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Securities and Exchange Commission v. Marshall

United States District Court, D. Nevada

May 7, 2018

SECURITIES AND EXCHANGE COMMISSION, Plaintiff,
v.
ROBERT CORTEZ MARSHALL, Defendants.

          COHEN JOHNSON PARKER EDWARDS H. STAN JOHNSON, ESQ.

          KEVIN M. JOHNSON, ESQ.Attorneys for Plaintiff

          H. STAN JOHNSON, ESQ. Attorney for Defendant Robert Cortez Marshall

          STIPULATION AND ORDER TO EXTEND DISCOVERY DATES AND TRIAL (FIRST REQUEST)

         IT IS HEREBY STIPULATED by and between Plaintiff, SECURITIES AND EXCHANGE COMMISSION, and Defendant ROBERT CORTEZ MARSHALL, by and through their respective counsel of record, that all case deadlines should all be continued, pursuant to LR IA 6-1, as follows:

         I. SIGNIFICANT RECENT DEVELOPMENTS

         Defendant has recently been served a private civil suit relating to the same events at the center of this action that will require Defendant's time and attention. Moreover, the parties have engaged in preliminary settlement discussions and are interested in alternative methods of dispute resolution. The parties plan to schedule a settlement conference with a magistrate judge in this matter.

         II. A STATEMENT SPECIFYING THE DISCOVERY COMPLETED

         Prior to bringing this action, the Securities and Exchange Commission conducted its investigation and reserves the right to conduct further depositions including that of the Defendant, which it noticed for April 20, 2018, and was informed that the Defendant would not appear on that date. Defendant has been reviewing the documents produced by Plaintiff in connection with its initial disclosures.

         III. A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED

         Defendant needs more time to review and analyze the investigation conducted by Plaintiff and respond with more discovery of its own. Specifically, Defendant will need time to conduct its own depositions of the witnesses in this matter in order to mount a defense. Plaintiff also reserves the right to conduct further depositions if this matter is not settled.

         IV. THE REASONS WHY DISCOVERY REMAINING WAS NOT COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY ORDER

         The aforementioned civil suit as well as continued efforts by the parties to settle this case have taken precedence over discovery in this matter.

         V. CURRENT ...


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