Defendant and Cross-Complainant Ron Merom’s Motion to Compel Plaintiff and Cross- Defendant Finclusion Labs, Inc., to Provide Documents in Response to a Subpoena Served on its Custodian of Records

Factual and Procedural Background

Second Amended Complaint

Founded in January 2017 by George Li (“Li”), Patrick Long (“Long”), Hoang Nguyen (“Nguyen”) and defendant Ron Merom (“Merom”), plaintiff Finclusion Labs, Inc. dba WeTrust (“Finclusion”) creates decentralized, peer-to-peer financial solutions that promote financial inclusion. (Second Amended Complaint (“SAC”), ¶¶1, 7, and 10.) In February 2017, soon after Finclusion’s inception, defendant Merom emailed co-founders Li and Long stating his intent to step down. (SAC, ¶12.)

For a brief time thereafter, defendant Merom appeared to have recommitted to Finclusion. (SAC, ¶13.) During that time between March and May 2017, the co-founders expressed an intent and agreement to subject their shares of Finclusion stock to vesting over a four-yea