DEFENDANTS COMPREHENSIVE CARE OF OAKLAND, LP’S AND COMPREHENSIVE CARE OF CALIFORNIA, LLC’S 

ADMINISTRATIVE MOTION FOR LEAVE TO FILE SUPPLEMENTAL DECLARATION IN SUPPORT OF THE OPPOSITION TO 

PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION AND FOR APPOINTMENT OF RECEIVER 

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Yosef Peretz (SBN 209288) 

yperetz@peretzlaw.com 

Sumy Kim (SBN 290082) 

skim@peretzlaw.com 

PERETZ & ASSOCIATES 

22 Battery Street, Suite 200 

San Francisco, CA 94111 

Telephone: 415.732.3777 

Facsimile: 415.732.3791 

Attorneys for Defendants COMPREHENSIVE CARE OF OAKLAND, L.P. 

And COMPREHENSIVE CARE OF CALIFORNIA, LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

SECURITIES AND EXCHANGE 

COMMISSION, 

 Plaintiff, 

vs.

SAN FRANCISCO REGIONAL CENTER, 

LLC; THOMAS HENDERSON; 

CALIFORNIA GOLD MEDAL, L.P.; 

CALLSOCKET, L.P.; CALLSOCKET II, 

L.P.; CALLSOCKET III, L.P.; 

COMPREHENSIVE CARE OF 

OAKLAND, L.P.; NA3PL, L.P.; WEST 

OAKLAND PLAZA, L.P.; CALLSOCKET, 

LLC; CALLSOCKET II, LLC; 

CALLSOCKET III, LLC; 

COMPREHENSIVE CARE OF 

CALIFORNIA, LLC; IMMEDIA, LLC; and 

NORTH AMERICA 3PL, LLC.

 Defendants. 

CALLSOCKET HOLDING COMPANY, 

LLC; CALLSOCKET III HOLDING 

COMPANY, LLC; CENTRAL 

CALIFORNIA FARMS, LLC; BERKELEY 

HEALTH CARE DYNAMICS, LLC; and JL 

GATEWAY, LLC. 

Relief Defendants. 

Civil Case No. 3:17-cv-00223-RS 

DEFENDANTS COMPREHENSIVE 

CARE OF OAKLAND, LP’S AND 

COMPREHENSIVE CARE OF 

CALIFORNIA, LLC’S 

ADMINISTRATIVE MOTION FOR 

LEAVE TO FILE SUPPLEMENTAL 

DECLARATION IN SUPPORT OF 

THE OPPOSITION TO PLAINTIFF’S 

MOTION FOR PRELIMINARY 

INJUNCTION AND FOR 

APPOINTMENT OF RECEIVER

Date: March 2, 2017 

Time: 1:30 p.m. 

Courtroom.: 3 - 17th Floor 

ORDER

Case 3:17-cv-00223-RS Document 97 Filed 03/23/17 Page 1 of 9
DEFENDANTS COMPREHENSIVE CARE OF OAKLAND, LP’S AND COMPREHENSIVE CARE OF CALIFORNIA, LLC’S 

ADMINISTRATIVE MOTION FOR LEAVE TO FILE SUPPLEMENTAL DECLARATION IN SUPPORT OF THE OPPOSITION TO 

PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION AND FOR APPOINTMENT OF RECEIVER

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Pursuant to Local Civil Rule 7-3(d), Defendants COMPREHENSIVE CARE OF 

OAKLAND, LP (“CCOO”) and COMPREHENSIVE CARE OF CALIFORNIA, LLC 

(“CCOC”) (collectively, “Defendants”) hereby request that the Court to grant leave to file 

supplemental material in support of its Opposition to Motion for Appointment of a Receiver. 

Defendants instantly seek to file the declaration of Marvin L. Tate, Certified Public Accountant, 

so that the Court may be further apprised as to the current financial status of Defendants. 

Specifically, CCOO was provided its 2016 unaudited financial report by Mr. Tate in late 

evening on February 21, 2017. As such, Defendants respectfully seek leave to file a short 

declaration of Mr. Tate to this financial statement and the relevant information concerning this 

document. This information was not available to Defendants at the time of filing its Opposition. 

[A true and correct copy of the proposed declaration is attached hereto as Exhibit “”.]

Dated: February 23, 2017 PERETZ & ASSOCIATES

By: /s/Yosef Peretz 

Yosef Peretz

Attorneys for Defendants

COMPREHENSIVE CARE OF 

OAKLAND, L.P. and COMPREHENSIVE 

CARE OF CALIFORNIA, LLC

[PROPOSED] ORDER

Having read and considered Defendants’ Motion for Leave to File Supplemental 

Declaration and finding good cause therefore,

IT IS HEREBY ORDERED that Defendants may file the attached supplemental material 

entitled Declaration of Marvin Tate in Support of Defendants’ Opposition.

Dated: _______________________

_____________________________

Hon. Richard Seeborg

United States District Court Judge 

3/23/17

Case 3:17-cv-00223-RS Document 97 Filed 03/23/17 Page 2 of 9
EXHIBIT 1

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EXHIBIT A 

Case 3:17-cv-00223-RS Document 97 Filed 03/23/17 Page 6 of 9
CONFIDENTIAL - ATTORNEYS' EYES ONLY

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CONFIDENTIAL - ATTORNEYS' EYES ONLY

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CONFIDENTIAL - ATTORNEYS' EYES ONLY

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