Securities & Exchange Commission v. Hemp, Inc. et al

Filing 58

ORDER Granting 51 Motion to Amend 40 Scheduling Order. ( Motions due by 9/13/2017.) Signed by Magistrate Judge Peggy A. Leen on 2/22/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-01413-JAD-PAL Document 51 Filed 02/13/17 Page 1 of 4

Amy J. Oliver (Utah #8785) (admitted pro hac vice)
[e-mail]
Daniel J. Wadley (Utah #10358) (admitted pro hac vice)
[e-mail]
James J. Thibodeau (Utah #15473) (admitted pro hac vice)
[e-mail]
Attorneys for Plaintiff
Securities and Exchange Commission
Salt Lake Regional Office
351 South West Temple
Suite 6.100
Salt Lake City, UT 84101-1950
Tel.: [phone]
Fax: [phone]

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.
HEMP, INC. a Colorado Corporation;
Case No. 2:16-cv-1413 JAD-PAL
BRUCE J. PERLOWIN, an individual; BARRY
K. EPLING, an individual; JED M. PERLOWIN,
STIPIULATED MOTION TO AMEND
an individual; FERRIS HOLDING, INC., a private THE SCHEDULING ORDER
Nevada Corporation; HOBBES EQUITIES INC., a
(First Request)
private Nevada Corporation; DIVERSIFIED
INVESTMENTS LLC, a private Nevada Limited
Liability Company; and QUANTUM ECONOMIC
PROTOCOLS LLC, a private Nevada Limited
Liability Company.
Defendants.

1

Case 2:16-cv-01413-JAD-PAL Document 51 Filed 02/13/17 Page 2 of 4

Plaintiff, Securities and Exchange Commission (the “Commission”), hereby moves the
Court to amend the previously entered Scheduling Order (Docket No. 40) by extending the dates
for expert discovery and dispositive motions. Defendants Hemp, Inc., Bruce J. Perlowin, Barry
K. Epling, Jed M. Perlowin, Ferris Holding, Inc., Hobbes Equities, Inc., Diversified Investments,
LLC, and Quantum Economic Protocols, LLC, through their respective counsel, have all
stipulated to the Plaintiff’s motion. This is the first stipulation for a motion to amend the
scheduling order.
The reasons for this Motion are as follows.

The parties are actively engaged in

discovery, including the exchange of written discovery and the taking of numerous depositions.
Most of these depositions will be taken either immediately preceding or after the current March
17, 2017 and April 17, 2017 deadlines for expert reports from the Plaintiff and the Defendants,
respectively. Were the parties to maintain the current schedule for expert discovery, it would
necessitate supplemental reports from experts and cause the parties to incur additional time and
expense.

Moving the expert deadlines would also necessitate allowing time for expert

depositions after the exchange of expert reports as well as moving the deadline for the filing of
dispositive motions so that the parties may have the benefit of completing expert discovery
before the dispositive motion deadline.
Therefore, the parties have stipulated to move the following deadlines by 90 days as set
forth below:
1. Plaintiff’s expert report(s) due on May 16, 2017.
2. Defendants’ expert report(s) due on June 15, 2017.
3. Discovery deadline for expert depositions on July 15, 2017.
4. Dispositive motion deadline on September 13, 2017.

2

Case 2:16-cv-01413-JAD-PAL Document 51 Filed 02/13/17 Page 3 of 4

IT IS SO STIPULATED.

Dated: February 13, 2017

s/Amy J. Oliver
Amy J. Oliver
Daniel J. Wadley
James J. Thibodeau
Attorneys for Plaintiff
Securities and Exchange Commission

Dated: February 13, 2017

s/Jonathan D. Bletzacker
Brent R. Baker
Jonathan D. Bletzacker
Attorney for Jed Perlowin, Diversified Investments
LLC, Quantum Economic Protocols LLC

Dated: February 13, 2017

s/Thomas A. Sporkin
Thomas A. Sporkin
Timothy J. Coley
Attorney for Bruce Perlowin, Hemp Inc., Barry
Epling, Ferris Holding, Inc., Hobbes Equities Inc.

IT IS SO ORDERED.

______________________________
HONORABLE PEGGY A. LEEN
UNITED STATES MAGISTRATE JUDGE
February 22, 2017
DATED: ______________________

3

Case 2:16-cv-01413-JAD-PAL Document 51 Filed 02/13/17 Page 4 of 4

CERTIFICATE OF SERVICE
I hereby certify that on the 13th day of February, 2017, I served STIPIULATED
MOTION TO AMEND THE SCHEDULING ORDER (First Request) to the following
parties entitled to service via the Court’s ECF system to the counsel indicated below:

Thomas A. Sporkin
Timothy J. Coley
BuckleySandler LLP
1250 24th Street NW, Suite 700
Washington D.C. 20037
[e-mail]
[e-mail]
Antony M. Santos
A.M. Santos Law, CHTD
3275 S. Jones Blvd. Ste 104
Las Vegas, Nevada 89146
[e-mail]
Brent R. Baker
Jonathan D. Bletzacker
ClydeSnow
One Utah Center
Thirteenth Floor
201 South Main Street
Salt Lake City, Utah 84111
[e-mail]
[e-mail]
Jacob L. Fonnesbeck
Smith Correll, LLP
3960 Howard Hughes Pkwy, Suite 500
Las Vegas, Nevada 89169
[e-mail]

4