Securities and Exchange Commission v. Shinderman et al

Filing 32

ORDER granting 31 Stipulation to Extend Deadlines for Dispositive Motions and Proposed Joint Pretrial Order by 60 Days. Signed by Magistrate Judge Peggy A. Leen on 3/20/2019. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:18-cv-00131-JCM-PAL Document 31 Filed 03/13/19 Page 1 of 5

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DONALD W. SEARLES (Cal. Bar No. 135705)
Email: [e-mail]
Attorneys for Plaintiff
Securities and Exchange Commission
Michele Wein Layne, Regional Director
Alka N. Patel, Associate Regional Director
Amy Jane Longo, Regional Trial Counsel
444 S. Flower Street, Suite 900
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SECURITIES AND EXCHANGE
COMMISSION,

Case No. 2:18-cv-00131-JCM-PAL

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JOINT STIPULATION AND MOTION
BY PLAINTIFF SECURITIES AND
EXCHANGE COMMISSION AND
DEFENDANTS QUICKSILVER
STOCK TRANSFER LLC AND ALAN
SHINDERMAN TO EXTEND
DEADLINES FOR FILING
DISPOSITIVE MOTIONS AND
JOINT PRETRIAL ORDER IN
LIGHT OF SETTLEMENT IN
PRINCIPLE

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(FIRST REQUEST)

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Plaintiff,
vs.
QUICKSILVER STOCK TRANSFER,
LLC and ALAN SHINDERMAN,
Defendants.

Case 2:18-cv-00131-JCM-PAL Document 31 Filed 03/13/19 Page 2 of 5

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Plaintiff Securities and Exchange Commission (“SEC”) and Defendants

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Quicksilver Stock Transfer LLC and Alan Shinderman (“Defendants”), through

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their respective counsel, hereby stipulate and move the Court to extend the

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deadlines for filing dispositive motions and the Proposed Joint Pretrial Order in

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this action by 60 days.

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WHEREAS, counsel for the SEC and counsel for Defendants have agreed to a
settlement in principle of this action;
WHEREAS, only the Commissioners of the SEC in Washington, D.C. have the
final authority to approve any settlement, SEC counsel has begun the process of

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obtaining final settlement approval and authorization from the SEC Commissioners,

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any Consent and Proposed Final Judgment as to Defendants cannot be filed until SEC

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counsel has obtained such authority from the Commission, and under the present

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circumstances, that process is expected to take approximately 60 days;

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WHEREAS, the current deadline for filing dispositive motions is March 13,
2019, and the deadline for filing the Proposed Joint Pretrial Order is April 12, 2019;
WHEREAS, Defendants and the SEC seek to minimize burden, fees, costs,

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and/or other expenses of preparation for a trial on the claims asserted against

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Defendants pending the Commission’s consideration of the SEC’s and Defendants’

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settlement in principle;

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NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED by

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counsel for the SEC and counsel for Defendants the deadline for filing dispositive

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motions and the Proposed Joint Pretrial Order be extended 60 days to allow the

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Commission consider and approve the settlement in principle.

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DATED: March 13, 2019

/s/ Donald W. Searles
DONALD W. SEARLES
Attorneys for Plaintiff
Securities and Exchange Commission

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Case 2:18-cv-00131-JCM-PAL Document 31 Filed 03/13/19 Page 3 of 5

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DATED: March 13, 2019

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/s/ Barney C. Ales
BARNEY C. ALES
Attorneys for Defendants
Quicksilver Stock Transfer, LLC and
Alan Shinderman

IT IS SO ORDERED.

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March 20, 2019
Dated: ______________

____________________________________
HON. PEGGY A. LEEN
UNITED STATES MAGISTRATE JUDGE

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Case 2:18-cv-00131-JCM-PAL Document 31 Filed 03/13/19 Page 4 of 5

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PROOF OF SERVICE
I am over the age of 18 years and not a party to this action. My business address is:
U.S. SECURITIES AND EXCHANGE COMMISSION,
444 S. Flower Street, Suite 900, Los Angeles, California 90071
Telephone No. [phone]; Facsimile No. [phone].
On March 13, 2019, I caused to be served the document entitled JOINT
STIPULATION AND MOTION BY PLAINTIFF SECURITIES AND
EXCHANGE COMMISSION AND DEFENDANTS QUICKSILVER STOCK
TRANSFER LLC AND ALAN SHINDERMAN TO EXTEND DEADLINES
FOR FILING DISPOSITIVE MOTIONS AND JOINT PRETRIAL ORDER IN
LIGHT OF SETTLEMENT IN PRINCIPLE (FIRST REQUEST) on all the
parties to this action addressed as stated on the attached service list:
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OFFICE MAIL: By placing in sealed envelope(s), which I placed for
collection and mailing today following ordinary business practices. I am readily
familiar with this agency’s practice for collection and processing of correspondence
for mailing; such correspondence would be deposited with the U.S. Postal Service on
the same day in the ordinary course of business.
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PERSONAL DEPOSIT IN MAIL: By placing in sealed envelope(s),
which I personally deposited with the U.S. Postal Service. Each such envelope was
deposited with the U.S. Postal Service at Los Angeles, California, with first class
postage thereon fully prepaid.
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EXPRESS U.S. MAIL: Each such envelope was deposited in a facility
regularly maintained at the U.S. Postal Service for receipt of Express Mail at Los
Angeles, California, with Express Mail postage paid.
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HAND DELIVERY: I caused to be hand delivered each such envelope to the
office of the addressee as stated on the attached service list.
☐
UNITED PARCEL SERVICE: By placing in sealed envelope(s) designated
by United Parcel Service (“UPS”) with delivery fees paid or provided for, which I
deposited in a facility regularly maintained by UPS or delivered to a UPS courier, at
Los Angeles, California.
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ELECTRONIC MAIL: By transmitting the document by electronic mail to
the electronic mail address as stated on the attached service list.
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E-FILING: By causing the document to be electronically filed via the Court’s
CM/ECF system, which effects electronic service on counsel who are registered with
the CM/ECF system.
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FAX: By transmitting the document by facsimile transmission. The
transmission was reported as complete and without error.

I declare under penalty of perjury that the foregoing is true and correct.
Date: March 13, 2019

/s/ Donald W. Searles
Donald W. Searles

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Case 2:18-cv-00131-JCM-PAL Document 31 Filed 03/13/19 Page 5 of 5

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SEC v. Quicksilver Stock Transfer LLC and Alan Shinderman
United States District Court – District of Nevada
Case No. 2:18-cv-00131-JCM-PAL

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SERVICE LIST
Barney C. Ales, Esq.
P.O. Box 20563
Las Vegas, NV 89112
Email: [e-mail]
Attorney for Defendants Quicksilver Stock Transfer, LLC, and Alan
Shinderman

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