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DEFS EX PARTE MOTION TO EXTEND DATES

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KENNETH G. EADE (SBN 93774)
keneade@gmail.com
8484 Wilshire Blvd., Suite 515
Los Angeles, CA 90211
Telephone: (323) 782-8802

Attorney for Defendant
Kenneth Eade, In Propria Persona



UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.
GOLD STANDARD MINING CORP.,
et al.,
Defendants.

Case No. CV 12-5662 JGB (CWx)
DEFENDANTS EX PARTE MOTION
TO EXTEND PRE-TRIAL DATES


Date: August 11, 2014
Time: N/A
Courtroom: 1, 3470 Twelfth Street
Riverside, CA 92501
Judge: Hon. Jesus G. Bernal


Defendant KENNETH G. EADE hereby moves this Court ex parte for an Order to
extend the last day to file and hear dispositive motions, the last day for mediation, and the
last day for conducting settlement conferences, given the parties stipulation to extend the
pre-trial and trial dates in this matter.
Said motion is based on this motion, the attached Declaration of Kenneth Eade, the
papers and records on file herein and upon such other and further evidence as the Court
may consider at the hearing of this motion.

Case 2:12-cv-05662-JGB-CW Document 94 Filed 08/08/14 Page 1 of 6 Page ID #:1335

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DEFS EX PARTE MOTION TO EXTEND DATES
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DATED: August 8, 2014
Respectfully submitted,

/s/ Kenneth Eade
KENNETH EADE (SBN 93774)
Attorney for Defendant, In Propria Persona
Case 2:12-cv-05662-JGB-CW Document 94 Filed 08/08/14 Page 2 of 6 Page ID #:1336

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DEFS EX PARTE MOTION TO EXTEND DATES
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DECLARATION OF KENNETH EADE
I, KENNETH EADE, hereby declare as follows:
1. That I am an attorney at law, duly licensed to practice before this Court, and,
if called upon as a witness, could competently testify as to the following facts, within my
personal knowledge.
2. Given the fact that the parties have stipulated to an extension of time for the
pretrial and trial dates in this case, and have not yet conducted any ADR proceedings as
required, good cause exists to extend the last day for dispositive motions, which is now
set for August 11, 2014, and the last day to conduct settlement conferences, which is now
set for August 30, 2014, as well as any other pretrial dates for this matter.
3. Since April 2013, I have been engaged in active settlement discussions with
the Plaintiff, including the submission of a financial statement in May 2013, and this
culminated in the Plaintiff forwarding a settlement offer to my attention for execution.
4. Twenty-four hours prior to making this motion, I advised Leslie Hughes,
Nancy Ferguson and Donald Searles, counsel for the plaintiff, and counsel for defendant
E. Randall Gruber, by email that I would be making this motion 24 hours after the email
notice. The names, addresses, email addresses and telephone for counsel are:
Leslie J. Hughes and Nancy J. Ferguson, Securities and Exchange Commission,
1801 California Street, Suite 1500, Denver, Colorado 80202; Tel: 303-844-1000;
email: HughesLJ@sec.gov; FergusonN@sec.gov.
Donald W. Searles, Securities and Exchange Commission, 5670 Wilshire Blvd.,
11
th
Floor, Los Angeles, California 90036; Tel: 323-965-4573; email:
SearlesD@sec.gov.
Marc A. Indeglia, Indeglia & Carney, 11900 Olympic Blvd., Suite 770, Los
Angeles, CA 90064; email: marc@indegliacarney.com.
Case 2:12-cv-05662-JGB-CW Document 94 Filed 08/08/14 Page 3 of 6 Page ID #:1337

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DEFS EX PARTE MOTION TO EXTEND DATES
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5. Counsel for the Defendant, Edward Randall Gruber and Gruber & Co., LLC
has indicated that the said Gruber defendants join in the motion. Counsel for the Plaintiff
has indicated that the SEC has no objection to this motion.

I declare under penalty of perjury under the laws of the United States of America
that all of the foregoing is true and correct this 8th day of August, 2014.

/s/ Kenneth Eade
KENNETH EADE
Case 2:12-cv-05662-JGB-CW Document 94 Filed 08/08/14 Page 4 of 6 Page ID #:1338

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PROOF OF SERVICE
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PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I am employed in the County of Los Angeles, State of California. I am over the
age of 18 and not a party to the within action, my business address is 8484 Wilshire
Blvd., Suite 515, Los Angeles, California 90048.
On August 8, 2014, I served the foregoing documents described as:
DEFENDANTS EX PARTE MOTION TO EXTEND PRE-TRIAL DATES;
(PROPOSED) ORDER
on the parties in this action by placing a true copy thereof enclosed in a sealed envelope
addressed as follows:
SEE ATTACHED SERVICE LIST
BY U.S. MAIL: I placed the envelope for collection and mailing, following our
ordinary business practices. I am readily familiar with this firms practice for
collecting and processing correspondence for mailing. On the same day that
correspondence or other service document is placed for collection and mailing, it is
deposited in the ordinary course of business with the United States Postal Service,
in a sealed envelope with postage thereon fully prepaid.
BY CM/ECF: The document was electronically served on the parties to this action
via the mandatory United States District Court of California CM/ECF system upon
electronic filing of the above-described document.
Executed this 8th day of August, 2014, at Los Angeles, California.
I declare that I am employed in the office of a member of the bar of this Court at
whose direction the service was made.
/s/ Nichelle Guzmn
NICHELLE GUZMAN

Case 2:12-cv-05662-JGB-CW Document 94 Filed 08/08/14 Page 5 of 6 Page ID #:1339

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PROOF OF SERVICE
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SERVICE LIST

COUNSEL FOR SECURI TI ES AND
EXCHANGE COMMI SSI ON

COUNSEL FOR DEFENDANTS GRUBER
AND COMPANY LLC & EDWARD RANDALL
GRUBER CPA
Leslie J Hughes
Nancy J. Ferguson
Securities and Exchange Commission
1801 California Street Suite 1500
Denver, CO 80202
303-844-1000
303-844-1068 (fax)
HughesLJ@sec.gov
FergusonN@sec.gov
Marc A Indeglia
Indeglia and Carney
1299 Ocean Avenue Suite 450
Santa Monica, CA 90401
310-982-2720
310-458-8007 (fax)
jessie@indegliacarney.com
Donald W Searles
Securities and Exchange Commission
5670 Wilshire Boulevard 11th Floor
Los Angeles, CA 90036
323-965-4573
323-965-3908 (fax)
searlesd@sec.gov



Case 2:12-cv-05662-JGB-CW Document 94 Filed 08/08/14 Page 6 of 6 Page ID #:1340