SEC v. Stephone N. Patton; Star Oil and Gas Company, Inc.; North Gulf Energy Corporation, Inc.; and Patton Farms, Inc., No. 8:23-cv-02212, Middle District of Florida (Sept. 29, 2023) — Complaint

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA

CASE NO. ___________

SECURITIES AND EXCHANGE COMMISSION,

                                 Plaintiff,

v.

STEPHONE           N.           PATTON,
STAR OIL AND GAS COMPANY, INC.,
NORTH GULF ENERGY CORPORATION, INC., and
PATTON FARMS, INC.,

   Defendants.
_________________________________________/

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF AND
DEMAND FOR JURY TRIAL

 Plaintiff Securities and Exchange Commission (the “Commission”) alleges
as follows:

I. INTRODUCTION

1. From  at  least  February  2020  through  March  2023  (the  “relevant
period”), Stephone N. Patton and his companies Star Oil and Gas Company, Inc.
(“Star  Oil”),  North  Gulf  Energy  Corporation,  Inc.  (“North  Gulf”),  and  Patton
Farms, Inc. (“Patton Farms”) (collectively “Defendants”) engaged in a scheme to
defraud investors, including senior investors.
2. Patton,  a  convicted  felon  in  Florida  and  Mississippi,  incorporated
Florida-based Patton Farms, and Mississippi entities Star Oil and North Gulf, and

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proceeded  to  make  over  30  filings  with  the  Commission  falsely  claiming  to  have
raised over $294 billion in investor funds for these companies, through the sales
of securities.  Additionally, Patton created a publicly accessible website for Star Oil,
which he used, among other things, to promote lies about the company’s annual
revenues, number of employees, numbers of oil platforms and operations.  Patton
also drafted bogus shareholder agreements full of false and misleading statements
as part of the scheme.
3. With his filings, website, and shareholder  agreements,  Patton  was
able to craft an illusion of himself as highly  educated,  falsely  stating  that  he  had
earned  multiple  degrees  from  prominent  universities  and  was  the  head  of  a
successful enterprise, to entice investors.  Patton used every lie at his disposal to
entice investors in various states to purchase shares of stock in Star Oil, North Gulf,
and Patton Farms.
4. Patton solicited investors with pressure tactics, false and misleading
statements  about  himself  and  his  companies’  operations,  assets,  and  revenues
promising   large   monthly   dividend   payments   and   substantial   returns   on
investments.
5. In  reality,  none  of  Patton’s  companies  were  operational,  generated
revenues,  or  had  any  assets.    Moreover,  none  of  the  companies  ever  made  any

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dividend payments or generated any returns for investors.  Patton pocketed every
dollar he raised from investors.
6. By  engaging  in  this  fraudulent  conduct,  Defendants  violated,  and
unless  enjoined,  are  reasonably  likely  to  continue  violating,  Section  17(a)  of  the
Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], Section 10(b) and Rule
10b-5  thereunder  of  the  Securities  Exchange  Act  of  1934  (“Exchange  Act”)  [15
U.S.C.  §  78j(b)  and  17  C.F.R.  §  240.10b-5].    Unless  enjoined,  Defendants  will
continue to violate the federal securities laws.
7. The Commission also seeks an order imposing an officer and director
bar against Patton, and an order mandating that Star Oil and Patton permanently
deactivate  www.staroilandgascompanies.webstarts.com  so  that  it  is  not  viewable
to internet users.
II.      DEFENDANTS

8. Stephone   N.   Patton,   age   52,   is   believed   to   currently   reside   in
Mississippi.      According   to   criminal   records
1
,   Patton   has   used   several   false
addresses   and   aliases   in   the   past.      Patton   falsely   lists   his   residence   at   a
multimillion-dollar   estate   in   Coral   Gables,   Florida.      He   also   lists   multiple
Mississippi  addresses  and  a  Texas  address  in  his  filings  on  the  SEC’s  Electronic

1
 See State of Florida v. Stephone Napoleon Patton, Case No. 16-05888-CF; State of Florida v.
Stephone Napoleon Patton, Case No. 1408208MMANO;
State of Florida v. Stephone Napoleon Patton, Case No. 1114595CFANO
.

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Data  Gathering,  Analysis,  and  Retrieval  system  (EDGAR),
2
  as well as in Florida
and Mississippi state corporate records.  Patton is president and CEO of Star Oil,
North Gulf, and Patton Farms.  Patton is a serial fraudster with multiple criminal
convictions.  Most recently, Patton pled guilty in December 2017 to several felony
counts of identity theft violations in Pinellas County, Florida and was sentenced to
2 years in prison.  Additionally, he has prior convictions in Florida and Mississippi
for defrauding financial institutions, check fraud and grand larceny.
9. Star Oil is a Mississippi corporation with purported principal places
of business in Dallas, Texas and Columbia, Mississippi.  Star Oil’s principal places
of business in its EDGAR and corporate filings are false.  In Form D filings by Star
Oil  from  February  2020  through  December  2022,  Star  Oil  claims  it  raised  over
$113 billion from at least 437 investors. On its website, Star Oil states it operates
around the world and has “31 offshore oil platforms and 6 production natural gas
platforms”  and  generates  “annual  revenues  of  $16  billion.”    The  website  also
advertises Patton as Star Oil’s “Owner and President.”
10. North  Gulf  is  a  Mississippi  corporation  with  its  purported  principal
place  of  business  in  Columbia,  Mississippi.    In  Form  D  filings  from  March  2021

2
 EDGAR is the primary system for companies and others for filing documents with the
Commission as required under the Securities Act, the Exchange Act, the Trust Indenture Act of
1939, and the Investment Company Act of 1940.

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through March 2023, North Gulf claims it has raised over $90 billion from at least
179 investors.
11. Patton  Farms  is  a  Florida  corporation  with  its  purported  principal
place of business in Wimauma, Florida.  In Form D filings from March 2020 to
March 2023, Patton Farms claims it has raised over $91 billion from at least 141
investors.

III.    JURISDICTION AND VENUE

12. This  Court  has  jurisdiction  over  this  action  pursuant  to  Sections
20(b), 20(d)(1), and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and
77v(a)];  Sections  21(d),  21(e),  and  27  of  the  Exchange  Act  [15  U.S.C.  §§  78u(d),
78u(e), and 78aa].
13. This  Court  has  personal  jurisdiction  over  Defendants  and  venue  is
proper  in  the  Middle  District  of  Florida.    Defendants  listed  multiple  Florida
addresses  in  corporate  and  EDGAR  filings  as  their  principal  place  of  business
and/or  mailing  address,  including  Patton  Farms’  purported  principal  place  of
business in Wimauma, Florida, which is located in this district.  Additionally, when
soliciting  investors,  Patton  told  them  that  he  lived  in  the  state  of  Florida  and
conducted business in the state.
14. In connection with the conduct alleged in this Complaint, Defendants,
directly  or  indirectly,  singly  or  in  concert  with  others,  made  use  of  the  means  or

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instrumentalities   of   interstate   commerce,   the   means   and   instruments   of
transportation or communication in interstate commerce, or the mails.
IV.     FACTS
A. Fraudulent Scheme - Material Misrepresentations

15. Since at least February 2020, Patton has held himself out to the public
as   a   highly   educated   doctor   in   philosophy   with   degrees   from   prominent
universities such as Georgetown University, University of Tennessee, Texas A&M
University, and Louisiana State University.  In fact, he does not have degrees from
any of these universities.
16. On Star Oil’s website (www.staroilandgascompanies.webstarts.com),
Patton  describes  his  company  as  a  global  enterprise  that  operates  around  the
world, generates annual revenues of $16 billion and has over 32,000 employees.
The website also contains images of computer-generated maps that falsely depict
locations  of  the  company’s  operations  and  sites  of  over  3,500  active  offshore  oil
platforms  off  the  coast  of  Texas,  Louisiana,  and  Mississippi.  For  example,  the
images below are copied from the Star Oil website:

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17. In furtherance of his scheme to defraud investors, Patton submitted
over  30  Form  D  Notice  filings
3
  claiming  various  safe  harbor  exemptions  from
securities registration for Star Oil, North Gulf, and Patton Farms on SEC’s EDGAR
website.    The  Defendants  falsely  claimed  to have raised hundreds of billions of
dollars  from  investors  in  dozens  of  exempt  private  offerings  conducted  since
February 2020.  The Defendants’ Form D filings also falsely claimed that Patton
received at least $387 million in management fees and other compensation from
the companies in the past three years.
18. The Form D filings included additional false statements, such as:
 Principal Place of Business for Star Oil and North Gulf – 1445 Ross
Ave.,  Dallas,  TX.    None  of  the  Defendants  leased  office  space  or
contracted with tenants.

 CEO Contact information – 11 Casuarina Concourse, Coral Gables,
FL.  Patton falsely lists this address as his residence on Star Oil, North
Gulf and Patton Farms Form D filings and on state corporate records.
Property records show that Patton does not own or reside at the $45
million estate.

 Minimum  Investment  accepted  from  any  outside  investor  -  $5
million.    Patton  solicited  investors  and  sold  investments  for  a  few
thousand dollars.

 Use of Proceeds – “Day to Day Running of the Company.”  There is
no  evidence  that  Patton  used  investors’  funds  to  operate  any  of  the
companies.

3
 Form D is used to file a notice of an exempt offering  of  securities  with  the  SEC.  The  federal
securities  laws  require  the  notice  to  be  filed  by  companies  that  have  sold  securities  without
registration under the Securities Act in an offering made under Rule 504 or 506 of Regulation D
or Section 4(a)(5) of the Securities Act.  A company must file this notice within 15 days after the
first sale of securities in the offering.

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19. None of Patton’s claims about his companies are true.  Patton has not
raised  billions  of  dollars  in  investors’  funds,  nor  has  he  received  hundreds  of
millions  of  dollars  to  operate  these  companies.    None  of  Patton’s  companies  are
operational,   have   any   assets,   or   generate   any   revenues.      Patton   fabricated
everything that he told investors about himself and his companies and everything
he  included  in  his  Form  D  filings.    Patton  did  all  of  this  to  entice  investors  to
purchase shares in his companies.
B.       Solicitation       of       Investors and Misappropriation of
Investor Funds

                      1.           Solicitation           of           Investors
20.  During  the  relevant  period,  Patton  spoke with investors in person and
on  the  telephone,  and  told  investors  elaborate  stories  about  his  companies  and
their  success.    He  told  investors  that  Star  Oil  had  contracts  with  Chevron  and
Texaco, had extensive operations throughout the southeast and Gulf of Mexico and
told  at  least  one  investor  that  the  company  was  investing  in  solar  production  in
California.  Patton made similar claims about North Gulf to at least one investor.
21.  Patton  promised  investors  substantial  returns  on  investments  and
large monthly dividend payments.  He also promised at least one investor that she
would  receive  a  non-voting  position  on  Star  Oil’s  board.    Patton  also  told  that
investor   that   Star   Oil   and   Patton   Farms   were   publicly   traded   companies.
Moreover,  Patton  created  bogus  documents  to  show  investors  his  annual  salary.
Patton  provided  at  least  one  investor  with  a  phony  shareholder  agreement  that

9
stated  Patton’s  annual  salary  as  President  of  Star  Oil  was  $280,966,500;  Patton
presented a fake Star Oil income statement to another investor that showed Patton
earned $36,000 per month.
22.  Patton’s  grift  knew  no  bounds.    In  one  instance,  Patton  introduced
himself to a senior citizen living in Fremont, California, as a legal liaison and health
care  advocate.    Patton  convinced  her  that  he would be able to assist her gain
guardianship  over  her  95-year-old  father.    Desperate  for  assistance,  she  trusted
Patton who advised her that as part of her application for guardianship, she would
have to show that she could support her father financially.
23. Patton used this situation to his advantage and aggressively solicited
her to purchase stocks in Star Oil and Patton Farms.  Patton sent this investor a
Star  Oil  shareholder  agreement,  which  stated  that  she  would  receive  dividend
payments  of  $3,460  per  month.    Patton  told  this  individual  she  could  use  the
returns and dividends she earned from her investments to show that she was able
to financially support her elderly father, which was particularly important to her.
The investor purchased Star Oil and Patton Farms’ stock from Patton through five
separate transactions from September through December 2021.
24.  In  at  least  two  other  instances,  between  June  and  November  2022,
Patton used his personal relationships with investors to persuade them to invest in
his  companies.    Patton  promised  one  of  those  investors  that  the  investor  would
receive the full amount of his investment plus interest within a few months.  Patton
also promised this investor that the investor would become the head of Star Oil’s

10
trucking  transportation  unit.    Patton  even  had  the  investor  speak  on  the  phone
with  an  individual  who  Patton  had  purportedly  hired  as  one  of  the  trucking
transportation unit’s newest drivers.
25. Patton directed investors to send money to his personal Cash App and
Capital  One  bank  account,  which  they  did.    Investors  sent  their  money  to
Defendants in reliance on Defendants’ materially false representations about their
companies’ performance, potential investment profits, and Patton’s business and
education  experience.    Patton  falsely  assured  investors  that  their  investments
would receive substantial returns and large monthly dividend payments.
26.  Defendants  continue  to  evade  all  investor  requests  to  return  funds.
Patton has not returned the calls, text, or email messages of at least two investors
who attempted to inquire about the promised returns on their investments and for
a refund of their investments.  Another investor questioned Patton about dividend
payments  that  were  owed  to  her,  Patton  assured  the  investor  that  Defendants
would make the payments, promising the investor that he would have his secretary
contact the investor with information regarding the dividend payment.  However,
Patton never paid this investor or any investor the promised dividends or returns
on their investments.
                      2.           Misappropriation           of           Investor           Funds
27. Patton did not use any of the investors’ funds as promised.  Instead,
Patton misappropriated all the money he raised through the sales of his companies’
stocks.  Patton created his companies in an effort to dupe investors into giving him

11
money for his personal use.  As investors deposited funds into Patton’s Cash App
and  personal  bank  account,  Patton  comingled  their  funds  with  whatever  other
funds were in his account at that time and used those funds on personal items and
expenses.
28.      Analysis  of  the  account  records  shows  that  Patton  spent  investors
funds  almost  as  soon  as  he  received  those  funds,  on  food  and  travel,  car
maintenance, home repair, miscellaneous purchases, and large cash withdrawals
including approximately:

 $9,900 branch and atm withdrawals;
 $23,520 home repairs and materials;
 $1,856 food and travel;
 $8469 Car maintenance and repairs; and
 $9,965 miscellaneous purchases.

29. Patton has evaded all investors’ requests to return funds.  In an effort
to avoid investors, Patton has not responded to their calls or emails, and routinely
changed  his  phone  number.    Additionally,  Patton  provided  investors  with  false
information  about  the  location  of  his  companies  and  his  personal  residence.    To
date, the Defendants have not returned any of the investors’ money.
V.       CLAIMS       FOR       RELIEF
COUNT I
Violations of Section 17(a)(1) of the Securities Act

30. The Commission adopts by reference paragraphs 1 through 29 of this
Complaint.

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31.      During  the  relevant  period,  Defendants,  in  the  offer  or  sale  of
securities by use of any means or instruments of transportation or communication
in interstate commerce or by use of the mails, knowingly or recklessly, directly or
indirectly employed devices, schemes, or artifices to defraud.
32. By reason of the foregoing, Defendants violated and, unless enjoined,
are reasonably likely to continue to violate Section 17(a)(1) of the Securities Act [15
U.S.C. § 77q(a)(1)].

COUNT II
Violations of Section 17(a)(2) of the Securities Act

33. The Commission adopts by reference paragraphs 1 through 29 of this
Complaint.
34.     During  the  relevant  period,  Defendants,  in  the  offer  or  sale  of
securities by use of any means or instruments of transportation or communication
in  interstate  commerce  or  by  use  of  the  mails,  directly  or  indirectly,  negligently
obtained money or property by means of untrue statements of material facts and
omissions to state material facts necessary in order to make the statements made,
in the light of the circumstances under which they were made, not misleading.
35. By reason of the foregoing, Defendants violated and, unless enjoined,
are reasonably likely to continue to violate Section 17(a)(2) of the Securities Act [15
U.S.C. § 77q(a)(2)].

13
COUNT III
Violations of Section 17(a)(3) of the Securities Act

36. The Commission adopts by reference paragraphs 1 through 29 of this
Complaint.
37.      During  the  relevant  period,  Defendants,  in  the  offer  or  sale  of
securities by use of any means or instruments of transportation or communication
in  interstate  commerce  or  by  use  of  the  mails,  directly  or  indirectly,  negligently
engaged in transactions, practices, or courses of business which have operated, are
now operating or will operate as a fraud or deceit upon the purchasers.
38. By reason of the foregoing, Defendants violated and, unless enjoined,
are  reasonably  likely  to  continue  to  violate  Section  17(a)(3)  of  the  Securities  Act
[15 U.S.C. § 77q(a)(3)].
COUNT IV
Violations of Section 10(b) and Rule 10b-5(a)
of the Exchange Act

39. The Commission adopts by reference paragraphs 1 through 29 of this
Complaint.
40.  During  the  relevant  period,  Defendants,  directly  or  indirectly,  using
any means or instrumentality of interstate commerce, or of the mails, knowingly
or recklessly employed devices, schemes or artifices to defraud in connection with
the purchase or sale of any security.

14
41. By reason of the foregoing, Defendants violated and, unless enjoined,
are  reasonably  likely  to  continue  to  violate  Section  10(b)  of  the  Exchange  Act
]15 U.S.C. § 78j(b)] and Exchange Act Rule 10b-5(a) [17 C.F.R. § 240.10b-5(a)].
COUNT V
Violations of Section 10(b) and Rule 10b-5(b)
of the Exchange Act

42. The Commission adopts by reference paragraphs 1 through 29 of this
Complaint.
43. During the relevant period, Defendants, directly or indirectly, by the
use  of  any  means  or  instrumentality  of  interstate  commerce,  or  of  the  mails,
knowingly  or  recklessly  made  untrue  statements  of  material  facts  or  omitted  to
state material facts necessary in order to make the statements made, in the light of
the  circumstances  under  which  they  were  made,  not  misleading,  in  connection
with the purchase or sale of any security.
43. By reason of the foregoing, Defendants violated and, unless enjoined,
are  reasonably  likely  to  continue  to  violate  Section  10(b)  of  the  Exchange  Act,
[15 U.S.C. § 78j(b)] and Exchange Act Rule 10b-5(b) [17 C.F.R. § 240.10b-5(b)].
COUNT VI
Violations of Section 10(b) and Rule 10b-5(c)
of the Exchange Act

45. The Commission adopts by reference paragraphs 1 through 29 of this
Complaint.

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46. During the relevant period, Defendants, directly or indirectly, by the
use  of  any  means  or  instrumentality  of  interstate  commerce,  or  of  the  mails,
knowingly or recklessly engaged in acts, practices, and courses of business which
have  operated,  are  now  operating  or  will  operate  as  a  fraud  upon  any  person  in
connection with the purchase or sale of any security.
47. By reason of the foregoing Defendants violated and, unless enjoined,
are reasonably likely to continue to violate Section 10(b) of the Exchange Act [15
U.S.C. § 78j(b)] and Exchange Act Rule 10b-5(c), [17 C.F.R. § 240.10b-5(c)].
48.  Defendants,  by  use  of  the  mails  or  any  means  or  instrumentality  of
interstate  commerce,  directly  or  indirectly,  knowingly  or  recklessly  employed  a
device, scheme, or artifice to defraud one or more clients or prospective clients.
49. By reason of the foregoing, Defendants violated and, unless enjoined,
are reasonably likely to continue to violate, Section 206(1) of the Advisers Act, 15
U.S.C. § 80b-6(1).
VI.     RELIEF     REQUESTED
WHEREFORE, the Commission respectfully requests that this Court find
the Defendants committed the violations alleged in this Complaint and,
A.       Permanent       Injunctions

Issue  Permanent  Injunctions,  enjoining  Patton,  Star  Oil,  North  Gulf  and
Patton Farms from violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)],
Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Exchange Act Rule 10b-
5 [17 C.F.R. § 240.10b-5].

16
B.       Conduct-Based       Injunction
Issue  a  Conduct-Based  Injunction,  enjoining  Patton  from  participating,
directly or indirectly, including, but not limited to, through any entity he owns or
controls, (1) participating in the issuance, purchase, offer, or sale of any security
provided, however, that such injunction shall not prevent Patton from purchasing
or selling securities for his own personal account; (2) exercising control over any
commercial  enterprise  or  project  that  issues,  purchases  or  sells  securities  to  any
person other than Patton; and (3) controlling any EDGAR account other than an
individual  EDGAR  account  in  his  own  name  to  comply  with  Patton’s  individual
shareholder  reporting  obligations,  if  any;  and  (4)  making  any  filings  using  the
Commission’s  EDGAR  system,  other  than  filings  related  to  Patton’s  individual
shareholder  reporting  obligations,  if  any,  pursuant  to  Section  21(d)(5)  of  the
Exchange Act, 15 U.S.C. § 78u(d)(5).
C. Disgorgement and Prejudgment Interest

Issue an Order directing Patton, Star Oil, North Gulf and Patton Farms to
disgorge  all  ill-gotten  gains  received  within  the  applicable  statute  of  limitations,
including prejudgment interest, resulting from the acts and/or courses of conduct
alleged in this Complaint.
D.      Civil      Penalty

Issue an Order directing Patton, Star Oil, North Gulf and Patton Farms to
pay a civil money penalty pursuant to Section 20(d) of the Securities Act [15 U.S.C.
§ 77t(d)], and Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)].

17
 E. Officer and Director Bar

Issue  an  Order,  pursuant  to  Section  20(e)  of  the  Securities  Act  [15  U.S.C.
§77t(e)],   and   Section   21(d)(2)   of   the   Exchange   Act   [15   U.S.C.   §78u(d)(2)],
permanently barring Patton from acting as an officer or director of any issuer that
has a class of securities registered with the Commission pursuant to Section 12 of
the Exchange Act [15 U.S.C. § 78l], or that is required to file reports pursuant to
Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)].
F.       Order       to       Deactivate Star Oil’s Website
Issue an Order directing Star Oil and Patton to permanently deactivate the
site www.staroilandgascompanies.webstarts.com so that it is not viewable to
internet  users  in  order  to  halt  any  potential  further  dissemination  of  false
statements,   pursuant   to   Section   21(d)(5)   of   the   Exchange   Act   [15   U.S.C.
§ 78u(d)(5)].
 G.      Further      Relief

Grant such other and further relief as may be necessary and appropriate.
H. Retention of Jurisdiction

Further,   the   Commission   respectfully   requests   that   the   Court   retain
jurisdiction over this action in order to implement and carry out the terms of all
orders  and  decrees  that  it  may  enter,  or  to  entertain  any  suitable  application  or
motion  by  the  Commission  for  additional  relief  within  the  jurisdiction  of  this
Court.
VII.   DEMAND FOR JURY TRIAL

18

The Commission hereby demands a trial by jury on any and all issues in this
action so triable.
September 29, 2023   Respectfully submitted,

      By:  s/Alise Johnson
      Alise Johnson
      Senior Trial Counsel
                                                                  Florida           Bar           No.           0003270

Attorney for Plaintiff
      Securities and Exchange Commission
      801 Brickell Avenue, Suite 1950
Miami, FL 33131
Telephone: (305) 982-6300
Facsimile: (305) 536-4154

UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 

 
CASE NO. ___________ 

 
SECURITIES AND EXCHANGE COMMISSION,    
  
 
   Plaintiff, 
     
v.    
        
STEPHONE N. PATTON,     
STAR OIL AND GAS COMPANY, INC.,    
NORTH GULF ENERGY CORPORATION, INC., and   
PATTON FARMS, INC.,      
             
   Defendants.  
_________________________________________/ 

 
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF AND  

DEMAND FOR JURY TRIAL  
 

 Plaintiff Securities and Exchange Commission (the “Commission”) alleges 

as follows: 

 
I. INTRODUCTION 
 

1. From at least February 2020 through March 2023 (the “relevant 

period”), Stephone N. Patton and his companies Star Oil and Gas Company, Inc. 

(“Star Oil”), North Gulf Energy Corporation, Inc. (“North Gulf”), and Patton 

Farms, Inc. (“Patton Farms”) (collectively “Defendants”) engaged in a scheme to 

defraud investors, including senior investors.   

2. Patton, a convicted felon in Florida and Mississippi, incorporated 

Florida-based Patton Farms, and Mississippi entities Star Oil and North Gulf, and 

Case 8:23-cv-02212   Document 1   Filed 09/29/23   Page 1 of 18 PageID 1



 

2 

proceeded to make over 30 filings with the Commission falsely claiming to have 

raised over $294 billion in investor funds for these companies, through the sales 

of securities.  Additionally, Patton created a publicly accessible website for Star Oil, 

which he used, among other things, to promote lies about the company’s annual 

revenues, number of employees, numbers of oil platforms and operations.  Patton 

also drafted bogus shareholder agreements full of false and misleading statements 

as part of the scheme.   

3. With his filings, website, and shareholder agreements, Patton was 

able to craft an illusion of himself as highly educated, falsely stating that he had 

earned multiple degrees from prominent universities and was the head of a 

successful enterprise, to entice investors.  Patton used every lie at his disposal to 

entice investors in various states to purchase shares of stock in Star Oil, North Gulf, 

and Patton Farms.   

4. Patton solicited investors with pressure tactics, false and misleading 

statements about himself and his companies’ operations, assets, and revenues 

promising large monthly dividend payments and substantial returns on 

investments.   

5. In reality, none of Patton’s companies were operational, generated 

revenues, or had any assets.  Moreover, none of the companies ever made any 

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dividend payments or generated any returns for investors.  Patton pocketed every 

dollar he raised from investors.       

6. By engaging in this fraudulent conduct, Defendants violated, and 

unless enjoined, are reasonably likely to continue violating, Section 17(a) of the 

Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], Section 10(b) and Rule 

10b-5 thereunder of the Securities Exchange Act of 1934 (“Exchange Act”) [15 

U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5].  Unless enjoined, Defendants will 

continue to violate the federal securities laws. 

7. The Commission also seeks an order imposing an officer and director 

bar against Patton, and an order mandating that Star Oil and Patton permanently 

deactivate www.staroilandgascompanies.webstarts.com so that it is not viewable 

to internet users. 

II. DEFENDANTS 
 

8. Stephone N. Patton, age 52, is believed to currently reside in 

Mississippi.  According to criminal records1, Patton has used several false 

addresses and aliases in the past.  Patton falsely lists his residence at a 

multimillion-dollar estate in Coral Gables, Florida.  He also lists multiple 

Mississippi addresses and a Texas address in his filings on the SEC’s Electronic 

 
1 See State of Florida v. Stephone Napoleon Patton, Case No. 16-05888-CF; State of Florida v. 
Stephone Napoleon Patton, Case No. 1408208MMANO; 
State of Florida v. Stephone Napoleon Patton, Case No. 1114595CFANO. 
 

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Data Gathering, Analysis, and Retrieval system (EDGAR),2  as well as in Florida 

and Mississippi state corporate records.  Patton is president and CEO of Star Oil, 

North Gulf, and Patton Farms.  Patton is a serial fraudster with multiple criminal 

convictions.  Most recently, Patton pled guilty in December 2017 to several felony 

counts of identity theft violations in Pinellas County, Florida and was sentenced to 

2 years in prison.  Additionally, he has prior convictions in Florida and Mississippi 

for defrauding financial institutions, check fraud and grand larceny.   

9. Star Oil is a Mississippi corporation with purported principal places 

of business in Dallas, Texas and Columbia, Mississippi.  Star Oil’s principal places 

of business in its EDGAR and corporate filings are false.  In Form D filings by Star 

Oil from February 2020 through December 2022, Star Oil claims it raised over 

$113 billion from at least 437 investors. On its website, Star Oil states it operates 

around the world and has “31 offshore oil platforms and 6 production natural gas 

platforms” and generates “annual revenues of $16 billion.”  The website also 

advertises Patton as Star Oil’s “Owner and President.” 

10. North Gulf is a Mississippi corporation with its purported principal 

place of business in Columbia, Mississippi.  In Form D filings from March 2021 

 
2 EDGAR is the primary system for companies and others for filing documents with the 
Commission as required under the Securities Act, the Exchange Act, the Trust Indenture Act of 
1939, and the Investment Company Act of 1940. 

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through March 2023, North Gulf claims it has raised over $90 billion from at least 

179 investors. 

11. Patton Farms is a Florida corporation with its purported principal 

place of business in Wimauma, Florida.  In Form D filings from March 2020 to 

March 2023, Patton Farms claims it has raised over $91 billion from at least 141 

investors.   

III. JURISDICTION AND VENUE 
 

12. This Court has jurisdiction over this action pursuant to Sections 

20(b), 20(d)(1), and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 

77v(a)]; Sections 21(d), 21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 

78u(e), and 78aa]. 

13. This Court has personal jurisdiction over Defendants and venue is 

proper in the Middle District of Florida.  Defendants listed multiple Florida 

addresses in corporate and EDGAR filings as their principal place of business 

and/or mailing address, including Patton Farms’ purported principal place of 

business in Wimauma, Florida, which is located in this district.  Additionally, when 

soliciting investors, Patton told them that he lived in the state of Florida and 

conducted business in the state.  

14. In connection with the conduct alleged in this Complaint, Defendants, 

directly or indirectly, singly or in concert with others, made use of the means or 

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instrumentalities of interstate commerce, the means and instruments of 

transportation or communication in interstate commerce, or the mails. 

IV. FACTS 

A. Fraudulent Scheme - Material Misrepresentations 
 

15. Since at least February 2020, Patton has held himself out to the public 

as a highly educated doctor in philosophy with degrees from prominent 

universities such as Georgetown University, University of Tennessee, Texas A&M 

University, and Louisiana State University.  In fact, he does not have degrees from 

any of these universities. 

16. On Star Oil’s website (www.staroilandgascompanies.webstarts.com), 

Patton describes his company as a global enterprise that operates around the 

world, generates annual revenues of $16 billion and has over 32,000 employees.  

The website also contains images of computer-generated maps that falsely depict 

locations of the company’s operations and sites of over 3,500 active offshore oil 

platforms off the coast of Texas, Louisiana, and Mississippi. For example, the 

images below are copied from the Star Oil website: 

  

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17. In furtherance of his scheme to defraud investors, Patton submitted 

over 30 Form D Notice filings3 claiming various safe harbor exemptions from 

securities registration for Star Oil, North Gulf, and Patton Farms on SEC’s EDGAR 

website.  The Defendants falsely claimed to have raised hundreds of billions of 

dollars from investors in dozens of exempt private offerings conducted since 

February 2020.  The Defendants’ Form D filings also falsely claimed that Patton 

received at least $387 million in management fees and other compensation from 

the companies in the past three years. 

18. The Form D filings included additional false statements, such as: 

 Principal Place of Business for Star Oil and North Gulf – 1445 Ross 
Ave., Dallas, TX.  None of the Defendants leased office space or 
contracted with tenants.  
 

 CEO Contact information – 11 Casuarina Concourse, Coral Gables, 
FL.  Patton falsely lists this address as his residence on Star Oil, North 
Gulf and Patton Farms Form D filings and on state corporate records.  
Property records show that Patton does not own or reside at the $45 
million estate.  

 
 Minimum Investment accepted from any outside investor - $5 

million.  Patton solicited investors and sold investments for a few 
thousand dollars.  
 

 Use of Proceeds – “Day to Day Running of the Company.”  There is 
no evidence that Patton used investors’ funds to operate any of the 
companies. 
 

 
3 Form D is used to file a notice of an exempt offering of securities with the SEC. The federal 
securities laws require the notice to be filed by companies that have sold securities without 
registration under the Securities Act in an offering made under Rule 504 or 506 of Regulation D 
or Section 4(a)(5) of the Securities Act.  A company must file this notice within 15 days after the 
first sale of securities in the offering.  
 

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19. None of Patton’s claims about his companies are true.  Patton has not 

raised billions of dollars in investors’ funds, nor has he received hundreds of 

millions of dollars to operate these companies.  None of Patton’s companies are 

operational, have any assets, or generate any revenues.  Patton fabricated 

everything that he told investors about himself and his companies and everything 

he included in his Form D filings.  Patton did all of this to entice investors to 

purchase shares in his companies.     

B. Solicitation of Investors and Misappropriation of  
Investor Funds 
 

  1. Solicitation of Investors 

20. During the relevant period, Patton spoke with investors in person and 

on the telephone, and told investors elaborate stories about his companies and 

their success.  He told investors that Star Oil had contracts with Chevron and 

Texaco, had extensive operations throughout the southeast and Gulf of Mexico and 

told at least one investor that the company was investing in solar production in 

California.  Patton made similar claims about North Gulf to at least one investor.   

21. Patton promised investors substantial returns on investments and 

large monthly dividend payments.  He also promised at least one investor that she 

would receive a non-voting position on Star Oil’s board.  Patton also told that 

investor that Star Oil and Patton Farms were publicly traded companies.  

Moreover, Patton created bogus documents to show investors his annual salary.  

Patton provided at least one investor with a phony shareholder agreement that 

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stated Patton’s annual salary as President of Star Oil was $280,966,500; Patton 

presented a fake Star Oil income statement to another investor that showed Patton 

earned $36,000 per month. 

22. Patton’s grift knew no bounds.  In one instance, Patton introduced 

himself to a senior citizen living in Fremont, California, as a legal liaison and health 

care advocate.  Patton convinced her that he would be able to assist her gain 

guardianship over her 95-year-old father.  Desperate for assistance, she trusted 

Patton who advised her that as part of her application for guardianship, she would 

have to show that she could support her father financially. 

23. Patton used this situation to his advantage and aggressively solicited 

her to purchase stocks in Star Oil and Patton Farms.  Patton sent this investor a 

Star Oil shareholder agreement, which stated that she would receive dividend 

payments of $3,460 per month.  Patton told this individual she could use the 

returns and dividends she earned from her investments to show that she was able 

to financially support her elderly father, which was particularly important to her.  

The investor purchased Star Oil and Patton Farms’ stock from Patton through five 

separate transactions from September through December 2021.   

24. In at least two other instances, between June and November 2022, 

Patton used his personal relationships with investors to persuade them to invest in 

his companies.  Patton promised one of those investors that the investor would 

receive the full amount of his investment plus interest within a few months.  Patton 

also promised this investor that the investor would become the head of Star Oil’s 

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trucking transportation unit.  Patton even had the investor speak on the phone 

with an individual who Patton had purportedly hired as one of the trucking 

transportation unit’s newest drivers.  

25. Patton directed investors to send money to his personal Cash App and 

Capital One bank account, which they did.  Investors sent their money to 

Defendants in reliance on Defendants’ materially false representations about their 

companies’ performance, potential investment profits, and Patton’s business and 

education experience.  Patton falsely assured investors that their investments 

would receive substantial returns and large monthly dividend payments.  

26. Defendants continue to evade all investor requests to return funds.  

Patton has not returned the calls, text, or email messages of at least two investors 

who attempted to inquire about the promised returns on their investments and for 

a refund of their investments.  Another investor questioned Patton about dividend 

payments that were owed to her, Patton assured the investor that Defendants 

would make the payments, promising the investor that he would have his secretary 

contact the investor with information regarding the dividend payment.  However, 

Patton never paid this investor or any investor the promised dividends or returns 

on their investments.     

  2. Misappropriation of Investor Funds 

27. Patton did not use any of the investors’ funds as promised.  Instead, 

Patton misappropriated all the money he raised through the sales of his companies’ 

stocks.  Patton created his companies in an effort to dupe investors into giving him 

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money for his personal use.  As investors deposited funds into Patton’s Cash App 

and personal bank account, Patton comingled their funds with whatever other 

funds were in his account at that time and used those funds on personal items and 

expenses.   

28. Analysis of the account records shows that Patton spent investors 

funds almost as soon as he received those funds, on food and travel, car 

maintenance, home repair, miscellaneous purchases, and large cash withdrawals 

including approximately: 

 $9,900 branch and atm withdrawals;  
 $23,520 home repairs and materials; 
 $1,856 food and travel;  
 $8469 Car maintenance and repairs; and 
 $9,965 miscellaneous purchases. 

 
29. Patton has evaded all investors’ requests to return funds.  In an effort 

to avoid investors, Patton has not responded to their calls or emails, and routinely 

changed his phone number.  Additionally, Patton provided investors with false 

information about the location of his companies and his personal residence.  To 

date, the Defendants have not returned any of the investors’ money. 

V. CLAIMS FOR RELIEF 

COUNT I 

Violations of Section 17(a)(1) of the Securities Act 
 

30. The Commission adopts by reference paragraphs 1 through 29 of this 

Complaint. 

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31. During the relevant period, Defendants, in the offer or sale of 

securities by use of any means or instruments of transportation or communication 

in interstate commerce or by use of the mails, knowingly or recklessly, directly or 

indirectly employed devices, schemes, or artifices to defraud. 

32. By reason of the foregoing, Defendants violated and, unless enjoined, 

are reasonably likely to continue to violate Section 17(a)(1) of the Securities Act [15 

U.S.C. § 77q(a)(1)]. 

COUNT II 

Violations of Section 17(a)(2) of the Securities Act 
 

33. The Commission adopts by reference paragraphs 1 through 29 of this 

Complaint.  

34. During the relevant period, Defendants, in the offer or sale of 

securities by use of any means or instruments of transportation or communication 

in interstate commerce or by use of the mails, directly or indirectly, negligently 

obtained money or property by means of untrue statements of material facts and 

omissions to state material facts necessary in order to make the statements made, 

in the light of the circumstances under which they were made, not misleading. 

35. By reason of the foregoing, Defendants violated and, unless enjoined, 

are reasonably likely to continue to violate Section 17(a)(2) of the Securities Act [15 

U.S.C. § 77q(a)(2)]. 

 

 

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COUNT III 

Violations of Section 17(a)(3) of the Securities Act 
 

36. The Commission adopts by reference paragraphs 1 through 29 of this 

Complaint. 

37. During the relevant period, Defendants, in the offer or sale of 

securities by use of any means or instruments of transportation or communication 

in interstate commerce or by use of the mails, directly or indirectly, negligently 

engaged in transactions, practices, or courses of business which have operated, are 

now operating or will operate as a fraud or deceit upon the purchasers. 

38. By reason of the foregoing, Defendants violated and, unless enjoined, 

are reasonably likely to continue to violate Section 17(a)(3) of the Securities Act 

[15 U.S.C. § 77q(a)(3)]. 

COUNT IV 

Violations of Section 10(b) and Rule 10b-5(a) 
of the Exchange Act 

 
39. The Commission adopts by reference paragraphs 1 through 29 of this 

Complaint. 

40. During the relevant period, Defendants, directly or indirectly, using 

any means or instrumentality of interstate commerce, or of the mails, knowingly 

or recklessly employed devices, schemes or artifices to defraud in connection with 

the purchase or sale of any security. 

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41. By reason of the foregoing, Defendants violated and, unless enjoined, 

are reasonably likely to continue to violate Section 10(b) of the Exchange Act 

]15 U.S.C. § 78j(b)] and Exchange Act Rule 10b-5(a) [17 C.F.R. § 240.10b-5(a)]. 

COUNT V 

Violations of Section 10(b) and Rule 10b-5(b) 
of the Exchange Act 

 
42. The Commission adopts by reference paragraphs 1 through 29 of this 

Complaint. 

43. During the relevant period, Defendants, directly or indirectly, by the 

use of any means or instrumentality of interstate commerce, or of the mails, 

knowingly or recklessly made untrue statements of material facts or omitted to 

state material facts necessary in order to make the statements made, in the light of 

the circumstances under which they were made, not misleading, in connection 

with the purchase or sale of any security. 

43. By reason of the foregoing, Defendants violated and, unless enjoined, 

are reasonably likely to continue to violate Section 10(b) of the Exchange Act, 

[15 U.S.C. § 78j(b)] and Exchange Act Rule 10b-5(b) [17 C.F.R. § 240.10b-5(b)]. 

COUNT VI 

Violations of Section 10(b) and Rule 10b-5(c) 
of the Exchange Act 

 
45. The Commission adopts by reference paragraphs 1 through 29 of this 

Complaint. 

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46. During the relevant period, Defendants, directly or indirectly, by the 

use of any means or instrumentality of interstate commerce, or of the mails, 

knowingly or recklessly engaged in acts, practices, and courses of business which 

have operated, are now operating or will operate as a fraud upon any person in 

connection with the purchase or sale of any security. 

47. By reason of the foregoing Defendants violated and, unless enjoined, 

are reasonably likely to continue to violate Section 10(b) of the Exchange Act [15 

U.S.C. § 78j(b)] and Exchange Act Rule 10b-5(c), [17 C.F.R. § 240.10b-5(c)]. 

48. Defendants, by use of the mails or any means or instrumentality of 

interstate commerce, directly or indirectly, knowingly or recklessly employed a 

device, scheme, or artifice to defraud one or more clients or prospective clients. 

49. By reason of the foregoing, Defendants violated and, unless enjoined, 

are reasonably likely to continue to violate, Section 206(1) of the Advisers Act, 15 

U.S.C. § 80b-6(1). 

VI. RELIEF REQUESTED 

WHEREFORE, the Commission respectfully requests that this Court find 

the Defendants committed the violations alleged in this Complaint and,  

A. Permanent Injunctions 
 

Issue Permanent Injunctions, enjoining Patton, Star Oil, North Gulf and 

Patton Farms from violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], 

Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Exchange Act Rule 10b-

5 [17 C.F.R. § 240.10b-5].   

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B. Conduct-Based Injunction 

Issue a Conduct-Based Injunction, enjoining Patton from participating, 

directly or indirectly, including, but not limited to, through any entity he owns or 

controls, (1) participating in the issuance, purchase, offer, or sale of any security 

provided, however, that such injunction shall not prevent Patton from purchasing 

or selling securities for his own personal account; (2) exercising control over any 

commercial enterprise or project that issues, purchases or sells securities to any 

person other than Patton; and (3) controlling any EDGAR account other than an 

individual EDGAR account in his own name to comply with Patton’s individual 

shareholder reporting obligations, if any; and (4) making any filings using the 

Commission’s EDGAR system, other than filings related to Patton’s individual 

shareholder reporting obligations, if any, pursuant to Section 21(d)(5) of the 

Exchange Act, 15 U.S.C. § 78u(d)(5). 

C. Disgorgement and Prejudgment Interest 
 

Issue an Order directing Patton, Star Oil, North Gulf and Patton Farms to 

disgorge all ill-gotten gains received within the applicable statute of limitations, 

including prejudgment interest, resulting from the acts and/or courses of conduct 

alleged in this Complaint. 

D. Civil Penalty 
 

Issue an Order directing Patton, Star Oil, North Gulf and Patton Farms to 

pay a civil money penalty pursuant to Section 20(d) of the Securities Act [15 U.S.C. 

§ 77t(d)], and Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)]. 

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 E. Officer and Director Bar 
 

Issue an Order, pursuant to Section 20(e) of the Securities Act [15 U.S.C. 

§77t(e)], and Section 21(d)(2) of the Exchange Act [15 U.S.C. §78u(d)(2)], 

permanently barring Patton from acting as an officer or director of any issuer that 

has a class of securities registered with the Commission pursuant to Section 12 of 

the Exchange Act [15 U.S.C. § 78l], or that is required to file reports pursuant to 

Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]. 

F. Order to Deactivate Star Oil’s Website 

Issue an Order directing Star Oil and Patton to permanently deactivate the 

site www.staroilandgascompanies.webstarts.com so that it is not viewable to 

internet users in order to halt any potential further dissemination of false 

statements, pursuant to Section 21(d)(5) of the Exchange Act [15 U.S.C. 

§ 78u(d)(5)]. 

 G. Further Relief 
 

Grant such other and further relief as may be necessary and appropriate. 

H. Retention of Jurisdiction 
 

Further, the Commission respectfully requests that the Court retain 

jurisdiction over this action in order to implement and carry out the terms of all 

orders and decrees that it may enter, or to entertain any suitable application or 

motion by the Commission for additional relief within the jurisdiction of this 

Court.  

VII. DEMAND FOR JURY TRIAL 

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The Commission hereby demands a trial by jury on any and all issues in this 

action so triable. 

September 29, 2023   Respectfully submitted, 
 
 
 
      By:  s/Alise Johnson 
      Alise Johnson 
      Senior Trial Counsel 
      Florida Bar No. 0003270 
 

Attorney for Plaintiff 
      Securities and Exchange Commission 
      801 Brickell Avenue, Suite 1950 

Miami, FL 33131 
Telephone: (305) 982-6300 
Facsimile: (305) 536-4154 

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