UNITED STATES DISTRICT COURT 

DISTRICT OF NEW HAMPSHIRE 

UNITED STATES SECURITIES AND 

EXCHANGE COMMISSION, 

Plaintiff, 

v. 

PIYUSH G. PATEL, DAVID J. KIRKPATRICK, 

ERIC JAEGER, BRUCE D. KAY, ROBERT J. 

GAGALIS, ROBERT G. BARBER, JR., 

LAWRENCE COLLINS, MICHAEL A. 

SKUBISZ, JERRY A. SHANAHAN, 

HOR CHONG (DAVID) BOEY, 

Defendants. 

No. 01:07-00039-SM 

DEFENDANT ERIC JAEGER’S SUPPLEMENT TO PRETRIAL STATEMENT 

Jonathan A. Shapiro 

Elizabeth Skey (admitted pro hac vice) 

WILMER CUTLER PICKERING HALE 

AND DORR LLP 

950 Page Mill Road 

Palo Alto, California 94304 

(650) 858-6000 

Jeffrey B. Rudman (admitted pro hac vice) 

James Prendergast (admitted pro hac vice) 

Peter A. Spaeth (admitted pro hac vice) 

James T. Lux (admitted pro hac vice) 

WILMER CUTLER PICKERING HALE 

AND DORR LLP 

60 State Street 

Boston, Massachusetts 02109 

(617) 526-6000 

October 19, 2012 

Case 1:07-cv-00039-SM Document 335 Filed 10/19/12 Page 1 of 4
NOW COMES Defendant Eric Jaeger, by and through his attorneys, and, pursuant to 

Local Rule 16.2(a)(8), hereby supplements and amends Section X of his October 12, 2012 

Pretrial Statement (Dkt. No. 319) to read in full as follows: 

I. DEMAND AND OFFER; ALTERNATIVE DISPUTE RESOLUTION 

Last week, Mr. Jaeger proposed to trial counsel for the SEC (associated with the SEC's 

Denver Regional Office) a settlement of this matter that, if consummated, would result in (i) the 

SEC’s voluntary dismissal of Count III (aiding and abetting a scheme), and (ii) entry of judgment 

on a no admit, no deny basis on Count IV (books and records) whereby Mr. Jaeger would agree 

to an injunction against a future books and records violation, without any cash payment or other 

penalty or sanction. The SEC’s trial counsel has advised Mr. Jaeger’s counsel that she has since 

recommended the proposed settlement for approval by the senior staff of the SEC in 

Washington, D.C. The SEC’s trial counsel has advised, however, that the staff in Washington, 

D.C. is unlikely to act on the recommendation before the October 30, 2012 pretrial conference 

and that, thereafter, the settlement must be placed on the calendar of the full Commission for 

final approval. 

Respectfully submitted, 

ERIC JAEGER, 

By his attorneys, 

/s/ Jonathan A. Shapiro 

Jonathan A. Shapiro 

Elizabeth Skey (admitted pro hac vice) 

WILMER CUTLER PICKERING HALE 

AND DORR LLP 

950 Page Mill Road 

Palo Alto, California 94304 

(650) 858-6000 

Jeffrey B. Rudman (admitted pro hac vice) 

James W. Prendergast (admitted pro hac vice) 

Case 1:07-cv-00039-SM Document 335 Filed 10/19/12 Page 2 of 4
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Peter A. Spaeth (admitted pro hac vice) 

James T. Lux (admitted pro hac vice) 

WILMER CUTLER PICKERING HALE 

AND DORR LLP 

60 State Street 

Boston, Massachusetts 02109 

(617) 526-6000 

Case 1:07-cv-00039-SM Document 335 Filed 10/19/12 Page 3 of 4
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 CERTIFICATE OF SERVICE 

I, Elizabeth H. Skey, hereby certify that Defendant Eric Jaeger’s Supplement to Pretrial 

Statement, filed through the ECF system will be sent electronically to the registered participants 

as identified on the Notice of Electronic Filing and paper copies will be sent to those indicated as 

non-registered participants on October 19, 2012. 

/s/ Elizabeth H. Skey 

Elizabeth H. Skey 

Dated: October 19, 2012 

Case 1:07-cv-00039-SM Document 335 Filed 10/19/12 Page 4 of 4