Page 1 

Commodity Futures Trading Commission 

CEA CASES 

NAME: J. H. KENT, THE KENT CO., AND EDWARD C. EPPERSON 

DOCKET NUMBER: 137 

DATE: MAY 4, 1966 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: J. H. Kent, The Kent Co., and Edward C. Epperson, Respondents 

CEA Docket No. 137 

Complaint and Notice of Hearing Under Section 6(b) of the Commodity Exchange 

Act 

There is reason to believe that the respondents, J. H. Kent, The Kent Co., 

and Edward C. Epperson, have violated the provisions of the Commodity Exchange 

Act (7 U.S.C. 1 et seq.), and the rules and regulations issued thereunder (17 

CFR, Part I), and in accordance with the provisions of section 6(b) of the said 

act (7 U.S.C. 9), this complaint and notice of hearing is issued stating the 

charges in that respect as follows: 

I 

Respondent J. H. Kent is an individual whose mailing address is Post Office 

Box 157, Greenville, Mississippi. He was at all times material herein the 

managing partner in a partnership doing business under the firm name of The Kent 

Co., whose mailing address is the same as that of respondent J. H. Kent. At all 

such times respondent J. H. Kent managed and controlled the said firm's trading 

in commodity futures. 

II 

Respondent Edward C. Epperson is an individual whose mailing address is Post 

Office Box 157, Greenville, Mississippi. He was at all times material herein an 

employee of respondent The Kent Co. 

III 

The Board of Trade of the City of Chicago was at all times material herein a 

duly designated contract market under the Commodity Exchange Act. All trades 

and positions hereinafter referred to were in commodity futures on the Board of 

Trade of the City of Chicago. 

IV 

During the period from November 22, 1965, through February 28, 1966, the 

respondents had an expressed or implied agreement or understanding among 

themselves that: (1) respondents The Kent Co. and Edward C. Epperson would make 

trades and hold speculative positions in grain futures on the Chicago Board of 

Trade; (2) respondent J. H. Kent would finance the trading activities of 

respondent Edward C. Epperson with money belonging to respondent The Kent Co.; 

and (3) the trading done and positions held by respondent Edward C. Epperson and 

respondent The Kent Co. would follow a trading plan determined by respondent J. 

H. Kent. 

V 
Page 2 

Acting pursuant to or in accordance with the agreement or understanding 

referred to in paragraph IV above, respondents The Kent Co. and Edward C. 

Epperson: (1) during the period from December 20, 1965, through February 28, 

1966, held net long speculative positions in the May 1966 wheat future which, 

combined, amounted to 2,150,000 bushels; (2) during the period December 20, 

1965, through February 28, 1966, held net long speculative positions 

in various wheat futures which, combined, ranged from 3,400,000 bushels to 

4,000,000 bushels; (3) on January 11, 1966, made aggregate speculative sales of 

2,850,000 bushels in the August 1966 soybean future; (4) on January 11, 1966, 

made aggregate speculative purchases of 2,850,000 bushels in the September 1966 

soybean future; (5) during the period from January 11 through February 28, 1966, 

held net short speculative positions in the August 1966 soybean future which, 

combined, ranged from 2,950,000 bushels to 4,000,000 bushels; and (6) during the 

period from January 11 through February 28, 1966, held net long speculative 

positions in the September 1966 soybean future which, combined, ranged from 

2,950,000 bushels to 3,500,000 bushels. 

VI 

By reason of the facts described in this complaint, the respondents traded in 

wheat and soybeans for future delivery on a contract market in amounts which 

resulted in positions in excess of the maximum permissible limit of 2,000,000 

bushels in each such commodity, and exceeded the maximum permissible limit of 

2,000,000 bushels on the daily amount of speculative trading in soybeans for 

future delivery, in willful violation of section 4a of the Commodity Exchange 

Act (7 U.S.C. 6a), and the orders of the Commodity Exchange Commission 

establishing limits on positions and trading in wheat and soybeans for future 

delivery (17 CFR 150.1, 150.4). 

WHEREFORE, it is hereby ordered that this complaint and notice of hearing be 

served upon the said respondents. The respondents will have twenty (20) days 

after the receipt of this complaint in which to file with the Hearing Clerk, 

United States Department of Agriculture, Washington, D. C. 20250, an answer with 

an original and five copies, fully and completely stating the nature of the 

defense and admitting or denying, specifically and in detail, each allegation of 

this complaint. Allegations not answered will be deemed admitted for the 

purpose of this proceeding. Failure to file an answer will constitute an 

admission of all the allegations of this complaint and a waiver of hearing. The 

filing of an answer in which all of the material allegations of fact contained 

in the complaint are admitted likewise shall constitute a waiver of hearing 

unless a hearing is requested. The respondents are hereby notified that unless 

hearing is waived, a hearing will be held at 10:00 am., local time, on the 14th 

day of June 1966, in Greenville, Mississippi, at a place therein to be specified 

later, before a referee designated to conduct such hearing. At such hearing, 

the respondents will have the right to appear and show cause, if any there be, 

why an order should not be made directing that all contract markets refuse all 

trading privileges to each respondent for such period of time as may be 

determined. 

It is ordered that this complaint and notice of hearing be served on the 

respondents at least twenty (20) days prior to the date set for hearing. 

Done at Washington, D.C. 

May 4, 1966 

[SEE SIGNATURE IN ORIGINAL] 

Assistant Secretary 

LOAD-DATE: June 12, 2008 
Page 3