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Motion for a Preliminary Injunction

Motion · Federal district court (general) · Draft

Saved Word PDF

In the United States District Court

for the District of Colorado

MERIDIAN ANALYTICS, INC.,

Plaintiff,

v.

HALVORSEN DATA PARTNERS, LLC,

TOBIAS KANE, and RENNICK VENTURES, LLC,

Defendants.

Case No. 1:26-cv-00614-RMR

Judge Regina M. Ruiz

JURY TRIAL DEMANDED

Plaintiff’s Motion for a Preliminary Injunction

17.

Kane resigned from Meridian’s board on 2 March 2026. His board portal credentials were not revoked until 6 March 2026. (MERIDIAN-000029)

18.

In those four days Kane opened the pricing model, the Tempo renewal schedule and the customer list — 214 documents in all. A former director who keeps board materials after resigning holds them in trust, and the continued use of those materials is itself the irreparable harm the statute contemplates. Alder Creek Sys., Inc. v. Verdant Logistics, LLC, 61 F.4th 1104, 1108 (10th Cir. 2023). (MERIDIAN-000029 at 4)

19.

Within three weeks, Halvorsen quoted Northstar Freight a renewal 35 percent below Meridian’s standing price — a figure it could not have reached without the pricing model. (MERIDIAN-000117)

20.

Halvorsen has continued to solicit Meridian’s customers using that pricing, and will continue to do so unless restrained.

12,481 wordsAbout 34.2 pages162 numbered paragraphsSuggestions on

Linked to the Record.When the Record Changes, the Draft Knows.

Every statement in a draft can carry the evidence behind it, opened in a drawer beside the page. If a document it cites changes or a fact is re-assessed after you wrote the sentence, the paragraph is flagged and the citation can be brought up to date.

Motion for a Preliminary Injunction

Motion · Federal district court (general) · Draft

Saved Word PDF

In the United States District Court

for the District of Colorado

MERIDIAN ANALYTICS, INC.,

Plaintiff,

v.

HALVORSEN DATA PARTNERS, LLC,

TOBIAS KANE, and RENNICK VENTURES, LLC,

Defendants.

Case No. 1:26-cv-00614-RMR

Judge Regina M. Ruiz

JURY TRIAL DEMANDED

Plaintiff’s Motion for a Preliminary Injunction

17.

Kane resigned from Meridian’s board on 2 March 2026. His board portal credentials were not revoked until 6 March 2026. (MERIDIAN-000029)

18.

In those four days Kane opened the pricing model, the Tempo renewal schedule and the customer list — 214 documents in all. A former director who keeps board materials after resigning holds them in trust, and the continued use of those materials is itself the irreparable harm the statute contemplates. Alder Creek Sys., Inc. v. Verdant Logistics, LLC, 61 F.4th 1104, 1108 (10th Cir. 2023). (MERIDIAN-000029 at 4)

19.

Within three weeks, Halvorsen quoted Northstar Freight a renewal 35 percent below Meridian’s standing price — a figure it could not have reached without the pricing model. (MERIDIAN-000117)

20.

Halvorsen has continued to solicit Meridian’s customers using that pricing, and will continue to do so unless restrained.

12,481 wordsAbout 34.2 pages162 numbered paragraphsSuggestions on

Ready to File?Every Paragraph, Checked Against the Record.

Readiness reads the draft paragraph by paragraph and marks each statement supported, partly supported, not supported or contradicted by the record, then checks the document for consistency, structure, format and citations.

Every quote and citation is checked against the record. The drafting AI never writes a citation itself; citations come only from records Codira ESQ holds.

Motion for a Preliminary Injunction

Motion · Federal district court (general) · Draft

Saved Word PDF

In the United States District Court

for the District of Colorado

MERIDIAN ANALYTICS, INC.,

Plaintiff,

v.

HALVORSEN DATA PARTNERS, LLC,

TOBIAS KANE, and RENNICK VENTURES, LLC,

Defendants.

Case No. 1:26-cv-00614-RMR

Judge Regina M. Ruiz

JURY TRIAL DEMANDED

Plaintiff’s Motion for a Preliminary Injunction

17.

Kane resigned from Meridian’s board on 2 March 2026. His board portal credentials were not revoked until 6 March 2026. (MERIDIAN-000029)

18.

In those four days Kane opened the pricing model, the Tempo renewal schedule and the customer list — 214 documents in all. A former director who keeps board materials after resigning holds them in trust, and the continued use of those materials is itself the irreparable harm the statute contemplates. Alder Creek Sys., Inc. v. Verdant Logistics, LLC, 61 F.4th 1104, 1108 (10th Cir. 2023). (MERIDIAN-000029 at 4)

19.

Within three weeks, Halvorsen quoted Northstar Freight a renewal 35 percent below Meridian’s standing price — a figure it could not have reached without the pricing model. (MERIDIAN-000117)

20.

Halvorsen has continued to solicit Meridian’s customers using that pricing, and will continue to do so unless restrained.

12,481 wordsAbout 34.2 pages162 numbered paragraphsSuggestions on

Review to Filing.Tracked Changes, Approvals, the Filing Package.

Partner review with tracked changes, comments and assignments, client review, a redline against any earlier version, and an approval before the draft is marked ready for filing, in the court’s own format.

Motion for a Preliminary Injunction

Motion · Federal district court (general) · Partner review

Tracking changesSaved Word PDF

In the United States District Court

for the District of Colorado

MERIDIAN ANALYTICS, INC.,

Plaintiff,

v.

HALVORSEN DATA PARTNERS, LLC,

TOBIAS KANE, and RENNICK VENTURES, LLC,

Defendants.

Case No. 1:26-cv-00614-RMR

Judge Regina M. Ruiz

JURY TRIAL DEMANDED

Plaintiff’s Motion for a Preliminary Injunction

17.

Kane resigned from Meridian’s board on 2 March 2026. His board portal credentials were not revoked until 6 March 2026. (MERIDIAN-000029)

18.

In those four days Kane opened the pricing model, the Tempo renewal schedule and the customer list — 214 documents in all. A former director who keeps board materials after resigning holds them in trust, and the continued use of those materials is itself the irreparable harm the statute contemplates. Alder Creek Sys., Inc. v. Verdant Logistics, LLC, 61 F.4th 1104, 1108 (10th Cir. 2023). (MERIDIAN-000029 at 4)

19.

Within three weeks, Halvorsen quoted Northstar Freight a renewal 35 percent below Meridian’s standing price — a figure it could not have reached without the pricing model. (MERIDIAN-000117)

20.

Halvorsen has continued to solicit Meridian’s customers using that pricing, and will continue to do so unless restrained.

12,481 wordsAbout 34.2 pages162 numbered paragraphsSuggestions on

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