Securities and Exchange Commission v. Helms et al

Filing 1

Copy of ORDER appointing receiver Thomas L. Taylor III by United States District Court, Western District of Texas, Judge Lee Yeakel on 12/03/2013. (Filing fee $ 46.00, Receipt Number 059594) (Attachments: # 1 Cover Letter, # 2 Notice of Filing, # 3 Complaint, # 4 Civil Cover Sheet) (sphil, ).

Case 1:13-cv-01036-LY Document 1 Filed 12/03/13 Page 1 of 16

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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION

SECURITIES AND EXCHANGE COMMISSION,

Z13 DEC -3

L;L,.

H

II:

T.
.:;

§
§

Plaintiff,

§
§

vs.

§
§

ROBERT A. HELMS,
JANNIECE S. KAELIN,
DEVEN SELLERS,
ROLAND BARRERA,
VENDETTA ROYALTY PARTNERS, LTD.,
VENDETTA ROYALTY MANAGEMENT, LLC,
VESTA ROYALTY PARTNERS, LP,
VESTA ROYALTY MANAGEMENT, LLC,
IRON ROCK ROYALTY PARTNERS, LP,
IRON ROCK ROYALTY MANAGEMENT, LLC,
ARCADY RESOURCES, LLC,
BAREFOOT MINERALS, G.P.,
G3 MINERALS, LLC,
HALEY OIL COMPANY, INC.,
LAKE ROCK, LLC,
SEBUD MINERALS, LLC, and
TECHNICOLOR MINERALS, G.P.,

§

§
§
§
§

A13CV1 036
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§

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§

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Defendants,

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and

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§

WILLIAM L. BARLOW, and
GLOBAL CAPITAL VENTURES, LLC,

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§

§

Relief Defendants, solely for the purposes of
equitable relief.

COMPLAINT

§
§

Civil Action No.:

38

EAs

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For its Complaint, Plaintiff Securities and Exchange Commission ("Commission")
alleges as follows:
I.

Summary
Defendants Robert A. Helms and Janniece S. Kaelin are engaged in fraudulent

securities offerings from an office in Austin, Texas. Since at least July 2011, they have offered
investors securities issued by Defendant Vendetta Royalty Partners, Ltd. ("Vendetta Partners"), a

limited partnership they control. Through December 31, 2012, they have raised at least $17.9

million from at least 80 investors in at least 13 states, promising them that Vendetta Partners
would use more than 99% of the investment proceeds to acquire a lucrative portfolio of oil-andgas royalty interests.
2.

In reality, Helms and Kaelin misappropriated the vast majority of the Vendetta

Partners offering proceeds, using the funds to cover personal expenses, payments to Relief
Defendants William L. Barlow and Global Capital Ventures, LLC ("Global Capital"), payments
to other entities they controlHaley Oil Company, Inc. ("Haley Oil"), Technicolor Minerals,

G.P., ("Technicolor Minerals"), and Barefoot Minerals, G.P.

("Barefoot")and payments to

investors of approximately $5.9 million in so-called "Partnership income." They derived the socalled Partnership income, however, primarily from offering proceeds. In other words, Helms
and Kaelin operated a Ponzi scheme through Vendetta Partners.

In the course of the scheme, Helms and Kaelin misrepresented and omitted to
disclose material facts to investors. They grossly understated bank-loan payments made with
offering proceeds. They concealed Vendetta Partners' imminent bank-loan default. And they

represented that there were no material legal proceedings pending against them or Vendetta
Partners when, in fact, they and Vendetta Partners were defendants in a civil case alleging they

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defrauded the plaintiff of $1 .2 million, and were subject to other legal proceedings.
4.

In addition, Helms and Kaelin paid combined commissions totaling $423,500 to

Defendants David Sellers and Roland Barrera, who sold Vendetta Partnership securities to an
investor for $3,050,000. Sellers and Barrera falsely represented to the investor that they would

receive only "small" commissionsin keeping with Vendetta Partners offering documents
stating that promotional expenses would not exceed $50,000when their actual commission was

nearly 14% of the purchase price.
After Vendetta Partners, Helms and Kaelin launched two more fraudulent
offerings, Vesta Royalty Partners, LP ("Vesta Partners") in 2012 and Iron Rock Royalty Partners
LP ("Iron Rock Partners") in 2013. For each of these limited partnerships, they control the

general partner, Vesta Royalty Management, LLC ('Vesta Management") and Iron Rock

Royalty Management, LLC ("Iron Rock Management"), respectively. In the Vesta Partners
offering, they have touted potential investment returns ranging from 300% to 500% to be
achieved in just five to seven years. In reality, their return projections are baseless.
6.

They are promoting the Iron Rock Partners offering through Iron Rock

Management and other companies they control, specifically Defendants SeBud Minerals, LLC

("SeBud Minerals"), Lake Rock, LLC ("Lake Rock"), G3 Minerals, LLC (G3 Minerals), and
Arcady Resources, LLC ("Arcady Resources"). In the Iron Rock Partners offering, they describe

their intent to raise $300 million by April 2014 and tout their "honesty and trustworthiness" and
Vendetta Partners' "successful performance." In reality, Vendetta Partners is a Ponzi scheme,
and they are dishonest and untrustworthy.
By committing the acts alleged in this Complaint, the Defendants directly and
indirectly engaged in, and unless restrained and enjoined by the Court will continue to engage in,

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acts, transactions, practices, and courses of business that violate the anti-fraud provisions of the

federal securities laws, specifically Section 17(a) of the Securities Act of 1933 ("Securities Act")
[15 U.S.C.

§

77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 ("Exchange Act")

[15 U.S.C.

§

78j(b)] and Rule 10b-5 thereunder [17 C.F.R.

§

Ban-era also violated Exchange Act Section 15(a) [15 U.S.C.

240.lOb-5]. Defendants Sellers and
§

78o(a)] by being unregistered

brokers in the offerings described herein.
8.

The Commission brings this action seeking permanent injunctions, disgorgement

plus prejudgment interest, and civil penalties, as to each Defendant and disgorgement as to each

Relief Defendant and all other equitable and ancillary relief to which the Court determines the
Commission is entitled.

II.

Jurisdiction and Venue
9.

The Court has jurisdiction over this action under Section 20(d) and 22(a) of the

Securities Act [15 U.S.C.

§

77t(d) and 77v(a)] and Sections 21(d), 21(e), and 27 of the

Exchange Act [15 U.S.C.

§

78u(d), 78u(e) and 78(aa)]. Venue is proper because the

Defendants and Relief Defendants reside in, and a substantial part of the events and omissions

giving rise to the claims occurred in, the Western District of Texas.

III.

The Parties
10.

Plaintiff Commission is an agency of the United States government.

11.

Defendant Robert A. Helms is a natural person residing in Austin, Texas.

12.

Defendant Janniece S. Kaelin is a natural person residing in Austin, Texas.

13.

Defendant Deven Sellers is a natural person residing in Arvada, Colorado.

14.

Roland Ban-era is a natural person residing in Costa Mesa, California.

15.

Defendant Vendetta Partners is a Texas limited partnership in Austin, Texas.

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16.

Defendant Vendetta Management is a Texas limited liability company in Austin,

17.

Defendant Vesta Partners is a Texas limited partnership in Austin, Texas.

18.

Defendant Vesta Management is a Texas limited liability company in Austin,

19.

Defendant Iron Rock Partners is a Delaware limited partnership principally

Texas.

Texas.

operating in Austin, Texas.
20.

Defendant Iron Rock Management is a Delaware limited liability company

principally operating in Austin, Texas.
21.

Defendant Arcady Resources is a Texas limited liability company in Austin,

22.

Defendant Barefoot Minerals is a Texas general partnership in Austin, Texas.

23.

Defendant G3 Minerals is a Texas limited liability company in Austin, Texas.

24.

Defendant Haley Oil is an Illinois corporation principally operating in Austin,

25.

Defendant Lake Rock is a Texas limited liability company in Austin, Texas.

26.

Defendant SeBud Minerals is a Texas limited liability company in Austin, Texas.

27.

Defendant Technicolor Minerals is a Texas general partnership in Austin, Texas.

28.

Relief Defendant William Barlow is a natural person residing in Austin, Texas.

29.

Relief Defendant Global Capital is a Texas limited liability company in Austin,

Texas.

Texas.

Texas.
V.

Facts
A.

Background

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30.

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Helms and Kaelin, through entities they control, have offered and sold and

continue to offer and sell securities in the form of limited-partnership interests issued by

Defendants Vendetta Partners, Vesta Partners, and Iron Rock Partners. Helms and Kaelin
control each entity through its general partnerDefendants Vendetta Management, Vesta
Management, and Iron Rock Management, respectively.
31.

Helms and Kaelin operate each limited partnership from an office at 8101

Cameron Rd. Suite 109, in Austin, Texas. They utilize a sales team, including Sellers and
Barrera, to offer the securities for sale to investors by telephone, by email, and by in-person

presentations. Helms and Kaelin also directly offer and sell the securities to investors in person
at the Austin office and through emails and phone calls.

B.
32.

The Vendetta Partners Offering

Helms and Kaelin formed Vendetta Partners in 2009. At or about that time,

Vendetta Partners acquired certain oil-and-gas royalty interests, along with limited partners, from

another limited partnership associated with Helms and Kaelin. From January

1,

2011, through

December 31, 2012, Vendetta Partners' royalty interests generated income totaling
approximately $1.4 million.
33.

On August 15, 2011, Vendetta Partners filed with the Commission a securities-

offering notice on Form D, signed by Helms, stating that Vendetta Partners sought to raise $50

million by selling limited-partnership interests. The Form D falsely stated that Vendetta Partners
had not yet sold any securities in the offering. In reality, Vendetta Partners sold securities to two
investors on July 29 and 30, 2011, in exchange for $275,000 combined. Moreover, the Form D
listed Vendetta Management, Helms, and Kaelin as the offering's only "promoters" and falsely
stated that no promoter had received, or would receive, any offering proceeds. In fact, at the

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time of filing Helms and Kaelin had already misappropriated nearly half of the $275,000

received on July29 and 30, 2011. Upon receipt, they transferred $135,000 of these funds to
Vendetta Management and, from there, withdrew $19,450 in cash and transferred an additional
$18,000 to Helms.
34.

In the Vendetta Partners offering, Helms and Kaelin distributed to prospective

investors a private-placement memorandum ("PPM"), which purported to explain the Vendetta
Partners investment. The PPM represented that Vendetta Partners had two "principal
objectives": (1) to purchase oil-and-gas "Royalty Interests" and (2) "to generate Partnership

income from such Royalty Interests." It also represented that the "Partnership will distribute
Partnership income quarterly."
35.

The PPM contained several false and misleading statements. It touted Helms' oil-

and-gas experience, representing that he had "worked with various mineral companies over the
last 10 years advising management on issues involving the acquisition and management of

royalty interests, mineral properties and related legal and financial issues." This statement was
misleading because it did not disclose that Helms the oil-and-gas experience came almost
entirely from operating Vendetta Partners and its affiliated or predecessor companies.
36.

Under the heading, "Accounting," the PPM also falsely stated that Vendetta

Management would furnish investors periodic reports on Vendetta Partners' property

acquisitions and operational results. In fact, it never furnished investors such reports.
37.

Finally, under the heading "Litigation," the PPM falsely stated: "There are no

material pending legal proceedings against the Partnership, the General Partner or its Affiliates."
In reality, Vendetta Partners, Vendetta Management, Technicolor Minerals, Helms, Kaelin, and

other entities affiliated with them were engaged in material litigation during the Vendetta

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Partners offering. A private party sued them in December 2011, alleging that they committed
fraud by purporting to sell mineral interests that they did not even own in exchange for S 1.2
million. The Illinois EPA initiated action against Haley Oil in May 2012, alleging illegal
"release incidents." And the IRS initiated action against Kaelin in October 2012, relating to a tax
liability.
38.

The PPM further represented that Vendetta Partners would use the anticipated $50

million offering proceeds solely for three purposes: (i) to purchase royalty interests; (ii) to pay
10%

of Vendetta Partners' $3,795,000 credit facility; and (iii) to pay promotional expenses. The

PPM contained a summary of the "estimated application and use of the proceeds," which stated
that Vendetta Partners would apply and use the $50 million as follows:

Application

of
Maximum Proceeds

Percent

of Subscriptions

Purchase Costs of Royalty Interests

$49,570,500

Loan Repayment

$

379,500

.76%

Promotional Expenses

$

50,000

.10%

39.

99.14%

From July 29, 2011, through December 31, 2012, Helms and Kaelin raised at least

$17.9 million through the Vendetta Partners offering from at least 80 investors in at least 13
states. Apart from the offering proceeds and the $1.4 million in cash generated from legitimate

royalty interests, which combined totaled approximately $19.3 million, Vendetta had no

significant cash assets. Rather than honor the PPM representations regarding the use of
proceeds, Helms and Kaelin, through a number of entities under their control, misappropriated
the vast majority of the funds.

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40.

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Helms and Kaelin controlled and oversaw the use of all funds that came into

Vendetta Partners. They shared signatory authority on its bank accounts and on the bank
accounts of Vendetta Management. From January

1,

2011, through December 31, 2012,

Vendetta Partners, at the direction of Helms and Kaelin, transferred approximately $4.4 million
to Vendetta Management. Because this was far in excess

of the $1.4 million generated from

legitimate royalty interest income, at least $3 million was misappropnated investor funds. Out of
the $4.4 million transferred to Vendetta Management, they transferred approximately $1.4

million to Helms and an additional $102,000 to Barefoot Minerals.
41.

In addition to the $4.4 million transferred to Vendetta Management, Helms and

Kaelin transferred approximately $702,000 directly to Helms' bank account. They transferred an
additional $193,000 to Technicolor Minerals. They paid approximately $1.6 million to cover
promotional expenses, approximately 32 times the amount promised in the PPM. They used
approximately $1.1 million for loan repayment, approximately four times the amount promised
in the PPM. And they spent approximately $1.6 million to purchase royalty interests, more than

90% less than promised in the PPM.
42.

Vendetta Partners, at the direction of Helms and Kaelin, also used approximately

$5.9 million to make so-called partnership-income distributions to investors. They used money

from later investors to pay these distributions to earlier investors. In this fashion, Helms and

Kaelin created the illusion that Vendetta Partners was a profitable enterprise when, in fact, it was
a fraudulent Ponzi scheme.
43.

Vendetta Partners, at the direction of Helms and Kaelin, transferred

approximately $86,737 combined to Relief Defendant Barlow and his company, Relief

Defendant Global Venture. Neither Barlow nor Global Venture had any legitimate claim to the

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proceeds. Barlow and Global Venture acquired at least some of these proceeds in round-trip

transactions with companies that Helms and Kaelin controlled. Helms orchestrated these
transactions was to create fictitious income to support the fraudulent partnership-income

distributions.
44.

For example, on November 17, 2011, Helms and Kaelin transferred $2,208,800

from Vendetta Partners to Barlow. The next day, Barlow transferred $2,200,300 to Defendant

Haley Oil, a company that Helms controlled, retaining $8,500. On December 5, 2011, Helms
transferred $1.4 million from Haley Oil to Vendetta Partners and falsely recorded it as royalty

income in Vendetta Partners' accounting system. On February

1,

2012, Helms transferred

$550,000 from Haley Oil to Vendetta Partners and falsely recorded it as "lease bonus" income on
Vendetta Partners' accounting system. Helms and Kaelin distributed the nearly $2 million from
the roundtnp transactions to Vendetta Partners investors, falsely characterizing these payments
as partnership-income distributions. Haley Oil retained investor funds totaling $245,300 that it

received in the roundtnp transactions.
45.

On several occasions, Helms and Kaelin provided investors tours of their Austin

office to promote their securities offerings. On at least one such tour in August 2012, they

falsely represented to two investors that Vendetta Partners paid its operating expenses, including
Helms and Kaelin's salaries, from the ongoing revenue stream generated by Vendetta Partners'

royalty interest portfolio. They falsely represented that the investors would earn a return of
150% to 200% on the investment within several months. And they represented that they would

use the proceeds from the investors' limited-partnership purchase$3,050,000--to buy out
another investor's limited-partnership interest. In reality, Helms and Kaelin misappropnated part

of the investors' money, using it to cover undisclosed expenses and to pay commissions to

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Sellers and Barrera, rather than buying out another investor.
46.

During office tours, Helms and Kaelin introduced potential investors to Vendetta

Management's financial analyst, who was a student at the University of Texas and who had not
yet attained a degree. Helms and Kaelin falsely stated to potential investors that the financial

analyst had a degree from the University of Texas. Helms and Kaelin prohibited the financial
analyst, under threat of demotion, from telling investors that he did not actually have a degree.
47.

Vendetta Partners, at the direction of Helms and Kaelin, paid Defendants Sellers

and Barrera approximately $400,000 in commissions, which they split almost evenly, for the
$3,050,000 investment described in paragraph 45, above. When offering the investment,

Sellers and Barrera represented to the investors that they would split a "small" commission. In
reality, their combined commission was more than 13% of the investment and more than eight

times the PPM's $50,000 limit for promotional expenses. Because they did not disclose the
actual size of their commission, their statement that it would be "small" was misleading. Sellers
and Barrera never corrected this misstatement, even as they continued to promote other

offeringsincluding Vesta Partners and Iron Rock partnersto the same investors.
C.
48.

The Vesta Partners Offering

Since at least, July 2012, Helms, Kaelin, Sellers, and Barrera have offered to sell

investors securities issued by Defendant Vesta Partners. At Helms and Kaelin's direction
through Vesta Management, Defendants Sellers and Barrera emailed two prospective investors a

Vesta Partners presentation, describing the company and its offering. According to the
presentation, Vesta Partners would provide investors "predictable quarterly cash distributions
with attractive yields (targeted 15% 20% gross annual yields)" and a 300% to 500% return
within five to seven years. It described Vesta Partners managementincluding Helms and

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Kaelinas having a "Proven track record of consistent investor cash-flows and overall market
performance." And it said that Helms and Kaelin had experience "managing and successfully
exiting royalty.
49.

. .

interest investments, including

. .

.

Vendetta Royalty Partners, Ltd."

These statements in the Vesta Partners presentation were false. Helms and Kaelin

had no reasonable basis to expect that Vesta Partners would provide attractive cash-distribution
yields or a 300% to 500% return within seven years. Indeed, their track record included the

Vendetta Partners Ponzi schemepromoted as a business model virtually identical to that of
Vesta Partnersin which they had never earned a legitimate profit for investors. And Vendetta
Partners was not a successful investment by any reasonable standard.

ft
50.

The Iron Rock Partners Offering

On April 25, 2013, Iron Rock Partners filed with the Commission a Form D,

signed by Helms as manager for Iron Rock Partners' general partner, Iron Rock Management.

The Form D indicates that Iron Rock Partners seeks to raise $300 million over a period not to

exceed one year. In addition to Helms, it lists the following affiliate entities as the offering
promoters: Defendants Iron Rock Management, SeBud Minerals, Lake Rock, G3 Minerals, and

Arcady Resources. It further says that the offering will only be solicited in Florida, New York,
North Carolina, and Pennsylvania.
51.

The Iron Rock Form D is false and misleading. Kaelin and Sellers have actively

promoted the Iron Rock Partners offering, but they are not disclosed as promoters on the Form
D. And Iron Rock Partners, through Helms, Kaelin, Sellers, and other affiliated promoters is

offering the securities in states beyond the four states listedincluding in California.
52.

On March

1,

2013, Sellers emailed an investor located in California, attaching a

"Proposal" in which Sellers offered for sale Iron Rock Partners securities. The Proposal falsely

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stated that investors could expect a 300% to 500% return in five to seven years. As is evident in

Helms and Kaelin's disastrous Vendetta Partners oil-and-gas project, these earnings projections
were baseless. It further said the Iron Rock Partners management teamincluding Helms and

Kaelinhas an "industry reputation of honesty and trustworthiness."

In fact, Helms and Kaelin

were dishonest and untrustworthy, a fact their industry reputation reflected. Indeed others in the

industry sued them for fraud and conspiracy.

FIRST CLAIM
Violations of Section 10(b) of the Exchange Act 115 U.S.C. § 78j(b)j
and Rule lOb-5thereunder [17 C.F.R. § 240.lOb-5]
Plaintiff Commission realleges and incorporates by reference paragraphs

53.

1

through 54 of this Complaint as if set forth verbatim.
Each Defendant, by engaging in the conduct described above, directly or

54.

indirectly, singly or in concert with others, in connection with the purchase or sale of a security,

by the use of means or instrumentalities of interstate commerce, or of the mails, or of the
facilities of a national securities exchange, knowingly or severely recklessly:
a.

employed a device, scheme, or artifice to defraud;

b.

made an untrue statement of a material fact or omitted to state a material fact
necessary in order to make the statements made, in the light of the
circumstances under which they were made, not misleading; or
engaged in an act, practice, or course of business which operated or would
operate as a fraud or deceit upon a person.

55.

By engaging in the conduct described above, each Defendant violated, and unless

restrained and enjoined will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C.
78j(b)] and Rule lOb-Sthereunder [17 C.F.R.

§

§

240.lOb-5].

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SECOND CLAIM
Violations of Section 17(a) of the Securities Act [15 U.S.C.

§

77q(a)J

Plaintiff Commission realleges and incorporates by reference paragraphs

56.

1

through 54 of this Complaint as if set forth verbatim.
Each Defendant, by engaging in the conduct above, singly or in concert with

57.

others, in the offer or sale of securities, by the use of means or instruments of transportation or

communication in interstate commerce or by use of the mails, directly or indirectly:

knowingly or severely recklessly employed a device, scheme, or artifice to

a.

defraud, or
b.

(b) knowingly, recklessly, or negligently obtained money or property by

means of an untrue statement of a material fact or an omission to state a
material fact necessary in order to make the statements made, in light of the
circumstances under which they were made, not misleading; or
c.

(c) knowingly, recklessly, or negligently engaged in a transaction, practice, or

course of business which operated or would operate as a fraud or deceit upon

the purchaser.
58.

By reason of the foregoing, each Defendant violated, and unless enjoined, will

continue to violate Section 17(a) of the Securities Act [15 U.S.C.

THIRD CLAIM
Violations of Section 15(a) of the Exchange Act
59.

§

115

77q(a)J.

U.S.C. § 78o(a)]

Plaintiff Commission realleges and incorporates by reference paragraphs

I

through 54 of this Complaint as if set forth verbatim.
60.

Defendants Sellers and Barrera, by engaging in the conduct described above,

directly or indirectly made use of the mails or means or instrumentalities of interstate commerce

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to effect transactions in, or to induce or attempt to induce, the purchase or sale of securities,

without being registered as a broker or dealer, or being associated with a registered broker or

dealer in accordance with Section 15(a) (1) of the Exchange Act [15 U.S.C.

§

78o(a) (1)].

Accordingly, Defendants Sellers and Barrera were brokers within the definition of

61.

that term in Section 3(a)(4) of the Exchange Act which defines "broker" as any person "engaged
in the business of effecting transactions in securities for the account of others." Defendants

Sellers and Barrera were never so registered and, acted as brokers which included: (1)

solicitation of investors to purchase securities; (2) involvement in negotiations between the issuer
and the investor; and (3) receipt of transaction-related compensation.

By reason of the foregoing, Defendants Rizvi and Strategy Partners violated and,

62.

unless enjoined, will continue to violate Section 15(a)(1) of the Exchange Act [15 U.S.C.

§

78o(a) (1)].

REQUEST FOR RELIEF
Plaintiff respectfully requests that this Court:
I.

Permanently enjoin each Defendant from violating Section 17(a) of the Securities Act [15
U.S.C.

§

77e(a)J and Section 10(b) of the Exchange Act [15 U.S.C.

[17 C.F.R.

§

§

78j(b)] and Rule lOb-S

240.lOb-5] thereunder.
II.

Permanently enjoin Defendants Sellers and Barrera from violating Section 15(a) of the
Exchange Act [15 U.S.C.

§

78o(a)(1)}.
III.

Order each Defendant and Relief Defendant to disgorge an amount equal to the funds and

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benefits obtained illegally, or to which that Defendant or Relief Defendant otherwise has no
legitimate claim, as a result of the violations alleged, plus prejudgment interest on that amount.

Iv.
Order each Defendant to pay a civil penalty in an amount determined by the Court
pursuant to Section 20(d) of the Securities Act [15 U.S.C.
Exchange Act [15 U.S.C.

§

§

77t(d)] and Section 21(d) of the

78u(d)] for the violations alleged herein.
V.

Order such other relief as this Court may deem just and proper.
Respectfully

December 3, 2103

subnedTi

/s/Timothy S. MeCole

r

/

aAI c

V'(

TIMOTHY S. McCOLE
Plaintiffs Lead Attorney
Mississippi Bar No. 10628
United States Securities and Exchange Commission
Burnett Plaza, Suite 1900
801 Cherry Street, Unit 18
Fort Worth, Texas 76102
Telephone: [phone]
FAX: [phone]
E-mail: [e-mail]

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