Delaware Court of Chancery, C.A. No. 2026-0495-MTZ. This page indexes the correspondence record of plaintiffs' counsel Geoffrey A. Boylston — extension grants, service objections, and the documented progression to a default judgment motion. Direct quotations only; no characterizations beyond the record.
Contessa Marine Research LLC is plaintiff; Joe Seinitz and Erica Stratmann are defendants. Per the CMR entity profile, CMR alleges breach of contract and fiduciary duty. Erica Stratmann's intervention was granted July 15, 2026, with a Verified Counterclaim (DE 16-3) designated operative, including RICO claims. Following Vice Chancellor Zurn's elevation to the Delaware Supreme Court, the matter was reassigned.
This action was filed against Joe Seinitz after his June 1, 2026 declaration — made under penalty of perjury and intended for use in CMR v. SYG (0:23-cv-61696) and this Chancery action — stated that Steven Ivankovich exercised de facto control over CMR and that Anthony Ivankovich never acted as member or manager. The timing is presented here as a chronology fact; any inference about retaliatory purpose is labeled Analysis below, not asserted as adjudicated fact.
Statements by Geoffrey A. Boylston, counsel for plaintiffs, indexed from correspondence. Each entry is a direct statement of counsel — the evidentiary weight of the statements themselves is for the Court.
| Date | Subject | Statement | Procedural Significance |
|---|---|---|---|
| 22 May 2026 | Extension Request | Extension granted through June 22, 2026, with warning that plaintiffs would exercise their rights if no response was filed. | Record of professional courtesy and notice before further action. |
| 10 Jul 2026 | Summons and Complaint | “We are willing to grant you one final extension through July 17, 2026.” — “No further extensions will be granted.” | Second extension; establishes plaintiffs' position on response sufficiency. |
| 10 Jul 2026 | Summons and Complaint | “If a response is not filed by July 17, 2026, we will move for default.” | Explicit default warning tied to a fixed deadline. |
| 10 Jul 2026 | Summons and Complaint | Not authorized to accept service for Contessa Marine Research LLC, Steven Ivankovich, or Olga Ivankovich. | Preserves service objections; rejects informal service efforts. |
| 10 Jul 2026 | Summons and Complaint | “Your emails do not constitute service.” | Formal procedural position on service requirements. |
| 10 Jul 2026 | FRCP 4 | “I am not authorized to accept service of this summons. Please proceed with completing service through another method accepted by law.” | Reaffirmed service position; instructed lawful service methods. |
| 29 Sep 2026 | Case status | “Mr. Seinitz did not file a response to the Amended Complaint by the Court's deadline, and we have accordingly moved for default judgment.” | Opposing counsel's representation that a default judgment motion is pending. |
| 29 Sep 2026 | Case status | Matter reassigned to the new Vice Chancellor following Vice Chancellor Zurn's elevation to the Delaware Supreme Court; counsel instructed to contact chambers upon confirmation to arrange oral argument on the default motion. | Court administration update; default motion expected to proceed to oral argument. |
| 29 Sep 2026 | Briefing schedule | “In light of the pending default judgment motion, and because our response to your motion may be contingent on the Court's ruling, we believe it would be most efficient to defer establishing a formal briefing schedule until that issue has been resolved.” | Counsel sought to sequence briefing around the default determination. |
Each item tagged Verified (direct statement of counsel, documented in correspondence) or Analysis (inference from the record).
Counsel granted at least two extensions before pursuing default relief: through June 22, 2026, and a “final” extension through July 17, 2026, each with stated consequences for non-compliance.
Counsel repeatedly denied authority to accept service, instructed service through lawful methods, and expressly stated that email communications do not constitute service. The record contains no waiver.
The record shows a documented progression: extension warnings, an explicit default warning tied to July 17, a default judgment motion, and a request to defer briefing on defendants' motion until the default issue resolves.
This Chancery action was filed against Joe Seinitz after his June 1, 2026 declaration stated that Steven Ivankovich exercised de facto control over CMR. Whether the suit is retaliatory is an inference from chronology and posture, not an adjudicated fact.
Counsel's statement that the response to defendants' motion “may be contingent” on the default ruling is consistent with positioning the default motion as potentially dispositive ahead of merits briefing. Alternative reading: routine case-management efficiency.
The reviewed correspondence contains procedural positions and litigation-status representations only. Counsel made no substantive factual admissions regarding the merits of the Contessa allegations.
“Your emails do not constitute service.”
Companion statement under FRCP 4: “I am not authorized to accept service of this summons. Please proceed with completing service through another method accepted by law.”
“We are willing to grant you one final extension through July 17, 2026… No further extensions will be granted… If a response is not filed by July 17, 2026, we will move for default.”
“Mr. Seinitz did not file a response to the Amended Complaint by the Court's deadline, and we have accordingly moved for default judgment.”
“We believe it would be most efficient to defer establishing a formal briefing schedule until that issue has been resolved.”