Securities and Exchange Commission v. Nadel et al

Filing 1316

NOTICE of compliance re 1315 Order on Motion to Strike by Burton W. Wiand (Lamont, Michael)

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.

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

ARTHUR NADEL,
SCOOP CAPITAL, LLC,
SCOOP MANAGEMENT, INC.
Defendants,
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,
Relief Defendants.
/
NOTICE OF COMPLIANCE WITH COURT ORDER DATED OCTOBER 4, 2017
On September 15, 2017, Burton W. Wiand, as Receiver (the “Receiver”) filed a
Motion to Enforce Constructive Trust Through Turnover of Real Property, or in The
Alternative, Through Foreclosure of The Receiver’s Equitable Lien (Doc. 1310) (the
“Motion”), along with his Declaration in support of the Motion (Doc. 1311). Prior to filing
the Motion, counsel for the Receiver conferred with counsel for the Lee’s, Mr. Benjamin
Martin, regarding the Motion. Mr. Martin, on behalf of the Lee’s, confirmed in writing that
they objected to the relief sought. That same day, the Motion and Declaration were sent via

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U.S. Mail and email to Mr. Martin. At no point did Mr. Martin indicate that he did not
represent the Lee’s or that the Motion should be served directly to them.
On October 4, 2017, the Court entered an Order (Doc. 1315) directing the Receiver to
immediately send a copy of the Motion (Doc. 1310) and his Declaration (Doc. 1311) to
Vernon Lee and Manon Summers-Lee to their address of 4018 Via Mirada, Sarasota, Florida
34238. The Receiver hereby files this notice to inform the Court that he has complied with
the Order. On October 4, 2017, counsel for the Receiver sent a copy of the Motion and
Declaration to Vernon Lee and Manon Sommers-Lee via Federal Express to the
aforementioned address.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 4, 2017, I electronically filed the foregoing
with the Clerk of the Court by using the CM/ECF system.

s/Michael Lamont
Michael S. Lamont FBN 0527122
[e-mail]
Jared J. Perez, FBN 0085192
[e-mail]
Wiand Guerra King P.L.
3000 Bayport Drive, Suite 600
Tampa, FL 33607
Tel: [phone]
Fax: [phone]
Attorneys for the Receiver, Burton W. Wiand

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