Replies to post #93490 on UnifiedOnline Inc fka UOIP

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EVENT DEADLINES

Counsel Shall Provide a Chart of All Relevant Deadlines

Application for Protective Order ~ Ten (10) days after close of pleadings

Rule 26(a)(1) Initial Disclosures ~ Five (5) days after close of pleadings

Document Production Completion ~ Four (4) months after close of pleadings.

Motions to Join Other Parties and to Amend or Supplement the Pleadings ~ May 13, 2022

Fact Discovery Cut Off ~ Six (6) months after close of pleadings.

Identification of Affirmative Experts ~ Thirty (30) days before the close of fact discovery.

Identification of Rebuttal Experts ~ Thirty (30) days after disclosure of affirmative experts.

Plaintiff Expert Report ~ Thirty (30) days after the close of fact discovery.

Rebuttal Expert Report ~ Thirty (30) days after initial expert reports.

Reply Expert Report ~ Fourteen (14) days after rebuttal expert reports.

Expert Discovery Cut Off ~ Forty-five (45) days after submission of reply expert reports

Objections to Expert Testimony ~ Fourteen (14) days after the close of expert discovery

Case dispositive motions relating to the validity of the Advisory Services Agreement ~ May 23, 2022

All other case dispositive motions ~ Thirty (30) days after the close of fact discovery

Pretrial Order and Motions in Limine ~ Seven (7) days before the Pretrial Conference

Pretrial Conference ~ May TBD, 2023

Trial ~ June TBD, 2023

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CBV, Inc. vs. ChanBond, LLC

Thursday, March 17, 2022
Amended STIPULATION Concerning Temporary Restraining Order and Interest by CBV, Inc.. (Grivner, Geoffrey)
31 ORAL ORDER re29 Notice of Withdrawal of Motion for Temporary Restraining Order,30 Stipulation Concerning Temporary Restraining Order and Interest - IT IS HEREBY ORDERED that Plaintiff's Motion for Temporary Restraining Order is WITHDRAWN. IT IS FURTHER ORDERED that the parties shall submit an amended stipulation that incorporates the following change to paragraph one: "ChanBond and its agents will voluntarily refrain from distributing the Settlement Funds to Proposed Intervenors until CBV's Motion for Preliminary Injunction is heard and a decision is rendered by the Court." ORDERED by Judge Maryellen Noreika on 3/17/2022. (dlw)

30 STIPULATION Stipulation Concerning Temporary Restraining Order and Interest by CBV, Inc.. (Grivner, Geoffrey)

29 NOTICE of Withdrawal of Plaintiff's Motion for Temporary Restraining Order by CBV, Inc. (Grivner, Geoffrey)

28 SO ORDERED re25 Stipulation and Order - IT IS HEREBY ORDERED that IPNAV, LLC and Deirdre Leane are added as Defendants in this action (Set/Reset Answer Deadlines: IPNAV, LLC answer due 3/23/2022; Deirdre Leane answer due 3/23/2022). Signed by Judge Maryellen Noreika on 3/17/2022. (dlw)

27 MOTION for Pro Hac Vice Appearance of Attorney Dylan M. Schmeyer - filed by IPNAV, LLC and Deirdre Leane.(Levine, James Harry)
Att: 1 Certification of Dylan M. Schmeyer, Esq.,
Att: 2 Text of Proposed Order

26 MOTION for Pro Hac Vice Appearance of Attorney Akiva M. Cohen - filed by IPNAV, LLC and Deirdre Leane.(Levine, James Harry)
Att: 1 Certification of Akiva M. Cohen Akiva M. Cohen, Esq.,
Att: 2 Text of Proposed Order
SO ORDERED re26 MOTION for Pro Hac Vice Appearance of Attorney Akiva M. Cohen,27 MOTION for Pro Hac Vice Appearance of Attorney Dylan M. Schmeyer filed by IPNAV, LLC and Deirdre Leane. ORDERED by Judge Maryellen Noreika on 3/17/2022. (dlw)

Delaware District Court
Judge: Maryellen Noreika
Case #: 1:21-cv-01456
Nature of Suit 190 Contract - Other Contract
Cause 28:1332 Diversity-Breach of Contract
Docket last updated: 49 minutes ago

Wednesday, March 16, 2022
25 2 pgs misc Stipulation-General (See Motion List for Stipulation to Extend Time) Wed 03/16 11:18 PM
STIPULATION to add Proposed Intervenors as parties in this action -- Stipulation and Order by IPNAV, LLC and Deirdre Leane. (Levine, James Harry)

24 11 pgs misc Proposed Order Wed 03/16 5:45 PM
PROPOSED ORDER Scheduling Order [Non-Patent Bench Trial] by CBV, Inc.. (Grivner, Geoffrey)

23 1 pgs notice Notice of Appearance Wed 03/16 3:03 PM
NOTICE of Appearance by James Harry Stone Levine on behalf of IPNAV, LLC and Deirdre Leane (Levine, James Harry)

Tuesday, March 15, 2022
20 motion Stipulation to EXTEND Time Tue 03/15 2:57 PM
STIPULATION TO EXTEND TIME to file Scheduling Order to March 23, 2022 - filed by CBV, Inc.. (Grivner, Geoffrey)

19 respm Brief - Opening Brief in Support Tue 03/15 2:51 PM
[SEALED] OPENING BRIEF in Support re18 MOTION for Temporary Restraining Order, Preliminary Injunction, and for Expedited Delivery filed by CBV, Inc. Answering Brief/Response due date per Local Rules is 3/29/2022.(Grivner, Geoffrey) Modified on 3/15/2022 (dlw)
Att: 1 Exhibit A

18 motion Temporary Restraining Order Tue 03/15 2:50 PM
[SEALED] MOTION for Temporary Restraining Order, Preliminary Injunction, and for Expedited Delivery - filed by CBV, Inc.(Grivner, Geoffrey) Modified on 3/15/2022 (dlw)
Att: 1 Proposed Order Granting Preliminary Injunction,
Att: 2 Proposed Temporary Restraining Order and Order for Expedited Discovery
order Oral Order Tue 03/15 3:29 PM

ORAL ORDER re18 MOTION for Temporary Restraining Order, Preliminary Injunction, and for Expedited Delivery - IT IS HEREBY ORDERED that Defendant shall file its answering brief no later than 6:00 PM on 3/17/2022 and Plaintiff shall file its reply brief no later than 6:00 PM on 3/18/2022. ORDERED by Judge Maryellen Noreika on 3/15/2022. (dlw)
order Oral Order Tue 03/15 3:30 PM
ORAL ORDER re20 STIPULATION TO EXTEND TIME to file Scheduling Order to March 23, 2022 - IT IS HEREBY ORDERED that the stipulation is DENIED. ORDERED by Judge Maryellen Noreika on 3/15/2022. (dlw)

Wednesday, March 02, 2022
17 motion Stipulation to EXTEND Time Wed 03/02 10:11 AM
STIPULATION TO EXTEND TIME to file a Scheduling Order to March 16, 2022 - filed by CBV, Inc.. (Grivner, Geoffrey)
order SO ORDERED Wed 03/02 12:02 PM
SO ORDERED re17 STIPULATION TO EXTEND TIME to file a Scheduling Order to March 16, 2022. ORDERED by Judge Maryellen Noreika on 3/2/2022. (dlw)

Thursday, February 03, 2022
16 misc Redacted Document Thu 02/03 4:22 PM
REDACTED VERSION of 11 Answer to Amended Complaint by ChanBond, LLC. (Golden, Ronald)

Tuesday, February 01, 2022
15 misc Statement Tue 02/01 2:27 PM
STATEMENT re 14 Oral Order // Defendant Chanbond, LLC's Statement by ChanBond, LLC. (Golden, Ronald) Modified on 2/1/2022 (dlw)

Monday, January 31, 2022
14 order Oral Order Mon 01/31 4:04 PM

ORAL ORDER - On or before 2/7/2022, ChanBond LLC shall file a statement indicating the citizenship of each of its member(s). If any member is itself an LLC (or LLP), then the statement shall also indicate the citizenship of each sub-member of the member LLC (or LLP). ORDERED by Judge Maryellen Noreika on 1/31/2022. (dlw)

13 order Oral Order Mon 01/31 11:26 AM
ORAL ORDER - IT IS HEREBY ORDERED that the parties shall confer regarding proposed dates in the scheduling order and shall submit a proposed order, including a proposal for the length and timing of trial, to the Court no later than thirty (30) days from the date of this Order. The parties are to use the Court's form scheduling order, which is posted at http://www.ded.uscourts.gov (see Chambers, Judge Noreika, Forms). If there are disputes or issues that the Court needs to address in the proposed scheduling order, the parties shall direct the Court to the paragraph numbers in which those appear in a cover letter to the Court. ORDERED by Judge Maryellen Noreika on 1/31/2022. (dlw)
order SO ORDERED Mon 01/31 11:17 AM
SO ORDERED re10 UNOPPOSED MOTION to File Under Seal. ORDERED by Judge Maryellen Noreika on 1/31/2022. (dlw)

Thursday, January 27, 2022
12 1 pgs misc Disclosure Statement - Rule 7.1 Thu 01/27 6:16 PM
Disclosure Statement pursuant to Rule 7.1: identifying Corporate Parent Unified Online, Inc. for ChanBond, LLC filed by ChanBond, LLC. (Golden, Ronald)

11 answer Answer to Amended Complaint Thu 01/27 6:12 PM
[SEALED] ANSWER to Amended Complaint, re:6 Amended Complaint, by ChanBond, LLC.(Golden, Ronald)
Att: 1 Certificate of Service

10 motion Miscellaneous Relief Thu 01/27 5:47 PM
MOTION to File Under Seal - filed by ChanBond, LLC.(Golden, Ronald)
Att: 1 1 pgs Proposed Order

Monday, January 03, 2022
order SO ORDERED ~ Util - Set/Reset Answer Deadline Mon 01/03 12:23 PM
SO ORDERED re9 STIPULATION TO EXTEND TIME for Defendant to Answer, Move or Otherwise Respond to Plaintiff's Amended Complaint to January 27, 2022 (Set/Reset Answer Deadlines: ChanBond, LLC answer due 1/27/2022). ORDERED by Judge Maryellen Noreika on 1/3/2022. (dlw)

Monday, December 27, 2021
9 motion Stipulation to EXTEND Time Mon 12/27 1:05 PM
STIPULATION TO EXTEND TIME for Defendant to Answer, Move or Otherwise Respond to Plaintiff's Amended Complaint to January 27th, 2022 - filed by ChanBond, LLC. (Golden, Ronald)

Monday, December 13, 2021
8 misc Redacted Document Mon 12/13 10:19 AM
REDACTED VERSION of6 Amended Complaint, by CBV, Inc..(Grivner, Geoffrey)
Att: 1 Exhibit,
Att: 2 Redline of First Amended Complaint

Tuesday, December 07, 2021
7 service Return of Service Executed Tue 12/07 4:24 PM
Return of Service Executed by CBV, Inc.. ChanBond, LLC served on 12/7/2021, answer due 12/28/2021. (Grivner, Geoffrey)

Monday, December 06, 2021
6 cmp Complaint - Amended Mon 12/06 12:41 PM
[SEALED] First AMENDED COMPLAINT against ChanBond, LLC- filed by CBV, Inc..(Sparks, Kody)
Att: 1 Exhibit [UNDER SEAL] Exhibits A-F to First Amended Complaint,
Att: 2 Exhibit [UNDER SEAL] Redline - Complaint to First Amended Complaint

Friday, October 22, 2021
5 31 pgs misc Redacted Document Fri 10/22 5:26 PM
REDACTED VERSION of2 Complaint by CBV, Inc.(Grivner, Geoffrey) Modified on 10/25/2021 (dlw).
Att: 1 5 pgs Exhibit

Wednesday, October 20, 2021
utility Case Assigned/Reassigned Wed 10/20 10:11 AM
Case Assigned to Judge Maryellen Noreika. Please include the initials of the Judge (MN) after the case number on all documents filed. (nms)

Friday, October 15, 2021
4 1 pgs order Order on Motion to Seal Fri 10/15 3:55 PM
ORDER granting (DI1 ) Motion to Seal complaint and exhibits. CBV shall file a public version of the Complaint, with the confidential information redacted, within seven (7) days of this motion being granted. Signed by Judge Leonard P. Stark on 10/15/2021. (twk)

3 misc Magistrate Consent Forms Fri 10/15 3:15 PM
Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (twk)

2 cmp Complaint Fri 10/15 3:08 PM
[SEALED] COMPLAINT filed against ChanBond, LLC - Magistrate Consent Notice to Pltf. ( Filing fee $ 402, receipt number ADEDC-3721765.) - filed by CBV, Inc..(twk)
Att: 1 Exhibit A-E,
Att: 2 Civil Cover Sheet

1 3 pgs motion Seal Fri 10/15 3:06 PM
Plaintiff's MOTION to file complaint and exhibits under seal - filed by CBV, Inc..(twk)
Att: 1 Text of Proposed Order
service No Summons Issued Fri 10/15 3:16 PM
No Summons Issued. (twk)
utility Remark Fri 10/15 3:21 PM
Remark: Exit electronic copies to Duty Judge (LPS). (twk)

Defendant
ChanBond, LLC

Plaintiff
CBV, Inc.

Represented By
Geoffrey Graham Grivner
Buchanan Ingersoll & Rooney PC

Kody Macgyver Sparks
Buchanan Ingersoll & Rooney PC