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Re: Specialneeds post# 93059

Tuesday, 12/14/2021 7:23:35 PM

Tuesday, December 14, 2021 7:23:35 PM

Post# of 96904
re: "This is a clear conflict of interest" ..word for word verbatim from latest legal documents CBV filed

perplexing that lawyers were NOT cognizant of any malfeasance


Legal Document
CBV, Inc. vs. ChanBond, LLC
December 6, 2021

> stymied by the actions of both the former and current owners of ChanBond

> rather, Ms. Leane, recognizing the value in the Patents, is trying the squeeze as much value out of them as she can by resorting to breaches of and fraudulent conduct

> in fact, she unilaterally signed for both parties three months after the and backdated the document to give the appearance that it was signed contemporaneously

> in fact, CBV was not informed of this conduct and had no knowledge of this fraudulent and invalid XX until 2020

> nothing more than a bad faith attempt by Ms. Leane to circumvent

> CBV is unaware of IPNav providing any services, for services which were minor, if rendered at all, would deprive CBV of funds for which it properly contracted.

> upon information and belief, William “Billy” Carter, ChanBond’s Manager, is Unified’s Chief Executive Officer

> a true and correct copy of the fraudulent XX is attached hereto as Exhibit B

> ChanBond has refused and failed to provide CBV with any documentation regarding the Settlement or any distributions of the Settlement proceeds

> the parties to the XX never agreed to such an arrangement. A true and correct copy of the purported is attached hereto as Exhibit C

> as such, CBV requested a copy of the XX to review. However, ChanBond and Ms. Leane’s attorneys refused CBV’s request, asserting that CBV had no right to review the contract

> CBV has been stonewalled by ChanBond as to specific information regarding the Settlement Agreement. Despite requests from CBV, ChanBond has refused to provide a copy of the Settlement Agreement, an accounting of the settlement funds, or any other specific information allowing CBV to determine the proper amount it should receive.

> CBV was notified of this amount by KWM in a July 14, 2021 email from Mark Raskin, a true and correct copy of which is attached hereto as Exhibit E. However, CBV was never provided any detail or supporting documentation regarding the settlement amount nor the purported amounts distributable to CBV or the other parties, despite requests from CBV. Upon information and belief, CBV is entitled to a much greater amount.

> as a result of Defendant’s refusal to pay Plaintiff the funds it is owed under the XX, Plaintiff will suffered certain negative tax implications. Specifically, Congress has passed (at least one house) an increase in the capital gains tax effective Sept 13, 2021. The new capital gains tax percentage will be 25% versus the old number of 20%.

> rather, Ms. Leane, unilaterally executed the XX for both parties to that transaction without any knowledge, input, or agreement by CBV, in breach of the XX. In fact, Ms. Leane was not involved in the initial negotiations between CBV and IP Navigation, outside of the very first meeting between the parties.

> Ms. Leane fraudulently drafted, backdated, and executed the XX without ever discussing the contract with CBV. Rather, CBV only learned of the XX existence through Ms. Leane’s various lawsuits. As such, the XX is improper and is void.

> CBV reasonably believes that it is entitled to greater than XX However, it has been stonewalled by ChanBond at every turn regarding any information about the settlement, funds disbursements, etc. ChanBond has refused to provide CBV with a copy of the Settlement Agreement, an accounting of funds disbursements, or any other information regarding the settlement funds, despite requests from CBV and despite XX

> such requests from CBV to ChanBond have been unreasonably refused to date. A failure to receive such an accounting will result in diversion of funds due to CBV to accounts outside the United States, with Ms. Leane being a citizen of the United Kingdom, and will cause irreparable harm to CBV.
Plaintiff therefore respectfully requests that the Court issue an Injunction barring disbursement of any payments from the settlement amount to any parties before an accounting has taken place and distributed.

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