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Commodity Futures Trading Commission 

CEA CASES 

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

DOCKET NUMBER: 137 

DATE: NOVEMBER 4, 1966 

DOCUMENT TYPE: AMENDED 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 

Amended Complaint and Notice of Hearing 

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 amended 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. Respondent J. H. Kent was at all times 

material herein the father-in-law of respondent Edward C. Epperson and of Robert 

C. Wood and Rebecca Kent, not respondents herein, and a general partner in a 

partnership doing business under the firm name of J. H. Kent Co., not a 

respondent herein. 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 Chicago Board of Trade and the New York Mercantile Exchange are now and 

were at all times material herein duly designated contract markets under the 

Commodity Exchange Act. The trades and positions in wheat and soybean futures 

hereinafter referred to were on or subject to the rules of the Chicago Board of 

Trade, The trades and positions in potato futures hereinafter referred to were 

on or subject to the rules of the New York Mercantile Exchange. 

IV 

During the period from November 22, 1965, through September 19, 1966, the 

respondents had an expressed or implied agreement or understanding among 

themselves that: (1) respondents The Kent Co. 
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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 

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 April 5, 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 April 5, 1966, held net long speculative positions in various 

wheat futures which, combined, ranged from 2,190,000 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 July 11, 1966, 

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

combined, ranged from 2,375,000 bushels 

to 4,000,000 bushels; (6) during the period from January 11 through April 14, 

1966, held net long speculative positions in the September 1966 soybean future 

which, combined, ranged from 2,210,000 bushels to 3,500,000 bushels; (7) during 

the period from June 14 through September 13, 1966, held net long speculative 

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

2,375,000 bushels to 3,800,000 bushels; and (8) during the period from July 12 

through September 19, 1966, held net long speculative positions in various 

soybean futures which, combined, ranged from 2,175,000 bushels to 3,900,000 

bushels. 

VI 

During the period July 26 through October 12, 1966, respondents J. H. Kent 

and Edward C. Epperson had an expressed or implied agreement or understanding 

that J. H. Kent Co, and Edward C, Epperson, in conjunction with Rebecca Kent and 

Robert C. Wood, would make speculative trades and hold speculative positions in 

potato futures on the New York Mercantile Exchange in accordance with a common 

trading plan. Pursuant to and in accordance with such agreement or 

understanding: (1) on July 26, 1966, J. H. Kent Co. and Rebecca Kent made 

speculative purchases of 100 carlots and 85 carlots, respectively, in the May 

1967 potato future which resulted in a combined net long speculative position of 

185 carlots in such future; 

(2) on July 29, 1966, J. H. Kent Co. and Rebecca Kent made speculative purchases 

of 50 carlots and 65 carlots, respectively, in the May 1967 potato future which 

resulted in a combined net long speculative position of 300 carlots in such 

future; (3) on August 1, 1966, Edward C. Epperson and Robert C. Wood made 

speculative purchases of 150 carlots and 144 carlots, respectively, in the May 

1967 potato future which resulted in a combined net long speculative position of 

594 carlots in such future; (4) from August 1 through October 12, 1966, J. H. 

Kent Co., Edward C. Epperson, Rebecca Kent and Robert C. Wood held net long 

speculative positions in the May 1967 potato future which, combined, ranged 

between 264 carlots and 600 carlots; (5) on August 12, 1966, J. H. Kent Co., 

Edward C. Epperson, Rebecca Kent and Robert C. Wood each made speculative 

purchases of 100 carlots in the April 1967 potato future which resulted in a 

combined net long speculative position of 402 carlots in such future; (6) from 
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August 12 through October 12, 1966, J. H. Kent Co., Edward C. Epperson, Rebecca 

Kent and Robert C. Wood held net long speculative positions in the April 1967 

potato future which, combined, ranged between 292 carlots and 473 carlots; (7) 

from August 1 through October 13, 1966, J. H. Kent Co., Edward C. Epperson, 

Rebecca Kent and Robert C. Wood held net long speculative positions in all 

potato futures combined on the New York Mercantile Exchange which, in the 

aggregate, ranged between 556 carlots and 1,070 carlots. 

VII 

By reason of the facts described in this complaint, the respondents (1) 

traded in wheat, soybeans and potatoes for future delivery in amounts which 

resulted in positions in excess of the maximum permissible limit in each such 

commodity, and (2) exceeded the maximum permissible limit on the daily amount of 

speculative trading in soybeans and potatoes 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, soybeans and potatoes for future delivery (17 CFR. 150.1, 

150.4, 150.10). 

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

hearing be served upon the said respondents. The respondents will have twenty 

(20) days after the receipt of the order granting the motion to file this 

amended complaint, if such motion is granted, 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 this 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 a.m., local time, on the 20th day of December, 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. 

Done at Washington, D. C. 

November 4, 1966. 

[SEE SIGNATURE IN ORIGINAL] 

Assistant Secretary 

George L. Mehren 

LOAD-DATE: June 12, 2008 
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