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UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

MICHAEL REGER; and

MLR HOLDINGS 2020, LLC,

a Florida limited liability company,

Plaintiffs,

v.

ALL THINGS GEL, LLC, et al.

Defendants.

Case No. 9:22-cv-81772-WPD

JURY TRIAL DEMANDED

PLAINTIFFS’ MOTION FOR JUDICIAL NOTICE

Plaintiffs Michael R. Reger and MLR Holdings 2020, LLC (collectively “Plaintiffs”), by 

and through undersigned counsel, respectfully submits this Motion for Judicial Notice for trial, 

and states as follows:

1. Federal Rule of Evidence 201 authorizes courts to take judicial notice of

documents. Specifically, pursuant to Fed. R. Evid. 201(c), “[t]he court (1) may take judicial notice

on its own; or (2) must take judicial notice if a party requests it and the court is supplied with the

necessary information.” See Fed. R. Evid. 201(c).

2. “A district court may properly take judicial notice of items in the public record, 

such as judicial opinions.” Thompson v. R.J. Reynolds Tobacco Co., 760 F.3d 913, 918 (8th Cir. 

2014) (holding that the district court properly took notice of a prior state court judgment). 

3. “A court may take judicial notice of its own records and the records of inferior 

courts.” Hooker v. United States, 2023 WL 3317413, 2 (11th Cir. 2023).

4. Federal Rule of Evidence 201(f) states that “the court must instruct the jury to 

accept the noticed fact as conclusive.”

5. Defendant, Peter J. Cordani (“Cordani”), filed a state court action against numerous 

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parties, including Plaintiffs, in the Circuit Court for Palm Beach County, Florida, Case No.: 

502021CA007368XXXXMB (“State Action”). Cordani’s claims in the State Action against Reger 

were for Breach of Fiduciary Duty of Good Faith, Waste of Corporate Assets, Unjust Enrichment, 

Breach of Fiduciary Duty of Loyalty, Invasion of Privacy, and Conversion. Cordani brought a 

claim in the State Action against MLR for Conversion. Cordani alleged in the State Action that 

GelTech Solutions, Inc. (“GelTech”) was looted by Reger when GelTech’s board of directors 

voted to transfer all of GelTech’s assets, including the “intellectual property of GelTech and which 

was the primary and most valuable asset of GelTech,” to Reger in January 2020 to settle a secured 

debt owed by GelTech to Reger.

All of Cordani’s claims in the State Action against Plaintiffs were “dismissed with 

prejudice” by the State Court by granting Summary Judgment in favor of Defendants. The Order 

Granting Michael Reger’s Motion for Summary Judgment is attached hereto as Exhibit “A”, the 

Order Granting Lawrence Reger’s, Luciana Jamison’s, David Jamison’s and MLR Holdings 2020, 

LLC’s Motions for Summary Judgment is attached hereto as Exhibit “B”, the Order Granting 

Michael Hull’s Motion for Summary Judgment is attached hereto as Exhibit “C”, and the Order 

Granting Victor Trotter’s and Neil Reger’s Motion for Summary Judgment is attached hereto as 

Exhibit “D” (collectively referred to as the Judgments”). Also, attached hereto is Cordani’s Second 

Amended Complaint in the State Action as Exhibit “E”, and Plaintiffs’ Answer and Affirmative 

Defenses in the State Action as Exhibit “F”. 

6. ATG Laboratories Corp. (“ATG”) filed for bankruptcy in the United States 

Bankruptcy Court Southern District of Florida, Case No.: 23-10244-EPK. ATG’s Voluntary 

Petition for Non-Invidiuals Filing for Bankruptcy is attached hereto as Exhibit “G”, and ATG’s 

Declaration Under Penalty of Perjury for Non-Individual Debtors is attached hereto as Exhibit 

“H”.

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7. Cordani filed for bankruptcy in the United States Bankruptcy Court Southern 

District of Florida, Case No.: 23-14226-EPK. Cordani’s Voluntary Petition for Individuals Filing 

for Bankruptcy is attached hereto as Exhibit “I”, and Cordani’s Notice of Chapter 13 Bankruptcy 

Case is attached hereto as Exhibit “J”. 

8. The Plaintiffs respectfully request that the Court take judicial notice of the 

aforementioned items, as well as the operative pleadings and default judgments entered in this 

action as are specifically identified below.

WHEREFORE, Plaintiffs, respectfully request that this Court take judicial notice for trial of:

1) The Judgments attached as Exhibit “A”, Exhibit “B”, Exhibit “C”, and Exhibit “D” for their 

existence and the substance of the court’s ruling;

2) Cordani’s Second Amended Complaint in the State Action, Exhibit “E”, for its existence;

3) Plaintiffs’ Answer and Affirmative Defenses in the State Action, Exhibit “F”, for its existence; 

4) Plaintiffs’ Amended Complaint in this action, DE 15, for its existence;

5) Plaintiffs’ Second Amended Complaint in this action, DE 110 as well its exhibits DE 110-1 

through DE 110-6, for its existence;

6) Defendants Answer and Affirmative Defenses, DE 141, for its existence;

7) Order Granting Plaintiffs’ Motion for Default Judgment Against Dyno Tech Laboratories Corp, 

Geltech Labs Corporation, Dyno Tech Laboratories Corp, Dynomat Inc., Whale Tank 

Ventures Inc., Logans Wipe Magic Inc., and Fireice Gel, LLC, DE 54, for its existence and 

ruling of liability;

8) Amended Default Judgment Against Defendant ATG Laboratories Corp, DE 104, for its existence

and ruling of liability;

9) Default Judgment as to Liability Against Defendant Dyntech Laboratories Inc., DE 196, for its

existence and ruling of liability;

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10) ATG’s Voluntary Petition for Non-Individuals Filing for Bankruptcy, Exhibit “G”, for its 

existence;

11) ATG’s Declaration Under Penalty of Perjury for Non-Individual Debtors, Exhibit “H”, for its 

existence;

12) Cordani’s Voluntary Petition for Individuals Filing for Bankruptcy, Exhibit “I”, for its 

existence; and 

13) Cordani’s Notice of Chapter 13 Bankruptcy Case, Exhibit “J”, for its existence.

CERTIFICATE OF COUNSEL PURSUANT TO LOCAL RULE 7.1(a)(3)

Undersigned counsel hereby certifies that Plaintiffs have conferred with Defendants’ counsel

who did not have any objections to Plaintiffs’ request that the Court take judicial notice of the attached 

documents. 

Respectfully submitted, 

GrayRobinson, P.A.

515 North Flagler Drive, Ste. 650

West Palm Beach, Florida 33401

Tel: (561) 268-5727

Fax: (561) 268-5747

By: /s/ Dane E. Leitner

Dane E. Leitner

Florida Bar No. 91181

dane.leitner@gray-robinson.com

Co-Counsel for Plaintiffs

CERTIFICATE OF SERVICE

I hereby certify that on August 23, 2024, I electronically filed the foregoing document with 

the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this 

day on all counsel of record, either via transmission of Notices of Electronic Filing generated by 

CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to 

received electronically Notices of Electronic Filing. 

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/s/ Dane E. Leitner 

Dane E. Leitner (FBN 91181)

GRAY ROBINSON, P.A.

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