DD Support Board and Research Team

[tdbowieknife]

TECO - I am apparently a really powerful dude...

In their Memorandum in Support of their cross-motion for summary judgment, defendants made valid points to the effect that this case is not about the SEC’s mission to (i) protect investors, (ii) maintain fair, orderly, and efficient markets and (iii) facilitate capital formation. Instead, this unjustified attack was about the failure on the part of the SEC “... to disassociate itself from persons who are knowingly abusing its process...”. It was undisputed that, prior to the filing, grave concern was expressed that “...unknown persons spewing venom at Blackburn were ‘using’ the Fort Worth office of the SEC to further their own twisted agenda...” Defendants identified an anonymous internet poster calling himself “tdbowieknife” as the leader of financial terrorists working out of the U.K., resulting in 92 celebration-posts on the day the Complaint was filed (December 15, 2014) boasting that:

“TD, looks like you wrote the complaint” Defendants also noted that tdbowieknife was instructing other Treaty-bashers where and how to find SEC trial lawyer Jessica Magee so they could feed her even more false allegations of fraud. Various points that defendants made were as follows:

1. Disassociation from persons abusing the process. Regarding the most important aspect of this case, defendants quoted in their motion from SEC v. Wheeling-Pittsburgh Steel, 648 F.2d 118 (3rd Cir. 1981), and provided language from the SEC’s own Enforcement Manual on the prohibition against the SEC selling itself to the interests of one person (David Hallin) who had a well-documented vendetta against defendant Ronald Blackburn. By relying on allegations from anonymous internet bashers and one person who would do anything to destroy the defendants, the SEC violated its own rules and court rulings preventing such conduct.

2. The responsibilities imposed by Rule 11. In this case, junior SEC associate Samantha Cox appears to have been influenced by tdbowieknife and other professional internet bashers who were destroying Treaty on behalf of unknown naked-short sellers. Thus, defendants quoted in their motion from Pavelic & LeFlore v. Marvel Entertainment, 493 U.S. 120 (1989), on the concept of “responsibility” in the drafting of a Complaint. The mistreatment of Ronald Blackburn by Samantha Cox was subhuman. He made a mistake in 1993 and paid his debt to society, hardly making him a “career criminal”, which was repeatedly alleged in pleadings and briefs throughout this case.

3. The damaging comments by David L. Peaver and David Woodstock. There was something manifestly wrong with the speed and manner in which the SEC directorship sent out three vicious announcements within moments of the filing of the Complaint. Defendants have looked high and low for similarly venomous press releases in other SEC cases but can find nothing close. The irresistible inference is that tdbowieknife wrote these press releases, which the SEC simply copied and pasted onto its letterhead. On December 15, 2014, new CEO Chris Tesarski was changing the directorship and the direction of Treaty. The refusal by the SEC to meet and the refusal by the SEC to participate fairly in the Wells process before filing suit irresponsibly ruined 9,000 shareholders’ modest investments.

4. In re: Kunstler. Defendants wanted to and did apprise the SEC that it could not engage in “...blind reliance on a client...” Here, without a shadow of a doubt, tdbowieknife was providing ammunition to the SEC for purposes of assassinating Ron Blackburn’s character. It was all for the benefit of Davin Hallin and his personal vendetta against Ronald Blackburn.

If interested in further reading...

https://drive.google.com/file/d/1WWrs7p_mT-djqUp5oDNyONXraQO_wubU/view


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