Update for Case 07-A-540161

[sandi66]

Update for Case 07-A-540161 Roger Glenn...
« Thread Started Today at 3:37pm »

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zanmia
Administrator
Posts: 6,541
Update for Case 07-A-540161 10/28/09


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www.clarkcountycourts.us/Anonymous/CaseDetail.aspx?CaseID=6649467

Court filing system has changed to a new "look"


10/23/2009 Motion to Dismiss
Donald Roger Glenn's and Edwards Angell Palmer & Dodge's Partial Motion to Dismiss


Register of Actions
Case No. 07A540161
CMKM Diamonds Inc vs Urban Casavant, The UAJC 2005 Irrevocable Trust, et al §
§
§
§
§
§

Case Type: Business Court
Subtype: Other Business Court Matters
Date Filed: 04/25/2007
Location: Department 25
Conversion Case Number: A540161
Party Information

Lead Attorneys
Conversion Extended Connection Type
No Convert Value @ 07A540161
Removed: 04/24/2009
Converted From Blackstone


Defendant
Bucko LLC


Defendant
Casavant, Urban


Defendant
Decosta, Patricia E


Defendant
Dvorak, Brian


Defendant
Edward Angell Palmer and Dodge LLP


Defendant
Glenn, Donald Roger


Defendant
Gutierrez, Ginger


Defendant
Kinney, James


Defendant
Monte Verde International Holdings LLC


Defendant
P A Holdings Inc


Defendant
The UAJC 2005 Irrevocable Trust


Defendant
Wayne, Deshawn L


Defendant
Williams, Cierra


Defendant
Williams, Mike


Defendant
Williams, Rendal


Other
Community Bank Of Nevada
Wixom, Michael B.

Retained

Other
Hurd, G Gene


Plaintiff
CMKM Diamonds Inc
KOCH, DAVID

Retained
Events & Orders of the Court
OTHER EVENTS AND HEARINGS
04/25/2007 Complaint
COMPLAINT FILED Fee $148.00
07A5401610001.tif pages
04/25/2007 Application
EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AFFIDAVIT OF KEVIN WEST IN SUPPORT THEREOF
07A5401610002.tif pages
04/25/2007 Statement
DECLARATION OF DAVID R KOCH IN SUPPORT OF EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER
07A5401610003.tif pages
04/25/2007 Initial Appearance Fee Disclosure
INITIAL APPEARANCE FEE DISCLOSURE
07A5401610004.tif pages
04/27/2007 Motion
PLTF'S EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER (TRO)
07A5401610005.tif pages
04/30/2007 Motion for Temporary Restraining Order (2:45 PM) (Judicial Officer Denton, Mark R.)
PLTF'S EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER (TRO) Court Clerk: Sue Burdette Heard By: Mark Denton
Parties Present
Minutes
Result: Matter Heard
05/02/2007 Motion
PLTF'S MTN FOR PRELIMINARY INJUNCTION
07A5401610006.tif pages
05/02/2007 Temporary Restraining Order
TEMPORARY RESTRAINING ORDER AND ORDER SETTING HEARING ON MOTIOIN FOR PRELIMINARY INJUNCTION
07A5401610008.tif pages
05/15/2007 Motion
PLTF'S MTN TO ASSOCIATE COUNSEL (WILLIAM FRIZZELL)
07A5401610009.tif pages
05/15/2007 Motion for Preliminary Injunction (1:30 PM) (Judicial Officer Denton, Mark R.)
PLTF'S MTN FOR PRELIMINARY INJUNCTION Court Clerk: Sue Burdette Heard By: Mark Denton
Parties Present
Minutes
Result: Continuance Granted
05/18/2007 Motion
MOTION TO INTERVENE
07A5401610011.tif pages
05/21/2007 Motion to Associate Counsel (9:00 AM) (Judicial Officer Denton, Mark R.)
PLTF'S MTN TO ASSOCIATE COUNSEL (WILLIAM FRIZZELL) Court Clerk: Sue Burdette Heard By: Mark Denton
Parties Present
Minutes
Result: Motion Granted
05/22/2007 Motion
MOTION TO INTERVENE
07A5401610012.tif pages
05/23/2007 Temporary Restraining Order
AMENDED TEMPORARY RESTRAINING ORDER AND ORDER SETTING HEARING ON MTN FOR PRELIMINARY INJUNCTION
07A5401610013.tif pages
05/30/2007 Motion
PLTF'S APPLICATION FOR TRO/MOTION FOR PRELIMINARY INJUNCTION
07A5401610014.tif pages
05/30/2007 Motion for Preliminary Injunction (10:00 AM) (Judicial Officer Denton, Mark R.)
PLTF'S MTN FOR PRELIMINARY INJUNCTION Court Clerk: Sue Burdette Heard By: Mark Denton
Parties Present
Minutes
Result: Granted in Part
06/01/2007 Conversion Case Event Type
GENE HURD'S MTN TO INTERVENE/06 (VC NTC 06/29/07)
07A5401610015.tif pages
06/08/2007 Conversion Case Event Type
PRELIMINARY INJUNCTION AND FURTHER TEMPORARY RESTRAINING ORDER
07A5401610016.tif pages
06/11/2007 Temporary Restraining Order
TEMPORARY RESTRAINING ORDER
07A5401610017.tif pages
06/11/2007 Motion for Temporary Restraining Order (9:00 AM) (Judicial Officer Denton, Mark R.)
PLTF'S APPLICATION FOR TRO/MOTION FOR PRELIMINARY INJUNCTION Court Clerk: Sue Burdette Heard By: Mark Denton
Parties Present
Minutes
Result: Granted in Part
06/13/2007 Lis Pendens
NOTICE OF PENDENCY OF ACTION LIS PENDENS
07A5401610018.tif pages
06/13/2007 Lis Pendens
NOTICE OF PENDENCY OF ACTION LIS PENDENS
07A5401610019.tif pages
06/13/2007 Lis Pendens
NOTICE OF PENDENCY OF ACTION LIS PENDENS
07A5401610020.tif pages
06/20/2007 Conversion Case Event Type
AMENDED PRELIMINARY INJUNCTION
07A5401610021.tif pages
06/26/2007 Order
ORDER ADMITTING TO PRACTICE
07A5401610022.tif pages
06/27/2007 Withdrawal
WITHDRAWAL OF MOTION TO INTERVENE
07A5401610023.tif pages
07/02/2007 CANCELED Motion to Intervene (9:00 AM) (Judicial Officer Denton, Mark R.)
Vacated
08/23/2007 Motion
PLTF'S MTN TO ENLARGE TIME TO SERVE/07
07A5401610024.tif pages
09/21/2007 Certificate
CERTIFICATE OF SERVICE OF SUMMONS AND COMPLAINT
07A5401610025.tif pages
09/24/2007 Motion (9:00 AM) (Judicial Officer Denton, Mark R.)
PLTF'S MTN TO ENLARGE TIME TO SERVE/07 Court Clerk: Sue Burdette Heard By: Mark Denton
Minutes
Result: Motion Granted
10/11/2007 Order Granting
ORDER GRANTING MOTION TO ENLARGE TIME TO SERVE SUMMONS AND COMPLAINT
07A5401610026.tif pages
10/16/2007 Appearance
OBJECTION TO SUBPOENA DUCES TECUM
07A5401610027.tif pages
10/16/2007 Initial Appearance Fee Disclosure
INITIAL APPEARANCE FEE DISCLOSURE
07A5401610029.tif pages
10/16/2007 Objection
OBJECTION TO SUBPOENA DUCES TECUM
07A5401610030.tif pages
10/17/2007 Notice of Entry of Order
NOTICE OF ENTRY OF ORDER
07A5401610028.tif pages
12/03/2007 Notice of Bankruptcy
NOTICE OF BANKRUPTCY FILING
07A5401610031.tif pages
12/11/2007 Motion
PLTF CMKM DIAMONDS, INC'S APPLICATION FOR ORDER FOR PUBLICATION OF SUMMONS/08
07A5401610032.tif pages
12/11/2007 Motion
PLTF CMKM DIAMONDS, INC'S 2ND APPLICATN FOR RETURN OFFUNDS/09 (VJ 01-10-08)
07A5401610033.tif pages
12/11/2007 Bond
PLAINTIFFS INJUNCTION BOND TO DEFENDANT #53BSBE02177 $10,000.00
07A5401610034.tif pages
12/19/2007 Order Granting
ORDER GRANTING PLTFS SECOND APPLICATION FOR RETURN OF FUNDS
07A5401610035.tif pages
12/19/2007 Order for Service by Publication
ORDER GRANTING APPLICATION FOR ORDER FOR PUBLICATION OF SUMMONS
07A5401610036.tif pages
01/10/2008 Conversion Case Event Type
MINUTE ORDER RE: PLTF'S APPL FOR ORDER FOR PUBLCATN OF SUMMONS/RETURN OF FUNDS
07A5401610037.tif pages
01/10/2008 Minute Order (2:20 PM) (Judicial Officer Denton, Mark R.)
MINUTE ORDER RE: PLTF'S APPL FOR ORDER FOR PUBLCATN OF SUMMONS/RETURN OF FUNDS Court Clerk: Sue Burdette Heard By: Mark Denton
Minutes
Result: Matter Heard
01/14/2008 CANCELED Motion (9:00 AM) (Judicial Officer Denton, Mark R.)
Vacated
01/14/2008 CANCELED Motion (9:00 AM) (Judicial Officer Denton, Mark R.)
Vacated
06/20/2008 Request
REQUEST FOR ISSUANCE OF SEPARTE SUMMONS NRCP 4A
07A5401610038.tif pages
07/29/2008 Affidavit of Publication
AFFIDAVIT OF PUBLICATION
07A5401610039.tif pages
08/13/2009 First Amended Complaint
First Amended Complaint for (1) conversion; (2) Breach of Fiduciary Duty; (3) Usurpation of Corporate Opportunity; (4) Constructive Trust; (5) Civil Conspiracy
10/23/2009 Initial Appearance Fee Disclosure
10/23/2009 Motion to Dismiss
Donald Roger Glenn's and Edwards Angell Palmer & Dodge's Partial Motion to Dismiss
11/30/2009 Motion to Dismiss (9:00 AM) (Judicial Officer Delaney, Kathleen E.)
Donald Roger Glenn's and Edwards Angell Palmer & Dodge's Partial Motion to Dismiss
Financial Information


Conversion Extended Connection Type No Convert Value @ 07A540161
Total Financial Assessment 413.00
Total Payments and Credits 413.00
Balance Due as of 10/28/2009 0.00

04/26/2007 Transaction Assessment 413.00
04/26/2007 Conversion Payment Receipt # 01352514 TURNER GREEN AFRASIABI & ARLEDGE LLP (148.00)
04/26/2007 Conversion Payment Receipt # 01352599 CASH ACCOUNT (19.00)
04/27/2007 Conversion Payment Receipt # 01352803 CASH ACCOUNT (19.00)
05/01/2007 Conversion Payment Receipt # 01353454 JUNES LEGAL SERVICE INC (100.00)
10/16/2007 Conversion Payment Receipt # 01387821 SMITH LARSEN WIXOM CHTD (101.00)
04/18/2008 Conversion Payment Receipt # 01424946 RESEARCH REPORTS (26.00)



Defendant Edward Angell Palmer and Dodge LLP
Total Financial Assessment 30.00
Total Payments and Credits 30.00
Balance Due as of 10/28/2009 0.00

10/23/2009 Transaction Assessment 30.00
10/23/2009 Payment (Window) Receipt # 2009-06651-CCCLK Snell & Wilmer LLP (30.00)



Defendant Glenn, Donald Roger
Total Financial Assessment 223.00
Total Payments and Credits 223.00
Balance Due as of 10/28/2009 0.00

10/23/2009 Transaction Assessment 223.00
10/23/2009 Payment (Window) Receipt # 2009-06650-CCCLK Snell & Wilmer LLP (223.00)

noahltl1.proboards.com/index.cgi?action=display&board=cmkx1&thread=1938

ty Duc

[sandi66]

by portrush:

These are the results of what transpired in court today, re; Tyler's suit against Glenn and E&A.

8/13/2009 First Amended Complaint
First Amended Complaint for (1) conversion; (2) Breach of Fiduciary Duty; (3) Usurpation of Corporate Opportunity; (4) Constructive Trust; (5) Civil Conspiracy

10/23/2009 Initial Appearance Fee Disclosure

10/23/2009 Motion to Dismiss

Donald Roger Glenn's and Edwards Angell Palmer & Dodge's Partial Motion to Dismiss

11/30/2009 Motion to Dismiss (9:00 AM) (Judicial Officer Delaney, Kathleen E.)
Donald Roger Glenn's and Edwards Angell Palmer & Dodge's Partial Motion to Dismiss

Looks like its next up on 11/30. Makes you wonder if there's a settlement here, or if they're just playing all options one at a time.


noahltl1.proboards.com/index.cgi?action=display&board=cmkx1&thread=1938

[sandi66]

by barefootgirl:

barefootgirl
DIAMOND DIGGER
Re: Suit against Roger Glenn and E&A
« Reply #26 Yesterday at 12:25pm »

The filing of a Motion to Dismiss immediately after the Complaint has been filed is common practice in a civil case. It's the quickest way to get rid of a case if the court determines there is no basis for the complaint. If the motion to dismiss is DENIED at the November hearing, then the case will proceed to discovery with depositions being taken, etc. If the Motion to Dismiss is GRANTED as to all parties, then the case will just go away. If only some of the parties are dismissed, the case will proceed with discovery. If through discovery, plaintiff discovers enough damaging evidence, the case could go into settlement negotiations at any time. However, discovery can still take time, sometimes years, depending on the number of depositions to be taken, attorney schedules, etc. But it has been our experience that many civil cases settle rather than going to trial.

I work for a superior court judge and worked on the civil bench for three years.

barefootgirl

noahltl1.proboards.com/index.cgi?action=display&board=cmkx1&thread=1938

[Duc N Altum]

Zeninvestor



Squelch06/20/2004 11:08:16 PM | | 268 reads | Post #8053311

THis is making the rounds of the numerous CMKX message boards. It is very interesting: -------------- A bit more research for those interested. Being a lawyer and fairly familiar with large law firm structures, I thought it would be helpful to dissect Edwards Angell. It certainly proved even more interesting than I expected. The reason I did this was because no matter how many times I toy with the facts (or lack of facts), I keep coming back to one question: why did Urban choose a heavy hitter law firm and why specifically Edwards Angell and why specifically Roger Glenn? Edwards Angell is based primarily out of Boston, but with a strong presence in Providence and New York. They are generally seen as a "Northeastern" law firm however, rather than a "New York" law firm. Which is where it gets interesting. Their New York office houses 44 attorneys. Of the 44 attorneys, Roger is the only partner that truly specializes in corporate securities. In fact, in total there are only about 4 partners in the New York office that I would even say qualify at all as Securities Partners, with the other 3 clearly having focuses in niche markets on securities (foreign acquisitions, insurance companies, and ERISA). In terms of general securities, financings, M&A, and filings, Roger is the MAN in the New York office. This is signficant. You do not have a presence in New York as a large law firm without making sure that your New York office is the absolute BEST that it can be in the securities department. With the proximity to the exchanges, Wall Street and all the financial business in New York, this is truly the "prestige" office. And Roger is THE guy. Breaking it down further, pay close attention to the publication that he authored in 2003. Its focus is the Sarbanes Oxley Act of 2002. That Act is a set of some of the most complex securities laws ever passed to ensure proper corporate accountability and governance in companies after the Enron and Worldcom scandals, specifically with respect to filings and dealings with the SEC. I hope this is starting to sink in. To be selected to write an authoritative text on interpreting this Act is a testament to the respect, expertise and integrity that Roger possesses in this field. Now think more about our situation. When it comes to proper filings, navigating the complexities of SEC/filings, and doing it all ABOVE BOARD and with maximum ACCOUNTABILITY, Roger is simply one of the best attorneys perhaps in New York to fit this role. Let me remind you. He is THE man in their New York office. Not one of dozens of partners. THE man. Now many might be thinking (and surely the bashers will be all over this) "maybe Urban did something wrong and needs Roger to bail him out". First, the press releases expressly stated Roger will "help them become fully reporting" which is quite different than than any corporate wrongdoing. Second, Edwards Angell has a "Corporate White Collar Crime" division specifically. Roger is not listed as one of the 16 attorneys with any expertise in that area. My opinion is that it is 99.9% unlikely that Roger would be involved with anything in that area when there are 16 other attorneys that specialize in that area at the firm. I'd also like to wrap into this that Edwards Angell is probably among a handful (probably among the top 10 in the country) of firms that specialize in venture capital and private equity financing. I cannot say how this may work into the equation but what I can say with confidence is that VC people at THIS level would not touch anything without complete and total due diligence and confidence in an emerging company. If in fact there is any additional financing (a secondary? a group willing to fund a move to get an asset base high enough to qualify for NYSE or AMEX listing?), this is THE firm to handle it professionally and with maximum benefit to shareholders and the company. So let's connect the dots. Three press releases in late 2003 to early 2004 confirm the buyback of 38 billion shares. Total listed shares as of February were 37 billion shares. 5 months have passed since then. During that time the stock basically traded at .0001. We do not know how many more shares Urban bought back during that time. Suddenly we have Urban switching transfer agents, announcing his intention of becoming fully reporting and hiring the top securities partner in the New York office of one of the nation's most prestigious law firms. If you were simply looking to perpetuate CMKX and sell shares into the market, why would you do all this, particularly when "fully reporting" would now mean full disclosure on all transactions? And why in the world if there were any "problems" would you hire the guy that wrote the book on strict corporate procedures and guidelines with respect to filings? And this is where I ponder heavily ... Why Roger and Edwards Angell? Why would you pick the New York office's top securities guy, the firm's top SEC filings guy to handle your "fully reporting" status? And why would ROGER who assuredly as their top securities guy (particularly the one that PUBLISHED a legal primer on corporate accountability and integrity) EVER take on a pink sheet company when basically his entire livelihood would take on about the largest black eye possible if ANYTHING fraudulent were involved. I know I'm rambling. Thanks for listening. A few other points. Roger specializes in Mergers & Acquisitions and was the only attorney I found listing "going private transactions" among his specialties. He also was CLEARLY the most recognized partner with respect to filing and becoming a public, reporting company. And being the MAIN guy in the New York office, something became lucidly obvious in thinking all this through .... and keep in mind this is just one attorneys subjective analysis of all this ... Urban has something so big and unique that not only does it require securities legal expertise of the highest level but it specifically requires that it be handled by someone who stands out in the ethics and integrity department as well. In other words, when all is available to the public, there should be an additional "protection" in everything in knowing that it was processed, approved and filed through an attorney with IMPECCABLE credentials. The fact that Roger Glenn published a legal treatise on Corporate Responsibility following the Sarbanes Oxley Act of 2002 is SIGNIFICANT. It essentially means that if Roger blesses what has transpired, it is meeting the HIGHEST standards of corporate responsibility. And if what I believe Urban is bringing to the table through Roger is what it is, this will be CRITICAL. To recap: I am 99.9% comfortable with dismissing the notion that Roger was brought on due to anything negative or to "bail out" Urban. I am 99.9% comfortable with the fact that Roger Glenn in no way would take on a pink sheet company trading at .0001 if he had ANY suspicion of anything unethical. I am 99.9% comfortable stating that Urban has hired a partner and law firm that represent the highest standards of ethical and responsible securities law practice in the country. And all this leads me to the conclusion that this is no mere "get me trading on the otc bulletin board situation". No, my (endless) rambling above leads me to believe that this must be a situation of MONUMENTAL significance. I am sorry this took so long to type. I hope people found it helpful. I have harped on the significance of this firm and man from day one. I felt it important to expand upon why this is the single most important hint to everything that has transpired so far. Good night and please have a wonderful Father's Day to all the dads out there. Hopefully next year for Father's Day, everyone will be considerably better off in life thanks to this investment. Take care. Z

www.stockhouse.com/bullboards/Mes....11&l=0&pd=0&r=0 <--- thanks Marantz3

[stockfred]

Zen...Thanks for opinion. I believe the same. My only issue is, why would Tyler not know all this and sue Glenn and E&A? As with all things CMKM Diamonds, it makes no sense.

[sandi66]

www.cmkmdiamondsinc.com/documents/2nd_amended_comp_cas.pdf new doc on CMKM Website

SECOND AMENDED COMPLAINT FOR: (1) conversion;
(2) BREACH OF FIDUCIARY DUTY;
(3) USURPATION OF CORPORATE OPPORTUNITY;
(4) CONSTRUCTIVE TRUST;
(5) CIVIL CONSPIRACY;
(6) UNJUST ENRICHMENT; and
(7) BREACH OF CONTRACT
(8) NEGLIGENCE
(9) NEGLIGENCE
(10) FRAUD
(11) STERILIZATION OF STOCK
EXEMPT FROM ARBITRATION: INJUNCTIVE RELIEF REQUESTED AND VALUE EXCEEDS $50,000


filed Jan 5, 2010

[sandi66]

www.cmkmdiamondsinc.com/documents/notice_emergency_motion_12-3-09.pdf

Notice of Entry of Order Shortening Time Regarding Emergency Motion to Associate Counsel on an Order Shortening Time




ty Liz

[sandi66]

(9:50 AM) jacbert:Tyler TX has a court action today in Nevada... 08/17/2010 Discovery Conference

(9:00 AM) (Judicial Officer Bulla, Bonnie)

9:55 AM) jacbert: 07A540161 CMKM Diamonds Inc vs Urban Casavant, The UAJC 2005 Irrevocable Trust, et al 04/25/2007
Department 11 Business Court
Open

(9:57 AM) jacbert: www.clarkcountycourts.us/Anonymous/default.aspx
you have to make some selection with that link,

1st) select district civil/ criminal records

2nd) next page, in the case box you select party

3)and then the next items check used sound x box put a check in there

4)then select business and type CMKM and then it should bring to today with the hearing of Defendant The UAJC 2005 Irrevocable Trust.

( if link is not working here in this post then just copy and paste it up top in search box and that should bring it up for those who wish to view it.)

08/17/2010 Discovery Conference

(9:00 AM) (Judicial Officer Bulla, Bonnie)

Result: Matter Heard

07A540161 CMKM Diamonds Inc vs Urban Casavant, The UAJC 2005 Irrevocable Trust, et al

www.clarkcountycourts.us/Anonymous/Search.aspx?ID=400&NodeID=101,103,104,105,200,201,202,203,500,600,601,602,603,604,605,606,607,608,609,610,611,612,613,614,615,616,617,699,700,701,702,703,704,705,706,707,708,709,710,711,712,713,714,715,716,717,718,719,720,721,722,723,724,797,798,2201,2202,2203,2204,2205,2206,2207,2208,2209,2210&NodeDesc=All+Courts

David Koch Lead Attorney for Plaintiff CMKM Diamonds Inc

[sandi66]

by Zanmia:

www.cmkmdiamondsinc.com/documents/JointCaseConferenceReport.pdf

tinyurl.com/4lozuor

JOINT CASE CONFERENCE REPORT



6. Close of all fact discovery: October. 29, 2010
7. Plaintiff to disclose expert testimony pursuant to Rule 16.1(a)(2) November. 19, 2010
9. Defendants to complete deposition(s) of Plaintiff expert(s) December. 17, 2010
10. Defendants to disclose expert testimony pursuant to Rule 16.2(a)(2) January 21, 2011
11. Close of all expert discovery February. 25, 2011
12. Final date to file dispositive motions: March 18, 2011
13. Final date to file Response to dispositive motions: April 15, 2011
14. Final date to file Replies in support of dispositive motions: April 29, 2011


LIST OF ALL DOCUMENTS, DATA COMPILATIONS AND TANGIBLE THINGS IN
THE POSSESSION, CUSTODY OR CONTROL OF EACH PARTY WHICH WERE
IDENTIFIED OR PROVIDED AT THE EARLY CASE CONFERENCE OR AS A
RESULT THEREOF: [16.1(a)(1)(B) and 16.1(c)(4)]
A. Plaintiff: Plaintiff has agreed to include in its initial disclosures the following
categories of documents:
• Complete information concerning all lawsuits in which CMKM was/is either plaintiff or
defendant since 2004,
• Complete information concerning all judgments entered in favor of or against CMKM.
• Complete information concerning any settlements entered into by CMKM since 2004
(regardless of whether litigation was actually filed),
• All written or recorded statements of any witnesses, including deposition transcripts.
• CMKM board minutes, resolutions and agendas
• All documents relating to CMKM's damages calculation, specifically including the names
of the shareholders and number of shares to whom CMKM alleges that stock was issued
without consideration.
• All subpoenas (estimated to be approx 100) served by CMKM uppon various banks,
trading firms and casinos, including all responses and any custodian of records affidavits -
Interestingly, we confirmed that CMKM has never subpoenaed records from Desmoreau,
Stoecklein or Levine and we have express permission to do so and we can represent that
CMKM has waived any privileges (attorney-client or accountant-client) it may hold
applicable to those groups of documents.
• Transcripts and exhibits of all depositions taken by the SEC
• First Global stock transfer records (estimated to be approx 75,000)
• NASD investigation file involving NevWest/CMKM (estimated to be approx 30,000)
• An index of documents formerly held by CMKM’s outside counsel, Lizzie Baird of
O’Melveny & Meyers
• All exhibits referenced in Plaintiff’s May 2008 demand letter
• 10 bank accounts from Bank of America
• 6 bank accounts from Community Bank of Nevada
• 10 bank accounts from Nevada State Bank
• 20 bank accounts from Silver State Bank
• 4 bank accounts from Sun West Bank
• 9 bank accounts from Wells Fargo Bank
• 1 bank account from Washington Mutual
• Casino Records from 9 casinos pertaining to Urban Casavant
• 19 stock trading accounts from various CMKM insiders at various brokerage houses
• Hearing transcript for the 12j proceeding in Los Angeles in May of 2005

• NASD investigation and the NASD complaint involving NevWest/CMKM First Global
stock transfer of records
B. Defendant: Defendants GLENN AND EAPD will re-produce the documents it has
already produced with new bates numbers specific to this litigation. Defendants GLENN AND
EAPD will also produce a copy of the relevant insurance policy

tramp2.proboards.com/index.cgi?board=general&action=display&thread=16390



ty Duc

[sandi66]

Court Document Third Amended Complaint

www.scribd.com/doc/52672962/Motio....-Complaint-Mamc



03/16/2011 Order to Show Cause
Order to Show Cause

03/16/2011 Order Setting Civil Bench Trial
Order Setting Bench Court Pretrial Conference Pursuant to NRCP 16

04/05/2011 Motion to Amend Complaint
Motion for Leave to File Third Amended Complaint

04/21/2011 Show Cause Hearing (9:00 AM) (Judicial Officer Delaney, Kathleen E.)
04/21/2011 Mandatory Rule 16 Conference (9:00 AM) (Judicial Officer Delaney, Kathleen E.)
05/10/2011 Motion for Leave (9:00 AM) (Judicial Officer Delaney, Kathleen E.)
Motion for Leave to File Third Amended Complaint

[sandi66]

Motion To Strike Plaintiff's First Amended Disclosures of Documents & Witnesses


Electronically filed 4-27-11 06:12:45 PM PM

www.scribd.com/doc/54300623/Motion-to-Strike-Plaintiff-s-First-Amended-Disclosures-of-Documents-and-Witnesses-Mstr-1