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imp82

06/09/22 11:16 AM

#95177 RE: zombywolf #95176

He was/is, but he also represented Deidre per their agreement. Case 3:20-cv-03097-B Document 1 Filed 10/09/20, page 12


"E. Unified And Chanbond Try And Eliminate The Advisory Services Agreement's
Economic Benefits To Ms. Leane.


48. In accordance with IPNav's obligations under the Advisory Services Agreement, Ms. Leane continued to work with ChanBond and the counsel she hired (Mishcon) in connection with the ChanBond Litigation.

49. On April 24, 2018, the ChanBond Litigation defendants deposed Ms. Leane. At the time of the deposition, Ms. Leane, IPNav, and ChanBond were all represented Mishcon, and Mishcon partner Bob Whitman represented Ms. Leane and ChanBond during the deposition.

50. Just prior to the lunch break, Ms. Leane testified about the Advisory Services
Agreement. Counsel for the defendants noted that ( for reasons unknown to Claimants) ChanBond had not produced the document.

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.

Whitman described himself, on the record at the deposition, as Ms. Leane's attorney. Moreover, under the terms of the retainer agreement between ChanBond and Mishcon de Reya, IPNav was a joint client of Mishcon de Reya along with ChanBond.

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.

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."
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TonyJoe1957

06/09/22 11:24 AM

#95179 RE: zombywolf #95176

Whitman described himself, on the record at the deposition, as Ms. Leane's attorney.

Was that an Ooops?