SEC v. DEPUY ORTHOPAEDICS INC, No. 3:19-cv-01538, Northern District of Texas (June 26, 2019)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION
________________________________________________
SECURITIES AND EXCHANGE COMMISSION, §
        §
 Plaintiff,      §
        §
vs.        §
        §
MARK ALLAN PLUMMER    § Civil Action No.: 3:19-cv-1538
        §
        §

Defendant.      §
________________________________________________§

COMPLAINT

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

SUMMARY

1. Defendant Mark Allan Plummer (“Plummer” or “Defendant”), through his

company Texas E&P Partners, Inc. and its affiliated entities (“Texas E&P”),1 defrauded

investors by misappropriating investor funds.  From February 2015 to April 2017, Texas E&P

raised $6.1 million by selling interests in joint ventures formed to drill and operate two separate

oil well projects.  However, instead of using all of these funds to drill and operate the oil well

projects—as represented to investors when soliciting their investments—Plummer

misappropriated large sums of money.  In total, Plummer misappropriated $399,011 for

undisclosed personal and unauthorized business expenses—including for entertainment, travel,

retail expenses, and his income taxes.

2. In doing so, Plummer violated the antifraud provisions of the federal securities

1 Texas E&P formerly operated under the name Chestnut Exploration Partners, Inc. (“Chestnut
Exploration”).

SEC v. Plummer   Page 2 of 7
Complaint

laws.  Thus, in the interest of protecting the public from further illegal activity, the SEC brings

this action seeking all available relief—including permanent injunctions, disgorgement of ill-

gotten gains plus prejudgment interest, and civil money penalties.

JURISDICTION AND VENUE

3. The Court has jurisdiction over this action under Sections 20(b), 20(d), and 22(a)

of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77t(b), 77t(d) and 77v(a)]; and

Sections 21(d), 21(e), and 27 of the Securities Exchange Act of 1934 (“Exchange Act”) [15

U.S.C. §§ 78u(d), 78u(e), and 78aa].

4. Each of the joint-venture interests offered and sold is an investment contract, and

therefore a “security” as that term is defined under Securities Act Section 2(a)(1) [15 U.S.C. §

77b(a)(1)] and Exchange Act Section 3(a)(10) [5 U.S.C. § 78c(a)(10)].

5. Defendant has, directly or indirectly, made use of the means or instrumentalities

of interstate commerce in connection with the transactions, acts, practices, and courses of

business alleged in the Complaint.

6. Venue is proper because a substantial part of the transactions, acts, practices, and

courses of conduct constituting violations of the federal securities laws occurred in the Northern

District of Texas.

PARTIES

7. Plaintiff SEC is an agency of the United States government.

8. Defendant Plummer is a natural person residing in Richardson, Texas.  He is the

founder, owner, and President of Texas E&P.  In December 2016, a Financial Industry

Regulatory Authority (“FINRA”) hearing panel found that Plummer and Texas E&P produced an

altered document to the FINRA staff, and that Plummer provided misleading testimony

SEC v. Plummer   Page 3 of 7
Complaint

regarding the document.  The FINRA decision expelled Texas E&P from FINRA membership

and barred Plummer from association with any FINRA member.  Plummer has a combined six

judgments from past FINRA arbitrations initiated by investors.  Plummer is not registered with

the SEC in any capacity and remains barred by FINRA.

FACTS

I. PLUMMER HAS A LENGTHY HISTORY PROMOTING OIL AND GAS INVESTMENTS.

9. Plummer has been in the oil business for over thirty years.  He founded numerous

entities related to his drilling projects—including oil and gas operating companies, funding

companies, service companies, and holding corporations.

10. Plummer has had many regulatory issues.  In 2012, the Texas State Securities

Board issued an order against Chestnut Exploration for overcharging investors.2  FINRA has also

conducted multiple investigations of Plummer and his entities over many years for misuse of

investor funds and inadequate supervisory procedures, among other concerns.  This resulted in

the expulsion and judgments in investor arbitrations discussed in Paragraph 8, above.

11. In January 2016, during the FINRA investigation, Plummer renamed Chestnut

Exploration to Texas E&P and continued fundraising for two projects under that name: East

Texas 2H and Salmon 2W.  Fundraising for the East Texas 2H project was active from February

to September 2015.  Salmon 2W fundraising was active from June 2015 through April 2017.

II. PLUMMER DISSEMINATED FALSE AND MISLEADING OFFERING MATERIALS TO
INVESTORS AND MISAPPROPRIATED INVESTOR FUNDS.

12. During this time period, Plummer marketed the Texas E&P securities using false

and misleading offering materials—including a Confidential Investor Memorandum (“CIM”).

2 In the Matter of the Dealer Registration of Chestnut Exploration Partners, Inc., Order No.
IC12-CAF-06 (Jan. 10, 2012).

SEC v. Plummer   Page 4 of 7
Complaint

He distributed the CIM to any investor interested in purchasing the Texas E&P securities.  In

total, at least 100 investors from at least 18 different states were solicited and invested in the

securities based on the representations in the CIM.  These investors included several from the

state of Texas, including Granbury, Fort Worth, and Dallas in the Northern District.

13. The CIM contained false and misleading statements and/or omissions regarding

the use of investor funds.  For example, the Salmon 2W CIM states that the offering’s objectives

are to: (1) acquire an interest in two oil and/or gas wells in Anderson County, Texas, and

participate in operations thereon; (2) provide cash distributions from operations; and (3) provide

tax benefits to investors.  The CIM details that the investor funds are to be used as follows:

Expense Category Salmon 2W
Drilling (Turnkey Portion) 57.63%
Sales Expenses (including Commissions
and Organizational Expenses)

14.0%

Due Diligence 1.0%
Completion, Testing and Equipping 27.37%
TOTAL 100%

14. The CIM also discloses that Texas E&P will be entitled to a one-time

“management fee.”  Though the fee is not quantified, it is defined as “an amount equal to the

excess, if any, of the Turnkey Drilling Price and/or the Turnkey Completion Price over the actual

cost of operations.”  Therefore, the management fee cannot be calculated—much less paid—until

the cost of operations is known.  Since the Salmon 2W well was never drilled, the cost of

operations remains unknown and Texas E&P is not entitled to a management fee on that well.

15. By April 2017, Plummer had raised a total of $6.1 million.  He spent

approximately $5 million of this money on allowable expenses—such as lease acquisitions,

SEC v. Plummer   Page 5 of 7
Complaint

utilities, legal fees, and permits.  However, he also misappropriated $399,011 as follows:3

Expense Amount
Country Club $16,682.15
Various Restaurants $17,887.13
Various Retail Stores  $45,651.25
College Tuition $9,028.50
Racquet Club $13,206.20
Income Taxes $144,462.58
Personal Transportation $14,706.96
Services/Memberships $2,667.99
Personal Travel $111,523.44
Other Miscellaneous $23,194.88
 $399,011.19

16. Therefore, as Plummer knew or was reckless or negligent in not knowing, the

statements in the CIM regarding the use of investor funds were false.  Plummer—who controlled

the Texas E&P bank accounts and credit cards—knew or should have known that hundreds of

thousands of dollars were being misappropriated.  At a minimum, he knowingly, recklessly, or

negligently omitted to disclose this widespread misappropriation to investors.

FIRST CLAIM

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

17.  Plaintiff SEC realleges and incorporates by reference paragraphs 1 through 16 of

this Complaint as if set forth verbatim.

 18.  Defendant directly or indirectly, by using any means or instrumentality of

interstate commerce, or of the mails, or of any facility of any national securities exchange, in

connection with the purchase or sale of any security:

3 Plummer also commingled investor funds from the Salmon 2W and East Texas 2H projects in
violation of the CIM.

SEC v. Plummer   Page 6 of 7
Complaint

(a) employed a device, scheme, or artifice to defraud;

(b) made an untrue statement of a material fact or omitted to state a material fact
 necessary in order to make the statements made, in the light of the circumstances
 under which they were made, not misleading; and

(c) engaged in an act, practice, or course of business which operates or would operate
as a fraud or deceit upon any person.

19.  Accordingly, the Defendant has violated and, unless enjoined, will again violate

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

§240.10b-5].

SECOND CLAIM

Violations of Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]

20. Plaintiff SEC realleges and incorporates by reference paragraphs 1 through 16 of

this Complaint as if set forth verbatim.

 21. Defendant, in the offer or sale of any security, by the use of any means or

instruments of transportation or communication in interstate commerce or by use of the mails,

directly or indirectly:

(a) employed a device, scheme, or artifice to defraud;

(b) obtained money or property by means of an untrue statement of a material fact
 or an omission of a material fact necessary in order to make the statements
 made, in light of the circumstances under which they were made, not misleading;
 and

(c) engaged in a transaction, practice, or course of business which operates or would
operate as a fraud or deceit upon the purchaser.

22. Accordingly, Defendant has violated and, unless enjoined, will again violate

Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].

SEC v. Plummer   Page 7 of 7
Complaint

REQUEST FOR RELIEF

 The SEC respectfully requests that this Court:

I.

Permanently enjoin Defendant from violating, directly or indirectly, Section 10(b) of the

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

17(a) of the Securities Act [15 U.S.C. §77q(a)].

II.

Order Defendant to disgorge an amount equal to the funds and benefits obtained illegally,

or to which Defendant otherwise has no legitimate claim, as a result of the violations alleged,

plus prejudgment interest on that amount.

III.

Order Defendant to pay a civil 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)] for the violations

alleged herein.

IV.

Order such other relief as this Court may deem just and proper.

June 26, 2019     Respectfully submitted,

     /s/ Chris Davis

CHRIS DAVIS
Plaintiff’s Lead Attorney
Texas Bar No. 24050483
United States Securities and Exchange Commission
Burnett Plaza, Suite 1900
801 Cherry Street, Unit 18
Fort Worth, Texas 76102
Telephone: (817) 900-2638
FAX: (817) 978-4927
E-mail: [email protected]

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   Securities and Exchange Commission      Mark Allan Plummer

Collin

15 U.S.C. §77q(a)(2), 15 U.S.C. § 78j(b), and 17 C.F.R. § 240.10b-5(b)

Securities offering fraud

June 26, 2019 /s Chris Davis

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 
________________________________________________ 
SECURITIES AND EXCHANGE COMMISSION, § 
        §    
 Plaintiff,      § 
        § 
vs.        §  
        § 
MARK ALLAN PLUMMER    § Civil Action No.: 3:19-cv-1538 
        §   
        § 

Defendant.      § 
________________________________________________§ 

 
COMPLAINT 

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

SUMMARY 
 

1. Defendant Mark Allan Plummer (“Plummer” or “Defendant”), through his 

company Texas E&P Partners, Inc. and its affiliated entities (“Texas E&P”),1 defrauded 

investors by misappropriating investor funds.  From February 2015 to April 2017, Texas E&P 

raised $6.1 million by selling interests in joint ventures formed to drill and operate two separate 

oil well projects.  However, instead of using all of these funds to drill and operate the oil well 

projects—as represented to investors when soliciting their investments—Plummer 

misappropriated large sums of money.  In total, Plummer misappropriated $399,011 for 

undisclosed personal and unauthorized business expenses—including for entertainment, travel, 

retail expenses, and his income taxes. 

2. In doing so, Plummer violated the antifraud provisions of the federal securities 
                                                           
1 Texas E&P formerly operated under the name Chestnut Exploration Partners, Inc. (“Chestnut 
Exploration”). 

                                                                                         
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SEC v. Plummer   Page 2 of 7  
Complaint  
 

laws.  Thus, in the interest of protecting the public from further illegal activity, the SEC brings 

this action seeking all available relief—including permanent injunctions, disgorgement of ill-

gotten gains plus prejudgment interest, and civil money penalties.     

JURISDICTION AND VENUE 

3. The Court has jurisdiction over this action under Sections 20(b), 20(d), and 22(a) 

of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77t(b), 77t(d) and 77v(a)]; and 

Sections 21(d), 21(e), and 27 of the Securities Exchange Act of 1934 (“Exchange Act”) [15 

U.S.C. §§ 78u(d), 78u(e), and 78aa].   

4. Each of the joint-venture interests offered and sold is an investment contract, and 

therefore a “security” as that term is defined under Securities Act Section 2(a)(1) [15 U.S.C. § 

77b(a)(1)] and Exchange Act Section 3(a)(10) [5 U.S.C. § 78c(a)(10)]. 

5. Defendant has, directly or indirectly, made use of the means or instrumentalities 

of interstate commerce in connection with the transactions, acts, practices, and courses of 

business alleged in the Complaint. 

6. Venue is proper because a substantial part of the transactions, acts, practices, and 

courses of conduct constituting violations of the federal securities laws occurred in the Northern 

District of Texas.   

PARTIES 
 

7. Plaintiff SEC is an agency of the United States government.  

8. Defendant Plummer is a natural person residing in Richardson, Texas.  He is the 

founder, owner, and President of Texas E&P.  In December 2016, a Financial Industry 

Regulatory Authority (“FINRA”) hearing panel found that Plummer and Texas E&P produced an 

altered document to the FINRA staff, and that Plummer provided misleading testimony 

                                                                                         
 Case 3:19-cv-01538-G   Document 1   Filed 06/26/19    Page 2 of 7   PageID 2

                                                                                         
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SEC v. Plummer   Page 3 of 7  
Complaint  
 

regarding the document.  The FINRA decision expelled Texas E&P from FINRA membership 

and barred Plummer from association with any FINRA member.  Plummer has a combined six 

judgments from past FINRA arbitrations initiated by investors.  Plummer is not registered with 

the SEC in any capacity and remains barred by FINRA.  

FACTS 

I. PLUMMER HAS A LENGTHY HISTORY PROMOTING OIL AND GAS INVESTMENTS. 
 

9. Plummer has been in the oil business for over thirty years.  He founded numerous 

entities related to his drilling projects—including oil and gas operating companies, funding 

companies, service companies, and holding corporations.   

10. Plummer has had many regulatory issues.  In 2012, the Texas State Securities 

Board issued an order against Chestnut Exploration for overcharging investors.2  FINRA has also 

conducted multiple investigations of Plummer and his entities over many years for misuse of 

investor funds and inadequate supervisory procedures, among other concerns.  This resulted in 

the expulsion and judgments in investor arbitrations discussed in Paragraph 8, above. 

11. In January 2016, during the FINRA investigation, Plummer renamed Chestnut 

Exploration to Texas E&P and continued fundraising for two projects under that name: East 

Texas 2H and Salmon 2W.  Fundraising for the East Texas 2H project was active from February 

to September 2015.  Salmon 2W fundraising was active from June 2015 through April 2017. 

II. PLUMMER DISSEMINATED FALSE AND MISLEADING OFFERING MATERIALS TO 
INVESTORS AND MISAPPROPRIATED INVESTOR FUNDS. 

 
12. During this time period, Plummer marketed the Texas E&P securities using false 

and misleading offering materials—including a Confidential Investor Memorandum (“CIM”).  

                                                           
2 In the Matter of the Dealer Registration of Chestnut Exploration Partners, Inc., Order No. 
IC12-CAF-06 (Jan. 10, 2012). 

                                                                                         
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SEC v. Plummer   Page 4 of 7  
Complaint  
 

He distributed the CIM to any investor interested in purchasing the Texas E&P securities.  In 

total, at least 100 investors from at least 18 different states were solicited and invested in the 

securities based on the representations in the CIM.  These investors included several from the 

state of Texas, including Granbury, Fort Worth, and Dallas in the Northern District. 

13. The CIM contained false and misleading statements and/or omissions regarding 

the use of investor funds.  For example, the Salmon 2W CIM states that the offering’s objectives 

are to: (1) acquire an interest in two oil and/or gas wells in Anderson County, Texas, and 

participate in operations thereon; (2) provide cash distributions from operations; and (3) provide 

tax benefits to investors.  The CIM details that the investor funds are to be used as follows: 

Expense Category Salmon 2W 
Drilling (Turnkey Portion) 57.63% 
Sales Expenses (including Commissions 
and Organizational Expenses) 

14.0% 

Due Diligence 1.0% 
Completion, Testing and Equipping 27.37% 
TOTAL 100% 

14. The CIM also discloses that Texas E&P will be entitled to a one-time 

“management fee.”  Though the fee is not quantified, it is defined as “an amount equal to the 

excess, if any, of the Turnkey Drilling Price and/or the Turnkey Completion Price over the actual 

cost of operations.”  Therefore, the management fee cannot be calculated—much less paid—until 

the cost of operations is known.  Since the Salmon 2W well was never drilled, the cost of 

operations remains unknown and Texas E&P is not entitled to a management fee on that well. 

15. By April 2017, Plummer had raised a total of $6.1 million.  He spent 

approximately $5 million of this money on allowable expenses—such as lease acquisitions, 

                                                                                         
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SEC v. Plummer   Page 5 of 7  
Complaint  
 

utilities, legal fees, and permits.  However, he also misappropriated $399,011 as follows:3 

Expense Amount 
Country Club $16,682.15 
Various Restaurants $17,887.13 
Various Retail Stores  $45,651.25 
College Tuition $9,028.50 
Racquet Club $13,206.20 
Income Taxes $144,462.58 
Personal Transportation $14,706.96 
Services/Memberships $2,667.99 
Personal Travel $111,523.44 
Other Miscellaneous $23,194.88 
 $399,011.19 

16. Therefore, as Plummer knew or was reckless or negligent in not knowing, the 

statements in the CIM regarding the use of investor funds were false.  Plummer—who controlled 

the Texas E&P bank accounts and credit cards—knew or should have known that hundreds of 

thousands of dollars were being misappropriated.  At a minimum, he knowingly, recklessly, or 

negligently omitted to disclose this widespread misappropriation to investors. 

FIRST CLAIM  
  

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

 
17.  Plaintiff SEC realleges and incorporates by reference paragraphs 1 through 16 of 

this Complaint as if set forth verbatim. 

 18.  Defendant directly or indirectly, by using any means or instrumentality of 

interstate commerce, or of the mails, or of any facility of any national securities exchange, in 

connection with the purchase or sale of any security: 
                                                           
3 Plummer also commingled investor funds from the Salmon 2W and East Texas 2H projects in 
violation of the CIM.   

                                                                                         
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SEC v. Plummer   Page 6 of 7  
Complaint  
 

(a) employed a device, scheme, or artifice to defraud; 

(b) made an untrue statement of a material fact or omitted to state a material fact 
 necessary in order to make the statements made, in the light of the circumstances 
 under which they were made, not misleading; and 

(c) engaged in an act, practice, or course of business which operates or would operate 
as a fraud or deceit upon any person. 

 
19.  Accordingly, the Defendant has violated and, unless enjoined, will again violate 

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

§240.10b-5]. 

SECOND CLAIM  
 

Violations of Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)] 
 

20. Plaintiff SEC realleges and incorporates by reference paragraphs 1 through 16 of 

this Complaint as if set forth verbatim. 

 21. Defendant, in the offer or sale of any security, by the use of any means or 

instruments of transportation or communication in interstate commerce or by use of the mails, 

directly or indirectly: 

(a) employed a device, scheme, or artifice to defraud; 

(b) obtained money or property by means of an untrue statement of a material fact 
 or an omission of a material fact necessary in order to make the statements 
 made, in light of the circumstances under which they were made, not misleading; 
 and 

(c) engaged in a transaction, practice, or course of business which operates or would 
operate as a fraud or deceit upon the purchaser. 

 
22. Accordingly, Defendant has violated and, unless enjoined, will again violate 

Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

                                                                                         
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SEC v. Plummer   Page 7 of 7  
Complaint  
 

REQUEST FOR RELIEF 

 The SEC respectfully requests that this Court: 

I. 

Permanently enjoin Defendant from violating, directly or indirectly, Section 10(b) of the 

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

17(a) of the Securities Act [15 U.S.C. §77q(a)]. 

II. 

Order Defendant to disgorge an amount equal to the funds and benefits obtained illegally, 

or to which Defendant otherwise has no legitimate claim, as a result of the violations alleged, 

plus prejudgment interest on that amount. 

III. 

Order Defendant to pay a civil 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)] for the violations 

alleged herein. 

IV. 

Order such other relief as this Court may deem just and proper. 

June 26, 2019     Respectfully submitted,  
      
 
     /s/ Chris Davis  

CHRIS DAVIS  
Plaintiff’s Lead Attorney  
Texas Bar No. 24050483  
United States Securities and Exchange Commission  
Burnett Plaza, Suite 1900  
801 Cherry Street, Unit 18  
Fort Worth, Texas 76102  
Telephone: (817) 900-2638  
FAX: (817) 978-4927  
E-mail: [email protected] 

                                                                                         
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JS 44   (Rev. 06/17)                                     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 
(For Diversity Cases Only)                            and One Box for Defendant) 

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 SOCIAL SECURITY 480 Consumer Credit 
 of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards 861 HIA (1395ff) 490 Cable/Sat TV 

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending   Act 862 Black Lung (923) 850 Securities/Commodities/ 
190 Other Contract  Product Liability 380 Other Personal 720 Labor/Management 863 DIWC/DIWW (405(g))   Exchange 
195 Contract Product Liability 360 Other Personal  Property Damage   Relations 864 SSID Title XVI 890 Other Statutory Actions 
196 Franchise  Injury 385 Property Damage 740 Railway Labor Act 865 RSI (405(g)) 891 Agricultural Acts 

362 Personal Injury -  Product Liability 751 Family and Medical 893 Environmental Matters 
 Medical Malpractice   Leave Act 895 Freedom of Information 

 REAL PROPERTY    CIVIL RIGHTS   PRISONER PETITIONS 790 Other Labor Litigation FEDERAL TAX SUITS   Act 
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 870 Taxes (U.S. Plaintiff 896 Arbitration 
220 Foreclosure 441 Voting 463 Alien Detainee  Income Security Act   or Defendant) 899 Administrative Procedure 
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRS—Third Party  Act/Review or Appeal of 
240 Torts to Land 443 Housing/  Sentence   26 USC 7609  Agency Decision 
245 Tort Product Liability  Accommodations 530 General 950 Constitutionality of 
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION  State Statutes 

 Employment Other: 462 Naturalization Application 
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 

 Other 550 Civil Rights        Actions 
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 

- TXND (Rev. 06/17)

   Securities and Exchange Commission      Mark Allan Plummer

Collin

15 U.S.C. §77q(a)(2), 15 U.S.C. § 78j(b), and 17 C.F.R. § 240.10b-5(b)

Securities offering fraud

June 26, 2019 /s Chris Davis

                                                                                         
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