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`
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`In re
`STARZ STOCKHOLDER LITIGATION
`
`
`In re
`STARZ APPRAISAL
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`CONSOLIDATED
`C.A. No. 12584-VCG
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`CONSOLIDATED
`C.A. No. 12968-VCG
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`RESPONDENT STARZ’ MOTION FOR COMMISSION
`FOR INTERACTIVE BROKERS LLC
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`Respondent Starz, by and through undersigned counsel, respectfully moves
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`this Court, pursuant to 10 Del. C. § 368 and Court of Chancery Rules 26, 28, 34 and
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`45, for an order in the form attached hereto directing that a Commission be issued to
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`any attorney-at-law, notary public, or other person authorized to issue oaths in the
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`State of Connecticut, empowering such person to issue a subpoena duces tecum to
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`Interactive Brokers LLC, c/o IBG LLC, One Pickwick Plaza, Greenwich,
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`Connecticut 06830, to produce documents identified in Schedule A.
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`In support of this motion, Respondent asserts as follows:
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`1.
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`2.
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`Interactive Brokers LLC is not a party to this action;
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`Interactive Brokers LLC is in possession, custody, or control of relevant
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`and material information and documents relating to the claims and defenses at issue
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`in this action; and
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`EFiled: Nov 28 2017 10:55AM EST
`Transaction ID 61398239
`Case No. Multi-Case
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`3.
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`Compulsory process is required to compel Interactive Brokers LLC to
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`produce documents identified in Schedule A.
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`WHEREFORE, Respondent respectfully requests that this Motion be granted.
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`DATED: November 28, 2017
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`CHIPMAN BROWN CICERO & COLE, LLP
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` /s/ Stephanie S. Habelow
`Paul D. Brown (#3903)
`Stephanie S. Habelow (#5184)
`Hercules Plaza
`1313 North Market Street, Suite 5400
`Wilmington, DE 19801
`Telephone: (302) 295-0191
`WORDS: 163
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`Conflicts Counsel for Respondent Starz
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 28th day of November, 2017, copies of the
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`foregoing (i) Respondent Starz’ Motion for Commission for Interactive Brokers
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`LLC, (ii) Order for Commission, (iii) Commission, and (iv) Schedule A to
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`Commission for Interactive Brokers LLC were caused to be served by File &
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`ServeXpress on the counsel of record indicated below:
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`Kevin G. Abrams, Esq.
`A. Thompson Bayliss, Esq.
`Abrams & Bayliss LLP
`20 Montchanin Road
`Wilmington, DE 19807
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`Stuart M. Grant, Esq.
`John C. Kairis, Esq.
`Jeremy Cole, Esq.
`Grant & Eisenhofer PA
`123 Justison Street
`Wilmington, DE 19801
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`
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`Norman M. Monhait, Esq.
`Rosenthal Monhait & Goddess PA
`919 Market Street, Suite 1401
`Wilmington, Delaware 19801
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`
`David J. Margules, Esq.
`Elizabeth A. Sloan, Esq.
`Erika R. Caeser, Esq.
`Jessica Watt, Esq.
`Suzanne O. Lufadeju, Esq.
`Ballard Spahr LLP
`919 North Market Street, 11th Floor
`Wilmington, DE 19801
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`Raymond J. DiCamillo, Esq.
`Sarah A. Clark, Esq.
`Ryan P. Durkin, Esq.
`Richards Layton & Finger PA
`920 N King Street
`Wilmington, DE 19801
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` /s/ Stephanie S. Habelow
`Stephanie S. Habelow (#5184)
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