effort, be ready for production.
>
>  99.  Pantone failed to inform Christensen of Pantone's lack of
knowledge of how to complete the device, and how Pantone required the
assistance of others to complete the process.
>  100. As a direct and proximate result of Pantone's
misrepresentation, Christensen did invest substantial time of funds to
Pantone's scheme.
>  101. As a direct and proximate result of Pantone's
misrepresentation, Christensen has been damaged in an amount to be
proven at time of trial.
> 102.  Pantone's conduct was willful, malicious, and in reckless
disregard of Christensen's rights.  Christensen is therefore entitled
to punitive damages in an amount to be proven at time of trial.
> PRAYER FOR RELIEF
>  WHEREFORE, Christensen demands judgment against plaintiffs and
cross-defendants as follows:
>  A.  Judgment in favor of Christensen in an amount to be proven at
time of trial on the First, Second, Third, Fourth Fifth, Sixth,
Seventh, Eighth and Ninth Causes of Action, together with interest at
the statutory rate.
>  B.  Punitive Damages in Christensen's Eighth and Ninth Causes of
Action, in an amount to be determined at trial, and
>  C.  Interest, reasonable attorney fees, and such other relief as
the Court deems appropriate
>  Dated: this ____ day of February, 2001.
>
>  _____________________________
>  M. Del Christensen
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>    CERTIFICATE OF SERVICE
> I hereby certify that I am a not a party to this action.  My
business address is:  3270 South 11 West, Building 400 salt Lake City,
Utah 84119 .  A true and correct copy of the above and foregoing:
>   ANSWER TO COMPLAINT AND CROSS-COMPLAINT
> was mailed via United States Mail, postage prepaid. to the following
at their address as shown below,
> Robert E. Mansfield
> Todd D. Weiler
> Parry, Anderson & Mansfield
> 1270 Eagle Gate Tower
> 60 East South Temple
> Salt Lake City, Utah 84111
>
>  this ___ of ______, 2001.
>
>
> _____________________________________

Hey phokes. I'm a whiz with html. Very meticulous, perfect spelling
and grammar. I can design the website. I just joined this list, so I'm
not completely up to speed on what the position of the people here is.
      For instance, do the people here believe that the geet device
works, but that Pantone isn't managing it properly just to piss
everybody off? Or do you fellas say it doesn't work at all? As for me,
I'm agnostic at this point. I'm still looking for evidence on either side.


--- In GEET-Paul-Pantone-Problems@y..., GEETofPA@a... wrote:
> Thanks Chad!  You're the best.
>
> Well, I think it's time to build this list even bigger that the last
> one.  I can submit this list's URL to over 386,000 search engines and
> directories using this handy-dandy submitter program.  Do we have a
> Web site to support the list?  The "GREED Bullsheet", perhaps?  I can
> host a site on my server for free (no annoying pop-ups) if someone
> wants to come up with a name and chip in a few bucks for the domain
> name.  They are only $9.95 at www.gkg.net.
>
> Anyway, if someone will pay for the domain name, I will host the site
> on my server.  If someone here wants to design a site themselves, I
> can just set up the account so you have FTP access to it.  Once the
> site is set up, perhaps Chad can post a link to it at the bottom of
> every post made to the list so it gets traffic and so that people
> don't have to search the archives to get the whole Paul Pantone
> story.
>
> I was going to do all this and more, much sooner, but Mike Holler
> asked me not to attack Paul like that.  Instead, he encouraged me to
> find ways to support the distributors, which, at the time, I thought
> was the best use of my time.  Yet, I think he may also have just been
> partly protecting his own butt, as Paul has definitely been after him
> for some reason.  I can't blame Mike, though.  He's been through hell
> and high water with Paul and just wants Paul completely out of his
> life.
>
> I think word needs to continue to get out about how Paul has hurt so
> many people.  So, keep up the good work, all.  I love you people.
>
> Regards,
> Peter

The Christensen countersuit is using the "doctrine of unclean hands"
on one point. My prediction – Pantone's patent will be
invalidated. Read this story to get some insight.

http://www.lgu.com/pubs/cr37.htm

CALIFORNIA COURT INVALIDATES ASHTON-TATE'S COPYRIGHT ON dBASE PROGRAMS
January 1991

When Ashton-Tate filed its copyright infringement suit against Fox
Software and Santa Cruz Operation in November 1988, it could hardly
have imagined a worse outcome than it experienced two years later at
the hands of federal judge Terry Hatter. Ashton-Tate's suit alleged
that Fox and SCO's "FoxBASE" line of programs infringed Ashton-Tate's
copyrights in dBase II, dBase III, dBase III Plus and dBase IV. In
its complaint, Ashton-Tate claimed that the "organization, structure
and sequence" of the dBase programs reflected forms of
expression "original" to Ashton-Tate and that Fox and SCO had
illegally copied the "unique look and feel" of the programs,
including "commands, menus and text."

On December 11, 1990, Judge Hatter issued an order invalidating
Ashton-Tate's copyrights in its own dBase line of programs, the
foundation of its business, on the ground that Ashton-Tate had
knowingly deceived the United States Copyright Office when it filed
its copyright registrations for the dBase programs. The court stated
that although Ashton-Tate knew that its programs were derived from
JPLDIS, a public domain program developed by the Jet Propulsion
Laboratory, it had "repeatedly failed" to disclose this fact to the
Copyright Office when it filed its copyright applications for the
programs.

The sanction imposed by the court on Ashton-Tate falls under the
quaintly (but descriptively) named legal doctrine of "unclean hands."
The defense of unclean hands may be raised by the defendant in a
copyright suit when the plaintiff has acted in a highly inequitable
manner with respect to the work in question (e.g., by procuring a
copyright through fraudulent representations made to the Copyright
Office). However, because the copyright owner's transgression must be
of serious proportions, this defense is seldom successful. Judge
Hatter's rare application of the rule indicates that he found Ashton-
Tate's failure to disclose the antecedents of its programs to have
been intentional, rather than negligent or inadvertent.
The consequence of the ruling, if it is upheld on the appeal which
Ashton-Tate is certain to seek, is to strip Ashton-Tate of its
copyright rights in dBase, and permit any company to copy the user
interface of the program.

TLB Comment: The outcome of the Ashton-Tate case shows that a company
may have more to lose than to gain when its sues a competitor for
proprietary rights violations. Although Ashton-Tate may have thought
it was stepping on an ant when it brought its claim against Fox and
SCO, it stumbled instead onto a landmine. Lotus took the same risk
when it brought suit against Paperback Software for infringement of 1-
2-3 (see TLB July 1990), knowing that the defendant would argue that
1-2-3 was derived from VisiCalc. Fortunately for Lotus, this defense
was emphatically rejected by the court.

One lesson to be learned from Ashton-Tate's fall is that before
commencing an aggressive campaign to protect proprietary rights, a
company must consider all possible counter-attacks, and carefully
weigh the benefit of its contemplated action, if successful, against
the risk that the defendant's counteroffensive will succeed, and the
consequences if it does.

The Ashton-Tate decision also is interesting, coming as it does on
the heels of the Lasercomb decision, where a court invalidated
Lasercomb's copyright under another branch of the "unclean hands"
doctrine. In this case, the court held that the owner had "misused"
its copyright by requiring a licensee to agree to a non-compete as a
condition to a copyright license (see TLB, October f1990). The
existence of this single clause in a license led the court to
invalidate the copyright. Although two events usually don't
constitute a trend, invalidation of a copyright is rare, and for two
courts to take such an action so close in time sends a strong message
to the software industry that the doctrine of unclean hands is here
to stay.

I would like to thank the tens of thousands of people from at least
132 countries all over the world who have offered to step forward
with contributions to this list.

All have not posted yet because of their concerns about getting
called at all hours of the night, getting obscenities screamed at
them, and then getting threatened with a lawsuit by the inventor.

As soon as certain protections are put in place, they will be posting
in at most a week or two.

Here are some examples of the emails:

"I sent the money and got nothing in return. I was given promise
after promise but never received anything."

"I installed the device exactly as in the plans and it did not work
at all. I made sure I followed the directions perfectly. Calls to the
inventor did not solve the problems."

"I emailed and asked for names of other kit buyers who were driving
modified cars and could never the company to give me even a single
name."

I would also like to thank the hundreds of university
professors who have emailed just in the last week since this group
was formed also wishing to contribute. All said they will be posting
next week. Thank you!

Here are some examples:

"We did experiments and the results do not match the claims. The
technology is old and well known. So are the limitations and
problems."

"Myself and many of my colleagues are insulted by the false
scientific claims being made. It causes great damage to the publics
perception of the legitimate research."


Look for thousands of emails being posted as soon as they are cleaned
up. Next week!!

Remember to update the link on your site to the new discussion list.


--- In GEET-Paul-Pantone-Problems@y..., "Bob Colvin" <bps@f...> wrote:
> www.friend.ly.net/GEET website server is down till next week.
Temporary site
> till the new server is online will be www2.
>
> www2.friend.ly.net/GEET
>
> www2.friend.ly.net/GEET/lawsuit.htm

www.friend.ly.net/GEET website server is down till next week. Temporary site
till the new server is online will be www2.

www2.friend.ly.net/GEET

www2.friend.ly.net/GEET/lawsuit.htm

--- In GEET-Paul-Pantone-Problems@y..., karensnow26@h... wrote:
> I believe if I were Pantone, after reading this, I would drop my
> lawsuit like a red hot potato!
>
> Karen Snow
> Chicago
>

As noted in the latest docket info below, the case has been assigned
to the Honorable Judge Ronald N. Boyce. This is extremely bad news
for Pantone and extremely good news for everyone else.

2/9/01 Answer to Complaint by M. Del Christensen (hom)

2/9/01 Clerk's mailing of certificate of acknowledgment of
        alternative dispute resolution option. Mailed or faxed to
        plaintiff Geet Intl, plaintiff Paul Pantone, plaintiff
        Molley Pantone, defendant M. Del Christensen (hom)

2/12/01 Order of Reference pursuant to 636(b)(1)(B) signed by Dee
         Benson 2/12/01. Mag directed to handle case up to and incl
         the R&R on any dispositive matters. cc:attys (kam)

2/13/01 Case referred to Judge Ronald N. Boyce  cc: atty (kam)


We need to give our thanks to Judge Dee Benson for assigning the case
to Judge Boyce. He is a very strict, conservative, no-nonsense jurist
who authored the Utah Prosecutor Handbook and is co-author of
Criminal Law and Criminal Law and Procedure.  I believe Judge Benson,
after reviewing the Christensen counter-suit filing, carefully chose
Judge Boyce to handle this case. To give you an idea of his opinions
regarding the sanctity and honor due the marriage covenant, read the
following AP Newswire:

Associated Press
JUDGE SAYS UTAH HAS RIGHT TO BAN ADULTERY

Adultery is not a victimless crime and
Utah has a right to ban it under an 1887
law that makes marital infidelity a
misdemeanor offense, a federal magistrate
says.

Adultery can bring disease, destruction
of the family, the birth of unwanted children
and state child support. ``The results can
be tragic and the social costs may impact
innocent children and relatives,'' U.S.
Magistrate Ronald Boyce wrote.

``That adultery may occur with some
frequency is no justification for a
constitutional restriction on the
criminalization of adultery any more than
on embezzlement or numerous other
violations of trust which frequently occur,''
he wrote.

Boyce's 52-page recommendation can
be accepted or rejected by U.S. District
Judge David Sam, but Boyce's reports are
almost always adopted by Utah's federal
judges.

The report was prompted by a case
involving West Valley City Police Sgt.
Gary Oliverson, who has spent six years
trying to overturn Utah laws banning
sodomy, fornication and adultery.

Oliverson was accused of violating
those laws by West Valley City and the
state police academy in 1986 after it was
discovered he had sex with at least two
women he met through the
police-sponsored Explorer Post program.
The program was intended to aid in the
development of young people, Boyce said
in his ruling.

Oliverson and other officers in the
department had sex with a 17-year-old
and two women, ages 18 and 20. The city
and the academy disciplined Oliverson for
violating state laws and exhibiting moral
turpitude.

Although the law against adultery is
constitutional, it is rarely used, said Salt
Lake County Attorney David Yocom.

``I don't know of anyone who has been
charged outright with adultery, but I know
of a few people who pleaded to it as a
plea bargain when a more serious sexual
offense was charged,'' Yocom said.

Boyce rejected Oliverson's claim that
the law violated his right to free speech and
privacy.

Extramarital sexual relations are not
within the privacy rights spelled out by the
Constitution. Other courts have ruled that
extramarital sexual activity such as
polygamy, child sexual abuse and
homosexual sodomy are not protected by
the right to privacy, Boyce wrote, and
neither is adultery.

Oliverson also said the law violated his
right to free speech, but Boyce refused to
equate sex with speech.

If Utahns want to legalize adultery,
Boyce wrote, they can vote to rescind the
law, which makes the offense a class A
misdemeanor.

Brian Barnard, Oliverson's attorney,
said Tuesday he wasn't surprised by the
ruling.

End of AP story


Judge Boyce also wrote law article opinions which argued for severely
limiting defendants to use the excuse of being intoxicated as a
mitigating factor in committing crimes. It does not take the IQ of a
genius to know what the Honorable Judge Boyce will think of Paul
Pantone when he hears the testimony and reads the police reports of
Pantone's spousal domestic violence and chronic drinking. Lawyers who
have argued before Judge Boyce know his tolerance for perjury is
ZERO! He is a con man's worst nightmare but is also the best friend
of an honest man.

Rejoice good people!

I hereby nominate the former president of the United States, Harry S.
Truman, as the inspirational leader of this forum.

Here is one of his famous quotes:

"I never give them hell. I just tell the truth and they think it's
hell."

Truth is hell to some. So let's tell the truth, the whole truth, and
nothing but the truth, so help us God!

Hi everybody,

so all messages are backed up now in the files
section of GeetCon group. When it should be
deleted again - no problem I got it all.

Peter


--- In GeetCon@y..., Peter_Matousek@f... wrote:
Hi folks,

so the file with almost all about GEET in egroups
(geet-vortex-carb, supercarbs, jln) and some of
off list mails about geet are now accesible in
files section (zipped). It's 16.3 Megs unpacked
and 3.6 Megs packed.

Good searching,
Peter

<snip>
--- End forwarded message ---

This list has just been submitted to over 386,500 search engines and
directories.  Next, I think I'll work to get it linked EVERYWHERE so
that this list comes up FIRST when people run a search for GEET or
Paul Pantone.

Next comes a possible article post to a site that receives over 1
million visits per month.  Anyone care to write that informative
article?  I'll wait until we have a Web URL to link to before we do
that.

What is the link to the GREED Bullsheet if that still exists?  I will
submit that link tomorrow.  Also, Bob, is there anything you'd like
to post on your former GEET site, or are you steering clear of that
now?  If you'd like to post anything, even a link to this list, I
will submit that URL for you.

Paul is really stupid, ya know?  He just poured gasoline on this fire.

Regards,
Peter

Thanks Chad!  You're the best.

Well, I think it's time to build this list even bigger that the last
one.  I can submit this list's URL to over 386,000 search engines and
directories using this handy-dandy submitter program.  Do we have a
Web site to support the list?  The "GREED Bullsheet", perhaps?  I can
host a site on my server for free (no annoying pop-ups) if someone
wants to come up with a name and chip in a few bucks for the domain
name.  They are only $9.95 at www.gkg.net.

Anyway, if someone will pay for the domain name, I will host the site
on my server.  If someone here wants to design a site themselves, I
can just set up the account so you have FTP access to it.  Once the
site is set up, perhaps Chad can post a link to it at the bottom of
every post made to the list so it gets traffic and so that people
don't have to search the archives to get the whole Paul Pantone
story.

I was going to do all this and more, much sooner, but Mike Holler
asked me not to attack Paul like that.  Instead, he encouraged me to
find ways to support the distributors, which, at the time, I thought
was the best use of my time.  Yet, I think he may also have just been
partly protecting his own butt, as Paul has definitely been after him
for some reason.  I can't blame Mike, though.  He's been through hell
and high water with Paul and just wants Paul completely out of his
life.

I think word needs to continue to get out about how Paul has hurt so
many people.  So, keep up the good work, all.  I love you people.

Regards,
Peter

Hi Paul,
      Sorry I have been gone so long. I have been very intent on
teaching my students how an engine really works. Like the fact that
the proper fuel mixture is 14.7 (air) to 1 (fuel). I think that the
reason the geet carb and other vapor carbs may not work properly is
because they run so lean any original performance is unatainable. I
am not an expert on the subject but I think if you have been working
on this project for 21 years, of course all the time helping
humanity, it might be time to look for another line of work. Of
course you may have different opinions but this is my story and I am
sticking to it.
      By the way, if anyone needs an ASE Master Certified Technician
and Texas State Certified Teacher for court purposes I am available.
Also, Paul told me I was off of the lawsuit. As to this date I still
see my name on www.geet.com. The truth must prevail!!! By the way
Paul, I rebuke you in the name of Jesus Christ to do no harm. No need
to thank me for the blessing. My address is listed below.
                                                     Kerry McMullan

Kerry McMullan
RR1 Box 128
O'Donnell, Texas 79351

>From: "Jeremiah Senner" <jsenner@...>
If you want all this posted just let me know and I will.

Hi little brother,
      Heck yes! Do it to it. Post much post often. May the force be with you.
                                                          Kerry McMullan
_________________________________________________________________
Get your FREE download of MSN Explorer at http://explorer.msn.com

I believe if I were Pantone, after reading this, I would drop my
lawsuit like a red hot potato!

Karen Snow
Chicago


--- In GEET-Paul-Pantone-Problems@y..., "Bob Colvin" <bps@f...> wrote:
> M. Del Christensen
> 3270 South 1100 West # 400
> Salt Lake City, Utah 84119
> Tele: (801) 973-4391
>
> In Propria Persona
>
>
>  IN THE UNITED STATES DISTRICT COURT
> FOR THE STATE OF UTAH
> CENTRAL DIVISION
>
______________________________________________________________________
_______________
> )
> GEET INTERNATIONAL INC., a Nevada )
> Corporation, PAUL PANTONE, an              ) DEFENDANT M. DEL
> individual, MOLLEY PANTONE, an            ) CHRISTENSEN ANSWER
> individual,                                                     )
TO PLAINTIFF'S COMPLAINT
> Plaintiffs )
>                        ) CASE NO: 2:01CV0014 B
>
vs.                                                                 )

> ) Judge Benson
> M. DEL CHRISTENSEN, an individual,       )
> PAUL  NOBEL, an individual, KERRY        )
>  MCMULLAN an individual, MICHELLE    )MCMULLAN, an individual,
JASON KIM )
> an individual, STEVEN L. MITCHELL, an  )
> individual, D.L. HOLDER, an individual, AL )
> AL TOTH, an individual, BOB COLVIN, an)
> individual, G.E.E.T. of UTAH LLC, a Utah  )
> Limited Liability Company, GEET OF  )
> MARYLAND, a Maryland Corporation,  )
> GEET OF COLORADO, a Colorado   )
> Corporation, JAY MCMULLAN, an  )
> individual, TOM BERRY, an individual,  )
> WENDY COLLARD, an individual, and  )
> GEET INTERNATIONAL INSTITUTE  a )
> dba of GEET of Utah, LLC )
> )
> Defendants )
>
______________________________________________________________________
____
> )
> M. DEL CHRISTENSEN, an individual        ) COUNTER-COMPLAINT
> )
> Cross-complainant )
> vs. )
> )
> PAUL PANTONE, an individual, MOLLEY )
> PANTONE, an individual, G.E.E.T.  )
> INTERNATIONAL, INC., a Nevada  )
> Corporation, GEET BUSINESS TRUST,  )
> PAUL PANTONE TRUST, PANTONE )
> FAMILY TRUST, and DOES I through X )
> inclusive, )
> )
> Cross-defendants )
>
______________________________________________________________________
____
>
> Comes now defendant M. Del Christensen (defendant), on his own
behalf and answers plaintiffs' complaint as follows:
> PARTIES, JURISDICTION AND VENUE
> 1.  Defendant admits the allegations set forth in paragraphs 3, 19,
20 and 21 of plaintiff's complaint.
> 2.  Due to a lack of sufficient information defendant denies the
allegations set forth 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15,
and 16 of plaintiff's complaint.
> 3.  As to the allegations set forth in paragraph 17 of plaintiff
complaint, defendant admits that GEET of Utah LLC has its principle
place of business in Salt Lake City, and is a registered limited
liability company in Utah.  Defendant denies all other allegations
set forth in this paragraph.
> 4. As to the allegations set forth in paragraph 18 of plaintiff
complaint, defendant admits that GEET international Institute had its
principle place of business in Salt Lake City.  Defendant denies all
other allegations set forth in this paragraph.
> //
> GENERAL ALLEGATIONS
> 5.   Defendant admits the allegations set forth in paragraphs 25,
31, 38, 43, 51, 65, and 67 of plaintiff's complaint.
> 6.  Due to a lack of sufficient information defendant denies the
allegations set forth 23, 24, 26, 27, 28, 34, 47, 58 and 72 of
plaintiff's complaint.
> 7.  Defendants deny the allegations set forth in paragraphs 22, 29,
30, 32, 33, 35, 36, 37, 39, 40, 41, 42, 44, 45, 46, 48, 49, 50, 52,
53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 66, 68, 69, 70, 71,
73, 74, 75, and 76 of plaintiff's complaint.
> FIRST CAUSE OF ACTION
> 8.  Defendant incorporates by reference paragraphs 1 through 7 of
his Answer as if set forth in full herein.
> 9.  Due to a lack of sufficient information, defendant denies the
allegations set forth in paragraphs 77, 78, and 79 of plaintiff's
complaint.
> 10.  Defendant denies the allegations set forth in paragraphs 80,
81, 82, 83, 84 and 85 of plaintiff's complaint.
> SECOND CAUSE OF ACTION
> 11.  Defendant incorporates by reference paragraphs 1 through 10 of
his Answer as if set forth in full herein.
> 12.  Defendant denies the allegations set forth in paragraphs 86,
87, 88, 89, 90, 91, and 92 of plaintiff's complaint.
> THIRD CAUSE OF ACTION
> 11.  Defendant incorporates by reference paragraphs 1 through 12 of
his Answer as if set forth in full herein.
> 13.  Defendant denies the allegations set forth in paragraphs 93,
94, 95, 96, 97, and 98 of
>
> plaintiff's complaint.
>
> FOURTH CAUSE OF ACTION
> 14.  Defendant incorporates by reference paragraphs 1 through 13 of
his Answer as if set forth in full herein.
> 15.  Defendant denies the allegations set forth in paragraphs 99.
100, 101, 102, 103, 104, and  105 of plaintiff's complaint.
> FIFTH CAUSE OF ACTION
> 16.  Defendant incorporates by reference paragraphs 1 through 15 of
his Answer as if set forth in full herein.
> 17.  Defendant admits the allegations in paragraph 110, that he
currently possesses property belonging to plaintiff, defendant
further states that he has requested that plaintiff remove said
property but has failed to do so.
> 18.  Defendant denies the allegations set forth in paragraphs 106,
107, 108, 109, 111, and 112  of plaintiff's complaint.
> SIXTH CAUSE OF ACTION
> 19.  Defendant incorporates by reference paragraphs 1 through 18 of
his Answer as if set forth in full herein.
> 20.  Defendant denies the allegations set forth in paragraphs 113,
114, 115, 116, 117, 118, and 119 of plaintiff's complaint.
> SEVENTH CAUSE OF ACTION
> 21.  Defendant incorporates by reference paragraphs 1 through 20 of
his Answer as if set forth in full herein.
> 22.  Defendant denies the allegations set forth in paragraphs 120,
121, 122, and 123 of
>
> plaintiff's complaint.
> EIGHTH CAUSE OF ACTION
> 23.  Defendant incorporates by reference paragraphs 1 through 22 of
his Answer as if set forth in full herein.
> 24.  Defendant denies the allegations set forth in paragraphs 124,
125, 126, 127, 128, and 129 of plaintiff's complaint.
> NINTH CAUSE OF ACTION
> 25.  Defendant incorporates by reference paragraphs 1 through 24 of
his Answer as if set forth in full herein.
> 26.  Defendant denies the allegations set forth in paragraphs 130,
131, 132, 133, and 134 of plaintiff's complaint.
> TENTH CAUSE OF ACTION
> 27.  Defendant incorporates by reference paragraphs 1 through 26 of
his Answer as if set forth in full herein.
> 28.  Defendant denies the allegations set forth in paragraphs 135,
136, 137, 138, and 139 of plaintiff's complaint.
> ELEVENTH CAUSE OF ACTION
> 29.  Defendant incorporates by reference paragraphs 1 through 28 of
his Answer as if set forth in full herein.
> 30.  Defendant denies the allegations set forth in paragraphs 140,
141, 142, and 143 of plaintiff's complaint.
> TWELFTH CAUSE OF ACTION
> 31.  Defendant incorporates by reference paragraphs 1 through 30 of
his Answer as if set forth in full herein.
> 32.  Defendant denies the allegations set forth in paragraphs 144,
145, 146, 147, 148, 149, 150 and 151 of plaintiff's complaint.
> THIRTEENTH CAUSE OF ACTION
> 33.  Defendant incorporates by reference paragraphs 1 through 32 of
his Answer as if set forth in full herein.
> 34.  Defendant denies the allegations set forth in paragraphs 152,
153, 154 and 155 of plaintiff's complaint.
> FOURTEENTH CAUSE OF ACTION
> 35.  Defendant incorporates by reference paragraphs 1 through 34 of
his Answer as if set forth in full herein.
> 36.  Defendant denies the allegations set forth in paragraphs 157,
158 and 159 of plaintiff's complaint.
> THEREFORE this answering defendant prays for judgment as follows:
> 1. That plaintiffs receive nothing by way of their complaint,
> 2. For cost of suit herein;
> //
> 3. For such other and further relief as the Court may deem proper.
>
> Dated: February  ____, 2001
______________________________
> M. Del Christensen
>
> FIRST AFFIRMATIVE DEFENSE
> As for a  FIRST SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, this answering defendant alleges that the alleged Causes
of Actions as set forth in plaintiffs' Complaint fail to state facts
sufficient to constitute any cause of action against this answering
defendant.
>      SECOND AFFIRMATIVE DEFENSE
> As a SECOND SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs  have failed to
mitigate their damages, if any have in fact been suffered.
>      THIRD AFFIRMATIVE DEFENSE
> As a THIRD SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to plaintiffs EIGHTH Cause of Action set forth
therein, this answering defendant alleges and avers that Truth is an
absolute defense.
> FOURTH AFFIRMATIVE DEFENSE
> As a FOURTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs  claims are
barred by the plaintiffs breaches of the covenant of good faith and
fair dealing.
> FIFTH AFFIRMATIVE DEFENSE
> As a FIFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiff breached the
contract alleged within the complaint, and plaintiffs claims are
therefore barred.
> SIXTH AFFIRMATIVE DEFENSE
> As a SIXTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that to the extent plaintiffs
have any claims for damages, which claim is expressly denied,
defendant is entitled to an offset against plaintiff in the amount of
damages incurred by defendant as a result of plaintiffs' breaches of
duty, failure to perform as promised and other wrongful acts as set
forth in the Counter-claim herein.
> SEVENTH AFFIRMATIVE DEFENSE
> As a SEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs claims are
barred by the doctrine of unclean hands.
> EIGHTH AFFIRMATIVE DEFENSE
> As an EIGHTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs damages, if
any, were proximately caused by third parties over whom defendant had
no control, and defendant cannot be held liable for such damages.
> NINTH AFFIRMATIVE DEFENSE
> As a NINTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that defendant is entitled to
his reasonable attorney's fees and cost incurred herein because
plaintiff's claims against defendant were filed in bad faith, are
without merit.
> TENTH AFFIRMATIVE DEFENSE
> As a TENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs complaint is
barred in whole or in part by the negligent and/or other wrongful
conduct of plaintiff and/or its agents.
> ELEVENTH AFFIRMATIVE DEFENSE
> As an ELEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiff's damage, if
any, were proximately and solely caused by plaintiff.
> TWELFTH AFFIRMATIVE DEFENSE
> As a TWELFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs'
Complaint, and to  each Cause of Action set forth therein, this
answering defendant alleges and avers that plaintiffs claim is barred
by the fact that plaintiff's patent is defective, as is defendants
alleged technology as plaintiffs are unable to produce an effective
devise that will produce the results as promised by plaintiffs.
> COUNTER CLAIM
> Cross-Complainant M. Del Christensen (Christensen), complains
against plaintiff and each of them as follows:
> BACKGROUND AND HISTORY
> 1. In October 1999, Christensen received information in regards to
the development of an energy saving technology, to which cross-
complainant investigated and met with cross-defendant Paul Pantone
(Pantone).  Christensen was allowed to observe some of the devises
created under the direction of Pantone at the then business location
for GEET Management LLC located in Salt Lake City, Utah.
> 2. Christensen expressed an interest in the technology, and Pantone
requested that Christensen prepare prototype "reaction chambers"
based on specifications provided by Pantone. Christensen
>  3.  Christensen quoted a price to prepare said prototypes for
$1,500.00, which amount was agreed to be acceptable by Pantone.
>  4.  Within 2 weeks of this agreement, on or about the end of
October, Christensen delivered 7 prototype reaction chambers, to
Pantone, which Pantone accepted as satisfactory.  Pantone was only
able to pay $1,000.00 but promised the remainder shortly.
>  5.  Pantone was satisfied with the product, so much so that
Pantone ordered an additional 500 of the units, to be at various
sizes, stating that Pantone needed these to sell at a show in Idaho
that Pantone was to attend. Pantone agreed to an estimated price of
$14,000.00
>  6.  Within 5 weeks of receiving this order, and within the time
frame as required by Pantone, Christensen delivered the 500 units to
Pantone, and provided an invoice for $14,000.00.
>  7.  Pantone had some concerns over some of the units provided, so
Christensen had some of his employees of his make the necessary
revisions, and produced the units to Pantone's satisfaction.
>  8.  These prototypes were specially manufactured, to the
specifications provided by Pantone, and were not useable in any other
application except as to meet Pantone's purposes.
>  9.  Pantone did not have the storage facilities at his residence,
to store all units provided by Christensen.  Pantone took
approximately 230 of the units and requested that Christensen store
the remainder, until Pantone returned from the Idaho show.
>  10.  Pantone promised to pay for the production in full upon his
return from Idaho, claiming that he would be able to sell or take
orders at the show sufficient to pay for the manufactured units.
>  11.  Upon Pantone's return, Pantone explained that he was only
able to sell 4 or 5 of the units, and tried to return them to
Christensen.  Christensen had no use for the units, but offered to
store them until Pantone was able to sell them.
>  12. Commencing in February, 2000, Pantone explained that his
company was undergoing some management changes, and that his wife
Molley had just left him, which made it difficult to concentrate on
his work. Pantone requested that Christensen have patience and
continue to work with Pantone, and that Christensen would be more
then compensated as soon as these problems were resolved.
>  13.  Pantone requested that Christensen continue to store the
reaction chambers all ready manufactured, but also requested other
product and asked that Christensen ship them to designated customers
as provided by Pantone. These products were to be shipped under the
GEET logo, and  Christensen would be paid upon receipt of funds.
>  14.  Christensen complied with Pantone's request, providing
Pantone with invoices for all product produced and shipped.
>  15.  Shortly thereafter Pantone moved his operations to Colorado
to attempt to reconcile with his wife.  Pantone requested that
Christensen continue to manufacture and ship product as ordered.
>  16.  Christensen produced and shipped approximately $50,000.00 in
product of which $15,000.00 has been received.
>  17.  In May of 2000, Christensen received a telephone call from
Pantone claiming that he was at the Exotic Research Conference being
held in Arizona. Pantone explained that the promoter of the
conference had disappeared and was not honoring his guarantee to make
payment to the Hotel causing Pantone and his group to be locked out
of their Hotel rooms and the Exhibit Hall.
>  18.  Pantone requested that Christensen let Pantone use his credit
card in order to get his belongings, and promised repayment within 3
days, and Christensen agreed.
>  19.  Pantone used Christensen's credit card, taking care of his
bill, to which Christensen agreed to, but then Pantone also used the
credit card to pay the bills of several others that were in the same
situation at the conference, but without the permission of
Christensen.
>  20.  Pantone placed about $5,000.00 on the credit card, but has
yet to reimburse Christensen for that amount.
>  21.  During the summer of 2000, Christensen received a telephone
call from Pantone claiming that he was in jail again, in Colorado,
for violating a court order relating to domestic violence charges,
and that he needed assistance in posting the bail of $1,000.00.
>  22.  Pantone promised that if Christensen would post the bail it
would be paid back within 1 week.
>  23.  Christensen used one of his credit cards, and had the bail
posted, but has not been reimbursed.
>  24. A few weeks later, Christensen received another similar
telephone call, Pantone was again in jail, for violating a court
order and needed bail posted in the amount of $1,500.00, and would
reimburse Christensen as soon as possible.
>  25.  Christensen again posted bail, but has not been reimbursed.
>  26.  A few weeks after being arrested, Pantone again contacts
Christensen by way of telephone, and requests that Christensen assist
him to getting out of Colorado, as Pantone claimed he was allowed to
leave the state, but was afraid that the authorities were after him,
and needed to get away. Pantone promised to reimburse Christensen for
all costs incurred to get him out of Colorado.
>  27.  Christensen made the necessary arrangements, renting a moving
van, obtaining and paying the wages of two men to drive to Pantone's
location and return him to Salt Lake. Christensen incurred a cost in
excess of $2,000.00 which remains unpaid.
>  28.  Upon Pantone's return to Utah, Pantone approached Christensen
and offered Christensen the GEET distributorship for Utah as partial
compensation for Christensen's assistance.
>  29.  Christensen subsequently discovered that Pantone had all
ready sold the distributorship rights to Utah to 2 other individuals
whose distributorship rights were never taken away.
>  30.  When Pantone returned he approached Christensen and produced
information that Pantone had received requests from over 250
individuals that wanted training in the GEET technology, and that he
had several that were ready to start immediately, at a suggested
training price of $1,500.00.
>  31.  Pantone suggested that Christensen could run the school to be
called GEET International Institute, and that Christensen would be
reimbursed out of the tuition, so long as a portion would go to
Pantone.  The parties agreed to initially charge $1,200.00 as the
tuition.
>  32.  Pantone stated that he had confirmation of 30 students, but
needed the school ready by August 7, 2000.
>  33. Christensen borrowed the funds necessary to obtain a suitable
place for the school, to obtain the necessary school supplies and
have the needed support staff in order to run the school. Christensen
incurred a debt of approximately $26,000.00 to have the school ready
by August 7, 2000 as demanded by Pantone.
>  34.  On August 7, 2000, no student showed up.
>  35.  Since that date, the GEET International Institute has had 12
students.
>  36.  Of these 12 students only 3 paid tuition, 8 of the remainder
were students that agreed to attend the school as a set off for
monies previously given to Pantone for product that was not received.
>  37. The school was shut down in December 2000, as there were no
students, no monies were raised to support the school, and the
promises of students did not materialize.
> 38.  As part of the instruction, it was the intent to demonstrate
to the students how the GEET technology worked.  Christensen on
several occasions requested that Pantone come to the school to
implement the technology on some of the engines there that would meet
the claims as made by Pantone.
> 39. A demo engine was provided, but did not burn all the fuel as
promised, likewise a genset was provided, but this was not able to
run at full power.
> 40. When asked to remedy the problem, Pantone explained that it had
been sabotaged by previous employees, and recommended that
Christensen make the repairs.
> 41.  While at the school. Pantone made several purchases on behalf
of the school that were charged to Christensen.  These included
without limitation costs for parts and equipment, acquired under the
guise of testing the technology, but did not produce anything
noteworthy.
> 42.  Christensen subsequently was introduced to other individuals
who were in the process of developing energy reduction processes that
were significantly different that that of Pantone, and appears to
have a future. Christensen is presently working with this group.
> 43.  Christensen has since entered into a business relationship
with these other individuals, but has not made any development on the
ineffective GEET technology.
> FIRST CAUSE OF ACTION
> Breach of Contract - Reaction Chambers
> 44.  Christensen incorporates by this reference paragraphs 1
through 43 of this complaint as if set forth in full herein.
> 45.  In February 2000, Pantone contracted with Christensen for the
delivery of 500 specially made reaction chambers for $14,000.00.
>  46.  Christensen delivered said reaction chambers, and after
making some minor changes were approved and accepted by Pantone.
>  47.  Demand for payment on these reaction chambers has been made,
but defendants and each of them refuse to pay as agreed.
> 48. These reaction chambers have no value to Christensen, except as
scrap.
> 49. Christensen has been damaged in an amount in excess of
$14,000.00.
> SECOND CAUSE OF ACTION
> Breach of Contract - Shipping
>  50.  Christensen incorporates by this reference paragraphs 1
through 50 of this complaint as if set forth in full herein
>  51.  In February and thereafter Pantone contracted with
Christensen to provide the shipping of GEET products.  Pantone agreed
to reimburse Christensen for all costs involved.
>  52.  Christensen incurred costs, including but not limited to
storage fees, supplies, outside labor, materials etc., in an amount
in excess of $50,000, or which $15,000.00 has been paid.
>  53.  Christensen has made demand for payment of the remainder, but
such demand has not been met.
> 54.  Christensen has been damaged by way of this breach of contract
in an amount top be proven at time of trial.
> THIRD CAUSE OF ACTION
> Breach of Contract - Conference Loan
>
> 55.  Christensen incorporates by this reference paragraphs 1
through 54 of this complaint as if set forth in full herein.
>  56.  In  May Pantone requested that Christensen loan Pantone
sufficient funds so that Pantone and other of the defendants would be
able to retrieve their belongings and finish the exhibit at the
Exotic Research Conference in Arizona.
> 57.  Christensen allowed Pantone to use Christensen's credit card
upon Pantone's promise to repay the amount needed within 3 days.
>  58.  Pantone charged approximately $ 5,000.00 on Christensen's
credit card.
>  59.  Christensen has demanded payment as agreed, but Pantone
continues to refuse to make payment.
>  60.  Christensen's credit card carries a monthly interest rate,
and Christensen has been damaged in an amount to be proven at time of
trial.
> //
> //
>
> FOURTH CAUSE OF ACTION
> Breach of Contract - First Bail
>  61. Christensen incorporates by this reference paragraphs 1
through 60 of this complaint as if set forth in full herein.
>  62.  In the summer of 2000, Pantone contacted Christensen and
requested a loan in the amount of $1,000.00 in order to bail Pantone
out of jail. Pantone promised payment within 2 weeks.
>  63.  Christensen made the arrangements and had $ 1,000.00 bail
posted on Pantone's account.
>  64.  Christensen has made demand for reimbursement for the
$1,000.00. but payment has not been received.
> 65. Christensen has been damaged in the amount of $1,000.
> FIFTH CAUSE OF ACTION
> Breach of Contract - Second Bail
>  66. Christensen incorporates by this reference paragraphs 1
through 65 of this complaint as if set forth in full herein.
>  67.  In the summer of 2000, Pantone contacted Christensen and
requested a loan in the amount of $1,500.00 in order to bail Pantone
out of jail another time. Pantone promised payment as soon as he got
out.
>  68.  Christensen made the arrangements and had $ 1,500.00 bail
posted on Pantone's account.
>  69.  Christensen has made demand for reimbursement for the
$1,500.00. but payment has not been received.
>  70.  Christensen has been damaged in the amount of $1,500.00.
> SIXTH CAUSE OF ACTION
> Breach of Contract - Loan for Utilities
>  71. Christensen incorporates by this reference paragraphs 1
through 70 of this complaint as if set forth in full herein.
>  72.  During the summer of 2000, Christensen received a telephone
call from Pantone who stated that his utilities, telephone and
satellite usage was about to be cut-off because of non-payment.
>  73.  Pantone requested a loan for $1,600.00 which Pantone promised
to pay within 1 week.
>  74.  Based on Pantone's promise to pay, Christensen arranged to
have these bills paid for on behalf of Pantone.
>  75.  Christensen has made demand for reimbursement, but has not
received repayment for this loan.
> 76.  Christensen has been damaged in an amount to be shown at time
of trial, but ion excess of $1,600.00.
> SEVENTH CAUSE OF ACTION
> Breach of Contract - Moving Expense
>
>  77.  Christensen incorporates by this reference paragraphs 1
through 76 of this complaint as if set forth in full herein.
>  78.  At the end of the summer of 2000, Pantone contacted
Christensen by telephone, stating that he needed to get out of
Colorado, and requested Christensen's financial assistance.
>  79.  Pantone represented that there was nothing requiring him to
remain, that he had cleared it with Teller County to be allowed to
leave, but needed his assistance.
>  80.  Christensen arranged to have a moving van rented, acquired
that services of 2 men to drive to Pantone's location, assist in
bringing Pantone's belongings back to Utah, and paid for food and gas
for the trip.
>  81.  Pantone promised to reimburse Christensen for all costs
incurred, which expenses were in excess of $2,000.00.
> 82.  Christensen has made demand for reimbursement of these
expenses, but has not been paid.
>  83.  Christensen has been damaged in the amount to be proven at
time of trial.
> EIGHTH CAUSE OF ACTION
> Fraud
>
>  84.  Christensen incorporates by this reference paragraphs 1
through 83 of this complaint as if set forth in full herein.
>  85.  Pantone represented to Christensen that he had 250 students
that had confirmed their interest in being trained in GEET technology.
>  86.  Pantone requested that Christensen run the school and be
compensated through the tuition that was received.
>  87.  At the time Pantone made these representations Pantone knew
that he did not have 250 students that had confirmed their interest.
>  88.  Pantone also knew that Christensen would rely on Pantone's
representations and incur substantial debt in order to prepare the
school.
> 89.Christensen did rely on Pantone's representations, to
Christensen's detriment, incurring substantial costs in excess of
$26,000.00.
>  90.  As a direct and proximate cause of Pantone's fraudulent
statement Christensen has been damaged in an amount to be proven at
time of trial.
> 91.  Pantone's and cross-defendants conduct was willful, malicious
and in reckless disregard of Christensen's rights.  Christensen is
there entitled to punitive damages in an amount to be proven at time
of trial.
> NINTH CAUSE OF ACTION
> Misrepresentation
>
>  92.  Christensen incorporates by this reference paragraphs 1
through 91 of this complaint as if set forth in full herein.
>  93.  Pantone on several occasions described his technology as
effective and functioning.
> 94.  Pantone and the other defendants made several representations
as to the increased fuel efficiency and reduction in pollution.
> 95.  Representations were made by cross-defendants and each of them
that this technology was developed by Pantone, and that he was
experienced in its implementation.
>  96. Pantone intentionally and knowingly represented that the GEET
device was close to complete and ready for full-scale production.
>  97.  Pantone represented that the GEET device worked in many
applications when Pantone knew that these applications had not been
completed.
> 98.  Pantone made these representations, with the intent to induce
Christensen to rely on Pantone's assurances and invest funds to
Pantone's scheme, with the Pantone promise that the devise would,
with a minimal amount of effort, be ready for production.
>
>  99.  Pantone failed to inform Christensen of Pantone's lack of
knowledge of how to complete the device, and how Pantone required the
assistance of others to complete the process.
>  100. As a direct and proximate result of Pantone's
misrepresentation, Christensen did invest substantial time of funds
to Pantone's scheme.
>  101. As a direct and proximate result of Pantone's
misrepresentation, Christensen has been damaged in an amount to be
proven at time of trial.
> 102.  Pantone's conduct was willful, malicious, and in reckless
disregard of Christensen's rights.  Christensen is therefore entitled
to punitive damages in an amount to be proven at time of trial.
> PRAYER FOR RELIEF
>  WHEREFORE, Christensen demands judgment against plaintiffs and
cross-defendants as follows:
>  A.  Judgment in favor of Christensen in an amount to be proven at
time of trial on the First, Second, Third, Fourth Fifth, Sixth,
Seventh, Eighth and Ninth Causes of Action, together with interest at
the statutory rate.
>  B.  Punitive Damages in Christensen's Eighth and Ninth Causes of
Action, in an amount to be determined at trial, and
>  C.  Interest, reasonable attorney fees, and such other relief as
the Court deems appropriate
>  Dated: this ____ day of February, 2001.
>
>  _____________________________
>  M. Del Christensen
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>    CERTIFICATE OF SERVICE
> I hereby certify that I am a not a party to this action.  My
business address is:  3270 South 11 West, Building 400 salt Lake
City, Utah 84119 .  A true and correct copy of the above and
foregoing:
>   ANSWER TO COMPLAINT AND CROSS-COMPLAINT
> was mailed via United States Mail, postage prepaid. to the
following at their address as shown below,
> Robert E. Mansfield
> Todd D. Weiler
> Parry, Anderson & Mansfield
> 1270 Eagle Gate Tower
> 60 East South Temple
> Salt Lake City, Utah 84111
>
>  this ___ of ______, 2001.
>
>
> _____________________________________

Lessons for company bashing;

Lesson 1: Remember, BASHERS NEVER Bash A BAD Person or Company.
Check the websites for People or companies with no potential. They never
have
any Bashers. Bashers only go after People or companies that are moving up or
have excellent potential to do so. Bashers work to bring the person or
company values down to either increase their position at the expense of
others or help others to steal the identity or company.  Sometimes they bash
because they are jealous of the other persons success.

(Bottom of GEET.com website)

M. Del Christensen
3270 South 1100 West # 400
Salt Lake City, Utah 84119
Tele: (801) 973-4391

In Propria Persona

 IN THE UNITED STATES DISTRICT COURT
FOR THE STATE OF UTAH
CENTRAL DIVISION
_____________________________________________________________________________________
)
GEET INTERNATIONAL INC., a Nevada )
Corporation, PAUL PANTONE, an              ) DEFENDANT M. DEL
individual, MOLLEY PANTONE, an            ) CHRISTENSEN ANSWER
individual,                                                     ) TO PLAINTIFF'S COMPLAINT
Plaintiffs )
                       ) CASE NO: 2:01CV0014 B
vs.                                                                 )    
) Judge Benson
M. DEL CHRISTENSEN, an individual,       )
PAUL  NOBEL, an individual, KERRY        )
 MCMULLAN an individual, MICHELLE    )MCMULLAN, an individual, JASON KIM )
an individual, STEVEN L. MITCHELL, an  )
individual, D.L. HOLDER, an individual, AL )
AL TOTH, an individual, BOB COLVIN, an)    
individual, G.E.E.T. of UTAH LLC, a Utah  )
Limited Liability Company, GEET OF  )
MARYLAND, a Maryland Corporation,  )
GEET OF COLORADO, a Colorado   )
Corporation, JAY MCMULLAN, an  )
individual, TOM BERRY, an individual,  )
WENDY COLLARD, an individual, and  )
GEET INTERNATIONAL INSTITUTE  a )
dba of GEET of Utah, LLC )
)
Defendants )
__________________________________________________________________________
)
M. DEL CHRISTENSEN, an individual        ) COUNTER-COMPLAINT
)
Cross-complainant )
vs. )
)
PAUL PANTONE, an individual, MOLLEY )
PANTONE, an individual, G.E.E.T.  )
INTERNATIONAL, INC., a Nevada  )
Corporation, GEET BUSINESS TRUST,  )
PAUL PANTONE TRUST, PANTONE )
FAMILY TRUST, and DOES I through X )
inclusive, )
)
Cross-defendants )
__________________________________________________________________________

Comes now defendant M. Del Christensen (defendant), on his own behalf and answers plaintiffs' complaint as follows:
PARTIES, JURISDICTION AND VENUE
1.  Defendant admits the allegations set forth in paragraphs 3, 19, 20 and 21 of plaintiff's complaint.
2.  Due to a lack of sufficient information defendant denies the allegations set forth 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, and 16 of plaintiff's complaint.
3.  As to the allegations set forth in paragraph 17 of plaintiff complaint, defendant admits that GEET of Utah LLC has its principle place of business in Salt Lake City, and is a registered limited liability company in Utah.  Defendant denies all other allegations set forth in this paragraph.
4. As to the allegations set forth in paragraph 18 of plaintiff complaint, defendant admits that GEET international Institute had its principle place of business in Salt Lake City.  Defendant denies all other allegations set forth in this paragraph.
//
GENERAL ALLEGATIONS
5.   Defendant admits the allegations set forth in paragraphs 25, 31, 38, 43, 51, 65, and 67 of plaintiff's complaint.
6.  Due to a lack of sufficient information defendant denies the allegations set forth 23, 24, 26, 27, 28, 34, 47, 58 and 72 of plaintiff's complaint.
7.  Defendants deny the allegations set forth in paragraphs 22, 29, 30, 32, 33, 35, 36, 37, 39, 40, 41, 42, 44, 45, 46, 48, 49, 50, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 66, 68, 69, 70, 71, 73, 74, 75, and 76 of plaintiff's complaint.
FIRST CAUSE OF ACTION
8.  Defendant incorporates by reference paragraphs 1 through 7 of his Answer as if set forth in full herein.
9.  Due to a lack of sufficient information, defendant denies the allegations set forth in paragraphs 77, 78, and 79 of plaintiff's complaint.
10.  Defendant denies the allegations set forth in paragraphs 80, 81, 82, 83, 84 and 85 of plaintiff's complaint.
SECOND CAUSE OF ACTION
11.  Defendant incorporates by reference paragraphs 1 through 10 of his Answer as if set forth in full herein.
12.  Defendant denies the allegations set forth in paragraphs 86, 87, 88, 89, 90, 91, and 92 of plaintiff's complaint.
THIRD CAUSE OF ACTION
11.  Defendant incorporates by reference paragraphs 1 through 12 of his Answer as if set forth in full herein.
13.  Defendant denies the allegations set forth in paragraphs 93, 94, 95, 96, 97, and 98 of

plaintiff's complaint.

FOURTH CAUSE OF ACTION
14.  Defendant incorporates by reference paragraphs 1 through 13 of his Answer as if set forth in full herein.
15.  Defendant denies the allegations set forth in paragraphs 99. 100, 101, 102, 103, 104, and  105 of plaintiff's complaint.
FIFTH CAUSE OF ACTION
16.  Defendant incorporates by reference paragraphs 1 through 15 of his Answer as if set forth in full herein.
17.  Defendant admits the allegations in paragraph 110, that he currently possesses property belonging to plaintiff, defendant further states that he has requested that plaintiff remove said property but has failed to do so.
18.  Defendant denies the allegations set forth in paragraphs 106, 107, 108, 109, 111, and 112  of plaintiff's complaint.
SIXTH CAUSE OF ACTION
19.  Defendant incorporates by reference paragraphs 1 through 18 of his Answer as if set forth in full herein.
20.  Defendant denies the allegations set forth in paragraphs 113, 114, 115, 116, 117, 118, and 119 of plaintiff's complaint.
SEVENTH CAUSE OF ACTION
21.  Defendant incorporates by reference paragraphs 1 through 20 of his Answer as if set forth in full herein.
22.  Defendant denies the allegations set forth in paragraphs 120, 121, 122, and 123 of

plaintiff's complaint.
EIGHTH CAUSE OF ACTION
23.  Defendant incorporates by reference paragraphs 1 through 22 of his Answer as if set forth in full herein.
24.  Defendant denies the allegations set forth in paragraphs 124, 125, 126, 127, 128, and 129 of plaintiff's complaint.
NINTH CAUSE OF ACTION
25.  Defendant incorporates by reference paragraphs 1 through 24 of his Answer as if set forth in full herein.
26.  Defendant denies the allegations set forth in paragraphs 130, 131, 132, 133, and 134 of plaintiff's complaint.
TENTH CAUSE OF ACTION
27.  Defendant incorporates by reference paragraphs 1 through 26 of his Answer as if set forth in full herein.
28.  Defendant denies the allegations set forth in paragraphs 135, 136, 137, 138, and 139 of plaintiff's complaint.
ELEVENTH CAUSE OF ACTION
29.  Defendant incorporates by reference paragraphs 1 through 28 of his Answer as if set forth in full herein.
30.  Defendant denies the allegations set forth in paragraphs 140, 141, 142, and 143 of plaintiff's complaint.
TWELFTH CAUSE OF ACTION
31.  Defendant incorporates by reference paragraphs 1 through 30 of his Answer as if set forth in full herein.
32.  Defendant denies the allegations set forth in paragraphs 144, 145, 146, 147, 148, 149, 150 and 151 of plaintiff's complaint.
THIRTEENTH CAUSE OF ACTION
33.  Defendant incorporates by reference paragraphs 1 through 32 of his Answer as if set forth in full herein.
34.  Defendant denies the allegations set forth in paragraphs 152, 153, 154 and 155 of plaintiff's complaint.
FOURTEENTH CAUSE OF ACTION
35.  Defendant incorporates by reference paragraphs 1 through 34 of his Answer as if set forth in full herein.
36.  Defendant denies the allegations set forth in paragraphs 157, 158 and 159 of plaintiff's complaint.
THEREFORE this answering defendant prays for judgment as follows:
1. That plaintiffs receive nothing by way of their complaint,
2. For cost of suit herein;
//
3. For such other and further relief as the Court may deem proper.

Dated: February  ____, 2001                        ______________________________
M. Del Christensen

FIRST AFFIRMATIVE DEFENSE
As for a  FIRST SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, this answering defendant alleges that the alleged Causes of Actions as set forth in plaintiffs' Complaint fail to state facts sufficient to constitute any cause of action against this answering defendant.
     SECOND AFFIRMATIVE DEFENSE
As a SECOND SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that plaintiffs  have failed to mitigate their damages, if any have in fact been suffered.
     THIRD AFFIRMATIVE DEFENSE
As a THIRD SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to plaintiffs EIGHTH Cause of Action set forth therein, this answering defendant alleges and avers that Truth is an absolute defense.
FOURTH AFFIRMATIVE DEFENSE
As a FOURTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that plaintiffs  claims are barred by the plaintiffs breaches of the covenant of good faith and fair dealing.             
FIFTH AFFIRMATIVE DEFENSE
As a FIFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that plaintiff breached the contract alleged within the complaint, and plaintiffs claims are therefore barred.
SIXTH AFFIRMATIVE DEFENSE
As a SIXTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that to the extent plaintiffs have any claims for damages, which claim is expressly denied, defendant is entitled to an offset against plaintiff in the amount of damages incurred by defendant as a result of plaintiffs' breaches of duty, failure to perform as promised and other wrongful acts as set forth in the Counter-claim herein.
SEVENTH AFFIRMATIVE DEFENSE
As a SEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that plaintiffs claims are barred by the doctrine of unclean hands.
EIGHTH AFFIRMATIVE DEFENSE
As an EIGHTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that plaintiffs damages, if any, were proximately caused by third parties over whom defendant had no control, and defendant cannot be held liable for such damages.
NINTH AFFIRMATIVE DEFENSE
As a NINTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that defendant is entitled to his reasonable attorney's fees and cost incurred herein because plaintiff's claims against defendant were filed in bad faith, are without merit.
TENTH AFFIRMATIVE DEFENSE
As a TENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that plaintiffs complaint is barred in whole or in part by the negligent and/or other wrongful conduct of plaintiff and/or its agents.
ELEVENTH AFFIRMATIVE DEFENSE
As an ELEVENTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that plaintiff's damage, if any, were proximately and solely caused by plaintiff.
TWELFTH AFFIRMATIVE DEFENSE
As a TWELFTH SEPARATE AND AFFIRMATIVE DEFENSE to plaintiffs' Complaint, and to  each Cause of Action set forth therein, this answering defendant alleges and avers that plaintiffs claim is barred by the fact that plaintiff's patent is defective, as is defendants alleged technology as plaintiffs are unable to produce an effective devise that will produce the results as promised by plaintiffs.
COUNTER CLAIM
Cross-Complainant M. Del Christensen (Christensen), complains against plaintiff and each of them as follows:
BACKGROUND AND HISTORY
1. In October 1999, Christensen received information in regards to the development of an energy saving technology, to which cross-complainant investigated and met with cross-defendant Paul Pantone (Pantone).  Christensen was allowed to observe some of the devises created under the direction of Pantone at the then business location for GEET Management LLC located in Salt Lake City, Utah.
2. Christensen expressed an interest in the technology, and Pantone requested that Christensen prepare prototype "reaction chambers" based on specifications provided by Pantone. Christensen
 3.  Christensen quoted a price to prepare said prototypes for $1,500.00, which amount was agreed to be acceptable by Pantone.
 4.  Within 2 weeks of this agreement, on or about the end of October, Christensen delivered 7 prototype reaction chambers, to Pantone, which Pantone accepted as satisfactory.  Pantone was only able to pay $1,000.00 but promised the remainder shortly.
 5.  Pantone was satisfied with the product, so much so that Pantone ordered an additional 500 of the units, to be at various sizes, stating that Pantone needed these to sell at a show in Idaho that Pantone was to attend. Pantone agreed to an estimated price of $14,000.00
 6.  Within 5 weeks of receiving this order, and within the time frame as required by Pantone, Christensen delivered the 500 units to Pantone, and provided an invoice for $14,000.00.
 7.  Pantone had some concerns over some of the units provided, so Christensen had some of his employees of his make the necessary revisions, and produced the units to Pantone's satisfaction.
 8.  These prototypes were specially manufactured, to the specifications provided by Pantone, and were not useable in any other application except as to meet Pantone's purposes.
 9.  Pantone did not have the storage facilities at his residence, to store all units provided by Christensen.  Pantone took approximately 230 of the units and requested that Christensen store the remainder, until Pantone returned from the Idaho show.
 10.  Pantone promised to pay for the production in full upon his return from Idaho, claiming that he would be able to sell or take orders at the show sufficient to pay for the manufactured units.
 11.  Upon Pantone's return, Pantone explained that he was only able to sell 4 or 5 of the units, and tried to return them to Christensen.  Christensen had no use for the units, but offered to store them until Pantone was able to sell them. 
 12. Commencing in February, 2000, Pantone explained that his company was undergoing some management changes, and that his wife Molley had just left him, which made it difficult to concentrate on his work. Pantone requested that Christensen have patience and continue to work with Pantone, and that Christensen would be more then compensated as soon as these problems were resolved.
 13.  Pantone requested that Christensen continue to store the reaction chambers all ready manufactured, but also requested other product and asked that Christensen ship them to designated customers as provided by Pantone. These products were to be shipped under the GEET logo, and  Christensen would be paid upon receipt of funds.
 14.  Christensen complied with Pantone's request, providing Pantone with invoices for all product produced and shipped.
 15.  Shortly thereafter Pantone moved his operations to Colorado to attempt to reconcile with his wife.  Pantone requested that Christensen continue to manufacture and ship product as ordered.
 16.  Christensen produced and shipped approximately $50,000.00 in product of which $15,000.00 has been received.
 17.  In May of 2000, Christensen received a telephone call from Pantone claiming that he was at the Exotic Research Conference being held in Arizona. Pantone explained that the promoter of the conference had disappeared and was not honoring his guarantee to make payment to the Hotel causing Pantone and his group to be locked out of their Hotel rooms and the Exhibit Hall.
 18.  Pantone requested that Christensen let Pantone use his credit card in order to get his belongings, and promised repayment within 3 days, and Christensen agreed.
 19.  Pantone used Christensen's credit card, taking care of his bill, to which Christensen agreed to, but then Pantone also used the credit card to pay the bills of several others that were in the same situation at the conference, but without the permission of Christensen.
 20.  Pantone placed about $5,000.00 on the credit card, but has yet to reimburse Christensen for that amount.
 21.  During the summer of 2000, Christensen received a telephone call from Pantone claiming that he was in jail again, in Colorado, for violating a court order relating to domestic violence charges, and that he needed assistance in posting the bail of $1,000.00.
 22.  Pantone promised that if Christensen would post the bail it would be paid back within 1 week.
 23.  Christensen used one of his credit cards, and had the bail posted, but has not been reimbursed.
 24. A few weeks later, Christensen received another similar telephone call, Pantone was again in jail, for violating a court order and needed bail posted in the amount of $1,500.00, and would reimburse Christensen as soon as possible.
 25.  Christensen again posted bail, but has not been reimbursed.
 26.  A few weeks after being arrested, Pantone again contacts Christensen by way of telephone, and requests that Christensen assist him to getting out of Colorado, as Pantone claimed he was allowed to leave the state, but was afraid that the authorities were after him, and needed to get away. Pantone promised to reimburse Christensen for all costs incurred to get him out of Colorado.
 27.  Christensen made the necessary arrangements, renting a moving van, obtaining and paying the wages of two men to drive to Pantone's location and return him to Salt Lake. Christensen incurred a cost in excess of $2,000.00 which remains unpaid.
 28.  Upon Pantone's return to Utah, Pantone approached Christensen and offered Christensen the GEET distributorship for Utah as partial compensation for Christensen's assistance.
 29.  Christensen subsequently discovered that Pantone had all ready sold the distributorship rights to Utah to 2 other individuals whose distributorship rights were never taken away.
 30.  When Pantone returned he approached Christensen and produced information that Pantone had received requests from over 250 individuals that wanted training in the GEET technology, and that he had several that were ready to start immediately, at a suggested training price of $1,500.00.
 31.  Pantone suggested that Christensen could run the school to be called GEET International Institute, and that Christensen would be reimbursed out of the tuition, so long as a portion would go to Pantone.  The parties agreed to initially charge $1,200.00 as the tuition.
 32.  Pantone stated that he had confirmation of 30 students, but needed the school ready by August 7, 2000.
 33. Christensen borrowed the funds necessary to obtain a suitable place for the school, to obtain the necessary school supplies and have the needed support staff in order to run the school. Christensen incurred a debt of approximately $26,000.00 to have the school ready by August 7, 2000 as demanded by Pantone.
 34.  On August 7, 2000, no student showed up.
 35.  Since that date, the GEET International Institute has had 12 students.
 36.  Of these 12 students only 3 paid tuition, 8 of the remainder were students that agreed to attend the school as a set off for monies previously given to Pantone for product that was not received.
 37. The school was shut down in December 2000, as there were no students, no monies were raised to support the school, and the promises of students did not materialize.
38.  As part of the instruction, it was the intent to demonstrate to the students how the GEET technology worked.  Christensen on several occasions requested that Pantone come to the school to implement the technology on some of the engines there that would meet the claims as made by Pantone.
39. A demo engine was provided, but did not burn all the fuel as promised, likewise a genset was provided, but this was not able to run at full power.
40. When asked to remedy the problem, Pantone explained that it had been sabotaged by previous employees, and recommended that Christensen make the repairs. 
41.  While at the school. Pantone made several purchases on behalf of the school that were charged to Christensen.  These included without limitation costs for parts and equipment, acquired under the guise of testing the technology, but did not produce anything noteworthy.
42.  Christensen subsequently was introduced to other individuals who were in the process of developing energy reduction processes that were significantly different that that of Pantone, and appears to have a future. Christensen is presently working with this group.   
43.  Christensen has since entered into a business relationship with these other individuals, but has not made any development on the ineffective GEET technology.
FIRST CAUSE OF ACTION
Breach of Contract - Reaction Chambers
44.  Christensen incorporates by this reference paragraphs 1 through 43 of this complaint as if set forth in full herein.
45.  In February 2000, Pantone contracted with Christensen for the delivery of 500 specially made reaction chambers for $14,000.00.
 46.  Christensen delivered said reaction chambers, and after making some minor changes were approved and accepted by Pantone.
 47.  Demand for payment on these reaction chambers has been made, but defendants and each of them refuse to pay as agreed.
48. These reaction chambers have no value to Christensen, except as scrap.
49. Christensen has been damaged in an amount in excess of $14,000.00.
SECOND CAUSE OF ACTION
Breach of Contract - Shipping
 50.  Christensen incorporates by this reference paragraphs 1 through 50 of this complaint as if set forth in full herein
 51.  In February and thereafter Pantone contracted with Christensen to provide the shipping of GEET products.  Pantone agreed to reimburse Christensen for all costs involved.
 52.  Christensen incurred costs, including but not limited to storage fees, supplies, outside labor, materials etc., in an amount in excess of $50,000, or which $15,000.00 has been paid. 
 53.  Christensen has made demand for payment of the remainder, but such demand has not been met.
54.  Christensen has been damaged by way of this breach of contract in an amount top be proven at time of trial.
THIRD CAUSE OF ACTION
Breach of Contract - Conference Loan

55.  Christensen incorporates by this reference paragraphs 1 through 54 of this complaint as if set forth in full herein.  
 56.  In  May Pantone requested that Christensen loan Pantone sufficient funds so that Pantone and other of the defendants would be able to retrieve their belongings and finish the exhibit at the Exotic Research Conference in Arizona.
57.  Christensen allowed Pantone to use Christensen's credit card upon Pantone's promise to repay the amount needed within 3 days.
 58.  Pantone charged approximately $ 5,000.00 on Christensen's credit card.
 59.  Christensen has demanded payment as agreed, but Pantone continues to refuse to make payment.
 60.  Christensen's credit card carries a monthly interest rate, and Christensen has been damaged in an amount to be proven at time of trial.
//
//

FOURTH CAUSE OF ACTION
Breach of Contract - First Bail
 61. Christensen incorporates by this reference paragraphs 1 through 60 of this complaint as if set forth in full herein.   
 62.  In the summer of 2000, Pantone contacted Christensen and requested a loan in the amount of $1,000.00 in order to bail Pantone out of jail. Pantone promised payment within 2 weeks.
 63.  Christensen made the arrangements and had $ 1,000.00 bail posted on Pantone's account.
 64.  Christensen has made demand for reimbursement for the $1,000.00. but payment has not been received.
65. Christensen has been damaged in the amount of $1,000.
FIFTH CAUSE OF ACTION
Breach of Contract - Second Bail
 66. Christensen incorporates by this reference paragraphs 1 through 65 of this complaint as if set forth in full herein.   
 67.  In the summer of 2000, Pantone contacted Christensen and requested a loan in the amount of $1,500.00 in order to bail Pantone out of jail another time. Pantone promised payment as soon as he got out.
 68.  Christensen made the arrangements and had $ 1,500.00 bail posted on Pantone's account.
 69.  Christensen has made demand for reimbursement for the $1,500.00. but payment has not been received.
 70.  Christensen has been damaged in the amount of $1,500.00.
SIXTH CAUSE OF ACTION
Breach of Contract - Loan for Utilities
 71. Christensen incorporates by this reference paragraphs 1 through 70 of this complaint as if set forth in full herein.   
 72.  During the summer of 2000, Christensen received a telephone call from Pantone who stated that his utilities, telephone and satellite usage was about to be cut-off because of non-payment.
 73.  Pantone requested a loan for $1,600.00 which Pantone promised to pay within 1 week.
 74.  Based on Pantone's promise to pay, Christensen arranged to have these bills paid for on behalf of Pantone.
 75.  Christensen has made demand for reimbursement, but has not received repayment for this loan.
76.  Christensen has been damaged in an amount to be shown at time of trial, but ion excess of $1,600.00.
SEVENTH CAUSE OF ACTION
Breach of Contract - Moving Expense

 77.  Christensen incorporates by this reference paragraphs 1 through 76 of this complaint as if set forth in full herein.   
 78.  At the end of the summer of 2000, Pantone contacted Christensen by telephone, stating that he needed to get out of Colorado, and requested Christensen's financial assistance.
 79.  Pantone represented that there was nothing requiring him to remain, that he had cleared it with Teller County to be allowed to leave, but needed his assistance.
 80.  Christensen arranged to have a moving van rented, acquired that services of 2 men to drive to Pantone's location, assist in bringing Pantone's belongings back to Utah, and paid for food and gas for the trip.
 81.  Pantone promised to reimburse Christensen for all costs incurred, which expenses were in excess of $2,000.00.
82.  Christensen has made demand for reimbursement of these expenses, but has not been paid.
 83.  Christensen has been damaged in the amount to be proven at time of trial.
EIGHTH CAUSE OF ACTION
Fraud

 84.  Christensen incorporates by this reference paragraphs 1 through 83 of this complaint as if set forth in full herein.   
 85.  Pantone represented to Christensen that he had 250 students that had confirmed their interest in being trained in GEET technology.
 86.  Pantone requested that Christensen run the school and be compensated through the tuition that was received.
 87.  At the time Pantone made these representations Pantone knew that he did not have 250 students that had confirmed their interest.
 88.  Pantone also knew that Christensen would rely on Pantone's representations and incur substantial debt in order to prepare the school.
89.Christensen did rely on Pantone's representations, to Christensen's detriment, incurring substantial costs in excess of $26,000.00.
 90.  As a direct and proximate cause of Pantone's fraudulent statement Christensen has been damaged in an amount to be proven at time of trial.
91.  Pantone's and cross-defendants conduct was willful, malicious and in reckless disregard of Christensen's rights.  Christensen is there entitled to punitive damages in an amount to be proven at time of trial.
NINTH CAUSE OF ACTION
Misrepresentation

 92.  Christensen incorporates by this reference paragraphs 1 through 91 of this complaint as if set forth in full herein.   
 93.  Pantone on several occasions described his technology as effective and functioning.
94.  Pantone and the other defendants made several representations as to the increased fuel efficiency and reduction in pollution.
95.  Representations were made by cross-defendants and each of them that this technology was developed by Pantone, and that he was experienced in its implementation.
 96. Pantone intentionally and knowingly represented that the GEET device was close to complete and ready for full-scale production.
 97.  Pantone represented that the GEET device worked in many applications when Pantone knew that these applications had not been completed.
98.  Pantone made these representations, with the intent to induce Christensen to rely on Pantone's assurances and invest funds to Pantone's scheme, with the Pantone promise that the devise would, with a minimal amount of effort, be ready for production.

 99.  Pantone failed to inform Christensen of Pantone's lack of knowledge of how to complete the device, and how Pantone required the assistance of others to complete the process.
 100. As a direct and proximate result of Pantone's misrepresentation, Christensen did invest substantial time of funds to Pantone's scheme.
 101. As a direct and proximate result of Pantone's misrepresentation, Christensen has been damaged in an amount to be proven at time of trial.
102.  Pantone's conduct was willful, malicious, and in reckless disregard of Christensen's rights.  Christensen is therefore entitled to punitive damages in an amount to be proven at time of trial.
PRAYER FOR RELIEF
 WHEREFORE, Christensen demands judgment against plaintiffs and cross-defendants as follows:
 A.  Judgment in favor of Christensen in an amount to be proven at time of trial on the First, Second, Third, Fourth Fifth, Sixth, Seventh, Eighth and Ninth Causes of Action, together with interest at the statutory rate.
 B.  Punitive Damages in Christensen's Eighth and Ninth Causes of Action, in an amount to be determined at trial, and
 C.  Interest, reasonable attorney fees, and such other relief as the Court deems appropriate
 Dated: this ____ day of February, 2001.

 _____________________________
 M. Del Christensen

   CERTIFICATE OF SERVICE
I hereby certify that I am a not a party to this action.  My business address is:  3270 South 11 West, Building 400 salt Lake City, Utah 84119 .  A true and correct copy of the above and foregoing:
  ANSWER TO COMPLAINT AND CROSS-COMPLAINT
was mailed via United States Mail, postage prepaid. to the following at their address as shown below,
Robert E. Mansfield
Todd D. Weiler
Parry, Anderson & Mansfield
1270 Eagle Gate Tower
60 East South Temple
Salt Lake City, Utah 84111

 this ___ of ______, 2001.

_____________________________________

----- Original Message -----
Subject: Re: Site ABUSE
At 03:10 PM 1/28/2001 -0500,  wrote:
Below is the result of your feedback form. It was submitted by
(pms@...) on Sunday, January 28, 2001 at 15:10

name: Paul Pantone
Client: Prospective_Client
remarks: I need your help ASAP.

The party you serve at friend.ly.net/geet,  has caused severe damage
by this site.  He is only one of many whose sites were damaging us and are
now tied into a hostile takeover. My site www.geet.com, is the
official site of my company. I have posted a copy of the Federal Law Suit
filed against this party and others and some of the details are found in our
LETTERS section.  The damages are far into the millions and growing.

The slander and blatent lies, are causing more damage by the hour. My number
is 801-558-2425. Please advise me if you are removing this site as did
Yahoo, AOL, webjump, or is further action by my attorneys necessary.

Sincerely
Paul and Molley

----------------------------------------------------------------------------
--------------------

Dear Mr. Pantone

Thank you for the notification.  But at this time our subscriber has
the right to utilize his/her website space for anything except for
pornographic materials. If you can provide us with materials from your
attorney we can then review it and approach our client.  Ultimately, the
resolution is between you and our client.

Thanks

Rattana Chhay           Putting a Friend.lay face on the Internet
:-)Friendly Network Staff  Voice 410.643.4606 / Fax 410.643.4216

----------------------------------------------------------------------------
--------------------

At 06:20 PM 2/13/2001 -0700, Paul Pantone CEO GEET wrote:

----- Original Message -----
From: "Paul Pantone CEO GEET" <pms@...>
To: "Rattana Chhay" <Ratt@...>
Cc: "Robert E. Mansfield" <rmansfield@...>
(Paul's Lawyer)

Sent: Tuesday, February 13, 2001 6:14 PM
Subject: Re: Site ABUSE

  I again request you to shut down the site below which is causing damage to
MyFamily and My Company GEET International Corp.  At this time being able to
prove that you are willfully and intentionally, allowing this site to
continue, knowing full well that the allegations are not fact, but are in
fact, slanderous, hate crimes, defamation of character, and the list goes
on, would only stand to reason that you are nopw acting as an accomplice to
the crimes and actions against us. Your site of endorsement and support does
have to conform to FCC ruleings and said site is; www.friend.ly.net

My site is www.geet.com, and a copy of the first Federal filing is
found in the Letters section at the top of my site. We are preparing a
revised and ammended complaint, shall I list you as a Defendant?


Paul Pantone, CEO
Molley Pantone, CFO
GEET International Corp
801-558-2425

----------------------------------------------------------------------------
--------------------

-----Original Message-----
From: mary@... <mary@...>
To: Paul Pantone CEO GEET <pms@...>;
staff@... <staff@...>
Date: Wednesday, February 14, 2001 10:31 AM
Subject: Re: Fw: Site ABUSE


Dear Mr. Pantone,

I went to www.geet.com and clicked on the letters link and saw no copy of
the Federal Filing.  Perhaps I overlooked it.  Can you send me the fully
qualified URL to this page for our review?

We are a ethical organization and in no way endorse "slanderous, hate
crimes, defamation of character" of ANY individual or organization; however,
Mr. Colvin has the right to choose what information he shares on his web
page without ever having to consult with Friendly Network, so long as it is
not pornographic in nature.  Furthermore, Friendly Network took no part in
the creation of any of these pages and have provided no such information to
our subscriber.

I have no way of knowing what is truth or fact in this situation; this is a
conflict between your organization and Mr. Colvin.  We have sent Mr. Colvin
an e-mail encouraging him to resolve this issue with you; however, as we
have written to you, our subscribers are free to post any information they
wish under their web space so long as it is not pornographic in nature.
Friendly Network is not responsible for the data posted by our subscribers.
If there is a court order, that will of course override our agreement with
our subscriber.  Anything less than that, then we must honor our agreement
with Mr. Colvin.

Sincerely,


Mary Chhay
410.643.4606 / 410.643.4216 fax
(-: putting a Friend.ly Face on the Internet :-)

Chad,

I am very happy to see that you have started this group. We must
continue to do all we can to see that nobody else is caught up in
Pantone's wicked scam. You deserve a big ol' kiss!

Karen Snow
Chicago

Let's shut this con man down!        Kerry McMullan
_________________________________________________________________
Get your FREE download of MSN Explorer at http://explorer.msn.com

YAHOO!!!

   We would like to thank the web servers from Yahoo, Webjump,
   Freeservers, and all of the others who have helped to get the lies and slander
OFF their sites.
It would now appear that only Friend.ly, will be added to the Federal
action, which will be amended this week or  early next.

--

  chadmay                          mailto:chadmay@...