Preview
Date Filed 4/12/2024 9:01 AM
Superior Court - Suffolk
Docket Number
BUSINESS LITIGATION SESSION
CIVIL ACTION COVER SHEET
coorernos B.L.S.. Massachusetts Trial Court
Superior Court
Business Litigation Session
PLAINTIFFS) DEFENDANTS)
Texas Insurance Company Cambridge Institute of Business Research, Inc.,
KnowledgeLink Group, Inc., Jianxin "Steven" Gao and
Xinwei "Christine" Lin
TTORNEY NAME, FIRM NAME, ADORE: | PHONE NUMBER, E-WATL ADORE: BBO NUMBER ATTORNEY (known)
Kevin J. O'Connor (555249), Peter C. Netburn (546935) Kevin T. Peters (BBO 550522); Jennifer A Henricks (BBO
CLYDE & CO US LLP 265 Franklin Street, Ste. 802, Boston, MA 02110 694635); Lauren B. Haskins (BBO 696678); T. Christopher
617-728-0050 Donnelly (BBO 129930); Nicholas Ramacher (BBO 680258)
‘Origin Code Original Complaint
TYPE OF ACTION AND TRACK DESIGNATION (ee reverse side) CODE NO., TYPE OF ACTION (specify), TRACK, IS THIS A JURY CASE? *
BK.1 Insurance Coverage @)[]¥es
The following is a full and detailed statement of the facts on which plaintiff relies to determine eligibility into the Business Litigation Session, including the
amount in controversy.
Plaintiff insurer seeks a declaration of its rights and obligations under a liability insurance policies issued to
Cambridge Institute of Business Research, Inc. with respect to a shareholder's derivative action pending
before the Business Litigation Session, May X. Zhou, as Shareholder of, and on behalf of Cambridge Institute
of Business Research, Inc., et al. v. Winwei “Christine” Lin, et al., C.A. No.: 2384CV01294-BLS2. Plaintiff
Texas Insurance Company disclaimed coverage.
The dispute between Plaintiff and Cambridge Institute of Business Research, Inc. involves complex issues of
law regarding insurance coverage for the underlying Plaintiff's derivative claims against Cambridge Institute of
Business Research, Inc., KnowledgeLink Group, Inc., Jianxin "Steven" Gao and Xinwie "Christine" Lin.
The case will require significant case management because the underlying related litigations, pending before
this Court, are ongoing. Declarations regarding the parties' respective rights and obligations are needed on an
expedited basis. If discovery is necessary, then it may involve confidential matters and information related to
the defense of the underlying litigation with respect to which confidentiality arrangements and protective orders
will be necessary.
* A Special Tracking Order shall be created by the Presiding Justice of the Business Litigation Session at the Rule 16 Conference.
nou. Lin, etal, uffoTK Superior, SAT VOTZI4-BLS! hou Vv. Lin, étal., SUNOIK Superior, TS84CV0Z607-BLS,_and
PLEASE IDENTIFY, BY CASE NUMBER, NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT.
Knowledgel
ink Group, Inc. v. ‘hou. Suffolk Superior, 1884CV02736-BI
Thereby Certify that have complied with the requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SJC Rule 1:18)
requiring that | provide my clients with information about court-connected dispute resolution services and discuss with them the advantages and
disadvantages of the various methods.” Signature of Attorney of Record Jsi Peter C, Netbum
DATE:. 4224
Date Filed 4/12/2024 9:01 AM
Superior Court - Suffolk
Docket Number
CIVIL ACTION COVER SHEET
INSTRUCTIONS
SELECT CATEGORY THAT BEST DESCRIBES YOUR CASE
BA.1 claims relating to the governance and conduct BE.1 claims involving breaches of contract or fiduciary, fraud, mis~
of internal of entities representation business torte or other violations involving
Baz. Claims relating to employment agreement business relationships
BAS. claime relating to 1fability of shareholders,
directors, officers, partners etc. BF.1 claims under the U.C.C. involving complex issues
BG.1 claims arising fron transactions with banks, investment bankers
BB.2 shareholder derivative claims
BBL? claime relating to or arising out of securities BH.1 claims for violation of antitrust or other trade regulation laws
transactions BH.2 claims of unfair trade practices involving complex issues
Be.2 claims involving mergers, consolidation, sales of BL.1 malpractice claims by business enterprises against professionals
assets, issuance of debt, equity and like interests
BD.2. claime to determine the use or status of, or claine BU.1 claims by or against a bueinese enterprice to which a government
involving, intellectual property entity is a party
BD.2 claime to’ determine the use or status of, or claine
involving, confidential, property or trade secret
information BK.1 other commercial claims, including insurance, conetruction, real
BD.3 claims to determine the use or status, or claims estate and consumer matters involving complex issues
Anvolving restrictive covenants
TRANSFER YOUR SELECTION TO THE FACE SHEET
EXAMPLE:
CODE NO. TYPE OF ACTION (SPECIFY) TRACK IS THIS A JURY CASE?
*
BD3 Restrictive covenants (B) Yes No
DUTY OF THE PLAINTIFF. The plaintiff, or plaintiffs counsel, shall set forth, in the face sheet a statement
specifying in full detail the facts upon which the plaintiff then relies for “presumptive” entry into the Business
Litigation Session. A copy of the civil action cover sheet shall be served on all defendants, together with the
complaint.
DUTY OF THE DEFENDANT. Should the defendant contest the entry into the Business Litigation Session, the
defendant shall file with the answer (or dispositive motion) a statement specifying why the action does not
belong in the Business Litigation Session. Such Statement shall be served with the answer (or dispositive
motion).
A CIVIL ACTION COVER SHEET MUST BE FILED WITH EACH COMPLAINT.
FAILURE TO COMPLETE THIS COVER SHEET THOROUGHLY AND ACCU-RATELY MAY RESULT IN
THE TRANSFER OF THIS ACTION FROM THE BUSINESS LITIGATION SESSION TO ANOTHER
APPROPRIATE SESSION OF THE SUPERIOR COURT.
* A special tracking order shall be created by the presiding justice of the Business Litigation Session at the Initial
Rule 16 Conference.
Preview
Date Filed 4/12/2024 9:01 AM Superior Court - Suffolk Docket Number BUSINESS LITIGATION SESSION CIVIL ACTION COVER SHEET coorernos B.L.S.. Massachusetts Trial Court Superior Court Business Litigation Session PLAINTIFFS) DEFENDANTS) Texas Insurance Company Cambridge Institute of Business Research, Inc., KnowledgeLink Group, Inc., Jianxin "Steven" Gao and Xinwei "Christine" Lin TTORNEY NAME, FIRM NAME, ADORE: | PHONE NUMBER, E-WATL ADORE: BBO NUMBER ATTORNEY (known) Kevin J. O'Connor (555249), Peter C. Netburn (546935) Kevin T. Peters (BBO 550522); Jennifer A Henricks (BBO CLYDE & CO US LLP 265 Franklin Street, Ste. 802, Boston, MA 02110 694635); Lauren B. Haskins (BBO 696678); T. Christopher 617-728-0050 Donnelly (BBO 129930); Nicholas Ramacher (BBO 680258) ‘Origin Code Original Complaint TYPE OF ACTION AND TRACK DESIGNATION (ee reverse side) CODE NO., TYPE OF ACTION (specify), TRACK, IS THIS A JURY CASE? * BK.1 Insurance Coverage @)[]¥es The following is a full and detailed statement of the facts on which plaintiff relies to determine eligibility into the Business Litigation Session, including the amount in controversy. Plaintiff insurer seeks a declaration of its rights and obligations under a liability insurance policies issued to Cambridge Institute of Business Research, Inc. with respect to a shareholder's derivative action pending before the Business Litigation Session, May X. Zhou, as Shareholder of, and on behalf of Cambridge Institute of Business Research, Inc., et al. v. Winwei “Christine” Lin, et al., C.A. No.: 2384CV01294-BLS2. Plaintiff Texas Insurance Company disclaimed coverage. The dispute between Plaintiff and Cambridge Institute of Business Research, Inc. involves complex issues of law regarding insurance coverage for the underlying Plaintiff's derivative claims against Cambridge Institute of Business Research, Inc., KnowledgeLink Group, Inc., Jianxin "Steven" Gao and Xinwie "Christine" Lin. The case will require significant case management because the underlying related litigations, pending before this Court, are ongoing. Declarations regarding the parties' respective rights and obligations are needed on an expedited basis. If discovery is necessary, then it may involve confidential matters and information related to the defense of the underlying litigation with respect to which confidentiality arrangements and protective orders will be necessary. * A Special Tracking Order shall be created by the Presiding Justice of the Business Litigation Session at the Rule 16 Conference. nou. Lin, etal, uffoTK Superior, SAT VOTZI4-BLS! hou Vv. Lin, étal., SUNOIK Superior, TS84CV0Z607-BLS,_and PLEASE IDENTIFY, BY CASE NUMBER, NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT. Knowledgel ink Group, Inc. v. ‘hou. Suffolk Superior, 1884CV02736-BI Thereby Certify that have complied with the requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SJC Rule 1:18) requiring that | provide my clients with information about court-connected dispute resolution services and discuss with them the advantages and disadvantages of the various methods.” Signature of Attorney of Record Jsi Peter C, Netbum DATE:. 4224 Date Filed 4/12/2024 9:01 AM Superior Court - Suffolk Docket Number CIVIL ACTION COVER SHEET INSTRUCTIONS SELECT CATEGORY THAT BEST DESCRIBES YOUR CASE BA.1 claims relating to the governance and conduct BE.1 claims involving breaches of contract or fiduciary, fraud, mis~ of internal of entities representation business torte or other violations involving Baz. Claims relating to employment agreement business relationships BAS. claime relating to 1fability of shareholders, directors, officers, partners etc. BF.1 claims under the U.C.C. involving complex issues BG.1 claims arising fron transactions with banks, investment bankers BB.2 shareholder derivative claims BBL? claime relating to or arising out of securities BH.1 claims for violation of antitrust or other trade regulation laws transactions BH.2 claims of unfair trade practices involving complex issues Be.2 claims involving mergers, consolidation, sales of BL.1 malpractice claims by business enterprises against professionals assets, issuance of debt, equity and like interests BD.2. claime to determine the use or status of, or claine BU.1 claims by or against a bueinese enterprice to which a government involving, intellectual property entity is a party BD.2 claime to’ determine the use or status of, or claine involving, confidential, property or trade secret information BK.1 other commercial claims, including insurance, conetruction, real BD.3 claims to determine the use or status, or claims estate and consumer matters involving complex issues Anvolving restrictive covenants TRANSFER YOUR SELECTION TO THE FACE SHEET EXAMPLE: CODE NO. TYPE OF ACTION (SPECIFY) TRACK IS THIS A JURY CASE? * BD3 Restrictive covenants (B) Yes No DUTY OF THE PLAINTIFF. The plaintiff, or plaintiffs counsel, shall set forth, in the face sheet a statement specifying in full detail the facts upon which the plaintiff then relies for “presumptive” entry into the Business Litigation Session. A copy of the civil action cover sheet shall be served on all defendants, together with the complaint. DUTY OF THE DEFENDANT. Should the defendant contest the entry into the Business Litigation Session, the defendant shall file with the answer (or dispositive motion) a statement specifying why the action does not belong in the Business Litigation Session. Such Statement shall be served with the answer (or dispositive motion). A CIVIL ACTION COVER SHEET MUST BE FILED WITH EACH COMPLAINT. FAILURE TO COMPLETE THIS COVER SHEET THOROUGHLY AND ACCU-RATELY MAY RESULT IN THE TRANSFER OF THIS ACTION FROM THE BUSINESS LITIGATION SESSION TO ANOTHER APPROPRIATE SESSION OF THE SUPERIOR COURT. * A special tracking order shall be created by the presiding justice of the Business Litigation Session at the Initial Rule 16 Conference.