Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 1 of 18
`
`Exhibit
`
`A
`
`

`

`Sty
`@
`F
`Baby
`Sey
`“Aa
`
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 2 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page
`2 of 18
`E-FILED; Howard Circuit Court
`CIRCUIT COURT FOR HOWARD 6QUN17¥%46/2021 10:07! !Sizhifission: 7/16/2021 10:01 AM
`MARYLAND
`Criminal: 410-313-3822
`Civil: 410-313-3844
`Juvenile: 410-313-3827
`9250 Judicial Way
`Land Records: 410-313-5850
`Ellicott City, Maryland 21043
`Calendar Office: 410-313-3575
`Family Law: 410-313-2225
`
`To: ESTRENO PHARMACEUTICALS LLC
`BLUMBERG CORPORATESERVICES, LLC
`245 WEST CHASE STREET
`BALTIMORE, MD 21201
`
`Case Number:
`Other Reference Number(s):
`Child Support Enforcement Number:
`
`SCIREGS INTERNATIONAL,INC. VS. IDENTI PHARMACEUTICALS, LLC, ET AL.
`
`C-13-CV-21-000484
`
`Issue Date: 7/16/2021
`
`summonedto file a written response by pleading
`You are
`hereby
`summonsupon you,in this court, to the attached complaint
`filed
`by:
`
`or
`
`motion, within 30 days after service of this
`
`WRIT OF SUMMONS
`
`SCIREGS INTERNATIONAL, INC.
`Maryland Corporation
`6333 Summercrest Drive
`Columbia, MD 21045
`
`This summonsis effective for service only if served within 60 daysafter the dateit is issued.
`
`WayneA.
`Robey
`Clerk of the Circuit Court
`
`To the person summoned:
`Failure to file a response within the time allowed may
`result in a
`sought against you.
`Personalattendancein court on the day named is NOTrequired.
`
`Instructions for Service:
`
`judgment by default or the granting
`
`ofthe relief
`
`1. This summonsis effective for service only if served within 60
`daysafter the date issued. If it is not served within
`must send a written request to have it renewed.
`the 60 days,the plaintiff
`2. Proof of Service shall set out the nameofthe person served, date and the particular place and mannerofservice.
`state the reasons.
`If service is not made, please
`3. Return of served or unserved processshall be made promptly and in accordance with Maryland
`separate affidavit as
`If this notice is served by private process, process servershall file a
`4.
`required by Maryland
`Rule 2-126(a).
`
`Rule 2-126.
`
`CC-CV-032 (Rev. 11/23/2020)
`
`Page 1 of 2
`
`07/16/2021 9:53 AM
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 3 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 3 of 18
`Circuit Court for Howard County
`SciRegs International, Inc. vs. Identi Pharmaceuticals, LLC,etal.
`Case Number: C-13-CV-21-000484
`
`SHERIFF'S RETURN
`
`(please print)
`
`To: ESTRENO PHARMACEUTICALS LLC
`
`Serving Sheriff's Name
`County Sheriffs office present to the court that I:
`
`ID#
`
`of the
`
`(1) Served
`
`on
`
`Date ofservice
`
`at
`
`by
`
`Nameof
`
`person served
`
`Location ofservice
`
`Mannerofservice
`
`with the
`
`following:
`
`[_] Summons
`[_] Complaint
`[_] Motions
`[_] Petition and Show Cause Order
`Other
`
`(]
`
`Please specify
`
`[(-] Counter-Complaint
`[_] Domestic Case Information Report
`Financial Statement
`
`[_]
`
`[_] Interrogatories
`
`(2) Was unable to serve because:
`Movedleft no
`forwarding address
`(J
`([] Addressnotin jurisdiction
`
`No such address
`[_]
`_] Other
`
`Please specify
`
`Sheriff fee: $
`
`(J waived by
`
`Date
`
`Signature of serving Sheriff
`
`Instructions to Sheriff’s Office or Private Process Server:
`days after the date issued. If it is not served within
`1. This Summonsis effective for service only if served within 60
`must send a written request to have it renewed.
`60 days, the plaintiff
`2. Proof of Service shall set out the name ofthe person served, date and the particular place and mannerofservice.
`state the reasons.
`If service is not made, please
`Return of served or unserved process shall be made promptly and in accordance with Rule 2-126.
`server shall file a
`separate affidavit as
`If this summonsis served by private process, process
`required by Rule 2-
`126(a).
`
`w
`4.
`
`CC-CV-032 (Rev. 11/23/2020)
`
`Page2 of 2
`
`07/16/2021 9:53 AM
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21
`4 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 4 of 18
`Page
`-FILED; Howard Circuit Court
`Docket: 7/15/2021 3:43 PM; Submission: 7/15/2021 3:43 PM
`
`IN THE CIRCUIT COURT FOR HOWARD COUNTY, MARYLAND
`
`SCIREGS INTERNATIONAL,INC.,
`a
`Marylandcorporation,
`6333 Summercrest Drive
`21045
`
`Columbia, Maryland
`
`*
`
`Civil Case No.
`
`©-19-CV-21-000484
`
`Plaintiff,
`
`V.
`
`IDENTI PHARMACEUTICALS, LLC,
`a Delawarelimited liability company,
`833 W 15th Place, Unit 901
`IL 60608
`Chicago,
`
`Serve On:
`
`Maryland State Department of
`Assessments and Taxation
`301 W Preston Street
`Baltimore, MD 21201
`
`and
`
`IDENTIRX, LLC,
`a Delawarelimited
`liability company,
`833 W 15th Place, Unit 901
`IL 60608
`Chicago,
`
`Serve On:
`
`State Departmentof
`Maryland
`Assessments and Taxation
`301 W Preston Street
`Baltimore, MD 21201
`
`and
`
`FLATWING PHARMACEUTICALS,LLC,
`a Delaware limited liability company,
`833 W 15th Place, Unit 901
`IL 60608
`Chicago,
`
`Serve On:
`
`State Department of
`Maryland
`Assessments and Taxation
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 5 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 5 of 18
`
`301 W Preston Street
`Baltimore, MD 21201
`
`and
`
`ESTRENO PHARMACEUTICALSLLC,
`a Delawarelimited liability company,
`1560
`Sawgrass Corporate Pkwy
`Sunrise, FL 33323
`
`Serve On:
`
`BLUMBERG CORPORATE
`SERVICES, LLC
`245 West Chase Street
`Baltimore, MD 21201
`
`and
`
`RAJNEESH KUMAR AHUJA,
`1800 S Ocean Dr, Apt 4301
`Hallandale Beach, FL 33009
`
`Defendants.
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`COMPLAINT
`
`SCIREGS INTERNATIONAL,INC. (“SciRegs”),
`
`a
`
`Maryland corporation, Plaintiff, by
`
`and
`
`through
`
`its attorneys, Eric W. Gunderson and G. Harrison Bliss, of Davis, Agnor, Rapaport
`
`&
`
`Skalny, LLC,
`
`files
`
`this Complaint against
`
`IDENTI PHARMACEUTICALS, LLC,
`
`IDENTIRX,
`
`LLC,
`
`FLATWING
`
`PHARMACEUTICALS,
`
`LLC,
`
`ESTRENO
`
`PHARMACEUTICALS LLC, and RAJNEESH KUMAR AHUJA, Defendants,
`
`andstates:
`
`l.
`
`Jurisdiction is conferred upon this Court pursuant
`
`to
`
`
`Md. Code Ann., Cts. & Jud.
`
`JURISDICTION
`
`Proc. § 1-501.
`
`2.
`
`Personal
`
`jurisdiction is conferred upon this Court over Defendants pursuant
`
`to
`
`

`

`Case 1:21-cv-02270-DLB Document1-1 Filed 09/03/21 Page 6 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 6 of 18
`
`Md. Code Ann., Cts & Jud. Proc § 6-103(b)(1), and venueis proper in this Court pursuant
`
`to
`
`Md.
`
`Code Ann., Cts & Jud. Proc § 6-201(b) and § 6-202(3).
`
`THE PARTIES
`
`3.
`
`Plaintiff is a
`
`Maryland corporation
`
`and hasits principle place of business in
`
`Howard County, Maryland.
`
`4,
`
`Defendant Identi Pharmaceuticals, LLC (“Identi”), is a Delaware limited liability
`
`company, and transacted and/or currently
`
`transacts business in Maryland,
`
`including, but not
`
`limited to, transacting business with Plaintiff in Howard County, Maryland and with the Food
`
`and Drug Administration in Montgomery County, Maryland.
`
`5.
`
`Defendant IdentiRx, LLC (“IdentiRx”), is a Delaware limited liability company,
`
`and transacted and/or currently
`
`transacts business in Maryland,
`
`including, but not limited to,
`
`transacting business with Plaintiff in Howard County, Maryland and with the Food and Drug
`
`Administration in
`
`Montgomery County, Maryland.
`
`6.
`
`Defendant Flatwing Pharmaceuticals, LLC (‘“Flatwing”),
`
`is a Delaware limited
`
`liability company, and transacted and/or currently
`
`transacts business in Maryland,including,
`
`but
`
`not limited to, transacting business with Plaintiff in Howard County, Maryland and with the
`
`Food and Drug Administration in Montgomery County, Maryland.
`
`7.
`
`Defendant Estreno Pharmaceuticals, LLC (“Estreno”),
`
`is a Delaware limited
`
`liability company, and transacted and/or currently
`
`transacts business in
`
`Maryland,including,
`
`but
`
`not limited to, transacting business with Plaintiff in Howard County, Maryland
`
`and with the
`
`Food and Drug Administration in Montgomery County, Maryland.
`
`8.
`
`Defendant Rajneesh Kumar Ahuja,
`
`is a resident of Florida, is a member and/or
`
`managing
`
`memberof Identi, IdentiRx, Chandra V, Flatwing, and Estreno, and also transacted
`
`and/or currently
`
`transacts business in
`
`Maryland
`
`and with the Food and Drug Administration in
`
`3
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 7 of 18
`7 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page
`
`Montgomery County, Maryland.
`
`9.
`
`The cause of actions arose out and are in connection with the business the
`
`Defendants conducted with Plaintiff in Howard County, Maryland.
`
`FACTS
`
`10.
`
`In August 2018, SciRegs entered into a written agreement with Defendant Identi
`provide consulting services and act as
`
`regulatory affairs agent
`
`to Identi in connection with
`
`to
`
`Identi’s effort
`
`to seek approval
`
`from the Food and Drug Administration (FDA)
`
`for the
`
`manufacture andsale of certain
`
`pharmaceutical drugs (the “Identi Agreement”).
`
`11.
`
`Pursuant to the Identi Agreement, and pursuant
`
`to Mr. Ahuja’s request and
`
`direction, SciRegs provided
`
`consultation services to Identi,
`
`as well as to otheraffiliated entities,
`
`including IdentiRx.
`
`12.
`
`Relevant to the claims here, at the request of and with the approval
`
`of Mr.
`
`Ahuja,
`
`Identi, and IdentiRX, SciRegs provided services to Identi and IdentiRx during the period
`
`from
`
`January 2020
`
`13.
`
`2020.
`
`through September
`SciRegs invoiced Mr. Ahuja for these services on a
`
`monthly basis, with the
`
`charges for services due uponreceipt.
`
`14.
`
`‘In
`
`particular, for the
`
`period February
`
`2020
`
`through September 2020, for services
`
`provided
`
`to Identi and IdentiRx, SciRegs invoiced Mr. Ahuja for services totaling $188,312.50.
`
`15.
`
`To date, despite written demandsto pay these invoices, neither Mr.
`
`Ahuja, Identi,
`
`nor IdentiRx have
`
`paid SciRegs for the services provided.
`In March 2018, SciRegs entered into a written agreement with Defendant
`
`16.
`
`Flatwing
`
`to
`
`provide consulting
`
`services to
`
`Flatwing in connection with Flatwing’s effort to seek
`
`approval from the FDA for the manufacture and sale of certain pharmaceutical drugs (the
`
`“Flatwing Agreement”).
`
`

`

`8 of 18
`Case 1:21-cv-02270-DLB Document1-1 Filed 09/03/21 Page
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 8 of 18
`
`17.
`
`Pursuant to the Flatwing Agreement, and pursuant
`
`to Mr.
`
`Ahuja’s request and
`
`direction, SciRegs provided
`
`consultation services to
`
`Flatwing
`
`and Estreno.
`
`18.
`
`Relevant to the claims here, at the request of and with the approval
`
`of Mr. Ahuja,
`
`Flatwing and Estreno, SciRegs provided services to
`
`Flatwing and Estreno during the period from
`
`February
`
`2020
`
`19.
`
`through September 2020.
`SciRegs invoiced Mr. Ahuja for these services on a
`
`monthly basis, with the
`
`charges
`
`for services due uponreceipt.
`
`20.
`
`‘In
`
`particular, for the period February
`
`2020
`
`through September 2020, for services
`
`provided
`
`to
`
`Flatwing and Estreno, SciRegs invoiced Mr. Ahuja
`
`for services totaling $54,637.50.
`
`21.
`
`To date, despite written demandsto pay these invoices, Mr. Ahuja, Flatwing and
`
`Estreno have not
`
`paid SciRegsfor the services
`
`provided.
`
`22.
`
`Pursuant to the express terms of the Identi Agreement,
`
`legal action or
`
`proceeding
`
`party whoprevails
`to enforce any provision of the agreementis entitled to recover costs
`
`a
`
`in a
`
`and expense,including reasonable attorney’s
`
`fees.
`
`COUNT I
`Defendants Identi and IdentiRX
`(Breach of Contract)
`
`23.
`
`Plaintiff
`
`incorporates
`
`herein by reference Paragraphs
`
`1-22 in their entirety
`
`as
`
`thoughstated in full.
`
`24.
`
` SciRegs provided consulting
`
`services to Identi and IdentiRx pursuant
`
`to the Identi
`
`Agreement.
`
`25.
`
`26.
`
` SciRegs invoiced Mr. Ahuja, Identi, and IdentiRx for the services provided.
`
`Identi and IdentiRx breached the Identi Agreement by
`
`not
`
`paying SciRegs for the
`
`services it
`
`provided.
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 9 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 9 of 18
`
`27.
`
`Asa result of their breaches of the Identi Agreement, SciRegs has been damaged
`as a result of non-paymentof the services provided totaling $188,312.50.
`
`28.
`
`In addition, SciRegs has incurred and continues to incur expenses,
`
`including
`
`attorney’s fees, in seeking
`
`to enforce the paymentprovisions
`
`of the Identi Agreement.
`
`WHEREFORE,Plaintiff SciRegs International,
`
`Inc.
`
`respectfully
`
`demands judgment
`
`against
`
`Defendants Identi Pharmaceuticals, LLC and IdentiRX, LLC,
`
`in the amount of One
`
`Hundred Eighty Eight Thousand Three Hundred Twelve dollars and fifty
`
`cents
`
`($188,312.50),
`
`plus
`
`court costs, pre-judgment interest, post-judgment interest, expenses, including reasonable
`
`attorney’s fees, and any
`
`other relief the Court deems
`
`just and proper.
`
`COUNT Il
`Defendants Identi and IdentiRX
`
`(Unjust Enrichment)
`
`29.
`
`Plaintiff incorporates
`
`herein by reference Paragraphs
`
`1-22 in their entirety
`
`as
`
`thoughstatedin full.
`
`30.
`
`Per Mr.
`
`Ahuja’s request and direction and/or the request of Identi and IdentiRx,
`
`SciRegs provided consulting
`
`services to Identi and IdentiRx.
`
`31.
`
` Identi and IdentiRx received the benefit of these services.
`
`32.
`
`33.
`
`SciRegs invoiced Mr.
`
`Ahuja, Identi, and IdentiRx for the services provided.
`
` Identi and IdentiRx have not
`
`paid SciRegs
`
`for the services and benefit conferred
`
`upon each of them.
`
`34.
`
`The value of the services and benefit conferred upon Identi and IdentiRx totals
`
`$188,312.50.
`
`35.
`
`Asa result of the non-paymentof the services and benefit conferred upon Identi
`
`and IdentiRx, they have been unjustly enriched to the detriment of SciRegs
`
`in the amount of
`
`6
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 10 of 18
`Case 1:21-cv-02270-DLB Document1-1 Filed 09/03/21 Page 10 of 18
`
`$188,312.50.
`
`WHEREFORE,Plaintiff SciRegs International,
`
`Inc.
`
`respectfully demands judgment
`
`against Defendants Identi Pharmaceuticals, LLC and IdentiRX, LLC,
`
`in the amount of One
`
`Hundred Eighty Eight
`
`Thousand Three Hundred Twelve dollars and fifty
`
`cents
`
`($188,312.50),
`
`plus
`
`court costs, pre-judgment interest, post-judgment interest, and any other relief the Court
`
`deems
`
`just and proper.
`
`COUNT Ill
`and Estreno
`Defendants Flatwing
`(Breach of Contract)
`
`36.
`
`Plaintiff incorporates herein by reference
`
`Paragraphs
`
`1-22 in their entirety
`
`as
`
`thoughstated in full.
`
`37.
`
`SciRegs provided consulting services to
`
`Flatwing
`
`and Estreno pursuant to the
`
`Flatwing Agreement.
`
`38.
`
`39.
`
`SciRegs invoiced Mr.
`
`Ahuja, Flatwing
`
`and Estreno for the services provided.
`
` Flatwing and Estreno breached the
`
`Flatwing Agreement by
`
`not
`
`paying SciRegs
`
`for the services it provided.
`
`40.
`
`Asa result of their breaches of the Identi Agreement, SciRegs
`
`has been damaged
`
`as a result of non-paymentofthe services provided totaling $54,637.50.
`
`WHEREFORE, Plaintiff
`
`SciRegs International,
`
`Inc.
`
`respectfully
`
`demands judgment
`
`against Defendants Flatwing Pharmaceuticals, LLC and Estreno Pharmaceuticals, LLC, in the
`
`amountof Fifty Four Thousand Six Hundred Thirty-Seven dollars and fifty
`
`cents
`
`($54,637.50),
`
`plus
`
`court costs, pre-judgment interest, post-judgment interest, and any other relief the Court
`
`deemsjust and proper.
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 11 of 18
`11 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page
`
`COUNT
`and Estreno
`Defendants
`Flatwing
`(Unjust Enrichment)
`
`41.
`
`Plaintiff incorporates herein by
`
`reference
`
`Paragraphs
`
`1-22 in their entirety
`
`as
`
`thoughstatedin full.
`
`42.
`
`Per Mr.
`
`Ahuja’s request and direction and/or the request of
`
`Flatwing and Estreno,
`
`SciRegs provided consulting services to
`
`Flatwing and Estreno.
`
`43.
`
`44.
`
`45.
`
`Flatwing and Estreno received the benefit of these services.
`
`SciRegs invoiced Mr.
`
`Ahuja, Flatwing
`
`and Estreno for the services
`
`provided.
`
` Flatwing and Estreno have not
`
`paid SciRegs
`
`for the services and benefit conferred
`
`upon each of them.
`
`46.
`
`The value of the services and benefit conferred upon Flatwing and Estrenototals
`
`$43,025.00.
`
`47.
`
`_Asaresult of the non-paymentof the services and benefit conferred upon Identi,
`
`IdentiRx and Chandra V, they
`
`have been
`
`unjustly
`
`enriched to the detriment of SciRegs in the
`
`amount of $54,637.50.
`
`WHEREFORE,Plaintiff SciRegs International,
`
`Inc.
`
`respectfully
`
`demands judgment
`
`against Defendants Flatwing Pharmaceuticals, LLC and Estreno Pharmaceuticals, LLC, in the
`
`amount of Fifty Four Thousand Six Hundred Thirty-Seven dollars and
`
`fifty
`
`cents
`
`($54,637.50),
`
`plus
`
`court costs, pre-judgment interest, post-judgment interest, and any other relief the Court
`
`deemsjust and proper.
`
`COUNT V
`Defendant
`
`—
`Ahuja
`(Intentional Misrepresentation
`
`Fraud/Deceit)
`
`48.
`
`Plaintiff incorporates herein by reference Paragraphs
`
`1-22 in their entirety
`
`as
`
`8
`
`

`

`12 of 18
`Case 1:21-cv-02270-DLB Document1-1 Filed 09/03/21 Page
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 12 of 18
`
`thoughstated in full.
`
`49.
`
`on behalf of Identi, IdentiRX, Flatwing and Estreno,
`
`Defendant Ahuja, acting
`intentionally and with the intent to deceive SciRegs solicited and requested that SciRegs provide
`consulting services to each ofthese entities with no intention of paying for the services provided.
`the consultation services to Identi,
`
`50.
`
`In connection with
`
`IdentiRX,
`
`providing
`Flatwing and Estreno as solicited and requested by Defendant Ahuja, SciRegs believed that
`Defendant Ahuja, and these entities, intended to pay SciRegsfor the services provided.
`was
`
`51.
`
`faith with
`
`in good
`Moreover, Defendant Ahuja knew that SciRegs
`working
`for the services provided and at no time requested SciRegs
`now seeks to recover
`
`the belief that they would be paid
`
`to
`
`stop providing the services for which SciRegs
`
`payment.
`
`52.
`
` Asaresult of Defendant Ahuja’s deceit, SciRegs has suffered damages,including,
`
`but not
`
`necessarily limited to, the non-paymentfor the services providedtotaling $242,950.00.
`
`53.
`
` SciRegs also seeks punitive damages against Ahuja for his intentionaldeceit.
`
`WHEREFORE,Plaintiff SciRegs International,
`
`Inc.
`
`respectfully demands judgment
`
`against Defendant Rajneesh Ahuja in the amount of Two Hundred Forty Two Thousand Nine
`court costs, pre-judgment
`
`Hundred Fifty dollars ($242,950.00), plus
`
`interest, post-judgment
`
`interest, and any other relief the Court deemsjust
`
`and proper.
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 13 of 18
`Case 1:21-cv-02270-DLB Document1-1 Filed 09/03/21 Page 13 of 18
`
`Respectfully Submitted,
`
`DAVIS,
`AGNOR,
`SKALNY, LLC
`
`RAPAPORT
`
`/s/ Eric W. Gunderson
`
`Eric W. Gunderson (CPF 0012120262)
`G. Harrison Bliss (CPF 1612130060)
`10211
`Circle
`Wincopin
`Suite 600
`
`Columbia, Maryland
`410-995-5800
`
`21044
`
`egunderson@darslaw.com
`Attorneysfor Plaintiff
`
`10
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 14 of 18
`14 of 18
`Case 1:21-cv-02270-DLB Document1-1 Filed 09/03/21 Page
`E-FILED; Howard Circuit Court
`Docket: 7/15/2021 3:43 PM; Submission: 7/15/2021 3:43 PM
`
`IN THE CIRCUIT COURT FOR Howard County
`-
`
`CIVIL
`
`(
`
`or Coun
`
`[<j
`
`
`
`
`
`
`
`
`
`
`
`
`
`NON-DOMESTIC CASE INFORMATION REPORT
`DIRECTIONS
`
`must be completed and attached to the
`Plaintiff: This Information Report
`complaintfiled with the
`Clerk of Court unless your case is exempted from the requirement by the Chief Judge of the Court of
`
`
`Appeals pursuant to Rule 2-111(a).
`Defendant: You mustfile an Information Report
`as
`
`required by Rule 2-323(h).
`
`THIS INFORMATION REPORT CANNOT BE ACCEPTED AS
` “CVEZT-O00482
`FORM FILED BY:63PLAINTIFF OIDEFENDANT
`CASENUMBER_
`
`CASE NAME; SciRegsIntemational, Inc.
`Identi Pharmaceuticals, LLC, et al.
`ys,
`“
`REE D
`PARTY'S NAME:SciRegsInternational, Inc.
`PHONE:-
`PARTY'S ADDRESS: 6333 Summercrest Drive, Columbia, MD 21045
`;
`PARTY'S E-MAIL:
`an
`If represented by
`attorney:
`PHONE: 410-995-5800
`W. Gunderson
`PARTY'S ATTORNEY'S NAME:Eric
`
`PARTY'S ATTORNEY'S ADDRESS;:10211 Wincopin Circle, Suite 600, Columbia, MD 21044
`
`PARTY'S ATTORNEY'S E-MAIL: egunderson@darslaw.com
`
`RY DEMAND? OyYes &No
`RELATED CASE PENDING? OYes &No If yes, Case A(s), if known:
`ANTICIPATED LENGTH OF TRIAL?: ____
`hours _2 days
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`OC) Administrative Appeal O Appeal
`New Case:
`®Original
`Existing Case:
`"
`OPost-Judgment Amendment
`-
`filing in an
`case, skip Case Category/ Subcategory
`go to Relief section.
`if
`existing
`IF NEW CASE: CASE CATEGORY/SUBCATEGORY(Check one box.)
`Constructive Trust
`Government
`PUBLIC LAW
`0
`ProductLiability
`(Asbestos
`ttomey Grievance
`OBond Forfeiture Remission 0
`A
`Contempt
`Notice
`Deposition
`AssaultandBattery
`__
`PROPERTY
`O Civil Rights
`1 Dist Ct Mtn Appeal
`© Conspiracy
`©) Adverse Possession
`Code/Ord
`Ol Conversion
`(Financial
`CCounty/Mnepl
`Domain/Condemn.
`Breach of Lease
`Miscellaneous
`QElection
`Grand Jury/Petit Jury
`© Defamation
`ClFalse Arrest/Imprisonment
`strain
`Law
`Deine
`"
`1
`-Eminent
`Coram Nobis
`0
`:
`ofDocuments Req.
`Environment
`Perpetuate Testimony/Evidence
`ClLead Paint-DOBof
`P
`y
`Fraud
`Forcible Entry/Detainer
`Ejectment
`4 Youngest Pit:__ O) Foreclosure |
`GJEror
`(Prod.
`Recelvership-sfer
`q
`O Commercial
`Set Aside Deed
`HabeasCorpus
`Oi Prisoner Rights
`4 Loss ofConsortium
`.
`(J Special Adm.-
`O Residential
`Malicious Prosecution
`Atty
`o
`O Currency or Vehicle
`Act
`Public
`©) Malpractice-Medical
`Records Gj SubpoenaIssue/Quash
`Info.
`gq
`CJ Deed of Trust
`©) Malpractice-Professional
`© Trust Established
`O Writ ofCertiorari
`Quarantine/Isolation
`©
`Installments
`O Misrepresentation
`Trustee Substitution/Removal
`Lien
`O) Witness Appearance-Compel
`©} Motor Tort
`Land
`EMPLOYMENT
`PEACE ORDER
`ADA .
`LJ Nuisance
`Mortgage
`Oright ofRedemption A
`fy
`0
`0 Peace Order
`FiNegligence
`0 Statement Condo
`Premises Liability
`Conspiracy
`EQUITY
`© Forfeiture of Property/ CJEEO/HR
`ProductLiability
`EQ
`Personal Item
`Specific Performance
`OFLSA
`Declaratory Judgment
`C)
`0) Fraudulent Conveyance FMLA
`oxic Tort
`C1 injunctive Relief
`( Landlord-Tenant
`CO) Workers' Compensation
`Equitable Relief
`rongful Death
`C1 Lis Pendens
`O Mandamus
`Trespass
`C) Wrongful Termination
`in
`Lien
`Asbestos
`(J Mechanic's
`CONTRACT
`OTHER
`© Accounting
`Li
`ale
`tition
`in Lieu
`PRS
`©)Maryland InsuranceAdministration
`pavnership
`=
`5
`Breach
`Tadgnen
`(Friendly Suit
`and Commercial & Quiet Title
`usiness
`© Assumption of Jurisdiction Grantor in Possession
`Coesed
`0 Miscellaneous
`Specific Transaction
`P
`1 Structured Settlements
`
`
`
`
`section
`
`ercial
`
`eye
`
`CIenreed PropetyD
`
`GRight of Redemption
`Tenant Holding Over
`g
`
`0 Construction
`O Debt
`Ol Fraud
`
`CC-DCM-002 (Rev.04/2017)
`
`GQAttomey Appointment
`atta
`Body AttachmentIssuance
`Commission Issuance
`Page1 of 3
`
`
`
`
`
`Authorized Sale
`
`

`

`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 15 of 18
`Case 1:21-cv-02270-DLB Document1-1 Filed 09/03/21 Page 15 of 18
`
`CO)
`
`IF NEW OREXISTING CASE: RELIEF (Check All that Apply)
`© Abatement
`O Earnings Withholding O Judgment-Interest
`© Return of Property
`©)
`OCJudgment-Summary Sale of
`Enrollment
`Administrative Action
`Property
`Appointment of Receiver O Expungement
`©) Specific Performance
`O Liability
`O Findings of Fact
`O Arbitration
`O Writ-Error Coram Nobis
`Oral Examination
`© Asset Determination
`CO) Foreclosure
`Writ-Execution
`OoOrder
`© Attachment b/f Judgment J Injunction
`Og
`Ol Ownership ofProperty
`Writ-Garnish Property
`O Cease & Desist Order
`©
`O Condemn Bidg
` Q)Partition of Property
`o Judgment-Attorney Feespeace Order
`Writ-Garnish Wages
`QJudgment-Affidavit_
`Writ-Habeas Corpus
`oO Contempt
`0 Judgment-Confessed
`(Possession
`rit-Possession
`O Court Costs/Fees
`WntMandamus
` OProduction ofRecords
`OJudgment-Consent
`Damages-Compensatory Cl
`Judgment-Declaratory OQuarantine/Isolation Order
`OReinstatement of Employment
`Damages-Punitive
`OJudgment-Default
`Ifyou indicated Liability above, mark oneof the following. This information is not an admission and
`may
`not be used for any purpose other than Track Assignment.
`OLiability is conceded, QLiability is not conceded, butis not seriously in dispute. DLiability is seriously in dispute.
`MONETARY DAMAGES(Do notinclude Attorney's Fees, Interest, or Court Costs
`-
`
`© Under $10,000
`
`$10,000
`
`$30,000
`
`-
`
`© $30,000
`
`$100,000
`
`Over $100,000
`
`O Medical Bills $
`
`OC Wage Loss $
`O Property Damages $
`ALTERNATIVE DISPUTE RESOLUTION INFORMATION
`Is this case
`appropriate for referral to an ADRprocess under Md. Rule 17-101? (Check all that apply)
`A. Mediation
`C.Settlement Conference Yes ONo
`®Yes ONo
`B. Arbitration
`D. Neutral Evaluation
`OYes
`&INo
`Yes ONo
`
`SPECIAL REQUIREMENTS
`Oita Spoken LanguageInterpreter is needed, check here and attach form CC-DC-041
`an accommodationfor a
`CO If you require
`disability under the Americans with Disabilities Act, check
`here and attach form CC-DC-049
`
`ESTIMATED LENGTH OF TRIAL
`With the exception ofBaltimore County and Baltimore City, please fill in the estimated LENGTH OF
`TRIAL.
`(Case will be tracked accordingly)
`© 1/2 dayoftrial or less
`oftrial time
`0 3 days
`C1 1 dayoftrial time
`oftrial time
`G Morethan 3 days
`oftrial time
`2 days
`
`Defendant's response EMERGENCY RELIEF REQUESTED
`
`BUSINESS AND TECHNOLOGY CASE MANAGEMENT PROGRAM
`Forailjurisdictions, ifBusiness and Technology track designation under Md. Rule 16-308 is requested,
`attach a
`and check one
`ofthe tracks below.
`duplicate copy ofcomplaint
`-
`© Expedited- Trial within 7 months of
`Defendant's response
`
`Trial within 18 months of
`
`CO) Standard
`
`CC-DCM-002 (Rev. 04/2017)
`
`Page 2 of 3
`
`

`

`Case 1:21-cv-02270-DLB Document1-1 Filed 09/03/21 Page 16 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 16 of 18
`
`COMPLEX SCIENCE AND/OR TECHNOLOGICAL CASE
`MANAGEMENT PROGRAM (ASTAR)
`
`FOR PURPOSES OF POSSIBLE SPECIAL ASSIGNMENT TO ASTAR RESOURCES JUDGESunder
`Ma. Rule 16-302, attach a
`duplicate copy ofcomplaint and check whether assignment to an ASTAR is requested.
`-
`
`Trial within 7 months of
`O Expedited
`Defendant's response
`
`O Standard- Trial within 18 months of
`Defendant's response
`
`
`
`
`
`
`
`
`IF YOUARE FILING YOUR COMPLAINTIN BALTIMORE CITY, OR BALTIMORE COUNTY,
`
`
`PLEASE FILL OUT THE APPROPRIATE BOX BELOW.
`
`CIRCUIT COURT FOR BALTIMORE CITY (CHECK ONLY ONE)
`Trial 60 to 120 days from notice. Non-jury matters.
`oO Expedited
`Trial 210 days from first answer.
`0 civil-Short
`Trial 360 days from first answer.
`1 Civil-Standard
`O custom
`Scheduling order entered by individual judge.
`C1 Asbestos
`Special scheduling order.
`Fill in: Birth Date ofyoungestplaintiff
`Lead Paint
`Special scheduling order.
`[J Tax Sale Foreclosures
`Oo Mortgage Foreclosures No scheduling order.
`
`CIRCUIT COURT FOR BALTIMORE COUNTY
`
`
`
`
`
`
`
`
`
`
`Attachment Before Judgment, Declaratory Judgment (Simple),
`
`Administrative Appeals, District Court Appeals and Jury Trial Prayers,
`Guardianship, Injunction, Mandamus.
`
`
`Standard
`Condemnation, Confessed Judgments (Vacated), Contract, Employment
`oO
`
`Related Cases, Fraud and
`(Trial Date-240 days)
`Misrepresentation, International Tort, Motor Tort,
`
`Other Personal Injury, Workers' Compensation Cases.
`
`Asbestos, Lender Liability, Professional Malpractice, Serious Motor Tort or
`Personal Injury Cases (medical expenses and wageloss of $100,000, expert
`
`and out-of-state witnesses (parties), and trial of five or more
`days), State
`
`
`Insolvency.
`
`Class Actions, Designated Toxic Tort, Major Construction Contracts, Major
`Complex
`oO
`
`(Trial Date-450 days)
`Product Liabilities, Other Complex Cases.
`
`
`
`
`
` ([] Extended Standard
`
`Expedited
`CT
`(Trial Date-90 days)
`
`(Trial Date-345 days)
`
`
`
`10211
`
`July 15, 2021
`ate
`Wincopin Circle, Suite 600
`ress
` Columbia
`City
`
`
`
`MD
`State
`
`21044
`Zip Code
`
`CC-DCM-002 (Rev. 04/2017)
`
`Page3 of 3
`
`

`

`-
`
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`GaB4
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`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21
`Circuit Court
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 17 of 18
`Page.+(Pb“Howard
`9250 JUDICIAL WAY
`CIRCUIT COURT FOR HOWARD 6QHN27t4eMceR¥d-c4NM; Submission: 7/16/2021 10:01 AM
`ELLICOTT CITY, MARYLAND 21043
`Main: 410-313-2111 Civil: 410-313-3844 Criminal: 410-313-3822 Juvenile: 410-313-3827 Land Records: 410-
`313-5850 Calendar Office: 410-313-3575 Family Law: 410-313-2225
`
`Case Number: C-13-CV-21-000484
`Other Reference Numbers:
`
`SciRegs International, Inc. vs. Identi Pharmaceuticals, LLC,etal.
`-
`
`PLEASE NOTE
`
`THE COURTHOUSE MOVEDON JULY6, 2021. THE NEW COURTHOUSEIS LOCATED
`AT 9250 JUDICIAL WAY, ELLICOTT CITY, MARYLAND 21043.
`
`ALL PHONE NUMBERS REMAIN THE SAME.
`
`SCHEDULING ORDER
`
`This Orderis yourofficial notice of dates established pursuant to this Courts Differentiated Case Management
`Plan. The above case has been assigned
`to the STANDARD TRACK. ANY MODIFICATIONSOF THIS
`SCHEDULING ORDER MUST BE REQUESTED BY WRITTEN MOTION AND FILED BEFORE THE
`causeto
`COMPLIANCE DATE(S). The motion must
`the requested modification. Stipulations
`provide good
`justify
`between the parties and/or their counsel shall not
`change any deadline in this Scheduling Order absent Court
`approval.
`
`events shall occur
`It is
`the following dates:
`ORDEREDthat the following
`hereby
`by
`1. Plaintiff’s Experts shall be identified by 02/13/2022. Pursuant to Md. Rule 2-402(g), any designation
`matter on which the expert is expectedto testify
`at trial; (ii) the
`include the
`following: (i) the subject
`substanceofthe findings and the
`and a summary of
`to
`to which the expert is expected
`testify
`opinions
`and
`groundsfor each opinion;
`(iii) the production of any written report made by the expert concerning those
`and
`findings
`opinions.
`
`shall
`
`2. Defendant’s Experts shall be identified by 03/15/2022. Pursuant to Md. Rule 2-402(g), any designation shall
`matter on which the expert is
`at
`to
`include the
`trial; (ii) the
`following: (i) the subject
`expected
`testify
`substance ofthe findings and the opinions
`testify and a summary of
`to which the expert is expected
`to
`and
`groundsfor each
`(iii) the production of any written report made by the expert concerning those
`opinion;
`findings and
`opinions.
`
`3. Rebuttal expert witnesses shall be identified by 03/23/2022. Pursuant to Md. Rule 2-402(g), any designation
`at
`matter on which the expert is expected
`to
`shall include the
`following:(i) the subject
`trial; (ii) the
`testify
`testify and a summary of
`to which the expert is expected
`to
`substanceof the
`findings and the opinions
`and
`grounds for each opinion;
`(iii) the production of any written report made by the expert concerning those
`and
`findings
`opinions.
`
`4. All discovery shall be commencedsoas to be concluded by 04/14/2022. The
`or
`filing of a motion to
`compel
`a motionfor protective order will not result in a
`are
`general extension of the discovery deadline. All parties
`advised that this Court will enforce the Discovery Guidelines of the State Bar as set forth in the Maryland
`Rules when resolving discovery disputes. Extensions of time to answer
`must be approved
`specific discovery
`cause shown. Failure to
`to
`by Court Order for good
`discovery fully and completely because
`timely respond
`or for any other reason
`the discovery deadline is not imminent,
`lacking merit, will subject the offending party
`to
`sanctions, including attorney’s fees.
`
`5. All amended
`
`pleadings
`
`mustbe filed by 04/22/2022.
`
`6. All motions (except motions in limine), including dispositive motions, must be filed by 05/07/2022.
`HOCC-V-006 (Rev. 07/2021)
`Page 1 of 2
`7/16/2021 9:58 AM
`
`

`

`“
`
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page 18 of 18
`Case 1:21-cv-02270-DLB Document 1-1 Filed 09/03/21 Page
`18 of 18
`SciRegs International, Inc. vs. Identi Pharmaceuticals, LLC,et al.
`Case Number: C-13-CV-21-000484
`Other Reference Number(s):
`
`on
`videotape, (including de bene esse
`depositions), for which a
`to
`portions of testimony
`party
`Objections
`seeks ruling by the Court for purposesoftrial shall be submitted no later than 30 daysprior
`to trial. Any
`opposition should be submitted within 10 days thereafter. Failure to
`timely follow these requirements may
`result in any such objection being considered waived.
`
`Notice of intent to use
`
`computer-generated evidenceat trial must be given
`
`30 daysprior
`
`totrial.
`
`statements on or before 04/23/2022. A final joint pretrial statement,
`Parties are to
`exchange draft pretrial
`witnesslist and list of exhibits shall be filed with the court on or before 04/30/2022.
`
`10.
`
`11.
`
`12.
`
`Court ordered Mediation shall be completed by 04/24/2022. An Order for Mediation will be mailedto all
`counsel and unrepresented parties.
`
`Parties shall attend any court ordered Pretrial Settlement Conference by 05/14/2022. An OrderforPretrial
`are not ordered
`Settlement Conference will be mailedto all counsel and unrepresented parties. If the
`parties
`to attend Mediation or Settlement Conference, the case will be scheduledfortrial. If settlement is not reached
`as a result of Mediation or Pretrial Settlement Conference, counsel and any unrepresentedparties will be
`directed to the Calendar ManagementOfficeto obtain a trial date.
`In cases whena
`voir dire, motionsin limine,
`jury trial has been prayed,a joint pretrial statement, requested
`proposed verdict sheet shall be submitted one week prior
`to trial. If using
`proposed jury instructions and
`Maryland Pattern Jury