UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 83245 / May 15, 2018 ADMINISTRATIVE PROCEEDING File No. 3 - 18484 In the Matter of Hedgebrook , JayHawk Energy, Inc. , and Rubicon Finan cial , Inc., Respondents. ORDER INSTITUTING ADMINISTRATIVE PROCEEDINGS AND NOTICE OF HEARING PURSUANT TO SECTION 12(j) OF THE SECURITIES EXCHANGE ACT OF 1934 I. The Securities and Exchange Commission (“Commission”) deems it necessary and ap propriate for the protection of investors that public administrative proceedings be, and hereby are, instituted pursuant to Section 12(j) of the Securities Exchange Act of 1934 (“Exchange Act”) against Respondents Hedgebrook , JayHawk Energy, Inc., and Rubi con Financial, Inc. II. After an investigation, the Division of Enforcement alleges that: A. RESPONDENT S 1 . Hedgebrook (CIK No. 1567852 ) is a defaulted Nevada corporation located in Houston, Texas with a class of securities registered with the Commissio n pursuant to Exchange Act Section 12(g). Hedgebrook i s delinquent in its periodic filings with the Commission, having not filed any periodic reports since it filed a Form 10 - Q for the period ended March 31, 2014, which reported a net loss of $37,977 for the prior three months. As of May 8 , 2018 , the company’s stock (symbol “ HBRK”) was quoted on OTC Link (previously “ Pink Sheets ” ) operated by OTC Markets Group Inc. ( “ OTC Link ” ) , had t wo market makers, and was eligible for the “piggyback” exception of Exch ange Act Rule 15c2 - 11(f)(3). 2 2 . JayHawk Energy , Inc . (CIK No. 1 308710 ) is a permanently revoked Nevada corporation located in Peoria, Arizona with a class of securities registered with the Commission pursuant to Exchange Act Section 12(g). JayHa wk Energy , Inc . i s delinquent in its periodic filings with the Commission, having not filed any periodic reports since it filed a Form 10 - Q for the period ended J une 3 0 , 201 6 , which reported a net loss of $ 730,504 for the prior nine months . As of May 8 , 2 018 , the company’s stock (symbol “ JYHW ”) was quoted on OTC Link, had s even market makers, and was eligible for the “piggyback” exception of Exchange Act Rule 15c2 - 11(f)(3). 3 . Rubicon Financial, Inc. (CIK No. 1103977 ) is a defaulted Nevada corporation located in Irvine, California with a class of securities registered with the Commission pursuant to Exchange Act Section 12(g). Rubicon Financial, Inc. is delinquent in its periodic filings with the Commission, having not filed any periodic reports since i t filed a Form 10 - Q for the period ended June 30, 201 5 , which reported a net loss of $1 66,931 for the prior six months. As of May 8 , 2018 , the company’s stock (symbol “ RBCF ”) was quoted on OTC Link, had five market makers, and was eligible for the “piggyba ck” exception of Exchange Act Rule 15c2 - 11(f)(3). B. DELINQUENT PERIODIC FILINGS 4 . As discussed in more detail above, all of the Respondents are delinquent in their periodic filings with the Commission, have repeatedly failed to meet their obligati ons to file timely periodic reports, and failed to heed delinquency letters sent to them by the Division of Corporation Finance requesting compliance with their periodic filing obligations or, through their failure to maintain a valid address on file with the Commission as required by Commission rules, did not receive such letters. 5 . Exchange Act Section 13(a) and the rules promulgated thereunder require issuers of securities registered pursuant to Exchange Act Section 12 to file with the Commission curr ent and accurate information in periodic reports, even if the registration is voluntary under Section 12(g). Specifically, Rule 13a - 1 requires issuers to file annual reports, and Rule 13a - 13 requires domestic issuers to file quarterly reports. 6 . As a result of the foregoing, Respondents failed to comply with Exchange Act Section 13(a) and Rules 13a - 1 and 13a - 13 thereunder. III. In view of the allegations made by the Division of Enforcement, the Commission deems it necessary and appropriate for the protection of investors that public administrative proceedings be instituted to determine: A. Whether the allegations contained in Section II hereof are true and, in connection therewith, to afford the Respondents an opportunity to establish any defense s to such allegations; and, B. Whether it is necessary and appropriate for the protection of investors to suspend for a period not exceeding twelve months, or revoke the registration of each 3 class of securities registered pursuant to Section 12 of the Ex change Act of the Respondents identified in Section II hereof, and any successor under Exchange Act Rules 12b - 2 or 12g - 3, and any new corporate names of any Respondents. IV. IT IS HEREBY ORDERED that a public hearing for the purpose of taking evidence o n the questions set forth in Section III hereof shall be convened at a time and place to be fixed, and before an Administrative Law Judge to be designated by further order as provided by Rule 110 of the Commission’s Rules of Practice , 17 C.F.R. § 201.110. IT IS HEREBY FURTHER ORDERED that Respondents shall file an Answer to the allegations contained in this Order within ten (10) days after service of this Order, as provided by Rule 220(b) of the Commission’s Rules of Practice , 17 C.F.R. § 201.220(b). If Respondents fail to file the directed Answers, or fail to appear at a hearing after being duly notified, the Respondents, and any successor under Exchange Act Rules 12b - 2 or 12g - 3, and any new corporate names of any Respondents, may be deemed in default a nd the proceedings may be determined against them upon consideration of this Order, the allegations of which may be deemed to be true as provided by Rules 155(a), 220(f), 221(f), and 310 of the Commission’s Rules of Practice , 17 C.F.R. §§ 201.155(a), 201.2 20(f), 201.221(f), and 201.310. This Order shall be served forthwith upon Respondents as provided for in the Commission ’s Rules of Practice. IT IS FURTHER ORDERED that, pursuant to Rule 360(a)(2) of the Commission’s Rules of Practice, 17 C.F.R. § 201.36 0(a)(2), the Administrative Law Judge shall issue an initial decision no later than 30 days from the occurrence of one of the following events: (A) The completion of post - hearing briefing in a proceeding where the hearing has been completed; (B) Where the hearing officer has determined that no hearing is necessary, upon completion of briefing on a motion pursuant to Rule 250 of the Commission’s Rules of Practice, 17 C.F.R. § 201.250; or (C) The determination by the hearing officer that a party is deemed to be in default under Rule 155 of the Commission’s Rules of Practice, 17 C.F.R. § 201.155 and no hearing is necessary. In the absence of an appropriate waiver, no officer or employee of the Commission engaged in the performance of investigative or prosecu ting functions in this or any factually related proceeding will be permitted to participate or advise in the decision of this matter, except as witness or counsel in proceedings held pursuant to 4 notice. Since this proceeding is not “rule making” wi thin the meaning of Section 551 of the Administrative Procedure Act, it is not deemed subject to the provisions of Section 553 delaying the effective date of any final Commission action. By the Commission. Brent J. Fields Secretary