|To: Tim Lento who wrote (1346)||3/13/2015 1:37:16 PM|
|re: ADEC / Eric Dickson sec.gov|
May 8, 2012, a number ofmicrocap promoters began touting AEDC across multiple media outlets, including the mass-mailing ofa 16-page newsletter to 1.2 million U.S. residents (the "AEDC Mailer"), along with e-mail blasts and internet website advertising. The AEDC Mailer made grossly exaggerated claims about the likely success ofAEDC' s oil exploration and the
potential value of AEDC shares.
36. For example, the AEDC Mailer contained unsupportable and false claims such as "Just $5,000 in AEDC [could] fetch a fast $110,550!," "AEDC could very well be a Billion dollar company by summer," "AEDC is already sitting on a massive play where just one of their wells is a proven $800 million gusher!" and "we could see shares hit $4.26 fast, and upwards of
$27.63 when all is said and done." The AEDC Mailer also encouraged investors to purchase
AEDC stock through statements such as "Take Action Now!" and recommended that they do so
at a price of under $4 per share. In addition, the AEDC Mailer falsely claimed that the Michigan
wells it invested in were in close proximity to other wells owned and operated by companies
including ExxonMobil when in reality, at the time, major oil and gas companies such as ExxonMobil were not the owners ofany oil or gas wells anywhere near the wells that AEDC invested in.
37. According to the AEDC Mailer, Themis Partners paid $1.6 million to a U.S. marketing company to conduct the promotional campaign and "approved for public dissemination" all statements within the document. Unbeknownst to the recipients of the AEDC Mailer, however, was that the Cravens used Themis Partners as a conduit to disguise their funding ofthe ,AEDC Mailer:
a. On March 17, 2012, D. Craven instructed Langold's broker to wire $510,000 from Langold's account to Themis Partners, referring to it as a "payment concerning a market awareness program on [AEDC]." On March 22,2012, Themis Partners used this money to fund its $500,000 wire to the marketing company as down payment for the AEDC Mailer.
b. On March 17, 2012, Arliss International, Inc., the Swiss account for which A. Craven is listed as the "settlor" (i.e., the person who creates the trust identified as the account's beneficial owner) and D. Craven had signatory authority and served as the sole director, wired $204,000 to Themis Partners. On March 28, 2012, Themis Partners wired that $200,000 to the marketing company as the second payment for the AEDC promotional campaign.
c. On May 5, 2012, Montafon's Swiss account, which is beneficially owned by A. Craven, wired $922,500 to Themis Partners. On May 8, 2012, Themis Partners
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