Andrew Durham v. Grapetree, LLC

COURT OF CHANCERY OF THE SAM GLASSCOCK III STATE OF DELAWARE COURT OF CHANCERY COURTHOUSE VICE CHANCELLOR 34 THE CIRCLE GEORGETOWN, DELAWARE 19947

September 4, 2020

Rachel Bleshman, Esq.

Sergovic Carmean Weidman McCartney & Owens, P.A.

75 Chestnut Street Georgetown, DE 19947 RE: Durham v. Grapetree, LLC, C.A. No. 2019-0366-SG Dear Special Master Bleshman: This letter is to clarify your duties under my Order of August 20, 2020, appointing you Special Master in this matter. My Order dated November 19, 2019 (the “Order”), required Defendant to provide to Plaintiff certain records consistent with the Settlement Agreement and Mutual Release of 2012 (which I have attached to this letter) and, going forward, to provide monthly financial statements to all Members of the LLC. The Plaintiff has moved to compel compliance with this Order; the Defendant avers that it has substantially complied. I have appointed you to determine whether the Defendant in fact is in compliance, and, if not, in what manner it is delinquent. I ask that you file a Master’s Report with your conclusion once you are able to answer these questions.

Plaintiff has submitted multiple exhibits to this Court detailing what he contends are incomplete records of the Defendant that do not comply with the Order. Please review these documents to determine Defendant’s compliance. You may also request additional documents from either party to the extent necessary to complete this assignment, and, if you determine it is helpful, proceed by evidentiary hearing and/or oral argument.

To the extent the foregoing requires an order to take effect, it is SO ORDERED.

Sincerely, /s/ Sam Glasscock III Sam Glasscock III