Looks very well drafted and strong evidence. Should be fine against any potential motions to dismiss or for summary judgment.
Main question he had was how much the individuals and the company have in order to be able to pay up. I told him even if they don't get $20 million and only get $4 million, that would be 2 cents a share for those w/preferred shares, and about 10x the current share price for common shares. And that was the end of that. Haha