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Anonymous ID: 19fab8 July 31, 2018, 12:44 p.m. No.2374333   🗄️.is 🔗kun   >>4367 >>4497 >>4561

https://www.cyber-berkut.ru/docs/04.11.16/50-main.pdf

 

Case 1:11-cv-02794-KMW Document 50 Filed 04/27/12 Page 1 of 2

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

———————————————————-)(

YULIA TYMOSHENKO,

Plaintift:

vs. Civil Action No.: 11-2794 (AJN)

DMYTRO FIRTASH, et al.

Defendants.

———————————————————)(

MOTION TO DISMISS OF DEFENDANT

VULCAN PROPERTIES INC.

Pursuant to Federal Rule of Civil Procedure 12(b), defendant Vulcan Propeliies Inc.

("Vulcan") hereby moves to dismiss the Amended Complaint ofplaintiffYulia Tymoshenko

("Plaintiff'). For the reasons set forth in the accompanying Memorandum of Law and those fully

set forth in the motion to dismiss filed by defendants Paul Manafort, Brad Zackson, CMZ

Ventures, LLC, the Dynamic Group and Barbara Ann Holdings LLC (which are adopted and

joined by Vulcan), Vulcan respectfully requests that the Court grant this motion and dismiss with

prejudice all claims in the Amended Complaint as against Vulcan.

Case 1:11-cv-02794-KMW Document 50 Filed 04/27/12 Page 2 of 2

Dated:

TO:

April 27, 2012

Kenneth Foard McCallion, Esq.

McCallion & Associates LLP

Attorneys for Plaintiff

100 Park Avenue

16th Floor

New York, New York 10017

(646) 366-0880

Respectfully submitted,

GOLDBERG WEPRIN FINKE

GOLDSTEIN, LLP

1501 Broadway - 22"d Floor

New York, New York 10036

Phone: (212) 221-5700

Fax: (212) 301-6532

Email: mhearleWlllwflllaw.com

Attorneys for Defendant

Vulcan Properties Inc.

Anonymous ID: 19fab8 July 31, 2018, 12:46 p.m. No.2374372   🗄️.is 🔗kun   >>4404 >>4488 >>4534 >>4650 >>4867

>>2374296

NICE FIND

  1. Defendant PAUL J. MANAFORT is a well-known Washington D.C.

lobbyist and political consultant. He is the senior partner in the firm Davis, Manafort and

Freedman. Manafort also worked in Ukraine on various political campaigns, including the

successful 2010 presidential campaign of Victor Yanukovich, who is the President of Ukraine at

present. Manafort played a key role in the defendants’ conspiracy and racketeering enterprise by

assisting Firtash to become a major “investor” and silent partner in defendants CMZ Ventures

(sometimes referred to as “ZMC Investors”), Group DF and their affiliated companies, through

which Firtash and his associates were able to money launder a large portion of the funds that

Firtash, Group DF and RUE were skimming from numerous Gazpron/Naftogaz natural gas

transactions, as well as the windfall payments and profits worth approximately $3.5 billion that

they received as a result of the corrupt transactions and breaches of fiduciary duties that resulted

in the Stockholm Arbitration award, as described below in greater detail. These monies were

then laundered through various New York based bank accounts under the guise of otherwise

legitimate real estate and other investment activities in New York and elsewhere in the United

States, and the contracts, agreements, meetings, discussions and electronic communications (e.g.,

computer, email and fax transmissions) relating to said money laundering and investment

activities were primarily conducted through defendants’ offices located at 1501 Broadway, 25th

floor. Each of the defendants had substantial and purposeful contacts with New York in that the

defendants either were based at the New York offices (“the New York defendants”) or, as to the

defendants who were based elsewhere, they had the New York defendants act as their agents

with regard to all activities of their racketeering enterprise that were conducted from the New

York offices.

Anonymous ID: 19fab8 July 31, 2018, 12:54 p.m. No.2374481   🗄️.is 🔗kun   >>4495 >>4587 >>4618

Didn't Q say something about learning Russian?

https://www.cyber-berkut.ru/en/index_02.php

 

15.04.2015 Photos of the Western Military Inspectors in Ukraine

We, CyberBerkut, remind all World that war in Ukraine, no less than the Maidan 2013 - 2014, are entirely organised and gurus of "colour revolutions" are co-ordinated by the Western Military experts, and. For all "faithless" and "gone blind", confirming to all told by us earlier - We, CyberBerkut, publish photos of the Western Military Inspectors in Ukraine: