Federal civil case Kevin D. Kent, in his capacity as Receiver  v. Emperor Global Enterprises, LLP, et al., No. 2:21-cv-13099 (D.N.J.)

On June 29, 2021, the Receiver filed a Complaint against Emperor Global Enterprises LLP (“Emperor Global”), EGE Limited, and their directors, Michael P. Michael and Georgia Iacovou, seeking to recover Receivership Assets transferred to Emperor Global and EGE Limited. 
​The following are select filings from this federal civil case:

2021-06-29 [1] Complaint
2021-10-14 [13] Stipulation and Order for Additional Time for Defendants to Respond to the Complaint
2021-10-14 [14] Letter to Court Re Stipulated Extension to Respond to Complaint and Mediation
2021-10-20 [17] Order Scheduling Settlement Conference
2022-06-20 [36] Motion to Dismiss for Lack of Jurisdiction
​2022-06-20 [37] Motion to Transfer Case to Virginia
2022-07-05 [44] Receiver’s Response in Opposition to Motion to Transfer
2022-07-14 [48] Defendant’s Reply in Support of Motion to Transfer
2022-07-25 [52] Receiver’s Sur-Reply in Further Opposition to Motion to Transfer
2022-11-02 [66] Opinion and Order Denying Motion to Transfer
2023-07-25 [100] Order Denying Motion to Dismiss
2024-12-10 [136] Motion to Approve Settlement

Federal civil case Kevin D. Kent, in his capacity as Receiver v. Medical Consultants Instructional Training Center, et al.,
​No. 2:21-cv-13104 (D.N.J.)

​On June 29, 2021, the Receiver filed a Complaint against Medical Consultants Instructional Training Center, Medical Construction Industrial Training Center, LLC, MCITC School of the Trades LLC d/b/a Medical Consultants Instructional Training Center and their owner, Carol Johnston, seeking to recover loans paid to/on behalf of the Defendants from Receivership Assets, and which are subject to repayment pursuant to the terms of promissory notes issued by Medical Consultants Instructional Training Center.
The following are select filings from this federal civil case:
2021-06-29 [1] Complaint
2021-09-07 [8] Motion to Dismiss Complaint
2021-09-20 [9] First Amended Complaint
2021-10-05 [12] Stipulation and Order Regarding Additional Time for Defendants to File an Answer to Amended Complaint
2021-11-04 [13] Answer to  Complaint
2021-11-15 [14] Order Regarding Initial Scheduling Conference
2022-07-05 [20] Motion to Approve Settlement
2022-08-04 [28] Order Approving Settlement

Federal civil case Kevin D. Kent, in his capacity as Receiver v. Richard Galvin, et al., No. 2:21-cv-13105 (D.N.J.)

​On June 29, 2021, the Receiver filed a Complaint against Richard C. Galvin and several of his entities, including Galvin Investment Company (“GIC”), Gilman Metals Company, LLC (“Gilman Metals”), Galvin Metals Company, LLC (“Galvin Metals”) and RG Coastal LLC (“RG Coastal”) seeking to recover Receivership Assets transferred to and/or on behalf of these defendants, and seeking damages in connection with conduct on the part of certain of the defendants which caused harm to the Receivership Parties.
The following are select filings from this federal civil case:
​2021-06-29 [1] Complaint
2022-04-15 [23] Defendants’ Amended Answer and Counterclaims
2022-05-06 [25] Receiver’s Motion to Dismiss Counterclaims
2022-06-08 [29] Defendants’ Response to Motion to Dismiss Counterclaims
2022-06-21 [30] Receiver’s Reply in Support of Motion to Dismiss Counterclaims
2022-10-13 [36] Order Granting Motion to Withdraw as Counsel for Defendants
2022-12-07 [39] Order Staying Counterclaims
2022-12-09 [40] Application to Strike Counterclaims
2022-12-12 [41] Request for Entry of Default
2022-12-12 Clerk’s Entry of Default Against Corporate Defendants
2024-06-28 [76] Motion to Approve Settlement
2024-07-23 [80] Order Approving Settlement

Federal civil case Kevin D. Kent, in his capacity as Receiver v. Agostinho Calcada, No. 2:21-cv-18396 (D.N.J.)

On October 11, 2021, the Receiver filed a Complaint against Agostinho Calcada, seeking to recover loans paid to/on behalf of Defendant from Receivership Assets, and which are subject to repayment pursuant to the terms of a promissory note.
The following are select filings from this federal civil case:
2021-10-11 [1] Complaint
2021-12-08 [14] Answer to Complaint
2021-12-13 [15] Order Regarding Initial Scheduling Conference
2022-06-29 [23] Amended Complaint
2022-07-18 [28] Answer to Amended Complaint
2023-04-27 [34] Receiver’s Motion for Summary Judgment
​2023-07-06 [47] Defendant’s Response to Receiver’s Motion for Summary Judgment
2023-08-07 [48] Receiver’s Reply in Support of Motion for Summary Judgment
​​2024-04-25 [55] Order Granting Receiver’s Motion for Summary Judgment
2024-07-10 [62] Clerk’s Order Taxing Costs
2024-07-24 [63] Order Awarding Attorneys’ Fees
2024-08-27 [64] Motion to Approve Settlement

Federal civil case Kevin Dooley Kent, in his capacity as Receiver v. Renato Iregui, et al., No. 2:21-cv-20691 (D.N.J.)

​On December 23, 2021, the Receiver filed a Complaint against Renato Iregui, Kelly Lynn Ulmer, Iregui LLC, Swiss Allied Capital Partners, Inc., Swiss Allied Trust, Inc., Investment Consultants PLLC, and Orbit Global Media S.L. seeking to recover Receivership Assets transferred to and/or on behalf of these defendants, and seeking damages in connection with conduct on the part of certain of the defendant which caused harm to the Receivership Parties.
The following are select filings from this federal civil case:
2021-12-23 [1] Complaint
2022-04-29 [12] Renato Iregui Answer to Complaint
2022-05-20 [14] Amended Complaint
2022-07-18 [23] Kelly Ulmer Answer to Complaint
2022-08-01 [25] Request for Entry of Default Against Corporate Defendants
2022-08-03 Clerk’s Entry of Default Against Corporate Defendants
2024-02-16 [63] Motion to Approve Settlement with Kelly Ulmer
2024-02-16 [72] Order Approving Settlement with Kelly Ulmer
​2024-12-17 [81] Motion for Summary Judgment Against Renato Iregui
​2024-12-17 [82] Motion for Default Judgment Against Iregui LLC, Orbit Global Media S.L., and Swiss Allied Trust & Estate Services, Inc.
2025-01-07 [83] Renato Iregui’s Response in Opposition to Motion for Summary Judgment
2025-01-14 [86] Receiver’s Reply in Support of Motion for Summary Judgment

Federal civil case Kevin Dooley Kent, in his capacity as Receiver v. Richard Shawn Ellis, et al., No. 2:21-cv-20754 (D.N.J.)

​On December 23, 2021, the Receiver initiated an action against Richard Shawn Ellis, Rose & Thorn Cowlitz, LLC, Rose & Thorn HQ, LLC, Rose & Thorn Denver, LLC, Mainspring, LLC, Semper Genus LLC, Frolic & Revelry, LLC, Hotel Carbon HQ, Inc. and Hotel Carbon CO 19.06, LLC. The lawsuit seeks to recover Receivership Assets transferred to and/or on behalf of these defendants, some of which were in the form of loans paid to and/or on behalf of certain of these defendants which are subject to repayment. The lawsuit also seeks damages in connection with conduct on the part of certain of the defendant which caused harm to the Receivership Parties.
The following are select filings from this federal civil case:
2021-12-31 [4] Redacted Complaint
2022-03-15 [26] Defendants’ Motion to Transfer Case to District of Colorado
2022-03-15 [29] Defendants’ Motion to Dismiss
2022-04-04 [35] Receiver’s Response to Motion to Transfer
2022-04-11 [37] Defendants’ Reply In Support of Motion to Transfer
2022-10-07 [42] Letter from Defendants’ Supplementing Motion to Transfer
2023-01-04 [43] Opinion and Order Denying Motion to Transfer
2023-09-21 [74] Motion to Approve Settlement
​2023-10-02 [78] Order Approving Settlement
​

Federal civil case Kevin Dooley Kent, in his capacity as Receiver v. Jordan Denise, et al., No. 2:22-cv-00388 (D.N.J.)

​On January 26, 2022, the Receiver filed a Complaint against Jordan Denise, Entercore, Inc. and Orange Splendor, Inc. seeking to recover Receivership Assets transferred to and/or on behalf of these defendants.
The following are select filings from this federal civil case:
2021-01-26 [1] Complaint
2022-05-24 [8] Answer to Complaint by Jordan Denise
2022-10-11 [18] Request for Entry of Default Against Corporate Defendants
2022-10-12 Clerk’s Entry of Default Against Corporate Defendants
2023-01-03 [24] Plaintiff’s Request for Leave to File Motion to Compel and for Sanctions
2023-01-04 [25] Order Granting Leave to File Motion to Compel and for Sanctions
2023-01-17 [26] Receiver’s Motion to Compel Discovery and for Sanctions Against Jordan Denise
​2023-12-06 [64] Receiver’s Motion for Sanctions Against Jordan Denise​
2024-01-09 [68] Defendant’s Response to Motion for Sanctions
2024-01-16 [73] Receiver’s Reply In Support of Motion for Sanctions
2024-01-24 [75] Order Regarding Motion for Sanctions

Federal civil case Surefire Dividend Capture, LP and Kevin Dooley Kent, Esq., as Receiver v. The Nottingham Company, et al.,
​No. 19-CV-04088-BMS (E.D. Pa.)

​On February 10, 2022, the Receiver filed a Motion for Leave to File a Complaint in Intervention and to Lift Stay, seeking permission to file a complaint against The Nottingham Company and its CEO, Kip Meadows, asserting claims for breach of contract, indemnification, negligence, deepening insolvency and aiding and abetting breach of fiduciary duty. The motion was granted on April 11, 2022, with the stay to be lifted on or about June 10, 2022. 
The following are select filings from this federal civil case:
2022-02-10 [131] Motion for Leave to File Complaint in Intervention and to Lift Stay
2022-04-11 [139] Order Granting Receiver’s Motion for Leave to File Complaint in Intervention and to Lift Stay
2022-06-15 [141] Stipulation of Dismissal of Claims Against Brenda Smith by Surefire
2022-06-15 [142] Stipulation of Dismissal of Claims Against Receivership Parties by Surefire
2022-06-15 [143] Receiver’s Amended Complaint in Intervention
2022-08-02 [155] Surefire’s Amended Complaint
2022-09-06 [161] Defendants’ Answer to Receiver’s Complaint
2022-10-14 [163] Answer of Nottingham Company and Kip Meadows to Amended Surefire Complaint
2024-03-05 [195] Receiver’s Motion for Partial Summary Judgment Against The Nottingham Company
2024-03-05 [196] Defendants’ Motion for Summary Judgment
2024-03-19 [201] Receiver’s Response to Defendants’ Motion for Summary Judgment
2024-03-19 [202] Defendants’ Response to Receiver’s Motion for Partial Summary Judgment
2024-03-22 [203] Surefire’s Response to Defendants’ Motion for Summary Judgment
2024-03-25 [204] Receiver’s Reply in Support of Motion for Partial Summary Judgment
​2024-05-31 [220] Order Granting Receiver’s Motion for Partial Summary Judgment and Denying Defendants’ Motion for Summary Judgment

Federal civil case Kevin Dooley Kent, in his capacity as Receiver v. Ronald Hightower, et al., No. 2:22-cv-01195 (D.N.J.)

On March 4, 2022, the Receiver filed a Complaint against Ronald Hightower, Janet Hightower, Blackburn International Limited and Vestimenta Investments, LLC seeking to recover Receivership Assets transferred to and/or on behalf of these defendants.
The following are select filings from this federal civil case:
2022-03-04 [1] Complaint
2022-05-31 [17] Motion to Dismiss
2022-07-05 [21] Receiver’s Response in Opposition to Motion to Dismiss
2022-07-25 [22] Reply Brief In Support of Motion to Dismiss
2022-12-30 [24] Order Denying Motion to Dismiss
2023-02-17 [37] Receiver’s Motion to Dismiss Counterclaims
2023-03-06 [38] Defendants’ Response to Motion to Dismiss Counterclaims
2023-03-13 [39] Receiver’s Reply in Support of Motion to Dismiss Counterclaims
2023-07-25 [48] Order Denying Motion to Dismiss and Staying Counterclaims
2024-06-05 [88] Motion to Withdraw as Counsel for Defendants
​2024-06-25 [89] Order Granting Motion to Withdraw as Counsel for Defendants
2024-08-09 [94] Request for Entry of Default Against Corporate Defendants
2024-08-12 Clerk’s Entry of Default Against Corporate Defendants

Federal civil case Kevin Dooley Kent, in his capacity as Receiver v. Jeffrey Bydalek, et  al., No 2:22-cv-01811 (D.N.J.)

On March 31, 2022, the Receiver filed a Complaint against Jeffrey Bydalek, Credit the Americas LP, FX Algo LLC, Hurricane Holdings, Inc. and M3 Media Group, Inc.
The following are select filings from this federal civil case:
2023-01-09 [28] Motion to Approve Settlement
2023-01-20 [35] Order Approving Settlement

Federal civil case Kevin Dooley Kent, in his capacity as Receiver v. Larry Hooper, et  al., No 2:22-cv-01876 (D.N.J.)

​On April 1, 2022, the Receiver filed a Complaint against Larry Hooper and Hooper Ranch, seeking to recover damages relating to their sale of certain minerals owned by Receivership Parties being stored on their property, asserting claims for conversion, breach of contract and unjust enrichment.
The following are select filings from this federal civil case:
2022-04-01 [1] Complaint
​2022-07-11 [8] Motion to Approve Settlement
2022-08-29 [15] Order Approving Settlement

Federal civil case Kevin Dooley Kent, in his capacity as Receiver v. Edward C. Britton, et al., No. 2:22-cv-02845 (D.N.J.)
​

​On May 16, 2022, the Receiver filed a Complaint against Edward C. Britton and Natural Impact Health and Fitness LP seeking to recover Receivership Assets transferred to and/or on behalf of these defendants.
The following are select filings from this federal civil case:
​2022-05-16 [1] Complaint
2022-10-12 [5] Plaintiff’s Request for Entry of Default
2022-10-14 Clerk’s Entry of Default
2023-01-04 [6] Plaintiff’s Motion for Default Judgment
2023-08-16 [8] Order Entering Default Judgment Against Defendants
2023-09-15 [10] Request for Award of Pre- and Post-Judgment Interest
2023-10-04 [11] Amended Default Judgment Award

Federal civil case Kevin Dooley Kent, in his capacity as Receiver v. Hector Valdes, et al., No. 2:23-cv-20475 (D.N.J.)

​On September 19, 2023, the Receiver filed a Complaint against Hector Valdes, Bluwater Holdings Corp., Doggtek, LLC, FOGO Resources, Terranovus Corp., Underground  Resources, Ltd., Valdesco, Ltd., and ZROC International, Ltd. seeking to recover Receivership Assets transferred to and/or on behalf of these defendants.
The following are select civil filings from this federal civil case:
2023-09-19 [1] Complaint
2024-01-03 [14] Defendants’ Answer to the Complaint