Dear Judge Andrews:
Pursuant to D. Del. LR 7.1.3, Defendants respectfully move for leave to file the attached
short reply letter in response to Plaintiff ChanBond, LLC’s (“ChanBond”)’s letter of May 4,
2018 (D.I. 255) in connection with the parties’ discovery dispute concerning ChanBond’s
purported claims of privilege.
Defendants seek leave to allow Defendants to address ChanBond’s new assertion that CB
Capital was retained as a non-testifying expert consultant, and new legal theories based on this
“expert” status not previously disclosed to Defendants during the parties’ meet and confer
discussions. Counsel for Defendants reached out to counsel for ChanBond, but ChanBond could
not confirm whether it would consent or oppose this request.
In view of the foregoing, Defendants respectfully requests leave to file a reply letter.
Penny Stock Analyst, not licensed, but may as well be...
