Jeffrey A. Carr 

PEPPER HAMILTON LLP 

(A Pennsylvania Limited Liability Partnership) 

Suite 400 

301 Carnegie Center 

Princeton, NJ 08543-5276 

(609) 452-0808 

Counsel for Defendants, Semprae Laboratories, Inc. 

(improperly plead as Semprae Pharmaceuticals), 

Rachel Scherl, Mary Jaensch, The Jannick Group, LLC 

(improperly plead as The Jannick Group), Ira Lubert, 

Quaker Bioventures and Independence Capital 

Partners, Inc. (improperly plead as Independence Capital Partners) 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEW JERSEY 

HAROLD P. MINTZ D/B/A 

ENHANCEMENT ASSOCIATES, 

Plaintiff,

v. 

SEMPRAE PHARMACEUTICALS, NEW 

SPRING CAPITAL PARTNERS, ZEV 

SCHERL, RACHEL SCHERL, MARY 

JAENSCH, THE JANNICK GROUP, IRA 

LUBERT, QUAKER BIOVENTURES, 

INDEPENDENCE CAPITAL PARTNERS, 

Defendants.

CIVIL ACTION NO. ________________ 

NOTICE OF REMOVAL 

PLEASE TAKE NOTICE that pursuant to 28 U.S.C. §§ 1446 and 1331, 

Defendants, Semprae Laboratories, Inc. (improperly plead as Semprae Pharmaceuticals), Rachel 

Scherl, Mary Jaensch, The Jannick Group, LLC (improperly plead as The Jannick Group), Ira 

Lubert, Quaker Bioventures and Independence Capital Partners, Inc. (improperly plead as 

Independence Capital Partners) (collectively referred to as the “Defendants”), through their 

Case 2:10-cv-03937-KSH-PS Document 1 Filed 08/03/10 Page 1 of 73 PageID: 1
-2- 

#12923091 v1 

undersigned counsel, and with the consent of all other defendants, New Spring Capital Partners 

and Zev Scherl (collectively referred to as the “New Spring Defendants”), file this Notice of 

Removal in the office of the Clerk of the United States District Court for the District of New 

Jersey. 

Defendants, by their undersigned counsel, state: 

1. On June 16, 2010, Plaintiff, Harold P. Mintz, d/b/a Enhancement 

Associates (“Plaintiff”) filed a Complaint against Defendants and the New Spring Defendants in 

the New Jersey Superior Court, Bergen County, which was docketed as BER-L-5950-10. A true 

and correct copy of all process, pleadings and orders, including the Plaintiff’s Complaint, are 

attached hereto as Exhibit A. 

2. This is a civil action over which this Court has original jurisdiction as it 

arises under the laws of the United States as provided in 28 U.S.C. § 1331. In particular, 

Plaintiff presents thirteen counts in his Complaint, including alleged violations of the Racketeer 

Influenced and Corrupt Organization Act, 18 U.S.C. § 1961-1968 (“RICO”) and the Hobbs Act, 

18 U.S.C. § 1951. Exhibit A, Complaint at the “Fifth Claim for Relief,” ¶¶ 134-141. 

3. On July 6, 2010, Quaker BioVentures was served with a copy of the 

Complaint. This is the earliest date any of the Defendants or New Spring Defendants was served 

or otherwise received notice of the Complaint. Thus, in accordance with 28 U.S.C. §1446(b), 

this Notice of Removal is being “filed within thirty days after receipt by the defendant, through 

service or otherwise, of a copy of an amended pleading, motion, order or other paper from which 

it may first be ascertained that the case is one which is or has become removable.” 

4. The New Spring Defendants, through their counsel, Aaron Krauss, Esquire 

of Cozen O’Connor, consent to Defendants’ removal of this action. 

Case 2:10-cv-03937-KSH-PS Document 1 Filed 08/03/10 Page 2 of 73 PageID: 2
-3- 

#12923091 v1 

5. Pursuant to 28 U.S.C. §1446(d), written notice of this removal is being 

given promptly to all parties and a copy of this Notice of Removal is being filed with the Clerk 

of the Superior Court of New Jersey, Bergen County, Law Division. 

Respectfully submitted, 

 s/ Jeffrey A. Carr 

Jeffrey A. Carr 

PEPPER HAMILTON LLP 

(A Pennsylvania Limited Liability Partnership) 

Suite 400 

301 Carnegie Center 

Princeton, NJ 08543-5276 

(609) 452-0808 

 

Counsel for Defendants, Semprae Laboratories, Inc. 

(improperly plead as Semprae Pharmaceuticals), 

Rachel Scherl, Mary Jaensch, The Jannick Group, 

LLC (improperly plead as The Jannick Group), 

Ira Lubert, Quaker Bioventures and Independence 

Capital Partners, Inc. (improperly plead as 

Independence Capital Partners) 

Dated: August 3, 2010 

Case 2:10-cv-03937-KSH-PS Document 1 Filed 08/03/10 Page 3 of 73 PageID: 3
EXHIBIT A 

Case 2:10-cv-03937-KSH-PS Document 1 Filed 08/03/10 Page 4 of 73 PageID: 4