D. Injunctive Relief ls Necessary To Protect Ms. Leane's Contractual Rights Under The ISA Or To Ensure That Unified Does Not Destroy The Value Of The Chanbond Patents.
44. The ChanBond Litigations have completed discovery, the Court has ruled on summary judgment motions and are awaiting trial. Upon information and belief, and based on Ms. Leane' s experience and industry sources, the ChanBond Litigations will likely settle before trial.
36. There is no indication that Unified intends to make the payment on the Note (which is now due). Indeed, it cannot do so, as it has no source of income and no assets other than ChanBond itself, which has not generated any income or recovery. Upon information and belief, Unified is insolvent with no money to pay the Note, which is now due and owing, which is the reason for its (unauthorized) continued borrowing from Bentham over-and-above the amounts Ms. Leane arranged in the initial Litigation Funding Agreement.
38. It would be deeply inequitable to allow Unified to retain the membership interests in ChanBond in exchange for consideration that Unified then stripped of all value. And the parties could easily be returned to the status quo ante by Ms. Leane' s return of the Unified stock and Unified's return of the ChanBond member interests. Under the circumstances, Ms. Leane is entitled to rescission of the ISA, and to an award of fees as provided for in Section 8 .2 of the ISA.
51. On the lunch break, Mr. Whitman advised Ms. Leane that ChanBond's failure to produce the Advisory Services Agreement would create problems for the ChanBond Litigations, including additional discovery and severe trial delays.
52. Mr. Whitman advised her that it was in ChanBond's, IPNav's, and her own interest to terminate and cancel the Advisory Services Agreement and enter a new agreement with ChanBond at a later date that would restore her to the same 22% economic position.
53. Through its agent, Whitman, ChanBond and Unified represented to Ms. Leane that it would restore her 22% interest in the recovery on the ChanBond Patents, which she then held through IPN av and the Advisory Services Agreement, if she agreed to terminate the Advisory Services Agreement.
54. In addition, Unified's principal, Billy Carter, specifically advised Ms. Leane that she would still get paid if she terminated the Advisory Services Agreement. 5 5. Though the Advisory Services Agreement provided that IPN av could unilaterally terminate it, requiring no action by ChanBond, Whitman drafted a "Termination Agreement" between IPNav and ChanBond that terminated the Advisory Services Agreement effective as of April 9, 2015.
55. Though the Advisory Services Agreement provided that IPN av could unilaterally terminate it, requiring no action by ChanBond, Whitman drafted a "Termination Agreement" between IPNav and ChanBond that terminated the Advisory Services Agreement effective as of April 9, 2015.
56. The Termination Agreement provided that ChanBond and IPNav were entering into an agreement to terminate the Advisory Services Agreement, in exchange for their mutual agreements and "other good and valuable consideration."
57. The only consideration IPNav received for terminating the Advisory Services Agreement was ChanBond's representation and agreement, conveyed by its attorneys, that ChanBond would execute a separate agreement binding itself to pay IPNav 22% of the proceeds of the ChanBond Patents, exactly as it had been required to do under the Advisory Services Agreement. 58. Ms. Leane relied on ChanBond's representations, and the representations of its counsel, in executing the Termination Agreement.
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