DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME PAGE 1

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

SECURITIES AND EXCHANGE 1

COMMISSION, 

Plaintiff,

v. 

TIMOTHY LYNCH BARTON 

CARNEGIE DEVELOPMENT, LLC 

WALL007, LLC 

WALL009, LLC 

WALL010, LLC 

WALL011, LLC 

WALL012, LLC 

WALL016, LLC 

WALL017, LLC 

WALL019, LLC 

HAOQIANG FU (a/k/a MICHAEL FU) 

STEPHEN T. WALL 

Defendants, 

DJD LAND PARTNERS, LLC 

LDG001, LLC 

Relief Defendants. 

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No. 3:22-CV-2118-X 

Jury Trial Demanded 

 

 

DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A 

REPLY ON MOTION FOR STAY PENDING APPEAL [ECF NO. 71], AND RESPONSE 

TO RECEIVER’S MOTION FOR APPOINTMENT OF APPRAISERS, APPROVAL OF 

APPRAISALS OF ROCK CREEK PROPERTY, AND SETTING HEARING 

REGARDING APPROVAL OF SALE OF ROCK CREEK PROPERTY [ECF NO. 76] 

Defendant Timothy Lynch Barton respectfully seeks a one-day extension of time to file a 

reply on his Motion for Stay Pending Appeal [ECF No. 71], and a response to the Receiver’s 

Motion for Appointment of Appraisers, etc. [ECF No. 76]. The Defendant seeks the extension 

because lead counsel for Defendant—Mr. Edney—became ill with the flu yesterday and remains 

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DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME PAGE 2

ill. He believes that, with a one-day extension, he will be able to substantively review and finalize 

the briefs due today by tomorrow. 

Defendant Barton’s current filing deadlines for both the Reply and the Response are 

December 12, 2022. The extension sought by Mr. Barton would extend those deadlines by one day 

to December 13, 2022. No prejudice to any party will result from this minor extension. 

In accordance with Local Rule 7.1, the undersigned counsel consulted with Plaintiff’s 

counsel and Receiver’s counsel, who both consented to the requested extension. Based on the 

foregoing, Defendant Barton respectfully requests that his unopposed motion for extension of time 

be granted. 

Dated: December 12, 2022 Respectfully submitted,

By: /s/ Ted A. Huffman 

Michael J. Edney 

Virginia Bar No. 48253 

DC Bar No. 492024 (admitted to N.D. Tex.) 

medney@hunton.com

Michael Dingman 

Virginia Bar No. 95762 

DC Bar No. 90001474 (admitted pro hac vice) 

mdingman@hunton.com 

HUNTON ANDREWS KURTH LLP 

2200 Pennsylvania Avenue NW

Washington, DC 20037

Phone: (202) 955-1500

Facsimile: (202) 778-2201 

Ted A. Huffman 

State Bar No. 24089015 

thuffman@hunton.com

HUNTON ANDREWS KURTH LLP

1445 Ross Avenue, Suite 3700 

Dallas, Texas 75202 

Phone: (214) 979-3000 

Facsimile: (214) 740-7110 

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DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME PAGE 3

Richard Roper 

State Bar No. 17233700 

richard.roper@hklaw.com

HOLLAND & KNIGHT LLP 

1722 Routh Street, Suite 1500 

Dallas, Texas 75201 

Phone: (214) 969-1345 

Facsimile: (214) 999-9252 

COUNSEL FOR TIMOTHY LYNCH BARTON

CERTIFICATE OF CONFERENCE 

I hereby certify that on December 12, 2022, the undersigned counsel consulted with 

Plaintiff’s counsel, Keefe Bernstein, who represented that Plaintiff consents to the relief sought 

herein. The undersigned also consulted with Receiver’s counsel, Charlene Koonce, who likewise 

represented that she consents to the relief sought herein.

/s/ Ted A. Huffman 

Ted A. Huffman 

CERTIFICATE OF SERVICE 

On December 12, 2022 I filed the foregoing document with the clerk of court for the U.S. 

District Court, Northern District of Texas. I hereby certify that I have served the document on all 

counsel and/or pro se parties of record by a manner authorized by Federal Rules of Civil Procedure 

5(b)(2).

/s/ Ted A. Huffman 

Ted A. Huffman 

 

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