Securities and Exchange Commission v. Nadel et al

Filing 1191

DECLARATION of Gianluca Morello re 1190 MOTION for miscellaneous relief, specifically Motion to Overrule Objections to Claims 403, 404, 405, 406, 407, 408, and 477 by Burton W. Wiand. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Morello, Gianluca)

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

Case No.: 8:09-cv-0087-T-26TBM

SCOOP REAL ESTATE, L.P.,
VALHALLA INVESTMENT PARTNERS, L.P.,
VALHALLA MANAGEMENT, INC.,
VICTORY IRA FUND, LTD,
VICTORY FUND, LTD,
VIKING IRA FUND, LLC,
VIKING FUND, LLC, AND
VIKING MANAGEMENT, LLC.
Relief Defendants.
/
DECLARATION OF GIANLUCA MORELLO IN SUPPORT
OF THE RECEIVER’S MOTION TO OVERRULE OBJECTIONS
TO CLAIMS 403, 404, 405, 406, 407, 408, AND 477
Gianluca Morello declares as follows:
1.

I am an attorney with Wiand Guerra King P.A. in Tampa, Florida, and I represent

Burton W. Wiand, as Receiver, in this and other related cases.
2.

I make this declaration based on information personally known to me and in

support of the Receiver’s Motion to Overrule Objections to Claims 403, 404, 405, 406, 407, 408,
and 477 (the “Motion”) being filed along with this declaration.

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3.

Attached as Exhibit A is a compilation of true and correct copies of the

objections to the Receiver’s determinations of Claims 403, 404, 405, 406, 407, 408, and 477
filed by the claimants who submitted those claims, the Vincentz.
4.

Attached as Exhibits B and C are true and correct copies of the Receiver’s

responses to the Vincentz’ objections.
5.

Attached as Exhibit D is a compilation of true and correct copies of the Vincentz’

replies to the Receiver’s responses.
6.

Attached as Exhibit E is a true and correct copy of an email thread between

Mr. Vincentz and Jordan Maglich, an attorney in my office who assisted me with this matter,
regarding the withdrawal of the Vincentz’ objections.
I DECLARE under the penalty of perjury that the foregoing is true and correct and is
executed this 12th day of August, 2015.
s/ Gianluca Morello
Gianluca Morello, FBN 034997
[e-mail]
WIAND GUERRA KING P.A.
5505 West Gray Street
Tampa, FL 33609
Tel: [phone]
Fax: [phone]
Attorney for the Receiver, Burton W. Wiand

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 12, 2015, a copy of the foregoing was
electronically filed with the Clerk of the Court using the CM/ECF system which will send
notification of this filing to all counsel of record.
I FURTHER CERTIFY that a true and correct copy of the foregoing has been served
upon the following via email and United States Mail:
Chester & Patricia Vincentz
6500 Lakeview Drive
Falls Church, VA 22041

s/ Gianluca Morello
Gianluca Morello, FBN 034997
[e-mail]
WIAND GUERRA KING P.A.
5505 West Gray Street
Tampa, FL 33609
Tel: [phone]
Fax: [phone]
Attorney for the Receiver, Burton W. Wiand

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