Securities and Exchange Commission v. Bivona et al

Filing 138

STIPULATION AND ORDER re 137 STIPULATION WITH PROPOSED ORDER Extending Time to Move to Amend the Complaint as to Potential Defendant 1 filed by Securities and Exchange Commission. Signed by Judge Edward M. Chen on 10/7/16. (bpfS, COURT STAFF) (Filed on 10/7/2016)

1 JINA L. CHOI (N.Y. Bar No. 2699718)
JOHN S. YUN (Cal. Bar No. 112260)
2 [e-mail]
MARC D. KATZ (Cal. Bar No. 189534)
3 [e-mail]
JESSICA W. CHAN (Cal. Bar No. 247669)
4 [e-mail]
5 Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
6 44 Montgomery Street, Suite 2800
San Francisco, CA 94104
7 Telephone: [phone]
Facsimile: [phone]
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SECURITIES AND EXCHANGE COMMISSION, Case No. 3:16-cv-01386-EMC

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Plaintiff,
v.

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STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO MOVE TO
AMEND THE COMPLAINT AS TO
POTENTIAL DEFENDANT 1

JOHN V. BIVONA; SADDLE RIVER
18 ADVISORS, LLC; SRA MANAGEMENT
ASSOCIATES, LLC; FRANK GREGORY
19 MAZZOLA,
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Defendants, and

21 SRA I LLC; SRA II LLC; SRA III LLC;
FELIX INVESTMENTS, LLC; MICHELE
22 J. MAZZOLA; ANNE BIVONA; CLEAR
SAILING GROUP IV LLC; CLEAR
23 SAILING GROUP V LLC,
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Relief Defendants.

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Stipulation and [Proposed] Order Extending Time To
Move to Amend the Complaint

Civ. 3:16-cv-01386-EMC

STIPULATION EXTENDING TIME TO MOVE TO AMEND THE COMPLAINT

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Plaintiff Securities and Exchange Commission (“Commission”) and Potential Defendant 11

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3 hereby stipulate to extend the Commission’s time to file a motion to amend the Complaint to add
4 Potential Defendant 1 as a defendant in this matter until January 31, 2017.
Commission staff, Potential Defendant 1, and Potential Defendant 1’s counsel, Jahan Raissi,

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6 are currently involved in discussions concerning the possible resolution of the Commission’s claims
7 against Potential Defendant 1. To provide sufficient time to complete these negotiations, the
8 Commission and Potential Defendant 1 stipulate as follows:
The Commission shall have until January 31, 2017 to file a motion to add Potential Defendant

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1 to this action. The deadline for moving to amend the Complaint as to any other claim or

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defendant remains October 31, 2016.

12 Dated: October 5, 2016

Respectfully submitted,

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/s/ Jessica W. Chan_________________________
Jessica W. Chan
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION

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/s/ Jahan P. Raissi
Jahan P. Raissi
Attorneys for Potential Defendant 1
SHARTSIS FRIESE LLP

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The parties having stipulated to the foregoing concerning the Commission’sS DISTmove to
E time to ICT

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UNIT
ED

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DATED: October __, 2016

Stipulation and [Proposed] Order Extending
Time To Move to Amend the Complaint

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E have been sued.
The Commission’s practice is not to identify potential defendants until theyR

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Civ. 3:16-cv-01386-EMC

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_____________________
EDWARD M. CHEN
hen
United States District Judgeward M. C
ge Ed
Jud

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ERED

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O ORD
IT IS S

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U
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22 amend the Complaint with respect to Potential Defendant 1, it is SO ORDERED.
TA

R NIA

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