Securities and Exchange Commission v. Fujinaga et al

Filing 567

ORDER Granting 564 Stipulation to Extend Time Re: 556 Motion for Order to Show Cause. Responses due by 4/21/2020. Signed by Judge James C. Mahan on 4/15/2020. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:13-cv-01658-JCM-CWH Document 566 Filed 04/14/20 Page 1 of 3

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CLARK HILL PLLC
MARK S. DZARNOSKI, ESQ.
Nevada Bar No. 3398
E-mail: [e-mail]
MICHAEL V. CRISTALLI, ESQ.
Nevada Bar No. 6696
E-mail: [e-mail]
DOMINIC P. GENTILE, ESQ.
Nevada Bar No. 1923
3800 Howard Hughes Parkway, Suite 500
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SECURITIES AND EXCHANGE
COMMISSION,

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CASE NO. 2:13-cv-01658-JCM-CWH

Plaintiff,
STIPULATION AND ORDER TO
EXTEND TIME TO RESPOND TO
RECEIVER’S APPLICATION FOR AN
ORDER TO SHOW CAUSE WHY
FORMER COUNSEL FOR DEFENDANT
SHOULD NOT BE COMPELLED TO
RETURN ESTATE FUNDS
(FIRST REQUEST)

v.
EDWIN YOSHIHIRO FUJINAGA and MRI
INTERNATIONAL, INC.,
Defendants.

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and

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CSA SERVICE CENTER, LLC THE
FACTORING COMPANY, JUNE FUJINAGA,
and THE YUNJU TRUST,

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Relief Defendants.

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IT IS HEREBY STIPULATED AND AGREED by and between Former Defense

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Counsel for relief defendant June Fujinaga and the Yunju Trust, Michael V. Cristalli, Esq., and

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Dominic P. Gentile, Esq., of the law firm of Clark Hill, PLLC and Counsel for the Receiver,

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Robb Evans & Associates, LLC, Michael F. Lynch, Esq., of the law firm of Lynch Law Practice,

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PLLC, hereby respectfully submit this Stipulation and Order Extending Time for Former

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Defense Counsel for relief defendant June Fujinaga and the Yunju Trust to Respond to
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Case 2:13-cv-01658-JCM-CWH Document 566 Filed 04/14/20 Page 2 of 3

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Receiver’s Application for an Order to Show Cause Why Former Counsel For Defendant Should

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Not Be Compelled To Return Estate Funds. This Stipulation is made in accordance with LR 6-1,

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LR 6-2, and LR II 7-1 of the Local Rules of this Court. This is the first request for an extension

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of time to file a response to Receiver’s Application for an Order to Show Cause Why Former

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Counsel for Defendant Should Not Be Compelled To Return Estate Funds.

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Receiver’s Application for an Order to Show Cause Why Former Counsel for Defendant

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Should Not Be Compelled To Return Estate Funds [ECF 556] was filed on March 31, 2020. The

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Response to Receiver’s Application is due April 14, 2020.

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Upon agreement by and between all the parties, the undersigned respectfully requests that

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this Court grant an extension of time in which the Response to Receiver’s Application for an

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Order to Show Cause Why Former Counsel for Defendant Should Not Be Compelled To Return
Estate Funds currently due April 14, 2020 be extended for a period of seven (7) days up to and

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including April 21, 2020.
...

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...

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Case 2:13-cv-01658-JCM-CWH Document 566 Filed 04/14/20 Page 3 of 3

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The reason for this request is that the COVID 19 emergency and related limitations have

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significantly hampered Clark Hill and Former Defense Counsel’s ability to complete their

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Reponses to Receiver’s Application.
DATED this 14th day of April, 2020.

DATED this 14th day of April, 2020.

CLARK HILL, PLLC

LYNCH LAW PRACTICE, PLLC

/s/ Mark S. Dzarnoski, Esq._____
MARK S. DZARNOSKI, ESQ.
Nevada Bar No. 3398
MICHAEL V. CRISTALLI, ESQ.
Nevada Bar No. 6696
DOMINIC P. GENTILE, ESQ.
Nevada Bar No. 1923
3800 Howard Hughes Parkway, Suite 500
Las Vegas, Nevada 89169
Tel: [phone]
Former Defense Counsel June Fujinaga and
The Yunja Trust

__/s/ Michael F. Lynch, Esq.
MICHAEL F. LYNCH, ESQ.
Nevada Bar No. 8555
3613 S. Eastern Ave.
Las Vegas, Nevada 89169
Tel: [phone]
Attorneys for the Receiver, Robb Evans &
Associates, LLC

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IT IS SO ORDERED:

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_________________________________________
UNITED STATES DISTRICT JUDGE
April 15, 2020
DATED: _________________________

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