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

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

Wynn, Paris
From: Wynn, Paris
Sent: Monday, January 03,2011 5:02 PM
To: RHBretzPC(§aol.com
Subject: Discovery Motion

Bob: .

Today I plan to file an emergency motion to compel, which seeks to compel your clients to attend their depositions and
produce relevant documents.

I'm aware of your representation that your clients will appear in los Angeles on January 10, 2011, and I've made the
Court aware of that representation in our filing. If they show, the portion of the motion may be moot. However, in view
of the manner in which your clients have conducted themselves, I'm not comfortable relying upon their representations
alone, especially in view of the pending discovery cut-off.

As far as documents, the "production" you sent me was woefully inadequate. Through third party discovery, I am aware
that Glisson and/or Tungwongsathong executed hundreds ofCMKM sales in 2010. I am also aware that Glisson
regularly received emails (and money orders made out to Tungwongsathong) in connection with these sales. However,
not a single email or financial record concerning such documents have been produced, even though plainly requested.

Paris A. Wynn
Enforcement Attorney
U.S. Securities and Exchange Commission
Los Angeles Regional Offce
5670 Wilshire Blvd., 10th Floor
Los Angeles, CA 90036-3648
Tel: (323) 965-4562
Fax: (323) 965-3908