Bartech Systems International, Inc. v. Mobile Simple Solutions, Inc. et al
Filing
269
ORDER re ECF No. 254 Order, ECF No. 255 -1 Proposed Order, and ECF No. 268 Minutes of Proceedings. (See pdf Order for specifics.) Signed by Judge Miranda M. Du on 4/6/2017. (Copies have been distributed pursuant to the NEF - DRM)
1
2
3
4
5
6
7
8
10
11
12
13
14
15
16
Michael R. Kealy,
Nevada Bar No. 971
Ashley C. Nikkel,
Nevada Bar No. 12838
PARSONS BEHLE & LATIMER
50 W. Liberty Street, Suite 750
Reno, Nevada 89501
Telephone:(775) 323-1601
Facsimile:(775)348-7250
Email: mkealy@parsonsbehle.com
anikkel@parsonsbehle.com
— and —
Gregory T. Lawrence, Esq.
(Admitted Pro Hac Vice)
Kyle S. Kushner, Esq.
(Admitted Pro Hac Vice)
CONTI FENN & LAWRENCE LLC
36 S. Charles Street, Suite 2501
Baltimore, Maryland 21201
Telephone: (410)837-6999
Facsimile:(410) 510-1647
Email: greg@lawcfl.com
kyle@lawcfl.com
Attorneys for Plaintiff/Counter-Defendant
BARTECH SYSTEMS INTERNATIONAL,INC.
17
UNITED STATES DISTRICT COURT
18
DISTRICT OF NEVADA
I9
20 BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
21
Plaintiff/Counter-defendant,
22 vs.
23
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
24 SOLUTIONS (IAS), INC., a Canadian
VINCENT
TESSIER, an
corporation,
25 individual, CHRISTELLE PIGEAT, an
individual,
26
27
28
PARSONS
BEHLE &
LATIMER
Defendants/Counterclaimants.
Case No. 2:15-cv-02422-MMD-NJK
[PROPOSED] ORDER
UPON CONSIDERATION of the pleadings, Plaintiff and Counter-Defendant Bartech
Systems International's ("Bartech") Second Motion for Contempt (ECF No. 117, sealed
unredacted ECF No. 121) and the errata thereto(ECF No. 132), the Response filed by Defendants
and Counterclaimants Mobile Simple Solutions, Inc., Mobile Simple Solutions (IAS), Inc.,
Vincent Tessier, and Christelle Pigeat ("Defendants")(ECF No. 128), the Reply filed by Bartech
(ECF No. 135), and for the reasons stated on the record during the March 23, 2017 hearing and
the minutes (ECF No. 254) and transcript of that hearing, it is hereby ORDERED that
Defendants shall:
(1) Immediately cease selling, leasing, renting, or offering for sale, lease, rent or
subscription any version of the ABreez software that contains any version of the PMS
application without leave of Court. Leave of Court shall not be granted except in the
following circumstances: an independent expert in the fields of computer science and
computer forensics, at Defendants' expense, shall file a status report with the
independent expert's certification that Defendants' software no longer contains
Bartech's source code or other misappropriated trade secrets.
(2) Provide notice via electronic and regular mail in the form of Exhibit A to this Order to
all customers of ABreez not using the ABreez software as a "stand alone" solution that
notifies such customers (identified in Exhibit B)that this Court's May 24, 2016 Order
(ECF No. 96) prohibits Defendants from selling, leasing, renting, or offering for sale,
lease, rent, or subscription any version of the ABreez software that contains any
version of the PMS application, and that any further use of the ABreez software is
prohibited without further Order of this Court.
(3) File proofs of service to show that the notice in the form of Exhibit A was provided to
the customers identified in Exhibit B.
PARSONS
BEHLE &
LATIMER
2
IT IS FURTHER ORDERED that:
2
(1) If Defendants fail to file proofs of service of the notice in the form of Exhibit A to the
3
customers identified in Exhibit B within five (5) days of the date of this Order, then
4
Bartech may provide the notice.
5
6
(2) Bartech is awarded reasonable attorneys' fees incurred in briefing and arguing the
Second Motion for Contempt.
7
8
IT IS SO ORDERED.
I()
I1
12 DATED:
April 6, 2017
UNITED STATES DISTRICT JUDGE
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
PARSONS
BEHLE &
LATIMER
3
4
EXHIBIT
7
8
9
I()
II
12
13
14
15
16
17
18
19
20
21
92
26
27
28
PARSONS
BEHLE &
LATIMER
EXHIBIT
4
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
individual,
Defendants/Counterclaimants.
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
You are hereby notified that the Holiday Inn Vilnius (the "Hotel") cannot use the ABreez
software until further notice. Therefore, please take whatever steps are necessary to disable the
ABreez software on the Hotel's network system, including uninstalling the ABreez software if
necessary. This directive is the result of a court order issued by the United States District Court
for the District of Nevada. The court found that the ABreez Property Management System
Application was developed using trade secrets misappropriated from Bartech Systems
International, Inc. Therefore, further use of the ABreez software is prohibited without
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
PARSONS
BEHLE &
LATIMER
5
UNITED STATES DISTRICT COURT
7
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
4 INC., a Delaware corporation,
5
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
6
MOBILE SIMPLE SOLUTIONS, INC., a
7 Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
8 corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
9
individual,
1O
Defendants/Counterclaimants.
11
12
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
13
You are hereby notified that the Beekman Hotel (the "Hotel") cannot use the ABreez
14
software until further notice. Therefore, please take whatever steps are necessary to disable the
15
ABreez software on the Hotel's network system, including uninstalling the ABreez software if
16
necessary. This directive is the result of a court order issued by the United States District Court
17
18
19
for the District of Nevada. The court found that the ABreez Property Management System
Application was developed using trade secrets misappropriated from Bartech Systems
20 International, Inc. Therefore, further use of the ABreez software is prohibited without
21
22
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
23
the Property Management System Application installed.
24
25
26
27
28
PARSONS
BEHLE &
LATIMER
7
1
UNITED STATES DISTRICT COURT
2
DISTRICT OF NEVADA
3
BARTECH SYSTEMS INTERNATIONAL,
4 INC., a Delaware corporation,
5
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
6
MOBILE SIMPLE SOLUTIONS, INC., a
7 Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
8 corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
9 individual,
10
Defendants/Counterclaimants.
11
12
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
13
You are hereby notified that the Royalton Hotel (the "Hotel") cannot use the ABreez
14 software until further notice. Therefore, please take whatever steps are necessary to disable the
15
ABreez software on the Hotel's network system, including uninstalling the ABreez software if
16
necessary. This directive is the result of a court order issued by the United States District Court
17
18
19
for the District of Nevada. The court found that the ABreez Property Management System
Application was developed using trade secrets misappropriated from Bartech Systems
20 International, Inc. Therefore, further use of the ABreez software is prohibited without
21
22
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
23
the Property Management System Application installed.
24
25
26
27
28
PARSONS
BEHLE &
LATIMER
8
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
individual,
Defendants/Counterclaimants.
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
You are hereby notified that the Wythe Hotel (the "Hotel") cannot use the ABreez
software until further notice. Therefore, please take whatever steps are necessary to disable the
ABreez software on the Hotel's network system, including uninstalling the ABreez software if
necessary. This directive is the result of a court order issued by the United States District Court
for the District of Nevada. The court found that the ABreez Property Management System
Application was developed using trade secrets misappropriated from Bartech Systems
International, Inc. Therefore, further use of the ABreez software is prohibited without
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
PARSONS
BEHLE &
LATIMER
9
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
individual,
Defendants/Counterclaimants.
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
You are hereby notified that the Nativ Hotel (the "Hotel") cannot use the ABreez software
until further notice. Therefore, please take whatever steps are necessary to disable the ABreez
software on the Hotel's network system, including uninstalling the ABreez software if necessary.
This directive is the result of a court order issued by the United States District Court for the
District of Nevada. The court found that the ABreez Property Management System Application
was developed using trade secrets misappropriated from Bartech Systems International, Inc.
Therefore, further use of the ABreez software is prohibited without further order of the
court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
PARSONS
BEHLE &
LATIMER
10
UNITED STATES DISTRICT COURT
2
DISTRICT OF NEVADA
3
BARTECH SYSTEMS INTERNATIONAL,
4 INC., a Delaware corporation,
5
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
6
MOBILE SIMPLE SOLUTIONS, INC., a
7 Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
8 corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
9 individual,
10
Defendants/Counterclaimants.
I I
I2
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
13
You are hereby notified that the Clift Hotel (the "Hotel") cannot use the ABreez software
14
until further notice. Therefore, please take whatever steps are necessary to disable the ABreez
15
software on the Hotel's network system, including uninstalling the ABreez software if necessary.
16
This directive is the result of a court order issued by the United States District Court for the
17
18
19
District of Nevada. The court found that the ABreez Property Management System Application
was developed using trade secrets misappropriated from Bartech Systems International, Inc.
20 Therefore, further use of the ABreez software is prohibited without further order of the
21
22
court.
The court ordered that this notice be sent to all customers using the ABreez software with
23
the Property Management System Application installed.
24
26
27
28
PARSONS
BEHLE &
LATIMER
11
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
individual,
Defendants/Counterclaimants.
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
You are hereby notified that The Raphael Hotel (the "Hotel") cannot use the ABreez
software until further notice. Therefore, please take whatever steps are necessary to disable the
ABreez software on the Hotel's network system, including uninstalling the ABreez software if
necessary. This directive is the result of a court order issued by the United States District Court
for the District of Nevada. The court found that the ABreez Property Management System
Application was developed using trade secrets misappropriated from Bartech Systems
International, Inc. Therefore, further use of the ABreez software is prohibited without
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
PARSONS
BEHLE &
LATIMER
12
1
UNITED STATES DISTRICT COURT
2
DISTRICT OF NEVADA
3
BARTECH SYSTEMS INTERNATIONAL,
4 INC., a Delaware corporation,
5
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
6
MOBILE SIMPLE SOLUTIONS, INC., a
7 Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
8 corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
9 individual,
10
Defendants/Counterclaimants.
11
12
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
13
You are hereby notified that the Peninsula Beverly Hills Hotel (the "Hotel") cannot use
14
the ABreez software until further notice. Therefore, please take whatever steps are necessary to
15
disable the ABreez software on the Hotel's network system, including uninstalling the ABreez
16
software if necessary. This directive is the result of a court order issued by the United States
17
18
District Court for the District of Nevada. The court found that the ABreez Property Management
19
System Application was developed using trade secrets misappropriated from Bartech Systems
20
International, Inc. Therefore, further use of the ABreez software is prohibited without
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
23
the Property Management System Application installed.
24
25
26
27
28
PARSONS
BEHLE &
LATIMER
13
UNITED STATES DISTRICT COURT
2
DISTRICT OF NEVADA
3
BARTECH SYSTEMS INTERNATIONAL,
4 INC., a Delaware corporation,
5
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
6
MOBILE SIMPLE SOLUTIONS, INC., a
7 Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
8 corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
9 individual,
10
Defendants/Counterclaimants.
11
12
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
13
You are hereby notified that The Quin Hotel (the "Hotel") cannot use the ABreez software
14
until further notice. Therefore, please take whatever steps are necessary to disable the ABreez
15
software on the Hotel's network system, including uninstalling the ABreez software if necessary.
16
This directive is the result of a court order issued by the United States District Court for the
17
18
19
District of Nevada. The court found that the ABreez Property Management System Application
was developed using trade secrets misappropriated from Bartech Systems International, Inc.
20 Therefore, further use of the ABreez software is prohibited without further order of the
21
22
23
court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
24
2$
26
27
28
PARSONS
BEHLE &
LATIMER
14
1
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
3
BARTECH SYSTEMS INTERNATIONAL,
4 INC., a Delaware corporation,
5
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
6
MOBILE SIMPLE SOLUTIONS, INC., a
7 Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
8 corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
9 individual,
10
Defendants/Counterclaimants.
11
12
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
13
You are hereby notified that the Renaissance Paris Republique (the "Hotel") cannot use
14
the ABreez software until further notice. Therefore, please take whatever steps are necessary to
15
disable the ABreez software on the Hotel's network system, including uninstalling the ABreez
16
software if necessary. This directive is the result of a court order issued by the United States
17
18
19
District Court for the District of Nevada. The court found that the ABreez Property Management
System Application was developed using trade secrets misappropriated from Bartech Systems
20 International, Inc. Therefore, further use of the ABreez software is prohibited without
21
22
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
23
the Property Management System Application installed.
24
25
26
28
PARSONS
BEHLE &
LATIMER
15
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
TESSIER, an
corporation,
VINCENT
individual, CHRISTELLE PIGEAT, an
individual,
Defendants/Counterclaimants.
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
You are hereby notified that the Mondrian Hotel (the "Hotel") cannot use the ABreez
software until further notice. Therefore, please take whatever steps are necessary to disable the
ABreez software on the Hotel's network system, including uninstalling the ABreez software if
necessary. This directive is the result of a court order issued by the United States District Court
for the District of Nevada. The court found that the ABreez Property Management System
Application was developed using trade secrets misappropriated from Bartech Systems
International, Inc. Therefore, further use of the ABreez software is prohibited without
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
PARSONS
BEHLE &
LATIMER
16
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
corporation,
VINCENT
TESSIER, an
individual, CHRISTELLE PIGEAT, an
individual,
Defendants/Counterclaimants.
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
You are hereby notified that The Dorchester Hotel (the "Hotel") cannot use the ABreez
software until further notice. Therefore, please take whatever steps are necessary to disable the
ABreez software on the Hotel's network system, including uninstalling the ABreez software if
necessary. This directive is the result of a court order issued by the United States District Court
for the District of Nevada. The court found that the ABreez Property Management System
Application was developed using trade secrets misappropriated from Bartech Systems
International, Inc. Therefore, further use of the ABreez software is prohibited without
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
PARSONS
BEHLE &
LATIMER
18
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
TESSIER, an
corporation,
VINCENT
individual, CHRISTELLE PIGEAT, an
individual,
Defendants/Counterclaimants.
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
You are hereby notified that the Trump Vancouver Hotel (the "Hotel") cannot use the
ABreez software until further notice. Therefore, please take whatever steps are necessary to
disable the ABreez software on the Hotel's network system, including uninstalling the ABreez
software if necessary. This directive is the result of a court order issued by the United States
District Court for the District of Nevada. The court found that the ABreez Property Management
System Application was developed using trade secrets misappropriated from Bartech Systems
International, Inc. Therefore, further use of the ABreez software is prohibited without
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
PARSONS
BEHLE &
LATIMER
19
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BARTECH SYSTEMS INTERNATIONAL,
INC., a Delaware corporation,
Case No. 2:15-cv-02422-MMD-NJK
Plaintiff/Counter-defendant,
vs.
MOBILE SIMPLE SOLUTIONS, INC., a
Delaware corporation, MOBILE SIMPLE
SOLUTIONS (IAS), INC., a Canadian
TESSIER, an
VINCENT
corporation,
individual, CHRISTELLE PIGEAT, an
individual,
Defendants/Counterclaimants.
NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE
You are hereby notified that the Pontchartrain Hotel (the "Hotel") cannot use the ABreez
software until further notice. Therefore, please take whatever steps are necessary to disable the
ABreez software on the Hotel's network system, including uninstalling the ABreez software if
necessary. This directive is the result of a court order issued by the United States District Court
for the District of Nevada. The court found that the ABreez Property Management System
Application was developed using trade secrets misappropriated from Bartech Systems
International, Inc. Therefore, further use of the ABreez software is prohibited without
further order of the court.
The court ordered that this notice be sent to all customers using the ABreez software with
the Property Management System Application installed.
PARSONS
BEHLE &
LATIMER
20
1
2
3
4
EXHIBIT B
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
PARSONS
BEHLE &
LATIMER
EXHIBIT B
21
State
Postal Code Country
Company
Hotel Name
Address
City
AB "Valmeda"
Holiday Inn Vilnius
Simyniskiy str 1
Vilnius
8358 Sunset Boulevard
Los
Angeles
California
90069
United States
123 Nassau Street
New York New York
10038
United States
5 Beekman
Property Owner LLC Beekman Hotel
38 Park Row
New York New York
10038
United States
Royalton 44 Hotel
Leasing L.L.C.
Royalton Hotel
545 E. John Carpenter Freeway
Suite 1300
Irving
Texas
75062-8124 United States
80 Wythe LLC
Wythe Hotel
45 Main Street, Suite 602
Brooklyn
New York
11201
United States
1612 Wazee LLC
Nativ Hotel
1612 Wazee LLC
Denver
Colorado
80202
United States
Clift Holdings LLC
Clift Hotel
c/o Cara Ciuffani, 475 Tenth Avenue
New York New York
10018
United States
Lighthouse
Properties, LLC
The Raphael Hotel
P.O. Box 856
Salina
Kansas
67402-0856 United States
Peninsula Beverly
Hills Hotel
Peninsula Beverly Hills
Hotel
9882 South Santa Monica Boulevard
Beverly
Hills
California
90212
United States
The Quin Hotel
The Quin Hotel
New York New York
10019
United States
Sunset Tower Hotel Sunset Tower Hotel
Beekman Hotel
Beekman Hotel
101 West 57th Street at 6th Avenue
Lithuania
Renaissance Paris
Republique SAS
S.H.P.R,
Renaissance Paris
Republique
40, Rene Boulanger
Paris
Wolverine Lessee
LLC
Mondrian Hotel
c/o I.W. Winsten
Honigman Miller Schwartz and Cohn LLP
660 Woodward Avenue
Detroit
Profitability
Consulting PTY
Limited
Alpine Gables
Apartment Hotel
PO. Box 1882
Wollongo New South
ng
Wales
53 Park Lane, Mayfair
London
W1K 1Q1
United Kingdom
1161 West Georgia Street
British
Vancouver Columbia
V6E 006
Canada
2031 St. Charles Avenue
New
Orleans
70130
United States
The Dorchester LTD The Dorchester Hotel
TA Hotel
Management LP
Trump Vancouver
Hotel
Pontchartrain Hotel Pontchartrain Hotel
75010
Michigan
Louisiana
France
48226-3506 United States
Australia
CERTIFICATE OF SERVICE
I hereby certify that I am an employee of the law firm of Parsons Behle & Latimer and
that on the 28th day of March, 2017, I served a true and correct copy of the foregoing
[PROPOSED] ORDER via courtesy email (listed below) and U.S. Mail, at Reno, Nevada, in a
sealed envelope with first-class postage fully prepaid and addressed as follows:
Mobile Simple Solutions, Inc.
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Mobile Simple Solutions (IAS), Inc.
3900-1, Place Ville Marie
Montreal, QC,H3B 4M7, Canada
Vincent Tessier
2298 Aria Drive
Henderson, Nevada 89052
Courtesy Email: vintessier(eb,gmail.com; vincent@mobile-simple.com
Christelle Pigeat
1457 rue Laurier Est,#4
Montreal, QC,H2J 1H8, Canada
Courtesy Email: christelleAmobile-simple.com; christelle.pigeatAgmail.com
/s/ Kathy Souviron
Employee of Parsons Behle & Latimer
PARSONS
BEHLE &
LATIMER
4810-9190-2497 vl
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?