NOTICE OF MOTION FOR SANCTIONS AND CONTEMPT
Please take notice that Petitioners Anatolie Stati, Gabriel Stati, Ascom Group, S.A., and Terra Raf Traiding Ltd., by and through their undersigned counsel, hereby move this Court for an Order (1) holding Respondent in contempt under Fed. R. Civ. P. 37(b)(2)(A), and (2) imposing monetary sanctions against Respondent pursuant to Fed. R. Civ. P. 37(b)(2)(C) and this Court's inherent authority.
The Court should grant the Motion for Sanctions and Contempt for the reasons set forth in Petitioners' Memorandum of Law dated December 2, 2019, together with the declaration of Thomas Childs, executed on December 2, 2019.
WHEREFORE, Petitioners respectfully request entry of an Order (1) granting the relief requested herein, and (2) granting Petitioners such other and further relief as the Court deems just. A proposed order is attached hereto.