IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS and ST. JOHN GREAT ST. JIM, LLC, and LSJE, LLC, v. PROSOLAR SYSTEMS, LLC, Plaintiffs, Defendant. CIVIL NO. ST-2019-CV-057 COMPLAINT FOR BREACH OF CONTRACT & FRAUD ANSWER Defendant, PROSOLAR SYSTEMS, LLC, by and through undersigned counsel, answering Plaintiff's Complaint, as to each numbered paragraph thereof, alleges as follows: 1. Defendant is without sufficient information or knowledge to either admit or deny the allegations contained in Paragraph 1 of the Complaint. To the extent said allegations allege or infer any negligence on the part of Defendant, they are specifically denied. 2. Defendant is without sufficient information or knowledge to either admit or deny the allegations contained in Paragraph 2 of the Complaint. To the extent said allegations allege or infer any negligence on the part of Defendant, they are specifically denied. 3. Admitted. 4. The Complaint speaks for itself. As to subject matter jurisdiction, Defendant does not concede, and therefore denies this allegation. 5. Denied. 6. Defendant is without sufficient information or knowledge to either admit or deny the allegations contained in Paragraph 6 of the Complaint. To the extent said allegations allege or infer any negligence on the part of Defendant they are specifically denied. EFTA00798007