Miscellaneous

Plaintiff's Opposition to Special Motion to Strike in Uulala Inc. v. Damiano Raigoza, Andre Urena, and Allan Sheu at the Superior Court of the State of California, County of Los Angeles. Editor's Note: In this filing, Uulala stated that the group's Initial Coin Offering in Bermuda "generated less than $25,000".

SEC's Ex Parte Application for Temporary Restraining Order Freezing Assets and Granting Other Relief against Ongkaruck Sripetch, Brehnen Knight, Amanda Flores, and Ashmit Patel in U. S. Securities and Exchange Commission v. Ongkaruck Sripetch, of Las Vegas, NV; Amanda Flores, of Las Vegas, NV; Brehnen Knight, of Escondido, CA; Andrew McAlpine, a citizen of Canada residing in the Cayman Islands; Ashmit Patel, a citizen of Canada residing in Ontario; Michael Wexler, a citizen of Canada residing in Ottawa; Dominic Williams, of Bonita, CA; Adtron Inc., a.k.a. Stockpalooza.com, of Nevada; ATG Inc., of Nevada; DOIT Ltd., domicile not specified; Doji Capital, Inc., of California; King Mutual Solutions Inc., of Nevada; Optimus Prime Financial Inc., of California; Orca Bridge, of Nevada; Redline International, of Nevis and California, and UAIM Corporation, of Belize, at the U. S. District Court for the Southern District of California.

Malcolm Duncan's Motion for an Order "appointing a receiver to sell the set of Nelson Mandela gold hands and accompanying certificates of authentication (the "Mandela Hands"); and (ii) modifying the February 27, 2020 temporary restraining order to permit the receiver to sell the Mandela Hands" in Malcolm Duncan, a citizen of South Africa v. Max Barber, SION Trading FZE, of Ras Al Khaimah, in the United Arab Emirates, and Barlan Enterprises Ltd., d.b.a. Guernsey's, a firm of auctioneers based in New York, at the Supreme Court of the State of New York, County of New York.

Motion to Dismiss Amended Consolidated Class Action Complaint styled as 'Tether and Bitfinex Crypto Asset Litigation' by iFinex Inc., a.k.a. Bitfinex; DigFinex Inc., BFXNA Inc., BFXWW Inc., Tether International Limited, Tether Operations Limited, Tether Holdings Limited, all of the British Virgin Islands; Tether Limited, of Hong Kong; Ludovicus Jan van der Velde, a citizen of the Netherlands, and Giancarlo Devasini, a citizen of Italy, in David Leibowitz et al v. iFinex Inc. et al at the U. S. District Court for the Southern District of New York.

Motion to Dismiss Amended Consolidated Class Action Complaint styled as 'Tether and Bitfinex Crypto Asset Litigation' by Philip G. Potter in David Leibowitz et al v. iFinex Inc. et al at the U. S. District Court for the Southern District of New York.

Motion to Dismiss Amended Consolidated Class Action Complaint styled as 'Tether and Bitfinex Crypto Asset Litigation' by Reginald Fowler in David Leibowitz et al v. iFinex Inc. et al at the U. S. District Court for the Southern District of New York.

Motion to Dismiss Amended Consolidated Class Action Complaint styled as 'Tether and Bitfinex Crypto Asset Litigation' by Bittrex Inc. and Poloniex LLC in David Leibowitz et al v. iFinex Inc. et al at the U. S. District Court for the Southern District of New York.

Motion for a Temporary Restraining Order and Preliminary Injunction in Whitebox Relative Value Partners LP, Whitebox Multi-Strategy Partners LP, Pandora Select Partners LP, all of the Cayman Islands, and Whitebox GT Fund LP, of Delaware v. Transocean Ltd., of Switzerland, and Transocean Inc., of the Cayman Islands, at the U. S. District Court for the Southern District of New York.

Applicant's Motion to Amend Relief regarding an investigation into suspected fraud and corruption in the Attorney General of the British Virgin Islands v. Lester S. Hyman at the U. S. District Court for the District of Columbia.

SEC's Motion for Temporary Restraining Order in U. S. Securities and Exchange Commission v. David C. Coggins and Coral Gables Asset Management LLC, as Defendants, and Coral Gables Asset Holdings LP and Coral Gables Capital LP, as Relief Defendants, at the U. S. District Court for the Southern District of Florida.

Notice of Motion for Summary Judgment In Lieu of Complaint in AI International Holdings (BVI) Limited, of the British Virgin Islands v. George Tushinsky at the Supreme Court of the State of New York, County of New York.

Notice of Motion for Leave for Alternative Service alleging that the individual defendants "have leveraged their online-only operations to avoid public tracing and, by extension, service" and are attempting to "skirt liability by vanishing into the fog of internet obscurity" in Joel Deutsch v. Status Research & Development GmbH, of Switzerland; Jarrad Hope, and Carl Bennetts at the U. S. District Court for the Southern District of New York.

Notice of Removal in Insured Aircraft Title Service LLC v. Comfort Jet Aviation Ltd., of the Isle of Man; Aeromanagement, Inc., Kent Aviation, LLC, and Dassault Falcon Jet-Wilmington Corp. at the U. S. District Court for the Western District of Oklahoma.

Special Motion to Strike by Damiano Raigoza in Uulala Inc., which is part of a cryptocurrency group that became the first applicant to be approved by Bermuda to conduct an Initial Coin Offering v. Damiano Raigoza, Andre Urena, and Allan Sheu at the Superior Court of the State of California, for the County of Los Angeles.

Notice of Removal, including a copy of the complaint seeking damages of $38 million, in Cimontubo - Tubagens e Soldadura Lda, of Portugal v. Petróleos de Venezuela SA and PDVSA Petróleo SA, both of Venezuela, at the U. S. District Court for the Southern District of Florida.

Emergency Ex Parte Motion for a Temporary Restraining Order regarding accounts in Canada, the Cayman Islands, Hong Kong, Isle of Man, Malta, and the USA in U. S. Securities and Exchange Commission v. Nelson Gomes, described as a citizen of Canada who "resides at various times in the Bahamas and Hong Kong"; Michael Luckhoo-Bouche, a citizen of Canada residing in Mississauga, Ontario; Shane Schmidt, a citizen of Canada residing in Vancouver, British Columbia; Douglas Roe, a citizen of Canada residing in Vancouver, British Columbia; Kelly Warawa, a citizen of Canada residing in Vancouver, British Columbia; FFS Capital Limited, of Hong Kong; Paifang Trading Limited, of Hong Kong; Atlantean Management Corporation, of Canada; Meadow Asia Limited, of Hong Kong, and Thyme International Limited, of Hong Kong, at the U. S. District Court for the District of Massachusetts.

Defense in JTC (Jersey) Limited, of Jersey, in the Channel Islands v. Sandra Looney, of London, England, at the High Court of Justice, in London, England.

Emergency Motion for Temporary Restraining Order in Griffin Asset Management LLC, of Delaware, and HASelect-FTM Medical Receivables Litigation Finance Fund SP, a segregated portfolio of HedgeACT International SPC Ltd., of the Cayman Islands v. Chadwick Meyer, of South Carolina; Tecumseh-Infinity Medical Receivables Fund, LP, of Delaware; FTM Limited, of Vanuatu, and Alternative Investment Specialists Limited, of Vanuatu, at the Circuit Court of Cook County, Illinois.

Defense in Circumference Investments (Europe) Limited, of England; Circumference (Luxembourg) Sàrl, of Luxembourg, and Circumference Holdings Ltd., of the Cayman Islands v. Nicholas James Martin, of Luxembourg, at the High Court of Justice, England and Wales.

Stipulation to file Amended Complaint regarding allegations of "corporate looting" involving Switzerland-domiciled Diligence Global Business Intelligence SA in Diligence Inc., a Delaware company majority owned by Cayman Islands-domiciled Information Security Investments Company v. Nicholas Day, a citizen of the United Kingdom residing in Chamonix, France, at the Court of Chancery of the State of Delaware.

Notice of Motion to Confirm Order of Attachment following an arbitration award of $142 million regarding allegations of fraud in La Dolce Vita Fine Dining Company Limited, and La Dolce Vita Fine Dining Group Holdings Limited, both of the Cayman Islands v. Zhang Lan, described in the motion as "a citizen and resident of China" and, in an exhibit, as "a citizen and resident of St. Kitts and Nevis"; Grand Lan Holdings Group (BVI) Limited, of the British Virgin Islands; Qiao Jiang Lan Development Limited, f.k.a. South Beauty Development Limited, of the British Virgin Islands, and Metro Joy International LLC, of New York, at the U. S. District Court for the Southern District of New York.

Notice of Removal, including a copy of the complaint alleging professional malpractice regarding a proposed transaction involving Warid Telecom International, of the United Arab Emirates, in Elko Broadband Ltd., of Reno, Nevada v. HaiderMota BNR, described as a law firm in Pakistan, and A.F. Ferguson & Company, described as an accounting firm in Pakistan, at the U. S. District Court for the District of Nevada.

SEC's Expedited Motion for the Appointment of a Receiver in U. S. Securities and Exchange Commission v. TCA Fund Management Group Corp., of Florida, and TCA Global Credit Fund GP Ltd., of the Cayman Islands, as Defendants, and TCA Global Credit Fund LP, TCA Global Credit Fund Ltd., and TCA Global Credit Master Fund LP, all of the Cayman Islands, as Relief Defendants, at the U. S. District Court for the Southern District of Florida.

Ex Parte Motion for Freezing Order regarding a "fraudulent offering of digital asset-related securities" in U. S. Securities and Exchange Commission v. Daniel F. Putnam, of Utah; Jean Paul Ramirez Rico, of Colombia; Angel A. Rodriguez, of Utah; MMT Distribution LLC, of Utah, and R&D Global LLC, d.b.a. Modern Money Team, d.b.a. Eyeline Trading, d.b.a. WealthBoss, as Defendants, and Richard T. Putnam, as Relief Defendant, at the U. S. District Court for the District of Utah.

Plaintiff's Motion for Preliminary Injunction in Commodity Futures Trading Commission v. Daniel Fingerhut, of Miami Beach, Florida; Digital Platinum Inc., of Florida; Digital Platinum Ltd., of Israel; Huf Mediya Ltd., a.k.a. Hoof Media Ltd., of Bulgaria; Tal Valariola, of Israel, and Itay Barak, of Israel, as Defendants, and Aicel Carbonero, of Miami Beach, Florida, as Relief Defendant, at the U. S. District Court for the Southern District of Florida.

Plaintiff's Expedited Motion for Leave to File Combined Memorandum regarding allegations of fraud involving binary options and cryptocurrencies in Commodity Futures Trading Commission v. Daniel Fingerhut, of Miami Beach, Florida; Digital Platinum Inc., of Florida; Digital Platinum Ltd., of Israel; Huf Mediya Ltd., a.k.a. Hoof Media Ltd., of Bulgaria; Tal Valariola, of Israel, and Itay Barak, of Israel, as Defendants, and Aicel Carbonero, of Miami Beach, Florida, as Relief Defendant, at the U. S. District Court for the Southern District of Florida.

Affidavit in support of application for arrest warrant alleging "knowingly and willfully conspiring with each other and persons in Iran to use the U.S. financial system to procure a petroleum tanker named Nautic, and later renamed to the Gulf Sky, in violation of the Iranian Transactions and Sanctions Regulations" in USA v. Amir Abdolaziz Dianat, a.k.a. Ameer Abdulaazeez Jaafar, and Kamran Ali Lajmiry, a.k.a. Kamran Ali Lajmiri, at the U. S. District Curt for the District of Columbia.

Opening Brief In Support of Defendant's Motion to Take Discovery regarding Switzerland-based Diligence Global Business Intelligence SA in Diligence Inc. v. Nicholas Day at the Court of Chancery of the State of Delaware.

Motion for Issuance of a Request for International Judicial Assistance to Obtain Evidence in the Cayman Islands from Bell Rock Corporate Services, Campbell Corporate Services Limited, CO Services Cayman Limited, DMS Corporate Services Ltd., Forbes Hare Trust Company Limited, Genesis Trust & Corporate Services Ltd., Harneys Services (Cayman) Limited, Intertrust Corporate Services (C.I.) Limited, Ocorian (Cayman) Limited, Sterling Trust (Cayman) Limited, Trident Trust Company (Cayman) Limited, Vistra (Cayman) Limited, and Walkers Corporate Limited regarding an allegedly fraudulent 12.7 billion Danish Kroner tax refund fraud scheme whose "principal organizer" was identified as Dubai-based British national Sanjay Shah in Skatteforvaltningen, a.k.a. SKAT, Denmark's tax collection agency v. John van Merkensteijn, Richard Markowitz, Bernina Pension Plan Trust, RJM Capital Pension Plan Trust, 2321 Capital Pension Plan, Bowline Management Pension Plan, California Catalog Company Pension Plan, Clove Pension Plan, Davin Investments Pension Plan, Delvian LLC Pension Plan, DFL Investments Pension Plan, Laegeler Asset Management Pension Plan, Lion Advisory Inc. Pension Plan, Mill River Capital Management Pension Plan, Next Level Pension Plan, Rajan Investments LLC Pension Plan, Spirit on the Water Pension Plan, and Traden Investments Pension Plan at the U. S. District Court for the Southern District of New York.

Motion for Issuance of a Request for International Judicial Assistance to Obtain Evidence in the British Virgin Islands from Harneys Corporate Services Limited, Intershore Consult (BVI) Ltd., Intertrust Corporate Services (BVI) Limited, MMG Trust (BVI) Corp., Mossack Fonseca & Co. (BVI) Limited, by its liquidator, Deloitte Ltd. (BVI); Overseas Management Company Trust (BVI) Ltd., Sentinel International Management SA, and Vistra (BVI) Limited regarding an allegedly fraudulent 12.7 billion Danish Kroner tax refund fraud scheme whose "principal organizer" was identified as Dubai-based British national Sanjay Shah in Skatteforvaltningen, a.k.a. SKAT, Denmark's tax collection agency v. John van Merkensteijn, Richard Markowitz, Bernina Pension Plan Trust, RJM Capital Pension Plan Trust, 2321 Capital Pension Plan, Bowline Management Pension Plan, California Catalog Company Pension Plan, Clove Pension Plan, Davin Investments Pension Plan, Delvian LLC Pension Plan, DFL Investments Pension Plan, Laegeler Asset Management Pension Plan, Lion Advisory Inc. Pension Plan, Mill River Capital Management Pension Plan, Next Level Pension Plan, Rajan Investments LLC Pension Plan, Spirit on the Water Pension Plan, and Traden Investments Pension Plan at the U. S. District Court for the Southern District of New York.

Motion for Judgment by Confession in Don David Gold Mexico SA de CV, of Mexico v. SION Trading FZE, of Ras Al Khaimah, and Scotia International of Nevada Inc., of Utah, at the Third Judicial District Court for the County of Salt Lake, Utah.

Transcript of Argument and Ruling on Defendant's Motion To Dismiss regarding a dispute over the alleged misappropriation of Switzerland-domiciled Diligence Global Business Intelligence SA in Diligence Inc., a Delaware company majority owned by Cayman Islands-domiciled Information Security Investments Company v. Nicholas Day, a citizen of the United Kingdom residing in France, at the Court of Chancery of the State of Delaware.

Diligence Inc.'s Opposition to Nicholas Day's Motion to Dismiss regarding a dispute over ownership of Switzerland-domiciled Diligence Global Business Intelligence SA in Diligence Inc., a Delaware company majority owned by Cayman Islands-domiciled Information Security Investments Company v. Nicholas Day, a citizen of the United Kingdom residing in France, at the Court of Chancery of the State of Delaware.

Opposition to Defendant's Motion to Dismiss regarding allegations of negligence, professional malpractice, and fraudulent concealment in Ardent Harmony Fund Inc. (in Liquidation), of the Cayman Islands v. BDO Trinity Ltd., a.k.a. BDO Trinidad & Tobago, of Trinidad & Tobago, at the Supreme Court of the State of New York.

Opposition by eMblaze ONE Inc. and Jaspreet Mathur to Application to Conduct Discovery in Hedrick House Limited, of the British Virgin Islands v. eMblaze ONE Inc. and Jaspreet Mathur, a.k.a. Jas Mathur, for use in legal proceedings in England, filed at the U. S District Court for the Central District of California.

Diligence Inc.'s Motion for Partial Summary Judgment regarding a dispute over ownership of Switzerland-domiciled Diligence Global Business Intelligence SA in Diligence Inc., a Delaware company majority owned by Cayman Islands-domiciled Information Security Investments Company v. Nicholas Day, a citizen of the United Kingdom residing in France, at the Court of Chancery of the State of Delaware.

Defendant's Motion to Dismiss in Nicholas Day v. Diligence, Inc. at the Court of Chancery of the State of Delaware.

Defendant's Opposition to Plaintiff's Motion for Entry of a Status Quo Order regarding Switzerland-domiciled Diligence Global Business Intelligence SA in Diligence Inc., a Delaware company majority owned by Cayman Islands-domiciled Information Security Investments Company v. Nicholas Day, a citizen of the United Kingdom, at the Court of Chancery of the State of Delaware.

Plaintiff's Reply in Further Support of its Motion for Entry of Status Quo Order in Diligence Inc. v. Nicholas Day at the Court of Chancery of the State of Delaware.

Plaintiff's Motion for Entry of Status Quo Order in Diligence Inc., of Delaware v. Nicholas Day, a British national residing in Switzerland, at the Court of Chancery of the State of Delaware.

Motion by the Law Offices of Dominquez & Associates PA to withdraw as counsel for Kenneth Rijock "regarding the payment of legal services" in Steven Slom, of Israel v. Kenneth Rijock at the Circuit Court of the 11th Judicial Circuit, in and for Miami-Dade County, Florida.

SEC's Motion for Default Judgment regarding an unregistered offering of cryptocurrencies in U. S. Securities and Exchange Commission v. ICObox, which "is no longer registered as a corporation with the Cayman Islands and its registered agent for service of process has resigned with no replacement", and Nikolay Evdokimov at the U. S. District Court for the Central District Court of California.

Plaintiff's Motion to Compel Discovery regarding a complaint alleging fraud in Joseph Greco, as the substituted party for The Evolant Blind Trust v. Scotia International of Nevada Inc., of Utah; Max Warren Barber, of Utah; SubGallagher Investment Trust, of Wyoming; Patricia Moore, of Wyoming, individually and as Trustee of SubGallagher Investment Trust, and Michael A. Casey, of Texas, at the U. S. District Court for the Eastern District of Pennsylvania.

Notice of Removal, including a copy of the complaint seeking damages of $457,224 alleging failure to execute wire transfer requests in Jamal Hammoud, described as "the majority owner and principal of Milestones Capital, LLC" v. Société Générale de Banque au Liban, of Lebanon, at the U. S. District Court for the Southern District of New York.

SEC's Motion for an Order Freezing and Repatriating Assets in the U. S. Securities and Exchange Commission v. Steve M. Bajic, Rajesh Taneja, Norfolk Heights Ltd., Fountain Drive Ltd., Island Fortune Global Ltd., Crystalmount Ltd., Wisdom Chain Ltd., SSID Ltd., Sure Mighty Ltd., Tamarind Investments Inc., Kenneth Ciapala, Anthony Killarney, BlackLight SA, Christopher Lee McKnight, and Aaron Dale Wise at the U. S. District Court for the Southern District of New York.

Motion by Non-Party The Michaels Companies, Inc. to Quash Subpoenas and for Protection in Willis Electric Co., Ltd., of Taiwan v. Polygroup Ltd., of Macau; Polygroup Macau Limited, of the British Virgin Islands, and Polytree (HK) Co., Ltd., of Hong Kong, at the U. S. District Court for the Northern District of Texas.

Transcript of Hearing on Motion To Dismiss by Côte d'Azur Estate Corporation and BGO Foundation regarding allegations that a Swiss attorney misappropriated an asset in France worth €25 million after a client died in Lilly Lea Perry, 72, the widow of Israel Igo Perry v. Dieter Walter Neupert, described as "Senior Partner" of Neupert Vuille Partners law firm, in Zurich, Switzerland; Côte d'Azur Estate Corporation, of Delaware, and BGO Foundation, of Liechtenstein, at the Court of Chancery of the State of Delaware.

Motion for Preliminary Injunction and Temporary Restraining Order in Seabras 1 Bermuda Ltd., of Bermuda v. Seabras Group LLC and Partners Group Searbas, LLC at the U. S. Bankruptcy Court for the Southern District of New York.

Notice of Removal. including a copy of the complaint alleging the defendants were contracted "to watch the destruction of electronics" but failed to do so resulting in theft, in Apple, Inc. v. Allan & Associates Limited, A2 Global Risk Limited, and Bradley James Allan, all of Hong Kong, at the U. S. District Court for the Northern District of California.

Motion for a Temporary Restraining Order and Preliminary Injunction in YA II PN Ltd., of the Cayman Islands v. Taronis Technologies Inc. and Taronis Fuels Inc. at the U. S. District Court for the Southern District of New York.