`
`
`TPG RE III VOLT HOLDINGS, L.P.,
`
`
`
`
`
` Plaintiff and
`Counterclaim-Defendant,
`
`
`v.
`
`
`
`QUANTUM LOOPHOLE, INC. and
`QUANTUM DEV, LLC,
`
`
`Defendants and
`Counterclaim-Plaintiffs,
`
`
`
`
`
`
`C.A. No. 2024-1002-PAF
`
`
`
`
`
`
`
`
`
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`)
`
`)
`QUANTUM MARYLAND JV, LLC
`)
`and QLOOP JV, LLC,
`
`)
`
`
`)
` Nominal Defendants.
`
`
`
`SUBPOENA AD TESTIFICANDUM DIRECTED TO
`GEO-TECHNOLOGY ASSOCIATES, INC.
`
`
`and
`
`To: Geo-Technology Associates, Inc.
`c/o Corporation Service Company
`251 Little Falls Drive
`Wilmington, DE 19808
`
`
`YOU ARE HEREBY COMMANDED:
`
`
`
`To produce for deposition upon oral examination, the person or persons most
`
`knowledgeable of the Deposition Topics set forth in Schedule A, on such date and
`
`at such location, including remotely via internet platform, as counsel for the parties
`
`and deponent shall agree or as ordered by the Court. The deposition will be taken
`
`EFiled: Nov 15 2024 04:45PM EST
`Transaction ID 75020268
`Case No. 2024-1002-PAF
`
`
`
`orally, under oath, before a court reporter, notary public, or other person authorized
`
`to administer oaths, shall continue day to day until completed or adjourned, and will
`
`be recorded by stenographic, audio, video, and/or real-time transcription (e.g.,
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`LiveNote). Any such recording may be admitted as testimony during the trial in the
`
`above-captioned action.
`
`This subpoena is issued pursuant to Court of Chancery Rule 45. A copy of
`
`Court of Chancery Rules 45(c) and (d), attached hereto as Schedule B, sets forth
`
`your protections and duties with respect to this subpoena.
`
`
`
`The Stipulation and Order for Production and Exchange of Confidential
`
`Information entered in the above-captioned action, a copy of which is attached
`
`hereto as Schedule C, sets forth protections available to you with respect to your
`
`deposition testimony requested pursuant to this Subpoena.
`
`
`
`2
`
`
`
`
`
`OF COUNSEL:
`
`Christopher R. Bankler
`Cody A. Martinez
`Meredith S. Tavallee
`JACKSON WALKER LLP
`2323 Ross Avenue, Suite 600
`Dallas, Texas 75201
`(214) 953-6000
`
`
`
`
`
`
`
`
`
`
`
`OF COUNSEL:
`
`William T. Reid, IV
`Lisa S. Tsai
`Craig Boneau
`Jeremy Wells
`Julia Di Fiore
`REID COLLINS & TSAI LLP
`1301 S. Capital of Texas Hwy
`Suite C300
`Austin, TX 78746
`(512) 647-6100
`
`Dated: November 15, 2024
`
`
`
`
`
`
`POTTER ANDERSON & CORROON LLP
`
`By: /s/ Lilianna Anh P. Townsend
`Jaclyn C. Levy (#5631)
`Mathew A. Golden (#6035)
`Lilianna Anh P. Townsend (#6213)
`Ellis H. Huff (#6825)
`Ryan M. Crowley (#7183)
`1313 North Market Street
`Hercules Plaza, 6th Floor
`Wilmington, Delaware 19801
`(302) 984-6000
`jlevy@potteranderson.com
`mgolden@potteranderson.com
`ltownsend@potteranderson.com
`ehuff@potteranderson.com
`rcrowley@potteranderson.com
`
`
`- and -
`
`
`REID COLLINS & TSAI LLP
`
`
`Norman M. Monhait (#1040)
`Jessica Zeldin (#3558)
`Alexander J. Rigby (#7257)
`300 Delaware Avenue, Suite 770
`Wilmington, DE 19801
`(302) 467-1765
`nmonhait@reidcollins.com
`jzeldin@reidcollins.com
`arigby@reidcollins.com
`
`
`Counsel for Defendants and Counterclaim-
`Plaintiffs Quantum Loophole, Inc. and
`Quantum Dev, LLC
`
`
`3
`
`
`
`IN THE COURT OF CHANCERYOF THE STATE OF DELAWARE
`
`
`C.A. No 2024-1002-PAF
`
`
`
`TPG RE III VOLT HOLDINGS, L.P.,
`
`Plaintiff,
`
`QUANTUM LOOPHOLE,INC. and QUANTUM DEV,LLC,
`
`Defendants and Counterclaim-Plaintiffs,
`
`QUANTUM MARYLAND JV, LLC and QLOOP JV, LLC,
`
`Nominal Defendants.
`
`
`AFFIDAVIT OF SERVICE
`
`ss.
`
`} }
`
`STATE OF DELAWARE
`
`COUNTY OF NEW CASTLE }
`
`I, Charles Hall, of Parcels, Inc., the State of Delaware, County of New Castle,
`being duly sworn, says that on the 15" day of November, 2024 at 12:45 p.m., I
`personally served a copy of aSUBPOENA AD TESTIFICANDUM with
`supporting documents on GEO-TECHNOLOGY ASSOCIATES,INC., by
`serving the registered agent, Corporation Service Company at 251 Little Falls
`Drive Wilmington, DE 19808.
`
`Nameofindividual accepting service: Lynanne Gares — Authorized to Accept.
`Description of individual: Caucasian female, 35-40 yrs. old, 150 Ibs., 55” with
`brownhair.
`
`~
`
`.Chagles Ball
`
`Subscribed and sworn before me
`This 15" day of November, 2024
`Notary Public
` ZAHID HOSSAIN NAWAZ
`
`NOTARY PUBLIC
`
`
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