Marco Continuance Motion

8/2/2019 Marco Continuance Motion

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1tD -.. RECEWEEKFQO SERVE;

* W $WWOarco (Risson

2 Defendant ln Pro Per)823 Tamiami Trial East # 567 IFF - 3 2712

:.j aples Florida aal la08-444-0181

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m THE IJNITIED STATES DISTRICT COURT

FOR TllE DISTRICT OF NEVADA

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ECURITIES A'ND EXCHANGE ) Case No.: 2:O9-cv-O01O4-LDG-GW F0OM M ISSION ,

11 DEFENDANT Gl-lsstm 's M OTION FORlaintil A CONTINUANCE OI7 TRIAL,2

DECLARATION OF MARCO GLISSONvs3 '

Date of Hearing: No Hearing Date SetRCO GLISSON, j4fendant. )e

15 )

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M ARCO GLISSON submits the within motion to continue the trial in this case to7

llow for adequate preparation of the case for trial.8

19M EM ORANDUM

20

21The trial of this case is set for April 9

, 2012. M arco Glisson hired N evada22

orney Fredrick Santacroce to prepare the case for trial and to try the case. On or about

23 arch 7, 2012, Santacroce informed Olisson that he was suspending al1 work on the case

24 less anduntil he was paid more money. Glisson informed Santacroce that he had been

25 id a11 of the money due and owing under their written rtxtainer agreement Santacroce

26 d an' d amrmed that he would not doany more work on the case, and that heagree

27 ould tile a motion to withdraw. On M arch 21, 2012, Santacroce fled his motion to

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Case 2:09-cv-00104-LDG -GWF Document 108 Filed 04/03/12 Page 1 of 18



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2 withdraw as Glisson's trial attorney. See Exhibit A-2. Glisson immediately prepared an

:.) opposition (Exbibit A-1) and ask Santacroce to tile it with the Court. See Exhibit A-l .

Santaorose refused.

W ithout having seen Glisson's opposition, and without hearing,the Court denied

Santacroce's motion on M arch 23, 20 l2.

As a result of their di sagreement over the financial asped of their relationships .

aad Santacroce's unwillingness to put Glisson's position before the Court (including that

he preferred to hire new Nevada counsel to take over for Santacroce and finish preparing9for trial and to try the casel, tension and uneasiness existed between Glisson and

10 Santacroce. Glisson was also concerned that

, as represented, Samacroce had not been

11 working on the case for approximately t'wo weeks and that the clse was not being

12 . .prepared for trial by Santacroce.

13 Glisson met with Santacroce in his om ces in Las Vegas on April 2, 2012 to

1.4 review the status of trial preparation. Glisson learned at that time that Glisson's trial

15 subpoenas had not yet gone out for service Glisson's trial witnesses had not yet been

16 intelwiewed (or sewed with trial subpoenas). No summaries for use at trial of key

17 witnesses' depositions had been prepared, and one important deposition transcript (SEC'S

18 witness Jason Perryl had not been purchased for use in preparing for trial despite prior

jg assurances to do so. Glisson summaa exhibits for use at trial had not been prepared.

There was no dralt of the proposed Glisson trial brief that was available for his review,0

and that the (ilisson proposed tindings of facts and conclusions of 1aw document had not1

been started and there seemed some confusion on Santacroce's part as to when it was2

adually due. None of Glisson's trial exhibits had been assembled for use at trial23

Glisson expressed his concern to Santacroce about the apparent lack of 24preparation for trial. His belief that the case was not ready for trial - - which is to take

25place beginning in four court days Glisson asked Santacroce if it was appropriate for

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2 Santacroce to ask the Court at the Calendar Call for a continuance of the trial date, so as

:.) to provide him with more time to get the case ready for trial. Santacroce told Glisson that

he would not make such motion/request (because he thought the case was ready to be

triedl; and that, if Glisson was concerned aboul the case not being ready for trialp he

would have to make such rm uest/motion to the Court himself

Glisson has concluded that his relationship with Santacroce has deteriorated to the7

point where he no longer has confdence in Santacroce's ability to represent his be't

8interests including selwe as his trial attorney.

9Accordinglys Glisson feels compelled to ask for a continuance of the trial date so

10as to allow Santacroce to actually prepare the case for trialk and, if the Court is agreeable,

11 to provide Glisson with the additional time necessary to retain new Nevada counsel to

12pick-up where Santacroce leh ofs and to prepare the case for trial and tb try the case.

13 see the accompanying Declaration of M arco Glisson.

14

Dated: April 3, 20125

16 Respectfully submitted,

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19 . M Y WNfarco Glisson

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1DECLARATION 0F M ARCO GLISSON

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3 The undersigned, M arco Glisson, hereby declares as follows:

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1. l am the defendant in this case and othenvise com petent to provide the within5Declaration statements which are based on my own personal knowledge.

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2. l have made a11 payments to M r. Santacroce required of me under our Rdainer

8 Agreement, and l have otherwise performed my obligations under the Agreement.

9 3. I will bring the Agreement to the Court appearance on April 3, 2012 so the

10 court can review and confirm the performance of my obligations to Mr. Santacroce under

11 the Agreement.

12 .4. Attached as Exhibits A-1 alzd A-2 are true and correct copies of the Santacroce

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motion to withdraw and the Glisson opposition provided by me for purposes of filing the.4

opposition with the Court.5

.16 5. The Trial of this case is set for April 9, 2012.

17 6 After M r Santaoroce told me on or about M arch 7, 2012 that he was

18 ding a1l work on this case until he was paid more money,I naturally becameuspen

19 .worried that the trial preparation work we had discussed was not being performed in a

20tim ely m anner.

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7. On April 2, 2012, l met with M r. Santacroce in his otlice in Las Vegas to2

2:$ review the status of a1l trial preparation matters and to try to assist in such trial

24 preparation.

25 8 As of that datesl could not confirm that any trial subpoenas had actually been

26 'ssued to the witness we had discussed calling to testify at trial as indicated on the Joint

27Pretrial Order (although Nlr. Santacroce showed me several subpoenas which he said

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1might have gone out for service which copies looked like drahs and listed the tlial date as

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April 6, 2012.

4 9. Mr. Santacroce told me that he had not yet had the opportunity to interview

5 any of my proposed trial witnesses.

6 10 we discussed the fact that the proposed summary (witness) exhibits had not

7 been prepared.

81 1. M r. Santacroce indicated that he had not yet prepared summaries of the

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depo'sitions of key witnesses (including my depositionl; and that he had not yet ordered0

the deposition transcript of the SEC'S key witness (Jason Pen'y) although he had1

12 previously committed to do so as a priority item (indicating that he had spent the money I

13 put up for costs to cover a cost bill he presented me with at the meeting).

14 h draft of the Glisson proposed trial brief for me2. M r. Santacroce did not ave a

15to review at the meetingk he seemed confused about the need to prepare and submit

16proposed lindings of facts and conclusions of 1aw on April 3, 2012, so we worked most

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of the day to try to pull that document together for subm ission to tbe Court the next day.18

19 13. There was also no binder or other compilation of the Glisson designated frial

20 exhibits available for me to look at duling the meeting.

21 14. Based on what l am able to learn, M r. Santaoroce has not yet prepared this

22case for trial' and I am very concerned that he will not be able to accomplish such

23preparation during the next 4-5 days before the start of the trial of this case.

24l 5, W hen he was asked if it made sense to ask the Court for a cominuance of the

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trial so hç would have more time to better prepare the case for tfial, M.r. Santacroce said6

27 that he did not want to ask for a continuance and that he thought he could be ready by

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1pril 9, 2012' and he said, that if l thought more time was needed then I would have to

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sk the Court for more time because he would not do it even if that was my request to

im.

5 l6. M y relationship with M r. Santacroce has deteriorated to the point where I no

6 onger have confidence in his ability to represent my best interests and to do a good job

7preparing my case for trial and selwing as my trial attorney.

8l7. lt is very hard now for M r. Santacroce and me to accomplish anything

9ogdher.

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18. My preference is to be able to get more time for M r. Saatacroce to prepare1

12 this c'ase for trial tgd trial subpoenas out and selved, obtain and prepare N mmaries of

13 depositions of important witnesses, etc.),' really, my preference to be able to hire another

1.4 xevada atorney to pickup wlwre Mr. santacroce Ieft ofll actually prepare this case ror

15trial in the best way possible and to tl'y this case for me.

1.6l9. If I am called to testify in Court in resped of the foregoing matters,l caan and

17will so testif

.y to the foregoing statements.

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20 This Declaration is made and given by the undersigned, under penalty of perjury

21 under the laws of the United States,In Las Vegas, Nevada.

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23Dated: April 3, 2012

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27M arco G isson

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M arco Glisson

(Defendan;t In Pro Per)3823 Tmm ami Trail East # 567Naples, FL 34l 12Phone: 608-449-0181

IN THE UNITIED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA

SECURITIES AND EXCHANGE ) Case No.: 2:09-cv-00104-LDG-GWFCOMMISSION, )

)) DEFENDANT GLISSON'S OPPOSITION) TO HIS TRIAL COUNSEL FREDRICK3létillti ll

,SANTACROCE S MOTION TO) W ITHDRAW ; DECLARATION OF MARCOS

. ) GLISSON) ,.ARCO GLISSON, ) ,

) Date of Hearing: Nb Hearing Date Setefendant)

MARCO GLISSON responds and objects to the Motion To Withdraw As Counsel

of Record filed by his attomey Fredrick Santacroce on March 2 l , 2012 tthe Etsantacroce

Motion'' or simply the ççhlotion'')

OPPOSITION M EM ORANDUM

The trial of this case is set for April 9, 2012. Less than 20 days before trial,

defendant Glisson's trial attorney has asked to withdraw as his attorney. As continued

by his Declaration, Santacroce was retained to prepare the case for trial atld to tl.y the

cmse. Glisson will be severely prejudiced if his trial attomey is pennitted to withdraw on

the eve of trial tmless the Cotut will continue the trial for a reœsonable period of time so

as to allow Glisson .to retain substitute local Nevada counsel to pregare for mld try the

case. '

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Glisson has performed ali of his obligations under the reuiner agreement with

Santacroce. Glisson will submit a copy of the agreement to the Court at the hearing on

the M otion so the Court can conlirm such fact Rather than any nonpedbrmance by

Glisson under the agreement, ms indicated by Santacroce as the basis for his decision to

seek to withdram Glisson believes that the real reason for the M otion is that Santacroce

had failed to prepare the case for trial

Robert Bretz' involvement as attorney for Glisson in this case (pursuant to LR IA

10-2 based on Mr. Santacroce's motion as resident memser of the Nevada Bar) was from

tlw outset expressly conditioned upon Glisson retaining local Nevada counsel to prepare

the case for trial and to try the case.1/ Santacroce wms inform ed when he was retained

that Bretz was not engaged to act ms Glisson's trial counsel. ln September 2011,

Santacroce agreed to act as Glisson's trial attemey. Bretz' tiles wel:e ttm zed over to

Santacroce; and, from that time fonvard to date,a11 filings in this case have been prepared

and made by Santacroce. Santacroce was retained for the purpose of, and he expressly

agreed to be responsible fors preparing this case for trial and f0r ttying this case; aad he is

aware that his requested withtlrawal immediately before trial will substantially prejudice ..-)

Glisson (especially if the cmse has not been prepared for trial by Santacroce)

Glisson is not interested in forcing Santacrooe to eontinue to act as his t'ial

counsel now that Santacroce has decided he wants to be relieved of his responsibility.

But, Glisson must have counsel represent him at tlle trial of this case.z/ If the case is

going to be tried smrting April 9, 2012, (Xisson has no choice but to object to

Santacroce's Motion To W ithdraw. lf the Court is willing to continue the trial for a

1/ It is doubtful that, if Santacroce is permitted to witlkdraw,tbal Bretz could

make any further appearance in this cmse (absent a co-counsel who is a resident member

of the bar of this Courtl. LR IA 10-2 (d).

2/ The Plaintiff SEC has not alleged any fraud by Glisson as the basis for itscase. The case is an unregistered broker-dealer case. (footnote continued on nextpage).

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reasonable peliod of time (150- 180 days) so as to permit Glisson to retain alternative

local Nevada counsel to prepm.e for and tlial this cmse, then Glisson will withdraw his

objection to Santacroce's untimely decision to seek to withdraw as his attorney.The within Opposition is made and based upon the Court's files and records in

this case, the accompanying Declaration of Marco Glisson and such further m atters as

the Court shall receives for purposes of the Motion including at oral argument on the

M otion.

Dated: M arch 23, 2012.

%

Respectfully submitted,

M arco cgisson

2/ (f'n. continuedkom prior page) But, the Plaintiff is seeking damages, fines andpenalties against Glisson in the millions of dollars. The cmse also has possible criminal

ramifications as a result of the Plaintilrs referral of certain discovery obtained in thiscase to the IRS relating to an unpaid tax obligation by Glisson which Is lmrelated to the

subject matter of this case. See Glisson's motions to stay, bifurcate and exclude currentlypending before the Court. Accordingly, Santacroce's civil and crim inal backgrotmd and

trial experience were factors tmderlying Glisson's decision to retain Santaoroce to serveas his trial counsel in this case. On facts and legal theories essentially the same as setforth in the Plaintiff's portion of the Joint Pretrial Order, the Court previously denied the

Plaintiffs motion for summary judgment.

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DECLAM TION OF M ARCO GLISSON

The undersigned, M arco Glisson,hereby declares as follows:

1. I am the defendant in this case and otherwise competent to provide the within

Declaration statements which are based on my own personal knowledge.

2. For pum oses of providing this Declaration,I have carefully reviewed the

written retainer agreemtnt between myself and Freclrick (t1Rick'') Santacroce dated

September 9 . 201 1 wherein M r Sanucroce agrees to act as my attom ey for purposes

of preparing this case for trial and toring this case.tthe GtAgreement''),

3 The Agreement does not contain any provision pennitting M r. Santacroce to

withdraw as m y attorney; he is only permitted to withdraw if l fail to make payment of

am ounts due and owing to him as provided for in the Agreement and,even then, only

consistent w1t.11 applicable rules of professional responsibility.

4. I have made a11 payments to M r Santacroce required of me tmder the

Agreement, and I have otherwise performed my obligations tmder the Agreement.

Agreem ent.

5. 1 will bring the Agreement to the heming on M r. Santacroce's M otion To

Withdraw so the Court can review mzd confirm the performarlce of my obligations to M r.

Santacroce under the Agreem ent.

6. 'I'he Trial of this case is set for April 9,2012.

7. In any event, Mr. Santcroce's M otion can not be considered as timely made in

my mind; and, if he is permitted to withdraw ms my trial attorney,1 believe I will be

substantially prejudiced if the trial of this case proceeds as presently scheduled.




2. Bmsed on what I have been able to determinesM r. Santacroce has not prepared

this cas: for trial in accordance with the specific provisions of the Agreem ent; and lam

concerned that his Motion To W ithdraw is likely the result of the lack of such

preparation.

9. Robert Bretz's involvement as an attom ey for m e in this case has always been

based on the understanding and agreement that l would retain local Nevada cotmsel to

prepare this case for trial mzd to try this case; and Mr. Santacroce was inform ed of this by

me when he was retained to be my trial attorney.

10. M r. Bret is retirement age and,to the best of my knowledge,he has no

presence or local capability in Nevada.

1 1. Prior to his early involvement as my loca! attom ey in this case and his

specilically having been retained as my trial attorney in this case, M r. Santacroce had

represented me in connection with another Nevada based matter; and,his background and

experience in trying both civil and criminal matters in Nevada Courts made him a good

candidate in my mind to senre as my trial attorney in this case (brought against me by an

agency of the U.S. Government).

12. Accordingly, I retained M r Santacroce and his Oflice to be my attorney for

purposes of the trial of this case.

13. The Agreem ent with M r. Santacroce contirm s that he was retained for

puposes of preparing my case for trial and acting as my trial attorney (as suted and

continned by M r. Santacroce in paragraph 6 of his Declaration dated M arch 21,2012).

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14. Obviously, I need Mr. Santacroce to continue as my trial attorney (if he can

prepare my case for trial) if the trial of this case is going to proceed on April 9, 2012)

and, consequently, 1 have no choice but to object to his Motion To Withdraw.

15. M y preferencc, however, would be to agree to M r. Santacroce's requested

with/ awal if the Court, as part of its decision to penuit Mr. Santacroce to withdraw, will

continue the trial date in this case for a reasonable period of tim e so as to allow me to

retain substitute local N evada counsel for pumoses of preparing arid trying my case for

trial.

16. I live in the Naples, Florida area.

17. Based on m y prior experience interviewing several Las Vegas attorneys

including M r. Santacroce in the Summ er of 20l l for purposes of engaging one of them to

serve ms my trial attorney in this case, I believe I could retain substitute counsel for

ptuw ses of preparing for and trying this case if the Court would continue the tlial date a

minimum of 150-180 days.

18. I have been inform ed, and believe, that I have a good chance to prevail at the

trial of this case based upon the Plaintifrs legal theory and contention that l was a

broker-dealer of securities for a period of tim e in 2005-2007.

19. If l am called to testify in Court in respect of the foregoing matters, l can and

will so testify to the foregoing statements.

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This Declaration is made and given by the undersigned under penalty of perjur,y

tmder the laws of the United States

Dated: M arch 23s 2012

. &' - .M arco Glisson

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1 SANTACROCE LAW UFFICE,LTD.

FREDERICK A.SANTACROCE, ESQ.Nevada BarNo. 5121

706 S. Bighth Street3 Las Vegas

,Nevada 89101Phone: (702) 598-1666 Facsimile: (702) 325-1327

5 UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

7 U.S. SECURITIES AND EXCHANGE ) Case No: 2:09-CV-00104-LDG-GAOM M ISSION, )

) M OTION TO W ITHDRAW ASlaintiff, ) COUNSEL OF RE CORD

)V'E;. )0

)ARCO GLISSON, )1

)

efendant. )2 )13

Pursuant to Nevada Rules of Professional Conduct 1.16 and Local Rule 10-6, Santacro4

Law Offices, Ltd., (the <tl7irm'') attorneys for Defendant M arco Glisson CtMr Glissolf'). llereb5 1

j; move this Court for an order granting this M otion to W ithdraw as Cotmsel of Record.

17M EM ORANDUM OF POINTS AND AUTHORITIES

1 81.

19 STATEM ENT OF FACTS

20 M r. Glisson retained Santacroce Law Om ces,Ltd., to act as locai counsel inthis matter

21 California attorney Robert H. Bretz, Esq. On or about September 2011, M r. Glisson retai

22 Santaccrooe Law offices Ltd.,to be responsible for pre-trail m atters as well as litigating the c

23 Approxim ately two weeks ago a dîspute arose between Santacroce Law Offices, Ltd and M

24 Glission regarding the term s an4 conditionsof tize retainer agreem ent. Further, tlle retai

25 agreement allows santacroce Law om oes, Ltd., to withdraw at any time upon notice to M

26 Glisson.M r.Glissonhasbeenie ormedthatunlesshisobligationsx dertheretaineragreemen

27 tulslledthat santacrocen w orfices, Ltd., would be withdrawing.M r. elissonhms failedto ful

28GERRY G. ZOBRIST.LTD.

Ademep at Law

54 West SaI= Ave, ite 2t!t ve xex s$! ,6

h nlriozj -,1,6

miu (,c ) 6r6.sI57 .-- j,yyy v . ;




1 those obligations

2 M r.Glisson would not be prejudiced by this witladrawal as California attorney Robert H

3 Bretz, Bsq., has been counsel on this cmse since its inception and continues to remain as

4 Glisson's Counsel.

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L EGAL ARGUM ENT

y A. Good Cause Exists For the Finn to W ithdraw

: Nevadw Rules of Professional Conduct 1.t6(b) provides in m rtinent part as follows

: lawyer may withdraw from repressenting a client if (5) the client fails substantially to fulfill

1() obligationto the lawyer regarding tlw lawyer's services and has been givenreasonable warning th

11 the lawyer will withdraw tmless tlle obligation is ftlltilled.'' In this case, M r. Olisson was inform

12 num erous times that a witlzdrawal would be tiled if he failed to m eet his obligation to the Firm

13 of this date, M r. Glisson has failed to do so and continuing to represent M r.Glisson will presen

14 substantial financialburdenontheFirm .PursuanttoLocal Rule 10-6,M r. Glissonhasbeennoti

15 of counsel's intentto w'ithdraw and electronio serviceofthis m olitm will serve as nolicetoopposi

16 counsel.

17 jjjcoxctrslfm

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Based on the foregoing Santacroce Law Ofrices,Ltd., respectfully requests that tllis C9

grmzt an order allowing the withdrawal of Smlucroce Law Offices,Ltdv, as counsel of record0

the Defendant M arco Glisson.1

zz DATED this Zl day of M arch,2012.

23 SANTACROCE LAW OFFICES, LTD.

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25 F RICK A. SANTACROCE, ESQ.N evada Bar No. 512126 706 S. Eighth Street

Las Vegas, N evada 8910127 Phone: (702) 598-1666

Facslmile: (702) 385-13278

GERRY G. ZOBPJST LTD.M omeys attmw

, 44n v/e. saw a Ave, sui 2:veo s w.w svl1:

'';s ina) 656-,1,6zef(,az) 6ss-sl 5, -2 -acs




1 CERTIFICATE OF SERVICE

2 I hereby certifythat onM arch 21,2012, Pursuant to Fed. R. Civ. P. 5@) thatl served atru

3 and correct copy of the foregoing M OTION TO W ITHDM W AS COUNSEL OF RECORD t

4 arties listed on the N otice of Electronic Filing via the CM/ECF system and m ailed to the pa

5 listed below :

6 Us secmities and Exchmve commission

Los Angele? Regional Office ,s670 w ilslure Blvd.. 1 l Floor

Los Angeles, cA 90ù36-3648

9 Robert .Bretz, Es .578 W ashington Blv ,Ste. 843M 'rm a Del Ray, CA 902920

11 M arco Glisson3823 Tamiami Trail East /5 67

12 Naples, FL 341 12 --.

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14 An employee of Santacroce Law Offices, Ltd.

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28GFA RY 0.ZOBRIST, LTD.

Attomeys at Law

5440 West Salu'tra Ave, Suite 20

Vegas Nevada 89 46,*;u, e(iaz) (;x-5!,)Facminile (702) 656-51 57 -3-




1 D-ECLARATION OF FREDERICK A. SANTACROCE

2 I declare as follows:

31. I am license to practice law in the State of Nevada and admitted to practice

4 before tlzis court.

5 2 'fhat the t'acts stated lwrein are based on my pemonal knowledge,unless stated t

6 be on inform ation mzd belief,and as to said facts, l believe them to be true.

7 is to the matters That I mn over eighteen years of age and am competent to test

8stated herein and am willing to testify if called upon to do so in open court.

9 4. 1 am the principal of Santacroce Law Offices, Ltd., which is currently local

10counsel for Defendant, M arco Glisson.

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5. That M r. Olisson reoined Sanucroce Law Oflices, Ltd., to act as local counse12this m atter for California attorney Robert H. Bretzy Esq.

136. That on or about September , 201 1, M r. Glisson retained Santacroce Law ofik

14Ltd., to be responsible for pre-trail m atters ms well as litigating the case.

157. Thatapproximatelytwo weeks ago a dispute arosebetween Santacroce Lawofti

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Ltd., and M r. Glission regarding the term s and conditions of the reoiner agreement.17

8. That the reuiner agreem ent allows SanGcroce Laaw Offices, Ltd., to withdr18

any time upon notice to M r. Glisson.9

9 'Ihat M r Glisson hms been infonned that unless his obligations under the re0 ' *

agreement are fulfilled tlmt Su tacroce Law Offkes, Ltd., would be withdrawing.1

10. M r. Glisson has failed to fulfil those obligations.2

z3 1 1 . Mr. Glisson would not be prejudiced by this withdrawal as Califomia attome

:,4 Robel't H . Bretz, Esq., hms been cotmsel on this cmse since its inoeption and continues to re

2s M r. Glisson's Cotmsel.

26 ///

2 7 ///

. ;t 8 ///GERRY G. ZOBRIST.L'ID.

Attomcys at I-aw

5449 Wtst Sahara Ave. Suite 20f-as Vegas Nevada 89146PNone X2) 656.5156Facsimile (792) 656-5157 -4-




1 12. That the last known address for M r. Glisson is 3823 Tamiami Trail East #567

2 Naples, FL 34l 12.

3 I declare the foregoing to be correct under penalty of perjuly

4 Dated this ,CJ day of March,2012.

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FRE ERICK A. SANT CROCE

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GERRY G.zoBFJsT.LTD.AuonzeysatLaw

544: viest sakva Ave sute 2Ncvada k9146as vegas

Psone(i02)656-5156Facsisule(702)656-5l57 - 5 -


Documents

Marco Continuance Motion