On 10/10/23, Defendant Timothy Lynch Barton (“Mr. Barton”) respectfully requests the Court hear 20 minutes of oral argument from each of the Securities and Exchange Commission and the Defendant on the Motion for Appointment of a Receiver, for a Preliminary Injunction and Ancillary Relief, and to Lift Stay for Limited Purpose. Such oral argument could be entertained at a time convenient for the Court, including in the days following the October 11, 2023, hearing where witness testimony will be taken.