Corn

I. BACKGROUND

A. Factual Summary Avanti Holdings is a Nevada limited liability company in which petitioner holds a 29.41 percent membership interest. The company’s other members are Hollister Health Holdings, LLC (Hollister), of which Individual Defendant Mark Bell (Bell) is the sole member and manager; Joel Freedman (Freedman); James MacPherson (MacPherson); and Nick Orzano. Avanti Holdings is managed by a board of managers comprised of petitioner, MacPherson, and Bell. Its wholly owned subsidiary Avanti Hospitals, also a Nevada limited liability company, is likewise managed by petitioner, MacPherson, and

1 The Paladin Defendants are Paladin Healthcare Capital, LLC (Paladin Capital) and Paladin-Avanti Management, LLC (Paladin Management).

3 Bell. Although petitioner was terminated in January 2012 from his position as CEO of Avanti Holdings, he retained his membership interest in the entity and continued to serve as a manager of that entity and of Avanti Hospitals. Approximately five months after he was removed as CEO, on May 29, 2012, petitioner entered into a confidential letter settlement agreement (the Letter Agreement) with Avanti Holdings. To be more precise, the…