CORGAN REQUEST FOR EXPEDITED DISCOVERY IN TNA SUIT SHINES LIGHT ON WHY SUIT MAY HAVE BEEN FILED, CORGAN CLAIMING HE HAS RIGHT TO 'REMOVE' MANAGEMENT OF IMPACT VENTURES

As noted earlier today, a number of documents related to the lawsuit Billy Corgan filed on 10/12 against TNA, it's parent company Impact Ventures LLC, TNA Chairman Dixie Carter, her husband Serg Salinas and TNA Chief Financial Officer Dean Broadhead were unsealed by the Chancery Court for Davidson County, TN.

While the lawsuit itself will remain sealed until next week, insight can be gained from Corgan's motion for expedited discovery. In the United States court system, discovery enables the parties to know before the trial begins what evidence may be presented so they can properly prepare for court.

The expedited discovery request notes that Corgan, Dixie Carter and Impact Ventures LLC entered into a Pledge and Security Agreement" on 8/11/16 and also makes reference to an "Operating Agreement for Impact Ventures" that was executed on 8/7/15. The filing does not make reference to whom may have signed that Operating Agreement.

In the request for expedited discovery, Corgan requested that TNA Entertainment LLC, it's parent company Impact Ventures LLC, TNA Chairman Dixie Carter:

*Admit that Impact Ventures is insolvent "as that term is used in Section 7 (e) (i) of the Pledge Agreement."

*Admit that Corgan notified you of the occurrence of an Event of Default under Section 7 of the Pledge Agreement on 9/29/16.

*Admit that Corgan currently has the right under the Pledge Agreement to exercise the voting rights associated with your equity interest in Impact Ventures LLC.

*Admit that Corgan has the right under the Pledge Agreement and the Operating Agreement to remove the managers of Impact Ventures and replace them with designees of Corgan's choosing.

If the defendants do not admit the above, they are then being asked to hand over:

*All documents related to Impact Ventures being insolvent or unable to pay all of its debts in full as it came due from January 1, 2016 to the present.

*All documents sent to or received from World Wrestling Entertainment or any of its representatives from January 1, 2016 to present.

*All documents sent to or received from "any third party" regarding that third party's potential acquisition of Impact Ventures LLC, TNA Entertainment LLC or any of the assets owned by either entity.

Corgan also requested that TNA Entertainment LLC identify the nature and extent of "each member's" ownership interest, that the company identify all of the current officers, directors and managers, identify all of it's assets, and for the LLC to produce "financial statements, including but not limited to, balance sheets, profit and loss statements, and statements of cash flows, whether audited or unaudited, from January 1, 2016 to the present." He also requested that the location of the TNA video library be stated, that the ownership of the library be stated and that any negotiations for the sale of the library be revealed.

All of this helps to add context into why Corgan filed the lawsuit on 10/12, but we won't get the full picture until the lawsuit is unsealed on 10/25.

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