IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`MIR ANWAR, JEREMY KRELL, and
`ROBERT HOROWITZ,
`Plaintiffs,
`v.
`QUIP NYC INC., SIMON ENEVER,
`WILLIAM MAY, and GEORGE
`WELLS,
`Defendants.
`Civil Action No. 2025-0258-MTZ
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`PLAINTIFFS, MIR ANWAR, JEREMY KRELL, AND ROBERT
`HOROWITZ’S MOTION FOR LEAVE TO FILE LIMITED SURREPLY
` Pursuant to Court of Chancery Rule 7, Plaintiffs Mir Anwar, Jeremy Krell,
`and Robert Horowitz (collectively, “Plaintiffs”), hereby move this Court for leave
`to file the proposed Limited Surreply Addressing Certain Statements Contained in
`Defendants’ Reply Brief (the “Limited Surreply”), attached hereto as Exhibit A. In
`support of this motion, Plaintiffs respectfully show the Court as follows:
`WHEREAS, on May 21, 2025, Plaintiffs’ counsel and Defendants’ counsel met
`and conferred regarding certain representations made in a single paragraph and
`accompanying footnote found between pages 9 and 10 of Defendants’ Reply Brief in
`Further Support of their Motion to Dismiss Plaintiffs’ Complaint;
`WHEREAS, Plaintiffs’ counsel requested that Defendants join in a stipulation
`granting Plaintiffs leave to file the Limited Surreply addressing those representations,
`and sent Defendants’ counsel an initial draft (since revised) of the Limited Surreply via
`email on May 30, 2025.
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`EFiled: Jun 11 2025 03:07PM EDT
`Transaction ID 76442218
`Case No. 2025-0258-MTZ
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`WHEREAS, on June 10, 2025, Defendants’ counsel informed Plaintiffs’
`counsel that Defendants do not consent to Plaintiffs’ motion for leave to file the
`Limited Surreply, contending that the issues in the Limited Surreply could instead be
`addressed at oral argument.
`WHEREAS, neither Plaintiffs’ counsel nor Defendants’ counsel have
`“contact[ed] the Court to schedule any requested oral argument” as required under
`this Court’s March 28, 2025 Order Governing Briefing on Defendants’ Motion to
`Dismiss;
`WHEREAS, no oral argument is scheduled or likely forthcoming on
`Defendants’ Motion to Dismiss;
`WHEREAS, Plaintiffs’ request leave to file the proposed 2.5-page Limited
`Surreply attached hereto, addressing only the challenged representations contained
`in the subject paragraph and footnote;
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`WHEREFORE, Plaintiffs’ request that the Court enter the proposed order
`below, granting leave for Plaintiffs to file the Limited Surreply.
`Respectfully submitted this 11th day of June, 2025.
`Words: 393/3,000 FREEMAN MATHIS & GARY, LLP
` /s/ Daniel M. Young
`OF COUNSEL: Daniel M. Young
` Delaware Bar No. 4945
`Jill R. Dunn* 1521 West Concord Pike, Suite 301
`Cameron N. Regnery* Wilmington, Delaware 19803
`100 Galleria Parkway, Suite 1600 (T): 856-866-8921
`Atlanta, Georgia 30339 Daniel.Young@fmglaw.com
`(T): 770-818-0000 (F): 833-330-3669 Counsel for Plaintiffs
`JDunn@fmglaw.com
`Cameron.Regnery@fmglaw.com
`(* pro hac vice applications forthcoming)
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