discover request documents

Documents Requested   All XTS Cloud LLC digital company files that were stored in Google Business Drive prior to April 16, 2021.  All XTS Cloud LLC digital email records from May 31, 2017 to April 16th, 2021.  Copies of any and all documents, records or writings...

Response to Motion Berenson

Plaintiff’s Response to Defendant’s Motion For Leave to Amend Answer and Counterclaim and Plaintiff’s Cross Motion For Leave to Amend Complaint.   Introduction & Counter Statement of Facts During the first week of April 2021, Plaintiff Charlie Ezuma...

Restaurant Partnership Agreement

Meta-title: Restaurant Partnership Agreement Introduction Various new restaurants elect to enter into restaurant partnership agreements with others. The selected partners often have the required finances and skills to steer a restaurant business towards success....

Ezuma Statement of Facts

Ezuma Statement of Facts   Introduction & Counter Statement of Facts During the first week of April 2021, Plaintiff Charlie Ezuma (“Ezuma”), the owner of XTS Cloud LLC (“XTS”), discovered that Defendant Jason Berenson (“Berenson”) had been, among other...