CMKM Diamonds Inc (fka CMKX)

[Jim Bishop]

It sounds like that is what they are trying to say.

They're throwing out all the defenses they can think of.

First that the SEC lacks the authority to even conduct the proceedings.

Second that the SEC's Division of Enforcement screwed up.

Third that they waited too long.

Fourth that the SEC screwed up again and can't figure out their own rules.

Fifth that it's just plain not fair to punish people that aren't allowed to appear before the proceedings.

Sixth that CMKX screwed up the 2003 filing but they were honest enough to bring that to the attention of the SEC, that they got bad legal advice previously and are now trying to fix things and once they get them fixed they promise not to mess up again.

Seventh that the SEC is vague and ambiguous in part of it's order.

Eighth that the SEC should have waited until after April 17th (60 days) to announce administrative proceedings.

Ninth...we're good guys, we're trying, we're doing our best, Urbie had a damn stroke and had been given bad advice and didn't know what he was doing in the first place.

And they end it with a prayer that the proceedings be dismissed and that the SEC take pity on them.