SEC v. Charles D. Oliver, Middle District of Florida (Dec. 15, 2025) — Complaint

[OCR_UNRECOVERABLE method=recover reason=missing_pdf ts=2026-08-11T14:53:34.666Z]                                                           

UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 

 
 
  
SECURITIES AND EXCHANGE 
COMMISSION, 

 

 No. 6:25-cv-01754 

  Plaintiff,  
 COMPLAINT 

 v.  
  
CHARLES D. OLIVER, JURY TRIAL DEMANDED 

  
  Defendant.  
  

 

Plaintiff Securities and Exchange Commission (“Commission” or 

“SEC”) alleges: 

SUMMARY 

1. From at least January 2020 through September 2021 (the 

“Relevant Period”), Defendant Charles D. Oliver (“Oliver”), a Florida-based 

insurance agent, marketed and sold approximately $52 million of 

investments in risky, oil and gas securities (the “Oil and Gas Securities”) to 

approximately 50 retail investors. The Oil and Gas Securities were sold in a 

series of unregistered securities offerings sponsored by Resolute Capital 

Partners, LLC (“Resolute”) and Homebound Resources, LLC (“Homebound”). 

Resolute paid transaction-based compensation to Oliver through an 

intermediary company, Beacon Global Group, Inc. (“Beacon Global”).  

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2. Oliver used a radio show and podcast he hosted, Hidden Wealth 

Radio, to reach a larger audience and to solicit additional investors. The 

radio show was broadcast in the Lake Mary, Florida area. During broadcasts, 

Oliver discussed investment and tax strategy while soliciting clients for his 

purported investment and tax advisory group Hidden Wealth Solutions. 

Hidden Wealth Solutions is not a legal entity; it is simply Oliver’s “doing 

business as name” (“DBA”).   

3. During the Relevant Period, Oliver acted as an investment 

adviser through his DBA, Hidden Wealth Solutions. Oliver received, on an 

annual basis, flat fees and fees as a percentage of assets under management 

from clients in exchange for providing investment and wealth management 

advice. He advised clients to invest in the Oil and Gas Securities.  

4. In violation of the federal securities laws, Oliver did not disclose 

to his advisory clients the additional transaction-based compensation he 

received for selling the Oil and Gas securities, which breached his fiduciary 

duty to his advisory clients.  

5. Oliver received at least $4,340,677 in transaction-based 

compensation from Resolute, through Beacon Global, for sales of Oil and Gas 

Securities during the Relevant Period. 

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6. Oliver has never been registered with the Commission in any 

capacity. 

7. Many of the individuals to whom Oliver sold the Oil and Gas 

Securities lost their money. The sponsoring entities, Resolute and 

Homebound, failed to make interest payments and return principal to debt 

investors when notes came due and made only de minimis distributions to 

equity investors.  

8. Oliver violated the federal securities laws by, among other 

things:  

(i) actively participating in the offer and sale of the Oil and Gas 
Securities in securities offerings that were not registered 
with the Commission or exempt from registration;  
 

(ii) acting as a broker in the offer and sale of the Oil and Gas 
Securities while failing to register with the Commission as, 
or associate with, a registered broker-dealer; and  
 

(iii) acting at least negligently, failing to disclose to advisory 
clients his financial conflict of interest in connection with the 
sale of the Oil and Gas securities. 
 

9. Oliver participated in unregistered offerings at key points in the 

chain of distribution of the Oil and Gas Securities, including by actively 

soliciting purchases from investors in this District and elsewhere in the 

United States. The Oil and Gas Securities offerings were not registered with 

the Commission or exempt from registration. 

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10. Oliver acted as an unregistered broker and engaged in the 

business of effecting transactions in securities for others. Defendant actively 

solicited his clients to purchase the Oil and Gas Securities and received 

transaction-based compensation in return.   

11. Acting at least negligently, Oliver also failed to disclose financial 

conflicts of interest while acting as an investment adviser. He recommended 

the Oil and Gas Securities to advisory clients, while failing to disclose to 

those clients the financial compensation he received from the sale of the 

securities.   

VIOLATIONS AND RELIEF SOUGHT 

12. As a result of conduct alleged in this Complaint, Defendant 

violated Sections 5(a) and 5(c) of the Securities Act of 1933 (“Securities Act”) 

[15 U.S.C. §§ 77e(a) and (c)]; Section 15(a) of the Securities Exchange Act of 

1934 (“Exchange Act”) [15 U.S.C. § 78o(a)]; and Section 206(2) of the 

Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(2)].   

13. The Commission seeks a judgment from this Court: 

(a) permanently restraining and enjoining Defendant from, 
directly or indirectly, violating:  (a)  Sections 5(a) and (c) of 
the Securities Act [15 U.S.C. §§ 77e], Section 15(a) of the 
Exchange Act [15 U.S.C. § 78o(a)]; and (b) Section 206(2) of 
the Advisers Act [15 U.S.C. § 80b-6(2)], by committing or 
engaging in specified actions or activities relevant to such 
violations;  
 

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(b) permanently restraining and enjoining Defendant from, 

directly or indirectly, including but not limited to through 
any entity he owns or controls, participating in the issuance, 
purchase, offer, or sale of any security; provided, however, 
that such injunction shall not prevent Defendant from 
purchasing or selling securities for his own personal account; 
 

(c) restraining and enjoining Defendant from, directly or 
indirectly, acting as or being associated with any broker, 
dealer, or investment adviser; for purposes of this 
paragraph: (a) a person is associated with a broker or dealer 
if such person is a partner, officer, director, or branch 
manager of such broker or dealer (or occupies a similar 
status or performs similar functions), directly or indirectly 
controls, is controlled by, or is under common control with 
such broker or dealer, or is an employee of such broker or 
dealer; and (b) a person is associated with an investment 
adviser if such person is a partner, officer, or director of such 
investment adviser (or performs similar functions), or 
directly or indirectly controls or is controlled by such 
investment adviser, including any employee of such 
investment adviser; 
 

(d) ordering Defendant to disgorge his ill-gotten gains, together 
with prejudgment interest thereon pursuant to Sections 
21(d)(3), (d)(5), (d)(7) of the Exchange Act [15 U.S.C. §§ 
78u(d)(3), (5), and (7)]; and 
 

(e) ordering Defendant to pay civil money penalties pursuant to 
Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)], 
Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)], and 
Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)]. 
   

JURISDICTION AND VENUE 

14. The Commission brings this action pursuant to the authority 

conferred upon it by Section 20(b) of the Securities Act [15 U.S.C. §§ 77t(b)], 

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Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)], and Section 209(d) of 

the Advisers Act [15 U.S.C. § 80b-9(d)]. 

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

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

21(d) and 27 of the Exchange Act [15 U.S.C. §§ 78u(d) and 78aa], and 

Sections 209(d), 209(e), and 214(a) of the Advisers Act [15 U.S.C. §§ 80b-9(d), 

80b-9(e), and 80b-14(a)]. 

16. In connection with the conduct alleged in this Complaint, 

Defendant, directly or indirectly, has made use of the means or instruments 

of transportation or communication in interstate commerce, or of a means or 

instrumentality of interstate commerce, or of the mails, in connection with 

the transactions, acts, practices, and courses of business alleged in this 

Complaint. Among other things, Defendant engaged in interstate emails and 

telephone calls with clients and Resolute personnel. 

17. Venue lies in this District pursuant to Section 22(a) of the 

Securities Act [15 U.S.C. §77v(a)], Section 27 of the Exchange Act [15 U.S.C. 

§78aa(a)], and Section 214 of the Advisers Act [15 U.S.C. §80b-14] because 

Defendant transacted business here, certain of the allegations in this 

Complaint occurred here, and Defendant resides and maintains a principal 

place of business in Lake Mary, Florida. 

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TOLLING AGREEMENTS 
 

18. Defendant and the Commission executed tolling agreements that 

tolled the running of any applicable statute of limitation from October 8, 

2024 to July 5, 2025. The Defendant’s securities law violations during the 

Relevant Period are within the five-year statute of limitations for certain 

relief as set forth in 28 U.S.C. § 2462. 

DEFENDANT 

19. Charles Davis Oliver, age 54, resides in Lake Mary, Florida. 

Oliver is a licensed insurance agent in Florida. During the Relevant Period, 

Oliver did business under the name Hidden Wealth Solutions and was the 

owner and operator of Hidden Wealth Radio, a radio show and podcast that 

focused on alternative investments and tax strategy. Oliver has never been 

registered with the Commission as a securities broker or associated with a 

registered broker.  

OTHER RELEVANT PERSONS AND ENTITIES 

20. Beacon Global Group, Inc. is a Georgia company located in 

Marietta, Georgia. Beacon Global purports to offer consultancy services to 

businesses. 

21. Resolute Capital Partners LTD, LLC is a Nevada company 

with offices in Texas, California, and Minnesota. Resolute created numerous 

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oil and gas debt and equity investment vehicles using oil and gas wells 

identified by Homebound and its affiliates.  

22. Homebound Resources, LLC (“Homebound”) is a Texas 

company located in Irving, Texas. Homebound acted as a project sponsor for 

Resolute’s offerings and was responsible for identifying and purchasing the 

oil and gas wells in which the Resolute investment vehicles owned working 

interests.  

23. Thomas Joseph Powell (“Powell”), age 53, is a resident of 

Reno, Nevada. Powell was the owner of Resolute and other related entities 

and served as the Senior Managing Partner of Resolute during the Relevant 

Period. 

24. Stefan Tiberiu Toth (“Toth”), age 48, is a resident of Frisco, 

Texas. Toth is the founder, co-owner, Chairman and Chief Executive Officer 

of Homebound Financial Group, LP, and also operated and controlled its 

subsidiaries, including Homebound, during the Relevant Period.   

25. A 2021 Commission Order found that Resolute, Homebound, 

Powell, and Toth violated registration and anti-fraud provisions of the 

federal securities laws. See In the Matter of Resolute Capital Partners, Ltd, 

LLC, et al., AP File No. 3-20597 (Sept. 24, 2021) (the “Commission Order”). 

In particular, the Commission Order found that Homebound, Resolute, 

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Powell, and Toth sold the Oil and Gas Securities in unregistered offerings 

that were not exempt from registration. It also found that their offering 

disclosures were inadequate and that they made materially misleading 

statements in marketing the Oil and Gas Securities. The misleading 

statements included insufficiently supported oil production projections, 

assertions about potential tax benefits that were unavailable to certain 

investors, and incomplete disclosures about potential uses of investor funds, 

including the amount of funds that would be used for payments to prior debt 

and equity investors. 

26. Each of Homebound, Resolute, Powell, and Toth reached a 

settlement with the Commission, neither admitting nor denying the 

Commission’s findings. The Commission Order found that Homebound, 

Resolute, Powell, and Toth violated Sections 5(a) and (c) and 17(a)(2) and (3) 

of the Securities Act and that Powell and Toth additionally violated Section 

15(a) of the Exchange Act. See https://www.sec.gov/files/litigation/admin/

2025/34-102390.pdf. 

FACTS 

I. The Unregistered Offerings of the Oil and Gas Securities 

27. The Oil and Gas Securities offered and sold by Resolute and 

Homebound included both equity securities and debt securities. The 

securities were offered and sold throughout the Relevant Period. 

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28. The equity securities were membership interests in pooled 

investment vehicles that purchased a percentage interest in a set of oil and 

gas wells identified and purchased by Homebound, including, for example, 

offerings titled Advantage Capital Holdings – I, LLC (“Advantage I”), 

Advantage Energy II, Advantage Capital IV, and Strategic Energy Assets – 

VIII. The offering materials for these equity securities stated that investors 

could expect monetary distributions from revenue earned by the wells’ oil or 

gas production and revenue from any subsequent sale of the wells. 

29. The debt securities were promissory notes issued by subsidiaries 

of Homebound, including, for example, offerings titled Choice Energy 

Holdings – III, the Resolute “Technology” Fund, and Technology Entry II.” 

The offering materials for these debt securities stated that the proceeds 

would be used by a subsidiary of Homebound to acquire oil and gas leases, 

among other things. The offering materials promised fixed interest payments 

ranging between 8% to 12% and the return of capital upon expiration of the 

notes. 

30. The Oil and Gas Securities were “securities” within the meaning 

of Section 2(a)(1) of the Securities Act and Section 3(a)(10) of the Exchange 

Act. The equity securities involved investors paying money to purchase 

membership interests in a common enterprise, and a reasonable expectation 

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of profits based on the efforts of third parties who identified, acquired, and 

drilled the wells. The promissory notes were “notes” as included in the 

definition of “security” set forth in Section 2(a)(1) of the Securities Act. 

31. The offerings of Oil and Gas Securities were required to be 

registered with the Commission under Sections 5(a) and (c) of the Securities 

Act or otherwise qualify for an exemption from registration. During the 

Relevant Period, no registration statement was filed or in effect for any 

offering of the Oil and Gas Securities, and no exemption from registration 

applied to these securities offerings. 

II. Oliver Contracted with Beacon Global  
to be a “Referral Agent” for Resolute 

32. On October 12, 2018, Beacon Global entered into a “Master 

Services Agreement” with Resolute. The agreement obligated Beacon Global 

to provide “support and compliance services” to Resolute. This included 

Beacon Global contracting with “Referral Agents” who would “refer” 

investors to Resolute for potential investment in the Oil and Gas Securities. 

Beacon Global was also required to provide “payment services” to Resolute by 

receiving a monthly ACH transfer from Resolute and using the funds to 

compensate the “Referral Agents.” The agreement stated that Beacon Global 

was to receive compensation, on a monthly basis, of the greater of (a) $20,000 

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or (b) 0.4% of monies brought in by the “Referral Agents.” The agreement 

also provided for reimbursement of Beacon Global’s expenses. 

33. On October 23, 2018, Oliver entered into an agreement with 

Beacon Global to act as a “Referral Agent” (or “Referral Contractor,” as the 

agreement states) for Resolute. The “Referral Contractor Agreement” 

provided that Beacon Global would compensate Oliver for “referring” 

investors to Resolute for investment in the Oil and Gas Securities. It 

specified that Oliver would be paid both a monthly fee and additional 

transaction-based compensation for his efforts. On July 22, 2020, Oliver 

entered into a new “Referral Contractor Agreement,” which updated the 

terms of Oliver’s compensation, but similarly provided that Beacon Global 

would compensate Oliver for his “referral” of investors to Resolute.  

34. The agreements prohibited Oliver, as a “Referral Contractor,” 

from engaging in certain activities. Among other things, Oliver was not 

permitted to: 

a. “Provide to prospective investors or lenders (‘Prospects’) 
any offering documents related to investment 
opportunities”; 
 

b. “Sell any securities or engage in any sales efforts”; 
 

c. “‘Pre-sell’ securities offered by [Resolute] in order to 
gauge a Prospect’s interest in an investment”; 
 

d. “Solicit any Prospect for investment”; 

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e. “Make any recommendation with respect to a potential 

investment”; 
 

f. “Give any advice or express any opinion with respect to a 
potential investment, or its advantages or 
disadvantages”; 
 

g. “Conduct any suitability analysis, conduct any due 
diligence, provide any valuation services, or provide any 
analysis of a potential investment”;  
 

h. “Do any advertising or mass marketing”;  
 

i. “Modify existing or create new educational materials”; 
and 
 

j. “Compensate another person, entity, or other third party 
based on a referral’s investment into any product.” 
 

Despite the foregoing prohibitions in the agreements, as described below, 

Oliver engaged in sales activities. 

III. Oliver’s Sales Activity Relating to the Oil and Gas Securities 

35. Although the “Referral Contractor Agreements” purported to 

limit his services to finding and referring potential investors to Resolute, 

Oliver in fact participated in the offer and sale of the Oil and Gas Securities 

to investors.  

36. Oliver sought out prospective investors through general 

solicitation efforts. He frequently touted his investment advisory services 

through his Hidden Wealth Radio program. Oliver discussed generally tax-

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minimizing investment strategies, and told his listeners that if they were 

interested, they should contact him directly for additional information.  

37. When listeners reached out to Oliver, they were invited to meet 

with him and his staff at the Hidden Wealth Group offices in Lake Mary, 

Florida, or alternatively, to meet via video conference. There, prospective 

clients were given questionnaires to assess their assets, expenses, wealth, 

risk tolerance, and retirement goals. Prospective clients later agreed to be 

advisory clients of Hidden Wealth Group and paid either percentage fees 

based on assets under management, or flat annual advisory fees.  

38. Oliver also hosted investment presentations in various locations 

including Orlando, Florida. Some potential investors attended these 

presentations via Zoom Video Meeting. At the presentations, Oliver spoke 

generally about oil and gas investing and introduced the main presenters—

Stephan Toth of Homebound and Thomas Powell of Resolute. 

39. Oliver described the Oil and Gas Securities in detail to his 

clients. He provided clients with marketing and offering documents for the 

securities, which he then reviewed with them, and discussed with clients the 

tax benefits of investing in the Oil and Gas Securities. Oliver advised his 

clients that the government provides tax incentives for investing in the 

securities, and that Resolute and Homebound had special technology which 

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allowed them to purchase old wells and make them productive. Oliver also 

advised clients that they should expect to double their money within 

approximately three years, when the rejuvenated wells would be sold for a 

substantial profit.   

40. Oliver provided clients with proposed portfolio allocations, 

suggesting how clients should invest in the various Oil and Gas Securities. 

He referred to these proposed portfolio allocations as “Custom Blueprint 

Plans.” 

41. Oliver told clients that Thomas Powell was the largest investor 

in the Oil and Gas Securities, repeating a false statement made by Powell at 

investment seminars. 

42. Oliver told clients that he was a large investor in the Oil and Gas 

Securities, and that he was on the Resolute board of directors. 

43. Oliver told clients that his son was an intern with Resolute. 

44. Oliver advised and answered questions from clients about their 

suitability for investing in the Oil and Gas Securities. 

45. Oliver prepared and sent clients detailed emails extolling the 

benefits of investing in the Oil and Gas Securities. For example, one multi-

page email to a client sent in April 2020 stated in part:  

The Resolute Capital business model is to build up and then sell 
their projects for a profit. The average payout period for each sold 

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project has been under 34 months. The performance has been a 
two times multiple average (Ex. 100k = 200k). The next project just 
became available Oct. 1st, and will be raising 100 million total 
capital raise. 
 
46. Oliver closely tracked his clients’ investments in the Oil and Gas 

Securities with Resolute. Oliver maintained records tracking, among other 

things, which clients had completed investment paperwork, whether they 

had signed relevant investment documents, and how much they had 

invested. Oliver also reached out to clients to confirm when they invested. As 

described above, Oliver actively participated in the sale of the Oil and Gas 

Securities to clients and was not merely a referral agent.  

47. Oliver also was an investment adviser through his DBA Hidden 

Wealth Solutions and advised clients to invest in the Oil and Gas Securities. 

Oliver received percentage fees of assets under management and flat annual 

fees in exchange for providing these clients investment and wealth 

management advice. Oliver failed to disclose to these clients who purchased 

the Oil and Gas Securities the financial compensation Oliver received from 

Resolute/Beacon, which was a breach of his fiduciary duty to his advisory 

clients. Following his recommendation, certain of Oliver’s clients purchased 

the Oil and Gas Securities.    

48. As part of his suite of services, Oliver also offered certain tax 

services including the preparation and filing of tax returns. 

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49. At times, Oliver negotiated debt security interest rates with 

Resolute on behalf of investors. 

50. Oliver’s contribution to the distribution of the Oil and Gas 

Securities was not de minimis. To the contrary, he generated approximately 

$52 million of sales for Resolute during the Relevant Period.  

IV. Specific Examples of Oliver’s Fraud and Deceit upon Investors 

A. Investor A 
 

51. Investor A is a retired senior citizen who resides in Arizona. 

52. In or around late 2019 and early 2020, Investor A heard 

advertisements for Oliver’s advisory services on his radio program Hidden 

Wealth Radio, which was broadcast on Saturday mornings. On the 

broadcasts, Investor A heard Oliver discuss tax avoidance and retirement 

investing. Investor A subsequently performed online research, and reviewed 

the Hidden Wealth Solutions website, including watching some of the videos 

on Oliver’s website. Investor A believed that Oliver’s investment strategies 

seemed appealing, so he called Oliver. 

53. During the initial call, Oliver and his team took information 

regarding Investor A’s current investments and requested a statement of 

current assets, which was provided. Oliver later provided Investor A with a 

“blueprint plan” to give specific advice on how to invest for retirement. 

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Investor A agreed with Oliver’s investment plan and transferred money from 

his brokerage account and his bank account for Oliver to manage. 

54. Investor A regarded Oliver as his investment adviser. Oliver 

charged Investor A $1,500 per year for managing his investments and 

providing tax services. Oliver also earned 1.5% from managing the assets in 

Investor A’s brokerage account. 

55. Oliver recommended that Investor A purchase the Oil and Gas 

Securities offered through Resolute. Oliver showed Investor A some charts 

and projections regarding the Oil and Gas Securities. Oliver explained that 

the investment would double every 12-18 months. Oliver’s main pitch to 

Investor A was that the Oil and Gas Securities provided a tax benefit. Oliver 

also told Investor A that he was an investor in the Oil and Gas Securities, 

and that he was on the Resolute board of directors.   

56. Based on Oliver’s advice, Investor A invested in the Oil and Gas 

Securities that he suggested. All of Investor A’s Oil and Gas Securities were 

in Advantage Capital Holdings – 1, LLC (“Advantage I”), an equity 

investment: investments of $210,000 on February 14, 2020; $50,000 on 

February 18, 2020; $100,000 on February 21, 2020; and $50,000 on February 

24, 2020. 

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57. In total, Investor A invested $410,000 in the Oil and Gas 

Securities based on Oliver’s advice and recommendations. 

58. Oliver never disclosed to Investor A whether he received 

compensation from selling and/or referring these Oil and Gas Securities.   

59. Investor A never received any of his money back that he invested 

in the Oil and Gas Securities.  

B. Investor B 
 

60. Investor B is a retired senior citizen who resides in Connecticut. 

61. In or around late 2019 and early 2020, Investor B listened to 

Oliver’s radio program Hidden Wealth Radio, which were broadcast on 

Saturday mornings. Investor B heard Oliver discuss tax avoidance and 

retirement investing on the radio programs. Investor B heard Oliver discuss 

a variety of investment strategies, with a focus on tax benefits via alternative 

investments.  

62. In or around late 2019 and early 2020, after listening to Oliver’s 

show three to four times, Investor B contacted Oliver regarding his advisory 

services. During the initial call, Oliver collected information about Investor 

B’s assets, income, and expenses. Oliver sent her questionnaires to fill out 

regarding her risk tolerance and retirement goals. Oliver also had her 

complete a suitability questionnaire. 

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63. In early 2020, Investor B retained Oliver as her investment 

advisor. Oliver led Investor B to believe that he was an investment advisor, 

and according to Investor B, convinced her to trust him. Although not certain 

on the specifics, Investor B believes that Oliver received a management fee 

for managing her assets. 

64. Oliver typically communicated with Investor B via telephone. 

65. Oliver sent to Investor B marketing materials that he 

purportedly received from Resolute regarding the Oil and Gas Securities. 

Oliver also send Investor B links to Zoom meetings with representatives of 

Resolute. According to Investor B, Oliver spoke during these presentations, 

speaking generally about the benefits of investing in oil and gas while 

introducing the Resolute presenters. 

66. In or around January 2020, Oliver explained the general concept 

of the Oil and Gas Securities to Investor B and recommended that she invest. 

Oliver also told her that the government wants people to invest in oil and gas 

so they give tax incentives. Oliver explained to Investor B that the 

investments were a good tax savings vehicle, and that Resolute was buying 

old wells and using new technology so they could extract from these wells. 

67. Oliver told Investor B that his son was an intern for Resolute.  

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68. Based on Oliver’s advice, on January 2, 2020, Investor B invested 

$200,000 in Strategic Energy Assets - VIII (an equity investment).  

Subsequently, Investor B invested an additional $150,000 in Choice Energy 

Holdings - III on March 9, 2020 (a debt investment). Oliver told Investor B 

that it may take two to three years before she starts receiving money back. 

69. In total, Investor B invested $350,000 in the Oil and Gas 

Securities based on Oliver’s advice and recommendations. 

70. Oliver never disclosed to Investor B whether he received 

compensation from selling or referring these Oil and Gas Securities.   

71. Investor B never received any of her money back that she 

invested in the Oil and Gas Securities.  

C. Investor C 
 

72. Investor C is a retired senior citizen who resides in Indiana. 

73. In or around March 2020, Charles Oliver was referred to 

Investor C. Oliver called Investor C to discuss his services. Oliver had 

Investor C complete a suitability questionnaire. Investor C told Oliver that 

she was very conservative with her investing, and Oliver explained that the 

Oil and Gas Securities were not risky.   

74. In or around March 2020, Investor C retained Oliver as her 

investment advisor, where he waived the flat advisory fee because her cousin 

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was one of his clients. However, Investor C paid Oliver a percentage advisory 

fee for managing her money held in a brokerage account. 

75. Oliver provided Investor C with a plan for how to invest her 

money in the Oil and Gas Securities. Oliver told her that if she invested in oil 

and gas, it would offset taxes from her previous investments. Oliver also told 

her that he and his family were all invested with the Oil and Gas Securities, 

so Investor C assumed the investments were safe. 

76. Oliver arranged a personal Skype video meeting with Investor C, 

Oliver, Thomas Powell of Resolute, and Stefan Toth of Homebound. Oliver 

moderated the discussion and spoke generally about the Oil and Gas 

Securities, Resolute, and Homebound. Both Toth and Powell made 

presentations regarding their investment offerings during the video meeting. 

77. Based on Oliver’s continued advice, Investor C made several 

investments in the Oil and Gas Securities, including a $100,000 investment 

in Choice Energy Holdings III in April 2020; $50,000, $50,000, and $62,000 

in separate investments in Advantage Capital IV in August 2020; $90,000 in 

Strategic Energy Assets VIII in September 2020; $10,000 in Advantage 

Energy II in September 2020; $10,000 in Choice Energy II in September 

2020; and $5,000 in Tech Entry II in September 2020.    

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78. In total, Investor C invested approximately $337,000 in the Oil 

and Gas Securities based on Oliver’s advice and recommendations. Investor 

C received dividend payments for a while until Resolute stopped making the 

payments. Investor C lost $216,000 in the Oil and Gas Securities. Investor C 

has been unable to contact Oliver since the Resolute scheme collapsed.  

79. Oliver never disclosed to Investor C whether he received 

compensation from selling or referring the Oil and Gas Securities. 

D. Investor D 
 

80. Investor D is a retired senior citizen who resides in Florida. 

81. Investor D listened to Oliver’s radio program Hidden Wealth 

Radio nearly every week for years, which was broadcast on Saturdays. On 

the broadcasts, Oliver discussed tax avoidance and retirement strategies. In 

or around January 2019, Investor D contacted Oliver to discuss his services. 

82. On or around January 24, 2019, Investor D and his spouse met 

with Oliver at his Lake Mary, Florida office. According to Investor D, Oliver 

and his team assessed Investor D’s assets and retirement goals. Investor D 

paid Oliver a $2,500 annual fee for his advisory services. In subsequent 

years, he waived the fee because Investor D complained about a lack of 

returns and not receiving timely, relevant financial statements relating to 

his Oil and Gas Securities.   

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24  

83. On or around January 24, 2019, at Oliver’s office, Oliver and his 

assistant made a presentation to Investor D regarding investing in oil and 

gas. Oliver explained that Resolute buys unproductive wells from large oil 

companies, uses special technology to extract oil from the wells, and makes a 

“fortune” extracting and selling the oil and later selling the wells. Oliver 

explained that the Oil and Gas Securities allowed for a 100% tax deduction 

from any qualified money that Investor D invested. Oliver explained that 

these were equity investments that were not regulated by the SEC. Oliver 

said that over the course of several years, none of the Resolute investments 

had returned less than 80% in 18-32 months.  

84. After the presentation, Investor D informed Oliver that he was 

interested in making the investment. Oliver had him complete a suitability 

questionnaire. Upon reviewing his questionnaire, Oliver told Investor D that 

his selections were too conservative and advised him on how to answer the 

questionnaire so that he would be eligible to invest in the Oil and Gas 

Securities. 

85. Based on Oliver’s advice, Investor D transferred most of his 

traditional 401k retirement account funds to an IRA with Goldstar Trust 

Company. 

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25  

86. Based on Oliver’s continued advice, Investor D made several 

investments in the Oil and Gas Securities, including a $50,000 investment in 

Choice Energy Holdings, III, LLC on March 17, 2020.   

87. In total, Investor D invested $550,000 in the Oil and Gas 

Securities based on Oliver’s advice and recommendations. Investor D only 

received approximately $10,000 back from the investments before the 

Resolute scheme collapsed. 

88. Oliver never disclosed to Investor D whether he received 

compensation from selling or referring the Oil and Gas Securities.   

89. After the Resolute payments and statements stopped, during a 

telephone call, Investor D asked Oliver and his assistant if this was a Ponzi 

scheme. After a long pause, Oliver eventually responded that everything 

with Resolute was legitimate. Oliver repeatedly made excuses to Investor D 

for why payments were delayed, and Oliver repeatedly said he and his 

mother were also investors.  

E. Investor E 
 

90. Investor E is a retired senior citizen who resides in Florida. 

91. In or around January 2019, Investor E began listening to Oliver’s 

radio program Hidden Wealth Radio, which was broadcast on Saturday 

mornings. On the broadcasts, Oliver discussed tax avoidance and retirement 

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26  

strategies through oil and gas investing. In or around January 2019, Investor 

E contacted Oliver to discuss his services. 

92. In or around January 2019, Investor E and her husband, who is 

now deceased, visited Oliver at his offices in Lake Mary, Florida. According 

to Investor E, Oliver assessed their risk tolerance, assets, and financial goals. 

They paid Oliver a flat annual fee of approximately $1,500 for his advisory 

services. 

93. Through at least February 2021, Oliver took over management of 

all of Investor E’s and her husband’s investments and told them what to buy 

and sell. Oliver showed them on his computer how much money they would 

make in the Oil and Gas Securities.   

94. Oliver aggressively pushed Investor E and her husband to 

purchase the Oil and Gas Securities and told them how wonderful the 

securities were for them. Oliver told Investor E and her husband that the Oil 

and Gas Securities would provide greater returns than their current 

investments.  

95. Based on Oliver’s continued advice, Investor E made several 

investments in the Oil and Gas Securities, including a $170,000 investment 

in Choice Energy Holdings III in February 2020, and again in February 

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27  

2021; a $50,000 investment in Advantage I in April 2020; and a $50,000 

investment in Advantage I in May 2020.   

96. In total, Investor E and her late husband invested approximately 

$662,000 in the Oil and Gas Securities based on Oliver’s advice and 

recommendations. They received dividend payments for a while until 

Resolute stopped making the payments. Investor E and her husband lost 

most of their money in the Oil and Gas Securities.  

97. Oliver never disclosed to them whether he received compensation 

from selling or referring the Oil and Gas Securities.   

98. Investor E believes Oliver lied to her and her husband when 

Resolute stopped paying dividends so that she would continue with her 

investments and not withdraw funds.  

F. Investor F 

99. Investor F is a retired senior citizen who resides in Florida. 

100. In or around February 2020, Investor F began listening to 

Oliver’s radio program Hidden Wealth Radio, which was broadcast on 

Saturday mornings. On the broadcasts, Oliver discussed tax avoidance and 

retirement strategies through oil and gas investing. In or around February 

2020, Investor F contacted Oliver to set up an appointment. 

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101. In or around February 2020, Investor F and her husband met 

with Oliver at his office in Lake Mary, Florida. According to Investor F, 

Oliver assessed their assets, risk tolerance, and goals. Investor F and her 

husband paid Oliver a flat fee of $1,000 to be their investment adviser. Oliver 

also received as a fee a percentage of their assets that he was managing. 

Investor F and her husband told Oliver that they did not want to gamble 

with high-risk investments due to their age and retirement status.  

102. In or around March 2020, Oliver recommended that they invest 

in the Oil and Gas Securities. Oliver told them that he had invested a lot of 

money in the Resolute investments, that his son was doing an internship 

with Resolute, and that he would not recommend anything in which he 

would not personally invest. Oliver also provided them with Resolute 

marketing materials further encouraging them to invest.    

103. Based on Oliver’s continued advice, Investor F and her husband 

invested $142,000 in Strategic Energy Assets VIII in or around March 2020. 

They received a few small distributions from the investment and lost nearly 

all of their money. 

104. Oliver never disclosed to Investor F whether he received 

compensation from selling or referring these Oil and Gas Securities. 

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CLAIMS FOR RELIEF 

Count I 

(Violations of Sections 5(a) and 5(c) of the Securities Act) 

 
105. The Commission re-alleges and incorporates by reference the 

allegations in paragraphs 1-104, inclusive, as if they were fully set forth 

herein. 

106. As detailed above, Oliver, by engaging in the securities offerings 

alleged in this Complaint directly or indirectly: 

(a) made use of the means or instruments of 
transportation or communications in interstate 
commerce or of the mails to sell securities through the 
use or medium of any prospectus or otherwise, without 
a registration statement in effect as to such securities;  
 

(b) carried or caused to be carried through the mails or in 
interstate commerce, by any means or instruments of 
transportation, securities for the purpose of sale or for 
delivery after sale, without a registration statement in 
effect as to such securities; and  
 

(c) made use of the means or instruments of 
transportation or communication in interstate 
commerce or of the mails to offer to sell through the 
use or medium of a prospectus or otherwise, securities 
as to which no registration statement had been filed. 
 

107. There were no applicable exemptions from registration for the 

offerings Oliver engaged in as described herein.  

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108. By reason of the foregoing, Defendant violated, and, unless 

enjoined, is reasonably likely to continue to violate, Sections 5(a) and 5(c) of 

the Securities Act, 15 U.S.C. § 77e(a) and 77e(c). 

Count II 

(Violations of Section 15(a) of the Exchange Act) 

109. The Commission re-alleges and incorporates by reference the 

allegations in paragraphs 1-26, and 32-104, inclusive, as if they were fully set 

forth herein. 

110. As detailed above, Defendant, directly or indirectly, by the use of 

the mails or the means or instrumentalities of interstate commerce, while 

acting as a broker or dealer, effected transactions in the purchase or sale of 

securities, while Oliver was not registered with the Commission as a broker 

or dealer in accordance with Section 15(b) of the Exchange Act [15 U.S.C. 

§ 78o(b)]. 

111. By engaging in the conduct described above, Defendant violated, 

and unless restrained and enjoined, is reasonably likely to continue to 

violate, Section 15(a) of the Exchange Act, 15 U.S.C. § 78o(a). 

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Count III 

(Violations of Section 206(2) of the Advisers Act) 

112. The Commission re-alleges and incorporates by reference the 

allegations in paragraphs 1-26, and 35-104 inclusive, as if they were fully set 

forth herein. 

113. By engaging in the acts and conduct alleged in this Complaint, 

Defendant acted as an investment adviser to his clients within the meaning 

of Section 202(a)(11) of the Advisers Act, 15 U.S.C. § 80b-2(a)(11), because, 

for compensation, he engaged in the business of advising others, either 

directly or through publications or writings, as to the value of securities or as 

to the advisability of investing in, purchasing, or selling securities. 

114. As detailed above, Defendant, directly or indirectly, by use of the 

mails or means or instrumentalities of interstate commerce, while acting as 

an investment adviser, acting with at least negligence, engaged in 

transactions, practices, or courses of business which operated as a fraud or 

deceit upon any client or prospective client. 

115. As an investment adviser, Defendant owed his clients a fiduciary 

duty of utmost good faith, undivided loyalty, and care to make full disclosure 

to them of all material facts, as well as a duty to act in their best interests 

and not to act in his own interests to the detriment of his clients. 

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116. Defendant breached his fiduciary duty to clients and engaged in 

fraudulent conduct by not disclosing conflicts of interest to his clients.  

117. By reason of the foregoing, Defendant violated, and unless 

enjoined is reasonably likely to continue to violate, Section 206(2) of the 

Advisers Act, 15 U.S.C. § 80b-6(2). 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court 

find that Defendant committed the violations of the federal securities laws 

alleged herein and: 

I. 

Permanent Injunction 
 

Issue an Order permanently restraining and enjoining Defendant from, 

directly or indirectly, violating (a) Sections 5(a) and (c) of the Securities Act 

[15 U.S.C. §§ 77e(a) and (c)], Section 15(a) of the Exchange Act [15 U.S.C. § 

78(o)]; and (b) Section 206(2) of the Advisers Act [15 U.S.C. § 80b-6(2)], by 

committing or engaging in specified actions or activities relevant to such 

violations. 

II. 

Conduct Based Injunction – Purchase, Offer, Sale of Security 

Issue an Order permanently restraining and enjoining Defendant from, 

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33  

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

or controls:  participating in the issuance, purchase, offer, or sale of any 

security; provided, however, that such injunction shall not prevent Oliver 

from purchasing or selling securities for his own personal account. 

III. 

Conduct Based Injunction – Broker, Dealer, Investment Adviser Bar 

Issue an Order restraining and enjoining Defendant from, directly or 

indirectly, acting as or being associated with any broker, dealer, or 

investment adviser; for purposes of this paragraph: (a) a person is associated 

with a broker or dealer if such person is a partner, officer, director, or branch 

manager of such broker or dealer (or occupies a similar status or performs 

similar functions), directly or indirectly controls, is controlled by, or is under 

common control with such broker or dealer, or is an employee of such broker 

or dealer; and (b) a person is associated with an investment adviser if such 

person is a partner, officer, or director of such investment adviser (or 

performs similar functions), or directly or indirectly controls or is controlled 

by such investment adviser, including any employee of such investment 

adviser. 

 

 

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IV. 

Disgorgement with Prejudgment Interest 

Issue an Order directing Defendant to disgorge all funds received from 

his illegal conduct, together with prejudgment interest thereon, pursuant to 

Section 21(d)(3), (d)(5), (d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3), (5), 

and (7)]; 

V. 

Civil Penalty 

Issue an Order directing Defendant to pay a civil penalty pursuant to 

Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)], Section 21(d) of the 

Exchange Act [15 U.S.C. § 78u(d)], and Section 209(e) of the Advisers Act [15 

U.S.C. § 80b-9(e)]; and 

VI. 

Further Relief 

Granting such other and further relief as this Court may deem just, 

equitable, or necessary. 

VII. 

Retention of Jurisdiction 

Further, the Commission respectfully requests that the Court retain 

jurisdiction over this action and the Defendant in order to implement and 

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35  

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.  

DEMAND FOR JURY TRIAL 

The Commission hereby demands a trial by jury in this case. 

 

 

Date: August 11, 2025  

Respectfully submitted, 

    /s/ Brian T. Fitzsimons 
    
 Brian T. Fitzsimons 
 Securities and Exchange Commission 
 100 F Street NE 
 Washington, D.C. 20549 

Tele: (202) 551-5905 (Fitzsimons) 
 [email protected] 
Of Counsel 
Brian O. Quinn 
David T. Frisof 
 

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JS 44   (Rev. 03/24) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as 
provided by local rules of court.  This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the 
purpose of initiating the civil docket sheet.    (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF 
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

II.  BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff 
and One Box for Defendant) (For Diversity Cases Only)

1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country

IV.  NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury  - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC 
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation

Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations

153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/

362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION Act/Review or Appeal of

Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of

Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition

560 Civil Detainee -
Conditions of 
Confinement

V.  ORIGIN (Place an “X” in One Box Only)
1 Original

Proceeding 
2 Removed from

State Court
3 Remanded from

Appellate Court 
4 Reinstated or

Reopened
5 Transferred from

Another District
(specify)

6 Multidistrict
Litigation - 
Transfer

8  Multidistrict
Litigation -
Direct File

VI.  CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:

VII.  REQUESTED IN
COMPLAINT:

CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P. 

DEMAND $ CHECK YES only if demanded in complaint:
JURY DEMAND: Yes No

VIII.  RELATED CASE(S) 
          IF ANY (See instructions):

JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

26 USC 7609

INTELLECTUAL

NATTTTTTTTTTTTTTTTTTTTTTTUREUREUREUREREUUUREEUUREUREEEUREREREREREREUREUUUU EEEEEUREEUUUU EEEUU EUU EEEEEEEEE OFOOOFOOFOFOFOFOFOFOFOOFFFFFOFOFFFOFFFFFOFFFOFOOOOOOOOO ATAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA TORNEY OFFFF RECO

Securities and Exchange Commission

Brian Fitzsimons, SEC, 100 F St. NE, Washington, DC 
20549, 202-551-5905

Charles D. Oliver

Benjamin Biard, Winget, Spadafora & Schwartzberg, LLP, 
One Southeast Third Avenue, Suite 1950, Miami, Florida 
33131

✖

✖

15 U.S.C. §§ 77e(a) and (c); 15 U.S.C. § 78o(a); 15 U.S.C. § 80b-6(2)

Violations of the federal securities laws

✖

✖

09/10/2025

Seminole

305-830-0604 

Case 6:25-cv-01754     Document 1-1     Filed 09/11/25     Page 1 of 2 PageID 36



JS 44 Reverse (Rev. 03/24)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as 
required by law, except as provided by local rules of court.  This form, approved by the Judicial Conference of the United States in September 1974, is 
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet.  Consequently, a civil cover sheet is submitted to the Clerk of 
Court for each civil complaint filed.  The attorney filing a case should complete the form as follows: 

I.(a) Plaintiffs-Defendants.  Enter names (last, first, middle initial) of plaintiff and defendant.  If the plaintiff or defendant is a government agency, use   
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then 
the official, giving both name and title.

   (b) County of Residence.  For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the 
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land 
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.) 

   (c) Attorneys.  Enter the firm name, address, telephone number, and attorney of record.  If there are several attorneys, list them on an attachment, noting  
in this section "(see attachment)". 

II.   Jurisdiction.  The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings.  Place an "X" 
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below. 
United States plaintiff.  (1) Jurisdiction based on 28 U.S.C. 1345 and 1348.  Suits by agencies and officers of the United States are included here. 
United States defendant.  (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box. 
Federal question.  (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment 
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes 
precedence, and box 1 or 2 should be marked. 
Diversity of citizenship.  (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states.  When Box 4 is checked, the  
citizenship of the different parties must be checked.  (See Section III below; NOTE: federal question actions take precedence over diversity  
cases.) 

III.   Residence (citizenship) of Principal Parties.  This section of the JS 44 is to be completed if diversity of citizenship was indicated above.  Mark this 
section for each principal party. 

IV. Nature of Suit.  Place an "X" in the appropriate box.  If there are multiple nature of suit codes associated with the case, pick the nature of suit code  
that is most applicable.  Click here for: Nature of Suit Code Descriptions. 

V.  Origin.  Place an "X" in one of the seven boxes. 
Original Proceedings.  (1) Cases which originate in the United States district courts. 
Removed from State Court.  (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.   
Remanded from Appellate Court.  (3) Check this box for cases remanded to the district court for further action.  Use the date of remand as the filing 
date. 
Reinstated or Reopened.  (4) Check this box for cases reinstated or reopened in the district court.  Use the reopening date as the filing date. 
Transferred from Another District.  (5) For cases transferred under Title 28 U.S.C. Section 1404(a).  Do not use this for within district transfers or
multidistrict litigation transfers. 
Multidistrict Litigation – Transfer.  (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. 
Section 1407. 
Multidistrict Litigation – Direct File.  (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.  
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7.  Origin Code 7 was used for historical records and is no longer relevant due to  
changes in statute. 

VI.  Cause of Action.  Report the civil statute directly related to the cause of action and give a brief description of the cause.  Do not cite jurisdictional  
statutes unless diversity.  Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service. 

VII.  Requested in Complaint.  Class Action.  Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P. 
Demand.  In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction. 
Jury Demand.  Check the appropriate box to indicate whether or not a jury is being demanded. 

VIII.   Related Cases.   This section of the JS 44 is used to reference related cases, if any.  If there are related cases, insert the docket  
numbers and the corresponding judge names for such cases. 

Date and Attorney Signature.  Date and sign the civil cover sheet. 

Case 6:25-cv-01754     Document 1-1     Filed 09/11/25     Page 2 of 2 PageID 37



AO 440 (Rev. 06/12)  Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

__________ District of __________ 

)
)
)
)
)
)
)
)
)
)
)
)

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure.  The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. 
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

Middle District of Florida

Securities and Exchange Commission

6:25-cv-01754

Charles D. Oliver

Charles D. Oliver
467 Hamptoncrest Circle Unit 301
Lake Mary, FL 32746

Brian T. Fitzsimons, Esq.
Securities and Exchange Commission
100 F. St. NE
Washington, DC 20549-5020

09/11/2025

Case 6:25-cv-01754     Document 1-2     Filed 09/11/25     Page 1 of 2 PageID 38



AO 440 (Rev. 06/12)  Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

I personally served the summons on the individual at (place)

on (date) ; or

I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individual’s last known address; or

I served the summons on (name of individual) , who is

 designated by law to accept service of process on behalf of (name of organization)

on (date) ; or

I returned the summons unexecuted because ; or

Other (specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

6:25-cv-01754

0.00

Case 6:25-cv-01754     Document 1-2     Filed 09/11/25     Page 2 of 2 PageID 39