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MICHAEL S. REEVES, ESQ. State Bar Number: 010420 1212 East Osborn Phoenix, Arizona 85014 Tel: [602] 604-7577 Fax: [602] 604-7555 Attorney for Ronald Holt UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Securities Exchange Commission Plaintiff ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CV 03-1825 PHX PGR MOTION TO EXTEND FURLOUGH
Vs. Ronald Holt, et al Respondents.
Related Cases Commodities Futures Trading Commission v. Ronald Holt, et al, CV 03-1826 Investors in IFA, et al, v. International Funding Association, et al, CV 03-1302
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Ronald Holt, by and through undersigned counsel, hereby requests that the Court extend the furlough currently granted to Mr. Holt by this Court. In the Court's recent furlough order, the Court expressed that it had not yet seen the settlement agreements. A copy of those agreements is attached hereto. Mr. Holt signed the CFTC's settlement documents in October 2005. Mr. Holt signed the SEC's settlement documents the first week of November 2005. Both agencies told counsel that they would sign and return the agreements executed by Mr. Holt to the Court within 4-5 days of Mr. Holt delivering to them the agreements. Those 4-5 days have now turned into 2 months. The agencies have not stated that they intended to modify the agreements, which they had drafted and both agencies stated to counsel that they did not need the signature, nor approval of any superior. Neither agency has given any reason for the failure to sign the executed and unmodified agreements. Both agencies received the agreements from Mr. Holt via Federal Express as they requested. Wherefore, as it appears that there is no reasonable explanation for the delay in delivery
Case 2:03-cv-01825-PGR
Document 270
Filed 01/03/2006
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of the settlement agreements to the Court and whereas the agencies have not indicated that the agreements need to be modified or changed, and whereas the agreements conclude the case with a full and final settlement, Mr. Holt requests that the Court extend his furlough until the Court either has a hearing in the settlements or until the Court signs final orders settling this case. Dated: January 3, 2006 /s/ MICHAEL S. REEVES CERTIFICATE OF SERVICE I hereby certify that on this date, January 3, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of Notice of Electronic Filing to the following CM/ECT registrants: Marshall Gandy Merwin D. Grant Patrick M. Murphy by: /s/ Michael S. Reeves
I hereby certify that on January 3, 2006, I served the attached document by U.S. mail, fax and/or e-mail on the following, who are not registered participants of the CM/ECF System: Timothy J. Mulreany, Chief Trial Attorney Karon Powell, Trial Attorney Division of Enforcement 1155 21st Street, NW Washington, D.C. 20581 Attorneys for the Commodities Future Trading Commission Warfield & Company, CPAs 14555 North Scottsdale Rd., #340 Scottsdale, Az 85254 Receiver Thomas M. Connelly, Esq. 2425 East Camelback Road, Suite 880 Phoenix, Az 85016-4208 Susanne Ingold, Esq. Burch & Cracchiolo, PA 702 East Osborn Rd., #200 P.O. Box 16882 Phoenix, AZ 85011-6882 by: /s/ Michael S. Reeves
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Case 2:03-cv-01825-PGR Document 270 Filed 01/03/2006 Page 2 of 2