IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

THE JAMES STREIBICH REVOCABLE 

TRUST OF 2002, an Illinois Trust, 

individually, and derivatively, on behalf of 

FOLDING LIGHT, LLC, a Delaware 

Limited Liability Company, 

Plaintiffs, 

v.

BROCK H. FLAGSTAD, an individual; 

OXFORD MARKETING PARTNERS, LLC, a Delaware Limited Liability 

Company; OXFORD MEDIA, LLC, an 

Illinois Limited Liability Company; 

OXFORD TAX PARTNERS, LLC, an 

Illinois Limited Liability Company;

OXFORD FG, LLC, an Illinois Limited 

Liability Company; OXFORD GP, LLC, an Illinois Limited Liability Company; 

FINANCIAL FREEDOM ADVISORS, LLC, an Illinois Limited Liability 

Company; and CLOVERPOINT 

PARTNERS, LLC, an Illinois Limited 

Liability Company; 

Defendants.

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No. 20 cv 2242 

Honorable Judge Manish S. Shah 

PLAINTIFFS’ MOTION FOR LEAVE TO PROVISIONALLY FILE 

AMENDED COMPLAINT UNDER SEAL

Plaintiff, THE JAMES STREIBICH REVOCABLE TRUST OF 2002, an Illinois Trust, 

individually (“the Trust”), and derivatively, on behalf of FOLDING LIGHT, LLC, a Delaware 

Limited Liability Company (“Folding Light”) (hereinafter collectively “the Plaintiffs”), 

respectfully move for an Order provisionally sealing the Amended Complaint For Injunctive 

Relief, Damages, And Appointment Of A Receiver (“Amended Complaint”), and states the 

following: 

1. The Plaintiffs commenced this action on April 9, 2020 filing an eight count

complaint for: Violation of RICO, 18 U.S.C. 1962 (c ) – Count I; Conspiracy to Violate Section 

1962 ( c ) of RICO, 18 U.S.C. 1962 (d) – Count II; Common Law Fraud; Count III; 

Case: 1:20-cv-02242 Document #: 41 Filed: 11/09/20 Page 1 of 5 PageID #:373
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Conversion/Theft – Count IV; Breach of Fiduciary Duty – Count V; Breach of Contract – Count 

VI; Civil Conspiracy – Count VII; and for an Accounting – Count VIII. Dkt.

2. The Defendants moved to dismiss the Complaint pursuant to Rule 12(b)(6) on 

July 1, 2020. Dkt. No. 29.

3. The Trust issued document subpoenas to third party financial institutions that 

included: American Express, Wintrust, PNC, Huntington National Bank, JP Morgan Chase, Fifth 

Third Bank, Ameris Bank, MB Financial Bank, U.S. Bank N.A., Bank of America, Citibank, and 

Prime South Bank. Not all the Respondents have completed the production of records as of this 

filing. However, some of the Respondents have produced records including Respondent Wintrust 

Financial. 

4. On July 23, 2020, the Defendants sought to quash the document subpoenas. Dkt.

No. 31. The court denied the Defendants Motion on August 10, 2020 and allowed the parties to 

commence limited written discovery. Dkt. No. 37. 

5. The court further entered a Confidentiality Order governing the use of documents 

obtained in discovery. Dkt. No. 38. The Confidentiality Order provides for designating financial 

information and records of any party as Confidential Information. 

6. The Trust further issued document requests to the Defendants. Those requests 

however have not been answered and the Defendants have produced no documents. This 

includes even basic corporate records from the defendant Folding Light in which the Trust has a 

membership interest.

7. On October 19, 2020, the Court granted the Defendants’ Motion to Dismiss

without prejudice on Counts I & II and declined to exercised supplementary jurisdiction over the 

Plaintiffs’ pendant state law claims. Dkt. No. 40. The Court further ordered that the Trust file an 

Amended Complaint on or before November 9, 2020. Dkt. No. 40.

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8. The Amended Complaint includes new allegations of fact that are derived from 

financial records recovered from the third party Respondents, including Wintrust. In Plaintiffs’ 

view, the information included in the Amended Complaint should not be confidential. Indeed,

some of the information can be obtained from public websites that report applicants for Paycheck 

Protection Program loans.

9. While the Plaintiffs do not believe that the Amended Complaint includes 

Confidential Documents or Information as defined by the Confidentiality Order, because new 

allegations of fact in the Amended Complaint were derived from records that may be subject to 

this court’s Confidentiality Order, the Plaintiffs have filed this motion for provisional relief and 

guidance from the Court pursuant to paragraph 11 of the Confidentiality Order. 

10. Pursuant to Local Rule 26.2, the Confidentiality Order will concurrently be 

submitted to the Court.

WHEREFORE, Plaintiffs respectfully request that this Court permit that the First 

Amended Complaint be filed provisionally under seal, that the court enter the proposed order 

granting that the Amended Complaint may be filed in the public record, and for such other and 

further relief the court deems as just. 

Dated: November 9, 2020 Respectfully submitted,

THE JAMES STREIBICH REVOCABLE TRUST 

OF 2002, an Illinois Trust, individually, and 

Derivatively, on behalf of FOLDING LIGHT, LLC, 

a Delaware Limited Liability Company

By: /s William K. Kane 

One of Its Attorneys

William K. Kane, Esq. (6194466)

David M. Poell, Esq.(6302765)

SHEPPARD MULLIN RICHTER & HAMPTON LLP

Three First National Plaza

70 West Madison Street, 48th floor

Chicago, Illinois 60602

Case: 1:20-cv-02242 Document #: 41 Filed: 11/09/20 Page 3 of 5 PageID #:375
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Telephone: 312.499.6300

Facsimile: 312.499.6301

wkane@sheppardmullin.com 

dpoell@sheppardmullin.com

Counsel for Plaintiffs, The James Streibich

Revocable Trust of 2002, an Illinois Trust,

individually, and derivatively, on behalf of Folding 

Light, LLC, a Delaware Limited Liability 

Company.

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CERTIFICATE OF SERVICE

I hereby certify that on this 9th day of November, 2020, I electronically filed the 

foregoing Motion to Provisionally File Amended Complaint Under Seal with the Clerk of the 

Court using the CM/ECF system which will send notification of such filing to all counsel of 

record.

/s/ William K. Kane

William K. Kane

Case: 1:20-cv-02242 Document #: 41 Filed: 11/09/20 Page 5 of 5 PageID #:377