IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS and ST. JOHN GREAT ST. JIM, LLC, and LSJE, LLC, v. PROSOLAR SYSTEMS, LLC, Plaintiffs, Defendant. CIVIL NO. ST-2019-CV-057 COMPLAINT FOR BREACH OF CONTRACT & FRAUD REPORT OF PARTIES' PLANNING MEETING PURSUANT TO VIRGIN ISLANDS RULES OF CIVIL PROCEDURE 16 AND 26(f) 1. Participants: Pursuant to V.I. R. Civ. P. 16 and 26(f), counsel for the parties have conferred and agreed on the matters set forth below. Participating in the preparation of and agreeing to this report are the following: CHRISTOPHER ALLEN KROBLIN, ESQ. Kellerhals Ferguson Kroblin, PLLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas, VI 00802 for Plaintiffs DOUGLAS L. CAPDEVILLE, ESQ. Law Offices of Douglas L. Capdeville, P.C. 2107 Company Street, Lot 4 Christiansted, VI 00820 for Defendant 2. Pre-Discovery Disclosures: The parties will exchange by April 30, 2019, the information required by V.I. R. Civ. P. 26(a)(1). 3. Discovery Plan: The parties jointly propose to the court the following discovery plan: Discovery will be needed on the following subjects: - factual bases of the allegations stated in the complaint; EFTA00807799 Parties Planning Meeting Report Page 2 the extent of the damages claimed by the plaintiff; and the defenses asserted by the defendants. A. Written discovery: All written discovery shall be propounded by May 15, 2019, and responded to by June 15, 2019. B. Fact witness depositions: All fad witness depositions shall be completed by October 30, 2019. Maximum number of depositions as provided by V.I. R. Civ. P. 30 (a)(2)(A)• Duration of depositions as provided by V.I. R. Civ. P. 30(d)(1). C. Expert discovery Reports from retained experts under Rule 26(a)(2) due: - from plaintiff by January 15, 2020; - from defendants by March 15, 2020. Expert witness depositions shall be completed by July 1, 2020. 4. Other Items: Mediation shall be scheduled prior to January 1, 2020. A post-mediation status conference shall be set by the Court. Settlement can be evaluated at any time during the pendency of the action. Final lists of witnesses and exhibits shall be provided as directed by the Court. The case should be ready for trial on a date set by the court at the final pretrial conference. EFTA00807800 Parties Planning Meeting Report Page 3 Kellerhals Ferguson Kroblin, PLLC DATED: BY: CHRISTOPHER ALLEN KROBLIN, ESQ. Attorneys for Plaintiffs V.I. Bar Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas, VI 00802. Law Offices of Douglas L. Capdeville,.. DATED: BY: DOUGLAS L. CAPDEVILLE, ESQ. Attorney for Defendant V.I. Bar 2107 Company Street, Lot #4 P. O. Box 224191 Christiansted, VI 00820 Tele hone: EFTA00807801