United States District Court, D. Nevada
JOHNSON PARKER EDWARDS H. STAN JOHNSON, ESQ.
M. JOHNSON, ESQ.Attorneys for Plaintiff
STAN JOHNSON, ESQ. Attorney for Defendant Robert Cortez
STIPULATION AND ORDER TO EXTEND DISCOVERY DATES AND
TRIAL (FIRST REQUEST)
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:
SIGNIFICANT RECENT DEVELOPMENTS
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.
A STATEMENT SPECIFYING THE DISCOVERY COMPLETED
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.
A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE
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.
THE REASONS WHY DISCOVERY REMAINING WAS NOT COMPLETED WITHIN
THE TIME LIMITS SET BY THE DISCOVERY ORDER
aforementioned civil suit as well as continued efforts by the
parties to settle this case have taken precedence over
discovery in this matter.