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Displaying 69-83 of 214 results

No. 182-2

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 182-2 (N.D.Okla. Dec. 12, 2022)
Upon production by Plaintiff of documents responsive to Defendant's requests and not withheld onthe basis of an objection outlined below,
The indication that production will be made does not mean that any of the documentscalled for exist, or that such documentsare in the possessionor control of, or that such documents are reasonably available to Plaintiff.
RESPONSE TO INTERROGATORYNO.24: Objection, Interrogatory No. 24 is overly broad, vague and ambiguous, and seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence pursuant to Okla. Stat.tit.
Armory has taken many steps to maintain its “corporate form” since its inception, including filing and paying the State of Oklahoma annual fees, but cannot possibly list each and every actionthat has been taken or not takento do so.
Comes now,the undersigned, JUD GUDGEL, being under oath andafter being first duly sworn, states that he is the President and CEO ofthe Plaintiff, GWACS Armory, LLC, has read the contents within the foregoing Interrogatory responses, knowsthe contents thereof, and states that the facts and matters therein are true and correct,tothe eatofSOS= belief, C Vi7 / sexteetsafistZe ona fai ee JUD GUDGEL Subscribed and sworn to before methis 28Tay of February, 2022, by Jud Gudgel.
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No. 182-5

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 182-5 (N.D.Okla. Dec. 12, 2022)
Case in point: your clients have literally objected to every single one of KEA’s second set of interrogatories; and flat out refused to produce its own CAD/CAMfiles related to the CAV-15.
Case 4:20-cv-00341-CVE-SH Document 182-5 Filed in USDC ND/OK on 12/12/22 Page 2 of 2 Letter to Tadd Bogan February 16, 2022 Page 2 In addition, your clients have already have obtained all of the emails, design files, and documents from each of KEA’s vendors, suppliers, and engineers, including Moldworx, Randy Sperry and MDI, Atthis point, your clients have obtained exhaustive information and details on the development and design of the KP-15; andall of this information evidences the samething: that the KP-15 was designed and developed using KEA’s aluminumbillet receiver.
If you feel that my clients have not properly responded to any of your clients’ written discovery requests, then please advise, and we will be happy to address the same in a meet and confer.
Fourth, with respect to your inquiry regarding the Tenth Supplement Disclosures,it is our understanding that Alisha Swindle, Brad Pace, and Tim McBride are all people who worked at both Cavalry Arms Corporation and KEA.
However, we are advised that Tool & Design Group, LLC has retained counsel that will be reaching out to your offices regarding the subpoena.
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No. 182-6

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 182-6 (N.D.Okla. Dec. 12, 2022)
I will nonetheless explain it again.
Nonetheless, we did send written discovery regarding these matters no February 8, 2022, over a weekbefore yourletter demanding the same be sent.
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No. 182-1

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 182-1 (N.D.Okla. Dec. 12, 2022)
Identify and describe any “proprietary information” that Plaintiff disclosed to BROWNELLS, INC. and KE ARMS, LLCas alleged in Paragraphs 55 and 113 of the Complaint.
Armory disclosed the condition of the molds; financial information of Armory; that Armory was seeking investors for continued manufacturing and development; total CAV-1 5 MKT lowersales volume; CAV-15 MKII sales following In Rangevideos;its intent to use Marks MIKI and MKIV for future CAV-15 models; financial projections for future CAV-15 production and sales; drawings/ renderings of the CAV-15; the MKIII CAD renderings and functionality improvements to include several features that were included in the KEA polymerreceiver; and the MKIV adjustable stock CADrenderings and functionality.
Identify the communications you had with the Defendants relating to proprietary information as identified Paragraphs 55 and 113 of Plaintiff's Complaint.
In 2018, numerous phone calls between Shel Jones and Paul Levy and Russell Phagan regarding the marketing of Asserted Mark once it was in production, discussions included design improvements and modifications to the MKII design, and the content and execution of the Brownell NDA.
In 2016, there were numerousphonecalls between Shel Jones and Paul Levy regarding the drafting and executionofthe updated Brownells NDA.
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No. 182-4

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 182-4 (N.D.Okla. Dec. 12, 2022)
Defendants, KE Arms, LLC (“KEA”), Russell Phagan (“Phagan”), an individual; Sinistral Shooting Technologies, LLC (“SST”), an Arizona limited liability company; Brownells, Inc., (“Brownell’s”) an Iowa corporation; and Shawn Nealon (“Nealon”), an individual (hereinafter collectively “Defendants” ) and Counter-Plaintiff KEA (“Counter- Plaintiff’), by and through their undersigned attorneys of record, hereby serve the following Sixth Supplemental Disclosures (Supplements appearin bold): //
KE Arms, LLC, Rule 30(b)(6) KE Arms, LLC is expected to testify Designee regarding the facts and circumstances c/o Marquis Aurbach Coffing giving rise to Plaintiff’s Complaint and 10001 Park Run Drive Counter-Plaintiff’s Counter-Complaint, Las Vegas, Nevada 89145 the damages he claims were sustained; and as to any other matter relevantto this action which maybe elicited by counsel at deposition, arbitrationortrial.
10001 Park Run Drive Plaintiff’s|Counter-Complaint, the Las Vegas, Nevada 89145 damageshe claims were sustained; and as to any other matter relevant to this action which may be elicited by counsel at deposition, arbitration ortrial.
GWACSDefense is expected to testify GWACS Defense Incorporated, regarding the facts and circumstances Rule 30(b)(6) Designee giving rise to Plaintiff’s Complaint and c/o JONES, GOTCHER & Counter-Plaintiff’s _Counter-Complaint,
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 maybeelicited by counsel at deposition, arbitration ortrial.
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No. 182-3

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 182-3 (N.D.Okla. Dec. 12, 2022)
Case 4:20-cv-00341-CVE-SH Document 182-3 Filed in USDC ND/OK on 12/12/22 Page 1 of 6 Case 4:20-cv-00341-CVE-SH Document 182-3 Filed in USDC ND/OK on 12/12/22 Page 2 of
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No. 179-9

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-9 (N.D.Okla. Nov. 23, 2022)
I asked them if I could cure MolyResin on the lower at 300 degrees without compromising the receiver.
Case 4:20-cv-00341-CVE-SH Document 179-9 Filed in USDC ND/OK on 11/23/22 Page 4 of 4 Company Name: Phone Number: 8644141219 What's the upper temperature limit for the CAV-15?
I tend to go for Moly Resin for painting, but that requires curing for an hour at 300 degrees.
- Nate H PLEASE NOTE: If you purchased a firearm, such as a lower receiver, rifle or handgun, it's your responsibility to have your local Federal Firearms Licensed dealer forward to us a copy of their FFL.
Please contact your dealer and have them fax or email a copy of their FFL.
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No. 179-8

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-8 (N.D.Okla. Nov. 23, 2022)
We are also hoping to launch a next generation lower that will have adjustability in length and multiple QD sockets.
Case 4:20-cv-00341-CVE-SH Document 179-8 Filed in USDC ND/OK on 11/23/22 Page 4 of 6 PLEASE NOTE: If you purchased a firearm, such as a lower receiver, rifle or handgun, it's your responsibility to have your local Federal Firearms Licensed dealer forward to us a copy of their FFL.
We are also hoping to launch a next generation lower that will have adjustability in length and multiple QD sockets.
Phone Number: 2052851189 When do you expect the Flat Dark Earth and OD Green lowers to be back in stock?
PLEASE NOTE: If you purchased a firearm, such as a lower receiver, rifle or handgun, it's your responsibility to have your local Federal Firearms Licensed dealer forward to us a copy of their FFL.
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No. 179-2

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-2 (N.D.Okla. Nov. 23, 2022)
Each carrier providing any such insurance, or portion thereof, shall be licensed to do business in the jurisdiction where the Dealer is located, and unless otherwise agreed by GAL in writing, shall have a claims paying ability rating by Best’s Guide of not less than “A Minus, VII” or better.
Dealer shall indemnify and hold GAL harmless from any and all claims, liabilities, losses, damages or expenses (including reasonable attorneys, fees and costs) arising directly or indirectly from, as a result of, or in connection with, the Dealer’s operation of the Dealer’s business.
GAL shall indemnify and hold Dealer harmless from any and all claims, liabilities, losses, damages or expenses (including reasonable attorneys, fees and costs) arising directly or indirectly from, as a result of, or in connection with, GAL’s operation of GAL’s business.
In the event of any litigation involving this Agreement, all such matters will be resolved exclusively in the state or federal courts seated in Tulsa County, Oklahoma, and the Dealer consents to such venue and jurisdiction.
3.Use a safe edge file to remove material from the mag well in the tight *If the buffer detent roll pin does not line up properly when hammed in to the lower, try inserting it from the opposite side to remedy the problem.
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No. 179-6

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-6 (N.D.Okla. Nov. 23, 2022)
I am hoping to have an upgraded model which we will look at the exchange rate in the future for you.
Please check back in 8 months and lets see where I am at.
I have two Sabre lowers, both made by Cavalry Arms, that I'm not so pleased w/.
I was very pleased w/ the last GWACS lower I got from you several years ago.
Gig 'em, Greg Bowling Fort Worth, TX 214 809 5249
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No. 178-4

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 178-4 (N.D.Okla. Nov. 23, 2022)

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No. 179-4

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-4 (N.D.Okla. Nov. 23, 2022)

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No. 179-7

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-7 (N.D.Okla. Nov. 23, 2022)

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No. 178-7

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 178-7 (N.D.Okla. Nov. 23, 2022)

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No. 178-2

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 178-2 (N.D.Okla. Nov. 23, 2022)

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