8:15-cv-00317-LES-FG3 Doc # 20 Filed: 10/05/15 Page 1 of 3 - Page ID # 65

UNITED STATES DISTRICT COURT

DISTRICT OF NEBRASKA

COR CLEARING, LLC, a Delaware limited

liability company,

)
)
)
Plaintiff,
)
)
v.
)
)
CALISSIO RESOURCES GROUP, INC., a
)
Nevada corporation; ADAM CARTER, an
)
individual; SIGNATURE STOCK TRANSFER, )
INC., a Texas corporation; and DOES 1-50.
)
)
Defendants.
)
)

Case No. 8:15-cv-00317-LES-FG3

EXPEDITED MOTION FOR ORDER
APPOINTING LIMITED PURPOSE
RECEIVER

Pursuant to Federal Rule of Civil Procedure 66, Plaintiff COR Clearing, LLC (COR
Clearing), by and through its attorneys of record, hereby moves the Court on an expedited
basis to appoint a Receiver for the limited purpose of instructing The Depository Trust &
Clearing Corporation to make post-payable adjustments in accordance with its policies and
procedures. COR Clearing proposes that Ronald F. Greenspan, Esq., be appointed as this limited
purpose Receiver. COR Clearing also proposes that any parties potentially affected by these
post-payable adjustments be given an opportunity to be heard by this Court before the Receiver
is appointed.
This Expedited Motion is supported by the Brief in Support of the Motion for Order
Appointing Limited Purpose Receiver and the Declarations of David L. Aronoff, Leonard
Hirschhorn, Carlos Salas, and Thomas Pikor contained in the Evidence Index submitted in
support of this Motion, which has been filed contemporaneously herewith, as well as the

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8:15-cv-00317-LES-FG3 Doc # 20 Filed: 10/05/15 Page 2 of 3 - Page ID # 66

pleadings, records and files herein which this Court may properly take judicial notice, and upon
such other and further evidence and arguments as the Court may receive prior to its decision.

WHEREFORE, COR Clearing hereby moves the Court for the appointment of a limited
purpose Receiver.

Dated: October 5, 2015

By:

s/ David L. Aronoff
Michael T. Hilgers (#24483)
mhilgers@goberhilgers.com
Carrie S. Dolton (#24221)
cdolton@goberhilgers.com
GOBER HILGERS PLLC
14301 FNB Parkway, Suite 100
Omaha, NE 68154
Telephone: (402) 218-2106
Facsimile: (877) 437-5755
David L. Aronoff*
daronoff@winston.com
Saul S. Rostamian*
srostamian@winston.com
Andrew G. Smith*
agsmith@winston.com
WINSTON & STRAWN LLP
333 S. Grand Avenue, 38th Floor
Los Angeles, CA 90071-1543
Telephone: (213) 615-1700
Facsimile: (213) 615-1750
* admitted pro hac vice
Attorneys for Plaintiff COR Clearing, LLC

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8:15-cv-00317-LES-FG3 Doc # 20 Filed: 10/05/15 Page 3 of 3 - Page ID # 67

CERTIFICATE OF SERVICE
I hereby certify that on October 5, 2015, a true and exact copy of the foregoing was
served on Defendant Calissio Resources Group, Inc. via U.S. Mail, postage pre-paid:
Clark Agency, LLC
5915 Edmond Ste 125
Las Vegas, NV 89118
s/ David L. Aronoff
David L. Aronoff

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