American Fusion Inc (AMFN)

[tdbowieknife]

1
Throughout their motion and in other public filings with this Court, Defendants have made repeated unsubstantiated and impertinent allegations of misconduct by Commission staff and have demonstrated a bizarre obsession with the Commission staff attorney who investigated this matter. See Defs. uncited “Statement of Uncontested Facts” (nearly all of which “facts” the SEC contests, and half of which center on a particular SEC attorney). These allegations and personal attacks on counsel are frivolous, defamatory, and abusive, and have nothing to do with the merits of SEC’s enforcement action. The SEC reserves the right to raise these issues in a separate Motion for Sanctions under Rule 11(c).

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