Case 1:22-cv-00349-SOM-KJM Document 60 Filed 10/26/22 Page 1 of 15 PageID.282
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`Oct 26, 2022, 10:49am
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`GLENN S. LEON
`Chief
`U.S. Department of Justice
`Criminal Division, Fraud Section
`
`CHRISTOPHER FENTON
`MATTHEW REILLY
`BLAKE GOEBEL
`Trial Attorneys
`1400 New York Avenue, N.W.
`Washington, D.C. 20005
`christopher.fenton@usdoj.gov
`matthew.reilly2@usdoj.gov
`blake.goebel@usdoj.gov
`(202) 514-0561 (Fenton)
`(202) 320-8523 (Reilly)
`(202) 768-2277 (Goebel)
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF HAWAII
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`Securities and Exchange Commission,
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`Plaintiff,
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`vs.
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`Semisub, Inc., Curtiss Edward Jackson, and
`Jamey Denise Jackson,
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`Defendants.
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`Case No. 1:22-CV-00349-SOM-KJM
`GOVERNMENT’S
`MEMORANDUM OF POINTS
`AND AUTHORITIES IN
`SUPPORT OF ITS MOTION:
`(1)
`TO INTERVENE; and
`(2)
`TO STAY DISCOVERY
`Hon. Susan Oki Mollway
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`The United States of America, by Glenn S. Leon, Chief of the Fraud Section
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`of the Criminal Division of the U.S. Department of Justice (the “Government”) (Trial
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`1
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`FILED IN THE
`UNITED STATES DISTRICT COURT
`DISTRICT OF HAWAII
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` John A. Mannle, Clerk of Court
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`Case 1:22-cv-00349-SOM-KJM Document 60 Filed 10/26/22 Page 2 of 15 PageID.283
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`Attorneys Christopher Fenton, Matthew Reilly, and Blake Goebel appearing),
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`respectfully: (i) moves to intervene in this securities fraud enforcement action by the
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`U.S. Securities and Exchange Commission (“Civil Action”) under Federal Rule of
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`Civil Procedure 24 (“Rule 24”); and (ii) moves for an initial six-month stay of
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`discovery, with leave to seek extensions thereof, in light of the Government’s
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`prosecution of Defendants Curtiss Edward Jackson and Jamey Denise Jackson based
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`upon similar allegations1 underlying the claims asserted in this Civil Action. See
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`United States v. Curtiss Jackson and J. Denise Jackson, 22-cr-00093-JM (unsealed
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`Oct. 24, 2022)
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`I.
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`FACTUAL BACKGROUND
`As the Court knows, the Civil Action was brought by Plaintiff U.S. Securities
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`and Exchange Commission seeking to enjoin Defendants from violating the federal
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`securities laws, and for other relief, and alleging that they engaged in fraudulent
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`scheme to defraud investors in Semisub, Inc. (“Semisub”), misappropriated investor
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`funds, and made untrue statements of material fact to investors. See Dkt. 1. Both
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`Defendants have answered, generally denying the allegations in the complaint. See
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`Dkts. 15, 18. To the Government’s knowledge, document discovery is set to
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`1 While the Government has not indicted Semisub, Inc.—a Defendant in the Civil Action—given
`that the charges against the individual Defendants stem from and intersect with their roles as
`Semisub’s CEO and President, respectively, the facts in the Civil Action alleged against Semisub
`substantially overlap with those underlying the Government’s prosecution of the individual
`Defendants.
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` 2
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`Case 1:22-cv-00349-SOM-KJM Document 60 Filed 10/26/22 Page 3 of 15 PageID.284
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`commence on October 31, 2022. See Dkts. 34, 45. As discussed further herein,
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`issues that will be the subject of discovery in the Civil Action are within the scope
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`of the criminal action.
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`II. LEGAL STANDARD
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`Under Rule 24(a)(2), the Court must permit anyone to intervene who “claims
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`an interest relating to the property or transaction that is the subject of the action, and
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`[he] is so situated that disposing of the action may as a practical matter impair or
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`impede [his] ability to protect [his] interest . . . .” Alternatively, under Rule
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`24(b)(1)(B), the Court may permit anyone to intervene who “has a claim or defense
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`that shares with the main action a common question of law or fact.” Rule 24
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`“traditionally receives liberal construction in favor of applicants for intervention.”
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`Arakaki v. Cayetano, 324 F.3d 1078, 1083 (9th Cir. 2003).
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`With respect to the requested stay, the Court has discretion to stay civil
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`proceedings “when the interests of justice seem [ ] to require such action.” Keating
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`v. Office of Thrift Supervision, 45 F.3d 322, 324 (9th Cir. 1995) (quoting United
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`States v. Kordel, 397 U.S. 1, 12 n. 27 (1970)). “The decision whether to stay civil
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`proceedings in the face of a parallel criminal proceeding should be made ‘in light of
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`the particular circumstances and competing interests involved in the case.’” Id.
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`(quoting Federal Sav. & Loan Ins. Corp. v. Molinaro, 889 F.2d 899, 902 (9th
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`Cir.1989)). “[A]ny public interest in the swift conclusion of a civil trial is balanced
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`by the countervailing public interest in law enforcement and the proper prosecution
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`of the accused.” Hawaii Cent. Fed. Credit Union v. Kealoha, No. CV 18-00108
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`LEK-KJM, 2018 WL 5499530, at *3 (D. Haw. Oct. 29, 2018); see also Bureerong
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`v. Uvawas, 167 F.R.D. 83, 87 (C.D. Cal. 1996) (quoting Campbell v. Eastland, 307
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`F.2d 478, 487 (5th Cir. 1962)) (“a trial judge should give substantial weight to [the
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`public interest in law enforcement] in balancing the policy against the right of a civil
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`litigant to a reasonably prompt determination of his civil claims or liabilities.”)
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`(alteration in original).
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`III. ARGUMENT
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`A.
`Intervention under Either Provision of Rule 24 Is Appropriate
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`Under Rule 24(a)(2), a party seeking intervention as of right must show that:
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`(1) the application is timely; (2) it has a “significant protectable interest” relating to
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`the property or transaction that is the subject of the action; (3) the disposition of the
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`action may, as a practical matter, impair or impede the applicant’s ability to protect
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`its interest; and (4) the existing parties may not adequately represent the applicant’s
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`interest. Arakaki, 324 F.3d at 1083. Here, the Government meets these
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`requirements. The Government’s motion is timely because the parties in the Civil
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`Action have yet to engage in discovery. Moreover, “[i]t is well established that the
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`United States Attorney may intervene in a federal civil action to seek a stay of
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`discovery when there is a parallel criminal proceeding, which is anticipated or
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`already underway that involves common questions of law or fact.” Bureerong, 167
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`F.R.D. at 86 (collecting cases). The Government has a “distinct and discernable
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`interest in intervening in order to prevent discovery in the civil case from being used
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`to circumvent the more limited scope of discovery in the criminal matter” and
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`“[c]learly, neither the [p]laintiffs nor the [d]efendants have this identical interest.”
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`Id. (quotations omitted). Moreover, the Government has conferred with Plaintiff’s
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`counsel and Plaintiff does not oppose the Government’s motion.2
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`Under Rule 24(b)(1)(B), which provides an alternative basis for intervention,
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`a party may intervene in a civil action when it “has a claim or defense that shares
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`with the main action a common question of law or fact.” In addition to considering
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`whether common questions exist, courts must also consider whether there is an
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`independent ground for jurisdiction and whether “intervention will unduly delay or
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`prejudice the adjudication of the original parties’ rights.” Mishewal Wappo Tribe of
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`Alexander Valley v. Salazar, 534 F. App’x 665, 667 (9th Cir. 2013) (quoting Fed. R.
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`Civ. P. 24(b)(3)). The Government meets these requirements as well. Here, key
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`questions of fact relevant to Plaintiff’s claims are encompassed within the scope of
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`the pending criminal prosecution. The Government also has an independent
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`2 As the individual Defendants are appearing pro se in the Civil Action, the Government did not
`confer with the individual Defendants or their counsel in the criminal matter prior to filing this
`motion. Therefore, Defendants’ positions on both intervention and the request for a stay are
`unknown.
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`Case 1:22-cv-00349-SOM-KJM Document 60 Filed 10/26/22 Page 6 of 15 PageID.287
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`jurisdictional ground for intervention because the Government would intervene as a
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`plaintiff and, under 28 U.S.C. § 1345, “the district courts shall have original
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`jurisdiction of all civil actions, suits or proceedings, commenced by the United
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`States.” Finally, merely allowing the Government to intervene to stay discovery for
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`a limited period of time will not significantly delay the civil action nor unduly
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`prejudice the parties. See, e.g., SEC v. Christian Stanley, Inc., No. CV 11–7147
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`GHK, 2012 WL 13009158, at *4 (C.D. Ca. Sept. 6, 2012) (“Where a party seeks to
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`intervene solely for the purpose of requesting a stay in the proceedings, the prejudice
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`of intervention on the original parties is minimal.”).
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`The Court should Stay Discovery in the Interests of Justice
`B.
`The Court has discretion to stay civil proceedings when it is in the “interests
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`of justice.” Keating, 45 F.3d at 324. The Ninth Circuit generally considers:
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`the extent to which the defendant[s’] fifth amendment rights are implicated.
`In addition, the decisionmaker should generally consider the following
`factors: (1) the interest of the plaintiffs in proceeding expeditiously with this
`litigation or any particular aspect of it, and the potential prejudice to plaintiffs
`of a delay; (2) the burden which any particular aspect of the proceedings may
`impose on defendants; (3) the convenience of the court in the management of
`its cases, and the efficient use of judicial resources; (4) the interests of persons
`not parties to the civil litigation; and (5) the interest of the public in the
`pending civil and criminal litigation.
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`Keating, 45 F.3d at 324-25; see also Sullivan v. United States, No. CV 20-00248
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`LEK-KJM, 2022 WL 105193, at *2 (D. Haw. Jan. 11, 2022). Each of the factors
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`supports staying discovery here.
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`Fifth Amendment Considerations Support the Requested Stay
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`The Government respectfully submits that the requested stay would eliminate
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`a potential substantial burden on the Defendants—namely, having to choose
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`between: (i) invoking their Fifth Amendment right to refuse to testify in the civil
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`case, which could be used against them in the civil litigation; or (ii) responding to
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`discovery and potentially testifying (whether at deposition or otherwise) in the civil
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`case, which statements and testimony could be used against them in a criminal case.
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`See Sullivan, 2022 WL 105193 at *3 (finding that Defendant’s Fifth Amendment
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`rights may be implicated if a civil case is litigated while charges are still pending in
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`an overlapping criminal case); see also SEC v. Nicholas, 569 F. Supp. 2d 1065, 1073
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`(C.D. Cal. 2008) (“the Court has a substantial interest in protecting [a civil
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`defendant’s] right to a fair trial in the criminal case”); see also Chagolla v. City of
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`Chi., 529 F. Supp. 2d 941, 947 (N.D. Ill. 2008) (“A civil defendant in this situation
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`who is effectively backed into a corner in which he has no viable choice but to claim
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`the privilege is forced to face a significant risk of unfair prejudice that may be
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`virtually impossible to remedy.”). In fact, “where both actions arise from the same
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`nucleus of fact, the Fifth Amendment is likely implicated and this factor will favor
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`a stay.” Ka'aina v. Kaua'i Island Util. Co-op., No. CIV 10-00169 ACK-LEK, 2010
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`WL 3834999, at *6 (D. Haw. Sept. 24, 2010) (“the strongest case for deferring civil
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`proceedings until after completion of criminal proceedings is where a party under
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`indictment for a serious offense is required to defend a civil or administrative action
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`involving the same matter”) (quoting Taylor, Bean & Whitaker Mortgage Corp. v.
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`Triduanum Financial, Inc., Civ. No. 2:09–0954 FCD–EFB, 2009 WL 2136986, *2
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`(E.D. Cal. July 15, 2009)).
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`The risk is particularly poignant in this case as the individual Defendants have
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`already invoked their Fifth Amendment rights in answering the Complaint in the
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`Civil Action. See Dkt. 15 ¶¶ 1, 3-5, passim; Dkt. 18 ¶ 1. Here, there is substantial
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`overlap between the SEC’s allegations in the Civil Action and the Government’s
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`criminal charges; staying discovery would alleviate a substantial burden on
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`Defendants concerning when and in what posture they assert their Fifth Amendment
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`rights. Accordingly, this heavily weighted factor favors a stay.
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`The Requested Stay Will Not Prejudice the Plaintiff
`The requested stay would not unduly delay the expeditious resolution of
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`Plaintiff’s claims. The requested stay is for a limited duration. See Sullivan, 2022
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`WL 105193, at *3 (finding a delay of seven months would not cause plaintiff
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`minimal, if any, prejudice). Moreover, at the conclusion of that time, absent a
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`renewed stay, the stay would be lifted and the parties would be permitted to engage
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`in full discovery. And, as noted above, Plaintiff does not oppose the Government’s
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`motion.
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`The Requested Stay neither Prejudices nor Burdens the Defendants
`Burden on the defendant is only a factor “tailored for the situation in which
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`the defendant is seeking a stay of civil proceeding in light of a parallel criminal
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`proceeding,” and is therefore “not applicable when the government is the party
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`seeking stay and the defendant opposes it.” See Christian Stanley, 2012 WL
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`13009158, at *4. Nonetheless, a stay of discovery for a limited duration would not
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`prejudice Defendants because the Court can provide appropriate opportunities for
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`discovery in advance of trial in the Civil Action following its lifting of the stay. See
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`SEC v. Downe, No. 92 Civ. 4092 (PKL), 1993 WL 22126, at *13 (S.D.N.Y. Jan. 26,
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`1993) (quoting SEC v. Chestman, 861 F.2d 49, 50 (2d Cir. 1988)). Moreover, the
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`substantial overlap in the Civil Action and the criminal prosecution will allow
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`Defendants to articulate and sharpen their defenses in the Civil Action through their
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`preparation for and defense in the criminal case. Defendants will also be able to
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`focus on their criminal exposure instead of undertaking civil discovery (as pro se
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`litigants) in the Civil Action while simultaneously defending themselves in the
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`criminal action.
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`The Requested Stay Might Streamline the Civil Litigation
`Similarly, central issues underlying Plaintiff’s claims in the Civil Action are
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`within the scope of the criminal prosecution, including Defendants’ individualized
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`roles in the scheme, the extent of their misappropriation, and the falsity of statements
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`made to investors. In fact, the Civil Action covers a more limited time period than
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`the criminal prosecution. Staying a civil case to allow a substantially similar
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`criminal case to proceed “is the more efficient use of judicial resources.” Sullivan,
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`2022 WL 105193 at *4; see also Christian Stanley, Inc., 2012 WL 13009158, at *5
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`(“considerations of judicial economy weigh most strongly in favor of staying a civil
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`proceeding or aspects of the civil proceeding when a parallel criminal proceeding is
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`pending at the same time and involves overlapping issues.”). If Defendants are
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`convicted in the criminal case, “some or all of the instant case may be barred by
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`the Heck doctrine. Thus, litigating the instant case after the criminal proceedings
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`have been resolved will likely streamline the issues that must be resolved in the
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`instant case.” Sullivan, 2022 WL 105193 at *4 (citing Heck v. Humphrey, 512 U.S.
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`477 (1994)); see also Christian Stanley, Inc., 2012 WL 13009158, at *5 (“a stay may
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`increase efficient use of judicial resources through the application of collateral
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`estoppel”); Nicholas, 569 F. Supp. 2d at 1071 (“collateral estoppel in the criminal
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`case may expedite the resolution of the civil case”); Bureerong, 167 F.R.D. at 87
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`(“some common factual questions may be conclusively determined in the criminal
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`action,” which “would pare down the issues to be determined in the civil case, and
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`serve the interests of judicial economy by narrowing the focus of the action to the
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`benefit of the litigants”). Thus, judicial economy weighs in favor of a stay.
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`The Interest of Non-Parties Are Advanced by a Stay
`As discussed with respect to the prior factor, turning to the disposition of the
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`Civil Action after the conclusion of the criminal proceedings would likely result in
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`a streamlined resolution of the issues. See Sullivan, 2022 WL 105193, at *4. This
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`naturally results in a reduced burden on relevant third parties and counsels in favor
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`of staying discovery in the Civil Action. Id.
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`Moreover, one critical group of non-parties—Semisub’s victim investors—
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`will likely benefit by allowing the criminal case to proceed first as the pool of victims
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`in the criminal case wholly overlaps with the victims in the Civil Action. Should the
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`Defendants be found guilty in the criminal action, criminal restitution could be
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`ordered to rectify the harm that victims suffered. This process is likely to be more
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`expeditious and provide a more wholistic remedy than awaiting the potential
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`resolution of the Civil Action. For example, should Plaintiff prevail and should the
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`Court order disgorgement in the Civil Action, those funds would only be distributed
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`to victims following the establishment and dispensation of a fair fund, and would be
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`limited to the “excess of [defendants’] net profits from wrongdoing.” Liu v. SEC,
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`140 S. Ct. 1936, 1946 (2020). Criminal restitution would likely provide a more
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`expeditious path for victim recovery.
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`For these reasons, the interest of non-parities—particularly the interests of the
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`victim investors—favors staying discovery in the Civil Action.
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`The Public Interest Weighs Strongly in Favor of the Requested Stay
` “[T]he public interest is furthered by a stay because the public’s interest in
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`the integrity of the criminal case is entitled to precedence over the civil
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`litigant.” Sullivan, 2022 WL 105193, at *4 (quoting Micron Tech., Inc. v. United
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`Microelectronics Corp., Case No. 17-cv-06932-MMC, 2019 WL 3037542, at *3
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`(N.D. Cal. July 11, 2019)). As a general matter, courts give “substantial weight” to
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`the “public interest in law enforcement” when balancing against the public interest
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`in prompt resolution of civil claims. Bureerong, 167 F.R.D. at 87 (quoting
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`Campbell, 307 F.2d at 487). While the public interest in Plaintiff’s enforcement of
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`the federal securities laws is substantial, when balanced against the potential
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`resolution of potentially determinative issues through the criminal process, a delay
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`of a few months is justified and ultimately to the public’s benefit. See Logan v.
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`Robert’s Hawaii, Inc., No. CV 20-00113 LEK-WRP, 2021 WL 6497512, at *3 (D.
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`Haw. Dec. 14, 2021) (citing SEC v. Alexander, 2010 WL 5388000, at *6 (N.D. Cal.
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`Dec. 22, 2010) (“where a criminal case on the same matter is already underway,
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`some courts have reasoned that the criminal case is of primary importance to the
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`public, and that the public's strongest interest is in ensuring the integrity of the
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`criminal proceeding”)).
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`The Government’s Interests Support the Requested Stay
`“The interest of the public may be reasonably inferred by the United States of
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`America’s … stance on the parallel proceedings.” Bell on Behalf of Eco Sci. Sols.,
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`Inc. v. Taylor, No. CV 17-00530-LEK-RLP, 2019 WL 1877285, at *4 (D. Haw. Apr.
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`26, 2019). Here, the Government—as putative intervenor—contends its interests
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`track the public’s interests. See Hawaii Cent. Fed. Credit, 2018 WL 5499530, at *3
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`(citing Williams v. United States, Civ. No. 08-00437 ACK-BMK, 2012 WL 406904,
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`at *8 (D. Hawai'i Feb. 8, 2012) (“the public also has a strong interest in law
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`enforcement and the proper prosecution of [the defendant in the criminal matter].”).
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`Specifically, factual questions and issues that will be the subject of discovery in the
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`Civil Action are central components of the Government’s prosecution. If discovery
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`is not stayed, the Defendants in the Civil Action may be able to use civil discovery
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`to obtain testimony and documents which they could not obtain in connection with
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`the ongoing criminal proceeding, therefore undermining the purposeful restrictions
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`on criminal discovery. See Downe, 1993 WL 22126 at *12 (“a stay of discovery is
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`often necessary where liberal discovery rules will allow a litigant to undermine, or
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`gain an unfair advantage in, a potential criminal prosecution”); Nicholas, 569 F.
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`Supp. 2d at 1071-72 (explaining that the criminal discovery rules that the litigants
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`would seek to circumvent “are purposefully limited so as to prevent perjury and
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`manufactured evidence, to protect potential witness[es] from harassment and
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`intimidation, and to level the playing field between the government and the
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`defendant, who would be shielded from certain discovery by the Fifth
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`Amendment”). For example, should discovery in the Civil Action remain active,
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`Defendants could be entitled to depose U.S.-based victims or other potential
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`Government witnesses, which they would not otherwise be entitled to under the rules
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`of criminal discovery.
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`Here, a stay of discovery for a finite period of time reasonably protects the
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`integrity of the Government’s prosecution, and is consistent with the relief often
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`granted by courts in similar cases, see Downe, 1993 WL 22126, at *13 (“[c]ourts
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`have granted stays of discovery in order to protect the integrity of the pending
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`criminal investigations, even where an indictment has not yet been returned”),
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`including numerous courts in this district.3 The Government respectfully submits
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`that its interests are compelling and weigh strongly in favor of a stay.
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`3 See Sullivan, 2022 WL 105193, at *4 (granting continuation of stay in civil action until
`defendant was sentenced and outstanding charges were dismissed in related criminal
`proceeding); Logan, 2021 WL 6497512, at *1 (staying federal civil proceedings pending
`resolution of state criminal charges against defendant); Hawaii Cent. Fed. Credit Union, 2018
`WL 5499530, at *3 (staying civil action pending resolution of either interlocutory sale of
`property subject to criminal forfeiture or the criminal action); Williams, 2012 WL 406904, at *9
`(staying civil case against Government pending resolution of criminal cases); E.E.O.C. v. Glob.
`Horizons, Inc., No. CV 11-00257 DAE-RLP, 2011 WL 5325747, at *7 (D. Haw. Nov. 2, 2011)
`(issuing a stay of civil case against corporate defendant when individual defendants’ Fifth
`Amendment rights in the criminal case could be implicated); Ka'aina, 2010 WL 3834999, at *9
`(staying general discovery in civil action against defendant—while allowing limited discovery
`related to proposed preliminary injunction—who was also defendant in federal criminal matter).
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`CONCLUSION
`V.
`For the foregoing reasons, the Government respectfully requests that the Court
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`grant its motion to intervene and to stay discovery in the Civil Action for six months,
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`with leave to seek extensions thereof.
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`October 26, 2022
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`By:
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`Respectfully submitted,
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`GLENN S. LEON
`Chief
`Fraud Section, Criminal Division
`U.S. Department of Justice
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`
`
`s/ Matthew Reilly
`
`Christopher Fenton
`Matthew Reilly
`Blake Goebel
`Trial Attorneys
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`1400 New York Avenue, N.W.
`Washington, D.C. 20005
`christopher.fenton@usdoj.gov
`matthew.reilly2@usdoj.gov
`blake.goebel@usdoj.gov
`(202) 514-0561 (Fenton)
`(202) 320-8523 (Reilly)
`(202) 768-2277 (Goebel)
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