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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA ex
rel. KAMAL MUSTAFA AL-SULTAN,
Plaintiff/Relator,
v.
THE PUBLIC WAREHOUSING
COMPANY, K.S.C., et al.,
Defendants.
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CIVIL CASE NO.
1:05-CV-02968-TWT
DEFENDANT TAREK ABDUL AZIZ SULTAN AL-ESSA’S MOTION TO
ADOPT CO-DEFENDANT THE PUBLIC WAREHOUSING COMPANY,
K.S.C.’S MOTION TO TRANSFER VENUE TO THE EASTERN DISTRICT
OF PENNSYLVANIA, PURSUANT TO 28 U.S.C. § 1404(a)
Defendant Tarek Abdul Aziz Sultan Al-Essa (“Sultan”), by and through his
counsel, hereby moves to adopt co-Defendant The Public Warehousing Company,
K.S.C., a/k/a Agility’s (“PWC”) Motion to Transfer Venue to the Eastern District
of Pennsylvania, Pursuant to 28 U.S.C. § 1404(a), and PWC’s brief and other
materials in support thereof (Dkt. 164), filed on July 18, 2016.
Relator Kamal Mustafa Al-Sultan (“Relator”) filed the initial complaint in
this action under seal on November 18, 2005, naming Mr. Sultan as well as PWC,
The Sultan Center Food Products Company, K.S.C., and two other individuals as
Case 1:05-cv-02968-TWT Document 203 Filed 08/22/16 Page 1 of 5
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defendants. (See Dkt. 1.) On November 13, 2009, the government officially
intervened in this action (Dkt. 65), and subsequently filed its Complaint in
Intervention and its First Amended Complaint in Intervention on January 5, 2011
and September 30, 2011, respectively. (See Dkts. 71, 78.) Neither of the
government’s complaints names Mr. Sultan as a defendant. Nonetheless, Mr.
Sultan has standing to file this motion because he remains a defendant in this
action as a result of Relator’s claims against him, and, accordingly, the legal and
factual arguments raised by co-Defendant PWC in support of transferring this case
to the Eastern District of Pennsylvania apply with equal force to him.
For the foregoing reasons, Mr. Sultan respectfully requests that the Court
allow him to join in PWC’s Motion to Transfer Venue to the Eastern District of
Pennsylvania, Pursuant to 28 U.S.C. § 1404(a), and PWC’s brief and other
materials in support thereof (Dkt. 164), and to adopt the same as his own.
Dated: August 22, 2016 Respectfully submitted,
s/ Richard Marmaro
Richard Marmaro (admitted Pro Hac Vice)
Cal. Bar No. 091387
Matthew E. Sloan (admitted Pro Hac Vice)
Cal. Bar No. 165165
Emily Ludmir Aviad (admitted Pro Hac Vice)
Cal. Bar No. 251995
SKADDEN ARPS SLATE MEAGHER & FLOM LLP
300 S. Grand Avenue, Suite 3400
Los Angeles, California 90071-3144
Case 1:05-cv-02968-TWT Document 203 Filed 08/22/16 Page 2 of 5
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Telephone: (213) 687-5000
Facsimile: (213) 687-5600
Dated: August 22, 2016 Respectfully submitted,
s/ Kristin N. Tahler
Kristin N. Tahler (admitted Pro Hac Vice)
QUINN EMANUEL URQUHART & SULLIVAN, LLP
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
Dated: August 22, 2016 Respectfully submitted,
s/ Richard H. Deane, Jr.
Richard H. Deane, Jr.
Ga. Bar No. 214875
Lucas W. Andrews
Ga. Bar No. 019533
JONES DAY
1420 Peachtree Street, N.E., Suite 800
Atlanta, Georgia 30309-3053
Telephone: (404) 521-3939
Facsimile: (404) 581-8330
Attorneys for Defendants
The Public Warehousing Company, K.S.C., and
Tarek Abdul Aziz Sultan Al-Essa
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LOCAL RULE 5.1 CERTIFICATION
I hereby certify that this document has been prepared in Times New
Roman 14-point font in accordance with Local Rule 5.1.
Dated: August 22, 2016 Respectfully submitted,
s/ Richard Marmaro
Richard Marmaro
Attorney for Defendants
The Public Warehousing Company, K.S.C., and
Tarek Abdul Aziz Sultan Al-Essa
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CERTIFICATE OF SERVICE
I hereby certify that on this day I have caused a copy of the
foregoing document to be electronically filed with the Clerk of Court using
the CM/ECF system, which will automatically send email notification of such
filings to all counsel of record.
This 22nd day of August, 2016.
s/ Richard Marmaro
Richard Marmaro
Case 1:05-cv-02968-TWT Document 203 Filed 08/22/16 Page 5 of 5
