Case 2:12-cv-01216-DSC Document 35 Filed 02/18/14 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
STUART A. WILLIAMS, Tmstee of
THE STUART A. AND FRANCINE W.
WILLIAMS REVOCABLE TRUST,
CEDE & CO., Nominee Name ofthe
Depository Tmst Company,
PLAINTIFF'S RESPONSE TO THE MOTION FOR LEAVE TO FILE REPLY
MEMORANDUM IN SUPPORT OF MOTION TO QUASH, OR
ALTERNATIVELY, MODIFY SUBPOENAS SERVED ON
NONPARTY HENRY GUSKY, LIQUIDATION TRUSTEE OF
THE PRESIDENT CASINOS, INC. LIQUIDATION TRUST AND
HIS AGENT, COMPUTERSHARE TRUST COMPANY, N.A.
The Plaintiff, Stuart A. Williams, Tmstee of The Stuart A. and Francine W. Williams
Revocable Tmst (the "Williams Trast") files the following Response to the Motion for Leave to
File Reply Memorandum in Support of Motion to Quash, or Altematively, Modify Subpoenas
Served on Nonparty Henry Gusky ("Gusky"), Liquidation Trustee ofthe President Casinos, Inc.
Liquidation Trust and His Agent, Computershare Tmst Company, N.A ("Computershare"). The
Williams Tmst submits that the Court should not grant Gusky and Computershare with leave to
file the Reply Memorandum. Similar to their Motion to Quash, the Reply Memorandum
continues the personal attacks on Mr. Williams and attempts to frastrate the Williams Tmst's
attempt to gather documents and communications relevant to the instant matter filed against
Cede & Co., nominee name ofthe Depository Trust Company ("Cede") in this Court.
Accordingly, the Court should not grant leave to file the Reply Memorandum.
Case 2:12-cv-01216-DSC Document 35 Filed 02/18/14 Page 2 of 3
In the event that the Court grants Gusky and Computershare with leave to file the Reply
Memorandum, it is still be clear that the Williams Tmst, as permitted in the Federal Rules of
Civil Procedure, served Subpoenas upon Gusky and Computershare in order to obtain relevant
documents and communications to ascertain how the mistake with the First Liquidation
Distribution was made. The Williams Tmst requests that the Court grant the Williams Trust with
leave to file a brief response to the Reply Memorandum and/or schedule a hearing on the Motion
WHEREFORE, the Williams Trast respectfully requests that this Court deny Gusky and
Computershare's request for leave to file the Reply Memorandum and order Gusky and
Computershare to respond to the Subpoena within ten (10) days ofany Order entered and deny
Gusky and Computershare's request for attomeys' fees. Altematively, the Williams Trust
requests that the Court grant the Williams Trust with leave to file a brief response to the Reply
Memorandum and/or schedule a hearing on the Motion to Quash.
Date: Febraary 18, 2014
/s/Danny P. Cerrone, Jr.
Allen M. Lopus, Esquire
Pa. I.D. #76544
Danny P. Cerrone, Jr., Esquire
Pa. I.D. #201091
CLARK HILL THORP REED
One Oxford Centre
301 Grant Street, 14* Floor
Pittsburgh, PA 15219-1425
Attorneys for Stuart A. Williams, trustee of
The Stuart A. and Francine W. Williams
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Case 2:12-cv-01216-DSC Document 35 Filed 02/18/14 Page 3 of 3
CERTIFICATE QF SERVICE
I hereby certify that, on this 18'*' day of Febmary 2014, the foregoing was electronically
filed with the Clerk of Courts through the CM/ECF system, which will send a notice of
electronic filing to all CM/ECF participants.
/s/ Danny P. Cerrone, Jr.
Danny P. Cerrone, Jr.