Receiver's Reply to Zi Corporation's Memorandum in Opposition to Receiver's Motion for Contempt and for Sanction S
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION NIGHT BOX FILE D SECURITIES AND EXCHANGE COMMISSION , K' - 6 2006 Plaintiff, ;. t 4 MADDAX ~' . U~ACISDpldlMIA V. MICHAEL LAUER, LANCER MANAGEMENT GROUP, LLC, and LANCER MANAGEMENT GROUP II, LLC, Case No. 03-80612 CIV-MARRA Defendants, Jointly Administere d and LANCER OFFSHORE, INC ., LANCER PARTNERS, LP, OMNIFUND, LTD., LSPV, INC ., and LSPV, LLC , Relief Defendants . / In re : Chapter 11 Cas e LANCER PARTNERS L .P., Case No. : 04-8021 1 -CIV-MARRA Debtor. RECEIVER'S REPLY TO ZI CORPORATION'S MEMORANDUM IN OPPOSITION TO RECEIVER'S MOTION FOR CONTEMPT AND FOR SANCTION S Marty Steinberg, Esq ., the court-appointed receiver (the "Receiver") for the Lancer Entities' submits this Reply to Zi Corporation's Memorandum in Opposition to Receiver's Motion for Contempt and for Sanctions (the "Response Brief') . 'Lancer Management Group LLC ("Lancer Management"), Lancer Management Group II LLC ("Lancer Management II"), Lancer Offshore Inc . ("Offshore"), Omnifund Ltd . ("Omnifund"), LSPV Inc . ("Offshore LSPV"), LSPV LLC ("Partners LSPV"), Alpha Omega Group, Inc . ("AOG"), G .H. Associates LLC, and CLR Associates, LLC (the "Receivership Entities" ), and Lancer Pa rtners, L.P. ("Partners") . CASE NO. 03-80612 -CIV-MARRA /VITUNAC Case No.: 04-80211 -ClV-MARRA - Jointly Administere d 1. INTRODUCTION In a feeble attempt to hopefully avoid the inherent problems created for Zi Corp . ("Zi") by the Voting Rights Agreement ("VRA") it executed on July 15, 2004, coupled with this Court's Receivership Order and Case Management Order ("CMO"), Zi asserts futile and/or inapplicable legal doctrines and principles in its Response Brief as purported justification for the Court's denial of the Receiver's Motion for Contempt and for Sanctions (the "Contempt Motion").
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