Securities and Exchange Commission v. Nadel et al

Filing 942

Unopposed MOTION for extension of time to file response/reply as to 936 MOTION for miscellaneous relief, specifically for Possession of and Title to Real Property Located in Marshfield, VT, Unopposed MOTION to continue Hearing by Anne Nadel-Walbridge. (Farmer, Matthew)

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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, Relief Defendants. _______________________________________/ NON-PARTY ANNE NADEL-WALBRIDGE’S UNOPPOSED MOTION FOR EXTENSION OF TIME AND CONTINUANCE OF HEARING Non-party Anne Nadel-Walbridge, through her undersigned counsel, hereby moves for a 14 day extension of time in which to file her response to the “Receiver’s Motion for Possession of and Title to Real Property Located in Marshfield, VT.” (Doc. 936). By Order issued November 1, 2012 (Doc. 938), this Court set a deadline of today’s date for the response. Non-party Nadel-Walbridge also moves for a 14 day continuance of the November 15, 2012 motion hearing, which was set by the same Order (Doc. 938). Neither the receiver, through Gianluca Morello, Esq., nor the SEC, through Scott Masel, Esq., objects to the relief sought by this motion. MEMORANDUM OF LAW Non-party Nadel-Walbridge relies on Fed. R. Civ. P. 6(b)(1)(A). As good cause, the undersigned counsel states that he was retained on November 10, 2012 to represent non-party Nadel-Walbridge. WHEREFORE, non-party Nadel-Walbridge moves to extend the time in which to respond to the motion (Doc. 936) for 14 days, and moves for a corresponding continuance of the hearing scheduled for November 15, 2012 at 9:30 a.m. Respectfully submitted, FARMER AND FITZGERALD, P.A. /s MATTHEW P. FARMER, ESQ. Matthew P. Farmer, Esq. Fla. Bar No. 0793469 708 E. Jackson St. Tampa, Florida 33602 (813) 228-0095 FAX (813) 224-0269 MattFarmer1@aol.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished by electronic mail to the following this 13th day of November, 2012: Scott Masel, Esq. masels@sec.gov Gianluca Morello, Esq. gmorello@wiandlaw.com /s Matthew P. Farmer, Esq. COUNSEL

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