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)

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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. § § § § § § § § § § § § 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: (214) 855-8000 Facsimile: (214) 855-8200 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: (214) 855-8000 Facsimile: (214) 855-8200 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

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