Rothstein Kass Filings

Case Number 3:19-cv-01594-D

Thomas L. Taylor III, in his capacity as Court-appointed temporary Receiver v. Rothstein Kass & Company, PLLC and Brian Matlock

In the United States District Court for the Northern District of Texas, Dallas Division

Filings relevant to investors in the main Receivership matter can be found below. Documents are available for viewing by clicking on the docket number.
A comprehensive list of all filings in this lawsuit is available on the website of the United States Courts, Public Access to Court Electronic Records (“Pacer”).

This table will be updated in the coming days as we finished building this website. Thank you for your patience.

04/21/2021
120 Appendix in Support filed by Thomas L Taylor, III re 119 Motion to Approve Proposed Settlement with Rothstein Kass
04/21/2021
119 Motion to Approve Proposed Settlement with Rothstein Kass filed by Thomas L Taylor, III with Brief Memorandum in Support.
02/12/2021
118 Order Administratively Closing Case
02/12/2021
117 Alternative Dispute Resolution Summary
02/09/2021
116 Stipulation and Order Regarding Page Limits for Briefing on Defendants’ Daubert Motion
02/09/2021
115 Appendix in Support of the Receiver’s Response to Defendants’ Motion to Strike Saul Solomon’s Opinions and Exclude his Testimony From Trial
02/09/2021
114 Receiver’s Response to Defendants’ Motion to Strike Saul Solomon’s Opinions and Exclude his Testimony from Trial
02/09/2021
113 Stipulation and Proposed Order Regarding Page Limits For Briefing on Defendants’ Daubert Motion
02/04/2021
112 Plaintiff’s Notice of Supplemental Authority in Support of His Response to Defendants’ Motion for Summary Judgement
01/27/2021
111 Stipulation and Order Regarding Document Production and Briefing Schedule for Pending Motions
01/27/2021
110 Stipulation and Proposed Order Regarding Document Production and Briefing Schedule for Pending Motions
01/19/2021
109 Defendant’s Appendix in Support of Motion to Designate Responsible Third Parties
01/19/2021
108 Rothstein Kass’s and Brian Matlock’s Memorandum of Law in Support of Motion to Designate Responsible Third Parties
01/19/2021
107 Defendant’s Motion to Designate Responsible Third Parties
01/19/2021
106 Proposed Order Granting Defendant’s Motion to Strike Saul Solomon’s Opinions and Exlude his Testimony From Trial
01/19/2021
105 Defendant’s Appendix in Support of Motion to Strike Saul Solomon’s Opinions and Exclude his Testimony From Trial
01/19/2021
104 Defendant’s Memorandum in Support of Motion to Strike Saul Solomon’s Opinions and Exclude his Testimony From Trial
01/19/2021
103 Defendant’s Motion to Strike Saul Solomon’s Opinions and Exclude his Testimony From Trial
01/13/2021
102 Table of Contents
01/12/2021
101 Appendix in Support of the Receiver’s Response to Rothstein Kass’s Motion for Summary Judgment and Brief in Support
01/12/2021
100 The Receiver’s Response to Defendant Rothstein Kass’s Motion for Summary Judgment and Breif in Support
01/08/2021
99 Stipulation and Order Regarding Document Production and Motion for Summary Judgment Briefing
01/07/2021
98 Stipulation and Proposed Order Regarding Document Production and Motion for Summary Judgement Briefing
12/11/2020
97 Memorandum Opinion and Order
12/09/2020
96 Appendix in Support filed by Brian Matlock, Rothstein Kass & Company PLLC, Rothstein Kass PA re 94 MOTION for Summary Judgment (Attachments: # 1 Exhibit(s) 1, A-M, # 2 Exhibit(s) N-AE, # 3 Exhibit(s) AF-AP, # 4 Exhibit(s) AQ-CB, # 5 Exhibit(s) CC-CG, # 6 Exhibit(s) CH-CL, # 7 Exhibit(s) CM-CP, # 8 Exhibit(s) CQ-CR, # 9 Exhibit(s) CS-DF) (Morgan, Nicolas)
12/08/2020
95 Defendants’ Memorandum in Support of Motion For Summary Judgment
12/08/2020
94 Defendant’s Motion for Summary Judgment
11/18/2020
93 Defendants; Appendix in Support of Reply in Support of Motion to Compel Deposition of SEC
11/18/2020
92 Defendant’s Reply in Support of Motion to Compel Deposition of SEC
11/17/2020
91 Stipulation Regarding Michael Miller’s Deposition and Order
11/16/2020
90 Stipulation Regarding Rick Hoover’s Depostion Testimony in the Jinsun Action and Order
11/16/2020
89 Joint Status Report
11/16/2020
88 Stipulation Regarding Michael Miller’s Depostion and Proposed Order
11/16/2020
87 Stipulation Regarding Rick Hoover’s Deposition Testimony in the Jinsun Action and Proposed Order
11/12/2020
86 Amended Agreed Order on Amendment of Scheduling Order
11/09/2020
85 Agreed Order on Amendment of Scheduling Order
11/04/2020
84 Appendix in Support of Nonparty U.S. SEC’s Response to Defendants’ Motion to Compel
11/04/2020
83 Response and Objection
11/04/2020
82 Join Motion to Amend Scheduling Order
10/30/2020
80 Appendix in Support of Plaintiff’s Reply Brief in Support of Motion for Protective Order
10/30/2020
79 Plaintiff’s Reply Brief in Support of Motion for Protective Order
10/21/2020
78 Defendants’ Appendix in Support of Reply in Support of Renewed Motion to Compel Document Production
10/21/2020
77 Defendants’ Reply in Support of Renewed Motion to Compel Document Production
10/16/2020
76 Defendants’ Appendix in Support of Opposition to Plaintiff’s Motion for Protective Order
10/16/2020
75 Defendant’s Opposition to Plaintiff’s Motion for Protectvie Order
10/14/2020
74 Appendix in Support filed by Brian Matlock, re 73
10/14/2020
73 MOTION to Compel Deposition from Securities and Exchange Commission filed by Brian Matlock
10/07/2020
72 Appendix in Support filed by Thomas L Taylor, III re 71
10/07/2020
71 RESPONSE AND OBJECTION filed by Thomas L Taylor, III re 67 MOTION to Compel Document Production
09/25/2020
70 Appendix in Support of Plaintiff’s Motion for Protective Order
09/25/2020
69 Plaintiff’s Motion for Protective Order
09/16/2020
68 Defendant’s Appendix in Support of Renewed Motion to Compel
09/16/2020
67 Motion to Compel Document Production
07/31/2020
66 Order Granting Unopposed MOTION to Withdraw as Attorney Laura Maninger
07/30/2020
65 Unopposed MOTION to Withdraw as Attorney Laura Maninger
06/29/2020
64 ORDER denying Motion to Compel Document Production from Plaintiff the Receiver
06/29/2020
63 ELECTRONIC Minute Entry for proceedings held before Magistrate Judge Rebecca Rutherford: Telephone Conference held on 6/29/2020. Re: 39 MOTION to Compel Document Production filed by Brian Matlock, Rothstein Kass & Company PLLC with Brief/Memorandum in Support. Attorney Appearances: Plaintiff – Edward Snyder; Defense – Nicholas Morgan, Lunda Stahl.
06/25/2020
62 Appendix
06/25/2020
61 Defendant’s Supplement to Joint Report
06/24/2020
60 ELECTRONIC ORDER: The parties have alerted the Court that they failed to resolve the remaining matters presented in Defendants’ Motion to Compel 39 after conference. Accordingly, pursuant to the Court’s Order 57 , the parties have requested a follow-up telephone conference. The Court sets the matter for a telephone conference on June 29, 2020 at 11:00 a.m. The parties are to set up a conference phone line and inform the Court by email at rutherford_chambers@txnd.uscourts.gov of the dial-in information for the conference on or before June 29, 2020 at 9:00 a.m. The parties are advised that the Court has set aside 45 minutes for this telephone conference. Finally, to the extent
either party wishes to submit written argument in advance of the telephone conference, it may do so before the close of business on June 25, 2020. Such supplemental argument may not exceed 10 double-spaced pages. (Ordered by Magistrate Judge Rebecca Rutherford on 6/24/2020) (chmb) 
06/19/2020
59 Stipulation and Order
06/19/2020
58 Stipulation and Proposed Order Regarding Limit of Depositions
06/02/2020
57 ELECTRONIC ORDER: Following a telephone conference with the parties on 39 
Defendants’ Motion to Compel, the Court directed the Receiver to produce to counsel for Defendants, subject to 36 the protective order and no later than June 12, 2020, the documents responsive to Rothstein Kass’s Request for Production No. 31 that have been previously segregated by the Receiver or his assistant. The Court takes under advisement whether Defendants are entitled to any further relief. On or before the date that is 10 days from the date of the Receivers production, counsel will confer again by telephone to determine whether they can resolve this discovery dispute without further court involvement. If the matter is resolved by agreement, the parties will submit an agreed proposed order on the Motion to Compel on or before June 24, 2020. If the matter is not resolved by agreement, however, the Court will schedule a follow-up telephone conference on a mutually-agreeable date during the week of June 29, 2020. Any party may file a supplement to their portion of the Joint Report, not to exceed 10 double-spaced pages, at least one full business day prior to the follow-up telephone conference. (Ordered by Magistrate Judge Rebecca Rutherford on 6/2/2020) (chmb) 
06/02/2020
56 ELECTRONIC Minute Entry for proceedings held before
Magistrate Judge Rebecca Rutherford: Telephone Conference held on 6/2/2020. Re: 39 Motion to Compel. Attorney Appearances: Plaintiff – Edward Snyder; Defense – Nicholas Morgan, Linda Stahl. (Court Reporter: Shawn McRoberts) (No exhibits) Time in
Court – :22. (mcrd)
06/02/2020
55 Stipulation and Order
06/02/2020
54 Stipulation and Proposed Order Regarding Deposition
05/21/2020
53 ELECTRONIC ORDER: The parties have submitted a Joint Report 51 wherein they represent that oral argument regarding the pending Motion to Compel 39 would be helpful. Accordingly, the Court sets the Motion to Compel for a telephonic hearing Tuesday, June 2, 2020 at 3:00 PM before Magistrate Judge Rebecca Rutherford. The parties are to set up a conference phone line and inform the Court by email at rutherford_chambers@txnd.uscourts.gov of the dial-in information for the conference on or before June 2, 2020 at 12:00 PM. (Ordered by Magistrate Judge Rebecca Rutherford on 5/21/2020) (chmb)
05/19/2020
52 Appendix in Support of Joint Report
05/19/2020
51 Joint Submission on Discovery Matters
05/08/2020
50 Certificate of Interested Persons/Disclosure Statement
05/08/2020
49 Defendant’s Answer to Receiver’s First Amended Complaint
05/07/2020
48 Trial Setting Order
05/01/2020
47 Stipulation and Order
04/30/2020
46 Stipulation and Proposed Order Regarding Depositions
04/24/2020
45 Amended Complaint with Jury Demand
04/24/2020
44 Order Approving Unopposed Motion for Leave to File Amended Complaint and Rule Stipulation
04/24/2020
43 Unopposed Motion for Leave to File Amended Complaint and Rule
04/23/2020
42 Order Requiring Joint Report
04/21/2020
41 Appendix- Motion to Compel Document Production and Brief in Support
04/21/2020
40 Order of Reference
04/21/2020
39 Motion to Compel Document Production
04/03/2020
38 Stipulation and Protective Order
04/03/2020
37 ADVISORY TO COUNSEL: Please submit your proposed order for the following
document — in modifiable Word or WordPerfect format — to
Fitzwater_Orders@txnd.uscourts.gov.: 36 STIPULATION and Proposed Protective Order by Brian Matlock, Rothstein Kass & Company PLLC. (Senior Judge Sidney A. Fitzwater).
04/02/2020
36 Stipulation and Proposed Protective Order
2/28/2020
35 ANSWER to 1 Complaint, filed by Brian Matlock, Rothstein Kass & Company PLLC.
2/4/2020
34 MEMORANDUM OPINION AND ORDER granting in part, denying in part 19
MOTION to Dismiss Receiver’s Original Complaint filed by Brian Matlock, Rothstein Kass & Company PLLC.
1/14/2020
33 AGREED ORDER ON AMENDMENT OF SCHEDULING ORDER: ( Amended
Pleadings due by 6/1/2020. Discovery due by 11/16/2020. Joinder of Parties due by
5/15/2020. Motions due by 12/1/2020. Status Report due by 11/16/2020.)
1/13/2020
32 Agreed MOTION to Amend/Correct 29 Scheduling Order, filed by Thomas L Taylor, III
11/6/2019
31 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by Brian
Matlock, Rothstein Kass & Company PLLC.
10/21/2019
30 ORDER: Accordingly, no later than 21 days after this order is filed, defendants must comply with Rule 7.4 so that the court can ensure that recusal is not required in this case. 
10/21/2019
29 SCHEDULING ORDER: Amended Pleadings due by 3/31/2020. Discovery due by
8/14/2020. Joinder of Parties due by 1/30/2020. Motions due by 8/28/2020. Status
Report due by 8/14/2020.
10/16/2019
28 ORDER granting 27 Motion to Withdraw as Local Counsel For Receiver. The Clerk is ORDERED to remove Ballard & Littlefield LLP, Donald R. Littlefield, and Charles A. Hammaker from the service list for this matter.
10/16/2019
27 MOTION for Leave to Allow Withdrawal of counsel filed by Thomas L Taylor, III
10/11/2019
26 Proposal for contents of scheduling and discovery order by Thomas L Taylor, III.
10/4/2019
25 REPLY filed by Brian Matlock, Rothstein Kass & Company PLLC re: 19 MOTION to Dismiss Receiver’s Original Complaint
9/25/2019
24 ORDER granting 23 Unopposed Motion for Relief From In-Person Conference
Requirement filed by Rothstein Kass & Company PLLC.
9/24/2019
23 MOTION Unopposed Motion for Relief From In-Person Conference Requirement filed by Rothstein Kass & Company PLLC
9/20/2019
22 RESPONSE AND OBJECTION filed by Thomas L Taylor, III re: 19 MOTION to Dismiss Receiver’s Original Complaint
9/19/2019
21 Order for Scheduling Order Proposal: Proposed Scheduling Order due by
10/17/2019.
9/4/2019
20 ORDER granting 18 MOTION for Leave to Proceed without Local Counsel filed by Thomas L Taylor, III.
9/3/2019
19 MOTION to Dismiss Receiver’s Original Complaint filed by Brian Matlock, Rothstein Kass & Company PLLC with Brief/Memorandum in Support.
9/3/2019
18 MOTION for Leave to Proceed without Local Counsel filed by Thomas L Taylor, III 
7/22/2019
17 ELECTRONIC ORDER granting 14 Application for Admission Pro Hac Vice of Nicolas Morgan. Important Reminder: Unless excused for cause, an attorney who is not an ECF user must register within 14 days of the date the attorney appears in a case pursuant to LR 5.1(f) and LCrR 49.2(g).
7/22/2019
16 ELECTRONIC ORDER granting 13 Application for Admission Pro Hac Vice of Thomas A. Zaccaro. Important Reminder: Unless excused for cause, an attorney who is not an ECF user must register within 14 days of the date the attorney appears in a case pursuant to LR 5.1(f) and LCrR 49.2(g).
7/19/2019
15 NOTICE of Attorney Appearance by Linda R Stahl on behalf of Rothstein Kass &
Company PLLC.
7/19/2019
14 Application for Admission Pro Hac Vice with Certificate of Good Standing for
Attorney Nicolas Morgan (Filing fee $25; Receipt number 0539-10128408) filed by
Rothstein Kass & Company PLLC
7/19/2019
13 Application for Admission Pro Hac Vice with Certificate of Good Standing for
Attorney Thomas A. Zaccaro (Filing fee $25; Receipt number 0539-10128444) filed by Rothstein Kass & Company PLLC
7/19/2019
12 ***DISREGARD – REFILED AS 14 *** Application for Admission Pro Hac Vice with Certificate of Good Standing for Attorney Nicolas Morgan (Filing fee $25; Receipt number 0539-10128408) filed by Rothstein Kass & Company PLLC
7/19/2019
11 NOTICE of Attorney Appearance by Courtney Barksdale Perez on behalf of Rothstein Kass & Company PLLC.
7/18/2019
10 WAIVER OF SERVICE Returned Executed as to Brian Matlock. Waiver sent on
7/2/2019.
7/18/02019
9 WAIVER OF SERVICE Returned Executed as to Rothstein Kass & Company PLLC.
Waiver sent on 7/2/2019. 
7/16/2019
8 NOTICE of Attorney Appearance by Edward C Snyder for Jesse R. Castillo on behalf of Thomas L Taylor, III.
7/16/2019
7 NOTICE of Attorney Appearance by Edward C Snyder on behalf of Thomas L Taylor, III.
7/10/2019
6 Court Request for Recusal: The referral judge for this case has been reassigned via
random assignment to U.S. Magistrate Judge Rebecca Rutherford. U.S. Magistrate Judge David L. Horan is no longer assigned to the case.
7/2/2019
5 ORDER TRANSFERRING CASE. This case is hereby TRANSFERRED to the docket of the Honorable Sidney A. Fitzwater. All future pleadings shall subsequently be filed under case No. 3:19-CV-1594-D. Judge Jane J. Boyle no longer assigned to case.
7/1/2019
4 New Case Notes: A filing fee has been paid. Pursuant to Misc. Order 6, Plaintiff is
provided the Notice of Right to Consent to Proceed Before A U.S. Magistrate Judge
(Judge Horan). Clerk to provide copy to plaintiff if not received electronically.
7/1/2019
3 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by Thomas L Taylor, III.
7/1/2019
2 NOTICE of Related Case filed by Thomas L Taylor, III
7/1/2019
1 COMPLAINT WITH JURY DEMAND against All Defendants filed by Thomas L Taylor, III.