Securities and Exchange Commission v. Woods et al
Plaintiff: Securities and Exchange Commission
Defendant: John J. Woods, Livingston Group Asset Management Company doing business as Southport Capital and Horizon Private Equity, III, LLC
Respondent: TD Ameritrade, Inc. and Relevance Capital III, L.P.
Receiver: A. Cotten Wright
Case Number: 1:2021cv03413
Filed: August 20, 2021
Court: US District Court for the Northern District of Georgia
Presiding Judge: Steven D Grimberg
Nature of Suit: Securities/Commodities
Cause of Action: 15 U.S.C. ยง 77
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on October 18, 2021. A more recent docket listing may be available from PACER.

Date Filed Document Text
October 18, 2021 Filing 78 MOTION Supplement to Motion for Authority to Employ Middleswarth Bowers & Co, LLP, as Accountants for the Receiver to Include Business Valuation Services #36 MOTION Authority to Employ Middlewarth, Bowers & Co., L.L.P. as Accountants for the Receiver by A. Cotten Wright. (Wright, Anna)
October 15, 2021 Filing 77 STATUS REPORT Receiver's First Report by A. Cotten Wright. (Wright, Anna)
October 13, 2021 Opinion or Order Filing 76 STIPULATED PROTECTIVE ORDER Signed by Judge Steven D. Grimberg on 10/13/2021. (jkb)
October 13, 2021 Opinion or Order Filing 75 ORDER granting #74 Motion for Entry of Protective Order. Signed by Judge Steven D. Grimberg on 10/13/2021. (jkb)
October 11, 2021 Filing 74 Joint MOTION for Entry of Stipulated Protective Order #73 Notice (Other) by IBERIABANK. (Attachments: #1 Exhibit A - Stipulated Protective Order, #2 Exhibit B - [Proposed] Order on Joint Motion for Entry of Stipulated Protective Order)(Rosenwasser, Steven) Modified on 10/13/2021 to edit event(jkb).
October 8, 2021 Filing 73 NOTICE by A. Cotten Wright of Service of Subpoena (Martinez, Michael)
October 1, 2021 Filing 72 MOTION for Order Approving Receiver's Liquidation Plan and Related Case Procedures #26 Order on Motion to Appoint Receiver by A. Cotten Wright. (Martinez, Michael) Modified on 10/4/2021 to edit text(jkb).
September 30, 2021 Filing 71 MOTION For Authority to Honor Notice of Redemption of Interests in Chattanooga Professional Baseball, LLC with Brief In Support by A. Cotten Wright. (Attachments: #1 Brief Memorandum of Law, #2 Exhibit Exhibit 1 Notice of Redemption and Letter, #3 Exhibit Exhibit 1A CPB Operating Agreement, #4 Exhibit Exhibit 1B Woods Resignation Letter, #5 Exhibit Exhibit 1C IBI Form, #6 Exhibit Exhibit 1D Media, #7 Exhibit Exhibit 1E MLB PDL Letter, #8 Exhibit Exhibit 2 First Bank Letter, #9 Exhibit Exhibit 3 Affidavit of Jason M. Freier)(Wright, Anna) Modified on 10/1/2021 to edit text (jkb).
September 30, 2021 RETURN of #69 APPLICATION for Admission of Justin Sveadas Pro Hac Vice. to attorney for correction re: party not listed on docket. (nmb)
September 27, 2021 Filing 70 NOTICE of Appearance by Michael L. Martinez on behalf of A. Cotten Wright (Martinez, Michael)
September 23, 2021 Filing 69 APPLICATION for Admission of Justin Sveadas Pro Hac Vice.by First Volunteer Bank. (Kuprovska, Kseniya) Documents for this entry are not available for viewing outside the courthouse.
September 23, 2021 Filing 68 NOTICE of Appearance by Kseniya Kuprovska on behalf of First Volunteer Bank (Kuprovska, Kseniya)
September 22, 2021 Clerk's Certificate of Mailing to Attorney A. Cotten Wright re #67 Order on Motion for Miscellaneous Relief. (jkb) Modified on 9/22/2021 to edit text (jkb).
September 21, 2021 Opinion or Order Filing 67 ORDER granting #63 Motion for authority to employ Stretto, Inc. as consultant for the receiver pursuant to services agreement. Signed by Judge Steven D. Grimberg on 09/21/2021. (jkb)
September 21, 2021 Filing 66 NOTICE Of Filing by John J. Woods of Disclosures Pursuant to September 1, 2021 Preliminary Injunction Order (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit)(Chaiken, David)
September 21, 2021 Filing 65 NOTICE of Appearance by Anna Cotten Wright on behalf of A. Cotten Wright (Wright, Anna)
September 21, 2021 RETURN of #64 APPLICATION for Admission of Justin Sveadas Pro Hac Vice (Application fee $ 150, receipt number AGANDC-11271103). to attorney for correction re: Local counsel's physical address. (cdg)
September 20, 2021 Filing 64 APPLICATION for Admission of Justin Sveadas Pro Hac Vice (Application fee $ 150, receipt number AGANDC-11271103).by First Volunteer Bank. (Kapperman, Cameron) Documents for this entry are not available for viewing outside the courthouse.
September 20, 2021 Filing 63 MOTION for Authority to Employ Stretto, Inc. as Consultant for the Receiver Pursuant to Services Agreement by A. Cotten Wright. (Patterson, William)
September 20, 2021 APPROVAL by Clerks Office re: #54 APPLICATION for Admission of A. Cotten Wright Pro Hac Vice. Attorney A. Cotten Wright added appearing on behalf of A. Cotten Wright (cdg) Modified on 9/22/2021 to edit text(jkb).
September 20, 2021 Opinion or Order ORDER granting #54 Application for Admission Pro Hac Vice of A. Cotten Wright. Approved by Judge Steven D. Grimberg on September 20, 2021. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(ash)
September 20, 2021 0APPROVAL by Clerks Office re: #62 APPLICATION for Admission of Ryan Loofbourrow Pro Hac Vice (Application fee $ 150, receipt number AGANDC-11259066).. Attorney Ryan Patrick Loofbourrow added appearing on behalf of Relevance Capital III, L.P. (nmb)
September 20, 2021 Opinion or Order ORDER granting #62 Application for Admission Pro Hac Vice of Ryan Loofbourrow. Approved by Judge Steven D. Grimberg on September 20, 2021. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(ash)
September 20, 2021 Opinion or Order ORDER granting #55 Application for Admission Pro Hac Vice of Michael L. Martinez. Approved by Judge Steven D. Grimberg on September 20, 2021. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(ash)
September 17, 2021 APPROVAL by Clerks Office re: #55 APPLICATION for Admission of Michael L. Martinez Pro Hac Vice. Attorney Michael L. Martinez added appearing on behalf of A. Cotten Wright (cdg)
September 15, 2021 Filing 62 APPLICATION for Admission of Ryan Loofbourrow Pro Hac Vice (Application fee $ 150, receipt number AGANDC-11259066).by Relevance Capital III, L.P.. (Swindle, Andrew) Documents for this entry are not available for viewing outside the courthouse.
September 15, 2021 Filing 61 NOTICE of Appearance by Andrew M. Swindle on behalf of Relevance Capital III, L.P. (Swindle, Andrew)
September 15, 2021 Filing 60 NOTICE by Relevance Capital III, L.P. re #25 Preliminary Injunction Non-Party Relevance Capital III, L.P.'s Certified Statement of Horizon Private Equity III LP's Assets (Swindle, Andrew)
September 15, 2021 Filing 59 NOTICE by Securities and Exchange Commission of withdrawal of counsel by consent (Mayes, Joshua)
September 14, 2021 Filing 58 WAIVER OF SERVICE Returned Executed by Securities and Exchange Commission. Horizon Private Equity, III, LLC waiver mailed on 9/14/2021, answer due 11/15/2021. (Roback, Harry)
September 14, 2021 Filing 57 WAIVER OF SERVICE Returned Executed by Securities and Exchange Commission. Livingston Group Asset Management Company waiver mailed on 9/2/2021, answer due 11/1/2021. (Roback, Harry)
September 14, 2021 Filing 56 WAIVER OF SERVICE Returned Executed by Securities and Exchange Commission. John J. Woods waiver mailed on 9/3/2021, answer due 11/2/2021. (Roback, Harry)
September 13, 2021 Filing 55 APPLICATION for Admission of Michael L. Martinez Pro Hac Vice.by A. Cotten Wright. (Patterson, William) Documents for this entry are not available for viewing outside the courthouse.
September 13, 2021 Filing 54 APPLICATION for Admission of A. Cotten Wright Pro Hac Vice.by A. Cotten Wright. (Patterson, William) Documents for this entry are not available for viewing outside the courthouse.
September 10, 2021 Opinion or Order Filing 53 ORDER granting #47 Motion to Amend. Signed by Judge Steven D. Grimberg on 09/10/2021. (jkb)
September 10, 2021 Opinion or Order Filing 52 ORDER granting #44 Motion for Relief from Order/Judgment. Signed by Judge Steven D. Grimberg on 09/10/2021. (jkb)
September 10, 2021 Opinion or Order Filing 51 ORDER granting #46 Motion to Amend. The Order Imposing Preliminary Injuction, order Freezing assets and for an Accounting, Order Prohibiting Destruction of Documents, Order Expediting Discovery, and Order Requiring Repatriation of Assets is amended to correct all references to Livingston Asset Management Company d/b/a Southport Capitalto read Livingston Group Asset Management Company d/b/a Southport Capital. Signed by Judge Steven D. Grimberg on 09/10/2021. (jkb)
September 10, 2021 Filing 50 NOTICE of Appearance by Cameron Kapperman on behalf of First Volunteer Bank (Kapperman, Cameron)
September 10, 2021 Opinion or Order ORDER granting #34 Motion to Employ Ragsdale, Beals, Seigler, Patterson & Gray, LLP as Local Counsel to the Receiver. Ordered by Judge Steven D. Grimberg on September 10, 2021. (ash)
September 10, 2021 Opinion or Order ORDER granting #35 Motion for Authority to Employ Grier Wright Martinez, PA as General Counsel to the Receiver. Ordered by Judge Steven D. Grimberg on September 10, 2021. (ash)
September 10, 2021 Opinion or Order ORDER granting #36 Motion for Authority to Employ Middlewarth, Bowers & Co., L.L.P. as Accountants for the Receiver. Ordered by Judge Steven D. Grimberg on September 10, 2021. (ash)
September 10, 2021 RETURN of #32 APPLICATION for Admission of Michael L. Martinez Pro Hac Vice (Application fee $ 150, receipt number AGANDC-11243164). to attorney for correction re: Incorrect Form. (nmb)
September 10, 2021 RETURN of #31 APPLICATION for Admission of A. Cotten Wright Pro Hac Vice (Application fee $ 150, receipt number AGANDC-11243137). to attorney for correction re: Incorrect Form. (nmb)
September 9, 2021 Filing 49 TRANSCRIPT of Proceedings held on 8/24/21 (TRO/Other Emergency Relief), before Judge Steven D. Grimberg. Court Reporter/Transcriber Alicia B. Bagley. A full directory of court reporters and their contact information can be found at www.gand.uscourts.gov/directory-court-reporters. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/30/2021. Redacted Transcript Deadline set for 10/12/2021. Release of Transcript Restriction set for 12/8/2021. (Attachments: #1 Notice of Filing Transcript) (pjm) (Additional attachment(s) added on 10/5/2021: #2 Verification of Financial Arrangements) (kac).
September 9, 2021 Filing 48 CERTIFICATE OF SERVICE re #25 Preliminary Injunction, #26 Order on Motion to Appoint Receiver filed by A. Cotten Wright (Patterson, William) Modified on 9/22/2021 to edit text(jkb).
September 9, 2021 Filing 47 MOTION to Amend #26 Order on Motion to Appoint Receiver by A. Cotten Wright. (Attachments: #1 proposed Order)(Patterson, William) Modified on 9/22/2021 to edit text (jkb).
September 9, 2021 Filing 46 MOTION to Amend #25 Preliminary Injunction by A. Cotten Wright. (Attachments: #1 proposed order)(Patterson, William) Modified on 9/22/2021 to edit text (jkb).
September 9, 2021 Filing 45 NOTICE Of Filing by TD Ameritrade, Inc. re #25 Preliminary Injunction TD Ameritrade, Inc.'s Statement of Accounts (Coleman, Keisha)
September 9, 2021 Filing 44 Consent MOTION for Relief from #25 Preliminary Injunction to Permit Vehicle Sale by John J. Woods. (Attachments: #1 Text of Proposed Order)(Chaiken, David)
September 9, 2021 Filing 43 NOTICE of Appearance by William Russell Patterson, Jr on behalf of A. Cotten Wright (Patterson, William) Modified on 9/22/2021 to edit text (jkb).
September 8, 2021 Filing 42 NOTICE of Appearance by Steven Rosenwasser on behalf of IBERIABANK (Rosenwasser, Steven)
September 8, 2021 Filing 41 PROPOSED ORDER Order for Authority to Employ Middleswarth, Bowers & Co. L.L.P. as Accountants for the Receiver re: #36 MOTION Authority to Employ Middlewarth, Bowers & Co., L.L.P. as Accountants for the Receiver . (Patterson, William)
September 8, 2021 Filing 40 PROPOSED ORDER Order for Authority to Employ Grier Wright Martinez as General Counsel to the Receiver re: #35 MOTION for Authority to Employ Grier Wright Martinez, PA as General Counsel to the Receiver . (Patterson, William)
September 8, 2021 Filing 39 PROPOSED ORDER Order for Authority to Employ Ragsdale, Beals, Seigler, Patterson & Gray, LLP as Local Counsel to the Receiver re: #34 MOTION Motion to Employ Ragsdale, Beals, Seigler, Patterson & Gray, LLP as Local Counsel to the Receiver . (Patterson, William)
September 8, 2021 Filing 38 NOTICE by A. Cotten Wright re #25 Preliminary Injunction, #26 Order on Motion to Appoint Receiver Certificate of Service of Orders (Patterson, William) Modified on 9/22/2021 to edit text (jkb).
September 8, 2021 Filing 37 CERTIFICATE of Compliance re #34 MOTION Motion to Employ Ragsdale, Beals, Seigler, Patterson & Gray, LLP as Local Counsel to the Receiver (Patterson, William)
September 8, 2021 Filing 36 MOTION Authority to Employ Middlewarth, Bowers & Co., L.L.P. as Accountants for the Receiver by A. Cotten Wright. (Patterson, William) Modified on 9/22/2021 (jkb).
September 8, 2021 Filing 35 MOTION for Authority to Employ Grier Wright Martinez, PA as General Counsel to the Receiver by A. Cotten Wright. (Patterson, William) Modified on 9/22/2021 to edit text(jkb).
September 8, 2021 Filing 34 MOTION Motion to Employ Ragsdale, Beals, Seigler, Patterson & Gray, LLP as Local Counsel to the Receiver by A. Cotten Wright. (Patterson, William) Modified on 9/22/2021 to edit text(jkb).
September 8, 2021 Filing 33 NOTICE Of Filing Certification setting forth balance in any account in the name of Defendants Woods or Horizon by IBERIABANK re #25 Preliminary Injunction (Rosenwasser, Steven)
September 8, 2021 Filing 32 APPLICATION for Admission of Michael L. Martinez Pro Hac Vice (Application fee $ 150, receipt number AGANDC-11243164).by A. Cotten Wright. (Attachments: #1 Certificate of Compliance)(Patterson, William) Documents for this entry are not available for viewing outside the courthouse. Modified on 9/22/2021 to edit text(jkb).
September 8, 2021 Filing 31 APPLICATION for Admission of A. Cotten Wright Pro Hac Vice (Application fee $ 150, receipt number AGANDC-11243137).by A. Cotten Wright. (Attachments: #1 Certificate of Compliance)(Patterson, William) Documents for this entry are not available for viewing outside the courthouse. Modified on 9/22/2021 to edit text(jkb).
September 2, 2021 Filing 30 CERTIFICATE of Compliance (Kline, Gerald)
September 2, 2021 Filing 29 CERTIFICATE of Compliance (Chaiken, David)
September 2, 2021 Filing 28 CERTIFICATE of Compliance of Stephen D. Councill (Councill, Stephen)
September 1, 2021 Filing 27 NOTICE Of Filing Proposed asset freeze carve-out language re #25 Preliminary Injunction (jkb)
September 1, 2021 Opinion or Order Filing 26 ORDER granting #2 Motion to Appoint Receiver. A. Cotten Wright appointed as receiver for the estate of the Receivership Defendant. Signed by Judge Steven D. Grimberg on 09/01/2021. (jkb) Modified on 9/22/2021 to edit text (jkb).
September 1, 2021 Opinion or Order Filing 25 PRELIMINARY INJUNCTION, freezing assets and for an accounting, prohibiting destruction of documents, expediting discovery, and requiring repatriation of assets. See order for specific details. Signed by Judge Steven D. Grimberg on 09/01/2021. (jkb)
September 1, 2021 Filing 24 CERTIFICATE of Compliance of M. Graham Loomis (Loomis, Madison)
September 1, 2021 Filing 23 CERTIFICATE of Compliance of Harry Roback (Roback, Harry)
August 31, 2021 Filing 22 NOTICE by Securities and Exchange Commission of Recommendation of Receiver (Mayes, Joshua)
August 27, 2021 Opinion or Order Filing 21 ORDER granting #20 Motion for Extension of Time. The deadline for the submission to the Court of a proposed order respecting the appointment of a receiver and a receivership over Horizon is extended to the close of business on Tuesday, August 31, 2021. The Courts oral order of August 24, 2021 respecting the restraint of assets shall remain in effect during the interim. Signed by Judge Steven D. Grimberg on 08/27/2021. (jkb) Modified on 8/30/2021 to edit text(jkb).
August 27, 2021 Entered in error. Set Deadlines/Hearings: Discovery ends on 8/30/2021. (jkb) Modified on 8/30/2021 to edit text (jkb).
August 26, 2021 Filing 20 Unopposed MOTION for Extension of Time to Submit Proposed Order re: #17 Order on Motion for TRO,, Motion Hearing, by Horizon Private Equity, III, LLC, John J. Woods. (Attachments: #1 Text of Proposed Order)(Chaiken, David)
August 26, 2021 Opinion or Order Filing 19 ORDER granting #18 Motion for Leave to File Matters Under Seal. Exhibit F to the Declaration of John J. Woods [15-6] ishereby sealed. Signed by Judge Steven D. Grimberg on 08/25/2021. (jkb)
August 25, 2021 Filing 18 Amended MOTION for Leave to File Matters Under Seal re: #15 Notice of Filing, #16 MOTION for Leave to File Matters Under Seal re: #15 Notice of Filing, with Brief In Support by John J. Woods. (Attachments: #1 Brief Memorandum in Support of Motion to File Under Seal, #2 Text of Proposed Order Proposed Order)(Councill, Stephen)
August 24, 2021 Filing 17 Minute Entry for proceedings held before Judge Steven D. Grimberg: granting in part and denying in part #2 Motion for TRO; Motion Hearing held on 8/24/2021 re #2 MOTION for Temporary Restraining Order filed by Securities and Exchange Commission. (Court Reporter Alicia Bagley)(jkb)
August 24, 2021 Filing 16 MOTION for Leave to File Matters Under Seal re: #15 Notice of Filing, with Brief In Support by John J. Woods. (Attachments: #1 Brief Memorandum in Support of Motion to File Under Seal, #2 Text of Proposed Order Proposed Order)(Councill, Stephen)
August 24, 2021 Filing 15 SEALED NOTICE Of Filing Declaration of John J. Woods by John J. Woods (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I)(Councill, Stephen) Modified on 8/26/2021 To remove provisionally (jkb).
August 24, 2021 Filing 14 NOTICE Of Filing Declaration of John J. Woods by John J. Woods (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I)(Councill, Stephen)
August 24, 2021 Filing 13 AFFIDAVIT of Joshua Mayes by Securities and Exchange Commission. (Attachments: #1 Exhibit 1. Jennifer Greene Email to TD Ameritrade, #2 Exhibit 2. Julie Jones Email to Horizon Investor, #3 Exhibit 3. Email re Julie and Horizon Annuity Contract)(Mayes, Joshua)
August 24, 2021 Filing 12 NOTICE of Appearance by Stephen D. Councill on behalf of John J. Woods (Councill, Stephen)
August 24, 2021 Filing 11 AFFIDAVIT Jennifer Greene by Livingston Group Asset Management Company. (Attachments: #1 Affidavit Julie Jones Affidavit, #2 Affidavit Clay Parker Affidavit)(Kline, Gerald)
August 24, 2021 Filing 10 NOTICE of Appearance by Gerald B. Kline on behalf of Livingston Group Asset Management Company (Kline, Gerald)
August 24, 2021 Filing 9 NOTICE of Appearance by David M. Chaiken on behalf of Horizon Private Equity, III, LLC (Chaiken, David)
August 24, 2021 Filing 8 NOTICE of Appearance by David M. Chaiken on behalf of John J. Woods (Chaiken, David)
August 23, 2021 Opinion or Order Filing 7 STANDING ORDER Regarding Civil Litigation. Ordered by Judge Steven D. Grimberg on August 23, 2021. (ash)
August 20, 2021 Opinion or Order Filing 6 ORDER Setting Hearing on Motion #2 MOTION for Temporary Restraining Order : Motion Hearing set for 8/24/2021 at 02:00 PM before Judge Steven D. Grimberg. The hearing will be conducted via remote audio and video means. The dial in instructions are as follows: https://ganduscourts.zoomgov.com/j/1613474434; Meeting ID: 161 347 4434; Passcode: 485817. Signed by Judge Steven D. Grimberg on 08/20/2021. (jkb)
August 20, 2021 Filing 5 Electronic Summons Issued as to Livingston Group Asset Management Company. (dmb)
August 20, 2021 Filing 4 Electronic Summons Issued as to John J. Woods. (dmb)
August 20, 2021 Filing 3 Electronic Summons Issued as to Horizon Private Equity, III, LLC. (dmb)
August 20, 2021 Filing 2 MOTION for Temporary Restraining Order IMMEDICATE HEARING REQUESTED with Brief In Support by Securities and Exchange Commission. (Attachments: #1 Brief, #2 Rule 65, #3 Proposed Order for TRO, #4 Order Appointing Receiver, #5 Affidavit of Tiffany Kunkle, #6 Affidavit of Kathryn Campbell, #7 Exhibit A to Campbell Dec, #8 Exhibit B to Campbell Dec, #9 Exhibit C to Campbell Dec, #10 Exhibit D to Campbell Dec, #11 Exhibit E to Campbell Dec, #12 Exhibit F to Campbell Dec, #13 Exhibit G to Campbell Dec, #14 Exhibit H to Campbell Dec, #15 Affidavit of Bruce Goldstein (former Southport employee), #16 Exhibit A to Goldstein Dec (1 of 3), #17 Exhibit A to Goldstein Dec (2 of 3), #18 Exhibit A to Goldstein Dec (3 of 3), #19 Exhibit B to Goldstein Dec, #20 Exhibit C to Goldstein Dec, #21 Exhibit D to Goldstein Dec, #22 Exhibit E to Goldstein Dec, #23 Exhibit F to Goldstein Dec, #24 Exhibit G to Goldstein Dec, #25 Exhibit H to Goldstein Dec, #26 Exhibit I to Goldstein Dec, #27 Exhibit J to Goldstein Dec, #28 Affidavit of Melissa Mitchell (SEC Investigator), #29 Exhibit 1 to Mitchell Dec, #30 Exhibit 2 to Mitchell Dec, #31 Exhibit 3 to Mitchell Dec, #32 Exhibit 4 to Mitchell Dec, #33 Exhibit 5 to Mitchell Dec, #34 Exhibit 6 to Mitchell Dec, #35 Affidavit of Kenneth Himmler (former Southport consultant), #36 Exhibit A to Himmler Dec, #37 Exhibit B to Himmler Dec, #38 Affidavit of Kee Han (SEC Examiner), #39 Exhibit Exhibits to Han Dec, #40 Affidavit of Jan Gorman (investor), #41 Affidavit of Eugene Lyle (investor), #42 Affidavit of Sharon Goad (investor), #43 Affidavit of James Peele (investor), #44 Affidavit of Steven Worley (investor), #45 Affidavit of David Goad (investor), #46 Affidavit of Jerry Monnett)(dmb). Added MOTION to Appoint Receiver on 9/1/2021 (adg).
August 20, 2021 Filing 1 COMPLAINT with Jury Demand filed by Securities and Exchange Commission. (Attachments: #1 Civil Cover Sheet)(dmb) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form.
August 20, 2021 Submission of #2 MOTION for Temporary Restraining Order to District Judge Steven D. Grimberg. (dmb)

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Plaintiff: Securities and Exchange Commission
Represented By: Harry B. Roback
Represented By: Joshua A. Mayes
Represented By: Madison Graham Loomis
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Defendant: John J. Woods
Represented By: David M. Chaiken
Represented By: Stephen D. Councill
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Defendant: Livingston Group Asset Management Company doing business as Southport Capital
Represented By: Gerald B. Kline
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Defendant: Horizon Private Equity, III, LLC
Represented By: David M. Chaiken
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Respondent: TD Ameritrade, Inc.
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Respondent: Relevance Capital III, L.P.
Represented By: Ryan Patrick Loofbourrow
Represented By: Andrew M. Swindle
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Receiver: A. Cotten Wright
Represented By: Anna Cotten Wright
Represented By: Michael L. Martinez
Represented By: William Russell Patterson, Jr.
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