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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 

JOINT PRETRIAL STIPULATION 

 The parties, Plaintiffs Michael R. Reger and MLR Holdings 2020, LLC, and Defendants, 

Peter J. Cordani, Mark Daniels and Logan Cordani, by and through their undersigned counsel and 

pursuant to Fed. R. Civ. P. 26(a)(3), L.R. 16.1(e), and this Court’s Scheduling Order [DE-70] dated 

May 4, 2023, hereby file their pretrial stipulation. 

(1) CONCISE STATEMENT OF THE CASE BY EACH PARTY 

 Plaintiff’s Statement of the Case: 

GelTech Solutions, Inc, was a publicly traded company. Plaintiff, Michael Reger was the 

primary shareholder and primary secured creditor of the company. GelTech’s two main product 

lines were FireIce and Soil 20. FireIce is a gel used to efficiently put out fires. Soil20 is a gel used 

to improve growth and conserve water. The formulas for FireIce and Soil20 were assets of 

GelTech Solutions, Inc. Defendant, Peter J. Cordani, owned stock in GelTech, and over the years 

Cordani worked in various positions such as GelTech’s Chief Technology Officer, Chief Executive 

Officer, and was on the Board of Directors. 

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GelTech spent over ten years and millions of dollars on research and development to 

improve and market the products, including having the products tested and certified by various 

governmental agencies regarding its effectiveness and environmental safety in order to make the 

products more valuable to its customers. Unfortunately, due to financial issues GelTech could not 

continue to operate. As a result, GelTech assigned all its assets to Michael Reger in exchange for 

his cancellation of the nearly Seven Million Dollars owed to him which was secured by GelTech’s 

assets. 

After GelTech’s assets had been transferred to Michael Reger, Defendants asked Michael 

Reger to give them an exclusive license to market FireIce and Soil20. Mr. Reger rejected the 

request as he was going to continue to sell FireIce and Soil20. As a result, Defendants created 

knock off products called FireStorm and SoilMD. Defendants marketed these products to 

GelTech’s customers, using GelTech’s vendors and hiring former GelTech 

employees. Defendants copied GelTech’s label information regarding their products’ testing and 

certifications and they made the same claims about their knock-off products even though no such 

testing or certifications had been obtained and they copied GelTech’s safety data sheets to use for 

their products. Defendants tricked customers, and investors, into believing that FireStorm and 

SoilMD were essentially the same product as FireIce and Soil20. Defendants operated through a 

number of different companies with similar names to further their schemes. Through these various 

companies the Defendants have created confusion in the marketplace regarding the true owner of 

the intellectual property rights associated with the creation of FireIce and Soil20. 

Michael Reger has the right to market his products without the confusion and false claims 

of the Defendants. The Defendants do not have the right to use the trade secret formula owned by 

Michael Reger or confidential suppliers to create their knock-off products, and the public has the 

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right to received products which have actually been tested for safety and efficiency without being 

tricked into buying a knock-off product with false claims about testing and certifications. 

Defendant’s Statement of the Case: 

Plaintiffs have sued Defendants in a nine count Second Amended Complaint asserting 

various causes of action to include violation of federal and state law, an employment agreement, 

breach of fiduciary duty all centered around whether Plaintiffs whom contend they owned the right 

to the material that Defendants engaged in false advertising, misappropriation of trade secrets, 

copyright infringement and as a result Plaintiffs have been damaged. Defendants deny all of 

Plaintiffs claims and have asserted numerous defenses to each of Plaintiffs claims. Defendants 

refer to their issues of law and fact in this pretrial stipulation below which breaks down the issues 

of law and fact for consideration by the jury. 

(2) THE BASIS OF FEDERAL JURISDICTION

 This Court has subject matter jurisdiction over the Plaintiffs’ claims pursuant to Section 39 

of the Lanham Act, 15 U.S.C § 1121(a) and 28 U.S.C. § 1331. 

(3) PLEADINGS RAISING THE ISSUES

1. Plaintiff’s Second Amended Complaint [DE110]. 

2. Defendant’s Answer and Affirmative Defenses to Plaintiff’s First 

Amended Complaint [DE141] 

(4) UNRESOLVED MOTIONS REQUIRING ACTION BY THE COURT

 1. Plaintiffs’ Second Motion for Contempt and Sanctions [DE309] 

 2. Plaintiffs’ Amended Second Motion for Contempt and Sanctions [DE334] 

3. Damage and Remedies against defaulted All Things Gel, LLC, Dynotech 

Laboratories Corp, Dyntech Laboratories Inc., Logans’ Wipe Magic Inc., Geltech 

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Labs Corporation, ATG Laboratories Corp, Dynomat Inc., Whale Tank Ventures, 

Inc., FireIce Gel, LLC, Peter J Cordani Inc. 

4. Plaintiffs’ Omnibus Motion in Limine 

5. Plaintiffs’ Motion to Take Judicial Notice of State Court Final Judgments 

(5) CONCISE STATEMENT OF UNCONTESTED FACTS

Formation of GelTech Solutions, Inc. 

1. Dyn-O-Mat, Inc. (Dyn-O-Mat) was formed in 1994 by William Cordani 

(Peter Cordani’s Father) and was administratively dissolved for failure to 

file its annual business report in September 25, 2009. 

2. At one time Dyn-O-Mat had over 150 shareholders who invested in DynO-Mat. 

3. Peter Cordani was the Chief Executive Officer of Dyn-O-Mat from its 

inception until February 2007. 

4. GelTech Solutions, Inc. was incorporated in Florida on July 19, 2006, by its 

promoters, Dyn-O-Mat, Michael Cordani and Peter Cordani (“GelTech 

FL”). 

5. After incorporation, GelTech FL became a wholly-owned subsidiary of 

Dyn-O-Mat. 

6. After its incorporation, GelTech FL sold 385,000 shares of common stock 

to 9 accredited investors at $1.00 per share. 

7. GelTech Solutions, Inc was incorporated in Delaware on November 8, 2006 

(“GelTech DE”). 

8. On November 15, 2006, GelTech FL merged into GelTech DE (“Merger”). 

9. After the Merger, GelTech DE was the surviving corporation owning all the 

assets of GelTech FL and GelTech FL was dissolved. 

10. On July 11, 2007, GelTech DE filed an application with the State of Florida 

to conduct business in the State of Florida as a foreign corporation. 

11. Peter Cordani was the Chief Technology Officer of GelTech FL and 

GelTech DE from their inception. 

12. Peter Cordani became director of GelTech DE on July 3, 2007. 

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13. On May 29, 2007, GelTech DE sold 2,250,000 shares at $0.667 per share 

and 225,000 warrants exercisable at $1.00 per share to Michael Reger for 

$1,500,000 (“Initial Reger GelTech DE Purchase”). 

14. On July 20, 2006, GelTech DE and Dyn-O-Mat entered into a purchase 

agreement, whereby Dyn-O-Mat received 7,250,000 shares of GelTech DE 

common stock in exchange for its intellectual property and other limited 

assets. 

15. In late June 2007, Dyn-O-Mat, the parent corporation of GelTech DE, 

completed an exchange offer with its shareholders whereby Dyn-O-Mat 

shareholders received GelTech DE shares in exchange for its Dyn-O-Mat 

shares (“Exchange Offer”). 

16. More than150 Dyn-O-Mat shareholders accepted the exchange offer, and 

Dyn-O-Mat transferred 5,995,837 of GelTech DE shares to the Dyn-O-Mat 

shareholders participating in the Exchange Offer. 

17. The Cordani family members, including Mr. Michael Cordani, GelTech 

DE’s Chief Executive Officer, and three trusts controlled by Mr. Michael 

Cordani, received 2,967,310 shares of common stock in the exchange offer. 

18. Phil O’Connell, a GelTech DE Director, received, received 622,644 shares 

of GelTech DE common stock and 474,058 warrants exercisable at $1.05 

per share in the Exchange Offer. 

19. After the initial Exchange, Dyn-O-Mat’s ownership of GelTech DE was 

reduced from 7,250,000 shares to 1,254,358 shares. 

20. Mike Reger owned no shares in Dyn-O-Mat and did not participate in the 

exchange offer. 

21. GelTech DE filed for registration of its common shares with the SEC, and 

received a Notice of Effectiveness on December 27, 2007, and began 

publicly trading on the OTC Bulletin Board in June 2006. On October 1, 

2015, GelTech DE was approved for listing on the OTCQB. 

22. GelTech DE initially marketed and sold three products (1) RootGel – a line 

of agricultural moisture retention products, (2) FireIce – a fire suppression 

product which GelTech at one time had a patent pending with respect to its 

formulation, (3) IceWear – a garment line to assist in cooling body 

temperature. 

23. Upon the closing of GelTech ’s private placement on May 29, 2007 with 

respect to the Initial Reger GelTech DE Purchase, GelTech DE placed 

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orders with a third-party manufacturer for the initial inventory of RootGel. 

GelTech DE’s initial sales of RootGel, consisting of both the sprayable and 

granular forms, were to Golf Ventures for sale to their customers throughout 

Florida. 

24. On January 21, 2008, Michael Reger made a second investment in GelTech 

DE by purchasing 3,303,000 Shares of common stock for the total purchase 

price of $2,000,0000. 

25. Peter Cordani created the initial proprietary formula for RootGel for 

GelTech FL which became property of GelTech DE through the Merger. 

(Defendants contest this statement) 

26. RootGel was later rebranded as Soil20 in or around 2010 due to a trademark 

infringement action initiated by a third-party. 

27. GelTech DE filed a U.S. patent application, Serial No. 11/775,512 for a 

sprayable form of RootGel, water retention and method for spray 

application on July10, 2007, Final Rejection was delivered by the USPTO 

office to GelTech DE on April 12, 2010, and abandoned on October 21, 

2010. 

28. GelTech DE filed its application for the Soil20 trademark with the US 

Patent and Trademark office, and it received trademark registration on 

February 28, 2012. 

29. The initial proprietary formulation of Soil20 created by Peter Cordani for 

GelTech FL was subsequently modified by GelTech DE through internal 

and third-party testing, and new products such as Soil20 Golf were 

specifically formulated to address the golf industry, which resulted in a 

relationship with an international distributor, Trigon Turf Sciences, LLC, to 

serve the golf community under their private label in January 2018. 

(Defendants contest this statement) 

30. GelTech DE filed U.S. patent application, Serial No. 11/680,803 and 

International Patent application, Serial No. PCT/US07/63075 for FireIce on 

March 1, 2007. A Final Rejection Notice was sent to GelTech DE May 

27,2010, and abandoned on December 12, 2010. (Defendants contest that it 

was for trademark only)

31. In early 2008, GelTech DE filed its application with the United States 

Department of Forestry Department to have FireIce listed on the United 

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States Department of Forestry (the “Department”) Qualified Products List 

(“QPL”) to obtain Department approval within U.S. Department of 

Agriculture Forest Service Specification 5100-306a. 

32. In March 2011, FireIce passed all tests in accordance with Forest Service 

Specification 5100-306a and was listed on the Department’s QPL under the 

category of Water Enhancers for Wildland Fire Management. 

33. Subsequent to the acceptance of FireIce 561 on the QPL, GelTech filed 

application with the QPL to have its other products listed. The proprietary 

formulation for HVB-Fx, the latest product approved and listed on the QPL, 

incorporated the FireIce formulation, but was enhanced and developed 

internally by GelTech’s Wildland group, in conjunction with third-party 

chemical engineers. (Defendants contest this statement) 

34. As of 2024, the QPL Listed Products are: FireIce 561, FireIce HVB-Fx, and 

FireIce 561 Cool Blue-F. FireIce Sunset Orange was removed from the 

QPL due to certain forest regulations. 

35. GelTech DE filed its application for the FireIce Trademark with the US 

Patent and Trademark Office, and it received registration on May 20, 2008. 

36. GelTech filed its first Form 10-K for the period ending June 30, 2008 

(“GelTech DE First 10-K”). 

37. GelTech First 10-K list the following Patents and Patents pending: 

U.S. Patent No. 6,315,213 – Method of Modifying Weather; and 

U.S. Patent U.S. Serial No. 7,182,778 – Conforming Thermal Pack for 

IceWearTM. 

U.S. patent application, Serial No. 11/251,005 for IceWearTM; 

U.S. patent application, Serial No. 11/680,803 and International Patent 

application, Serial No. PCT/US07/63075 for FireIce®; 

and 

U.S. patent application, Serial No. 11/775,512 for a sprayable form of 

RootGelTM. 

38. GelTech DE First 10-K was audited by GelTech ’s independent Auditor, 

Salberg & Company. 

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39. GelTech DE had a net loss and net cash used in operating activities in 2008 

of $1,946,626 and $1,970,757 respectively and had a deficit accumulated 

during the development stage of $3,258,018 at June 30, 2008. 

40. GelTech’s business model focused on the environmentally friendly 

products: FireIce® gel, FireIce Shield®, Soil2O® Dust Control and 

Soil2O® moisture retention products, including Soil2O® Topical and 

Soil2O® Granular. 

41. GelTech®, Soil2O®, and FireIce® are registered trademarks. The 

trademark registration for Soil2O® has expired. 

42. In January 2020, Michael Reger announced he would no longer continue to 

fund the company. 

43. The products marketed and sold by Defendants are Firestorm and SoilMD. 

44. In 2020, Peter Cordani and Mark Daniels, a longtime friend of Peter’s, 

formed FireIce Gel, Inc., GelTech Labs Corporation, Dynomat Inc., All 

Things Gel, LLC and ATG Laboratories Corp. 

45. In 2021 Peter Cordani and Mark Daniels formed Dynotech Laboratories 

Corp. 

46. In 2023, Peter Cordani and Mark Daniels formed Dyntech Laboratories Inc. 

and Dynomat Laboratories. 

47. The Defendants’ FireStorm and SoilMD products were marketed or sold 

through All Things Gel, LLC, ATG Laboratories Corp., Dynotech 

Laboratories Corp., and Dyntech Laboratories Corp. 

48. In 2023 Defendants changed the name of FireStorm to FireFighter with the 

intention of marketing the product through the newly formed Dynomat 

Laboratories, Corp. 

49. Brent Hutson was a web and graphic designer for GelTech. 

50. Defendants’ Firestorm has not been tested or approved by the U.S. Forest 

Service and is not listed on their Qualified Product List. 

51. James Andy Lynch and his company, Fire Solutions Group, were hired by 

GelTech to conduct the necessary testing in order for GelTech’s FireIce 

product and its fire extinguisher to become UL certified. 

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52. The UL company helps companies demonstrate safety and achieve 

regulatory compliance. 

53. When the UL representative requested contact information for GelTech and 

ATG Labs to verify ATG Labs’ rights to the UL file, Mr. Lynch told the 

UL representative “Peter Cordani...is the past CEO of Geltech Solutions 

and the New CEO of ATGLabs...He can be the new point of contact for 

this transfer.” Peter Cordani was copied on the email. 

54. ATG Labs’ tri-fold marketing brochures claimed that FireStorm had passed 

UL equivalent testing. Peter Cordani contends he was unaware that is claim 

was being made on ATG Labs’ marketing brochures. 

55. Defendants allege that the various personnel they hired were responsible for 

the false advertising. 

56. Logan Cordani posted a video of himself on social media regarding 

Firestorm Shield saying it was created by him and his father. 

(6) ISSUES OF FACT WHICH REQUIRE TO BE LITIGATED AT TRIAL 

Defendants contend the following facts are disputed. 

1. GelTech DE filed its application for the Soil20 Trademark, and it received 

registration on February 28, 2012. 

2. The initial proprietary formulation for FireIce was created by Peter Cordani 

for GelTech FL and the proprietary formulation became the property of 

GelTech DE through the Merger. 

3. In order to market FireIce, GelTech DE was initially required to obtain 

third-party certification as to its safety. In late June 2007, GelTech DE 

engaged an independent laboratory to test the performance and safety of 

FireIce to determine whether FireIce met standards published by the 

National Fire Protection Association or NFPA or Underwriter’s 

Laboratories or UL. 

4. In or about early part of 2008, GelTech DE obtained its first third party 

laboratory testing for FireIce and received UL-711 2-A; UL-711 40-A 

certifications and a Custom Rubber and Tire Fire Listing. Upon receiving 

these third-party certifications GelTech DE marketed FireIce® initially to 

local fire departments and local government officials. 

5. The initial formulation of FireIce has been altered and modified throughout 

GelTech’s 13 year history as a result of internal and third-party testing to 

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determine and improve its safety, efficacy and its effect on the environment 

(fish, mammals, amphibians and vegetation). 

Plaintiffs state the following facts likely are unnecessary unless Defendants are 

permitted to re-litigate claims brought in the State Court Action and/or contest 

Michael Reger’s ownership of GelTech’s assets including the FireIce and Soil20 

trade secret formulas. 

Defendants state the following facts are likely unnecessary unless plaintiffs’ claims 

are permitted to litigate in this action their claims in the second amended complaint 

that should have been brought in the state court action and accordingly, defendants 

assert that these claims are barred by the doctrine of claim preclusion. That is, the 

claims should have and were not brought as compulsory or permissive 

counterclaims in the state court action between the parties. 

6. Over the years, GelTech has had numerous investors, including Michael 

Reger, who invested funds in GelTech in reliance upon the representation 

that GelTech owned the proprietary rights to its products, including FireIce 

and Soil20. 

7. GelTech spent hundreds of thousands of dollars testing, improving and 

certifying its products, which was materially necessary to market to its 

commercial customers. 

8. Peter Cordani executed an Employment Agreement with GelTech 

Solutions, Inc. in 2011, 2012 and amended the agreement in 2015. 

9. Every year, GelTech’s expenses exceeded its income. GelTech kept its 

doors open through loans and stock purchases. 

10. Each year, GelTech’s independent auditors included a comment in their 

report regarding the fact that GelTech was not a going concern. 

11. In 2019, GelTech had three secured loans outstanding, all of them owed to 

its board chairman and principal shareholder Michael Reger. 

12. All loans from Michael Reger were approved by the GelTech Board of 

Directors, reported on SEC Form 10-K and 10-Q filings, and audited by 

GelTech’s independent outside auditor. 

13. GelTech was never able to make cash payments for interest or principle on 

the Reger secured loans. 

14. Peter Cordani was GelTech’s Chief Technology Officer and Director since 

inception and was GelTech’s acting Chief Executive Officer from January 

2014 until the end of October 2018. 

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15. Peter was the highest paid GelTech employee, receiving a six-figure annual 

salary. 

16. Michael Reger was GelTech’s largest shareholder and largest creditor. 

17. Since inception, GelTech’s expenses exceeded its revenue and by 

September 2019, the accumulated losses were over 56 million dollars. 

18. On January 31, 2020, GelTech’s Board voted to assign all of GelTech’s 

assets including its intellectual property to Reger in exchange for 

cancellation of the approximate $7,000,000 secured debt. 

19. Michael Reger licensed to his company, MLR Holdings, the right to market 

GelTech’s brand of products. 

20. In February 2020, Peter Cordani proposed an exclusive license of the 

intellectual property assigned to Reger by GelTech. Michael Reger rejected 

the proposal. 

Issues Arising from the Pleadings are contested and disputed between the parties 

21. On May 17, 2024, Michael Reger was issued a patent for the process of 

manufacturing FireIce. 

22. After GelTech’s transfer to Michael Reger, Defendants created various 

companies to market products similar to the FireIce and Soil20 products 

marketed and sold by GelTech. 

23. The products marketed by GelTech and later by MLR Holdings are FireIce 

gel, FireIce Thermal Coat, Soil20, and Soil20 Dust Control. 

24. The base of GelTech’s products is a polymer specifically manufactured for 

GelTech by two confidential suppliers. 

25. The formula for GelTech’s products is a trade secret transferred to Michael 

Reger. 

26. Through the various companies formed after GelTech closed, Defendants 

ordered multiple polymer shipments from GelTech’s confidential suppliers 

to manufacture their competing products. 

27. Peter Cordani twice testified under oath that he did not sell or promote any 

products during his one year non-competition period following GelTech’s 

closing. However, here were multiple sales by Defendants’ companies 

during the 1 year non-competition period following GelTech’s closing. 

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28. Through their various companies Defendants sold their FireStorm and 

SoilMD or similar products to GelTech’s former customers, making the 

same exact claims regarding their products as were made regarding 

GelTech’s products by copying from GelTech’s copyrighted materials, 

leading customers to falsely believe they were the same products with the 

same qualities and safety certifications. 

29. At the direction of Peter Cordani and Mark Daniels, Defendants’ web 

designer used GelTech’s materials to create a website and brochures for 

Defendants’ products, which advertising contained false claims regarding 

the products’ safety certifications, testing, efficacy, and governmental 

approvals. 

30. Defendants’ companies used GelTech’s Soil20 and FireIce safety data 

sheets and other product materials to create advertising for their SoilMD 

and FireStorm products. The SDS falsely alleged that SoilMD and 

FireStorm had been government tested and proven to safe for plants, 

mammals, fish, etc. 

31. According to Peter Cordani, he used his knowledge of GelTech’s formulas 

and made changes to the chemical structure of GelTech’s products to make 

the FireStorm and SoilMD products different from GelTech’s FireIce and 

Soil20 products. 

32. Defendants’ SoilMD advertising contains testimonials from United Rock 

Products, Amec Foster Wheeler, Senior Pastor Walter Hoefflin, and 

Michael Carbonaro in Defendants’ trifold brochure for SoilMD. The 

testimonials were copied from GelTech’s literature or website which is 

copyrighted. The testimonials were given regarding GelTech’s Soil20, not 

Defendants’ SoilMD as falsely alleged in their advertising. 

33. After GelTech closed, Defendants’ attempted to steal the UL listing 

obtained by GelTech and transferred to Michael Reger. 

34. Although FireStorm did not pass UL equivalent testing, ATG Labs claimed 

on their website and in their marketing brochures that FireStorm had passed 

UL equivalent testing. 

35. Defendants’ website and marketing materials falsely claimed that FireStorm 

was “tested by the U.S. Forest Service," was “capable of containing a fire 

up to 5,000° F”, was classified by the U.S. Forest Service as "nontoxic to 

mammals, aquatic and terrestrial species, was deemed environmentally 

benign by the EPA and USDA.” among other false claims. 

36. Included in Defendants’ offices is a large trade board advertisement for an 

All Things Gel product called “Dust Defend.” The false claims in the Dust 

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Defend advertisement was copied directly from published materials 

regarding GelTech’s Soil20 Dust Control Product and falsely claims the 

product has received approval from Federal, State and Local governments. 

37. In 2023, Defendants attempted to gain investors of one of their companies, 

Dyntech, using investment brokers, falsely claiming the intellectual 

property of Dyntech was worth $30,000. 

38. Defendants provided false testimonials to the investment brokers, Geoffrey 

Shenk and Andrew Miller purportedly regarding FireStorm for use in 

marketing to potential consumers and investors of Dyntech. 

39. In 2021, Mark Daniels and Peter Cordani prepared a private placement 

memorandum regarding ATG Laboratories to use in encouraging potential 

investors to invest in that company. The private placement memorandum 

claimed that ATG Laboratories’ intellectual property was valued in excess 

of $30 million. 

40. Miller and Shenk were falsely told that Peter Cordani had licensed his 

intellectual property rights to Dyntech Labs and that no one else was 

actively marketing FireIce. 

41. Doug Watler, Trustee of the Watler Family Trust, invested $50,000 to 

purchase one share of stock in Dyntech, in reliance upon Defendants’ false 

claims. However, the share was never delivered to Watler, Defendants kept 

the $50,000 and refused to return the funds. Defendants closed the company 

and opened another company called Dynomat Laboratories Corp. to attempt 

to avoid responsibility to Mr. Watler. 

42. A company owned by Peter Cordani and Logan Cordani ordered polymer 

product from GelTech’s confidential supplier. 

43. Logan Magic products are marketed and displayed with Defendants’ other 

products. 

44. GelTech’s posters used by Defendants have registered copyrights (Reg. No. 

VA 2-319-511) and GelTech’s website, its SDS, and its Soil20 website are 

copyrighted. 

45. Peter Cordani emailed GelTech’s confidential information to his personal 

email address before GelTech closed and Defendants ordered products from 

GelTech’s vendors and marketed to GelTech’s customers using 

Defendants’ trade secrets and violating Peter Cordani’s employment 

agreement. 

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46. Defendants kept changing companies because of Plaintiffs’ attempts to 

legally enforce his rights. 

47. Peter Cordani assigned from ATG Labs the FireStorm trademark to himself 

without consideration. He did so because of the pending litigation and his 

desire to keep it protected. 

48. Defendants ignored all corporate formalities regarding their various 

companies. They marketed the same products through multiple companies, 

using the same marketing materials with the company name changed only, 

and the funds flowing through the various bank accounts of the companies 

revealed a total lack of separation between companies and the individuals 

Defendants. The Delaware companies created by Cordani and Daniels, 

never filed with the State of Florida to be recognized as foreign corporation. 

49. Prior to GelTech closing, Peter Cordani secreted away GelTech product 

which he later sold under the FireStorm label. 

50. Peter Cordani put ATG Labs into bankruptcy, falsely testifying that the 

company had no assets and had made only two sales. Defendants had a 

warehouse of equipment, inventory with ATG Labs labels shortly after the 

bankruptcy was voluntarily dismissed. 

51. The Jupiter Warehouse formerly used by GelTech and later used by 

Defendants was the business location for at least 15 of Defendants’ 

companies but rent and other shared expenses were never apportioned or 

accounted for. 

52. Defendants’ companies were set for an illegal purpose, to merely unfairly 

compete with MLR and intentionally use information about their products 

to deceive customers, only to default each company and move assets to a 

new company with same purpose and products. 

53. Defendants used the Whale Tank Warehouse in Jupiter as a blending facility 

for ATG products. 

54. Logan Cordani maintained an office space at the Jupiter warehouse while 

permitting Defendants to blend product at his old warehouse for the benefit 

of the other companies. 

55. Logan Cordani stored his Logan Wipe Magic at the Jupiter warehouse 

without incurring costs or expense. 

56. Logan Cordani participated at the investor meeting at the Jupiter 

Warehouse. 

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57. Logan’s products were marketed with Defendants’ FireStorm and SoilMD 

products. 

58. Defendants attempted to get Logan Cordani’s product UL certified but the 

product failed testing. 

59. Defendants violated the Lanham Act through false advertising and unfair 

competition, causing Plaintiffs’ damage. 

60. Defendants engaged in unfair and deceptive trade practices through false 

advertising, causing Plaintiffs’ damage. 

61. Defendants infringed on Plaintiffs trademarks by using confusingly similar 

marks and through reverse palming off of Plaintiffs’ products, causing 

Plaintiffs damage. 

62. Defendants misappropriated Plaintiffs’ trade secrets causing Plaintiffs 

damage, causing Plaintiffs damage. 

63. Defendants unlawfully used Plaintiffs copyrighted materials causing 

Plaintiffs damage. 

64. Peter Cordani breached his employment agreement by using and failing to 

keep secret GelTech’s trade secrets including its customers, vendors, 

suppliers, and product formulas, causing Plaintiffs damage. 

65. Peter Cordani breached his fiduciary duty by using and failing to keep secret 

GelTech’s trade secrets including its customers, vendors, suppliers, and 

product formulas, and by violating GelTech’s Settlement Agreement with 

Michael Reger, causing Plaintiffs damage. 

Defendants propose the following issues of fact. Plaintiffs contend these issues 

have never been framed by the pleadings, were part of the State Action brought 

by Peter Cordani and Defendants are barred from relitigating the issues here; 

are irrelevant to the claims raised in Plaintiffs’ Second Amended Complaint, or 

are contrary to facts admitted by Defendants in these proceedings. 

66): Peter J. Cordani was the original sole inventor over twenty (20) years ago of 

FireIce and Rootgel. 

67): Rootgel changed its name to Soil20 approximately ten (10) years ago. 

68): The FireStorm and SoilMD are different formulas constructed only by Peter J. 

Cordani modified and improved from the original FireIce and Soil20 formulas 

invented only by Peter J. Cordani. 

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69): That defendants assert upon GelTech’s closing they never marketed FireIce 

and SoilMD under the names of FireStorm and SoilMD. 

70): That any “ trade secrets “ or proprietary information of FireIce and SoilMD 

are Peter J. Cordani’s and not plaintiffs . 

71): That Peter J. Cordani only “ assigned “ to GelTech Solutions the delivery 

systems ( not the apparatuses ) not formulas , to GelTech or anyone else . 

72): That plaintiffs as of September 9,2022 no longer owned , as a trademark, 

Soil20as its trademark had expired . 

73): That Michael Reger in a letter dated October 19,2019 addressed to Peter J. 

Cordani and the Board of Directors and employees told GelTech “ 2020 shall be a 

banner year.” 

74): That Peter J. Cordani initially abstained on voting relating to the closing of 

GelTech but informed in an email its attorney( Brian Bernstein ) within 24 hours 

of the Board meeting that he was objecting to any efforts or attempts or vote to 

close GelTech. 

75): That GelTech not its attorneys never filed with the SEC or any entity a written 

settlement agree to referenced in its 10-k filing with the SEC. 

76): That prior to its ( GelTech) closing Michael Reger 

77): That Michael Reger in lieu of cash payments or interest or principal payments 

on any loans he made to GelTrch received stock options . 

78): That Peter J. Cordani asserts he never authorized his lawyer(s) to propose to 

Michael Reger a license for GelTech’s intellectual property ; Upon learning this 

occurred , without his authorization or consent , Peter J. Cordani “fired” his lawyer 

(s). 

79): That Peter J. Cordani formed with Mark Daniels companies to disallow 

Michael Reger from obtaining those names and to allow these new entities to 

develop and market different products ., to include a fire cooldown “gel” and “ plant 

growth enhancement “ product. 

80): That Peter J . Cordani only began selling his own proprietary products he 

devolved only under Firestorm and SoilMD. These products were “ ground” 

products not “ sifted “ products , and accordingly were different . 

81): That any representations included on website or marketing brochures relating 

to testing adequate testing and certifications were not made by defendants but 

others without defendants consent authorization or ratification . 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 16 of 46
 17

82): That defendants assert they never represented to third parties they were the 

successor to GelTech. 

83): That Mark Daniels primarily was just an “ investor “ in all of the newly crested 

companies with the exception of assisting Peter J. Cordani on a limited basis with 

You Tube Google marketing that unbeknownst to Peter J. Cordani excepting his 

posting on social media his own book was still in the social domain . 

85): Logan Cordani Peter J. Cordani and Mark Daniels assert Logan Cordani was 

unconnected uninvolved with any of the newly created companies or predecessor 

companies except his own company . 

86): Peter J. Cordani and Mark Daniels not any of the defendants assert they 

authorized Logan Cordani to post a brief social media post regarding Firestorm 

Shield to proclaim it was created by Logan Cordani and his father . 

87): Peter J. Cordani never had in existence post January 2020 an employment 

agreement to include a noncompete agreement with Plaintiffs . 

88): Peter J. Cordani maintains that the closing of GelTech in January 2020 was 

unauthorized without his consent and did not result in Peter J. Cordani relinquishing 

any of his own proprietary rights intellectual property or licensing agreements 

relating to his own inventions during his career as an inventor 

(7) CONCISE STATEMENT OF ISSUES OF LAW ON WHICH THERE IS 

 AGREEMENT 

1. Default Judgments have been entered against All Things Gel, LLC, Dynotech 

Laboratories Corp, Dyntech Laboratories Inc., Logans’ Wipe Magic Inc., 

GelTech Labs Corporation, ATG Laboratories Corp, Dynomat Inc., Whale 

Tank Ventures, Inc., FireIce Gel, LLC, and Peter J Cordani Inc. (“Defendants’ 

Defaulted Companies”) for injunctive relief, damages to be decided post jury 

trial. 

2. The Defaulted Companies engaged in false advertising in violation of the 

Section 43(a) of the Lanham Act, 15 U.S.C. §1125(a), and unfair competition 

in violation of the Lanham Act 15 U.S.C. § 1125(a). 

3. The Defaulted Companies infringed on Plaintiffs’ trademarks and are guilty of 

trademark infringement in violation of the Lanham Act, 15 U.S.C. § 1114(1)(a). 

4. The Defaulted Companies misappropriated Plaintiffs’ trade secrets in violation 

of the Defend Trade Secrets Act, codified at 18 U.S.C. §§ 1836 and 1839 and 

Florida Uniform Trade Secrets Act, codified at §688.001, et seq., Fla. Stat. 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 17 of 46
 18

5. The Defaulted Companies engaged in unfair and deceptive practices in 

violation of the Florida Deceptive and Unfair Trade Practices Act Violation, §§ 

501.201-212, Fla. Stat. 

6. The Defaulted Companies violated Michael Reger’s exclusive rights as 

provided by 17 U.S.C. § 106 and are guilty of copyright violations. 

7. A foreign company may not transact business in this state until it obtains a 

certificate of authority from the department. F.S. 605.0902(1), 607.1503(1) 

8. ATG Laboratories, Inc., its officers, directors, employees or agents are 

prohibited from: 

A. Making or disseminating, or causing the making or dissemination of, the 

Defaulting Defendant’s false and misleading claims regarding its 

“FIRESTORM XT” 20 oz Aerosol or “SOIL MD” or related products; 

B. Promoting, selling, or otherwise making claims regarding any affiliation 

by ATG Laboratories or related parties’ products with any of the Plaintiffs’ 

products, including, but not limited to, the Plaintiffs’ FireIce® products and 

trademark or GelTech’s products or trademark; 

C. Making or disseminating or causing the making or dissemination of 

products or commercial advertising bearing the name “FIRESTORM”, 

“SOIL MD”, or GelTech” or any other mark similar to FIREICE, SOIL2O, 

and GELTECH SOLUTIONS; 

D. Using, disseminating, or disclosing Plaintiffs’ trade secrets to solicit 

customers and/or develop competing product(s) and/or otherwise use or 

disclose the identity of GelTech’s or Plaintiff’s customers, manufacturers, 

the proprietary formulas developed by the manufacturer for GelTech’s 

exclusive use or GelTech’s other trade secrets transferred to Michael Reger 

and licensed to MLR Holdings 2020, LLC. 

9. Product specification sheets (SDS) fall under the category of "commercial 

advertising.” See, e.g. Merck Eprova AG v. Gnosis S.p.A., No. 07 Civ. 5898 

(RJS), 2011 U.S. Dist. LEXIS 30683, 2011 WL 1142929, at *4 (S.D.N.Y. Mar. 

17, 2011). 

10. Whether Defendants should be prohibited from making false statements about 

David Jamison, Esquire, Dewight Cartwright in an attempt to impugn their 

integrity. 

 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 18 of 46
 19

(8) ISSUES OF LAW WHICH REMAIN FOR DETERMINATION BY 

THE COURT 

 

1. Whether Defendants are precluded from litigating claims raised or 

which could have been raised by Peter Cordani in the State Action 

against Plaintiffs, Case No. 502021CA007368XXXXMB which claims 

were “dismissed with prejudice” by the State Court by granting 

Summary Judgment in favor of Michael Reger and MLR Holdings 

2020, LLC. 

2. Whether Plaintiffs’ claim in the second amended complaint are barred 

since Defendants contend Plaintiffs impermissibly split their causes of 

action in this case by not bringing them as a permissive or compulsory 

counterclaim in the state case, pursuant to Defendants’ first affirmative 

defense. 

3. Whether (in addition to the State Court Judgments which have already 

adjudicated that all of GelTech’s intellectual property belong to Reger) 

Defendants’ newly raised claim that Peter Cordani owns FireIce and 

Soil20 and their formulas has been waived pursuant to Federal Rules of 

Civil Procedure, Rule 12 because this new defense was never asserted 

in any responsive pleading. 

4. Whether Defendants should be prohibited from playing to the jurors 

sympathy or emotions by discussing deaths in Cordani’s family years 

ago and by claiming to be the David to Reger’s Goliath or falsely 

alleging that Reger is a “billionaire’ or similarly make comments about 

his homes or possessions. 

5. Whether Defendants should be prohibited from claiming “tortious 

interference” similar claims regarding Reger legally enforcing his rights 

in these proceedings. 

6. Whether the individual Defendants used the Defaulted Companies as 

alter egos. 

7. Whether the individual Defendants are personally liable for the 

unlawful acts of their Defaulted Companies. 

8. Whether Plaintiffs have been damaged as a result of Defendants’ false 

advertising, unfair competition, copyright infringement, 

misappropriation of trade secret, trademark infringement, unfair and 

deceptive trade practices, and Peter Cordani’s breach of fiduciary duty 

and breach of employment agreement, if so how much. 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 19 of 46
 20

9. Whether Defendants should be enjoined from continuing their unlawful 

conduct. 

10. Whether the Plaintiffs can prove by the greater weight of the evidence 

that there was a Lanham Act violation by Defendants, as alleged in 

Count 1 of the Second Amended Complaint, and if, so, the damages, if 

any to Plaintiffs. 

11. Whether Plaintiffs can prove by the greater weight of the evidence that 

Defendants as alleged in counts 2 and 3 of the Second Amended 

Complaint engaged in Unfair Competition and Trademark 

Infringement, and if so, the damages, if any, of the Plaintiffs. 

12. Whether Plaintiffs can prove by the greater weight of the evidence as 

alleged in counts 4 and 5 of the Second Amended Complaint, if 

Defendants misappropriated trade secrets under Federal law and the 

Florida Uniform Trade Secrets Act, and if so, the damages if any of the 

Plaintiffs. 

13) Whether Plaintiffs can prove by the greater weight of the evidence 

whether as alleged in count 6 of the Second Amended Complaint if 

Defendant Peter J. Cordani breached a duty of loyalty owed to Plaintiffs, 

and if so, the damages if any of the Plaintiffs. 

14) Whether plaintiffs can prove by the greater weight of evidence as 

alleged in count 7 of the Second Amended Complaint Defendant Peter 

J. Cordani breached an employment agreement with plaintiffs, and if so, 

the damages if any of the Plaintiffs. 

15) Whether the Plaintiffs can prove by the greater weight of evidence as 

alleged in count 8 of the Second Amended Complaint whether 

Defendant committed a violation under the “FDUTPA” And if so, the 

damages if any of the Plaintiffs.

16) Whether Plaintiffs can prove by the greater weight of evidence as 

alleged in count 9 of the Second Amended Complaint Defendants 

committed Copyright Infringement , and if so, the damages if any of the 

Plaintiffs. 

17) The affirmative defenses alleged by Defendants in their answer and 

affirmative defenses to the Second Amended Complaint to include those 

set forth in paragraphs 322-324 of their answer (DE 141). 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 20 of 46
 21

(9) LIST OF TRIAL EXHIBITS

 Plaintiff’s Exhibits 

 See attached Schedule A. 

 Defendant’s Exhibits 

 See attached Schedule B. 

(10) LIST OF TRIAL WITNESSES

 Plaintiff’s Witnesses 

 See attached Schedule C. 

 Defendant’s Witnesses 

 See attached Schedule D. 

(11) ESTIMATED TRIAL TIME

The parties estimate the jury trial will take approximately 5 days. However, it is Plaintiff’s 

position that if Defendants are permitted to re-litigate claims raised unsuccessfully in the 

State Court Action a full two weeks may be necessary.

 (12) ESTIMATED ATTORNEY’S FEES 

 Plaintiff’s attorney fees are estimated at $600,000 through trial. 

Dated August 23, 2024. 

Respectfully submitted, 

/s/ Denise J. Bleau 

Denise J. Bleau, Esquire 

Florida Bar No. 599514 

TAYLOR ENGLISH DUMA LLP 

9314 Forest Hill Blvd, Suite 335 

Wellington, Florida 33411 

Telephone: (561) 765-6717 

Fax: (770) 434-7376 

Email: dbleau@taylorenglish.com 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 21 of 46
Page 1 of 17

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 

EXHIBIT LIST 

By stating specific objections to exhibits, the parties do not alleviate their responsibility to introduce and meet adm

respect to any exhibit. The parties may abbreviate objections as needed. The number in the “Exhibit Number” column 

identification label (e.g., P-1 or D-1).1

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-1 P-1 NOR-506541778-20210309 - patents P-2 P-2 NOR-900600711-20210309 - trademarks P-3 P-3 Patent and IP Assignment Geltech to RegerP-4 P-4 Settlement Agreement P-5 P-5 Trademark Assignment Geltech to RegerP-6 P-6 Memo Style P-7 P-7 Memo Style_RedactedP-8 P-8 US6315213(B1) P-9 P-9 US6440160(B1) 

1 The Plaintiffs’ exhibits must be marked numerically with the letter “P” as a prefix; the Defendants’ exhibits must be m

letter “D” as a prefix. 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 2 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-10 P-10 US7182778(B2) P-11 P-11 US7992647(B2) P-12 P-12 US8555991(B2) P-13 P-13 US8673651(B2) P-14 P-14 US8757280(B2) P-15 P-15 US8833476(B2) P-16 P-16 USD637357(S) P-17 P-17 USD649294(S) P-18 P-18 USD684662(S1) P-19 P-19 1403.083 U.S. Patent Application for Colorized Fire 

Extinguishing Compositions 

P-20 P-20 FW

_ Geltech issued patents 

P-21 P-21 Equine Dust Report 2013 P-22 P-22 GT

_

126

_

Soil2O

_

Hansen

_

Dam

_Report 

P-23 P-23 GT

_

184

_

Bahia

_

CS 

P-24 P-24 Soil2O-Saudi Research Report 21.08.2020 P-25 P-25 8k Settlement P-26 P-26 2018 Collection Agreement GelTech USDA P-27 P-27 Andrew Dercher Engineer Consent to hire P-28 P-28 Assignment-Contribution Geltech Assets to MLRP-29 P-29 Chase Assumption and Mutual Release-Reger and 

Chase Execution Copyt 

P-30 P-30 Chemical Testing Sulfur Dercher-Not 

Cordani

__

Redacted

P-31 P-31 Composite Sample Customer Requests-RedactedP-32 P-32 Corrosion P-33 P-33 Email to Cargill Agriculture 2016 P-34 P-34 EMFIDS P-35 P-35 FINALLY... New QPL listing for HVB-Fx P-36 P-36 Forest Service Bill For Collection P-37 P-37 Form-8 QPL Listing Press Release P-38 P-38 Mammal and fish toxicity testingP-39 P-39 Manufacturer Supply AgreementCase 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 3 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-40 P-40 Manufacturing patent P-41 P-41 Mike Reger-Slavin-Patent Pending FireIce -Cordani P-42 P-42 MiningP-43 P-43 Press Releases P-44 P-44 QPL June 2024 P-45 P-45 Remediation of Commercialized Patents P-46 P-46 SDS Comparison - P-47 P-47 Trade Secret Agreement GelTech _ Agronomics (1) P-48 P-48 Trigon emails re interest in MLR OrderP-49 P-49 UL-GelTech P-50 P-50 USDA Forest Service Interim Approval P-51 P-51 1st Amd Secured Note and Security Aug 13 2019 P-52 P-52 2nd Amd Secured Note and Security Aug 28 2019 P-53 P-53 3rd Amd Secured Note and Security Sept 27 2019 P-54 P-54 4th Amd Secured Note and Security Sept 27 2019 P-55 P-55 5th Amd Secured Note and Security Oct 11 2019 P-56 P-56 6th Amd Secured Note and Security Oct 18 2019 P-57 P-57 7th Amd Secured Note and Security Oct 25 2019 P-58 P-58 8th Amd Secured Note and Security Oct 30 2019 P-59 P-59 Secured Note June 18 2019 P-60 P-60 Security Agr June 15 2019 P-61 P-61 Sept 2012 Related Party Quest from RegerP-62 P-62 Copy of Year End 2018 Draft_MS Comments P-63 P-63 Email 2019 Michael Hull Option Recomendation 

Holiday Bonus 

P-64 P-64 Options and Holidays - Michael Hull -2018 Options P-65 P-65 Year End 2019 Draft P-66 P-66 Year End Bonus and Options P-67 P-67 8-K Conversion 2.5M P-68 P-68 8k Reger Resignation P-69 P-69 10-K emails December 31 2018 P-70 P-70 10-K Post Conversion P-71 P-71 10-Q September 30 2019 Last 10Q GLTC 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 4 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-72 P-72 2019-06-18 8K re new note P-73 P-73 2020-01-07 Peter letter to RegerP-74 P-74 Board Call Agenda and Materials - Sept 4 2019 P-75 P-75 Brian Bernstein-Email ConversionP-76 P-76 Certifications by PeterP-77 P-77 Composite - Quarterly Report Report June 30 2018 P-78 P-78 Composite Comparison Revenue 3M P-79 P-79 Composite-8-K MR Advances on MR 500K plus 

Loan 

P-80 P-80 Consent to Convert

_

P-81 P-81 December 2019 Financial Statements P-82 P-82 December Financial 2019 Statements - Michael Hull 

- 

P-83 P-83 Email and December 2019 Financial Statements P-84 P-84 Email and December Financial Statements P-85 P-85 Email December Financial Statements 2019 Michael 

Hull - Outlook

P-86 P-86 Email re right person P-87 P-87 Emails re underwriterP-88 P-88 Form 4 MR 2.5 Million ConversionP-89 P-89 FW_ Board Meeting October Financials and 

September Board Call Minutes - Michael Hull - Outlook

P-90 P-90 GelTech Solutions, Inc. Form 8-K Current Report 

Filed 2020-01-28 

P-91 P-91 GLTC Consent 104K Final MR Loan P-92 P-92 Hull's Spreadsheet P-93 P-93 Payroll Deferral - Michael Hull - O P-94 P-94 Peter's Proposed License AgrP-95 P-95 Post Conversion Quarterly Report June 30 2018 P-96 P-96 Post Resignation communications w BoardP-97 P-97 Post Resignation communications w Board-2 P-98 P-98 Re Mike as ceo P-99 P-99 SC 13D

_

A Michael Reger Updated

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 5 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-100 P-100 Security Agreement with UCC-1 P-101 P-101 2-2019 Audit Committee Questionnaire P-102 P-102 3-2019 Auditor letterP-103 P-103 Audit Committee CharterP-104 P-104 Composite-GelTech - 12-31-18 Audit - ACL audit 

committee 

P-105 P-105 ResignationP-106 P-106 2020-ATG-SoilMD-DustControl-SDS P-107 P-107 2020-ATG-SoilMD-Topical-SDS P-108 P-108 2020-ATG-Topical-Brochure-11x17-TOPRINT P-109 P-109 2020-FireStorm-WeldShield-SDS P-110 P-110 2020-FireStormXT-SDS P-111 P-111 2020-idigify-ATG-FireStorm-Brochure-11x17-

TOPRINT 

P-112 P-112 2020-idigify-ATG-FireStorm-Weld-Brochure11x17-TOPRINT P-113 P-113 2020-idigify-ATG-Soil-DustControlBrochure11x17-TOPRINT P-114 P-114 2020-idigify-ATG-Soil-Granular-Brochure-11x17-

TOPRINT 

P-115 P-115 ATG Lab Corp-Website US Forestry TestedP-116 P-116 ATG-Labs.com - About P-117 P-117 ATG-Labs.com - Contact P-118 P-118 ATG-Labs.com - Home Page - 1 P-119 P-119 ATG-Labs.com - Home Page - 2 P-120 P-120 ATG-Labs.com - Industries - Agriculture P-121 P-121 ATG-Labs.com - Industries - Construction - 1 P-122 P-122 ATG-Labs.com - Industries - Construction - 2 P-123 P-123 ATG-Labs.com - Industries - Firefighting - 1 P-124 P-124 ATG-Labs.com - Industries - Firefighting - 2 P-125 P-125 ATG-Labs.com - Industries - Industrial - 1 P-126 P-126 ATG-Labs.com - Industries - Industrial - 2 P-127 P-127 ATG-Labs.com - Industries 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 6 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-128 P-128 ATG-Labs.com - News & Media - 1 P-129 P-129 ATG-Labs.com - News & Media - 2 P-130 P-130 ATG-Labs.com - News & Media - 3 P-131 P-131 ATG-Labs.com - News & Media - 4 P-132 P-132 ATG-Labs.com - News & Media - 5 P-133 P-133 ATG-Labs.com - News & Media - 6 P-134 P-134 ATG-Labs.com - Products - Firestorm - 1 P-135 P-135 ATG-Labs.com - Products - Firestorm - 2 P-136 P-136 ATG-Labs.com - Products - Logans Magic - 1 P-137 P-137 ATG-Labs.com - Products - Logans Magic - 2 P-138 P-138 ATG-Labs.com - Products - Soil MD - 1 P-139 P-139 ATG-Labs.com - Products - Soil MD – 2 P-140 P-140 ATG-Labs.com - Products Page P-141 P-141 Ex 14-Brent NDA P-142 P-142 Exhibit 42-IMG

_

1408 

P-143 P-143 Exhibit 43-2019 FireIceXT Promo Launch P-144 P-144 Hutson web pageP-145 P-145 Exhibit 002 Summers P-146 P-146 Exhibit 003 Summers P-147 P-147 Exhibit 004 Summers P-148 P-148 Exhibit 005 Summers P-149 P-149 Exhibit 008 Summers P-150 P-150 Exhibit 009 Summers P-151 P-151 Exhibit 010 Summers P-152 P-152 Exhibit 012 Summers P-153 P-153 2017 QPL and email P-154 P-154 Agriculture, Turf & Timber _ Soil2O P-155 P-155 Amec Foster Wheeler Solves Dust Problem P-156 P-156 Dust DefendP-157 P-157 FireIce Advertisement P-158 P-158 FireIce Shield Gel SDS - Peter Cordani - Paul 

Chrisle Email 

P-159 P-159 FireIce Shield SDS Paul to Peter (1) 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 7 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-160 P-160 FireIce Shield SDS Paul to PeterP-161 P-161 Guardian Christle emails P-162 P-162 Homeowner & Consumer 

_

 Soil2O 

P-163 P-163 Mining Download White Paper- Dust DefenderP-164 P-164 QPL MSDS Testing and ListingP-165 P-165 RE Aerosol Gel (FireIce) P-166 P-166 RE

_

 soil2o sell sheet - Paul Christle - 2 

P-167 P-167 RE

_

 soil2o sell sheet - Paul Christle - Outlook

P-168 P-168 Soil2O-SellSheet-29.7.2019-Final-Web P-169 P-169 Soil20 Sodding and Seeding and Pre-Planting 

Compare Soil20 

P-170 P-170 Soil20 website P-171 P-171 Soil20 website2 P-172 P-172 Soil20 website3 P-173 P-173 Sunniland MLR Order documents P-174 P-174 Dynotech Pitch Decks to SunnilandP-175 P-175 Dyntech extinguisherP-176 P-176 Dyntech pail P-177 P-177 Dyntech Price List P-178 P-178 Fire Shield product P-179 P-179 Thermal coat P-180 P-180 Bruce requesting info re golf course testingP-181 P-181 Dupe w Shenk-June 8, 2023 email P-182 P-182 Email re Zoom meeting with attorneys Shenk and 

Miller-4 

P-183 P-183 Emails re issues with Shenk Miller deal P-184 P-184 Gleason Testimonial sent to Shenk-MillerP-185 P-185 Peter's 2nd cease and desist to Bruce P-186 P-186 Request for UL, Forest cert etc P-187 P-187 Selz email to Bruce P-188 P-188 Shamrock Filling LLC P-189 P-189 SNF cease and desist email P-190 P-190 Stone email re Shenk and Miller

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 8 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-191 P-191 Stone email re SoilMD FAQ P-192 P-192 UL Invoice email P-193 P-193 Screenshot

_

2024-01-19-12-28-27 

P-194 P -194IMG

_1211[40] 

P-195 P-195 IMG

_

1215 

P-196 P-196 IMG

_

1259 

P-197 P-197 IMG

_

1260 

P-198 P-198 IMG

_

1265 

P-199 P-199 IMG

_

1267 

P-200 P-200 IMG

_

1268 

P-201 P-201 IMG

_

1269 

P-202 P-202 IMG

_

1287 

P-203 P-203 IMG

_

1290 

P-204 P-204 IMG

_

1375 

P-205 P-205 IMG

_

1380 

P-206 P-206 IMG

_

1383 

P-207 P-207 IMG

_

1618 

P-208 P-208 IMG

_

1679 

P-209 P-209 IMG

_

5204 

P-210 P-210 IMG

_

5205 

P-211 P-211 IMG

_

5206 

P-212 P-212 IMG

_

5207 

P-213 P-213 Investor Letter

_

P-214 P-214 June 8, 2023 email P-215 P-215 Letter to Mark 8.9 P-216 P-216 Shenk-Miller Texts to PeterP-217 P-217 Text re investment P-218 P-218 Warehouse P-219 P-219 ATG Laboratories Corp P-220 P-220 Detail by Registered Agent Name P-221 P-221 Division of Corporations - DynTech P-222 P-222 Dyn-O-Mat Inc P-223 P-223 Dynomat, Inc 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 9 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-224 P-224 FireIce Gel, Inc. P-225 P-225 GELTECH LABS CORPORATION P-226 P-226 LOGAN'S EXCLUSIVES, LLC P-227 P-227 PETER J. CORDANI, INC. P-228 P-228 Whale Tank Productions Corp DE P-229 P-229 Whale Tank Ventures Inc DE P-230 P-230 Whale Tank Ventures LLC P-231 P-231 Whale tank Ventures, Inc. P-232 P-232 PC Rogs March 7, 2024 P-233 P-233 PC Rogs March 19, 2024 P-234 P-234 PC Rogs March 19, 2024 P-235 P-235 PC Rogs March 26, 2024 P-236 P-236 PC Rogs March 27, 2024 P-237 P-237 Email GLTC - Important - 10-15 Board Call 

Tomorrow-1 

P-238 P-238 Email re $104K more from RegerP-239 P-239 Email re GelTech - CEO (2) P-240 P-240 Email re GelTech - CEO (3) P-241 P-241 Email re GLTC - Trading Stock-2 P-242 P-242 Email re Important (10) P-243 P-243 Email re Important (11) P-244 P-244 Email re Important (12) P-245 P-245 Email re Important (13) P-246 P-246 Email re Important (14) P-247 P-247 Email re Important (15) P-248 P-248 Email re Important (16) P-249 P-249 Email re Important (17) P-250 P-250 Email re Important (18) P-251 P-251 Email re Important (19) P-252 P-252 Email re votes re cash payments P-253 P-253 Emails re D&O policyP-254 P-254 04-15-2021 Int PO 1136 GuardianP-255 P-255 05-22-2020 Int PO 1114 Guardian Aerosol Cans 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 10 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-256 P-256 All Things Gel Lease P-257 P-257 ATG assignment to PeterP-258 P-258 ATG assignment to Peter-2 P-259 P-259 ATG Invoice 5-21 P-260 P-260 ATG reinstatement P-261 P-261 Bank Statement w Watler wire P-262 P-262 Binding Agreement-Miller ShenkP-263 P-263 Composite exh of income P-264 P-264 Composite January 31 emails P-265 P-265 Cordani acceptance of UL testing quote P-266 P-266 Cordani Cumulative Assignment P-267 P-267 Customer requesting Forest Certification etc P-268 P-268 Defendant's Production Pages 49-85 (37 pages) P-269 P-269 Dynotech Laboratories Lease P-270 P-270 Dyntech NDA. P-271 P-271 EJ Metals P-272 P-272 Email re Austrailia P-273 P-273 Email re FireIceXT P-274 P-274 Email re possible testingP-275 P-275 FireIce Wet SDS-Sent to Peter Cordani own 

Account 

P-276 P-276 General

_

Training (1) 

P-277 P-277 General

_

Training (2) 

P-278 P-278 Greg Johnson text P-279 P-279 Iberia Bank email P-280 P-280 IMG

_1408 (02787265xBE13C) 

P-281 P-281 IMG

_

1540 

P-282 P-282 IMG

_

5238 

P283 P283 Logan's Tik Toc video P-284 P-284 Maryland Fire and Rescue Institute NDA P-285 P-285 Michael HULL Cash Payment AP and Cash 1-29-

2020 

P-286 P-286 NDA ATG Guardian 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 11 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-287 P-287 Peter assignment to GelTech P-288 P-288 Peter Cordani-Email to Personal Email-David Smith 

Sunbelt 

P-289 P-289 Peter's $$ P-290 P-290 Pic Posters on the wall P-291 P-291 pitch deck draft to Peter - tested up to 5000 degrees P-292 P-292 Pitch re extinguisher sent to PeterP-293 P-293 plastic battery box P-294 P-294 PROPOSAL AND SCOPE OF WORK for testing 

Logan'sP-295 P-295 Screen capture of video_

P-296 P-296 SNF cease and desist email P-297 P-297 Sunniland Composite Exhibit P-298 P-298 UL equ testing Logan's MagicP-299 P-299 UL equ testing Logan's Magic-results P-300 P-300 UL Testing Invoice P-301 P-301 UL testing Quote Logan's Magic P-302 P-302 UL testingP-303 P-303 Mark Daniels' Discovery Responses srvd 3-8-24 P-304 P-304 Mark Daniels' Discovery Responses srvd 3-19-24 P-305 P-305 Mark Daniels' Discovery Responses srvd 3-27-24 P-306 P-306 Mark Daniels' Discovery Responses srvd 4-22-24 P-307 P-307 Screenshot

_

20230502

_

230245

_

Messages 

P-308 P-308 Whale Tank Productions Corp P-309 P-309 Whale Tank Ventures Inc P-310 P-310 Whale Tank Ventures LLC P-311 P-311 47836 2020-ATG-SoilMD-Granular-SDS

_

B 

P-312 P-312 47836 2020-ATG-SoilMD-Topical-SDS_B P-313 P-313 47836 2020-FireStorm-WeldShield-SDS

_

B 

P-314 P-314 47836 2020-idigify-ATG-FireStorm-Brochure11x17-TOPRINT

_

B 

P-315 P-315 47836 2020-idigify-ATG-SoilDustControlBrochure-11x17-TOPRINT

_

B 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 12 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-316 P-316 Invoice

_

47836 

P-317 P-317 47836 FIRESTONE WELD SHIELDL

_

BACK

P-318 P-318 47836 FIRESTONE WELD SHIELDL

_

FRONT 

P-319 P-319 47836 FIRESTONE

_

BACK

P-320 P-320 47836 FIRESTONE

_

FRONT 

P-321 P-321 47836 soil dust control BACKP-322 P-322 47836 soil dust control FRONT P-323 P-323 47836 soil GRANULAR

_

BACK

P-324 P-324 47836 soil GRANULAR

_

FRONT 

P-325 P-325 47836 soil TROPICAL

_

BACK

P-326 P-326 47836 soil TROPICAL

_

FRONT 

P-327 P-327 Invoice

_

49142 

P-328 P-328 50357 Soil MD Granular_Front Label - Green_6_25 

X 7

_

75 Inches 

P-329 P-329 50357 Soil MD Topical_Front Label - Silver_6_5 X 

5 Inches 

P-330 P-330 Invoice

_

50357 

P-331 P-331 51631 decal 6x4

_

lucas oil logo_1UP_PF 

P-332 P-332 51631 decal 6x4

_

lucas oil logo_2UP 

P-333 P-333 Invoice

_

51631 

P-334 P-334 52078 Peter Cordiani Soil MD_Brochure_1_PF_10 

pgs 

P-335 P-335 Invoice

_

52078 

P-336 P-336 52092 Logan Decal_1UP_PF P-337 P-337 Invoice

_

52092 

P-338 P-338 55168 FireFighter XT_XS EXTINGUISHER3

_

5x4

_

5-1 Flattened

P-339 P-339 Invoice

_

55168-Note 

P-340 P-340 AlphaGraphics Invoice April 2022 P-341 P-341 DYNOMAT - FIREFIGHTER LOGO FILE PDF5 P-342 P-342 Fwd New logos and art P-343 P-343 Graphic changes DYNOMAT and FireFighter logo 

art 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 13 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-344 P-344 Krebbs email of AlphaGraphics of the Palm 

BeachesP-345 P-345 Mark-Krebbs email 

P-346 P-346 Peter Cordani- amended art graphic FireFighterP-347 P-347 Stress Relief Pillow CardP-348 P-348 3-23-19 - Audit email P-349 P-349 3-25-19 - Audit email P-350 P-350 3-26-19 - Audit email P-351 P-351 3-26-19 2- Audit email P-352 P-352 3-28-19 - Audit email P-353 P-353 3-28-19 2- Audit email P-354 P-354 December 31, 2016 Independent Auditor Report P-355 P-355 December 31, 2017 Independent Auditor Report P-356 P-356 December 31, 2018 Independent Auditor Report P-357 P-357 June 30 2008 Independent Auditor Report 10-KP-358 P-358 June 30 2009 Independent Auditor Report P-359 P-359 June 30 2010 Independent Auditor Report 10KP-360 P-360 June 30 2011-Independent Accountant Report 10-KP-361 P-361 June 30 2012 Independent Accountants Report P-362 P-362 June 30 2013 Independent Accounting Report 10-KP-363 P-363 June 30 2014 Independent Accounting Report 10-KP-364 P-364 June 30 2015 Independent Auditor Report 10KP-365 P-365 2013-1 8-k Mike reger stock for loand due and 

interest 

P-366 P-366 2013-2 8-K 1 M Note Mike RegerP-367 P-367 2015 8-K more interest paid by stockP-368 P-368 2016 -1 8-K Interest Mike Reger Loan paid by 

Common Stock

P-369 P-369 2016 -2 8-K Amending 5M Credit line-Note balance 

at date 

P-370 P-370 2018 8-K Conversion 2.5M with balance of 4.4M P-371 P-371 2019-6-5-Consent Mike Reger 75 K Purchase P-372 P-372 2019-6-8-K 500k Loan Mike Reger doc 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 14 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-373 P-373 2019-6-11-Consent Mike Reger 500K Loan Security 

Agreement 

P-374 P-374 2019-10-11 8K re 100 Loan from Mike P-375 P-375 2019-11-1 8K re 75K loan P-376 P-376 2019-11-15 8K 120KP-377 P-377 2019-11-27 8K 150KP-378 P-378 Excerpts 7.23.19 email P-379 P-379 Secured Promissory Note 500 8-KP-380 P-380 2nd Quarter Consents and BOD Minutes P-381 P-381 8-11-10 email and two attachments P-382 P-382 2008 10-KP-383 P-383 Comments EQR 10-Q-August 2019 P-384 P-384 Comments EQR Last 10-Q-June 2018 P-385 P-385 Composite Salberg Documents P-386 P-386 Debt roll forward-ever sent to Scott P-387 P-387 Email and comment to FS-10Q Sept 2019 P-388 P-388 Excerpts-Sample Consents - to Salberg Email P-389 P-389 Michael Reger Questionnaires_- Composite P-390 P-390 No other related party interests-2018-Composite P-391 P-391 Peter Cordani Questionnaires From AuditorComposite P-392 P-392 SALBERG – GELTECH SOLUTIONS – 

003621

_

Redacted

P-393 P-393 Salberg Documents batch 1 0f 2 P-394 P-394 Doug Watler Signed - Dyntech Labs Subscription 

Agreement 6.20.23 

P- 395 P- 395 Text re investment P-396 P-396 11-775,512

_Complete Original Application 

P-397 P-397 About GelTech (16Nov2016) P-398 P-398 Division of Corporations - Filing Geltech 2 P-399 P-399 Division of Corporations - FilingP-400 P-400 FORM SB-2 P-401 P-401 FORM SB-2 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 15 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-402 P-402 GelTech FL merger into GelTech DE P-403 P-403 Michael Harris-Incorporator of GelTech DE P-404 P-404 2015-05-21 signed Amnd 1 P-405 P-405 2015-05-21 signed Amnd 2 P-406 P-406 Peter Cordani Employment March 10, 2011-

Paragraph 11 

P-407 P-407 Peter's 2012-10-01 Original employment agreement P-408 P-408 2011-09-30-GLTC 10-Q P-409 P-409 2019-09-30 10Q P-410 P-410 2019-09-30 8KP-411 P-411 2020-01-28 8K re Mike ResigningP-412 P-412 2020-01-31 8K re settlement and resignations of 

BOD 

P-413 P-413 2020-02-06-GelTech Solutions Filing Articles Feb 

2020 

P-414 P-414 2021.04.29 UCC filingP-415 P-415 Annual Report 10K for 2018 P-416 P-416 Bernstein and Peter emails re Jan 28 w attached 8KP-417 P-417 Brian Bernstein Email-Cordani-Directors-Neil's 

Resignation is Accepted

P-418 P-418 Consents 2.5M Brian and Mike P-419 P-419 Email Brian Bernstein Consent w attachments P-420 P-420 Email Brian Bernstein Consent P-421 P-421 Form 4 Cordani Sales

_

P-422 P- 422 Ck. Check to Brent 8.7.20 P-423 P-423 Stmt. Bank Statement August 2020 P-424 P-424 Sig card. Signature Card for new business account 

8.6.20 

P-425 P-425 Wd. Withdrawal from TD Bank 8.14.20 P-426 P-426 Deposits P-427 P-427 Bank Statement w Watler wire -June 2023 P-428 P-428 December Peter J Cordani statement – Dec 2022 P-429 P-429 Diane Reeves Loan 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 16 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-430 P-430 Dynomat Corp Resolution 12.01.23 P-431 P-431 Dynomat Deposits 12.01.23 P-432 P-432 Dynomat Jan - Feb 2024 Stmt-RedactedP-433 P-433 Dynomat March check -3.8.24 P-434 P-434 Dynomat New Bank Account Opening_RedactedP-435 P-435 Dynomat Wires P-436 P-436 Dynotech account #1-Sig Card 12.16.21 P-437 P-437 Dynotech account #2-Checks – 10.12.22 & 3.10.23 P-438 P-438 Dynotech account #2-Dep – Oct & Nov 2022 P-439 P-439Dynotech account #2-Sig Card – 9.12.22 P-440 P-440 Dynotech account #2-Wd – Nov 2022 P-441 P-441 Dynotech Deposits – Dec 2021 – March 2022 P-442 P-442 Dyntech Sig Card_4 – 3.10.23 P-443 P-443 Dyntech Statements #2 – July 2023 P-444 P-444 Dyntech Statements – March 2023 P-445 P-445 Dyntech-Ck_2 March 2023 P-446 P-446 Dyntech-Dep – Jan 2023 – March 2023 P-447 P-447 Jan 2022 Dynotech Stmt - P-448 P-448 Jan Dynotech wdP-449 P-449 January Smt Dynomat P-450 P-450 June Dyntech checks P-451 P-451 Logan Cordani stmt – Oct 2022 P-452 P-452 Logan Cordani-Dep – Oct 2022 – March 2023 P-453 P-453 Logan Cordani-Sig Card – 10.19.22 P-454 P-454 2020-03 - Request for GelTech formulaP-455 P-455 2020-03-18 Whaletank Order of GelTech SAP P-456 P-456 2020-08-31 Order - ATG P-457 P-457 2020-10-27-Order – Zappa Stewart P-458 P-458 2020-10-28 order-Feb 2021 delivery – FireStorm XT P-459 P-459 2021-03-25 ATG Labs Order – FireStorm XT P-460 P-460 2021-09-21 order - FireStorm P-461 P-461 2023-02-03 Order – Zappa Stewart P-462 P-462 2023-03-08-Order – Zappa Stewart 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
Page 17 of 17

Exhibit 

Number 

Description Bates Range / 

Other Source 

Objections and Reasons 

P-463 P-463 2023-03-08-Order= Zappa Stewart P-464 P-464 2023-03-21 All Things Gel – Zappa Stewart P-465 P-465 2023-03-21-Order – Zappa Stewart P-466 P-466 2023-05-01-Order – Zappa Stewart P-467 P-467 FireStorm XT Power Point P-468 P-468 FireStorm XT Brochure P-469 P-469 FireStorm XT Composite Emails P-470 P-470 SDS - FireStorm XT Aerosol SprayP-471 P-471 SDS - FireStorm XT Powder P-472 P-472 SDS - FireStorm XT Weld ShieldP-473 P-473 Covanta Composite Documents P-474 P-474 Email and Invoice ATG to Greg Johnson's GelTech 

Email 

P-475 P-475 Email from Johnson with PO attached-1 P-476 P-476 Email from Johnson with PO attached-2 P-477 P-477 Email Guardian to Greg Johnson's email NDA P-478 P-478 Purchase Order Aerosol-Guardian Protective 

Services-corrected 10-20 

P-479 P-479 Purchase

_

Order

_

501

_

from

_

GelTech

_Solutions (1) 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 
1

SCHEDULE B

DEFENDANTS’, PETER J. CORDANI, LOGAN CORDANI and MARK DANIELS

EXHIBIT LIST

Exhibit No. Description Bates Range/Other Source Objections and Reasons 

D1 Pictures, dated 06/26/02, Peter Cordani torch on hand gel/fire and tire fire demo ( 2 pages )

D2 Gmail account Peter Cordani (pcordani1961@gmail.com) dated Oct 12, 2017

D3 Police Report-Jupiter PD, dated 10/16/2017, Report 17-052011 ( 9 pages )

D4 Police Report-Jupiter PD, dated 03/02/20, Report 20-063118 ( 2 pages )

D5 Denise Bleau, email dated Jun 12, 2024, notice patent Mr. Reger filed, published Sep. 16, 2021, US 2021/0283448 A1

D6 Police Report-Jupiter PD, dated 06/17/24, Report 24-156762 ( 2 pages)

D7 Anne Cordani, Affidavit dated February 17, 2020

D8 Text communications (Group MMS, Peter Cordani, Michael Reger, Dan Simon) “we don’t need luck we have Peter”

D9 Daniel Simon, Affidavit dated February 18, 2020

D10 Dan Simon, email dated February 23, 2017, to Peter Cordani, discussion “...Mike was doing illegal things...”

D11 Dan Simon, text ( 2 pages ) to Peter Cordani, “...Reger offered them the utility end of Fire Ice for 7 million...”

D12 USB DRIVE, various videos and media regarding Peter Cordani 

D13 Michael Reger letter, Dec 20, 2019 to Geltech Team Members, “We look forward to 2020 being the breakout year...”

D14 Peter Cordani text to Brian Bernstein, concerning board meeting about Michael Reger, loans and Geltech asset matters

D15 Brian Bernstein email dated January 28, 2020, to Geltech board, about selling Geltech entity as public vehicle

D16 Greg Johnson, forwarded to Peter Cordani and Bruce Stone, communication to Michael Reger, dated 2/22/20

D17 Brian Bernstein, communication dated Jan 31, 2020, regarding resignation of Neil Reger from Geltech 

D18 Geltech Minutes, Michael Reger, May 15, 2017 “...Mr. Reger had agreed to accept stock in lieu of cash payments...”

D19 Phillip D. O’Connell, Affidavit Jan 6, 2023, (7pages) “...I have not received a written copy of the settlement proposal...”

D20 Communications with Phil O’Connell, dated FY2017, Anne Cordani, concerning Geltech/Reger fraud matters

D21 Tony Tricarico, communications, January 31, 2020 to Michael Reger/Matt Struzziero (4 pages)

D22 Brian Bernstein, communications and establishment of Whale Tank Ventures (56 pages)

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 39 of 46
2

D23 Geltech / Mosler / Klacker documents filed, transfer of assets to Michael Reger (28 pages)

D24 FireIce Solutions/Gerry Kennedy communications AVM (Michael Reger / Warren Mosler / Rob Printz) (54 pages)

D25 Neil Reger stock sale (9 pages)

D26 Matt Struzziero, ECOTECH Fire Solutions formation 2020-02-06 in Colorado (26 pages)

D27 Geltech 2019 press releases and information about success announcements (152 pages)

D28 Michael Hull, Paul Crystal, David Jamison, communications, password changes, tampering with emails (73 pages)

D29 Logan’s Wipe Magic, documents, filings, pictures, labeling, information, tests and ratings (337 pages)

D30 Geltech closing, Affidavit of Marc Thibault, documents, pictures of facility,matters relating to Dave Jamison (55 pages)

D31 Michael Reger, Affidavit and communications, documents (260 pages)

D32 Peter Cordani, letter from attorney Scott Wagner,February 16, 2017, concerns Michael Reger / Geltech fraud (10pages)

D33 Dan Simon, email communications concerning Michael Reger taking the company private (2pages)

D34 Michael Matte, final judgment in favor of Peter Cordani (6 pages)

D35 Geltech / Michael Hull, filings, communications, emails, documents (switched pages in employment docs) (218 pages)

D36 Geltech / communications Peter Cordani, Michael Reger / Michael Hull, Lawrence Reger, signature fraud (207pages)

D37 Geltech filings and relative communications with board (83 pages)

D38 Geltech / Cordani, communications with Dave Jamison, Phil O’Connell, employment agreement (92 pages)

D39 Shenk and Miller (Hydroscience) documents and communications (32 pages)

D40 SNF / Michael Veldez communications, letter to ATG as source supplier of product and data information (30 pages)

D41 Peter Cordani / Dynomat engineering patent designs, Dyno-Gel FY2004, sprinker and extinguisher systems (38 pages)

D42 Geltech SEC filings, Dave Hopkins lawsuit/settlement , Jerome Eisenberg lawsuit for $25 million (107 pages)

D43 Dyntech subscription agreement, original draft sent with disclosure of lawsuit (sec 3.5) 

D44 Neil Reger-profit sharing Keogh et al ( Bernard Madoff ) matter, bankruptcy court

D45 Bruce Stone, communications, testing, photos, reports, documents (264 pages)

D46 Michael Hull-Peter Cordani, email communication Aug 20, 2017, about conflicting documents-employment agreement 

D47 Dewight Cartwright, Kathi Allen, documents, police reports, communications (229 pages)

D48 Peter Cordani, patent list schedule 3/23/2018 from McHale-Slavin, Patent attorneys (14 pages)

D49 Peter Cordani emails, communications regarding David Jamison / Ross DiMaggio, subject Geltech closing (16 pages)

D50 Amended Counter-claim in State court action between Peter Cordani and Michael Reger and MLR Holdings 2020

D51 Geltech SEC 8K filing without attachment of alleged settlement agreement

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 40 of 46
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 

 Evidentiary 

 X Trial 

 Other 

WITNESS LIST 

 X Plaintiffs Defendant 

Name Subject and Brief 

Description of Testimony 

Date(s) Testified 

(Court Only) 

1. 

Michael L. Reger Plaintiff who will testify 

regarding the claims in the 

Second Amended Complaint 

including damages and will 

address the false claims raised 

by Defendants. 

2. 

Michael Becker CPA and former Fire Chief 

who will testify regarding the 

importances of certifications 

and will address the false claims

raised by Defendants. 

3. 

Brent Hutson Website and graphics designer 

who worked for GelTech and 

was involved in creating 

advertising for Defendants and 

will address the false claims 

raised by Defendants. 

4. 

Thomas Summers Employed by Defendants and 

has knowledge of copyright 

violations and false advertising 

and will address the false claims

raised by Defendants. 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 41 of 46
5. 

Paul Christle Employed by GelTech and will 

testify about the creation of 

GelTech’s copyrighted 

materials, SDS, GelTech’s 

website, GelTech’s testing and 

will address the false claims 

raised by Defendants. 

8. 

Bruce Stone This witness worked with 

Defendants and will testify 

about their use of GelTech’s 

confidential and proprietary 

information, their 

misrepresentations to potential 

customers and investors, their 

defrauding Doug Watler out of 

$50K, their use of various sham 

companies to hide their 

scheme, Mark Daniels intimate 

involvement in Defendants’ 

activities, the overall activities 

of Defendants and he will 

address the false claims raised 

by Defendants. 

9. 

Jason Macki Defendants marketed to this 

witness who will testify about 

the false statements made and 

their use of FireIce relabeled as 

FireStorm. 

10. Geoffrey Shenk This witness will testify about 

his involvement with Peter 

Cordani and Mark Daniels, 

their false representations 

regarding ownership rights, 

certifications, the importances 

of certifications, Defendants’ 

misrepresentations regarding 

their intellectual property and 

value, relabeling of products, 

defrauding Doug Watler out of 

$50K, Defendants’ usurpation 

of Plaintiffs’ business 

opportunities, Defendants’ use 

of various sham companies to 

hide their scheme, Defendants’ 

use of GelTech’s assets, Mark 

Daniels intimate involvement 

in Defendants’ activities, the 

overall activities of 

Defendants, and will address 

the false claims raised by 

Defendants. 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 42 of 46
11. Tom Tremblay Trigon General Manager 

former customer of GelTech 

and later customer of 

Defendants. 

12. AlphaGraphics Graphic designer company 

used by Defendants to create 

additional false advertising and 

further violate Plaintiffs’ 

copyright. 

14. Doug Watler/The Watler Living 

Trust 

This witness will testify about 

being defrauded by Defendants 

into “investing” in Dyntech and

their refusal to refund the funds.

15. Michael Donohoe Former FBI and current private 

investigator involved in 

background checks and capture 

of various website information. 

16. Mark Daniels Defendant 

17. Peter Cordani Defendant 

18. Logan Cordani Defendant 

19. ATG Laboratories Corp Defaulted Company. 

Testimony from this Defendant 

will be through Peter Cordani 

or Mark Daniels 

20. All Things Gel, LLC Defaulted Company. 

Testimony from this Defendant 

will be through Peter Cordani 

or Mark Daniels 

21. Dyntech Laboratories, Inc. Defaulted Company. 

Testimony from this Defendant 

will be through Peter Cordani 

or Mark Daniels 

22. Dynotech Laboratories Corp. Defaulted Company. 

Testimony from this Defendant 

will be through Peter Cordani 

or Mark Daniels 

23. Dynomat Laboratories Corp. Defaulted Company. 

Testimony from this Defendant 

will be through Peter Cordani 

or Mark Daniels 

24. MLR Holdings 2020, LLC Testimony from this Plaintiff 

will be through Michael Reger. 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 43 of 46
The following witnesses will 

only be necessary if Peter 

Cordani is permitted to relitigate the claims raised and lost

in the State Case. 

 

6 

Michael Harris If needed, he will testify about 

Dynomat, the formation and 

evolution of GelTech, the 

transfer of intellectual property 

to GelTech, and will address 

the false claims raised by 

Defendants. 

7. 

Brian Bernstein If needed, he will testify about 

GelTech’s operations, Peter 

Cordani’s involvement in the 

company, Michael Reger’s 

loans, conversions, share 

purchases, $7 MM debt, 

assignment of assets to Reger 

and cancellation of debt, and 

will address the false claims 

raised by Defendants. 

13. Salberg & Company, P.A If needed, GelTech’s 

independent auditors for many 

years have intimate knowledge 

of GelTech’s procedures, 

Reger’s loans, GelTech’s 

related party questionnaires, 

and will address the false claims

raised by Defendants. 

Michael Becker If needed, Mr. Becker will 

testify about his time on the 

GelTech Board and as Chair of 

the Audit Committee and will 

address the false claims raised 

by Defendants. 

 

Witness via Deposition 

25. Peter Cordani 

26. Dewight Cartwright 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 44 of 46
27. James Andrew Lynch 

Records Custodian through 

Declaration 

 

 

28. Chase Corporation Business Records 

29. Covanta Plymouth Renewable 

Energy nka Reworld Plymouth 

Business Records 

30. Guardian Protective Services Business Records 

31. Sunbelt Business Records 

32. TD Bank Business Records 

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 45 of 46
1

SCHEDULE D

DEFENDANTS’, PETER J. CORDANI, LOGAN CORDANI and MARK DANIELS

WITNESS LIST

 Name Subject and brief description of testimony

1. MICHAEL SLAVIN Patent and Trademark matters

2. MICHAEL REGER Plaintiff and former CEO of Geltech, financial and daily operations

3. TONY TRICARICO Employee of Geltech, business and fireice matters

4. ANNE CORDANI Employee of Geltech, mother of Peter Cordani, daily operations

5. DAN SIMON Employee of Geltech, accounts and daily operations

6. KEVIN SPANE Employee of Geltech, daily operations and technical matters

7. MARIAN L. HOLLAND Denise Bleau’s partner-wife

8. CHAD J. STOFFEL Lives at Denise Beau/Marian L. Holland residence

9. LISA CORDANI BUSCHER Former wife of Peter Cordani, character of Peter Cordani

10. NEIL REGER Board of Director of Geltech, company operations

11. LAWRENCE REGER Employee and attorney of Geltech, company matters

12. WARREN MOZLER Investor and President, CFO, Secretary of Geltech, company matters

13. SILVIA KLAKER Vice President and Employee of Geltech, company matters

14. MICHAEL HARRIS SEC attorney for Geltech, company matters and SEC filings

15. GERRY KAISER Employee of Geltech, daily operations and company sales/matters

16. GARY NACHT Employee of Geltech, company sales and contracts

17. MATTHEW STUZZIERO Employee and corporate officer-CEO of Geltech, wildland division

18. DAVID JAMISON Employee and attorney for Geltech, company matters

19. BRIAN BERNSTIEN SEC attorney and General Counsel of Geltech, legal matters 

20. PHIL O’CONNELL Investor and Board of Director of Geltech, corporate matters

21. QUINT BAREFOOT Former supplier – Chase, source products and product matters

22. MICHAEL VALDEZ Former supplier – SNF, source products and product matters

23. TOM SUMMERS Contractor ATG Labs, graphics and production manager

24. JACK GRUMMET Investor and sales of Geltech, 

25. PAUL CRYSTAL Employee of Geltech, head of IT and sales

26. ROB PRINCE Investor and partner of Geltech, was associated to FireIce Solutions

27. MEL WARNER Investor of Geltech

28. MICHAEL HULL Employee of Geltech, Treasurer, Secretary, CFO representative

29. LEONARD MASS Geltech Director

30. VICTOR TROTTER Geltech Director

31. DAVID GUTMANN Geltech Director

32. BRUCE STONE Geltech employee, involved with Peter Cordani post Geltech closing matters

33. GREG JOHNSON Geltech employee, involved with Peter Cordani post Geltech closing matters

34. STEVEN SELZ Peter Cordani attorney

Case 9:22-cv-81772-WPD Document 350 Entered on FLSD Docket 08/23/2024 Page 46 of 46