Securities and Exchange Commission v. Nadel et al

Filing 1030

NOTICE of Appearance by Mark A. Platt on behalf of Van Operating, Ltd. (Platt, Mark)

IN THE UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.
ARTHUR NADEL, SCOOP CAPITAL, LLC,
SCOOP MANAGEMENT, INC.
Defendant.

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CASE NO. 8:09:CV-87-T-26TMB

NOTICE OF APPEARANCE
PLEASE TAKE NOTICE that the undersigned represents Van Operating, Ltd. (“Van”),
holder of a promissory note (the “Note”) secured by a properly perfected mineral deed of trust,
security agreement and assignment covering over 3,200 acres in Schackleford County, Texas
(the “Mortgaged Property”). The Mortgaged Property is owned by Quest Energy Management
Group, Inc., whose assets, pursuant to the Order entered at Docket No. 1024, the receivership
created in this case was expanded to include. The Note became due on March 31, 2012, and it
has remained in default since that date. The amount outstanding on the Note was $516,888.00
($496,615.00 principle and $20,273.00 interest) as of May 31, 2013.
PLEASE TAKE FURTHER NOTICE that Van requests to be added to the Court’s
CM/ECF list, and that copies of any and all notices, pleadings, motions, applications,
presentments, petitions, memoranda, affidavits, declarations, orders, or other documents, filed or
entered in this case, be transmitted to:
Mark A. Platt, Esq.
Fulbright & Jaworski LLP
2200 Ross Avenue, Suite 2800
Dallas, Texas 75201

55964293.2

Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
PLEASE TAKE FURTHER NOTICE that neither this Notice of Appearance nor any
subsequent appearances, pleadings, claims, proofs of claim, documents, suits, motions nor any
other writings or conduct, shall constitute a waiver of Van’s:
a.
right to have any and all proceedings wherein Van is a party heard in a venue
and/or jurisdiction other than this Court; and
b.
other rights, claims, actions, defenses, setoffs, recoupments or other matters to
which Van is rightly entitled under any agreements or at law or in equity or under the United
States Constitution.
All of the above rights are expressly reserved and preserved unto Van without
exception and with no purpose of confessing or conceding jurisdiction in any way by this filing
or by any other participation in these matters.
Dated: June 20, 2013

Respectfully submitted,
FULBRIGHT & JAWORSKI LLP
By:

/s/ Mark A. Platt
Mark A. Platt
2200 Ross Ave., Ste. 2800
Dallas, Texas 75201
Telephone: [phone]
Facsimile: [phone]
ATTORNEYS FOR VAN OPERATING, LTD.

55964293.2

CERTIFICATE OF SERVICE
This certifies that on June 20, 2013, a true and correct copy of the foregoing was served
via email through the Court’s Electronic Case Filing System on those parties that have consented
to such service.
/s/ Mark A. Platt______
Mark A. Platt

55964293.2