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Bills of Particulars
DUE TODAY
Due 04/02/2026. Verified Bill of Particulars drafted and ready for filing.
Goldberg Deposition
BLOCKED
FAILED APPEARANCE 02/24/2026. Motion to compel or sanctions pending. Deadline: 06/02/2026.
Motion to Deem RFAs Admitted
DRAFT COMPLETE
Draft motion complete. Ready for counsel review and filing.
CN-37833 Production
REFUSED
Formally demanded 01/30/2026 — reporting on all name uses through Customer Number 37833. Goldberg's counsel refused production.
Motion to Compel CN-37833
PENDING
Draft complete. Targets Goldberg's refusal to produce USPTO Customer Number records.
Spoliation Motion (Email Retaliation)
PENDING
Litman's email accounts eliminated 07/18/2025 — one day after litigation threat. Draft motion for sanctions complete.