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UNITED STATES DISTRICT COURT 

DISTRICT OF NEW HAMPSHIRE 

UNITED STATES SECURITIES AND 

EXCHANGE COMMISSION, 

Plaintiff, 

 v. 

ERIC JAEGER and 

JERRY A. SHANAHAN, 

Defendants. 

No. 01:07-00039-SM 

JOINT SUBMISSION RE: PRE-TRIAL AND TRIAL SCHEDULE 

 Further to the Court’s February 10, 2012 notice that trial of this action will not proceed on the 

previously scheduled March 20, 2012 trial date, Plaintiff Securities and Exchange Commission 

(“SEC”) and Defendants Jaeger and Shanahan have conferred and propose a revised pre-trial 

schedule as follows: 

Pre-Trial Submissions

1. March 2, 2012: The parties shall exchange objections to their respective proposed 

trial exhibits. 

2. March 12, 2012: The parties shall exchange responses to objections made to 

proposed trial exhibits.

3. March 23, 2012: Pursuant Fed. R. Civ. P. 26(a)(3) and D.N.H. L. R. 16.2, the parties 

shall file their respective Pretrial Statements, Proposed Jury Instructions, Motions In 

Limine, Voir Dire Requests, and proposed Verdict Forms.

Case 1:07-cv-00039-SM Document 298 Filed 02/15/12 Page 1 of 4
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4. April 13, 2012: The parties shall file responses and objections to Proposed Jury 

Instructions, Motions In Limine, Voir Dire Requests, and proposed Verdict Forms.

Schedule for Final Pre-Trial Conference and Trial

 The parties further propose that, following the Court’s decision on pending motions for 

summary judgment submitted respectively by the SEC and Defendant Shanahan, the Court schedule a 

status conference for the purpose of setting a date for the Final Pretrial Conference and for Trial. Due 

to the schedules of counsel and the parties with respect to a series of other successive, previouslyscheduled trials and business obligations, the parties further propose that the date to be set for trial be 

no earlier than (i) sixty (60) days after the Court’s decision on the pending summary judgment 

motions, or (ii) October 1, 2012, whichever is later. 

 WHEREFORE, the parties respectfully request that the Court enter the foregoing schedule. 

Should the Court have questions about, or wish to discuss, the foregoing proposed schedule, counsel 

are prepared to appear before the Court at its convenience.1

 

 

1

 In the event the Court wishes to convene such a conference, counsel, all of whom are out-of-state, respectfully 

request that they be permitted to participate telephonically. 

Case 1:07-cv-00039-SM Document 298 Filed 02/15/12 Page 2 of 4
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Respectfully submitted, 

ERIC JAEGER, 

By his attorneys, 

/s/ Jonathan A. Shapiro 

Jonathan A. Shapiro 

Elizabeth H. Skey (admitted pro hac vice) 

Wilmer Cutler Pickering Hale and Dorr LLP 

950 Page Mill Road 

Palo Alto, CA 94304 

(650) 858-6000 

Jeffrey B. Rudman (admitted pro hac vice) 

James W. 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 

JERRY A. SHANAHAN 

By his attorneys, 

/s/ Andrew Good 

Andrew Good 

Philip G. Cormier 

Good & Cormier 

83 Atlantic Avenue 

Boston, MA 02110 

agood@goodcormier.com 

pcormier@goodcormier.com 

U.S. SECURITIES AND EXCHANGE 

COMMISSION 

/s/ Nancy J. Gegenheimer 

Nancy J. Gegenheimer 

U.S. Securities and Exchange Commission 

1801 California Street, Suite 1500 

Denver, CO 80202 

(303) 844-1000 

gegenheimern@sec.gov 

February 15, 2012 

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CERTIFICATE OF SERVICE 

I, Elizabeth H. Skey, hereby certify that the foregoing Joint Submission Re: Pre-Trial 

and Trial Schedule, 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 February 15, 2012. 

/s/ Elizabeth H. Skey

Elizabeth H. Skey 

Dated: February 15, 2012 

Case 1:07-cv-00039-SM Document 298 Filed 02/15/12 Page 4 of 4