Case 1:17-cv-02542-ARR-CLP Document 7 Filed 06/19/17 Page 1 of 2 PageID #: 151

ROGER L. FIDLER
Attorney at Law
12 Marlboro Road
West Milford , NJ 07421
(201) 220-8734
(201) 464-7943 (Fax)
rfidler0099@aol.com

VIA ECF FILING AND EMAIL

June 19, 2017

The Honorable Allyne R. Ross, U.S.D.J.

United States District Court
Eastern District of New York
225 Cadman Plaza
Brooklyn, New York 11201

RE: Dolat Ventures, Inc. v. VStock Transfer LLC et al.

Docket No. 1:17-cv-02542-ARR-CLP

Dear Judge Ross:

We represent Dolat Ventures, Inc. (Dolat) in the above referenced matter. I submit this letter to
request a modification of the Courts Order entered in response to the letter of Steven A.
Feldman, Esq. dated June 15, 2017.

Our firm undertook to provide an opportunity for all defendants in this case to voluntarily accept
service pursuant Fed. R. Civil P. 4(d) on or about the filing date of the Complaint on April 27,
2017 which would require service by July 26, 2017 to avoid dismissal of domestic defendants
under Fed. R. Civ. P. 4(m). We have yet to request service of domestic defendants through
formal process but can send to the relevant U.S. Marshalls the Summonses and Complaints by
June 20, 2017 although realistically for service to effected would take some time.

It should be noted that of the 37 defendants, 20 of them are believed to be resident in Ireland
based upon the addresses provided to Dolats transfer agent, VStock Transfer LLC. Service in
accordance with Irish law would take some considerable additional time.

Under these circumstances, as well as the unusual nature of these issuances, in particular the
issuance of stock for consulting services to defendant Schwebel, which at various times
apparently accounted for up to over 40% of the then issued and outstanding shares in the
Company, and the indication in a May 10, 2017 press release from the Connecticut U.S.
Attorneys Office naming Dolat as a vehicle used by prior management in the time period of
2011 to 2015 during which time these unusually large issuances were made to Rivie Schwebel,
coupled with defendant Schwebels apparent failure to properly report these issuances under
SEC Rules, it might be advisable to allow additional time for service of the Summonses and
Case 1:17-cv-02542-ARR-CLP Document 7 Filed 06/19/17 Page 2 of 2 PageID #: 152

Complaints upon all defendants which should require no more than three weeks so that we can
determine how many of them in fact existed, and the relationships between them, if any.

We will attempt to serve defendants as indicated in Your Honors Order and had previously sent
the Rule 4(d) requests for voluntary acceptance to all of them at mostly the same addresses
where we will attempt service. So far we have heard from four defendants, all in the United
States and formal acceptance of service from I believe one.

Thank you for your considerations of these additional facts.

Respectfully submitted,
Roger L. Fidler, Esq.