Ghilezan

I. Background Global is a three-partner limited liability partnership. The three partners were Ghilezan, Dryden and Huber. Four years into the partnership, Ghilezan came to believe Dryden and Huber had committed “bad acts” against the partnership, including “diverting significant amounts of money from [Global] to themselves” and/or Gracehollandcannon, LLC and CRD Legal Services, Inc., companies they allegedly control. On December 12, 2022, Ghilezan gave Dryden and Huber notice of his disassociation from Global. The same day, Ghilezan filed a lawsuit against

the defendants. In his operative complaint,1 Ghilezan asserted causes of action for fraud, breach of fiduciary duty, aiding and abetting of breach of fiduciary duties, and dissolution. He also asserted derivative causes of action on behalf of Global for an accounting, sale of partnership assets (appointment of a receiver), and declaratory relief seeking the return of resources unlawfully diverted by defendants from Global. Global was named both as a nominal plaintiff and a nominal defendant. Defendants retained Global, and its associate Joshua Herndon, to represent them and to prosecute a cross-complaint; this included…