throbber
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`D1 JASPER HOLDINGS LP, D1 SPV
`JL MASTER LP, JAY BLOCKER
`LTD., JAY DOMESTIC LLC, GCCU II
`LLC, TOCU XX LLC, OC II FIE VIII LP,
`JL SPV HOLDINGS, LLC, EMS JINV
`LLC, DISRUPTIVE TECHNOLOGY
`SOLUTIONS XIV, LLC, DISRUPTIVE
`TECHNOLOGY SOLUTIONS XVI,
`LLC–SERIES A, DISRUPTIVE
`TECHNOLOGY SOLUTIONS XVI,
`LLC–SERIES B, and DISRUPTIVE
`TECHNOLOGY SOLUTIONS XVI,
`LLC–SERIES C,
`
`Plaintiffs,
`
`v.
`
`JUUL LABS, INC. and JL TAO LLC,
`
`Defendants.
`
`C.A. No. 2023-1060-NAC
`
`PUBLIC VERSION
`filed April 16, 2024
`
`DEFENDANTS’ OPPOSITION
`TO PLAINTIFFS’ MOTION TO COMPEL
`
`PRELIMINARY STATEMENT
`Plaintiffs’ Motion to Compel (the “Motion”)1 rests on a fundamental
`
`1.
`
`mischaracterization of the record. Plaintiffs assert that at trial, Barse “reverse[d]
`
`course” from his deposition and put at issue privileged advice to JLI’s Independent
`
`1 D.I. 261.
`
`EFiled: Apr 16 2024 03:20PM EDT
`Transaction ID 72757216
`Case No. 2023-1060-NAC
`
`

`

`Committee. In reality, Barse’s trial testimony was consistent with his deposition
`
`testimony, he did not try to make affirmative use of counsel’s advice, and Plaintiffs’
`
`strategic decision to wait until trial to object to his description of the Committee’s
`
`diligence should not be rewarded.
`
`2.
`
`Plaintiffs’ claim that Barse “affirmatively introduced [at trial] the very
`
`advice and facts that JUUL and the Independent Committee had refused to provide
`
`in discovery”2 is false. Consistent with his deposition testimony, Barse simply
`
`testified at trial that the Committee was advised by counsel on the Transaction,
`
`including that it was Qualified, without introducing the substance of counsel’s
`
`advice. Defendants do not rely on counsel’s advice: the question of whether the
`
`Transaction was Qualified is governed entirely by the Agreements, irrespective of
`
`the Committee’s process.
`
`3.
`
`Plaintiffs also have no authority for the extreme relief they seek. They
`
`do not cite a single case in which a court reopened discovery following trial, struck
`
`the entirety of a witness’s trial testimony, or drew an adverse inference. The law is
`
`clear: if any remedy were warranted (none is), at most it would be to strike the
`
`challenged portion of Barse’s trial testimony. Plaintiffs’ Motion should be denied.
`
`2 Motion at 2.
`
`
`
`2
`
`
`
`
`
`

`

`BACKGROUND
`The sole issue in this contract case is whether the Transaction was
`
`4.
`
`Qualified.3 The Agreements do not condition this on any determination by JLI’s
`
`Independent Committee at all, much less on the process it used in approving the
`
`Transaction. Despite this, Plaintiffs have tried to put at issue the conduct of the JLI
`
`Board and Independent Committee, alleging that the Transaction “is the latest in a
`
`series of conflicted transactions in which the Insiders have” benefited themselves4
`
`and arguing that the Committee “rubber stamp[ed]” it.5 At trial, Plaintiffs called
`
`Barse in their own case to question him, not about the actual facts relevant to the
`
`contractual analysis, but about what the Committee knew when, and what diligence
`
`it did. In response, Defendants’ trial examination of Barse presented the
`
`Committee’s process in negotiating and approving the Transaction.
`
`A.
`
`5.
`
`JLI provided the requested discovery.
`
`Plaintiffs sought broad discovery of the Committee and its members,
`
`which JLI and counsel for the Committee provided. 6 In total, nearly 1,000
`
`
`3 D.I. 55 at 2-3. Capitalized terms not defined herein have the same meaning as in
`Defendants’ Pre-Trial Briefs. D.I. 223, 239.
`
`4 D.I. 1 at 2.
`
`5 D.I. 224 at 49.
`
`6 E.g., JX-502; JX-560; JX-610; JX-644.
`
`3
`
`
`
`
`
`

`

`documents relating to the Committee were produced,7 and its communications with
`
`counsel reflecting substantive legal advice were withheld as privileged.8 During
`
`discovery, Plaintiffs raised no timely issues with this production nor with the
`
`privilege assertions.9
`
`6.
`
`At their January depositions, Committee members Barse and Aronzon
`
`provided substantive responses (to the best of their recollection) on a host of topics
`
`related to the Transaction, while asserting privilege over communications with
`
`counsel reflecting substantive legal advice. Barse in particular testified at his
`
`deposition that:
`
`• he knew “Pritzker had no financial interest nor control in JL Tao,” and that he
`
`“became more aware of how they were related” around October 2023,
`
`including that “the beneficiaries [are] the children of Nick”;10
`
`
`7 E.g. JX-459; JX-466; JX-480; JX-502; JX-521; JX-560; JX-607; JX-610; JX-618; JX-
`638; JX-644; JX-707; JX-757; JX-777; JX-916; JX-01069; JX-01067; JX-01074; JX-
`01082; JX-01101; JX-01106; JX-01107; JX-01111.
`
`8 See Motion, Appendix 1.
`
`9 Plaintiffs sent two letters requesting supplemental productions, which JLI promptly
`made.
`
`10 Barse Dep. 46:10-25, 149:7-9.
`
`4
`
`
`
`
`
`

`

`• he did not discuss Bowen’s Board resignation with other Board members, but
`
`it was “not relevant” because “at the time of the qualified financing proposal
`
`that we were reviewing, he was not a member of the board”;11
`
`• “the provisions of the [NWPA] were pretty clear . . . about what made one
`
`qualified,” and he was prepared to discuss further “if you showed me” the
`
`provisions (Plaintiffs did not);12
`
`• the Guggenheim presentation provided the Committee with “information that
`
`went to supporting that this was, in fact, a qualified financing”; he did not
`
`recall the details, but he volunteered to “talk through” the presentation “if we
`
`can go back to [it],” asking multiple times that “you show[] me something”
`
`(Plaintiffs declined).13
`
`7.
`
`Barse and Aronzon both testified to the fact that the Committee “was
`
`advised by counsel that [the Transaction] met the standards of the qualified
`
`financing,”14 and counsel instructed them not to disclose the substance of the advice,
`
`11 Id. 102:14-106:8.
`
`
`
`12 Id. 142:18-143:6; 132:12-16; 131:4-14.
`
`13 Id. 170:5-13; 45:19-21; 54:7-16.
`
`14 Id. 151:5-8; 154:8-15; 143:7-17; Aronzon Dep. 303:11-16; 136:9-17.
`5
`
`
`
`
`
`

`

`including any legal analysis.15 If Plaintiffs believed in January that any of this put
`
`counsel’s advice at issue (it did not), they could have raised it with JLI then and
`
`moved to compel before the close of discovery.
`
`Barse testified consistently at trial.
`
`Barse’s testimony at trial was consistent with his deposition, including
`
`B.
`
`8.
`
`that:16
`
`• counsel for the Committee “did a thorough legal analysis of the contract and
`
`made recommendations to us [that] the financing met the requirements.”17
`
`• the Guggenheim presentation “was our way
`
`to have supporting
`
`information”—from the Investors—“as to the determination that it was indeed
`
`a Qualified Financing.”18 He then talked through what two slides showed the
`
`Committee about why the Transaction was Qualified.19
`
`
`15 Barse Dep. 105:12-14; 150:6-8.
`
`16 See Appendix 1 (comparing Barse’s deposition and trial testimony).
`
`17 Tr. 367:19-24. Compare Barse Dep. 151:5-8 (“I was advised by counsel that [the
`Transaction] met the standards of the Qualified Financing.”).
`
`18 Id. 373:8-14.
`
`19 Id. 373:10-374:16; JX-1087 at -08599-600. Compare Barse Dep. 166:22-167:5; 169:19-
`23; 170:5-13.
`
`
`
`6
`
`
`
`

`

`• “I was fully aware of the fact that we needed to have 500 million in total
`
`financing, 400 million of which came from shareholders under 5 percent,” and
`
`the Committee concluded those were satisfied.20
`
`*
`
`*
`
`*
`
`9.
`
`Defendants tried to avoid burdening the Court with this dispute.
`
`Following the Court’s guidance, Defendants asked Plaintiffs to confer on a possible
`
`resolution.21 Plaintiffs refused to do so, and instead simply filed their motion. Not
`
`only are Plaintiffs wrong to assert a conflict between Barse’s deposition and trial
`
`testimony, they are also wrong to suggest that Defendants intend to use such
`
`testimony (and the Committee’s determination) “in order to prove [their] case.”22
`
`Had Plaintiffs timely conferred, this Motion may have been avoided, which this
`
`Court has recognized is grounds to deny a motion to compel.23
`
`
`20 Tr. 378:10-16. Compare Barse Dep. 142:18-143:6
`
`21 Exhibit 1 (March 22, 2024 email to Plaintiffs).
`
`22 Motion at 11 (internal citation omitted), 14.
`
`23 See Transcript and Rulings on Defendants’ Motions to Compel at 25 (Feb. 27, 2024)
`(D.I. 255) (“[F]olks haven’t met and conferred and instead have thrown this in the Court’s
`lap.”).
`
`
`
`7
`
`
`
`

`

`ARGUMENT
`A. Defendants have not put the Committee’s privilege at issue.
`
`10. The “at-issue” exception to the attorney-client privilege arises only
`
`when “(1) a party injects the privileged communications themselves into the
`
`litigation, or (2) a party injects an issue into the litigation, the truthful resolution of
`
`which requires an examination of confidential communications.” In re William Lyon
`
`Homes S'holder Litig., 2008 WL 3522437, at *3 (Del. Ch. Aug. 8, 2008). The
`
`exception ensures that “a defendant may not refuse to produce privileged attorney-
`
`client communications only to rely subsequently on the substance of those
`
`communications to prove its case.” In re Quest Software Inc. S'holders Litig., 2013
`
`WL 3356034, at *2 (Del. Ch. July 3, 2013) (emphasis added). Here, Defendants
`
`have not injected privileged communications into this litigation, and determining
`
`whether the Transaction is a Qualified Financing does not require delving into the
`
`Independent Committee’s views on the matter. Nor are Defendants relying on the
`
`substance of any withheld privileged communications or advice for their defense.
`
`11. Plaintiffs argue Defendants put the privilege at issue because Barse
`
`testified (1) “that his memory was ‘refreshed’ by a number of documents shown to
`
`him after his deposition”; (2) “in detail about which Insider entities met which
`
`requirements of the notes”; and (3) that the Independent Committee’s counsel “did
`
`
`
`8
`
`
`
`

`

`a thorough legal analysis of the contract” concluding that the Transaction “‘met the
`
`requirements’ . . . to be a ‘Qualified Financing.’”24 This testimony does not show
`
`waiver.
`
`12. Refreshed Recollection. Plaintiffs argue that Barse’s “recollection had
`
`been refreshed by counsel as to facts about which he denied any knowledge at his
`
`deposition,”25 and that, “contrary to his deposition testimony[], Barse claimed at trial
`
`that counsel had made him aware of ownership and management changes to JL Tao
`
`in 2023.”26 This is wrong. First, Barse made clear he refreshed his recollection by
`
`reviewing non-privileged documents. 27 Second, Plaintiffs do not identify any
`
`substantive differences between his deposition and trial testimony. Regarding JL
`
`Tao, Barse testified at trial—consistently with his deposition—that in October 2023
`
`he did not know “there were changes [made] to JL Tao in the May through
`
`September period,”28 and that he and Aronzon did not consider “what the structure
`
`was of JL Tao months or years earlier in considering whether this was a qualified
`
`
`
`24 Motion at 12.
`
`25 Id. at 2.
`
`26 Id. at 9.
`
`27 Tr. 377:3-14 (“Q. [Did you review] any privileged communications from your counsel?
`A. No.”).
`
`28 Id. 377:15-22.
`
`
`
`9
`
`
`
`

`

`financing.”29 Finally, this testimony was elicited by Plaintiffs, and Defendants are
`
`not relying on it.
`
`13. Testimony About Contractual Requirements. Plaintiffs also claim that
`
`“Barse proceeded to testify at trial that the Independent Committee believed that the
`
`funds from Bowen’s and Monsees’s investment vehicles, as well as JL Tao, counted
`
`toward a Qualified Financing,” after being instructed not to answer such questions
`
`during his deposition.30 This is not true. Barse’s trial testimony merely summarized
`
`how the Guggenheim presentation (which was produced) presented that the
`
`Transaction was Qualified—information apparent on the face of that document and
`
`that Plaintiffs have known for months.31
`
`14. Specifically, at trial, Barse was shown the Guggenheim presentation,
`
`and he explained that “this was our way to have supporting information”—from the
`
`Investors—“as to the determination that it was indeed a Qualified Financing.”32 He
`
`then simply testified about information on two pages of the presentation and what it
`
`
`29 Id. 375:1-6. Plaintiffs are relying on snippets of Barse’s deposition testimony in which
`he was being asked questions about documents Plaintiffs declined to put in front of him; it
`is neither surprising nor suspicious that his recollection was better when (before and during
`trial) he was actually able to review them. See infra ¶ 15.
`
`30 Motion at 10.
`
`31 See JX-1087 at -08599-600.
`
`32 Tr. 373:8-14.
`
`
`
`10
`
`
`
`

`

`showed about how three of the investors satisfied the requirements for a Qualified
`
`Financing.33 He did not separately testify as to “which entities he believed met those
`
`requirements,”34 or what his counsel advised him. This was all consistent with his
`
`deposition, where Barse explained that the Guggenheim presentation provided
`
`“specifics about [JL Tao] and whether they had met the provision of what was or not
`
`a qualified party,” and he noted “if we can go back to the exhibit, we can talk through
`
`it specifically” (Plaintiffs’ counsel never did).35
`
`15. Equally meritless is Plaintiffs’ claim that Barse waived privilege in
`
`testifying “about what he believed the contractual requirements for a Qualified
`
`Financing to be.”36 That testimony could not have revealed privileged information
`
`because—as Barse testified at his deposition—the non-privileged NWPA is
`
`“specific on its face” about the requirements for a Qualified Financing.37 Barse
`
`explained during his deposition that “the provisions of the document were pretty
`
`
`
`33 Id. 373:10-374:16.
`
`34 Motion at 2.
`
`35 Barse Dep. 166:22-167:5; 170:5-13; 169:19-23.
`
`36 Motion at 10.
`
`37 Barse Dep. 131:3-14.
`
`11
`
`
`
`
`
`

`

`clear . . . about what made one qualified,”38 and while he did not recall the specifics,
`
`he stated, “if you showed me something, I’m sure it would help refresh my
`
`recollection.”39 Plaintiffs declined. Nothing Barse said at trial contradicted that
`
`deposition testimony. He did say that he “was fully aware” that a Qualified
`
`Financing required “500 million in total financing, 400 million of which came from
`
`shareholders under five percent” ownership,40 but that is the very information that
`
`appears on the face of the NWPA. Moreover, he had just looked at the Guggenheim
`
`presentation,41 which on page -08598 summarizes the contractual requirements. He
`
`never said his knowledge of these contractual requirements came from counsel.
`
`16. Testimony About Counsel’s Analysis. Plaintiffs claim that Defendants
`
`put legal advice at issue when Barse testified that counsel provided “analysis” and
`
`recommended that the Transaction “‘met the requirements’ . . . to be a ‘Qualified
`
`Financing.’”42 Not so.
`
`
`
`38 Id. 142:18-143:6.
`
`39 Id. 143:3-6.
`
`40 Tr. 378:10-16.
`
`41 JX-1087; Tr. 372:7.
`
`42 Motion at 12; Tr. 367:19-24.
`
`
`
`12
`
`
`
`

`

`17. First, Barse never testified about the substance of counsel’s advice or
`
`why counsel concluded the Transaction was Qualified. At trial (and nearly verbatim
`
`to his deposition, where Plaintiffs’ counsel questioned him on the Committee’s
`
`determination of how the Transaction was Qualified),43 Barse merely testified as to
`
`the fact that counsel “did a thorough legal analysis of the contract and made
`
`recommendations to us [that] the financing met the requirements under the
`
`noteholders agreement that it was qualified financing.”44 Plaintiffs never claimed
`
`that Barse’s nearly identical deposition testimony put the Committee’s privilege at
`
`issue.45
`
`18. Second, Plaintiffs’ presumption that Defendants will “rely on [legal
`
`advice given to the Independent Committee] . . . to argue that the [] Financing
`
`constituted a Qualified Financing,” 46 is wrong. Barse’s trial testimony was in
`
`response to questioning about the Committee’s “process”—not its analysis or
`
`counsel’s advice. And, as noted, Defendants are not relying on either that analysis
`
`
`43 Barse Dep. 150:12-151:8.
`
`44 Tr. 367:19-24. Compare Barse Dep. 151:5-8 (“I was advised by counsel that [the
`Transaction] met the standards of the Qualified Financing.”).
`
`45 See Transcript and Ruling on Plaintiffs’ Motion to Compel at 7-12 (Mar. 4, 2024) (D.I.
`258).
`
`46 Motion at 14, 11
`
`
`
`13
`
`
`
`

`

`or advice as a reason why the Court should conclude the Transaction was Qualified.
`
`As Plaintiffs well understand and have themselves argued, the Committee’s analysis
`
`of the Qualified Financing provision “is irrelevant. The issue is going to be
`
`determined by the Court, not Mr. Barse.”47 Indeed, Defendants introduced evidence
`
`about the Committee and its process only to correct the misleading impression
`
`Plaintiffs have tried to create that the Transaction “is the latest in a series of
`
`conflicted transactions” in which the Investors acted “for their own personal gain to
`
`the detriment of JUUL’s other stakeholders,” 48 and that the Committee “rubber
`
`stamped” it. Those points are contractually irrelevant, and Barse’s testimony did not
`
`put counsel’s advice at issue; Defendants will not rely on that testimony in post-trial
`
`briefing.49 See Quest, 2013 WL 3356034, at *4 (finding no waiver provided that
`
`defendant would not “rely on the substance of any privileged communications to
`
`support their case”); In re Comverge, Inc. S'holders Litig., 2013 WL 1455827, at *3-
`
`4 (Del. Ch. Apr. 10, 2013) (“[E]xamination of privileged communications is not
`
`required for the truthful resolution of this litigation” largely because “Defendants
`
`reaffirmed that ‘we have always maintained that we are not relying on an advice-of-
`
`47 Tr. 376:3-7.
`
`48 D.I. 1 at 2.
`
`49 Tr. 367:19-24.
`
`14
`
`
`
`

`

`counsel defense’”); In re Liquid. Of Indem. Ins. Corp., RRG, C.A. No. 8601-VCZ,
`
`at 5 (Del. Ch. Mar. 18, 2019) (ORDER)50 (similar).
`
`19.
`
`Plaintiffs’ cases are inapposite. The issue in Citadel Holding was
`
`whether a party’s attorneys’ work was reasonable; the party waived privilege over
`
`attorney timesheets after attorney witnesses testified about them. 603 A.2d 818, 825
`
`(Del. 1992). Similarly, in Amirsaleh defendant waived privilege when it relied on
`
`counsel’s advice to justify treating plaintiff differently than others. 2008 WL
`
`241616, at *3 (Del. Ch. Jan. 17, 2008). Unlike both cases, Defendants are not basing
`
`their defense on counsel’s advice or privileged information. Finally, William Lyon
`
`supports Defendants. There, defendant produced evidence about consulting counsel
`
`but did not disclose the details of any advice in service of its case, and the court
`
`found no waiver. William Lyon, 2008 WL 3522437, at *3-4.
`
`B.
`
`20.
`
`Plaintiffs have requested significantly overbroad relief.
`
`Finally, Plaintiffs’ proposed relief is overbroad and not supported by
`
`caselaw. As Plaintiffs’ cases affirm, waiver is “limit[ed] . . . to the subject matter of
`
`the disclosed communication.” Citadel, 603 A.2d at 825; TCV VI, L.P. v.
`
`TradingScreen Inc., 2015 WL 5674874, at *6 (Del. Ch. Sept. 25, 2015). But here,
`
`Plaintiffs request hundreds of documents without linking each one to allegedly
`
`50 Exhibit 2.
`
`15
`
`
`
`

`

`problematic testimony, and most of them have nothing to do with counsel’s analysis.
`
`Their list includes documents discussing: (i) a financing term sheet with Plaintiffs,
`
`(ii) strategy in an unrelated books-and-records litigation, (iii) negotiation of the
`
`Transaction’s economic terms, and (iv) the NWPA in 2022.51
`
`21.
`
`Plaintiffs’ alternative remedy is equally overbroad and unprecedented.
`
`Where this Court has found that trial testimony put at issue counsel’s advice that had
`
`previously been shielded during discovery, the court has struck only that specific
`
`testimony. In Plaintiffs’ own case, Chesapeake Corp., the Court determined “not to
`
`give any weight” to testimony on the narrow issue about which Defendants withheld
`
`information. 771 A.2d 293, 301 (Del. Ch. 2000). We are aware of no case where
`
`this Court has struck a witness’s testimony in its entirety, let alone drawn an adverse
`
`inference—and Plaintiffs cite none.
`
`22. While Defendants maintain that Plaintiffs are not entitled to any relief
`
`for the reasons detailed above, were a remedy called for, it would be at most to strike
`
`the particular testimony found problematic. Logan v. Salix Pharmas., Ltd., C.A. No.
`
`2019-0059-SG, at 5:1-5 (Del. Ch. Sept. 14, 2022) (TRANSCRIPT) 52 (denying
`
`motion to compel because “there’s an easy resolution, and that is to simply exclude
`
`51 Motion at 13, Appendix 1 (entries 441, 645, 361, 509).
`
`52 Exhibit 3.
`
`16
`
`
`
`

`

`this testimony . . . because it’s not relevant to the issue that will be presented at
`
`trial”); Restanca, LLC v. House of Lithium, Ltd., 2023 WL 4306074, at *15 (Del.
`
`Ch. June 30, 2023) (“[T]he court will not consider [] testimony [on the waived
`
`issues].”).
`
`CONCLUSION
`For the foregoing reasons, Defendants respectfully request that the
`
`23.
`
`Court deny Plaintiffs’ motion.
`
`OF COUNSEL
`
`Roger A. Cooper (Pro Hac Vice)
`Lina Bensman (Pro Hac Vice)
`CLEARY GOTTLIEB STEEN
`& HAMILTON LLP
`One Liberty Plaza
`New York, New York 10006
`(212) 225-2000
`
`MORRIS NICHOLS ARSHT &
`TUNNELL
`
`/s/ David J. Teklits
`David J. Teklits (#2432)
`Alexandra M. Cumings (#6146)
`Grant E. Michl (#7088)
`Kirk C. Andersen (#7156)
`1201 North Market Street, 16th Floor
`Wilmington, DE 19801
`(302) 658-9200
`
`Attorneys for JUUL Labs, Inc.
`
`17
`
`
`
`

`

`RICHARDS, LAYTON & FINGER, P.A.
`
`/s/ Richard P. Rollo
`Richard P. Rollo (#3994)
`Travis S. Hunter (#5350)
`John M. O’Toole (#6448)
`920 North King Street
`Wilmington, Delaware 19801
`(302)651-7700
`
` Attorneys for JL Tao LLC
`
`Words: 2,995/3,000
`
`Dated: April 9, 2024
`
`18
`
`
`
`

`

`CERTIFICATE OF SERVICE
`I hereby certify that on April 16, 2024, a copy of the foregoing
`
`[PUBLIC VERSION] Defendants’ Opposition to Plaintiffs’ Motion to Compel was
`
`served by File & ServeXpress on the following attorneys of record:
`
`Daniel A. Mason
`Sabrina M. Hendershot
`Elizabeth Wang
`PAUL, WEISS, RIFKIND, WHARTON
`& GARRISON LLP
`500 Delaware Avenue, Suite 200
`Wilmington, DE 19801
`
`Richard P. Rollo
`Alexander M. Krischik
`Travis S. Hunter
`John M. O’Toole
`RICHARDS, LAYTON & FINGER, P.A.
`One Rodney Square
`920 North King Street
`Wilmington, Delaware 19801
`
`Kirk C. Andersen
`Kirk C. Andersen (#7156)
`
`
`
`
`
`
`
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket