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No. 182 RESPONSE in Opposition to Motion (Re: 177 MOTION for Sanctions ) by GWACS Armory, LLC ; (With ...

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 182 (N.D.Okla. Dec. 12, 2022)
Motion for Sanctions
(See Declaration of Shel Jones, Ex. 3, at ¶ 4) Nonetheless, as stated above, the information contained in the emails relied upon in Defendants’ Motion are neither the trade secrets nor the proprietary information at issue in this case.
Nonetheless, none of the emails discussed below were requested in discovery.
Nonetheless, the information provided to McBride did not contain the cost of materials, the cost of producing lowers, the volume of sales, sales projections, Armory’s market weaknesses, or any of the other information used by ...
None of the wall thicknesses of the CAV-15 are .135 inches thick.
178-4 at p. 4) As described above, none of the emails which are the subject of Defendants’ Motion were requested in discovery.
None of the emails used to support Defendants’ Motion evidence Armory’s disclosure of its CAD files, or the unified process, design, and operation of or for manufacturing the CAV-15.
Therefore, Defendants cannot claim to have been prejudiced by Armory’s disclosure of pieces of information to third-parties, especially when the information provided was neither precise nor factually accurate, and when none of those ...
Nonetheless, because Defendants did not request the emails in question, it is impossible for Defendants to allege Armory’s failure to produce the same was done in bad faith or that it was 17 Case 4:20-cv-00341-CVE-SH Document 182 ...
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No. 178 DECLARATION of Alexander Calaway (Re: 176 MOTION for Leave to File Supplement to Dispositive ...

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 178 (N.D.Okla. Nov. 23, 2022)
Case 4:20-cv-00341-CVE-SH Document 178 Filed in USDC ND/OK on 11/23/22 Page 2 of 2 withheld by plaintiff in discovery.
I also make this declaration in support of defendants’ motion for spoliation sanctions against plaintiff.
Exhibit 3 is a true and correct copy of my letter to Armory’s counsel dated January
Exhibit 6 is a true and correct copy of a letter to Armory’s counsel dated July 20,
As of the date of this filing, Armory’s counsel has not responded to this letter nor my requests to confer.
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No. 180 DECLARATION of Timothy McBride (Re: 176 MOTION for Leave to File Supplement to Dispositive ...

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 180 (N.D.Okla. Nov. 23, 2022)
On or about 2004 I met defendants Shawn Nealon (“Nealon”) and Russell Phagan (“Phagan”) when they operated Cavalry Arms Corporation (“Cavalry”).
During this time, I observed the mold fixture, CAV-15 MKII halves, the vibration welding equipment, and trimming setup.
In August of 2005 I joined the United States Army, becoming a Cavalry Scout, partially due to my time with Nealon.
In 2010 when I exited active-duty service, I started a gunsmithing business and discussed purchasing the CAV-15 MKII mold from Phagan.
Exhibit 1 is a true and correct copy of the email and attachments I received from Armory on January 15, 2013.
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No. 179 DECLARATION of Russell Phagan (Re: 176 MOTION for Leave to File Supplement to Dispositive Motions, ...

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179 (N.D.Okla. Nov. 23, 2022)
Case 4:20-cv-00341-CVE-SH Document 179 Filed in USDC ND/OK on 11/23/22 Page 1 of 3 Case 4:20-cv-00341-CVE-SH Document 179 Filed in USDC ND/OK on 11/23/22 Page 2 of 3 Case 4:20-cv-00341-CVE-SH Document 179 Filed in USDC ND/OK on 11/23/22 Page 3 of 3
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No. 173 PRETRIAL DISCLOSURES by GWACS Armory, LLC (Bogan, Tadd) (Entered: 11/16/2022)

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 173 (N.D.Okla. Nov. 16, 2022)
Mr. Jones is expected to testify regarding the facts and circumstances giving rise to Plaintiff’s Complaint and Counter- Plaintiff’s Counter-Complaint, the damages he claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at trial.
Mr. Merrill is expected to testify regarding the facts and circumstances giving rise to Plaintiff’s Complaint and Counter-Plaintiff’s Counter-Complaint, the damages he claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at trial.
Mr. Anderson is expected to testify regarding the facts and circumstances giving rise to Plaintiff’s Complaint and Counter-Plaintiff’s Counter-Complaint, the damages he claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at trial.
Mr. Haygood will serve as the Plaintiff’s expert witness, and is expected to testify regarding his review of the records, his findings and opinions, within a reasonable degree of certainty, regarding the damages, if any, sustained by Defendants, and related issues in his report produced herein; and as to any other matter relevant to this action which may be elicited by counsel at trial.
Mr. Levy is expected to testify regarding the facts and circumstances giving rise to Plaintiff’s Complaint and Counter- Plaintiff’s Counter-Complaint, the damages he claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at trial.
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No. 171 PRETRIAL DISCLOSURES by Brownells, Inc., KE Arms, LLC, Shawn Nealon, Russell Phagan, Sinistral ...

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 171 (N.D.Okla. Nov. 14, 2022)
Subject of Discoverable Information KE Arms, LLC is expected to testify regarding the facts and circumstances giving rise to Plaintiff’s Complaint and Counter-Plaintiff’s Counter-Complaint, the damages he claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at trial.
GWACS Defense is expected to testify regarding the facts and circumstances giving rise to Plaintiff’s Complaint and Counter-Plaintiff’s Counter-Complaint, the damages he claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at trial.
Case 4:20-cv-00341-CVE-SH Document 171 Filed in USDC ND/OK on 11/14/22 Page 6 of 23 Mr. Oppenheimer is expected to testify regarding the facts and circumstances giving rise to Plaintiff’s Complaint and Counter-Plaintiff’s Counter-Complaint, the damages he claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at trial.
Mr. Newman will serve as the Defendants’/Counter-Plaintiff’s expert witness, and is expected to testify regarding his review of the records, his findings and opinions, within a reasonable degree of certainty, regarding intellectual property, including, but not limited to trade dress, unfair competition law, and copyright, and related issues in his report produced herein; and as to any other matter relevant to this action which may be elicited by counsel at trial.
Mr. Jones is expected to testify regarding the facts and circumstances giving rise to Plaintiff’s Complaint and Counter-Plaintiff’s Counter-Complaint, the damages he claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at trial.
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No. 167 RESPONSE in Opposition to Motion (Re: 165 Opposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ...

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 167 (N.D.Okla. Sep. 16, 2022)
Case 4:20-cv-00341-CVE-SH Document 167 Filed in USDC ND/OK on 09/16/22 Page 3 of 5 Further, the final two factors set forth in United States of America v. Rivera, 900 F.2d 1462 (10th Cir. 2003), citing Morris v. Slappy, 461 U.S. 1, 103 S.Ct.
(See Dkt. #134) The basis for this request was Defendants sharing information with non-parties represented by the same counsel, including a video titled “WWSD – GWACS Armory Sucks” posted to YouTube and various websites.
(See example voice mail transcripts attached as Exhibits ‘4” and “5”) Notably, Defendants have failed to state in any of their publications that KEA initially sued Armory in Arizona over the issues in this case, and have knowingly mischaracterized Armory’s claims as being anti-gun/Second Amendment.
According to the recent reddit.com post by Phagan and KEA, Defendants have publicly stated that they have spent over $400,000 in attorney fees, that the trial will cost $100,000, and they are at risk of running out of funding for the lawsuit.
WHEREFORE, premises considered, GWACS Armory, LLC, prays the Court deny Defendants’ Opposed Motion to Continue Trial and Amend Scheduling Order [Dkt. #165].
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No. 166 DECLARATION of Brian R. Hardy, Esq. in Suppor of Defendants' Opposed Motion to Continue Trial ...

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 166 (N.D.Okla. Sep. 14, 2022)
Specifically, I am retained as lead counsel for one of the major political parties in the state of Nevada.
(begins the 3rd Saturday before the General Election through the Friday preceding the General Election) During this period, a registered voter may request to vote early in person at designated Early Voting locations.
Ballots delivered to and mail ballot central counting board shall be processed and prepared for counting GENERAL ELECTION – (1st Tuesday after the 1st Monday in November in each even-numbered year) The General Election is held.
CANDIDATES IF NO RECOUNT DEMANDED – (no later than 14 days after the election) For contests involving offices for Governor, Lt.
In order to adequately protect the Defendants’ interests and fulfill my obligations to other clients, I file this motion and respectfully ask this Court to continue this trial.
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No. 2 COMPLAINT with Jury Demand against All Defendants (paid $400 filing fee; receipt number AOKNDC-2234357) ...

Document GWACS Armory, LLC v. KE Arms, LLC et al, 4:20-cv-00341, No. 2 (N.D.Okla. Jul. 15, 2020)
Complaint
(“Plaintiff”), by and through its attorneys of record, James E. Weger and Tadd J.P. Bogan of the law firm of Jones, Gotcher & Bogan, P.C., and hereby submits its Complaint against Defendants, KE Arms, LLC, an Arizona limited liability company (“KEA”); Russell Phagan, an individual (“Phagan”); Sinistral Shooting Technologies, LLC, an Arizona limited liability company (“SST”); Brownells, Inc., an Iowa corporation (“Brownells”); and Shawn Nealon, an individual (“Nealon”) (hereinafter collectively referred to as “Defendants”).
Pursuant to the IP Purchase Agreement, SST represented that it owned sole, exclusive, good and merchantable title to the assets free and clear of all pledges, claims, liens, restrictions, security interests, charges and other encumbrances.
SST breached the IP Agreement and NDA by disclosing the IP and other trade secrets to KEA in an effort to circumvent Plaintiff and make a deal directly with Brownells relating to future production of the CAV-15.
In the IP Purchase Agreement SST represented it had sole, exclusive, good and merchantable title to the IP, free and clear of all pledges, claims, liens, restrictions, security interests, charges and other encumbrances.
Case 4:20-cv-00341-CVE-FHM Document 2 Filed in USDC ND/OK on 07/15/20 Page 18 of 20 (3) Against Defendant Sinistral Shooting Technologies, LLC, on Plaintiff’s causes of action for breach of implied covenant of good faith and fair dealing (Seventh COA), and breach of contract (Eight COA), and award Plaintiff judgment in the amount in excess of Seventy-Five Thousand Dollars ($75,000), plus exemplary damages, injunctive relief, attorney fees, costs and all other relief this Court deems just and equitable.
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No. 188-2

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 188-2 (N.D.Okla. Jan. 6, 2023)

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No. 188-1

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 188-1 (N.D.Okla. Jan. 6, 2023)

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No. 187-2

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 187-2 (N.D.Okla. Jan. 4, 2023)

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No. 187-1

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 187-1 (N.D.Okla. Jan. 4, 2023)

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Schiewe et al v. Cessna Aircraft Company et al

Docket 4:11-cv-00560, Oklahoma Northern District Court (Sept. 6, 2011)
James H Payne, presiding, Frank H McCarthy
Airplane Product Liability
DemandPlaintiff
Cause28:1332 Diversity-Airline Crash
Case Type315 Airplane Product Liability
Tags315 Airplane Product Liability, 315 Airplane Product Liability
Plaintiff Jade P Schiewe
Plaintiff Zachary Pfaff
Defendant Cessna Aircraft Company
...
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No. 183-1

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 183-1 (N.D.Okla. Dec. 13, 2022)

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