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-cv-01636) but I have read (link below) BDG’s Reply in Support of Partial Summary Judgement.Appears BDG sued (for what I’m not sure) then Affordable Care filed a counter-suit., that seems to sound a whole lot like a SLAPP suit (boy, I’ve been there…lol).Plaintiff Boston Dental Group’s trademark rights in its Affordable Dental mark, which began at least as early as January 2008, therefore have priority over Affordable Care’s illegal activity.Affordable Dental At Laughlin, LLCAffordable Dental at Westcliff, LLCBDG Coaching, LLC (what exactly is being coached?

RESPONSE: In addition to the foregoing General Objections, Affordable Care objects to this request as irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Affordable Care further objects to this Interrogatory because the information sought in this Interrogatory is not proportional to the needs of the case. 13: Please state in detail the factual basis, including, but not limited to, identification of all documents and persons, of all reimbursements, including, but not limited to, fee-for-service methods of reimbursements paid to you and/or paid by you to your affiliated dental practices located in California and Nevada. (Filed under Seal)“In addition to the fact that Affordable Care’s surprise declaration and exhibits were never produced and should not be considered, this untimely evidence contradicts the evidence that is properly of record in this case, including the sworn testimony of Affordable Care’s only witness, As set out in detail in BDG’s Motion, this is a clear violation of Nevada law. Steelman and the undisclosed Vegas Financial Statements and Vegas Fee Statements, the arrangement between Affordable Care and its Nevada dental office appears to be illegal under Nevada law.”“This is abundantly clear from the Vegas Financial Statements and the Vegas Fee Statements. (Filed under Seal) Affordable Care’s arrangement with the Nevada dental office is illegal under Nevada law and cannot form the basis of any trademark rights. 2007).” (Filed under Seal)“In this case, BDG, a company owned by a licensed Nevada dentist, is merely seeking a declaratory judgment that Affordable Care’s trademarks for dental services are invalid and should be cancelled.

If the financial arrangements with those dental offices are illegal, this illegal activity cannot form the basis of any trademark rights, and Affordable Care’s has trademarks are unenforceable.”The illegality of Affordable Care’s management agreement was an issue throughout this case and multiple discovery requests by BDG sought information concerning this illegal arrangement.

Despite the numerous discovery requests, Affordable Care refused to identify any witnesses or produce any financial documents on this issue.

)Boston Dental Group at Anthem, LLCBoston Dental Management, LLCC and T Dental Laboratory, LLCCambridge Dental Consulting Group Cambridge Dental Technology, Inc Dapha Dental Technology, Inc. )Friendly Ting, PCHaider, Ting and Chung, LLCHandpiece Club, LLCLooting, LLC (WHAT!

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