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Contract analysis / letter-broadview-bond-release.docx
letter-broadview-bond-release.docx
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1. No claim has been made against the Bond by any defendant or any other party since the
1. No claim has been made against the Bond by any defendant or any other party since the Bond was issued on March 7, 2025.
2. To CRH's knowledge, after consultation with counsel, no defendant or other party inten
2. To CRH's knowledge, after consultation with counsel, no defendant or other party intends to assert, or has threatened to assert, any claim against the Bond.
3. The Settlement Agreement executed today by all parties to the Action contains mutual g
3. The Settlement Agreement executed today by all parties to the Action contains mutual general releases that encompass any claims that any defendant could have asserted against the Bond.
4. Upon entry of the Consent Order by Vice Chancellor Zhao, the TRO will be dissolved and
4. Upon entry of the Consent Order by Vice Chancellor Zhao, the TRO will be dissolved and vacated in its entirety, and the underlying obligation secured by the Bond—namely, the potential liability of CRH for damages sustained by the defendants as a result of the issuance of the TRO—will be extinguished.
5. There is no remaining legal or factual basis for the Bond to remain in force, and its
5. There is no remaining legal or factual basis for the Bond to remain in force, and its continued maintenance would impose unnecessary cost and administrative burden on CRH as principal. Accordingly, we respectfully request that Broadview process this discharge request and take all steps within its control to effect the formal cancellation and termination of the Bond at the earliest practicable date following entry
1. Copy of the Motion to Dissolve the Temporary Restraining Order Upon Entry of Consent O
1. Copy of the Motion to Dissolve the Temporary Restraining Order Upon Entry of Consent Order, filed with the Delaware Court of Chancery on April 14, 2025;
2. Copy of the Stipulation of Settlement and Proposed Consent Order, filed with the Delaw
2. Copy of the Stipulation of Settlement and Proposed Consent Order, filed with the Delaware Court of Chancery on April 14, 2025;
3. Copy of the original Order Granting Temporary Restraining Order, entered by Vice Chanc
3. Copy of the original Order Granting Temporary Restraining Order, entered by Vice Chancellor Zhao on March 7, 2025. Please note that a conformed copy of the entered Consent Order will be forwarded to Broadview promptly upon receipt from the Register in Chancery. We anticipate that Vice Chancellor Zhao will enter the Consent Order within approximately five to ten business days of filing, although the precise timing
1. Motion to Dissolve the Temporary Restraining Order Upon Entry of Consent Order (filed
1. Motion to Dissolve the Temporary Restraining Order Upon Entry of Consent Order (filed April 14, 2025)
2. Stipulation of Settlement and Proposed Consent Order (filed April 14, 2025)
2. Stipulation of Settlement and Proposed Consent Order (filed April 14, 2025)
3. Order Granting Temporary Restraining Order (entered March 7, 2025)
3. Order Granting Temporary Restraining Order (entered March 7, 2025)