DELOITTE & TOUCHE LLP’S RESPONSE TO 

PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER

Robert C. Weaver, Jr., OSB #801350 

E-Mail: rweaver@gsblaw.com 

Paul H. Trinchero, OSB #014397 

E-Mail: ptrinchero@gsblaw.com 

Eryn Karpinski Hoerster, OSB #106126 

E-Mail: ehoerster@gsblaw.com 

Daniel L. Keppler, OSB #923537 

E-Mail: dkeppler@gsblaw.com 

Garvey Schubert Barer, P.C. 

121 SW Morrison Street, Eleventh Floor 

Portland, Oregon 97204-3141 

Telephone: (503) 228-3939 

Peter A. Wald (admitted pro hac vice) 

E-Mail: peter.wald@lw.com

Gavin M. Masuda (admitted pro hac vice) 

E-Mail: gavin.masuda@lw.com 

Latham & Watkins LLP 

505 Montgomery Street, Suite 2000 

San Francisco, California 94111 

Telephone: (415) 391-0600 

Attorneys for Defendant Deloitte & Touche LLP 

(Additional Counsel Listed on Signature Page) 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

LAWRENCE P. CIUFFITELLI, for himself 

and as Trustee of CIUFFITELLI 

REVOCABLE TRUST, et al., 

 Plaintiffs, 

 v. 

DELOITTE & TOUCHE LLP; 

EISNERAMPER LLP; SIDLEY AUSTIN 

LLP; TONKON TORP LLP; TD 

AMERITRADE, INC.; INTEGRITY BANK 

& TRUST; and DUFF & PHELPS, LLC 

Defendants.

Case No. 3:16-cv-00580-AC 

DEFENDANT DELOITTE & 

TOUCHE LLP’S RESPONSE TO 

PLAINTIFFS’ MOTION FOR 

PROTECTIVE ORDER 

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PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER

I. INTRODUCTION 

Plaintiffs, none of whom were clients of CliftonLarsonAllen Wealth Advisors, LLC 

(“CLAWA”), seek to interject themselves into a dispute between Deloitte and CLAWA to 

obstruct this third-party discovery on grounds that it is irrelevant and unduly burdensome. But 

Plaintiffs lack standing to quash the subpoena because they cannot claim any right of privacy or 

privilege in the information sought. Even if Plaintiffs had standing, none of their relevance or 

burden objections have merit. The motion should be denied. 

II. BACKGROUND 

Plaintiffs seek to represent a putative class of investors who purchased hundreds of 

millions of dollars in securities from Aequitas Commercial Finance and seven other Aequitas 

entities. CLAWA is a prominent national registered investment adviser (“RIA”) firm, which 

recommended to no fewer than 33 of its clients—all members of the putative class—that they 

purchase over $16 million in various Aequitas securities. Deloitte’s subpoena to CLAWA seeks 

production of documents that are essential to understanding CLAWA’s role in selling Aequitas 

securities.1

 

There can be no doubt that CLAWA played a critical role in the sales of those securities 

to its clients because, as a fiduciary, CLAWA was obligated to (i) perform adequate due 

diligence on the Aequitas entities; (ii) understand its clients’ financial situation, investment 

 

1

 Plaintiffs also moved to quash Request Nos. 2 and 4 in Deloitte’s subpoenas to third-party 

investment advisers Aaron D. Maurer and Antonio Ramirez. See Plaintiffs’ Motion for 

Protective Order (“Mot.”), Dkt. 545, at 7-9. Maurer and Ramirez have responded to Deloitte 

stating that they possess no responsive documents. As a result, Plaintiffs’ Motion for Protective 

Order as to these Requests is moot. Deloitte, however, reserves the right to take the depositions 

of Maurer and Ramirez and subpoena them for trial. Plaintiffs acknowledge that the instant 

Motion does not address Deloitte’s deposition subpoenas to Maurer and Ramirez, as “Plaintiffs 

intend to file a separate motion for protective order to limit or preclude those depositions.” Mot. 

at 2 n.1. 

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objectives, and risk tolerances; and (iii) make investment recommendations that were suitable in 

light of its clients’ financial situation, investment objectives, and risk tolerances. Indeed, 

testimony from this action and related actions uniformly confirms that RIAs like CLAWA—

because of their unique roles as fiduciaries and the trust their clients placed in them—were the 

most important factor in their clients’ decisions to purchase Aequitas securities. 

Deloitte’s subpoena therefore seeks CLAWA policies and procedures that will show what 

CLAWA believed its fiduciary duties required, vis-à-vis CLAWA’s clients (Request No. 11). 

The subpoena seeks evidence of the diligence CLAWA performed because that diligence (if any) 

informed CLAWA’s investment recommendations to its clients (Request No. 12). Finally, the 

subpoena seeks evidence regarding what CLAWA knew about its clients, because that 

understanding determines whether CLAWA’s recommendations were suitable to its clients’ 

investment needs and objectives (Request Nos. 6, 10, 13). These documents are critical to 

Deloitte’s defense that it was CLAWA’s close relationships with its clients and the related advice 

it gave—not any conduct by Deloitte—that caused dozens of its clients to invest in Aequitas 

securities, despite the clear cautions in Deloitte’s reports and the financial statements it audited. 

CLAWA has asserted certain objections to the subpoena and Deloitte’s motion to compel 

CLAWA to produce these documents is pending. See Dkt. 506, 520. 

II. ARGUMENT 

A. Plaintiffs Lack Standing To Quash Deloitte’s Subpoena To CLAWA 

A party generally lacks standing to quash or modify a subpoena served upon a non-party, 

“except as to claims of privilege relating to the documents being sought.” See MD Helicopters, 

Inc. v. Aerometals, Inc., 2019 WL 1227919, at *5 (E.D. Cal. Mar. 15, 2019). Under this rule, 

parties “lack[] standing to object to the subpoena on the grounds of relevance or undue burden. 

A party cannot seek to quash a Rule 45 subpoena except to the extent that it has ‘a personal right 

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or privilege in the information sought to be disclosed.’” Id. (citing Cal. Sportfishing Prot. All. v. 

Chico Scrap Metal, Inc., 299 F.R.D. 638, 643 (E.D. Cal. 2014)); accord In re REMEC, Inc. Sec. 

Litig., 2008 WL 2282647, at *1 (S.D. Cal. May 30, 2008). 

Plaintiffs cannot claim a personal right of privacy or privilege in the documents Deloitte 

seeks for one simple reason: Plaintiffs were not CLAWA clients and therefore did not provide 

CLAWA with any personal information or have any privilege with CLAWA. See Mot. at 7-10 

(failing to identify any right to privacy or privilege in documents in CLAWA’s possession). The 

Motion should be denied on this basis alone. See MD Helicopters, Inc., 2019 WL 1227919, at *5 

(finding that “plaintiff lacks standing to object to the [Rule 45] subpoena on grounds of 

relevance or undue burden”). 

Because Plaintiffs cannot identify any right to privacy or privilege in CLAWA’s 

documents, they claim the subpoena causes them “undue burden and expense”—and that such 

showing is sufficient to confer standing to object. Plaintiffs are wrong as a matter of law and 

fact. On the law, Plaintiffs omit the holding of In re REMEC, where the court observed that 

“[a]s a general proposition, a party lacks standing under [Rule 45] to challenge a subpoena issued 

to a non-party unless the party claims a personal right or privilege with respect to the documents 

requested in the subpoena.” In re REMEC, Inc. Sec. Litig., 2008 WL 2282647, at *1 (denying 

motion to quash third-party subpoena for lack of standing as to all asserted grounds, except as to 

work product); see also MD Helicopters, Inc., 2019 WL 1227919, at *5. 

But even assuming Plaintiffs could establish standing based on “undue burden or 

expense,” Plaintiffs admit they must show how their “own interests are jeopardized by discovery 

sought from a third party.” See Mot. at 4 (citing In re REMEC); see also Local Rule 26-4 

(requiring party moving for protective order to demonstrate that “specific prejudice or harm will 

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result if no order is granted”). Plaintiffs cannot make this factual showing because, while the 

subpoena asks CLAWA to incur moderate expense associated with producing the requested 

documents, it imposes no burden on Plaintiffs. Indeed, Plaintiffs’ principal objections to the 

subpoena sound in relevance—i.e., Plaintiffs’ (mistaken) belief that the requested documents are 

unrelated to the claims or defenses at issue in this action. See Mot. at 2 (arguing that Deloitte’s 

requests “seek a kitchen pantry of irrelevant material”). But “relevance” does not confer upon 

Plaintiffs the standing necessary to object. See MD Helicopters, Inc., 2019 WL 1227919, at *5. 

B. The Requested Documents Are Relevant To Plaintiffs’ Claims And Deloitte’s 

Defenses 

Deloitte’s subpoena seeks documents that are essential to understanding the role that 

CLAWA played in the sales of more than $16 million worth of Aequitas securities to putative 

class members. Although CLAWA has stonewalled Deloitte’s efforts to obtain these documents, 

other discovery in this action reveals just how important RIAs like CLAWA were to their 

clients’ purchase decisions. Among many other examples, Plaintiff Greg Warrick testified to a 

longstanding relationship with his RIA (Concert Wealth Management), which recommended that 

he purchase Aequitas securities. See Declaration of Gavin M. Masuda in Support of Response 

(“Masuda Decl.”) Ex. 1 (Warrick Tr.) at 26:10-20. Mr. Warrick further testified that he learned 

of Aequitas through his RIA, received all of his information about Aequitas through in-person 

meetings with his RIA, understood that his RIA performed diligence on Aequitas before 

recommending that he purchase Aequitas securities, and relied on his RIA’s recommendation 

when deciding to purchase. Id. at 44:17-46:17, 63:19-64:9. There can be no dispute that Mr. 

Warrick’s RIA was the most important factor in his decision to purchase Aequitas securities. 

The role played by the RIAs in the securities sales at issue is relevant to the claims and/or 

defenses in this action for numerous reasons. First, Plaintiffs claim that Aequitas sold securities 

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“by means of” materially false or misleading statements, in violation of ORS 59.115(1)(b). 

Plaintiffs claim these statements were contained in Aequitas’s various private placement 

memoranda (“PPMs”)—and that the misleading statements were materially similar over time. 

See Dkt. 522 (Pls.’ Mot. for Class Cert.) at 27-28. But as discovery has revealed, Aequitas’s 

PPMs had very little to do with its securities sales. Instead, the Aequitas securities were sold “by 

means of” a wide-ranging mix of marketing materials (ranging from one-page sheets containing 

no financial information, to one-page “tear sheets” showing unaudited financial information, to 

PowerPoint presentations touting Aequitas’s supposed history of repaying its investors). See, 

e.g., Masuda Decl. Ex. 2 (Taylan Tr.) at 83:1-84:25 (testifying to materials that Aequitas 

provided for marketing securities to investors). They also were sold “by means of” the oral 

representations that RIAs made to their clients—including representations that the securities 

were “safe” and “secure,” in direct contravention of PPM disclosures describing the Aequitas 

securities as involving a “HIGH DEGREE OF RISK.” See Masuda Decl. Ex. 3 at 3. All this 

information—written and orally conveyed by the RIAs—must be considered in determining 

whether Aequitas’s statements to investors were materially false or misleading. See ORS 

59.115(1)(b) (providing that only persons not knowing of the untruth or omission may recover 

damages). 

Second, Plaintiffs claim that Deloitte “materially aided in” the sales at issue because it 

“lent clout” to the Aequitas entities and the securities they sold. See Dkt. 257 (2d Am. Compl.) 

¶ 16. But discovery has disproven this aspect of Plaintiffs’ claim because it has revealed instead 

that Aequitas actively concealed Deloitte’s audit opinions and audited financial statements from 

investors—precisely because Deloitte’s audit opinions and the audited financial statements 

emphasized and revealed Aequitas’s precarious financial condition. See Masuda Decl. Ex. 2 

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(Taylan Tr.) 74:2-75:14. Instead, Aequitas provided RIAs with a litany of other marketing 

materials and excerpted financial statements (excluding Deloitte’s audit opinion and the notes to 

the financial statements), which the RIAs in turn conveyed to their clients. See, e.g., Masuda 

Decl. Ex. 4. Meanwhile, Aequitas misleadingly “touted” Deloitte to the RIAs and investors by 

falsely characterizing the status of Deloitte’s audits and the content of its opinions—

characterizations that RIAs then conveyed to their clients. See Masuda Decl. Ex. 2 (Taylan Tr.) 

153:23-155:25. Discovery regarding the role played by the RIAs—including CLAWA—in the 

securities sales at issue here is critical to determining whether Deloitte “materially aided” in the 

challenged sales. See Prince v. Brydon, 307 Or. 146, 149 (1989) (finding that “it is a drafter’s 

knowledge, judgment, and assertions reflected in the contents of the documents that are 

‘material’ to the sale”). The information Deloitte seeks to obtain from CLAWA may reveal what 

CLAWA knew about the Aequitas securities, what it knew about Deloitte’s work in auditing 

Aequitas’s financial statements, what it knew about Deloitte’s audit opinions—and what 

information CLAWA chose to share with its clients about the Aequitas securities and about 

Deloitte. 

Notably, Plaintiffs do not object to the majority of Deloitte’s requests to CLAWA. Their 

objections are only as to three categories, which seek (i) policies and procedures that CLAWA 

created in order to comply with the Investment Advisers Act of 1940 (“Advisers Act”) (Request 

No. 11); (ii) documents regarding the due diligence CLAWA was required to conduct on its 

clients’ Aequitas investments (Request No. 12); and (iii) documents related to the suitability 

analyses and other services that CLAWA performed in connection with its Aequitas 

recommendations to clients (Request Nos. 6 (“suitability analysis” documents), 10 (client 

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disclosures, waivers, and acknowledgements), and 13 (client investment files)). None of these 

objections have merit. 

First, regarding CLAWA’s Advisers Act policies,2 Plaintiffs’ only objection is that these 

policies “have nothing whatsoever to do with Plaintiffs’ claims or Deloitte’s defenses.” Mot. at 

10. Not so. These policies are critical to understanding how CLAWA interpreted its obligations 

under the Advisers Act—which, in turn, informed everything that CLAWA did (or did not do) 

with respect to its clients and their Aequitas investments. For example, Deloitte expects that 

CLAWA’s policies dictated the extent to which CLAWA was required to perform due diligence 

on Aequitas investments before recommending them to their clients—including whether 

CLAWA was required to obtain and review Aequitas’s audited financial statements—as well as 

what information CLAWA was required to provide to its clients. These documents are relevant 

and must be produced. 

Second, regarding CLAWA’s due diligence documents, CLAWA was duty-bound to 

perform due diligence sufficient to inform CLAWA’s client recommendations regarding 

Aequitas. Supra, pp. 1-2 (discussing role of RIA due diligence). Plaintiffs argue CLAWA’s due 

diligence is irrelevant because this Court has ruled that Plaintiffs had no duty of inquiry. See 

Mot. at 9. But Deloitte’s subpoena is not addressed to the Plaintiffs or the diligence they 

performed; it is addressed to CLAWA, and seeks evidence regarding what CLAWA knew, and 

 

2

 The Advisers Act sets forth, in very broad terms, an RIA’s fiduciary obligations to its clients. 

See SEC v. Capital Gains Research Bureau, 375 U.S. 180, 191-92 (1963). It does not, however, 

specify the means by which an RIA is to comply with these broad obligations—leaving RIAs to 

implement specific policies and procedures within the broad mandates the Advisers Act 

provides. See id. Such policies and procedures might include, among other things, policies 

governing the extent of due diligence that the RIA must perform, its full and fair disclosure of all 

facts material to the client’s engagement, and its provision of suitable investment advice in light 

of the client’s financial situation and investment objectives. 

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what it conveyed (or failed to convey) to its clients. The information CLAWA conveyed to its 

clients is relevant to the question of whether the securities at issue were sold “by means of” 

materially false or misleading statements (as Plaintiffs allege), and whether Plaintiffs knew the 

“truth” regarding the allegedly false and misleading statements on which they rely for their 

claims. See supra, pp. 4-5 (describing Plaintiffs’ primary liability claims). And the information 

CLAWA did not convey—such as Deloitte’s actual audit opinion and Aequitas’s audited 

financial statements, supra, pp. 5-6—is relevant to whether Deloitte’s audit opinion and the 

audited financial statements “materially aided” the securities sales to CLAWA’s clients. If, for 

example, CLAWA misrepresented or concealed the content of the audit opinions or the audited 

financial statements, the jury could reasonably infer that neither Aequitas nor CLAWA believed 

that those documents aided sales. CLAWA’s diligence documents also must be produced. 

Finally, regarding CLAWA’s suitability analysis and related documents,3

 CLAWA was 

duty-bound to understand its clients’ financial condition and risk tolerances, and to recommend 

securities that were “suitable” in light of this information. Supra, pp. 1-2. In order to obtain this 

understanding, RIAs typically will conduct interviews of their clients and request limited 

financial documentation in order to obtain a general understanding of their clients’ financial 

condition and ability to bear risk. See Masuda Decl. Ex. 2 (Taylan Tr.) 26:24-27:4 (requiring 

clients to complete financial questionnaires). RIAs then use that understanding to match their 

clients’ profiles and objectives to “suitable” investments. Id. The suitability analyses CLAWA 

performed, if any, go to the heart of CLAWA’s recommendations to its clients—who claim 

 

3

 Deloitte is willing to limit Request Nos. 6 and 13 to documents related to the Aequitas 

transactions by CLAWA’s clients, as it did in conferring with Plaintiffs over Deloitte’s subpoena 

to Messrs. Maurer and Ramirez. Mot. at 8. Regardless, CLAWA has objected to producing 

documents responsive to Request Nos. 6 and 13, even if limited to Aequitas transactions. See 

Dkt. 520-1, at 43-54. 

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(through the putative class) they were misled into believing that Aequitas securities were “safe” 

and “secure.” Dkt. 257 ¶¶ 2. These claims simply cannot be squared with Aequitas’s PPMs, all 

of which described the subject securities as “INVOLV[ING] A HIGH DEGREE OF RISK” and 

intended only for investors who could afford to lose their entire investment. See Masuda Decl. 

Ex. 3, at 3. 

Against this, Plaintiffs misleadingly argue that the Court’s order denying Deloitte 

discovery of documents (“Order”), Dkt. 421, related to Plaintiffs’ financial condition (“financial 

condition documents”)—defined to include documents like tax returns and brokerage 

statements—precludes discovery of CLAWA’s suitability analyses. See Mot. at 7.4

 Plaintiffs’ 

argument is misplaced, because the purpose of Deloitte’s request to CLAWA is different from 

the purpose of its financial condition documents request—which was to discover whether 

Plaintiffs qualified as “accredited investors” under applicable federal law. 

Here, as discussed above, these documents are relevant to CLAWA’s understanding of its 

clients and the appropriateness of its investment recommendations—which are simply different 

issues. Supra, pp. 1-2. Moreover, the documents Deloitte seeks from CLAWA are different in 

nature from the financial condition documents that Deloitte sought from Plaintiffs. As noted 

above, suitability analyses do not typically involve a full review of an investor’s financial 

condition or its federal tax returns; instead, an RIA typically will ask questions to understand 

their clients’ risk tolerance and financial objectives. These documents could contain information 

about investors’ net worth. But if they did include such information, such inclusion would only 

 

4

 Plaintiffs say that they intend to seek judgment on the pleadings and/or partial summary 

judgment as to certain of Deloitte’s “comparative-fault like” defenses and equitable defenses. 

Mot. at 6. This is a red herring. Deloitte does not argue that the requested documents are 

relevant to these affirmative defenses; rather Request Nos. 6, 10, and 13 are relevant to 

Plaintiffs’ secondary-liability claims and Deloitte’s ability to rebut those claims. 

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confirm the information’s relevance to CLAWA’s investment recommendation. Deloitte expects 

that such analyses would be documented in CLAWA forms or files that would not be 

burdensome to produce. These requests are not, as Plaintiffs suggest, a backdoor attempt to 

obtain documents related to Plaintiffs’ status as accredited investors.5

III. CONCLUSION 

For the foregoing reasons, Deloitte respectfully requests that the Court deny Plaintiffs’ 

Motion for Protective Order. 

 

5

 Even if the Court’s Order precluded documents related to the financial condition and 

investment experience of CLAWA’s clients, this would not warrant quashing the entirety of 

Request Nos. 6, 10 or 13. Request No. 10 does not seek any information that would reveal a 

client’s “financial condition,” and Plaintiffs fail to explain how this Court’s Order precludes the 

discovery sought by Request No. 10. In addition, Plaintiffs ignore that Request Nos. 6 and 13 

seek other relevant information that does not implicate “financial condition” issues -- such as 

CLAWA’s investment strategy and client investment restrictions. Because Plaintiffs’ Motion 

cannot assert that these documents are precluded by the Court’s Order, the Court must—at 

minimum—allow Request Nos. 6, 10, and 13 to the extent that they do not concern a CLAWA 

client’s financial condition. 

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PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER 

Dated: May 22, 2019 Respectfully submitted, 

LATHAM & WATKINS LLP 

By: /s/ Peter A. Wald 

Peter A. Wald (admitted pro hac vice)

Gavin M. Masuda (admitted pro hac vice)

Nicole C. Valco (admitted pro hac vice)

Marcy C. Priedeman (admitted pro hac vice) 

505 Montgomery Street, Suite 2000 

San Francisco, CA 94111-6538 

Telephone: (415) 391-0600 

Email: peter.wald@lw.com 

gavin.masuda@lw.com 

nicole.valco@lw.com 

marcy.priedeman@lw.com 

And– 

Nicholas J. Siciliano (admitted pro hac vice) 

LATHAM & WATKINS LLP 

330 North Wabash Avenue, Suite 2800 

Chicago, IL 60611 

Telephone: (312) 876-7700 

Email: nicholas.siciliano@lw.com 

-AndRobert C. Weaver, Jr., OSB No. 801350 

Gary I. Grenley, OSB No. 751380 

Paul H. Trinchero, OSB No. 014397 

Eryn Karpinski Hoerster, OSB No. 106126 

Daniel L. Keppler, OSB No. 923537 

GARVEY SCHUBERT BARER, P.C. 

121 SW Morrison Street, 11th Floor 

Portland, OR 97204 

Telephone: (503) 228-3939 

Email: rweaver@gsblaw.com 

ggrenley@gsblaw.com 

ptrinchero@gsblaw.com 

ehoerster@gsblaw.com 

dkeppler@gsblaw.com 

Attorneys for Defendant Deloitte & Touche 

LLP 

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