IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS, SHERMAN DIVISION

NELSON WILLIS,

Plaintiff,

vs.

ADAM M. ARON,

Defendant.

Case No.: 4:23-CV-732-ALM

JULY 16, 2024

FILED

JUL 1 6 2024

CLERK, U.S. DISTRICT COURT

EASTERN DISTRICT OF TEXAS

THE HONORABLE DISTRICT JUDGE AMOS LOUIS MAZZANT, III

PLAINTIFF S RESPONSE TO DEFENDANT'S RESPONSE (68) TO PLAINTIFF'S EMERGENCY MOTION (57) TO

COMPEL IMMEDIATE PRODUCTION OF EMAILS, TEXT MESSAGES, AND OTHER COMMUNICATIONS

PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 37(a)

Your Honor,

Plaintiff humbly and respectfully submits the following.

I. Introduction

Plaintiff Nelson Willis submits this response to Defendant Adam M. Aron's opposition to Plaintiff's

Emergency Motion to Compel Immediate Production of Emails, Text Messages, and Other

Communications [Dkt. 57].

II. Argument

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1. Necessity of Immediate Production

• The Plaintiff has provided substantial evidence demonstrating the need for immediate production of

the requested communications due to the ongoin and deliberate fraudulent activities conducted by the

Defendant and his Board of Directors. The nature and urgency of the evidence justify the immediate

intervention of this Court.

2. Federal Rule of Civil Procedure 37(a)

• Under FRCP 37(a), a party is entitled to move for an order compelling discovery if the opposing party

fails to provide information or materials requested during the discovery process. Given the serious

allegations and the compelling evidence provided, the Plaintiff s motion is both appropriate and

necessary.

3. Relevance to Original Complaint

• The Defendant s assertion that the Plaintiff is going out of the scope of the lawsuit is unfounded. The

original complaint comprehensively covers Project Popcorn 1.0, the theft of shares, the rigged

shareholder vote, and related fraudulent activities. The requested communications are directly relevant

to these allegations and are essential for establishing the full extent of the Defendant's actions.

4. Exception to Usual Discovery Processes

• Given the unique and extraordinary nature of the allegations, the Plaintiff requests an exception to the

usual discovery processes. The Plaintiff has not engaged in direct discovery requests from the Defendant

due to the severe and urgent circumstances, and the Defendant's established pattern of fraudulent

behavior necessitates immediate Court intervention.

5. Evidence of Defendant's Direct Involvement

• The Defendant's email response to the Plaintiff on April 3, 2023, at 3 AM, from his CEO Adam account

at AMC Entertainment Holdings Inc., directly implicates him in the matters at hand. This demonstrates

the Defendant's personal involvement and further substantiates the need for the immediate production

of all relevant communications.

6. Premature Claims by the Defense

• The Defendant's claim that the Plaintiff's motion is premature is unfounded. The Defendant's

continuous obstructive behavior and refusal to address the allegations substantively have left the

Plaintiff with no other recourse but to seek emergency relief from this Court. The Plaintiff has

demonstrated a consistent pattern of seeking the Court's intervention due to the significant and

immediate risks posed by the Defendant's actions.

7. Defendant's Presumed Special Relationship with the Bench

• The Defendant appears to assume a special relationship with the bench, expecting preferential

treatment due to his position. This assumption is evident in his objections to the Plaintiff's motions.

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However, justice demands that all parties be treated equally, and the Defendant s status should not

shield him from accountability.

8. Preemptive Strike Against Potential Rebuttals

• Any additional objections from the Defendant should be vie ed throu h the lens of his ongoing

attempts to evade scrutiny and accountability. The Defendant s consistent pattern of obstruction and

delay tactics only serve to underscore the necessity of granting the Plaintiff's emergency motion.

III. Conclusion

For the reasons stated above, Plaintiff respectfully requests that the Court grant the Emergency Motion

to Compel Immediate Production of Emails, Text Messages, and Other Communications.

IV. Prayer for Relief

Plaintiff prays for the following relief:

1. Immediate production and verification of all communications between AMC's CEO and the Board of

Directors relevant to the allegations.

2. Compliance with the specified discovery requests as outlined in the Motion to Compel [Dkt. 57].

3. Any further relief the Court deems just and proper.

Dated: July 16, 2024

Respectfully submitted.

Pro Se Litigant

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CERTIFICATE OF SERVICE

I hereby certify that on July 16, 2024, a true and correct copy of the foregoing document was served

upon all counsel of record via the Court s electronic filing system.

July 16, 2024

Nelson Willis

Pro Se Litigant

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