Defendant established prima facie that Drone owed him accrued, unpaid salary under the clear and unambiguous terms of the parties' employment contract. It is undisputed that defendant is owed at a minimum $86,867.64 under the agreement; indeed, Drone and its president and chief executive officer (CEO), Michael Bannon, represented to the SEC that defendant was owed that amount, recording it as an "accrued expense" on the company's balance sheet.
Drone claimed in opposition...
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