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jammastermike

03/23/23 12:00 PM

#96425 RE: long uoip #96422

thanks for the breakdown :)
very much appreciated :)

long uoip

03/24/23 10:11 AM

#96428 RE: long uoip #96422

NOTICE OF SERVICE

PLEASE TAKE NOTICE that on March 14, 2023, (i) Defendants Deirdre Leane
and IPNAV, LLC’s 2nd Set of Requests for Production to Plaintiff CBV, Inc.;

link > TOPICS OF INQUIRY

#23 is an INTERESTING QUERY indeed


40. Any and all facts that support YOUR calculations of damages in THIS ACTION.

39. Any and all facts that support YOUR claims or defenses in THIS ACTION.

38. Any and all facts related to any of YOUR efforts to search for, identify, collect, review, and produce documents in the instant litigation.

37. Any and all facts related to YOUR conversations or communications with members of the InvestorsHub UnifiedOnline board found at
https://investorshub.advfn.com/UnifiedOnline-Inc-fka-UOIP-5196.

36. Any and all facts related to your monitoring of or participation on the InvestorsHub UnifiedOnline board found at https://investorshub.advfn.com/UnifiedOnline-Incfka-UOIP-5196.

35. Any and all facts related to the provenance, authorship, history, intended audience, and purpose of the documents bearing Bates stamps CBV-00005017 and CBV00005018.

34. Any and all facts related to any monies received from or in connection with UNIFIED, UOIP, CHANBOND, or CARTER.

33. Any and all facts related to any measures YOU undertook to conduct due diligence into the investigating the terms the Mishcon de Reya, Bentham, and IPNAV retainer agreements.

32. Any and all facts related to YOUR receipt of funds in relation to YOUR role in the prosecution of the CHANBOND PATENT LITIGACTION.

31. Any and all facts related to YOUR participation in the CHANBOND PATENT LITIGATION, including discovery, testimony given at trial and the preparation for same.

30. Any and all facts related to the disposition of funds YOU received pursuant to the RRC.

29. Any and all facts related to the execution of the RRC.

28. Any and all facts related to the negotiation of the RRC.

27. Any and all facts related to YOUR knowledge and interpretation of the ASA.

26. Any and all facts related to YOUR knowledge and interpretation of the ISA.

25. Any and all facts related to YOUR knowledge and interpretation of the Common Interest Agreement YOU entered into in conjunction with the PPA.

24. Any and all facts related to YOUR negotiation and interpretation of the PPA or any of its provisions.

23. Any and all facts related to CARTER’s capacity, authority, ability, and/or fitness to act on behalf of CHANBOND and/or UNIFIED.

22. Any and all facts related to any and all agreements between CARTER on behalf of CHANBOND and any other person or entity.

21. Any and all facts related to YOUR interactions with CHANBOND.

20. Any and all facts related to YOUR interactions with HOWE.

19. Any and all facts related to the “Billy Document” referenced in CBV-00000842.

18. Any and all facts related to YOUR interactions with CARTER.

17. Any and all facts related to YOUR interactions with LEANE.

16. Any and all facts related to YOUR interactions with SPANGENBERG.

15. Any and all facts related to YOUR interactions with IPNAV.

14. Any and all facts related to YOUR negotiations with any other person or entity regarding the purchase or license of the CHANBOND PATENTS.

13. Any and all facts related to YOUR decision to monetize the CHANBOND PATENTS.

12. Any and all facts related to YOUR initial assessment of possible license fees and arrangements.

11. Any and all facts related to YOUR assessment of how and where infringement was occurring.

10. Any and all facts related to YOUR determination that the CHANBOND PATENTS were being infringed.

9. Any and all facts related to measures YOU undertook to preserve CBV’s access for purposes of litigation to documents maintained on Z-BAND’s servers.

8. Any and all facts related to the disposition of Z-BAND’s assets.

7. Any and all facts related to YOUR sale of Z-BAND.

6. Any and all facts related to YOUR decision to separate CBV and Z-BAND.

5. The process by which YOU make decisions, including the role of each of HENNENHOEFER, SNYDER, and STINE in making decisions on YOUR behalf.

4. The role of STINE in YOUR corporation.

3. The role of SNYDER in YOUR corporation.

2. The role of HENNENHOEFFER in YOUR corporation.

1. The structure of YOUR corporation.

161 NOTICE to Take Deposition of CBV, Inc. on October 31, 2022 filed by IPNAV, LLC, Deirdre Leane. (Attachments: # 1 Exhibit Schedule A)(Levine, James Harry) (Entered: 10/21/2022)

Oct 21, 2022