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  • Letter From Haftar's Legal Counsel PDF

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    Umar Farooq
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    This letter summarizes two cases, Elzagally et al v. Haftar and al-Suyid et al v. Hifter et al, in which General Khalifa Hifter is named as a defendant. The letter requests that the court allow General Hifter to enter and respond to the cases, as he was previously unaware of them. It also notes that General Hifter intends to file motions to appear pro hac vice and respond to the complaints and magistrate reports in the two cases. The letter requests an additional two weeks for General Hifter to file these responses.

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    This letter summarizes two cases, Elzagally et al v. Haftar and al-Suyid et al v. Hifter et al, in which General Khalifa Hifter is named as a defendant. The letter requests that the court allow General Hifter to enter and respond to the cases, as he was previously unaware of them. It also notes that General Hifter intends to file motions to appear pro hac vice and respond to the complaints and magistrate reports in the two cases. The letter requests an additional two weeks for General Hifter to file these responses.

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    © All Rights Reserved
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    230 views2 pages

    Letter From Haftar's Legal Counsel PDF

    Uploaded by

    Umar Farooq
    This letter summarizes two cases, Elzagally et al v. Haftar and al-Suyid et al v. Hifter et al, in which General Khalifa Hifter is named as a defendant. The letter requests that the court allow General Hifter to enter and respond to the cases, as he was previously unaware of them. It also notes that General Hifter intends to file motions to appear pro hac vice and respond to the complaints and magistrate reports in the two cases. The letter requests an additional two weeks for General Hifter to file these responses.

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    of 2

    Case 1:20-cv-00170-LMB-JFA Document 33 Filed 07/31/20 Page 1 of 2 PageID# 165

    230 PARK AVENUE, SUITE 440


    DUNCAN P. LEVIN NEW YORK, NEW YORK 10169
    DIRECT DIAL: 646-445-7825
    [email protected]
    212-330-7626
    FACSIMILE: 212-422-3305

    July 31, 2020

    BY ECF

    Honorable Leonie M. Brinkema


    U.S. District Judge
    Albert V. Bryan U.S. Courthouse
    401 Courthouse Square
    Alexandria, VA 22314

    Re: Elzagally et al v. Haftar


    U.S. District Court for the Eastern District of Virginia
    1:19-cv-00853-LMB-MSN

    al-Suyid et al v. Hifter et al
    U.S. District Court for the Eastern District of Virginia
    1:20-cv-00170-LMB-JFA

    Dear Judge Brinkema:

    As this Court is aware, General Khalifa Hifter, commander of the Libyan National Army, is
    named as a defendant in both of the above-captioned cases. Gen. Hifter is now aware of these two
    cases, and he has retained the undersigned to represent him before this Court. In turn, this Firm has
    asked Edward Ungvarsky, Esq. of Ungvarsky Law, PLLC to serve as local counsel.

    Each case was referred to a U.S. Magistrate Judge who then issued a report outlining proposed
    findings of facts and recommendations to this Court. In Elzagally et al v. Haftar, the Magistrate
    recommended that the Court dismiss plaintiff’s motion for default judgment. However, in al-Suyid et
    al v. Hifter et al., the Magistrate recommended that the Court enter default judgment in favor of the
    plaintiffs.

    As Gen. Hifter did not receive service of the complaints or the reports and recommendations
    and was previously unaware of the two cases, we respectfully request that this Court allow Gen. Hifter
    to enter these matters and respond substantively and procedurally to the complaints and Magistrate
    reports and recommendations. Furthermore, as plaintiffs’ complaint al-Suyid et al v. Hifter et al
    acknowledges, Gen. Hifter left Virginia almost a decade ago and has been resident in Libya since 2011.
    Accordingly, Gen. Hifter does not consent to any assertion of personal jurisdiction in these matters.
    Case 1:20-cv-00170-LMB-JFA Document 33 Filed 07/31/20 Page 2 of 2 PageID# 166

    Honorable Leonie M. Brinkema


    July 31, 2020
    Page 2

    If permitted by this Court, Gen. Hifter therefore intends to answer to the complaints and reports and
    recommendations in these matters with formal motions or other responsive pleadings.

    Counsel for Gen. Hifter in these matters also intends to file a Motion for Leave to Appear
    Pro Hac Vice before this Court in the above-captioned cases. Further, in light of the similar factual
    and legal issues involved in these two cases, and similar requests for relief, Gen. Hifter may seek to
    move the Court to consolidate the two cases under Rule 42 of the Federal Rules of Civil Procedure.

    For all the foregoing reasons, undersigned counsel for Gen. Hifter seeks leave of this Court
    to enter the above-captioned cases, and respectfully requests two additional weeks to file the formal
    motions requesting to appear pro hac vice and to respond to the complaints and magistrate reports
    and recommendations in those matters.

    Respectfully submitted,

    Duncan P. Levin, Esq.

    cc: All parties (via ECF)

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