`
`C.A. No. 2023-0053-JTL
`
`)))))))))))))))))))))))
`
`TY HULS,
`
`
`
`Plaintiff,
`
`v.
`
`TEESPRING, INC., a Delaware
`corporation, AMAZE HOLDING
`COMPANY LLC, a Delaware limited
`liability company, AMAZE
`SOFTWARE INC., a Delaware
`corporation, CHRISTOPHER
`LAMONTAGNE, ANNELIES
`JANSEN, CARMEN BECKWITH,
`EVAN STITES-CLAYTON, and
`NICK BELL, APOLLO PROJECTS,
`L.P., ALTMAN FAMILY, LLC,
`HYDRAZINE CAPITAL, LP,
`HYDRAZINE CAPITAL III, LP,
`9POINT VENTURES, LLC, and
`SAMUEL H. ALTMAN
`
`Defendants.
`
`STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE
`FOR NON-TEESPRING DEFENDANTS TO RESPOND TO
`VERIFIED AMENDED COMPLAINT
`WHEREAS, Plaintiff Ty Huls (“Plaintiff”) filed his Verified Complaint
`
`against Defendants Teespring, Inc., Amaze Holding Company LLC, Amaze
`
`Software Inc., Christopher Lamontagne, Annelies Jansen, Carmen Beckwith, Evan
`
`Stites-Clayton, and Nick Bell (the “Original Defendants”) on January 18, 2023 [DI
`
`1];
`
`EFiled: Jul 24 2023 04:09PM EDT
`Transaction ID 70469783
`Case No. 2023-0053-JTL
`
`
`
`WHEREAS, Plaintiff filed his Verified Amended Complaint in this action on
`
`May 16, 2023, including Apollo Projects, L.P., Altman Family, LLC, Hydrazine
`
`Capital, LP, Hydrazine Capital III, LP, 9Point Ventures, LLC, and Samuel H.
`
`Altman as defendants (the “New Defendants”) [DI 43];
`
`WHEREAS, on June 12, 2023, the Court entered a Stipulation and Order
`
`Vacating the Briefing Schedule for the Original Defendants Pending Appearance of
`
`the New Defendants [DI 55];
`
`WHEREAS, on June 26, 2023, the Court entered a Stipulation and Order
`
`Extending the Deadline for New Defendants to Respond to the Verified Amended
`
`Complaint to August 4, 2023 [DI 59];
`
`WHEREAS, counsel for Plaintiff, Original Defendants, and New Defendants
`
`(collectively, the “Parties”) are engaged in settlement negotiations and require
`
`additional time for those discussions;
`
`WHEREAS, the Parties have met and conferred and agreed, subject to the
`
`Court’s approval, that (i) the deadline to answer or otherwise respond to the Verified
`
`Amended Complaint shall be extended to September 8, 2023 for Defendants Amaze
`
`Holding Company LLC, Amaze Software Inc., Christopher Lamontagne, Annelies
`
`Jansen, Carmen Beckwith, Evan Stites-Clayton, Nick Bell, Apollo Projects, L.P.,
`
`Altman Family, LLC, Hydrazine Capital, LP, Hydrazine Capital III, LP, 9Point
`
`Ventures, LLC, and Samuel H. Altman (the “Non-Teespring Defendants”); and (ii)
`
`
`
`if the Non-Teespring Defendants file a motion to dismiss in response to the Verified
`
`Amended Complaint, that the opening brief for the motion shall be filed by
`
`September 8, 2023.
`
`NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED,
`
`by the Parties, through their undersigned counsel and subject to the approval of the
`
`Court, that: (i) the Non-Teespring Defendants shall answer or otherwise respond to
`
`the Verified Amended Complaint by September 8, 2023; and (ii) if the Non-
`
`Teespring Defendants file a motion to dismiss in response to the Verified Amended
`
`Complaint, the opening brief for the motion shall be filed by September 8, 2023.
`
`
`
`CROSS & SIMON, LLC
`
`RICHARDS, LAYTON & FINGER, P.A.
`
`
`
`/s/ David G. Holmes
`David G. Holmes (#4718)
`1105 North Market Stret, Suite 901
`Wilmington, Delaware 19801
`(302) 777-4200
`
`Attorney for Plaintiff Ty Huls
`
`
`
`/s/ Travis S. Hunter
`Travis S. Hunter (#5350)
`Nathalie A. Freeman (#7053)
`One Rodney Square
`920 North King Street
`Wilmington, Delaware 19801
`(302) 651-7700
`
`SMITH, KATZENSTEIN & JENKINS, LLP
`
`/s/ Jason Z. Miller
`Robert K. Beste (#3931)
`Jason Z. Miller (#6310)
`1000 West Street, Suite 1501
`Wilmington, Delaware 19801
`(302) 652-8400
`
`Attorneys for Defendant Carmen
`Beckwith
`
`Attorneys for Defendants Amaze Holding
`Company LLC and Amaze Software Inc.
`
`LEWIS BRISBOIS BISGAARD & SMITH LLP
`
`/s/ Sean M. Brennecke
`Sean M. Brennecke (#4686)
`500 Delaware Avenue, Suite 700
`Wilmington, Delaware 19801
`(302) 985-6009
`
`Attorney for Defendants Christopher
`Lamontagne, Annelies Jansen, Evan
`Stites-Clayton and Nick Bell
`
`BAYARD, P.A.
`
`/s/ Peter B. Ladig
`Peter B. Ladig (#3513)
`600 N. King Street, Suite 400
`Wilmington, Delaware 19801
`(302) 655-5000
`Attorneys for Apollo Projects, L.P.,
`Altman Family, LLC, Hydrazine Capital,
`LP, Hydrazine Capital III, LP, 9Point
`Ventures, LLC and Samuel H. Altman
`
`
`
`DATED: July 24, 2023
`
`SO ORDERED, this ____ day of _________, 2023.
`
`_________________________________
`Vice Chancellor J. Travis Laster
`
`
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