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IN THE COURT OF CHANCERY FOR THE STATE OF DELAWARE
`
`
`C.A. No. 2017-0048-AGB
`
`ABRAHAM SPETNER, KALATSKY
`FAMILY LLC, JOSEPH GAD, and
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`RASON LLC,
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`Plaintiffs,
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`
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`v.
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`
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`GREEN OIL ENERGY, LLC, a Delaware
`Limited Liability Company,
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`
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`
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`
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`
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`Defendant.
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`)
`)
`)
`)
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`PLAINTIFFS’ SECOND AMENDED
`MOTION FOR DEFAULT JUDGMENT
`AGAINST DEFENDANT GREEN OIL ENERGY, LLC
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`Plaintiffs, Abraham Spetner, Kalatsky Family LLC, Joseph Gad, and Rason
`
`LLC (“Plaintiffs”), hereby move for the entry of a default judgment (“Motion”)
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`against defendant Green Oil Energy, LLC (“Green Oil”). The grounds for this
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`Motion are set forth in Plaintiffs’ opening brief and supporting Affidavits of
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`Jonathan E. Neuman and Christopher D. Loizides and the exhibits attached thereto,
`
`being filed contemporaneously herewith.
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`DATED: November 2, 2017
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`SECOND AMENDED MOTION FOR DEFAULT JUDGMENT
`
`
`
`/s/ Christopher D. Loizides
`
`Christopher D. Loizides (No. 3968)
`LOIZIDES, P.A.
`1225 King Street, Suite 800
`Wilmington, DE 19801
`Telephone: (302) 654-0248
`Facsimile:
`(302) 654-0728
`Email:
`loizides@loizides.com
`
`Counsel for Plaintiffs
`
`WORDS: 62
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`EFiled: Nov 02 2017 04:16PM EDT
`Transaction ID 61314159
`Case No. 2017-0048-AGB
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`
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`
`

`

`
`
`OF COUNSEL:
`Jonathan E. Neuman, Esquire
`LAW OFFICES OF JONATHAN E. NEUMAN
`176-25 Union Turnpike, Suite 230
`Fresh Meadows, NY 11366
`Telephone: (347) 450-6710
`Email:
`jnesq@jenesqlaw.com
`
`
`
`SECOND AMENDED MOTION FOR DEFAULT JUDGMENT
`
`2
`
`

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