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To: scion who wrote (12255)	5/17/2010 12:05:09 PM
From: scion	Respond to of 12518

04/06/2010 16 Joint MOTION for discovery to Conduct Additional Depositions by all parties (Infelise, Jeffrey) Motions referred to Magistrate Judge Gregory J. Kelly. Modified on 4/7/2010 (LAK). (Entered: 04/06/2010) Doc 16 PDF file viewer.zoho.com JOINT MOTION FOR LEAVE TO CONDUCT ADDITIONAL DEPOSITIONS Pursuant to the Court’s Case Management Form, undersigned counsel for plaintiff, the Securities and Exchange Commission (the “Commission”) and counsel for defendants, Big Apple Consulting USA, Inc., MJMM Investments, LLC, Marc Jablon, Matthew Maguire, Mark C. Kaley and Keith Jablon (“defendants”), respectfully request leave to conduct 20 depositions per side. This case involves four individual defendants and two corporate defendants. Therefore, six depositions will be required just to depose all the defendants. Additionally, there are numerous witnesses who were employees and/or officers of CyberKey Solutions, Inc. residing outside the district and who, therefore, must be deposed in order to ensure their testimony is available for trial. This includes James Plant, the former CEO of CyberKey who is presently incarcerated in federal prison in Florence, Colorado. In its initial disclosures, the Commission identified 27 potential witnesses and defendants identified over 100 potential witnesses, the vast majority of whom reside outside the District. Counsel for the Commission and defendants believe that because of the complexity of this case and the number of individuals involved, they require 20 depositions per side. April 6, 2010 Respectfully submitted,