UnifiedOnline Inc fka UOIP

[long uoip]

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

April 25, 2022 at 4:30 p.m ORAL ARGUMENT

respectfully request that the Court permit Steven Rader to participate and present in oral argument by video or telephonic appearance
Counsel for CBV, Inc.; Deirdre Leane and IPNAV, LLC have stated that they do not oppose this motion,
but counsel for ChanBond, LLC has stated they oppose the motion

CBV, INC.,
Plaintiff/Counterclaim-
Defendant v.
CHANBOND, LLC, Defendant/Crossclaim- Defendant DEIRDRE LEANE, and IPNAV, LLC
Defendants/Counterclaim Plaintiffs/Crossclaim- Plaintiffs.
C.A. No. 1:21-cv-01456-MN

PROPOSED INTERVENORS’ MOTION FOR LEAVE TO PARTICIPATE IN ORAL ARGUMENT REMOTELY
Proposed intervenors, Gregory Collins and Kamal Mian, derivatively on behalf of Unified
Online, Inc. (“Intervenors”) respectfully request that the Court permit Steven Rader, Esq. (“Mr.
Rader”), counsel for Intervenors, to participate and present in oral argument by video or telephonic
appearance. 1. Pursuant to Oral Order dated April 6, 2022 [D.I. 64], this case is currently scheduled
for oral argument regarding Defendant ChanBond, LLC’s Emergency Request to Protect
Confidentiality of ChanBond, LLC’s Under Seal Filing [D.I. 59] and Intervenors’ Response to
Emergency Request to Protect Confidentiality [D.I. 60] to be held in the United States District
Court for the District of Delaware, J. Caleb Boggs Federal Building, 844 N. King Street,
Wilmington, DE 19801, Courtroom 4A on April 25, 2022 at 4:30 p.m.
2. Fed. R. Civ. P. 43(a)’s provision for remote appearance by testifying witnesses has
also been applied to non-testimonial roles. See e.g. Shell v. Henderson, 2013 WL 4502271 *1 (D.
Colo.) 3. Mr. Rader is located in Irvine, California. Traveling to and staying in Wilmington,
Delaware for argument would require extensive close contact with a large number of people at a
time when the City of Philadelphia (home to the closest major airport) is re-introducing masking
mandates due to increased COVID-19 community transmission which appear to be the BA.1 –
BA.5 variants of the Omicron strain. Even with personal protective equipment, the risk could be
mitigated with a remote appearance. 4. Local counsel for Intervenors will appear in person at the court hearing.
5. For the foregoing reasons, Intervenors respectfully request that the Court permit
Mr. Rader to participate in the April 25, 2022 oral argument remotely either by videoconference
or teleconference. 6. Counsel for CBV, Inc.; Deirdre Leane and IPNAV, LLC have stated that they do
not oppose this motion, but counsel for ChanBond, LLC has stated they oppose the motion.

Respectfully submitted,
THE WILLIAMS LAW FIRM, P.A.
By: /s/ John L. Williams
John Legaré Williams (Del. Bar #4473)
Brian Charles Crawford (Del. Bar #4941)
1201 N. Orange Street, Suite 600
Wilmington, DE 19801
Tele: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]

and CENTAURI LAW GROUP, P.C.
Steven L. Rader (pro hac vice)
Jason R. Dilday (pro hac vice)
15615 Alton Pkwy, Suite 245
Irvine, CA 92618
Phone: [phone]
E-mail: [e-mail]
[e-mail]

Attorneys for proposed intervenors
KAMAL MIAN and GREGORY COLLINS
Derivatively on behalf UNIFIEDONLINE, INC.
Dated: April 14, 2022
_______________________________________________________

Case: CBV, Inc. v. ChanBond, LLC
Docket Number: 82.0
Docket Text: MOTION re 64 Oral Order,, Set Hearings, For Permission for Out of State Counsel to Appear Remotely - filed by Gregory Collins, Kamal Mian.(Crawford, Brian)

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