Greenfield One III Gmbh v. Chaney (2025)

Case details
Full caption
Greenfield One III Gmbh & Co. Kg v. Chaney
Country
United States
Jurisdiction
Delaware (DE)
Court
Delaware Supreme Court
Decided
2025
Disposition
Motion Granted
Majority
Will (Justice)
Greenfield One III Gmbh & Co. Kg v. Chaney, 2025 WL 3682613 (2025) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.12025 WL 3682613 (Del.Ch.) (Trial Order)Chancery Court of Delaware.GREENFIELD ONE III GMBH & CO. KG, Fafa Sports Gmbh, PK Projects Gmbh, EmanuelHenrich Coen, Romm Holding GMBH, Companion-M Gmbh, and Gregoire Le Jeune, individuallyand derivatively on behalf of 1Zero Labs, Inc., d/b/a Fancurve, a Delaware corporation, Plaintiffs,v.Chris CHANEY, Defendant,and1Zero Labs, Inc., d/b/a Fancurve, a Delaware corporation, Nominal Defendant.No. 2024-0663-LWW.December 18, 2025.Editor's Note: This document contains discussion of unverified citations, likely generatedby AI tools used by a party or counsel. These citations are not attributable to the Court. Theunverified citations have been preserved as part of the official record, but links are unavailable.(Proposed) Order Granting Plaintiffs' Motion to Compel and for SanctionsLori W. Will, Judge.*1 [EDITOR'S NOTE: By ruling of the court, Proposed Order is GRANTED IN PART. Please see PDF for full proposed order.]Plaintiffs Greenfield One III GmbH & Co. KG, FAFA Sports GmbH, PK Projects GmbH, Emanuel Heinrich Coen, ROMMHolding GmbH, Companion-M GmbH, and Gregoire le Jeune, having filed a Motion to Compel Discovery (the “Motion”) andthe Court having found good cause therefor;IT IS HEREBY ORDERED this _____ day of _____, 2025, as follows:1. Plaintiffs' Motion is GRANTED;2. Within thirty (30) days of the entry of this Order, Defendants shall fully and properly respond to Plaintiffs' Requests forProduction, which shall reference responsive documents by Bates number(s);3. Within thirty (30) days of the entry of this Order, Defendants shall produce all documents responsive to Plaintiffs' Requestsfor Production with sequential Bates stamps and any applicable privilege logs;4. Within thirty (30) days of the entry of this Order, Defendants shall fully and properly respond to Plaintiffs' Interrogatoriesand shall verify their responses; and5. Defendants shall reimburse Plaintiffs for their reasonable costs and expenses incurred in pursuing this Motion. Plaintiffs shallsubmit an affidavit of their reasonable fees and costs incurred in bringing the Motion within seven (7) days of entry of thisOrder for consideration by the Court.
Greenfield One III Gmbh & Co. Kg v. Chaney, 2025 WL 3682613 (2025) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.2IT IS SO ORDERED.Vice Chancellor Lori W. WillCourt Authorizer Comments:The plaintiffs moved to compel and for sanctions (the “Motion”) against defendant Chris Chaney, who is proceeding pro seafter his counsel withdrew. The motion is also brought against nominal defendant 1ZERO Labs, Inc., which is unrepresented.See Dkt. 49 (explaining that the company cannot proceed pro se). The Motion is granted; the request for sanctions is deniedwithout prejudice. Oral argument is unnecessary.The Motion concerns: (1) document production; (2) interrogatory responses; and (3) sanctions.The plaintiffs assert that Chaney failed to timely produce responsive documents or a privilege log. Chaney responds that hesatisfied his obligations by producing ten core documents, claiming that the company is “dormant” and the dispute is “narrow.”Chaney's position is legally insufficient. Discovery under Court of Chancery Rule 26(b)(1) is broad and far-reaching, coveringany non-privileged matter relevant to a claim or defense. See New Castle Cnty. v. Christiana Town Ctr., LLC, 2004 WL 1835103,at *4 (Del. Ch. Aug. 16, 2004).First, financial records are relevant. The plaintiffs allege a breach of that agreement involving the specific use of investmentproceeds for a “personal loan” to satisfy Chaney's purported personal debts. Documents showing fund movement-such as bankstatements, financial ledgers, and communications about the loan-must be produced. t is not enough to produce the side letter.Second, the company's dormancy does not absolve Chaney of the duty to produce records generated while operational. If Chaneyhas possession, custody, or control of historical documents, they must be produced.*2 Third, Chaney's production of 10 documents is in tension with his prior counsel's representation that search terms producedtens of thousands of hits.Fourth, the scope of discovery extends beyond the side letter to the SAFE agreement. Documents related to the company'sdissolution, cessation of business, or payments to other creditors are relevant.Fifth, “professional efforts” are at issue. Discovery about Chaney's outside business activities-and any legal impediments, suchas investigations or detentions, that restricted his ability to work-cannot be withheld as “personal.”Regarding interrogatories, Chaney previously verified interrogatory responses that directed the plaintiffs to “documents thatwill be produced.” But the documents have not been produced, and Chaney also relied on boilerplate objections. Thus, theseinterrogatory responses are incomplete and deficient.Chaney is ordered to proceed as follows:(1) He must produce the financial records sought by the plaintiffs (including in requests for production numbers 4, 15, 17,21-22, and 31). This includes Fancurve bank statements showing the receipt of the seed round investment and the disbursementof the personal loan.(2) He must produce emails, text messages, or other correspondence between himself and the Board (or investors) regardingthe approval and terms of the personal loan.
Greenfield One III Gmbh & Co. Kg v. Chaney, 2025 WL 3682613 (2025) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.3(3) He must produce records related to the SAFE agreement, including those regarding the company's cessation of operations,dissolution events, and any payments made to creditors or shareholders upon termination.(4) He must provide written answers to the outstanding interrogatories (including interrogatory numbers 2, 5-8, 10-14, and16-17). He cannot simply respond by saying “see attached documents” unless those documents have been produced and arespecifically identified in the response. He must also fully answer interrogatories regarding his professional time commitmentsand any investigations or legal proceedings that may have affected his ability to perform his duties.(5) If Chaney continues to object to any specific request, he must provide a detailed written explanation for the objection (beyondboilerplate language) and must meet and confer with plaintiffs' counsel to attempt to resolve the dispute in good faith.(6) If Chaney is withholding any document on the grounds of attorney-client privilege, he must create a privilege log describingthe date, author, recipient, and subject matter of the document so the plaintiffs can assess the claim.Chaney has until January 17, 2026 (30 days) to comply with the instructions above. If he fails to produce these materials or detailfor the plaintiffs' counsel why they no longer exist by the deadline, I will entertain a renewed motion for sanctions, includingdefault judgment. Currently, I decline to impose sanctions or fees. Given that Chaney's counsel withdrew recently, leaving himto navigate the deadline pro se, I afford him some leniency. But this is Chaney's final warning.I also note that Chaney also referenced an erroneous citation in his filing: Hudson v. Wesley Coll., 2018 WL 2435541, at 3(Del. Ch. May 30, 2018), which does not exist. He must be more careful going forward. A separate order will issue regardingthe use of generative AI.*3 /s/ Judge Lori W. WillEnd of Document© 2026 Thomson Reuters. No claim to original U.S. Government Works.
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