In an update on the lawsuit filed by TNA Wrestling President Billy Corgan against TNA Wrestling Chairman Dixie Carter-Salinas, her husband Serg Salinas, TNA Wrestling, its parent company IMPACT Ventures LLC and TNA Wrestling’s Chief Financial Officer Dean Broadhead, a report from notes that some additional material from the unsealed documents were released today. The report notes that on October 19th, Billy Corgan filed a motion to compel Dixie Carter-Salinas and IMPACT Ventures LLC to provide full and fair responses to the discovery requests after being unsatisfied with responses given by the two defendants on October 18th and that in the motion to compel, it was noted that the Court had previously denied a request from Corgan’s attorneys that Carter-Salinas and a corporate representative of IMPACT Ventures LLC be deposed.

Meanwhile, the responses from Carter-Salinas and IMPACT Ventures LLC were from the expedited discovery request and in that response, Carter-Salinas denied that the company was as the term is used in the Section 7 (e) (i) of the Pledge Agreement at issue in this action. Carter-Salinas in her response said that the term insolvent is not defined in the Pledge Agreement and that under Tennessee law, an entity is insolvent only if the sum of the debtor’s debts is greater than all of the debtor’s assets, at a fair valuation and that IMPACT Ventures’ assets are of greater value than its debt. Carter-Salinas also denied that Billy Corgan informed her of an Event of Default under Section 7 of the Pledge Agreement on September 29th, 2016 and also denied that Billy Corgan has the right, under the Pledge Agreement and the Operating Agreement to remove the managers of IMPACT Ventures LLC and replace them with designees of his choosing. Carter-Salinas said that the transfer of governance rights is invalid under Tennessee law and the Operating Agreement and that there has also not been an Event of Default as that term is used in the Pledge Agreement and that IMPACT Ventures has not been insolvent since August 11th, 2016 and is not insolvent at present.

In regards to the documentation request of Dixie Carter-Salinas which include documents backing up her statements, all documents related to IMPACT Ventures LLC being insolvent or unable to pay all of its debts in full as it came due from January 1st, 2016 to the present, all documents sent to or received from World Wrestling Entertainment or any of its representatives from January 1st, 2016 to present and 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, Carter-Salinas responded by stating, “Ms. Salinas objects to this request on the grounds that it seeks information that, at least in part, can be obtained from some other source that is more convenient, less burdensome, and/or less expensive, named Plaintiff. Subject to, and waiving that objection, and consistent with the Tennessee Rules of Civil Procedure, Ms. Salinas is producing responsive documents herewith.” Some of Dixie Carter-Salinas’s responses also claimed that documents requested were also overly broad, not relevant and not reasonably calculated to lead the discovery of admissible evidence because it is not limited to any period of time.

The report states that Corgan’s attorneys, noting that they will not be able to get a deposition from Carter prior to the next hearing on October 26th, stated their Plaintiff will be left to guess the basis of the claims that the company is solvent until the defendants file their own brief on October 24th, just 48 hours prior to the scheduled hearing, leaving the attorneys just that amount of time to prepare for the hearing and that it was noted that TNA Wrestling and the other defendants have handed over 17,000 pages worth of documents that are currently being reviewed and assessed by Corgan’s attorneys.