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Microcap & Penny Stocks : PLNI - Game Over -- Ignore unavailable to you. Want to Upgrade?

To: scion who wrote (12207)	4/13/2009 10:28:43 AM
From: scion	Read Replies (1) \| Respond to of 12518

04/10/2009 21 JOINT REPORT of Rule 26(f) Planning Meeting. (Gegenheimer, Nancy) (Entered: 04/10/2009) -------- Doc 21 Extract JOINT REPORT OF PARTIES AND PROPOSED DISCOVERY PLAN Pursuant to Fed. R. Civ P. 26(f), and the Court’s Order of March 3, 2009 the parties had a conference call on April 2, 2009 and thereafter exchanged e-mails regarding a discovery plan and scheduling dates. On April 7, 2009 the parties had a lengthy conference call in which defendant James Turek commented on the proposed Joint Report and the parties agreed on various dates. The participants in the call were: Nancy J. Gegenheimer Attorneys for Plaintiff Securities and Exchange Commission 1801 California Street, Suite 1500 Denver, Colorado 80202 Telephone: (303) 844-1000 Facsimile: (303) 844-1010 James Turek 1795 Alysheba Way, #3105 Lexington, KY 40509 jturek@elitemediagroups.com Telephone: (859) 263-1872 Facsimile: (859) 806-0999 The parties have reached agreement on the dates by which they reasonably believe it will be necessary to complete the following: a. The parties have discussed and will continue to discuss possibilities for a resolution. b. The parties views and proposals required by Rule 26(f). 1. The parties agree that disclosures will be completed the week of April 27, 2009. 2. Discovery will be needed as follows: (i) The parties do not expect to exceed the number of depositions, interrogatories or requests for production allowed by the Federal Rules. (ii) The parties agree there will be no limit on requests for admission to authenticate documents but other request for admissions will be limited to 20. (iii) Pretrial discovery will be completed by January 15, 2010. c. No later than September 15, 2009, the counsel for the parties shall file all motions to join additional parties and to amend the pleadings. d. No later than November 1, 2009, counsel for the parties shall file all dispositive motions. e. No later than October 15, 2009, the parties will make expert disclosures required by Rule 26(a)(2), which will be during the pretrial discovery phase of the case. f. The parties have agreed on a three (3) day trial. Defendant indicated in the planning call that he will demand a jury. g. The dates that are mutually convenient with the parties to assign this case for trial are: After April 1, 2010. h. The parties do not desire a scheduling conference before entry of a scheduling order. i. The parties do not agree that this action may be referred to a United States Magistrate Judge for trial but may be referred for all other proceedings pursuant to 28 U.S.C. § 636(c) j. This case is not one in which qualified immunity is a defense. k. This case is not a product liability case l. This case is not an E.R.I.S.A. case. Dated: April 10, 2009 Respectfully submitted: _s/Nancy J. Gegenheimer__ Nancy J. Gegenheimer Attorneys for Plaintiff Securities and Exchange Commission 1801 California Street, Suite 1500 Denver, Colorado 80202 Telephone: (303) 844-1000 Facsimile: (303) 844-1010 s/ James Turek_ James Turek 1795 Alysheba Way, #3105 Lexington, KY 40509 jturek@elitemediagroups.com Telephone: (859) 263-1872 Facsimile: (859) 806-0999

To: scion who wrote (12207)	4/23/2009 1:21:02 PM
From: scion	Read Replies (2) \| Respond to of 12518

Pacer update 21 Apr 09 Case Number 5:08-cv-00395-JBC Securities And Exchange Commission v. Turek et al Date Filed # Docket Text 04/21/2009 24 NOTICE OF FILING by Securities And Exchange Commission (Attachments: # 1 Proposed Order Granting SEC's Motion to Withdraw the Reference)(Gegenheimer, Nancy) (Entered: 04/21/2009) 04/21/2009 NOTICE OF DEFICIENCY TO Nancy Gegenheimer re 23 MOTION to Withdraw Reference by Securities And Exchange Commission. Attorney has failed to submit a proposed order as an electronic attachment to the motion. Entry by attorney; attorney shall prepare a pleading entitled Notice of Filing (with a certificate of service), file the Notice using the event Notice of Filing, attach the proposed order, and create a link to the related docket entry within 3 business days. cc: COR (STB) (Entered: 04/21/2009) 04/20/2009 23 MOTION to Withdraw Reference by Securities And Exchange Commission (Gegenheimer, Nancy) (Additional attachment(s) added on 4/22/2009: # 1 Proposed Order) (STB). (Entered: 04/20/2009) 04/14/2009 22 SCHEDULING ORDER: (1) parties exchange initial disclosures by 5/1/2009; (2) exchange expert disclosures by 10/15/2009; (3) supplementations due 30 days of discovery of new info or no later than 30 days prior to close of discovery; (4) Discovery due by 1/15/2010; (5) discovery disputes referred to Magistrate Judge James B. Todd; (6) motions to amend pleadings or join parties due by 9/15/2009; (7) Dispositive Motions due by 2/15/2010; (8) witness list, exhibit list, pretrial memo due 7 days prior to PTC; (9) premark exhibits 7 days prior to PTC; (10) conduct conference re agreed proposed jury instructions 7 days prior to PTC; (11) PRETRIAL CONFERENCE set for 5/13/2010 at 10:00 AM in LEXINGTON before Judge Jennifer B Coffman; (12) agreed proposed jury instructions due at PTC; (13) submit agreed statement of case at PTC; (14) objections to use of depos, admissiblity of exhibits due at PTC; (15) submit copy of exhibits to chambers 3 days prior to trial; (16) JURY TRIAL set for 6/14/2010 at 9:00 AM in LEXINGTON before Judge Jennifer B Coffman for 3 days; (17) Requests to modify dates herein submit upon motion; (18) TELEPHONIC STATUS CONFERENCE set for 8/27/2009 at 10:00 AM before Judge Jennifer B Coffman. Signed by Judge Jennifer B Coffman.(STB)cc: COR,D,JC (Entered: 04/14/2009)