EFiled: Nov 20 2019 07:49A] om
Transaction ID 64447025 t ad
Case No. 2019-0928- Nees
oe OES
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE 22055”
ENTERPRISE DIVERSIFIED, INC.,
a Nevada corporation,
Plaintiff,
C.A. No. 2019- -
v.
WOODMONT LEXINGTON, LLC, a
Delaware limited liability company
and MT MELROSE, LLC, a Delaware
limited liability company,
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Defendants.
PLAINTIFF ENTERPRISE DIVERSIFIED, INC.’S
MOTION FOR EXPEDITED PROCEEDINGS
Plaintiff Enterprise Diversified, Inc., by and through its undersigned counsel,
hereby moves for expedited proceedings in this matter. The grounds for this
motion are set forth in Enterprise Diversified, Inc.’s Opening Brief in Support of
Motions for Temporary Restraining Order and Expedited Proceedings filed
contemporaneously herewith.
BAYARD, P.A,
(si Peter B. Ladig
Peter B. Ladig (#3513)
Brett M. McCartney (#5208)
600 N. King Street, Suite 400
Wilmington, Delaware 19801
Attomeys for Plaintiff
Dated: November 20, 2019 Words: 46EFiled: Nov 20 2019 07:494MES Ts
Transaction ID 64447025 Pe
Case No. 2019-0928-
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
ENTERPRISE DIVERSIFIED, INC.,
a Nevada corporation,
Plaintiff,
v. CA. No. 2019-, -
WOODMONT LEXINGTON, LLC, a
Delaware limited liability company
and MT MELROSE, LLC, a Delaware
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»)
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limited liability company, )
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Defendants.
[PROPOS| TEMPORARY RESTRAL iG ORDER
WHEREAS, Plaintiff Enterprise Diversified, Inc., having filed a Motion for
Temporary Restraining Order (the “Motion”);
WHEREAS, the Court having considered the Motion, IT IS HEREBY
ORDERED, this day of. __, 2019, as follows:
lL. The Motion is GRANTED.
2. Defendant Woodmont Lexington, LLC (“Woodmont”), and_ its
directors, officers, employees and agents, and any person or entities acting in
concert or participation with Palmetto are hereby ENJOINED fromMaking any
further public statements of any kind, including on social media, regarding the
Membership Purchase Agreement dated June 18, 2019 (the “Purchase
Agreement”) or Woodmont’s purchase of units of Mt Melrose, LLC;3. Woodmont is hereby ORDERED to remove or delete from any social
media accounts, including without limitation Twitter, all public statements
referring or relating to the Purchase Agreement or Woodmont’s purchase of units
of Mt Melrose, LLC.
4. This Order shall remain in full force and effect until such time as this
lly orders otherwise.
[Vice] Chancellorie
erm
EFiled: Nov 20 2019 07:49,
Transaction ID 64447025
Case No. 2019-0928-
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
ENTERPRISE DIVERSIFIED, INC.,
a Nevada corporation,
Plaintiff,
_ C.A.No. 2019-_ =
)
)
)
)
)
,
WOODMONT LEXINGTON, LLC, a)
Delaware limited liability company)
and MT MELROSE, LLC, a Delaware)
limited liability company, )
)
Defendants. )
ENTERPRISE DIVERSIFIED, INC.’S.
MOTION FOR TEMPORARY RESTRAINING ORDER
Plaintiff Enterprise Diversified, Inc., by and through its undersigned
attorneys, moves pursuant to Court of Chancery Rule 65 for an order temporarily
restraining defendant Woodmont Lexington, LLC, and its directors, officers,
employees and agents, and any person or entities acting in concert or participation
with Woodmont Lexington, LLC (collectively, “Woodmont”), from making public
statements regarding the parties’ Purchase Agreement (as defined in the
Complaint) or Purchase (as defined in the Purchase Agreement) and compelling
Woodmont to remove or delete all public statements previously made. The
grounds for this motion are set forth in Plaintiff's Brief in Support of its Motion for
Temporary Restraining Order and Expedited Proceedings filed contemporaneously
herewith,Dated: November 20, 2019
BAYARD, P.A.
és/Peter B.Ladig
Peter B. Ladig (#3513)
Brett M. McCartney (#5208)
600 N. King Street, Suite 400
Wilmington, Delaware 19801
Attorneys for Plaintiff
Words: 110