Cd,
Regarding the issue of not knowing about the re-audit requirement until 9/11:
For that to be true we would have to believe that Robison Hill, hired on 7/21 and Deloitte, "approved" on 8/24 either did not know or chose not to tell the client that they would not be able to file a 10K that included financial statements audited by an accounting firm that had its registration revoked. And that Drakeford, de-registered as of 6/16, also neglected to mention it. This wasn't something that the SEC just made up on the fly.
BTW, given a year end of 5/31 Drakeford should've been doing prep work on the 2009 audit by the date of their de-registration. Leaving it hard for me to understand why the company took until 7/21 to hire a replacement. Even in the best of circumstances, absent a requirement to re-audit the previous year, expecting an audit firm to perform an audit in 5 weeks (7/21-8/29) is a lot to ask.