~-

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

U.S. COMMODITY FUTURES TRADING 

COMMISSION, 

Plaintiff, 

v. 

AMARANTH ADVISORS, L.L.C., AMARANTH 

ADVISORS (CALGARY) ULC and BRIAN HUNTER, 

Defendants. 

JUDGE CHIN 

'07 CIV 6682 

Case No. -------

ECF Case 

By and for its complaint; the U.S. Commodity Futures Trading Commission ("CFTC") 

alleges as follows: 

I. SUMMARY 

I. As is more fully alleged below, Defendants Amaranth Advisors L.L.C. and 

Amaranth Advisors (Calgary) ULC (collectively "Amaranth"), by and through their employees 

and agents, including Defendant Brian Hunter ("Hunter"), engaged in a scheme of price 

manipulation that violated the Commodity Exchange Act, as amended (the "Act"), 7 U.S.C. §§ 1, 

et seq. (2002). 

2. Defendants intentionally and unlawfully attempted to manipulate the price of 

natural gas futures contracts on the New York Mercantile Exchange ("NYMEX") in 2006. 

3. As more fully described below, Defendants violated Sections 6(c), 6(d) and 

9(a)(2) of the Act, 7 U.S.C. §§ 9, 13b, and 13(a)(2). 
4. Furthennore, on or about August 15, 2006, Amaranth Advisors L.L.C., in a 

communication with NYMEX, willfully falsified, concealed, or covered up by trick, scheme or 

artifice a material fact or made false, fictitious, or fraudulent statements or representations in 

violation of Section 9(a)(4) of the Act, 7 U.S.C. § 13(a)(4). 

5. Accordingly, pursuant to Section 6c of the Act, 7 U.S.C. § 13a-l, Plaintiff brings 

this action to enjoin such acts and practices, and compel compliance with the Act. In addition, 

Plaintiff seeks civil monetary penalties and such other equitable and ancillary relief as the Court 

deems necessary or appropriate under the circumstances. 

6. Unless restrained and enjoined by this Court, there is a reasonable likelihood that 

Defendants will continue to engage in the acts and practices alleged in this Complaint or similar 

acts and practices, as is more fully described below. 

II. JURISDICTION AND VENUE 

7. This Court has jurisdiction pursuant to Section 6c of the Act, 7 U.S.C. § 13a-l, 

which authorizes the CFTC to seek injunctive relief against any person, or to enforce compliance 

with the Act, whenever it shall appear to the CFTC that such person has engaged, is engaging, or 

is about to engage in any act or practice constituting a violation of any provision of the Act or 

any rule, regulation or order thereunder. 

8. Venue lies properly with this Court pursuant to Section 6c(e) of the Act, 7 U.S.C. 

§ 13a-l (e), in that Defendants transacted business within this District, and the acts and practices 

in violation of the Act occurred within this District. 

2 
III. THE PARTIES 

9. Plaintiff U.S. Commodity Futures Trading Commission is an independent federal 

regulatory agency that is charged with the responsibility for administering and enforcing the 

provisions of the Act, 7 U.S.C. §§ 1, et seq., and the regulations promulgated thereunder, 17 

C.F.R. §§ 1, et seq. A purpose of the Act is "to deter and prevent price manipulation or any 

other disruptions to market integrity." 7 U.S.C. § 5. 

10. Defendant Amaranth Advisors L.L.C. is a Delaware company, which was founded 

in September 2000, with its principal place of business in Greenwich, Connecticut. Defendant 

Amaranth Advisors L.L.C. is the investment advisor and manager of the Amaranth group of 

investment funds including Amaranth LLC, a multi-strategy private investment fund. As of on 

or about December 2005, Amaranth LLC and its subsidiaries had net assets of over $6 billion, 

and natural gas futures positions valued at over $5 billion. 

11. Defendant Amaranth Advisors (Calgary) ULC is a Nova Scotia unlimited liability 

company with its principal place of business in Calgary, Alberta Province, Canada. Amaranth 

Advisors (Calgary) ULC has never been registered with the Commission. 

12. Defendant Amaranth Advisors (Calgary) ULC is a 99%-owned indirect subsidiary 

of Amaranth Advisors L.L.C. 

13. Amaranth provided investment, management and advisory services on behalf of 

Amaranth LLC with regard to energy-related commodity instruments and related investments. 

14. Defendant Brian Hunter is an individual who resides in Calgary, Alberta 

Province, Canada. From or about October 2005 until or about September 2006 Defendant 

Hunter was president of Defendant Amaranth Advisors (Calgary) ULC. 

3 
IV. FACTS 

15. Amaranth traded both exchange-traded and over-the-counter ("OTC") derivative 

contracts including futures, options, and swaps. 

16. A futures contract is an agreement to purchase or sell a commodity for delivery in 

the future at a price that is determined at initiation of the contract, that obligates each party to the 

contract to fulfill the contract at the specified price, that is used to assume or shift price risk, and 

that may be satisfied by delivery or offset. 

17. The natural gas futures contract traded on the NYMEX is for a volume of 10,000 

million British thermal units (MMBtu) of natural gas to be delivered at the Henry Hub in 

Louisiana during the month specified in the contract. 

18. The NYMEX is a designated contract market under Section 5{b) of the Act and 

Commission Regulations 38.3(a)(l )(ii) and (iii). The IntercontinentaiExchange ("ICE") is an 

exempt commercial market under Section 2(h)(3) through (5) of the Act and Commission 

Regulation 36.3. 

19. Amaranth was not capable of accepting delivery of or of delivering physical 

natural gas and thus at the end of trading of the spot month NYMEX natural gas futures contract 

needed to have a flat position in that contract. 

20. In or around October 2005, Defendant Hunter, who oversaw most of the natural 

gas trading at Amaranth, transferred from the Greenwich, Connecticut office to Calgary and 

became head of energy trading in the Calgary office. Certain natural gas traders under 

Defendant Hunter's supervision continued to work at the Greenwich office, and risk 

management and compliance personnel in charge of overseeing the trading of the Calgary office 

continued to work in Greenwich. 

4 
21. Defendant Hunter's compensation in 2005 was over $100 million. 

22. At all times relevant to this complaint, Defendant Hunter was Amaranth's head 

natural gas trader. 

23. In 2006, Defendants engaged in. a scheme to attempt to manipulate natural gas 

futures prices on the NYMEX, including on February 24 and April 26, 2006. Defendants' 

manipulative scheme included, in part, the purchase of a substantial amount ofNYMEX natural 

gas futures contracts in advance of the closing range that Defendants planned to sell during the 

last half hour on the final day of trading such contracts (the "Manipulative Scheme"). 

24. Defendants effectuated the Manipulative Scheme through a variety of acts and 

practices that were intended to manipulate the prices ofNYMEX natural gas futures contracts. 

25. In accordance with NYMEX Rules, the settlement price of the NYMEX natural 

gas futures contracts is determined by the volume weighted average of trades executed from 

2:00-2:30 p.m. ("closing range") on the last day of trading of such contracts ("expiration day"). 

26. Defendants intended to create artificial natural gas futures prices by placing large 

sell orders in the closing range on expiration day. 

27. A look-alike swap is an OTC swap that is cash settled based upon the settlement 

price of a similar exchange-traded futures contract on a specified trading day. 

28. On the expiration days in issue, Amaranth held, as compared to its NYMEX 

futures position, a substantially larger short natural gas financially-settled swaps position, 

primarily on the lntercontinentaiExchange ("ICE"). 

29. The ICE natural gas swap is a look-alike swap that is financially settled, meaning 

that upon expiration of the swap the holder will either pay or be paid the difference in the price 

5 
paid for the swap and the final settlement price of the swap. In calculating the settlement price 

for its natural gas swaps, ICE uses the NYMEX settlement price. 

30. Defendants sought to lower the prices of the NYMEX natural gas futures contract 

to benefit Amaranth's larger short natural gas swaps positions on ICE and elsewhere. 

A. Defendants' Attempt to Manipulate Futures Prices on February 24, 2006 

31. On or about February 24, 2006, the expiration day of the March 2006 NYMEX 

natural gas futures contract, Defendants attempted to manipulate natural gas futures contract 

prices by obtaining a large long futures contract position in order to sell those contracts in the 

closing range. 

32. On February 23, 2006, Defendant Hunter told Amaranth natural gas trader 

Matthew Donohoe ("Donohoe") "make sure we have lots of futures to sell MoC [market on 

close] tomorrow". See instant message attached as Exhibit A document number 

AALLC REG0684056. 

33. On or about the start of futures trading on February 24, 2006, Amaranth had a 

short position of over I, 700 March 2006 natural gas futures contracts. 

34. At that time Amaranth operations personnel in Greenwich informed Defendant 

Hunter and his natural gas traders that they were "short- 1729 Nat Gas Mar 06" futures contracts 

and to "[p]Iease make sure we are flat by the end of the day today." See e-mail attached as 

Exhibit A document number AALLC REG0672597. 

35. As part of the Manipulative Scheme, on February 24, 2006 before the start of the 

closing range, Defendants reversed their natural gas futures positions from being short to being 

long over 3000 March 2006 contracts. 

6 
36. On February 24, 2006 prior to the closing range, Defendant Hunter stated to 

another Amaranth natural gas trader that he would ''just need H [March natural gas futures 

contract] to get smashed on settle then day is done." See instant message attached as Exhibit A 

document number AALLC R£00684186. 

3 7. Defendant Hunter has testified that the term "smashed" in the context of futures 

prices means "if something fell really, really quickly, if the prices fell really, really quickly, you 

say those prices got smashed." 

38. Less than half an hour before the closing range on February 24, 2006, Defendant 

Hunter disclosed part of the Manipulative Scheme to a natural gas trader at another firm: 

1:31 :25 PM EST Brian Hunter: We have 4000 to sell MoC 

I :3 I :28 PM EST Brian Hunter: shhhh 

1 :3 I :36 PM EST gloverb: come on 

I :31 :39 PM EST Brian Hunter: y 

I :31 :43 PM EST gloverb: unless you are huge bearish 

I :31 :49 PM EST gloverb: position 

1 :3I :54 PM EST gloverb: why the f would yo do that 

1:32:16 PM EST Brian Hunter: all from options yestrday 

I :32:25 PM EST Brian Hunter: so we 11 see what the floor has 

I :32:33 PM EST Brian Hunter: bit of an expiriment [sic] mainly 

I :32:43 PM EST gloverb: what the f 

I :32:46 PM EST gloverb: that is huge 

I :35:34 PM EST Brian Hunter: I think John [Arnold] and Sempra [Energy] are sellers too 

See instant message attached as Exhibit A document number AALLC_R£00684227. 

39. A few minutes after the start of the closing range on February 24, 2006, the same 

natural gas trader asked Defendant Hunter "arent you done" selling your futures. Defendant 

Hunter, knowing that the Manipulative Scheme was not yet concluded, replied "no ... have alot 

more to sell. .. waiting until 2:20." See instant message attached as Exhibit A document number 

AALLC _REG0684264. 

7 
40. Defendant Hunter and Donohoe congratulated themselves, at about half way 

through the closing range on February 24, 2006, when Defendant Hunter stated to Donohoe 

"today came together quite nicely" and Donohoe later replied: 

2:30:21 PM EST Matthew Donohoe: h [March contract] will setlle lower 

2:30:47 PM EST Matthew Donohoe: and h/j wider 

2:31:30 PM EST Matthew Donohoe: nice 

2:31 :37 PM EST Brian Hunter: I am flexing here 

2:31:40 PM EST Matthew Donohoe: looking preety [sic] bang on 

2:31 :50 PM EST Matthew Donohoe: we already mimiced 

2:31 :53 PM EST Matthew Donohoe: lol 

2:31:58 PM EST Matthew Donohoe: llliiiiiitmnnn 

2:32:04 PM EST Brian Hunter: hahahahaha 

2:32:23 PM EST Matthew Donohoe: 2nd best...sept/oct last year still the best 

2:32:27 PM EST Matthew Donohoe: oh yeag [sic] 

See instant message attached as Exhibit A document number AALLC _ REG0704931. 

41. On February 24, 2006, during their selling spree on the closing range, Defendants 

placed orders to sell over 3,000 March NYMEX natural gas futures contracts in an attempt to 

manipulate the contract price. At that time, Amaranth had a short swaps position of at least 

12,000 contracts (futures equivalents), that would benefit from a lower settlement price of the 

March natural gas futures contract. 

42. On or about March 10, 2006 Amaranth Advisors (Calgary) ULC issued a 

compliance manual that prohibited manipulative and fraudulent trading practices, including 

engaging in "trading or apparent trading activity for the purpose of artificially causing the price 

of a commodity to move up or down, and then take advantage of such price movement by buying 

or selling at such 'artificial' price level." 

43. The compliance manual also prohibited engaging in "'marking the close' at or 

near the close of trading for the primary purpose of attempting to change the closing price to 

protect or alter the value of an existing position or to avoid a margin call, although this 

8 
prohibition is not intended to preclude trades at or near the close of trading that have a legitimate 

business purpose, manage business risk or that otherwise have economic substance." 

B. Defendants' Attempt to Manipulate Futures Prices in April26, 2006 

44. On or about April26, 2006, the expiration day of the May 2006 NYMEX natural 

gas futures contract, Defendants attempted to manipulate natural gas futures contract prices by 

obtaining a large long futures contract position in order to sell a large number of offsetting 

contracts using three large orders that were placed near the end of the closing range. 

45. On or about April21, 2006, Amaranth reversed its futures position by acquiring 

futures contracts, such that for the first time in the month they were long May NYMEX natural 

gas futures contracts. 

46. From then, until April 26, 2006 the Defendants continued to build their long 

futures position, such that by the time of the closing range they were long in excess of3,000 May 

2006 natural gas futures contracts. 

47. Going into the closing range on April26, 2006, Amaranth also had a short May 

swap position of over 19,000 contracts (futures equivalents). 

48. Defendant Hunter was concerned that Centaurus Advisors LLC, another hedge 

fund, was going to be a large buyer of natural gas futures in the closing range and that this would 

affect the settlement price of the May 2006 NYMEX natural gas futures contract, which in turn 

would adversely affect Amaranth's short swaps positions. 

49. Beginning at 12:45 pm on April26, 2006, Hunter had an instant message 

conversation with David Chasman ("Chasman"), the energy risk manager at Amaranth, where he 

discussed what he thought Arnold planned to do and why: 

12:48:48 pm Brian Hunter: FYI Arnold is getting scary short into the [Energy 

Information Agency gas storage] number tomorrow 

9 
12:50:26 pm David Chasman: what u think arnold has? 

12:50:28 pm Brian Hunter: we are rolling size into may 

12:50:42 pm Brian Hunter: and I am worrie[d] that Anold [sic] has taken the other side 

of everything 

12:51:00 pm Brian Hunter: so either he runs it up on the close today and gets short 

tomorrow 

12:51:08 pm Brian Hunter: 

12:53:03 pm David Chasman: 

12:53:17 pm Brian Hunter: 

12:54:36 pm David Chasman: 

12:55:16 pm Brian Hunter: 

12:55:29 pm Brian Hunter: 

12:55:47 pm Brian Hunter: 

or has a HUGE view on the number tomorrow 

other side of everything meaning buying from everyone 

else selling- or buying from [you] 

no buying may and selling June ... with me 

does he know what [you are] up [to] [with respect to] 

rolling off length? ... sorry rolling off short 

probably 

I think its more that he thinks its going to get [f ... d) 

tomorrow 

me may try to help it by running the market up on the 

close 

12:56: I 0 pm David Chasman: kinda hard to do when [you are] selling - no? 

12:56:39 pm Brian Hunter: Arnold is the master of moving theclose? 

See instant message attached as Exhibit A document number A_CFTC032874. 

50. Defendant Hunter expressed a similar sentiment to an outside trader in an instant 

message wherein Hunter wrote "I think John [Arnold] wants to bid it on close." See instant 

message attached as Exhibit A document number AALLC_REG0593127. 

51. To affect the price for the May 2006 NYMEX natural gas futures contract, 

Defendants intentionally waited to sell their May 2006 NYMEX natural gas futures contracts. 

52. At the beginning of the closing range on April 26, 2006, Defendant Hunter stated 

to an Amaranth risk manager that he is seeing many buyers but he (Defendant Hunter) has "yet 

to sell." See instant message attached as Exhibit A document number A_CFTC032878. 

10 
53. Also early in the closing range on April26, 2006, Defendant Hunter stated to an 

Amaranth trader, Matthew Calhoun "we are wa[i]ting to sell." See instant message attached as 

Exhibit A document number A CFTC032910. 

54. Defendant Hunter knew that his selling would mute the effect of the buyers, 

whose purchases would tend to exert upward price pressure. 

55. At about the middle of the close on April 26, 2006, Defendants placed their first 

order to sell 500 May 2006 NYMEX natural gas futures contracts with instructions to hold 

execution of the order until the last eight minutes of the closing range, as part of the 

Manipulative Scheme. 

56. The order ticket for that order indicates the instruction to wait to execute the order 

until the last eight minutes of the closing range: 

11 
TFS ENERGY FUTURES, LLC 

Buy ~~67 -- ·-'~ ... ·-.. 

SELL 

(]X) 

)c.. 

t"O<-

\f> I 

ACCOUNT 

57. Around the same time on April26, 2006, Defendants placed another order to sell 

544 May 2006 NYMEX natural gas futures contracts with instructions to hold execution of the 

order until the last eight minutes of the closing range, as part of the Manipulative Scheme. 

58. The order ticket for that order indicates the instruction to wait to execute the order 

until the last eight minutes of the closing range: 

12 
~30:~ •• t?tr .... ..... 

~ . 

1sJ~ 

i(ps-~ N\--'f\~ 

·, qU .. ~\'17 

\ t't- ~- l'Zg 

59. At about 2:22p.m. on April26, 2006, with only eight minutes left in the closing 

range, Defendants placed a third order to sell 2,000 May 2006 NYMEX natural gas futures 

contracts. This final order represents two-thirds of the position Amaranth held going into the 

closing range. 

60. . The order ticket for the 2,000 lot order, with an indication that 1,675 of those lots 

were executed during the close, appears below: 

13 
'P!f'!B•· 

Boy-

• • §J 

"~' 

• 

• 

~LX ~ERGY, INC. 

61. The 2,000 Jot order was so large, and came so late in the closing range, that the 

broker was not able to execute the entire order during the closing range. 

C. The Cover-up 

62. On or about August 2, 2006, in furtherance of their official duties under the Act, 

the NYMEX Compliance Department sent a letter to Amaranth inquiring about Amaranth's 

trading of May 2006 NYMEX natural gas futures contracts on April 26, 2006 (the "August 2 

Letter"). The August 2 Letter is attached as Exhibit B. 

14 
63. In the August 2 Letter the NYMEX Compliance Department informed Amaranth 

that it had commenced an investigation to review Amaranth's natural gas trading activity on 

April 26, 2006. 

64. Specifically, NYMEX's August 2 Letter stated that a heavy concentration of 

Amaranth's trading of May 2006 NYMEX natural gas futures contracts occurred in the final 

minutes prior to the termination of trading in the contract, and that Amaranth sold 99% of its 

contracts in the final four minutes of the closing range and 78% of its contracts in the final 

minute of the closing range. 

65. In the August 2 Letter, NYMEX requested that Amaranth review its May 2006 

NYMEX natural gas futures trading activity for April 26, 2006 and provide a written explanation 

of the commercial need and justification for its trading. 

66. Knowing, therefore, that NYMEX was investigating whether it had engaged in 

banging the closing range, and that the Manipulative Scheme would unravel if the true account 

of its trading activity was disclosed, in response to the NYMEX inquiry Amaranth submitted a 

letter to cover-up what actually occurred. In that letter Amaranth willfully falsified, concealed, 

or covered up by trick, scheme or artifice a material fact and/or made false, fictitious, or 

fraudulent statements or representations in describing its April 26, 2006 trading. 

67. On or about August 15,2006, Amaranth sent a letter to NYMEX (the "August 15 

Letter") in response to NYMEX's August 2 Letter. The August 15 Letter is attached as Exhibit 

c. 

68. The August 15 Letter contains a number of false and misleading statements, 

including the manner in which Amaranth described its positions and trading strategy, 

deliberately concealing from NYMEX that Amaranth had given specific instructions to its floor 

15 
brokers on April26, 2006 as to when Amaranth's sales orders should be executed, claiming that 

it did not decide to sell its March natural gas futures contracts outright until 2: 17 p.m. or later, 

and claiming that to the extent any part of Amaranth's orders was executed in the post-close 

trading session it was not due to Amaranth's instructions but perhaps occurred because a floor 

broker erroneously failed to comply with Amaranth's directive to complete the execution of its 

orders during the closing range. 

V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT 

COUNT 1: 

ATTEMPTED MANIPULATION OF THE PRICE OF 

NATURAL GAS FUTURES 

69. Paragraphs I through 68 are re-alleged and incorporated herein by reference. 

70. Sections 6(c), 6(d) and 9(a)(2) of the Act, 7 U.S.C. §§ 9, 13b, and 13(a)(2), make 

it unlawful for any person to attempt to manipulate the price of any commodity in interstate 

commerce, or for future delivery on or subject to the rules of any registered entity, including any 

contract market. 

71. Defendants intended to affect the price of natural gas futures in 2006, including 

on or about February 24 and April 26, 2006. 

72. Defendants engaged in overt actions in furtherance of their intent to affect the 

price of natural gas futures in 2006, including on or about February 24 and April 26, 2006. 

73. By their conduct, Defendants Amaranth Advisors L.L.C., Amaranth Advisors 

(Calgary) ULC, and Hunter each violated Sections 6(c), 6(d) and 9(a)(2) of the Act, 7 U.S.C. §§ 

9, 13b, and 13(a)(2). 

16 
74. Each and every overt action in furtherance of the intent to affect the price of 

natural gas futures contracts, coupled with that intent, including but not limited to every 

purchase, sale, bid, offer, telephone call, e-mail and instant message, is alleged herein as separate 

and distinct violation of Sections 6(c), 6(d) and 9(a)(2) of the Act, 7 U.S.C. §§ 9, 13b, and 

13(a)(2). 

75. Amaranth Advisors L.L.C. and Amaranth Advisors (Calgary) ULC are also liable 

for violating Sections 6(c), 69d) and 9(a)(2) of the Act pursuant to Section 2(a)(l )(B) of the Act, 

by virtue of the acts of its official, agent or other person acting within the scope of his 

employment or office, including Defendant Hunter. 

COUNT2 

THE COVER-UP 

76. Paragraphs 1 through 75 are re-alleged and incorporated herein by reference. 

77. Section 9(a)(4) of the Act, 7 U.S.C. § 13(a)(4), makes it unlawful for any person 

willfully to falsify, conceal, or cover up by any trick, scheme, or artifice a material fact, make 

any false, fictitious, or fraudulent statements or representations, or make or use any false writing 

or document knowing the same to contain any false, fictitious, or fraudulent statement or entry to 

a registered entity, board of trade, or futures association designated or registered under the Act 

acting in furtherance of its official duties under the Act. 

78. NYMEX is a board of trade as defined by Section la(2) of the Act, 7 U.S.C. § 

la(2). 

79. NYMEX was acting in furtherance of its official duties under the Act in 

reviewing Amaranth's natural gas trading activity. 

17 
80. On or about August 15, 2006, Amaranth Advisors, L.L.C. made material 

misrepresentations to NYMEX by, among other things, the manner in which it described its 

positions and trading strategy, deliberately concealing from NYMEX that Amaranth had given 

specific instructions to its floor brokers on April 26, 2006 as to when Amaranth's sales orders 

should be executed, and claiming that it did not decide to sell its March natural gas futures 

contracts outright until 2:17p.m. or later. 

81. By its conduct Defendant Amaranth Advisors, L.L.C. violated Section 9(a)(4) of 

the Act, 7 U.S.C. § 13(a)(4). 

82. Each and every instance of such conduct by Amaranth Advisors L.L.C. is alleged 

herein as separate and distinct violation of Section 9(a)(4) of the Act, 7 U.S.C. § 13(a)(4). 

83. Amaranth Advisors L.L.C. is also liable for violating Section 9(a)(4) of the Act, 7 

U.S.C. § 13(a)(4), pursuant to Section 2(a)(l)(B) of the Act, by virtue ofthe acts of its official, 

agent or other person acting within the scope of his employment or office, including Defendant 

Hunter. 

VI. RELIEF REQUESTED 

WHEREFORE, Plaintiff respectfully requests that this Court, as authorized by Section 6c ofthe 

Act, 7 U.S.C. § 13a-l, and pursuant to its own equitable powers 

A. Find Defendants liable for violating Sections 6(c), 6(d), and 9(a)(2) of the Act, 7 

U.S.C. §§ 9, 13b, and 13(a)(2); 

B. Find Amaranth Advisors L.L.C. further liable for violating Section 9(a)(4) ofthe Act, 

7 U.S.C. § 13(a)(4); 

C. Enter an order of permanent injunction restraining and enjoining Defendants and any 

of their affiliates, agents, servants, employees, successors, assigns, attorneys and persons in 

18 
active concert with them who receive actual notice of such order by personal service or 

otherwise, from directly or indirectly violating Sections 6(c), 6(d), and 9(a)(2) of the Act, 7 

U.S.C. §§ 9, 13b, and 13(a)(2); 

D. Enter an order of permanent injunction further restraining and enjoining Amaranth 

Advisors L.L.C. and any of its affiliates, agents, servants, employees, successors, assigns, 

attorneys and persons in active concert with them who receive actual notice of such order by 

personal service or otherwise, from directly or indirectly violating Section 9(a)(4) of the Act, 7 

U.S.C. § 13(a)(4) 

E. Enter an order of permanent injunction prohibiting Defendants and any of their 

affiliates, agents, servants, employees, successors, assigns, attorneys and persons in active 

concert with them who receive actual notice of such order by personal service or otherwise, 

from: 

1. trading on or subject to the rules of any registered entity, as that term is 

defined in Section 1 a(29) of the Act, 7 U .S.C. § 1 a(29) (2002); 

2. engaging in, controlling or directing the trading for any commodity 

interest account for or on behalf of any other person or entity, whether by power of 

attorney or otherwise; 

3. soliciting or accepting any funds from any person in connection with the 

purchase or sale of any commodity interest; 

4. applying for registration or claiming exemption from registration with the 

Commission in any capacity, and engaging in any activity requiring such registration or 

exemption from registration with the Commission, except as provided for in Regulation 

4.14 (a)(9), 17 C.F.R. § 4.14(a)(9) (2006), or acting as a principal, agent or any other 

officer or employee of any person registered, exempted from registration or required to 

be registered with the Commission, except as provided for in Regulation 4.14 (a)(9), 17 

C.F.R. § 4.14(a)(9) (2006); 

5. entering into any commodity interest transactions for their own personal 

accounts, for any account in which they have a direct or indirect interest and/or having 

any commodity interests traded on their behalf; and/or 

6. engaging in any business activities related to commodity interest trading; 

19 
F. Enter an order directing Defendants to pay civil monetary penalties, to be assessed by 

the Court, in an amount not to exceed $130,000 or triple the monetary gain to them for each 

violation of the Act, as described herein; 

G. Enter an order providing for such other and further equitable and ancillary relief as 

this Court may deem necessary and appropriate, including but not limited to restitution and 

disgorgement of ill-gotten gains and damages; and 

H. Enter an order requiring Defendants to pay costs and fees as permitted by 28 U.S.C. 

§§ 1920 and 2412(a)(2). 

20 
VII. DEMAND FOR JURY TRIAL 

Plaintiff hereby demands a jury trial. 

Dated: July 25, 2007 

New York, New York 

21 

Respectfully submitted, 

ATTORNEYS FOR PLAINTIFF 

U.S. COMMODITY FUTURES TRADING 

COMMISSION 

Gregory G. Mocek 

Director, Division of Enforcement 

Vincent A. McGonagle 

Senior Deputy Director 

Division of Enforcement 

1155 21 51 Street, N.W. 

Washington, D.C. 20581 

(202) 418-5387 

(202) 418-55 1 9 (facsimile) 

vmcgonagle@cftc.gov 

Stephen J. Obie 

Regional Counsel and Associate Director 

David W. MacGregor 

ChiefTrial Attorney 

Mana] Sultan 

ChiefTrial Attorney 

Commodity Futures Trading Commission 

140 Broadway, 19th Floor 

New York, NY 1 0005 

(646) 746-9766 

(646) 746-9940 (facsimile) 

sobie@cftc.gov 
EXHIBIT A 
From: 

sent 

To: 

windoVIISadmin@amaranthllc.com 

Thursday, February 23, 2006 3:13PM 

amaranth.dom@amaranth.cfigltalsafe.net 

Subject SUBJECT: CONVERSATION PARTICIPANTS = BHUNTER@AMARANTHLLC.COM; 

MDONOHOE@AMARANTHLLC.COM . 

IM Network: J\OL IM 

IM Users:· 

participant~bhunter@amaranthllc.com "hunterarnaranth" . participant=mdonohoe@amaranthllc.com "mjtdonohoe" 

IM Dialog: 

Thursday, February 23, 2006 3:13:29 EM EST Matthew Donohoe started conversation. 

Thursday, February 23, 2006 3:13:29 EM EST Brian Hunter has entered the conversation. 

Thursday, February 23, 2006 3:13:29 EM EST Matthew Donohoe: i think that was mother rock 

Thursday, February 23, 2006 3:13:38 ~EST Matthew Donohoe: they were buying all the pen 

last Thursday, February 23, 2006 3.:16:2.3 PM EST Brian· Hunter: vol Thursday, February 23, 

2006 3:16:24 PM EST Brian Hunter: 78.50%51.00%50.00%48.75%48.25%48.50%48.75%48.75%48.50% 

48.50%50.50%S0.50%50.50t35.25%34.25%34.25%34.75%34,75%34.75%36.00%38.45%39.50%40.00%40.50% 

41.i0%30.00%29.00%29.00%29.50%29.75%30.00%30.50%31.50%32.00%33.00%33.25%35.00%27.50%27.00% 

27.00%27.00%27.00%21.00%27.50%28.00%28.50% . Thursday, February 23, 2006 3:16:27 EM EST Brian Hunter: big changes Thursday, February 

23, 2006 3:16:35 PM EST Brian Hunter: don't forget Cathy's marks Thursday, Februar; 23, 

2006 3:16:46 ~EST Matthew Donohoe: got them Thursday, February 23, 2006 3:17:13 PM EST 

Matthew Donohoe: 13m hit Thursday, February 23, 2006 3:17:25 PM EST Matthe\'1 Donohoe: down 

11.5 m Thursday, February 23, 2006 3:17:31 PH EST Matthew Donohoe: total Thursday, 

February 23, 2006 3:18:25 PM EST Brian Hunter: l gave yc•u new curve Thursday, February 23, 

2006 3:18:32 PM EST Brian Hunter: J.3007.4307.5967.7317.8647.9448.015B.l109.12710.13410.79910~82610.6048.7548.5548.6248.709B 

• 7798.7898.8599.46410.02910.41410.39410.2040.1999.0098.0798.1378.2028.2098.2698.8429.4179. 

8429.8329.6407.6257.4207.4907.5557.6157,6251.6858.3008.8909.3359.3309.1357.1556.9957.0407. 

0907.1407.1257.1?57.7458.3158.8958.8858.7107.3207.1007.1807.2057.2457.2307.2701.7408.160 

Thursday, February 23, 2006 3:20:53 PH EST Matthew Donohoe: yeah got that Thursday, 

February 23, 2006 3:20:59 PM EST Matthew Donohoe: price makes 9m Thursday, February 23, 

2006 3:21:19 PM EST Matthew Donohoe: vol losses 20 Thursday, February 23, 2006 3:21:43 PH 

EST Brian Hunter: we'll make back alittle off Cathy's optoins Thursday, February 23, 2006 

3:21:57 PM EST Brian Hunter: also I want you to mark the put skew in Cal9 puts Thursday, 

February 23, 2006 3:22:05 PM EST Matthew Donohoe: sure Thursday, February 23, 2006 3:22:11 

PM EST Brian Hunter: 2.5-5.5-ve -,06 cents Thursday, February 23, 2006 3:22:29 FM EST 

Matthew Donohoe: neg skes Thursday, February 23, 200E 3:22:42 PM EST Brian Hunter: y 

Thursday, Fellruuy 23, 2006 3:22:.50 FM EST Brian Hunter: 2.20 to 5.00 out of the IUIJney 

strike Thursday, February 23, 2006 3:22:54 PM EST Brian Hunter: 6 cents nevative Thu.r·sday, 

.february 23, 2006 3:22:57 PM EST Matthew Donohoe: got it Thursday, February 23, 2006 

3:22:58 PM EST Brian Hunter: they are 4 cents right now Thursday, February 23, 2006 

3:23:08 PM EST Brian Hunter: Cath'y trades will amke mack 6mm Thursday, February 23, 2006 

3:23:16 PM EST Brian. Hunter: and skew another 2mm Thursday, February 23, 2006 3:23:57 PM 

·EST Matthew Donohoe: ·.re will loss 4m on adjust to esc Thursday, February 23, 2006 3:23:59 

PM EST Matthew Donohoe: right Thursday, February 23, 2006 3:26:36 PM EST Matthew Donohoe: 

rallying here Thursday, February 23, 2006 3:26:44 PM EST Matthew Donohoe: 35 bid h' 

Thursday, February 23, 2006 3:30:19 Hi EST Brian Hunter: new curve Thursday, February 23, 

2006 3:30:23 PM EST Brian Hunter: 7.4~87.5437.7037.8437.9738.053a.1238.21S9.22B10.20810.86810.86810.6688.8188.6088.6G88.138B 

.7988.818S.8939.49810.06810.49110.49110.321B.2218.0368.0868.1468.2018.2268.2918.8569.4169. 

8799.8699.669?.6097.4047.4747.5397.5947.6191.6898.2848.8649.3049.2949.1047.1046.926.9657.0 

187.0647.C747.1447.7248.3C48.8958.8858.7107.3207.1007.1807.205i.245?.2307.2707.7408.160 

Thursday, February 23, 2006 3:39:48 fM EST Brian Hunter: PBN tnu.ling 13.5 for size H.J 

CONFIDENTIAL TREATMENT REQUESTED AALLC_REG0684055 
Thursday, Fecruary 23, 2006 3:39:58 Ei EST Brian Hunter: make sure we have lots of futures 

to se!l •toe tomorrow 

CONFIDENTIAL TREATMENT REQUESTED AALLC_REG0684056 
From: M idlCEI M a a:::h [ mmaa:::h@arm:rmthllc.oom] 

Sa1t: Friday, Februa-y 24, 200610:23AM 

To: MattheN Calhoun; MattheN Donohoe; Brien Hunter; Bra:l Bas:r9Widl; Peter Geery; Ale< Villani!; 

Adam Glassmm · 

Cc: Energy Opercii ons 

&Jbj ect: Book2.xls 

A ttachmEflts Book2.xl s 

<<Book2.xls>> 

Please. see the above concerning our position which agrees with JPMU of short -1729 Nat Gas Mar 06 (NGH6). 

Please make sure we are flat by the end of the day today. 

Thanks, 

Mike 

CONFIDENTIAL TREATMENT REQUESTED AALLC_REG0672597 
From: 

Sent: 

To: 

Wlndowsadmin@amaranthllc.com 

Friday, February 24, :mas 12:10 PM 

amaranth.dom@amaranth.digitalsafe.net 

Subject: SUBJECT: CONVERSATION PARTICIPANTS= MCALHOUN@AMARANTHLLC.COM; 

BHUNTER@AMARANTHLLC.COM 

!H >1-:t..,.ot·i:: AOL IM 

IH iJE"~rs: 

;:-articipan:=rncalhoun@amaranthllc. c<::Jm "::all i frnicat ion" 

!)arti·~l.pant~bhunter@ amaranth11c. co1n "hunteramaranth" 

!M Dialog: 

Friday, t'".!bruary 2<1, 2006 12: 10:16 ?H EST l1atthew Calhoun stat·tP.d convf!rsation. 

F"l"idl\y, Febr11ary 24, 2006 12:10:)6 PH EST Brian Hunt&l" ha" entet·ed the conversation. 

Fc-iday, February 24, 2006 12:10:16 PH EST Matthew C.:~lhoun: very much so Friday, February 

24, 2006 12:10:16 PM EST MattheH Calhoun: very much so F"riday, !ebruary 24, 2006 12:14:43 

?1-1 E:Z":' !3rian Hunter: jv/xh seems ve::y big Friday, February 24, 2006 12:14:43 PM EST !lriar. 

H•.mter: jv/:th seem.s ·~er; big Friday, F'e.bruary 24, 2006 12:14:45 PH EST Brian Hunter: JV7 

is =t:r-:·nq Friday, February 24 ,. 2006 12:14: 4!i PH EST Brian Hunter: jv7 is strong Friday, 

febnlary 24, 2006 12:15: 10 PM EST fiat thew Calhoun: yeah, not :nany sellers out there 

Fr:.dav, February 24, 2006 12:15:10 PH EST l1atthew Calhoun: yeah, not many sellers out 

there Friday, February 24, 2006 12:15:41 ~1 EST Brian Hunter: that's pushinq up the s~r 

>~lnter Friday, February 24, 2005 12:15:41 PM EST Brian Hunter: that's pushing up the 

summer 1o1inter Friday, February 24, 2006 12:15:47 PH EST Brian Hunter: and 7/10 Friday, 

February 24, 2006 12:15:47 PM EST Brian Hunter: and 7/10 Friday, February 24, 2006 

12:15:52 ~EST Brian Hunter: hello .•. 

Fl"iday, February 24, 2006 12:15:52 PH EST Brian Hunta1·: hello ... 

ft·iday, February 24, 2006 12:15:57 PH EST i1rian Hunter: sweat Fl"iday, Februat"'J 24, 2006 

12:1.5:57 EM EST Brian Hunter: sweet Friday, February 24, 2006 12:15:59 PM EST Matthew 

Calhoun: lol Friday, February 24, 2006 12:16:00 PH EST Matthew Calhoun: lol Friday, 

.February 24, 2006 12:16:06 PH EST Matthew Calhoun: pain everywhere Friday, Febrllar"l 24, 

2006 :2:16:06 PH EST Matthew Calhoun: pain everywhere Friday, FebruarJ 24, 2006 12:16:28 

PH EST Brian Hunter: just need H to get smashed on settle Friday, February 24, 2006 

12:16:28 ~EST Brian Hunter: just need H to get smashed on settle Friday, Februar1 24, 

2006 :..2:16:31 PM EST Brian Hunter: then day is done Friday, February 24, 2006 12:16:31 Hi 

E£T Brian Hunter: then day is done Friday, February 24, 2006 12:16:43 PH EST Matthew 

Calhoun: 01 is huge for Friday, February.24, 2006 12:16:43 PH EST l".atthew Calhoun: OI is 

t.:.:ge fc;r Friday, February 24, 2006 12: 16:45 FM EST Matthew Calhoun: ld friday, Februory 

21. 2006 12:16:45 PH EST Matthew Calhoun: ld Friday, February 24, 2006 12:16:48 ~EST 

~~tthe~ Calhoun: 3Jk Friday, Feb~~ary 24, 2006 12:16:48 ~EST Matthew Calhoun: 33k 

Frio:iay, F"'bruary 24, 2006 12: l7 :46 ?M EST t1atthew Calhoun: ycu think cl holds these gains? 

Fdd<~y, Februar; 24, 2006 12:17:48 PH EST Hatthew Calhoun: you think c1 holds these 9ains? 

Fl"iday, FebruarJ 24, 2006 12:25:54 PH EST Brian Hunter: yeah Friday, February 24, 2006 

12::::5:54 12M EST Brian Hunter: yean Friday, February 24, 2006 12:25:59 PH EST Brian Hunter: 

pr.,.mium stays big Friday, February 24, 2006 12:25:59 PM EST Brian Hunter: premium stays 

big !!"riday, February 24, 2006 12:27:06 PH EST 1-~tthew Ca.i.houn: great day for that spread 

sc tar Friday, February 24, 2006 12:27:06 PH EST Matthew Calhoun: great day for that 

.:;pre ad so far Friday, february 24, 2006 12:29:32 PH EST Brian Hunter: eayh Friday, 

february 24, 2006 12:29:32 P~ EST Brian Hunter: eayh ~·riday, February 24, 2006 12:29:39 !:'M 

EST Brian Hunter: unwindinq iv/xh here is good for us .•• 

Fndav, r .. bruary 24, 2006 12:29:39 PM EST Brian Hunt<:~r: unwinding iv/xh here is good for 

us ..... 

Ft·iday, F.;bruar; 24, 2006 12:31:20 PM EST 11atthew Calhoun: definitely Friday, Februart :::.; , 

2~•(1.; :;::31 :20 PM EST Matthew Calhoun: definitely Friday, Feb["IJary 24, 2006 12:33:23 ?M ES"l' 

~~tthew Calhoun: u still have jv? to sell to me? 

fr·.idcoy, F"'bcuar·y 2~. 2006 12:33:23 PH EST !1atthaw Calhoun: u still have jv7 to sall to m;,o? 

CONFIDENTIAL TREATMENT REQUESTED AALLC_REG0684186 
Friday, February 24, 2006 12:34:13 PM EST Brian Hunter: y Friday, February 24, 2006 1~::4:13 ~EST Brian Hunter: y Friday, Februar-J 24, 2006 12:Ji:09 Ri EST Matthew C~lhoun: 

ccol friday, Fsbruart 2~, 2006 12:37~09 a~ EST Matthew.Calhoun: cool 

2 

CONFIDENTIAL TREATMENT REQUESTED AALLC_REG0684187 
From: 

Sent 

To: 

windowsadmin@amaranthllc.com 

Friday, February 24, 2006 1 :30 PM 

amaranth.dom@amaranth.digitalsafe.net 

Subject SUBJECT: CONVERSATION PARTICIPANTS= "GLOVERS"; "HUNTER_AMARANTH" 

IH Network: Yahoo IM 

IH Users: 

participantg"gloverb" 

participanta"hunter_amaranth" 

IH Dialog: 

Friday, february 24, 2006 1:30:02 PH EST glovarb started conversation. 

Friday, February 24, 2006 1:30:02 PH EST Brian Hunter has entered the conversation. 

Friday, Februa~t 24, 2006 1:30:02 PH EST gloverb: IM Administrator: NOTE: This session is 

recorded and the recording is the sole property of Amaranth. 

Friday, February 24, 2006 1:30:02 PH EST Brian Hunter: IH Administrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Friday, February 24, 2006 1:30:02 PM EST gloverb: you still t hink down Friday, February 

24, 2006 1:30:49 ~EST Brian Hunter: Sandy and RBI bidding the H Friday, February 24, 

2006 1:30:51 PH EST Brian Hunter: nothing trading friday, February 24, 2006 1:30:56 PH EST 

Brian Hunter: I "tonder what will hapen Friday, February 24, 2006 1:31:05 PM EST Brian 

Hunter: lots of EFS went through Friday, February 24, 2006 1:31:07 PH EST 9rian Hunter: OI 

down alot Friday, February 24, 2006 1:31:09 ~EST gloverb: all i am told Friday, February 

24, 2006 1:31:15 PH EST gloverb: is it is going to rally hard Friday, February 24, 2006 

1:31:21 PH EST glovl!rb: but guys running on Cloo1· Friday, February 24, 2006 1:31:22 PM EST 

glovarb: lol Friday, February 24, 2006 1:31:25 PM EST Brian Hunter: we have 4000 to sell 

HoC Fr-iday, February 24, 2006 1:31:28 PM EST Brian Hunter: shhhh Friday, February 24, 2006 

1:31:36 PM EST gloverb: come on Friday, February 24, 2006 1:31:39 PH EST Brian Hunter: y 

Friday, Februa~t 24, _2006 1:31:43 PM EST gloverb: unless you are huge bearish Friday, 

February 24, 2006 1.:31: 4 9 PM EST gloverb: position Friday, February 24, 2006 1: 31:54 PM 

EST gloverb: why the f would yo do that Friday, February 24, 2006 1:32:16 PM EST Brian 

Hunter: all from options yestrday Friday, February 24, 2006 1:32:25 PM EST Brian Hunter: 

so.we'll see what the floor has Friday, February 24, 2006 1:32:33 PM EST Brian Hunter: bit 

of an expirinent mainly Friday, February 24, 2006 1_:32:43 PH E,ST gloverb: what the f 

Friday, February 24, 2006 1:32:46 PH EST gloverb:· that is huge Friday, February 24, 2006 

1:35:34 PM EST Brian Hunter: I think John and Sempra are sellers too 

CONFIDENTIAL TREATMENT REQUESTED AALLC_REG0684227 
From: 

sent: 

To: 

Subject: 

m Network: Yahoc. 1!1 

IN Users: 

Wlndowaadmin@amaranthllc.com 

Friday. February 24, 2006 2:11 PM 

amaran1h.dom@amaranth.digi1alsafe.net 

SUBJECT: CONVERSATION PARTICIPANTS = •GLOVERS·; 

BHUNTER@AMARANTHLLC.COM 

puticipant""q1ovcrb" 

participant .. bhunter~amaranthllc. cozn "hunter_BIIIaranth" 

I~ Dialog: 

Friday, February 2~. 2006 2:10:5~ ~EST gloverb ~tarte~ ccnversation, 

Friday, Febr•Jary 2~, :!0(11) ::! : 10: 53 ~ £S':' Br :.an Hunter hat entr.re:! ::.he- conve::sa-: i·:lt •• 

Friday, Febr•Jary 2~. 201j6 2:10:53 ~EST gl,,v ... rb: ar~nt yrJu don<: Friaay, r ... t.:-Ja:·y ;z.;, ZO:l6 

::!:11:31 ~ !:ST ~::ia1o Hunt-e~·: n'J F:.-i::la'J, r .... i::ruary 2~, ~O(It; 2:11:35 Ell·: ::s: Bria.:; Hur.t ... r: 

nave ale~ ~ore -:o s,...ll Fri~ay, rebruary 2~. 200~ 2:ll:4G PM ES7 Brian Hunter: waitinc u~::.~ 

:!:20 Friaa:t. Fei::ruary 2~, ;11)(•-5 :!:2o:'i:'2 PH £ST glovert:: wsll rr!.:iay, !ebrulH"Y :z.;, :!C/O( 

:!:2o:46 PM ::sr E!t:"ian Hunte:: did you hear ~errill bough~ 101: 6.00 ::alls'? 

Friday, Febr'JIIry 2.;, ~006 ::2!l:52 P.-1 E!lT Isr:.an Hunt~:: !o: today? 

Friaay, Febr:.~ary 2.;, 201J'.> :!:2!~:!1~ P!-1 £S'!' Br:.nn liunter: woo.-1 Friciay, Februar~· :;.;, ~Ot>? 

:!:26:55 PM £5'!' Brion Hunt,...:: yeah Fr.i.aay, Fec:uar~· :i.;, 200t :!:26:5~ ?!-! EST Briar. H~:r.te::: 

t3t ~orad out nicely ~·rid:~y, fecruary 24, 200Q .:::.27:00 I'M E:S1" glaverb: really f"riaay, 

February 24, .2001) ::! :27: o:. I-1-1 EST g.!.:averb: wow Friday, febr~ary 2.;, 200G 2::!7 :2j ffol te":" 

qloverb: for 3 cent Friday, February 24, 2006 :!:29:3:! Pl·l EST Brian tlunur: veal. Frida·1, 

February 24, ::oo.; .2:28:3f. FM EST Brian Hunter: ;,INl, friday, F<Jbruary 2r., .2006 :!:2il:39 Pf~ 

EST B:-ian Hunter: a bit risl:i' •.• 

Fdday, February z.;, 201)6 2:2B:46 ?.-!EST &r:.an Hunter: :'=' ll'.iss i: cy 1.0(; F:iday, Februa:v 

2,, 2006 2:29:54 1'1-: EST c;~laverb: nigher or :..~wo.r after ::-lse()(o f:iday, recruary 2~. 2C% • 

2:30:25 PM ES'!' lhlllll Hulll':.':: nige:· Fr.i.dai', F<.ti.UUlUl 2~, 20::>6 :!:30:40 P!'. £.S! ~:~~tr. !h::!l':':: 

but will ~CB1':.':> l~<<:h.i':l:: IS l.illl<t Friday, oeb,·u11ry 2~, 2:l06 :?.:3<:::46 PI·~ !:S! 9:~tlli Hur;~~:: 

dP.pends or. C!. and WIHith<t• 1-'orriay Fri:i!ly, Febmilry 24, ?.llOii ~::lfl:~6 PM £S7 ;lcwerh: j ~nn-. 

k..we:- F:-:i:iay, F&nrul'l~i· '"?4, :.wo6 :!:3!,:4e l'f-1 ::s; ?lnvern: ini rl'l:ly F:'iday, •~h~·111ry ~~. :;-r,rh: :::30:5~ :'M :::;-:· Ilrian Hunt"!:-: but ca:::.s are gong t~ be rl.i.:! 'Fri~ay, 'F!!bruari' 2~. :ZOIJ• .• ::!::!~::~:: 

PH !::!'1' gl_,·,ert: :.. meor. ::oda:· Friday. Februarj• 20:, :!!='0~ 2:;10:5~ Fl·! E!lT Briar. H~nt~:-: ,_.:_':~. 

C~ heore F:iday. reDrucr:l 2~. ~O:JO 2:31::: :M tS7 Orlan Uur.te:-: f:-or.t ,.._.il! -=~ 'J;; ·~.nal'a~.t 

;vtxh s~ar.s tO ~liaer. Frld3").', F!IDt"UBl'"'j :z~. :!UOi> :!::ll::!~ [1·l :::sr Brian Hunter: !"1'-'.l.:-· r:.:.'::Dj", 

rebruar-l 2~. ~006 .::::!! ::.!4 I'M ~51 !:lr:.an Hunto:: :~1:. 105 tlic ·u:-: ~n tile !1oo:-

CONFIDENTIAL TREATMENT REQUESTED AALLC_REG0684264 
• 

From: 

Sent 

To; 

Subject: 

wintlowsadmin@amaranthllc.com 

Friday, FebrUary 24, 2006 2:14PM 

amaranth.dom@amaranth.digitalsate.net 

SUBJECT: CONVERSATION PARTICIPANTS= BHUNTER@AMARANTHLLC.COM; 

MDONOHOE@AMARANTHLLC.COM 

X-ZANTAZ-MESSAGE-DATE: 02/24/2006 19:13:31; 02/24/2006 19:15:11; 02/24/2006 19:15:31; 

02/24/2006 19:15:38; 02/24/2006 19:15:47; 02/24/2006 19:15:51; 02/24/2006 19:16:03; 

02/2412006 19:16:34; 02/24/2006 19:16:39; 02/24/2006 19:16:41; 02/24/2006 19:16:52; 

02/24/2006 19:16:53; 02/24/2006 19:16:55; 02/24/2006 19:16:59; 02124/2006 19:11:01; 

02/24/2006 19:17:04; 02/24/2006 19:17:12; 02/24/2006 19.:17:28; 02/24/2006 19:11:33; 

02/24/2006 19:18:09; 02/24/2006 19:18:19; 02/24/2006 19:18:21; 02/24/2006 19:18:25; 

02/24/2006 19:18:27; 02/24/2006 19:18:30; 02/24/2006·19:24:06; 02/24/2006 19:24:13; 

02/24/2006 19:24:17; 02/24/2006 19:24:26; 02/24/2006 19:24:29; 02/24/2006 19:25:04; 

02/24/2006 19:27:50; 02/24/2006 19:27:58; 02/24/2006 19:27:59; 02/24/2006 19:30:04; 

02/24/2006 19:30:07; 02/24/2006 19:30:14; 02/24/2006 19:30:21; 02/24/2006 19:30:41; 

02/24/2006 19:31:30; 02/24/2006 19:31:37; 02/24/2006 19:31:40; 02/24/2006 19:31150; 

02/24/2006 19:31:53; 02/24/2006 19:31:58; 02/24/2006 19:32:04; 

02/24/2006 19:32:23; 02/24/2006 19:32:27; 02/24/2006 19:32:34; 02/24/2006 19:32:39; 

02/24/2006 19:32:52; 02/24/2006 19:32:59; 02/24/2006 19:33:34; 02/24/2006 19:33:40; 

02/24/2006 19:33:43; 02/24/2006 19:34:52; 02/24/2006 19:34:58; 02/24/2006 19:35:14; 

02/24/2006 19:35:18; 02/24/2006 19:35:21; 02/24/2006 19:37:54; 02/24/2006 19:38:16; 

02/24/2006 19:38:18; 02/24/2006 19:38:21; 02/24/2006 19:38:24; 02/24/2006 19:39:38; 

02/24/2006 19:38:41; 02/24/2006 19:38:44; 02/24/2006 19:38:45 

X-ZANTAZ-PARTICIPANT-EMHAMES: hunteramaranth; mjtdonohoe 

X-ZANTAZ-RECIPIENT-NAME: Brian Hunter; Matthew Donohoe X-ZANTAZ-PARTICIPANT-~5: mjtdonohoe; hunteramaranth 

X-ZANTAZ-SENDER-NAME: Matthew Donohoe; Brian .Hunter 

X -ZANTAZ-GUID: ·El92C6AO-9B22-4C5E-A02C-OBB8 4 8CO 6F35S 95164 56 96632703 

X-ZANTAZ-URL: notused x-oriqinalArrivalT~e: 24 Feb 2006 19:40:21.0839 (UTC) FILETIME•(2652C5F0:01C6397A] 

IM Network: AOL IM 

IM U.ser.s: 

participantabhunter@amaranthllc.com "hunteramaranth" participant~noboe@wmaranthllc.com •mjtdonohoe" 

IM Dialog: 

Friday, February 24, 2006 2:13:31 PM EST Matthew Donohoe started conversation. 

Friday, February 24, 2006 2:13:·31 PM EST Brian Hunter has entered the conversation. 

Friday, February 24, 2006 2:13:31 P.M EST Matthew Donohoe: 22 h/j Friday, February 24, 2006 

2:13:31 P.M EST Brian Hunter: IM Administrator: NOTE: This session is recorded and the 

recording is the sole property of ~aranth. 

Friday, February 24, 2006 2:13:31 PM EST Matthew Donohoe: IM Administrator: NOTE: This 

session is recorded and the recording is the sole property of ~aranth. . Friday, February 24, 2006 2:15:11 P.M EST Brian Hunter: 105 bid v/x ·Friday, February 24, 

2006 2:15:31 PM EST Brian Hunter: nice Friday, February 24, 2006 2:15:38 PM EST Brian 

Hunter: cciday came together quite nicely •• Friday, February 24, .2006 2:15:47 PM EST Brian Hunter: you can sell Maatt the jv7 Friday, 

February 24, 2006 2:15:51 PM EST Brian Hunter: if you haven't done so Friday, February 24, 

2006 2:16:03 PM EST Matthew Donohoe: done Friday, February 24, 2006 2:16:34 PM EST Brian 

Hunter: we'll hit the rest near the end·of this Friday, February 24, 2006 2:16:39 PM EST 

Matthew Donohoe: what is fair for calhoun Friday, February 24, 2006 2:16:47 PM EST Matthew 

Donohoe: y Friday, February 24, 2006 2:16:52 PM EST Brian Hunter: 65 Friday, February 24, 

2006 2:16:53 PM EST Matthew Donohoe: i have h/j to roll Friday, February 24, 2006 2:16:55 

PM EST Matthew Donohoe: 450 Friday; February 24, 2006 2:16:55 PM EST Brian Hunter: 1. am 

CONFIDENTIAL:. TREATMENT REQUESTED AALLC_REG0704931 
thnking friday, February 24, 2006 2:16:59 PM EST Matthew Donohoe: could just· sell :) 

Friday, February 24, 2006 2:17:01 PM EST Brian Hunter: nothing realyl moving but H Friday, 

February 24, 2006 2:17:04 I?M EST Matthew Donohoe: if you· want Friday, February 24,· 2006 

2:17:12 PM EST Brian Hunter: your pick Friday, February 24, 2006 2:17:28 PM EST Brian 

Hunter: 68 jv Friday, February 24, 2006 2:17:33 PM EST Brian Hunter: 66/10 Friday, 

February 24, 2006 2:18:09 PM EST Matthew Donohoe: 68's done with calhoun Friday, February 

24, 2006 2:18:19 PM EST Brian Hunter: maybe leave the j's Friday, February 24, 2006 

2:18:21 PM EST Brian Hunter: doen sell them Friday, February 24, 2006 2:18:25 I?M EST Brian 

Hunter: lets roll off more Friday, February 24, 2006 2:18:27 PM EST Brian Hunter: its a good level Friday, February 24, 2006 2:18:30 PM EST Matthew Donohoe: ok Friday, February 

24, 2006 2:24:06 PM EST Matthew Donohoe: yo how are the cals holding Friday, February 24, 

2006 2:24:13 PM EST Brian Hunter: strong Friday, February 24, 2006 2:24:17 PM EST Matthew 

Donohoe: just trying to get an estimate for rricky Friday, February 24, 2006 2:24:26 PM 

EST Brian Hunter: 25 Friday, February 24, 2006 2:24:29 PM EST Brian Hunter: ish Friday, 

February 24, 2006 2:25:04 PM EST Matthew Donohoe: good Friday, February 24, 2006 2:27:50 

PM EST Brian Hunter: stay ong the j Friday, February 24, 2006 2:27:58 I?M EST Brian Hunter: 

we'll be able to sell it bet~er Friday, February 24, 2006 2:27:59 I?M EST Matthew Donohoe: 

ok Friday, February 24, 2006 2:30:04 PM EST Brian Hunter: · 7.1507.3507.5207.6577.7927.8747.9458.0409.08210.10410.77410.80110.5798.7298.5298.5998.6848 

.754B.7648.B349.43910.00410.38910.3a910.179B.l447.9548.0248.0828.147B.l548.2148.7729.3329. 

7579.7479.5557.5407.3351.4057.4707 .5307. 5407 .6008.1958.7659.2109.2059.-0107.0306.8706.9156. 

9657.0157.0007.0507.6208.1908.7708.7608.5857.1956.9757.0557.0807.1207.1057.1457.6158.035 

Friday, February 24, 2006 2:30:07 PM EST Brian Hunter: what' do you think? 

Friday, February 24, 2006 2:30:14 PM EST Brian Hunter: of this curve? 

Friday, February 24, 2006 2:30:21 PM EST Matthew Donohoe: h will setlle lower Friday, 

February 24, 2006 2:30:47 PM EST Matthew Donohoe: and h/j •tider Friday, February 24, 2006 

2:31:30 PM EST Matthew Donohoe: nice Friday, February 24, 2006-2:31:37 EM EST Brian 

Hunter: I am flexing here Friday, February 24, 2006 2:31:40 PM EST Matthew Donohoe: 

looking preety bang on Friday, February 24, 2006 2:31:50 I?M EST Matthew Donohoe: we already rnimiced Friday, February 24, 2006 2:31:53 PM EST Matthew Donohoe: lol Friday, 

February 24, 2006 2:31:58 PM EST Mat-thew Donohoe: rrrrrrrrrrrrrrrrrrr Friday, February 24, 

2006 2:32:04 PM EST Brian Hunter: hahahahnha Friday, February 24, 2006 2:32:23 PM EST 

Matthew Donohoe: 2nd best ••• sept/oct last year still the best Friday, February.24, 2006 

2:32:27 PM EST Matthew Donohoe: oh yeag Friday, February 24, 2006 2:32:34 PM EST Brian 

Hunter: y Friday, February 24, 2006 2:32:39 PM EST Brian Hunter: where is Calhoun? 

Friday, February 24, 2006 2:32:52 PM EST Matthew Donohoe: jsut stepped off Friday·, 

February 24, 2006 2:32:59 PM EST Matthew Donohoe: hey red h/j Friday, February 24, 2006 

2:33:34 PM EST Brian Hunter: y Friday, February 24, 2006 2:33:40 PM EST Brian Hunter: 

tighter F~iday, February 24, 2006 2:33:43 PM EST Brian Hunter: I lef twider Friday, 

February 24, 2006 2:34:52 PM EST Matthew Donohoe: 22 h/j Friday, February 24, 2006 2:34:58 

PM EST Matthew Donohoe: should pay you a bit more Friday, February 24, 2006 2:35:14 PM EST 

Brian Hunter: yeah Friday, February 24, 2006 2:35:18 PM EST Brian Hunter: I night adjust a little Friday, February 24, 2006 2:35:21 PM EST Matthew Donohoe: nice-and concervative on cals spreads too Friday, February 24, 2006 2:37:54 PM EST Matthew Donohoe: check v/f on the floor Friday, February ~4, 2006 2:38:16 P.M EST Brian Hunter: where is it on box? 

Friday, february 24, 2006 2:38:18 PM EST Brian Hunter: any market Friday, ·February 24, 

2006 2:38:21 PM_EST Brian Hunter: it was pretty bid Friday, February 24, 2006 2:38:24 PM 

EST Matthew Donohoe: 165/74 Friday, February 24, 2006 2:38:38 PM EST Matthew Donohoe: i 

asked and got wider just before close Friday, Fabruary 24, 2006 2:38:41 PM EST Brian 

Hunter: 75 will be settle Friday, Februa·ry 24, 2006 2:38:44 I'M EST Matthew Donohoe: y 

Friday, February 24, 2006 2:38:45 PM EST Brian Hunter: 105 bid v/x 

2 

CONFIDENTIAL TREATMENT REQUESTED AALLC _REG0704932 
From: 

Sent: 

To: 

windowsadmin@amaranthllc.com 

Wednesday, April 26; 2006 1.2:45 PM 

amaranth.dom@amaranth.digitalsafe.net 

Subject: SUBJECT: CONVERSATION PARTICIPANTS= DCHASMAN@AMARANTHLLC.COM: 

BHUNTER@AMARANTHLLC.COM 

X-ZANTA2-MESSAGE-DATE: 04/26/2006 16:44:49; 04/26/2006 16:45:12; 04/26/2006 16:45:45; 

04/26/2006 16:45:46; 04/26/2006 16:46:29; 04/26/2006 16:47:28; 04/26/2006 16:47:29; 

04/26/2006 16:48:03; 04/26/2006 16:48:02; 04/26/2006 16:48:04; 04/26/2006 16:48:05; 

04/26/2006 16:48:20; 04/26/2006 16:46:30; 04/26/2006 16:48:31; 04/26/2006 16:48:48; 

04/26/2006 16:49:45; 04/26/2006 16:50:04; 04/26/2006 16:50:05; 04/26/2006 16:50:06; 

04/26/2006 16:5o:o7; 04/26/2006 16:50:25; 04/25/ioo6 16:50:26: 04/26/2006 16:50:28: 

04/26/2006 16:50:29; 04/26/2006 16:50:42; 04/26/2006 16:51:00; 04/26/2006 16:50:59; 

04/26/2006 16:51:08; 04/26/2006 16:51:07; 04/26/2006 16:51:16; 04/26/2006 16:53:03; 

04/26/2006 16:53:11; 04/26/2006 16:53:18~ 04/26/2006 16:53:19; 04/26/2006 16:54:36; 

04/26/2006 16:54:49; 04/26/2006 16:55:16; 04/26/2006 16:55:17; 04/26/2006 16:55:23; 

04/26/2006 16:55:24; 04/26/2006 16:55:29; 04/26/2006 16:55:33; 04/26/2006 16:55:35; 

04/26/2006 16:55:34; 04/26/2006 16:55:47; 04/26/2006 16:55:48; 

04/26/2006 16:55:49; 04/26/2006 16:56:10; 04/26/2006 16:56:39; 

04/26/2006 16:56:41; 04/26/2006 16:57:04; 04/26/2006 16:57:05; 

04/26/2006 16:58:31; 04/26/2006 16:58:32; 04/26/2006 16:59:10; 

04/26/2006 17:02:14; 04/26/2006 17:02:15; 04/26/2006 17:03:01; 

X-ZANTAZ-PARTICIPANT-IMNAMES: hunteramaranth; davidchasrnan2 

X-~AZ-RECIPIENT-NAME: Brian Hunter; David Chasman 

X-ZANTAZ-PARTICIPANT-IMNAMES: davidchasman2; hunteramaranth 

X-ZANTAZ-SENDER-NAME: David Chasman; Brian Hunter 

04/26/2006 

04/26/2006 

04/26/2006 

04/26/2006 

X-ZANTAZ-GUID: 2ElC3D4C-3B31-4DB5-B3Fl~82CEA2A23FlF11113036398851880 

X-~AZ-URL: notused 

16:56:40; 

16:57:10; 

16:59:11; 

17:03:00 

X-OriginalArrivalTime·: 26 Apr 2006 17:11:35.0013 (UTC) FILETIME= [7BB7F950: 01C66954J 

IM Network: AOL n~ 

IM Users: 

participant=dchasman@amaranthllc.com "davidchasman2" 

participant"'bhunter@amaranthllc.com "hunteramaranth" 

IM Dialog: 

tiednesday, April 26, 2006 12:44:49 PM EDT David Chasman started conversation. 

Wednesday, April 26, 2006 12:44:49 PM EDT Brian Hunter has entered the conversation. 

Wednesday, April 26, 2006 12:44:49 PM EDT David Chasman: IM Administrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 12:44:49 PM EDT David Chasman: IM Adndnistrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 12:44:49 PM EDT Brian Hunter: IM Adndnistrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

~lednesday, April 26, 2006 12:4-4:49 PM EDT Brian Hunt:er: IM Administrator: NOTE: This 

session is recorded and the .recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 12:44:49 PM EDT David Chasman: hey Wednesday, April 26, 2006 

12:44:49 P.M EDT David Chasman: hey Wednesday, April 26, 2006 12:45:12 PM EDT Brian Hunter: 

hey Wednesday, April 26, 2006 12:45:12 PM EDT Brian Hunter: hey Wednesday, April 26, 2006 

12:45:45 PM EDT David Chasman: I'm seeing -40K lots summer rite now Wednesday, April 26, 

2006 12:45:46 PM EDT David Chasman: I'm seeing -40K lots summer rite now \'lednesday, April 

26, 2006 12:46:29 PM EDT Brian Hunter: June puts Wednesday, April 26, 2006 12:46:29 PM EDT 

Brian Hunter: June puts Wednesday, April 26, 2006 12:47:28 PM EDT David Chasman: what we gonna do to protect the winter position ? 

Wednesday, April 26, 2006 12:47:29 PM EDT David Chasman: what we qonna do to protect the 

winter position ? 

Wednesday, April 26, 2006 12:48:03 PM EDT Brian Hunter: ·sell cal7 and 8 \~ednesday, April 

Confidential Treatment Requested A_CFTC032874 
26, 2006 12:48:02 E'H EDT Brian Hunter: sell cal7 and B tvecinesday, April 26, 2006 12:48:04 

PM EDT Brian Hunter: and H/J Wednesday, April 26, 2006 12:48:05 PM EDT Brian Hunter: and 

H/J Wednesday, April 26, 2006 12:48:20 PM ~DT David Chasman: how much cal7 u gonna dump ? 

Wednesday, April 26, 2006 12:48:20 PM EDT David Chasman: how much ca17 u .gonna dump ? 

Wednesday, April 26, 2006 12:48:30 PM EDT Brian Hunter: rest of the week irJednesday, April 

26, 2006 12:48:30 PM EDT Brian Hunter: rest of the week Wednesday, April 26, 2006 12:48:31 

PM EDT Brian Hunter: 14k Wednesday, April 26, 2006 12:48:31 PM EDT Brian Hunter: 14k 

1-l'ednesday, April 26, 2006 12:48:48 PM EDT Br:l.an Hunter: FYI Arnold is getting scary shor~ 

into the number tomorrow Wednesday, April 26, 200~ 12:48:48 PM EDT Brian Hunter.: FYI 

Arnold. is getting scary short into the number tomorrow Wednesday, April 26, 2006 12:49:45 

PM EDT David Chasman: how many june puts we got ? 

Wednesday, April 26, 2006 12:49:45 PM EDT David Chasman: how many june puts we got ? 

Wednesday, April 26, 2006 12:50:04 PM EDT Brian Hunter: 14k Wednesday, April 26, 2006 

12:50:05 PM EDT B:~:ian Hunter: 14k Wednesda~F:id-2·&.,-2·{HM-!~·:·SfJ-:-&6-PM-eB'f. Brian Hunter. 

and adding Wednesday, April 26, 2006 12:50:07 PM. EDT Brian Hunter: and adding Wednesday, 

April 26, 2006 12:50:25 PM EDT David Chasman: what u think arnold has ? t~ednesday, April 26, 2006 12:50:26 PM EDT David Chasman: what u think arnold has.? 

Wednesday, April 26; 2006 12:50:28 PM EDT Brian Hunter: we are rolling size into may 

Wednesday, April 26, 2006 12:50:29 PM EDT Brian Hunter: we are rolling size into may 

Wednesday, April 26, 2006 12:50:42 PM EDT Brian Hunte.r: and I am worries that Anold has 

taken the other side of everything Wednesday, April 26, 2006 12:50:42 PM EDT Brian Hunter: 

and I am worries that Anold ha~ taken the other side of everything Wednesday, April 26, 

2006 12:51:00 PM EDT Brian Hunter: so either he runs it up on the close today and gets 

short tomorrow Wednesday, April 26~ 2006 12:50:59 PM EDT Brian Hunter: so either he runs 

it up on the close today and gets short tomorrow Wednesday, April 26, 2006 12:51:08 PM EDT 

Brian Runter: or has a HUGE view on the nnumber tomorrow Wednesday, April 26, 2006 

12:51:07 PM EDT Brian Hunter: or has a HUGE view on the nnumber tomorrow Wednesday, April 

26, 2006 12:51:16 PM EDT Brian Hunter: which we think is goign to be stupid bearish 

Wednesday, April 26, 2006 12:51:16 PM EDT Brian Hunter: which we think is goign to be 

stupid bearish Wednesday, April 26, 2006 12:53:03 PM EDT David Chasman: other side of 

everything-meaning buying from everyone else selling- or buying from u Wednesday, April 

26, 2006 12:53:03 PM EDT David Chasman: other side of everything meaning buying from 

everyone else selling - or buying from u Wednesday, April 26, 2006 12:53:17 PM EDT Brian 

Hunter: no buying may and selling June Wednesday, April 26, 2006 12:53:17 PM EDT Brian 

Hunter: no buying may and selling June Wednesday, April 26, 2006 12;53:18 PM EDT Brian 

Hunter: with me Wednesday, April 26, 2006 12:53:19 PM EDT Brian Hunter: with me Wednesday, 

April 26, 2006 12:54:36 PM EDT David Chasman: does he know what ur up 2 wrt to rolli~g off 

length ? 

Wednesday, April 26, 2006 12:54:36 PM EDT David Chasman: do-es he know what ur up 2 wrt to 

rolling off length ? 

Wednesday, April 26, 2006 12:54:49 PM EDT David Chasman: sorry rolling off short 

Wednesday, April 26, 2006 12:54:49 PM EDT Dav:l.d Chasman: sorry rolling off short 

Wednesday, April 26, 2006 12:55:16 PM EDT Brian Hunter: probably Wednesday, April 26, 2006 

12:55:17 PM EDT Brian Hunter: probably Wednesday, April 26, 2006 12:55:23 PM EDT David 

Chasman: anybody selling 1 day calls ? 

Wednesday, April 26, 2006 12:55:24 PM EDT David Chasman: anybody selling 1 day calls ? 

Wednesday, April 26, 2006 12:55:29 PM EDT Brian Hunter: I think its more that he thinks 

its going to get fucked. tomorrow wednesday, April 26, 2006 12:55:29 PM EDT Brian Hunter: I 

think its more that he thinks its going to get fucked tomorrow Wednesday,. April 26, 2006 

12:55:33 PM EDT Brian Hunter: that is mos~ lilely Wednesday, April·26, 2006 12:55:35 PM 

EDT David Chasman: ( other than him J Wednesday, April 26, 2006 12.:55:35 PM EDT David 

Chasman: ( other ~an him J Wednesday, April 26, 2006 12:55:34 PM EDT Brian Hunter: that 

is most li1ely Wednesday, April 26, 2006 12:55:47 PM EDT Brian Hunter: me may try to help 

it by running the market up on the close ~ednesday, April 26, 2006 12:55:47 PM EDT Brian 

Hunter: me may t:::y to help it by running the market up on the close Wednesday, April 26, 

2006 12:·55:48 PM EDT David Chasman: well, we'll find out Wednesday, April 26, 2006 

12:55:49 PM EDT David Chasman: well, we'll find out Wednesday, April 26, 2006 12:56:10 PM 

EDT David Chasman: kinda hard to do when ur selling - no ? 

Wednesday, April 26, 2006 12:56:10 PM EDT David Chasman: kinda hard to .do when ur selling - no ? 

Wednesday, April 26, 2006 12:56:39 PM EDT Brian Hunter: Arnold is the master of moving 

theclose? 

Wednesday, April 26, 2006 12:56:39 PM EDT Brian Hunter: Arnold is the master of moving 

theclose? 

Wednesday, April 26, 2006 12:56:40 PM EDT Brian Hunter: close Wednesday, April 26, 2006 

12:56:41 PM EDT Brian Hunter: close Wednesday, April 26, 2006 12:57:04 PM EDT David 

Confidential Treatment Requested A_CFTC032875 
Chasman: well in 90 minutes, we'll find out Wednesday, April 26, 2006 12:57:05 PM EDT 

David Chasman: well in 90 minutes, we'll find out We~e6day, April 26, 2006 12:57:10 PM 

EDT David Chasman: what's our may pos Wednesday, Ap-ril 26, 2006 12:57:10 PM EDT David 

Chasman: what's our may pos Wednesday, April 26, 2006 12:58:31 PM EDT David Chasman: .:: u 

done selling may yet ? 

Wednesday, April 26, 2006 12:58:32 PM EDT David Chasman: r u done selling may yet : Wednesday, April 26, 2006 12:59:10 PM EDT Brian Hunter: I think so Wednesday, April 26, 

2006 12: 5·9:11 PM EDT Brian Hunter: I thi::l.k so Wednesday, .April 26, 2006 1:02:14 PM EDT 

David Chasman: how many we short now ? · 

Wednesdayl April 26, 2006 ~:02:15 PM EDT David Chasman: how many we short now? 

Wednesday, April 26, 2006 1:03:01 PM EDT Brian Hunter: 15k Wednesday, April 26, 2006 

1:03:00 PM EDT Brian Hunter: 15k 

Confidential Treatment Requested A_CFTC032876 
From: 

Sent 

To: 

v.;ndowsadmin@amaranlhllc.com 

Wednesday, April26, 20061:22 PM 

amaranlh.dom@amaranlh.digitalsafe.net 

Subject SUBJECT: CONVERSATION PARTICIPANTS = BHUNTER@AMARANTHUC.COM: 

"TRDRXTRA" 

IH Network: Yahoo IH 

IH Users: 

participant~ohuntor@amaranthllc.com "huntcr_amaranth" 

participant~"trdrxtra" 

IH Dialog: 

Wednesday, April 26, 2006 1:22:01 ?M EDT Brian Hunter startod conversation. 

Wednesday, April 26, 2006 1:22:01 ?M EDT trdrxtra has entered the con~ersation. 

Wednesday, April 26, 2006 1:22:07 ?M EDT Brian Hunter: IM 1\.dministrator: HOT£: This 

session is recorded and thP. recording is th<) Sf)lP. pro~c:ty of A:uaranth. 

Wednesday, April 26, 2006 1:22:07 ?M £DT trdrxtr.n: IH Administra::oc:: NOT£: This session is 

recorded and the recording is the sole ?roporty oC Amaranth. 

Wednesday, April 26, 2006 1:22:07 PH EDT trdrxtra: higher or lower Nednesday, April 26, 

2006 1:22:08 ~I £DT trdrxtra: on close Wednesday, April 26, 2006 1:22:~3 PH £DT trd:xtra: 

me thinks a tad higher Wednesday, April 26. 2006 1 :23:01 PM EDT Brian llunter: I think John 

wants to bid it on close Wednesday, April 26, 2006 1:23:07 PH EDT Brian Hunter: and then 

bury it tomorrow 1-ledncsday, April 26, 2006 1:23: 1"1 PH £DT trdrxtra: i illll set up Lhat way 

Wednesday, April 26, 2006 1:23:27 PH £DT Bria~ Hunter: I think market is Wednesday, April 

26, 2006 1:23:43 l'H EDT Briar. Hunter: that's why I a touch worried about a lon'Or close 

Wednesday, April· 26, 2006 1:23:54 PM EDT t.rdrxtra: ho just. sold 500 Wednesday, April 26, 

2006 1:23:59 I'l-l EDT trdrxtra: 7 samo days Wednesday, April 26, 2006 1:2'1:09 PM E:DT 

trdrxtra: i think 1-lednesday, April 26, 2006 1:24:11 PI-I EDT trdrxtra: it was him Wednesday, 

April 26, 2006 1:24:24 FM £DT trdrxtra: 1-.m Wednesday, Apdl 2~, 2006 1:24:27 PM £DT 

trdrxtra: any opinion Wednesday, April 26, 2006 1:26:0) ~I EDT Brian Hunter: not really 

Wednesday, April 26, 2006 1:26:13 PM EDT Brian lluut ... r: .John is long may like c:t·at.y 

1-tednesday, Ap~il 26, 2006 1:26:21 ?M £DT Brian Hunl~r: shot·t June like crazy Wednesday, 

April 26, 2006 1:7.6:2S FH tOT Brian Hunter: that's~ good indica~i~n wednesday, April 26, 

2006 1:26:58 FI-t £DT trdrxtra: dood Wednesday, Apri I 26, 7.006 1:27:01 FM F:OT trdr~<t.rn: good 

Wednesday, 1\pril 21;, 2006 1:27:02 ?H E:DT trdrxtrll: i guess Nednesday, April 26, 2006 

1:27:3!) I'M EDT trdrxtra: it is almost too obvious Wednesday, npril 7.6. 2006 1:27:43 FH ED'i' 

trdrxtra: this happened a couple of months ago Wednesday, April 26, 2006 1:27:49 PH EDT 

Brian Hunter: I remember l-lodnesday, Apri 1 26, 2006 1:28:00 PM E.DT Brian Hunter: we bought 

l!>k june 7.25 put:J yesterday Wednesday, April 26, 2006 1:29:10 PH £UT Brian lluntor: so 

we'll see how that goes Wcdnesd.:'ly, April 26, 2006 1:29:33 P,., EDT trdrxtra: holy crap 

Wednesday, April 26, 2006 1:31:15 PM EDT trdrxtra: you are not afraid to spend premium 

wednesday, April 26, 2006 l:jl:J6 PH E:DT Brian Hunter: this thing has to qiv ein the front 

wednesday, April 26, 2006 1:31:41 PH EDT Brian Hunter: at some point Wednesday, April 26, 

2006 1:31:47 Ftl EDT trdrxtra: pira Wednesday, April 26, 2006 1:31:48 EM £DT Brian Uuntor: 

if not this conth Wednesday, April 26, 2006 1:31:50 PH EDT Brian Hunter: then next 

Wednesday, April 26, 2006 1:31:56 ~roT trdrxtra: said we have to get into shut in levels 

Wednesday, April 21;, 2006 1:32:00 PM rDT Brian flw1ter: coal Wlidnesday, April 26, 2006 

1:32:00 PH EDT trdt·xtra: like 91 Wednesday, April 26, 20061:32:02 PI-t EDT Bl"ian Hunter: t 

think Wednesday, April 7.6, 2006 1:32:04 FH r.tr. Bt"iiln llunter: not shut in Wednesday, April 

26, 2006 1:32:04 FH EDT trdrxtra: to spur dmoand ~lednesdny, April 26, 2006 1:32:09 I'M EDT 

tr~rxtra: 550 Wednesday, April 26, 2006 1:32:12 FH EDT trdrxtra: is coal Wednesday, April 

26, 2006 1:32:14 FM EDT trdrxtra: in che east Wednesday, April 26, 2006 1:32:21 AM EDT 

Brian Hunter: yeah 5.00 mere Wednesday, April 26, 2006 l :32:25 E'H EDT Brian llunter: long 

way Wednesday, April~&. 7.006 1:32:44 PH EDT lt·drxtra: i bought the 8/"11& lly Wcd.nusday, 

April 25, 2006 1:32:45 I'M EDT t rdrxt ra: in v 

CONADENTIALTREATMENTREQUESTED AALLC_REG0593127 
From: 

Sent: 

To: 

windowsadmin@amaranthllc.com 

Wednesday, April26, 20061:46 PM 

amaranth.dom@amaranth.dlgitalsafe.net 

Subject: SUBJECT: CONVERSATION PARTICIPANTS= DCHASMAN@AMARANTHLLC.COM; 

BHUNTER@AMARANTHLLC.COM 

IM Network: AOL IM 

IM Users: 

pa.rtlcipant=dchasman@amaranthllc. com "davidcha:sman2'' 

part:icipant=bhunter.@amaranthllc.com "hunteramarantb" 

IM Dialog: 

Wednesday, April 26, 2006 1:45:58 PM EDT David Chasman sta~ted conversation. 

Wednesday, April 26, 2006 1:45:58 PM EDT Brian Hunter has entered the conversation. 

Wednesday, ApJ:i.1 26, 2006 1:45:58 PM EDT David Chasman: IM Administratoc: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 1:45:56 PM EDT David Chasman: IM Administrator: NOTE: This 

session is recorded and the ~ecording is the sole property of Amaranth. 

Wednesday, April 26, 2006 1:45:5.8 P!1 EDT Brian Hunter: IM Administrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 1:45:58 PM EDT Brian Hunter: IM Administrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 1:45:58 PM ~DT David Chasman: seeing anything yet ? 

Wednesday, April 26, 2006 1:45:58 PM EDT David Chasman: seeing anything yet ? 

Wednesday, April 26, 2006 1:46:52 PM EDT Brian Hunter: not yet Wednesday, April 26, 2006 

1:46:52 PM EDT Brian Hunter: not.yet Wednesday, April 26, 2006 1:46:57 PM EDT Brian 

Hunter: trying to get some back stuff done Wednesday, April 26, 2006 1: 46:·58 PM EDT Brian 

Hunter: trying to get some back stuff done Wednesday, April 26, 2006 2:01:46 PM EDT Dav~d 

Chasman: bingo Wednesday, April 26, 2006 2:01:46 PM EDT David Chasman: bingo Wednesday, 

April 26, 2006 2:02:17 PM EDT Brian Hunter: seem$ to be that way so far Wednesday, April 

26, 2006 2:02:18 EM EDT Brian Hunter: seems to be that way so far Wednesday, April 26, 

2006 2:02:25 PM EDT BrianHunter: defintely buyers Wednesday, April 26, 2006 2:02:25 ?M 

EDT Brian Hunter: defintely buyers Wednesday, April 26, 2006 2:02:28 PM EDT Brian Hunter: 

but we have yet to sell Wednesday, April 26, 2006.2:02:28 PM EDT Brian Hunter: but we have 

yet to sell 

Confidential Treatment Requested A_ CFTC032878 
From: 

Sent: 

To: 

Subject: 

IM Network: AOL IH 

IM Use:s: 

windowsadmin@amaranthllc.com 

Wednesday, April 26. 2006 2:07 PM 

amaranth.dom@amaranth.digitalsafe.net 

SUBJECT: CONVERSATION PARTICIPANTS= "CALLIFRNICATION"; 

UHUNTERAMARANTHA 

participant="callifrnication•• 

participant="hunte:::amaranth" 

IM Dialog: 

Wednesday, April 26, 2006 2:06:30 PM EDT Matthew Calhoun started conversation. 

Wednesday, April 26, 2006 2:06:30 PM EDT Brian Hunter has entered the conversation. 

Wednesday, April 26, 2006 2:06:30 PM EDT Matthew Calhoun: IM Adminiatrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 2:06:30 PM EDT Matthew calhoun: IM Administrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

wednesday, April 26, 2006 2:06:30 PM EDT Brian Hunter: IM Administrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 2:06:30 PM EDT Brian Hunter: IM Administrator: NOTE: This 

session is recorded and the recording is the sole property of Amaranth. 

Wednesday, April 26, 2006 2:06:30 PM EDT Matthew Calhoun: ja Wednesday, April 26, 2006 

2:06:30 PM EDT Matthew Calhoun: ja t'lednesday, April 26, 2006 2:06:36 PM EDT Matthew 

Calhoun: workin hard Wednesday, April 26, 2006 2:06:37 PM EDT Matthew Calhoun: workin hard 

Wednesday, April 26, 2006 2:06:43 PM EDT Brian Uunter: oh yeah Wednesday, April 26, 2006 

2:06:45 ?M ~DT Brian Hunter: its all good Wednesday, April 26, 2006 2:06:44 PM EDT Brian 

Hunter: oh yeah Wednesday, April 26, 2006 2:06:46 PM EDT Brian Hunter: its all good 

Wednesday, April 26, 2006 2:06:52 PM EDT Brian Hunter: we are finally selling h>j's etc .•• 

Wednesday, April 26, 2006 2:06:52 PM EDT Brian Hunter: we are finally selling h>j's etc .•• . Wednesday, April 26, 2006 2:06:55 PM EDT Brian Hunter: cals Wednesday, April 26, 2006 

2:06:55 ~ EDT Brian Hunter: cals Wednesday, April 26, 2006 2:06:58 PM EDT Brian Hunter: 

we are wating to sell Wednesday, April 26, 2006 2:06:58 PM EDT Brian Hunter: we are wating 

to sell Wednesday, April 26, 2006 2:07:03 PM EDT Matthew Calhoun: yup Wednesday, April 26, 

2006 2:07:04 PM EDT Matthew Calhoun: yup 

Confidential Treatment Requested A_CFTC032910 
EXHIBITB 
New York Me~tile Exchange 

Via E-mail and USPS 

Mike Carricri 

Chief Compliance Officer 

Amaranth LLC 

One American Lane 

Greenwich. cr 0683 J 

Dear Mr. Carrieri: 

August 2. 2006 

The Compliance Department of the New York Mercantile Exchange ("Exchangej 

has comm~mccd lDvcstigatioD Number MS-04-06 to tl)view Amaranth LLC's ("Amaranth.,) 

NYMEX NatutaJ Gas futures trading activity for trade date April 2.6, 2006. Exchange 

records indicated a heavy concentration of Amuanth's May 2006 Natnrnl Gas ("NG") 

futures trading activity occtured in the final minutes prior to the tennination of trading in the 

GOnttaCL 

Specifically. Amarnnth sold 2,527 futures contracts during the finaJ 30 minutes of 

regular crading hours. Of these 2,527 contracts, Amaranth sold 99%, or 2,517 contracts, 

during tbc fi1lal four minutes of regular muiing hours. Of these 2.S) 7 contmc~ Amaranth 

sold 75%; or 1,897 contracts. during the final minute of regular tnlding hours. Amaranth 

fur1ber sold 517 contracts during the "post-close" troding session. 

The Exchange requests that Amaranth :cview its May 2006 NO trading activity for 

trade date April 26, 2006, and provide a wrinen explanation of the commercial need and 

justification for their trading. Plense submit your explanation on or before August 15, 2006. 

Should you bave any questions concerning this matter, please conrac1 the undersigned at 

(211) 299-2881. 

cc: Nancy M. Minctt 

Bonnie H. Yurga 

CoreyTmub 

MS-04-06 

N""' York Maaoal: Ez.t:lungc, ~ 

Wad:! FinaPdal Caner 

One Ncn:h End Awa.uc 

New Yo:lt. NY' l02BH l 01 

(:Z12) :ZIJ9.2000 

Tht Ht» Tcwi MnuarU. EMI"~'I!I'• lrtt., " '""'!•IU ofrwo liiPiniMt 

Thr NTMEX DiPiJilm ojfrm rrNinaon mNi• r~~l, llftari>O.!f ~1, -~IARasol.,ot, 

"""'roaiB"'· •lurrUU,, ttl<ll, i""'P"'"'· pia~'-"'• •...t p4114Ji,.,.. Thr COMEX Vi-ru""' 

•lftrt rnr;4bo,e '" ,,u, tilpar, "'""'· -~~ ..; .......... ... 
EXHIBIT C 
August 15, 2006 

Mr. ADthony Densieski 

Senior Director 

Market Surveillance 

.New York Mercantile Exchange 

World FiDancial Center 

One North End Avenue 

NewYork,NY 10282-1101 

Re: MS-04-06 

Dear Mr. Dcnsieski: 

/a/Amaranth one American une G~dlcr06831 

T 203 4213300 

F 203 42135110 

I am writing regarding the above-referenced matter in response to your letter to Amaranth 

LLC ("ADiarcmth") dated ~gusi ~ 2006, in which you requested that Amaranth explaili 1he 

commercial.need and justification for its trading in the NYMEX May 2006 Natural Gas futures 

con1ract ("NG") on April26, 2006. Because tbis letter contains confidential and proprietary 

information conceming Amaranth's positions and trading strategies; we respectfully request that 

NYMEX protect the confidcotiaJi:ty of such information and. that it be. only disclosed to 

employees and officials ofNYMEX on a "need to know" basis. 

Amaranth is a m.ulti-s1mtegy fund that had approximately $8.7 billion in capitDl as of the 

end of April 2006. · Among its ~gies is energy 1mding, which typically involves 1Dking 

positions in variOl.lS energy derivatives, including =xclumge trade4 futures, options on :futures, 

OTC forwards,. swaps, and options on a bi1atcral .and clemed basis. Amaranth does not 1rade 

physical natural uDs· Amaranth has not, to-date, ever made or taken delivery under NG · 

contmcts, but has al~s closed out such conttacts prior to the teunination of 'trading. 

Amaranth seeks tO ensure that its trailing activities, including the liquidation of open NG 

cantmcts during the spot month, are con.ducm:d in lin onierly :fashion so as not to disrupt the 

market Amamnth's trading of natural gaS derivatives. includi:Dg NG con~ is based upon its 

evaluation of fundamental market factOrs and fmecasts relating 1D global and local production, 

storage, inventory, distribution, and consumption affecting the price of naturai gas. 

In April2006, as in the preceding several months, .Amaranth's prlmmy natural gas trading 

strategy was to hold.long winter month positions aud short SUDlDlel' month positions (which 

consisted of NG, ICE OTC Cleared, OTC and ClearPort Contracts). This strategy ~ been 

successful, particularly in April. Consequem:ly, Amaranth had be~ to contemplate efficient 

strategies to reduce its holdings. One c1fective strategy bad been to sell winter positions and · 

. cover slwrt summer positions by allowing financially settled swaps to expire and by either 

selling or rolling :futures prior to their expiration. 
Mr. Anthony Densieski 

August 15, 2006 

Page2 · 

Here's one way you might employ this strategy. As the end of April approaches, the goal 

is to reduce your short May positions and your long winter positions. Eliminating the May 

positions that expire in April is easy beC:anse you can hold.short positions in financially settled 

May swaps that do not require any expiration day trading. To eliminate winter. positions, you 

need to =ecnte trades in the markets, and it is challenging to set a precise position size schedule. 

On cxpimtion day, say you could confidently estimate the largest number of winter positions you 

thought you could eliminate. You would want to have a conesponding short position in 

financi.ally settled swaps that would expire the same day. In order to accommodate the 

Uncertainty regarding the actual number of winter contracts sold, you can hold some May NG 

contracts. These contracts give you the :flexibility to adjust the amount your short summer 

position decreases. If you sell the maximum number of winter contracts, you simply roll your 

long May futures position forward Qeaving your full financially settled swap position to expire). 

If you sell fewer winter contracts, you sell your May futures iDstewL 

By April 26, Amaranth had established short positions of approxim.alely 10,000 

financially settled May ICE swaps and 3,000 financially settled May ClearPort swaps, and a long 

position of3,044 May NG contracts. Using the logic described above, this gave Amaranth the 

ability to reduce its summer/winter spread holdings by as little as 10,000 lots (by selling the May 

contracts prior to expiry) and as many as approximately 13,000 lots (by rolling the May contracts 

forward). 

Amaranth monitored the winter natmal gas market on April 26th hoping to sell winter, 

and roll the long May NG to June on a spread. Towards the end of the trading day it became 

apparent that Amaranth would not be able to sell the winter contracts at attractive prices. Thus, 

· .Amanmth decided (to the best ofitS recollection), at some time between approximately 2:17-2:23 

p.m., to·sell the May NG contracts outright. Dming this period Amaranth placed three orders 

aggregating a total of 3,044 May NG contracts with three different NYMEX :floor brokf:rs 

{approximately 2000 contracts with ALX. 500 contracts with Gotham and 500 contracts with 

TFS) with the instruction to sell the contracts before the close at the best possible prices. 

Therefore, the timing of the execution of the trades in the tmding pit was at the discretion of 1he 

floor brokers. 

If any of Amaranth's orders were executed in the post-close session, that was not due to 

.Amar.mtlts iDstructions to do so, but perimps occu:aed because a :lloor broker cnoneously failed 

to comply with Amaranth's instructions to complete the execution of its orders prior to the close. 

As noted above, Amaranth historically has not made or taken delivery under NG COlltracts and 

thus would not want to take the risk of its orders not being filled prior to the close of trading. 

In conclusiori, Amaranth's 1mding ofMay NG contracts during the close of the May NG 

market was motivated by the desire to achieve an aggregate reduction in the risk ofits portfolio. 
:• 

Mr. Anthony Densieski 

August 15, 2006 

Page3 

Please feel free to contact me at 203-422-3317 should you have any questions ICglll'ding 

. the infDIIDation in this letter. 

cc: Nancy M. Minett 

Bonnie H. Ylirga 

Corey Traub 

Michael Cmieri 

Compliance Director 

Michael Philipp, W'JDSton .& Strawn LLP