Girn

FACTS AND PROCEDURAL HISTORY

I.

LEI’S HISTORY

LEI was founded in 2000 by Dr. Peter LePort (Dr. LePort). It previously owned and operated several Montessori schools across the country but has sold all of its schools except for one. Plaintiffs are LEI shareholders Ramandeep (Ray) Girn, Rebecca Girn, Kristina Biniek, and Guy Barnett (defined above as shareholder

1 Further undesignated references are to the Code of Civil

Procedure.

2 plaintiffs).2 Ray, Rebecca, and Barnett are also former officers and employees of LEI. LEI terminated Ray’s and Barnett’s employment in February 2016. Rebecca left LEI shortly thereafter. Barney defendants are Barney, Eric Juhlin, Lenny Esmond, and Rony Miller. Barney is an LEI investor and shareholder. In August 2016, he loaned LEI more than $17 million. In exchange, he obtained the right to serve on LEI’s six-member board of directors (the board) and to appoint three of the five remaining director positions. The other three defendants are directors that Barney appointed to the board. LEI suffered a series of financial setbacks, culminating in the sale of nearly all its assets to a third party in June 2018. After the sale, multiple lawsuits were…