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159 NOTICE of of intent to Serve Subpoena on Omni Bridgeway (USA) LLC by CBV, Inc. (Attachments: (1) Exhibit)(Grivner, Geoffrey)

https://storage.courtlistener.com/recap/gov.uscourts.ded.76834/gov.uscourts.ded.76834.159.1.pdf

REQUESTED DOCUMENTS
1. Any and all documents and/or communications related to the retention of Bentham as litigation funder with respect to the Patent Litigation.

2. Any and all documents and/or communications related to the September 9, 2015 Litigation Funding Agreement between ChanBond and Bentham Capital LLC d/b/a Bentham IMF, including, but not limited to, any and all documents and/or communications negotiating the Litigation Funding Agreement, any and all drafts of the Litigation Funding Agreement, and the final Litigation Funding Agreement.

3. Any and all documents and/or communications related to any and all amendments to the September 9, 2015 Litigation Funding Agreement between ChanBond and Bentham Capital LLC d/b/a Bentham IMF, including, but not limited to, the third amendment to the litigation funding and/or financing agreement.

4. Any and all documents and/or communications related to any and all draw downs on and/or disbursements of litigation funding Bentham, whether from the September 9, 2015 Litigation Funding Agreement between ChanBond and Bentham Capital LLC d/b/a Bentham IMF or any amendments thereto, and what these draw downs and/or disbursements were used for.

5. Any and all documents and/or communications related to any and all payments
made to Bentham out of the settlement proceeds from the Patent Litigation, including, but not limited to, documents demonstrating or explaining the calculation of these payments.

6. Any and all documents and/or communications related to the payment of $200,000 to CBV in the fall of 2015 in exchange for execution of the August 27, 2015 amendment to the PPA.

Oct 20, 2022


Main Doc­ument

Notice - Other

Attach­ment 1

Exhibit


IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

CBV, INC.,
Plaintiff/CounterclaimDefendant,
v.
CHANBOND, LLC,
Defendant/CrossclaimDefendant,
and
DEIRDRE LEANE, and IPNAV, LLC,
Defendants/CounterclaimPlaintiffs/CrossclaimPlaintiffs.

C.A. No. 1:21-cv-01456-MN

NOTICE OF INTENT TO SERVE SUBPOENA

PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 45, Plaintiff CBV, Inc. intends to serve a subpoena duces tecum, in the form attached hereto as Exhibit A, on Omni Bridgeway (USA) LLC, on October 20, 2022, or as soon thereafter as service may be effectuated.

BUCHANAN, INGERSOLL & ROONEY PC

Dated: October 20, 2022

/s/ Geoffrey Grivner
Geoffrey G. Grivner (#4711)
Kody M. Sparks (#6464)
500 Delaware Avenue, Suite 720
Wilmington, DE 19801-3036
[phone]
[e-mail]
[e-mail]
Patrick C. Keane, Esq.
BUCHANAN, INGERSOLL & ROONEY PC
1737 King Street, Suite 500
Alexandria, VA 22314-2727
[phone]
[e-mail]
Attorneys for Plaintiff