Case 2:09-cv-00104-LDG-GWF Document 57-1 Filed 02/04/11 Page 1 of 6

1 MOLLY M. WHITE, Cal Bar No. 171448

E-mail: whitem@sec.gov
2 PARIS A. WYNN, Cal. Bar No. 224428
E-mail: wynnp@sec.gov
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Attorneys for Plaintiff
4 Securities and Exchange Commission
Rosalind R. Tyson, Regional Director
5 Michele Wein Layne, Associate Regional Director
John M. McCoy III, Associate Regional Director
6 5670 Wilshire Boulevard, 11th Floor
Los Angeles, California 90036
7 Telephone: (323) 965-3998
Facsimile: (323) 965-3908
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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SECURITIES AND EXCHANGE COMMISSION, Case No. 2:09-cv-00104-LDG-GWF
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Plaintiff,
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vs.
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MARCO GLISSON,
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Defendant.
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18 DECLARATION OF PARIS A. WYNN
19 SUPPORTING PLAINTIFF’S REPLY BRIEF IN SUPPORT OF MOTION TO EXTEND
20 OR CLARIFY DISCOVERY SCHEDULE
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1 Pursuant to 28 U.S.C. § 1746, I, Paris A. Wynn, declare as follows:

2 1. I am an attorney in good standing and admitted to practice law in the State of
3 California and before this Court. I am employed by the Securities and Exchange Commission
4 (“Commission”) as an attorney in the Enforcement Division in the Los Angeles Regional Office.
5 I make this Declaration in Support of the Commission’s Reply Brief In Support of its Emergency
6 Motion to Extend or Clarify The Discovery Cut-Off. I have personal knowledge of the facts
7 herein, except as otherwise noted.
8 2. On January 3, 2011, I sent Glisson’s counsel, Robert Bretz, an email that
9 explicitly complained that no “financial records” had been produced in response to the
10 Commission’s document requests, although plainly called for in the pertinent requests. A true
11 and correct copy of my January 3, 2011 email is attached hereto as Ex. 1.
12 3. On January 24, 2011, I sent Robert Bretz (counsel to Glisson and
13 Tungwongsathong), an email informing him that, on January 24, 2011, the Commission would
14 be sending six subpoenas for bank records to three institutions where Glisson and
15 Tungwongsathong held accounts. A true and correct copy of my January 24, 2011 email to Mr.
16 Bretz is attached hereto as Ex. 2.
17 4. Subsequently, on January 24, 2011, I caused a total of six subpoenas to be sent to
18 the following three banks: (1) SunTrust; (2) BB&T; and (3) Suncoast Schools Federal Credit
19 Union. Each bank received two subpoenas—one for Glisson and one for non-party
20 Tungwongathong. All six of the subpoenas have return dates of February 14, 2011. True and
21 correct copies of each of the six subpoenas are attached hereto as Ex. 3-8.
22 5. In conversations between me and representatives from each of the banks that took
23 place during the week of January 14, 2011, each of the three banks agreed to accept service of
24 the pertinent subpoenas, thus obviating the need to effect personal service of the subpoenas on
25 the banks.
26 6. At approximately 5:52 p.m. on January 26, 2011, Mr. Bretz informed me via

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1 email that he did not receive notice of the three subpoenas that had been directed to Marco
2 Glisson’s bank accounts. Immediately thereafter, at approximately 6:00 p.m. on January 26,
3 2011, I emailed copies of the three subpoenas that had been sent to Glisson’s banks to Glisson’s
4 counsel, Mr. Bretz. A true and correct copy of my January 26, 2011 emails to Bretz (as well as
5 the email attachments to such emails) are attached hereto as Ex. 9.
6 7. The next day, on January 27, 2007, I made inquiries of pertinent Commission
7 staff members and determined that no formal notices had been sent to Glisson’s counsel
8 regarding the three subpoenas directed to Glisson’s banks on January 24, 2011, due to the fact
9 that the employee to whom that task had been assigned had fallen ill and did not report to work
10 on January 24, 2011 or January 25, 2011.
11 8. After determining that formal notices of the three Glisson bank subpoenas had not
12 been sent—and irrespective of the fact that the actual subpoenas had been forwarded by me to
13 Glisson’s counsel on January 26, 2011, on January 27, 2011, I took the additional step of sending
14 formal notices of the three Glisson bank subpoenas via electronic mail to Glisson’s counsel. A
15 true and correct copy of my January 27, 2011 email to Bretz (as well the attachments thereto) is
16 attached hereto as Ex. 10.
17 9. On January 24, 2011, I caused copies of each of the three Tungwongsathong
18 subpoenas — along with the detailed and comprehensive notice packages required by the RFPA
19 — to be sent to Glisson’s counsel. However, after the close of business, at approximately 5:52
20 p.m. on January 26, 2011, Glisson’s counsel informed me via email that he did not receive the
21 subpoena attachments associated with two of the subpoenas directed to Tungwongsathong’s
22 accounts. Immediately thereafter, I sent Glisson’s counsel the attachments that he indicated were
23 missing.
24 10. On February 3, 2011, I sent letters to each of the three banks instructing them not
25 to produce any records until the objections raised by Glisson herein had been resolved. On
26 February 3, 2011, I forwarded such letters via email, along with additional copies of all six

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1 subpoenas, to Robert Bretz, counsel for Glisson and Tungwongsathong. A true and correct copy
2 of of my February 3, 2011 email to Bretz (along with the attachments thereto) is attached hereto
3 as Ex 11 and 12.
4 I declare under penalty of perjury under the laws of the United States that the foregoing is
5 true and correct. Executed this 4th day of February 2011 in Los Angeles, California.
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/s/ Paris A. Wynn
7 Paris A. Wynn
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PROOF OF SERVICE
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I am over the age of 18 years and not a party to this action. My business address is:
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[X] U.S. SECURITIES AND EXCHANGE COMMISSION, 5670 Wilshire
3 Boulevard, 11th Floor, Los Angeles, California 90036-3648
4 Telephone No. (323) 965-3998; Facsimile No. (323) 965-3908.
5 On February 4, 2011, I caused to be served the document entitled DECLARATION
OF PARIS A. WYNN SUPPORTING REPLY BRIEF IN SUPPORT OF
6 EMERGENCY MOTION TO EXTEND OR CLARIFY THE DISCOVERY
CUT-OFF on all the parties to this action addressed as stated on the attached
7 service list:
8 [X] OFFICE MAIL: By placing in sealed envelope(s), which I placed for
collection and mailing today following ordinary business practices. I am
9 readily familiar with this agency’s practice for collection and processing of
correspondence for mailing; such correspondence would be deposited with
10 the U.S. Postal Service on the same day in the ordinary course of business.
11 [ ] PERSONAL DEPOSIT IN MAIL: By placing in sealed
envelope(s), which I personally deposited with the U.S. Postal Service.
12 Each such envelope was deposited with the U.S. Postal Service at Los
Angeles, California, with first class postage thereon fully prepaid.
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[ ] EXPRESS U.S. MAIL: Each such envelope was deposited in a
14 facility regularly maintained at the U.S. Postal Service for receipt of
Express Mail at Los Angeles, California, with Express Mail postage
15 paid.
16 [ ] UNITED PARCEL SERVICE: By placing in sealed envelope(s)
designated by United Parcel Service (“UPS”) with delivery fees paid or
17 provided for, which I deposited in a facility regularly maintained by UPS or
delivered to a UPS courier, at Los Angeles, California.
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[ ] ELECTRONIC MAIL: By transmitting the document by electronic mail
19 to the electronic mail address as stated on the attached service list.
20 [X] E-FILING: By causing the document to be electronically filed via the
Court’s CM/ECF system, which effects electronic service on counsel who
21 are registered with the CM/ECF system.
22 [ ] FAX: By transmitting the document by facsimile transmission. The
transmission was reported as complete and without error.
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I declare under penalty of perjury that the foregoing is true and correct.
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25 Date: February 4, 2011 /s/ Paris A. Wynn
Paris A. Wynn
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1 SEC v. MARCO GLISSON

United States District Court - District of Nevada
2 Case No. 2:09-cv-00104-LDG-GWF
(LA-3028)
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4 SERVICE LIST
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Robert H. Bretz, Esq.
6 578 Washington Boulevard, Suite 843
Marina del Rey, CA 90292
7 Email: Rhbretzpc@aol.com
Attorney for Marco Glisson
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