UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Commodity Futures Trading Commission, 

Plaintiff,

v. 

Long Leaf Trading Group, Inc., James A. 

Donelson, Timothy M. Evans, Jeremy S. 

Ruth, and Andrew D. Nelson, 

Defendants.

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Case No. 20-3758 

Hon. Thomas A. Durkin 

MOTION FOR ENTRY OF SUPPLEMENTAL RELIEF AGAINST DEFENDANTS 

DONELSON, LONG LEAF TRADING, AND RUTH1

Having prevailed on its motion for summary judgment against Defendants Donelson, 

Long Leaf Trading Group, Inc. (“Long Leaf Trading”), and Ruth (together, “Defendants”), 

Plaintiff Commodity Future Trading Commission (“CFTC”) now seeks entry of injunctive relief 

and a civil monetary penalty (“CMP”) against those defendants, as authorized by 7 

U.S.C.§ 13a-1. Defendants’ participation in a years-long, multimillion-dollar options fraud 

scheme justifies an injunction against the trading or ownership of commodity interests, i.e., 

commodity futures, options, or swaps, as well as an injunction against applying for or acting in 

the capacity of a CFTC registrant. It also justifies imposition of the maximum civil monetary 

penalty allowable under 7 U.S.C. § 13a-1, which here is triple Defendants’ ill-gotten gains. The 

foregoing relief is necessary to protect the public and the commodity markets from Defendants, 

 

1 Defendant Ruth and counsel for Defendant Donelson have advised the CFTC that they plan to oppose this motion. 

Counsel for Defendant Long Leaf Trading did not respond to the CFTC’s email. 

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as well as to punish Defendants and deter them (and other would-be fraudsters) from future 

violations of the Commodity Exchange Act (“Act”) and CFTC Regulations.

A. The Court Should Enter a Permanent Injunction Against Defendants.

The CFTC seeks an order permanently enjoining Defendants from engaging in: (a) 

substantially any activity relating to commodity interests2, i.e., a “trading ban;” (b) applying for 

registration or acting in a capacity that requires registration by Defendants, i.e., a “registration 

ban;” and (c) further violative conduct of the kind described in the Complaint. (Doc. 1., Compl. 

at 30-31.) 7 U.S.C. § 13a-1(b) provides that a permanent injunction may be entered against a 

defendant found to have committed a violation of the Act or Regulations upon a showing that 

there is “some reasonable likelihood of future violations” by the defendant. CFTC v. Hunt, 591 

F.2d 1211, 1220 (7th Cir. 1979) (holding that district court erred in failing to enter injunction 

against defendants). In assessing the likelihood of future violations, courts consider:

• the “egregiousness” of a defendant’s actions;

• whether the past misconduct was “founded on systematic wrongdoing, rather than 

an isolated occurrence;”

• the “degree of scienter” involved;

• whether a defendant has continued to maintain that his or her conduct was 

“blameless,” or otherwise failed to recognize “the wrongful nature of [the 

defendant’s] conduct;” and

• whether a defendant, because of his or her “professional occupation or career 

interest,” may once again be in a position to commit violations.

See, e.g., id.; CFTC v. Wilshire Inv. Mgmt. Corp., 531 F.3d 1339, 1346 (11th Cir. 2008) 

(affirming trading ban). These factors are present for Defendants, and militate strongly in favor 

of permanent injunctive relief. 

 2 “Commodity interests” is defined to mean any commodity future, option, or swap transaction. 17 C.F.R. 

§ 1.3.

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1. The Court Should Enter a Permanent Injunction, Including a Trading and 

Registration Ban, Against Defendant Donelson. 

a. Donelson willfully defrauded customers. 

Defendant Donelson was the principal of Long Leaf Trading from December 2017 

through December 2019. (Doc. 106, Order on CFTC’s Mot. for Summ. J. (hereinafter, “S.J. 

Order”) at 5.) During that time, Donelson willfully misled customers as to past results and 

potential profits from Long Leaf Trading’s options trading program. (See id. at 12-17.) 

Donelson knew that substantially all customers lost money participating in the program. 

(Id. at 5-6.) Donelson nonetheless failed to provide this information to customers, and expressly 

instructed his sales staff to withhold it from customers who asked. (Id. at 14-15.) Instead of 

telling customers the truth, Donelson provided customers with “track records” reflecting a subset 

of profitable trades while omitting the much larger universe of Long Leaf’s losing trades. (Id. at 

16.) Donelson knew that his sales staff were telling customers and prospective customers that 

Long Leaf “targets” returns of six to twelve percent, and enjoys a “statistical advantage,” and 

that those statements were highly misleading. (Id. at 17.) Donelson did nothing to prevent this. 

(See id.) Donelson also misled customers about his trading experience, intimating that he had a 

decade of experience with large trading firms when in fact he had substantially no personal 

trading experience. (Id. at 16.) 

b. There is a reasonable likelihood of future violations by Donelson. 

The facts of the case suggest a reasonable likelihood of future violations by Donelson. 

Donelson’s conduct is egregious by any standard. Donelson’s violations are not isolated, and 

took place in the over the course of two years’ worth of systematic wrongdoing. Donelson’s 

conduct evidences a high level of scienter, which the Court expressly found. (See id. at 14-17 

(finding scienter).)

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Donelson appears to believe that his conduct is blameless. Rather than admit 

wrongdoing, Donelson has continued to litigate the case through summary judgment. Moreover, 

Donelson’s positions on summary judgment—e.g., that Long Leaf’s false and misleading 

statements to customers were merely “hypothetical”—may reflect an earnest belief that his 

conduct is permissible.

Nothing in the record suggests that Donelson has attempted, or even expressed a desire, 

to repay Long Leaf’s customers. Donelson has, however, paid a series of lawyers to press his 

meritless defenses in this case, as well as an expert witness whose opinion the Court 

appropriately disregarded. (Docs. 14, 16, 40, 93, Appearances for Attorneys Landsman, 

Iavarone, Falvey, and McElvenny; Doc. 96.3, Burnside Decl.)

Donelson’s professional occupation and career interests have the potential to place him in 

a position where he may once again violate the Act or Regulations. Donelson previously worked 

for large proprietary trading firms. (Doc. 106, S.J. Order at 16.) The fact that he did so as an 

accountant is of no moment—Donelson’s career has, for more than a decade, been in the 

financial industry, and in particular, with trading firms. 

Donelson continues to work in the financial industry through the present day. Since 

Long Leaf Trading ceased operations, Donelson has started a new business venture relating to 

“middle office software for trading.” (Doc. 82.4, Donelson Test. 9:20–10:7; see also Doc. 82.5, 

Donelson Dep. 217:24–218:9.) Donelson’s post-Long Leaf work has also included consulting 

engagements with at least three trading firms, including a cryptocurrency trading firm. (Doc 

82.5, Donelson Dep. 217:5–219:10.) Donelson’s current LinkedIn profile extols his trading-firm 

bona fides, with the notable omission of his tenure at Long Leaf. (Ex. A, “Jim D.” Linkedin

Profile, available at https://www.linkedin.com/in/jim-donelson/ (last visited Aug. 12, 2022).) 

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The profile touts Donelson’s acumen in the areas of “innovative performance management and 

financial solutions.” (Id.) Given Donelson’s conduct at Long Leaf, it seems unlikely that his 

innovative performance management or financial solutions will inhere to the benefit of future 

customers or markets regulated by the CFTC. 

c. A trading and registration ban, as well as an injunction against 

further misconduct, is appropriate to prevent future violations by 

Donelson.

On the basis of the foregoing, the CFTC respectfully requests that the Court impose the 

injunctive relief sought in the Complaint. (Doc. 1 at 29–33 (itemizing requests in prayer for 

relief).) This relief includes a “trading ban,” i.e., an injunction banning Donelson from trading 

commodity interests, for his own account, directly or indirectly, or on behalf of others, or on or 

subject to the rules of any entity registered with the CFTC, e.g., a registered futures or options 

exchange, or from soliciting or accepting any funds for the purpose of trading commodity 

interests. The requested relief also includes a “registration ban,” to wit, an injunction against 

applying for, engaging in engaging in conduct that would require, or claiming an exemption from 

registration with the CFTC in any capacity, or acting as principal, agent, or other employee of a 

registered entity, or entity required to be registered. Finally, the requested relief includes an 

injunction against further conduct of the sort described in the Complaint. 

Because the Court has found Donelson’s conduct to be in violation of the Act and 

Regulations, it is appropriate that an injunction should issue to prevent further violations of the 

same sort. It is also appropriate for the Court to issue a trading and registration ban against 

Donelson. This is what courts typically impose in fraud cases, and it is what the Court should 

impose here. See, e.g., Wilshire, 531 F.3d at 1343, 1346-47 (affirming injunction against 

engaging in any commodity-related activity, including soliciting new customers ); CFTC v. 

McDonnell, 332 F. Supp. 3d 641, 726 (E.D.N.Y. 2018) (entering trading and registration bans

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against defendant involved in fraudulent virtual currency scheme); CFTC v. Harrison, 255 F. 

Supp. 3d 645, 646 (D.S.C. 2015) (“Because fraud is one of the primary threats to market 

integrity, many district courts ... have imposed permanent bans on market activity in response to 

the same types of fraudulent conduct engaged in by Defendant.”); CFTC v. Hunter Wise 

Commodities, LLC, 21 F. Supp. 3d 1317, 1352 (S.D. Fla. 2014) (entering trading and registration 

bans against defendants involved in off-exchange precious metals fraud scheme); CFTC v. 

Driver, 877 F. Supp. 2d 968, 982 (C.D. Cal. 2012) (entering trading and registration bans against 

defendants involved in commodity pool fraud scheme), aff’d, F. App’x 366 (9th Cir. 2014). 

Failing to impose trading and registration bans would make it possible for Donelson to commit 

further violations of the Act and Regulations.

Donelson’s conduct at Long Leaf Trading evidences a high level of scienter. As such, 

Donelson “cannot be trusted to operate only on his own behalf in a lawful and honest way.” See 

McDonnell, 332 F. Supp. 3d at 726. If Donelson is permitted to trade, even just for his own 

account, he may engage in disruptive or manipulative trading practices. He may also be tempted 

to engage in “pool fraud,” a common scheme in which a fraudster solicits investments from 

others and trades (or misappropriates) those investments through the fraudster’s own account. 

See, e.g., CFTC v. Kholamian, No. 18-CV-0797, 2022 WL 1577229 (N.D. Ill. Mar. 21, 2022)

(consent order in pool fraud case). Donelson should be precluded from participation in all 

markets regulated by the CFTC.

2. The Court Should Enter a Permanent Injunction Against Long Leaf 

Trading.

This Court found that Long Leaf Trading, acting through its agents, employees, and 

principals, engaged in a wide-ranging scheme to defraud customers out of millions of dollars. 

(Doc. 106, S.J. Order at 29.) The factors which mitigate in favor of a permanent injunction

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against Donelson apply with equal force to Long Leaf Trading. Donelson has nowhere 

suggested that he plans to abandon Long Leaf as a vehicle for further schemes.3 Indeed, he may

attempt to resurrect this entity. Donelson testified that he was planning in June 2019 to change 

the name of Long Leaf to “Forefront Options” to continue soliciting customers for his trading 

program. (Doc. 82.5, Donelson Dep. 211:11–212:15; see also Ex. B, Ill. Sec. of State Corp./ 

LLC search results for Long Leaf Trading, available at

https://apps.ilsos.gov/corporatellc/CorporateLlcController (last accessed Aug. 17, 2022) (listing 

“assumed named” for Long Leaf as “4Front Options, Inc.”).) The CFTC respectfully submits, 

 3 Long Leaf Trading is listed on the Illinois Secretary of State’s website as “dissolved.” (Ex. B, Ill. Sec. 

of State Corp./ LLC search results for Long Leaf Trading.) However, that dissolution is involuntary, 

meaning that it was dissolved by the Secretary of State for failure to pay fees. (Id.) Long Leaf Trading 

can be un-dissolved by Donelson at his pleasure. (See id.) Long Leaf Trading should therefore still be 

enjoined from further violations, and from trading commodity interests. See, e.g., SEC v. Diversified 

Corp. Consulting Grp., 378 F.3d 1219, 1228 (11th Cir. 2004) (affirming entry of injunction again 

purportedly dissolved corporation; rejecting argument there is “nothing to enjoin”); SEC v. Mahabub, 411 

F. Supp. 3d 1163, 1169 (D. Colo. 2019) (entering injunction against purportedly “defunct” corporation), 

aff’d sub nom. SEC v. GenAudio Inc., 32 F.4th 902 (10th Cir. 2022); SEC v. Amerindo Inv. Advisors Inc., 

No. 05 CIV. 5231 RJS, 2014 WL 2112032, at *13 (S.D.N.Y. May 6, 2014) (entering injunction against 

“inactive” corporation), aff’d, 639 F. App’x 752 (2d Cir. 2016).

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therefore, that a trading and registration ban, as well as an injunction against further violations, 

be entered against Long Leaf Trading. 

3. The Court Should Enter a Permanent Injunction Against Defendant Ruth. 

a. Ruth willfully defrauded customers. 

Ruth worked for Long Leaf Trading as a salesperson, known as an associated person, or 

“AP,” from late April 2015 through late August 2017. (Doc. 106, S.J. Order at 8-9.) In his 

capacity as an AP, Ruth solicited customers and prospective customers to participate in Long 

Leaf’s trading program. (Id.) Ruth failed to advise those customers or prospective customers 

that substantially all program participants lost money. (Id. at 25.) Ruth knew about the losses 

from customer account statements, customer complaints he received, and his own monitoring of 

Long Leaf’s recommended trades. (Id. at 26.) 

Notwithstanding this knowledge, Ruth made false and misleading statements to 

customers and prospective customers to the effect that, e.g., 6 to 12% returns would be “easy” to 

achieve, and that Long Leaf’s trades had a “strong statistical likelihood” of success. (Id. at 25-

26.) Ruth also told customers that he was “almost certain about our ability to get you to reach 

your financial goals.” (Id. at 26.) 

b. There is a reasonable likelihood of future violations by Ruth. 

There is a reasonable likelihood that Ruth will engage in future violations of the Act and 

Regulations. Ruth’s conduct in fraudulently soliciting customers and prospective customers was

egregious, and evidenced a high degree of scienter. (See id. at 24-28.) Ruth knowingly misled 

customers and prospective customers, and did so with gleeful rapacity. (See Doc. 76.8, Email 

from J. Ruth to T. Evans, Jan. 26, 2017 (“I just got a good laugh reading this [customer 

complaint] again.”); Doc. 76.4, Email from J. Ruth to J. Leeney, Long Leaf AP, Apr. 27, 2017 

(“the value in this call is how to get around a request for a track record and how to show empathy 

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so he feels you understand him”).) Ruth’s misconduct was not fleeting or isolated, but 

systematic and ongoing over the two-year period he worked for Long Leaf Trading. 

Ruth has continued to maintain that his conduct was blameless, complaining that he was 

just following a script his bosses gave him. (Doc. 106, S.J. Order at 28.) As the Court points 

out, Ruth knew the script was false. (See id.) Rather than resigning his employment in what 

Ruth knew was a fraudulent scheme, Ruth continued to mislead customers at Long Leaf Trading 

for a two-year period. 

Ruth’s professional occupation or career interests may put him in a position to commit 

future violations. After leaving Long Leaf, Ruth implemented Long Leaf’s “business model” at 

another introducing broker (“IB”) called Postrock Brokerage LLC (“Postrock”). (See Doc. 

76.21, Ruth Test. 23:1–24:5 (Ruth’s customers at Postrock traded out-of-the-money options 

spreads in a “broker-assisted” program), 386:16–386:21 (“I did something similar to the Time 

Means Money Program.”).) In March 2020, the National Futures Association (“NFA”) brought a 

complaint against Ruth for a panoply of NFA rule violations during his time at Postrock arising 

out of Ruth’s “Time of Our Lives” options trading program, including: making misleading 

statements to customers; failing to disclose that his other customers lost money; failing to 

disclose the impact of commissions on account performance; placing unauthorized trades on 

behalf of customers; and placing trades with no economic benefit to customers. (Ex. C, NFA 

Decision at 1–2.) Ruth settled the NFA’s claims on a neither-admit-nor-deny basis. (Id. at 2.) 

After leaving Postrock, Ruth took steps to start his own IB firm, though his efforts to date have 

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not been successful. (Doc. 76.21, Ruth Test. 19:18–20:7 (“I’ve been trying to open up my own 

GIB4.”) 

c. A trading and registration ban, as well as an injunction against further 

misconduct, is appropriate to prevent future violations by Ruth.

A permanent injunction against further violations, as well as a trading and registration 

ban, is appropriate against Ruth for the same reasons it is appropriate against Donelson. Ruth’s 

high level of scienter in the Long Leaf Trading scheme evidences a propensity for dishonesty 

that could manifest itself in manipulative or deceptive trading practices, or in some new fraud 

upon customers. Ruth should be permanently excluded from trading commodity interest on his 

own behalf, or on behalf of others. He should likewise be precluded from seeking to register or 

acting in the capacity of, or working for, a registrant. This is consistent with the results in other 

fraud cases, cited above. Ruth is at least as likely to violate the Act or Regulations as the 

defendants in those cases, as reflected in his post-Long Leaf conduct.

B. The Court Should Enter a Civil Monetary Penalty Against Defendants.

In addition to permanent injunctions, the CFTC seeks a CMP against each Defendant in 

the amount of three times their ill-gotten gains. (Doc. 1, Compl. at 32–33.) 7 U.S.C. § 13a1(d)(1)(A) provides for civil monetary penalties against a defendant found to have committed a 

violation of the Act or Regulations, in an amount of not more than $199,0945 or triple the 

monetary gain to the defendant for each violation, whichever is greater. In determining the 

amount of a CMP, courts look to: (1) the nature of the violations, (2) the injury caused by the 

 4 “GIB” refers to a guaranteed IB, i.e., an IB that operates with the benefit of a guarantee from a futures 

commission merchant or other CFTC registrant.

5 Adjusted for inflation, per 17 C.F.R. § 143.8. 

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violations, and (3) penalties used in similar cases.6

 See CFTC v. Li, No. 15 C 5839, 2016 WL

8256392, at *8 (N.D. Ill. Dec. 9, 2016) (citing Monieson v. CFTC, 996 F.2d 852, 864 (7th Cir. 

1993)). These factors weigh heavily in favor of imposing the maximum CMP on Defendants in 

this case.

The nature of Defendants’ violations is serious; all three defendants were involved in a 

willful, systematic, multi-year fraud scheme aimed at retail investors. The injuries caused to 

those investors was substantial. Indeed, investors lost more than $5.7 million during the fouryear course of Long Leaf’s so-called trading program. (Doc. 106, S.J. Order at 29.) $2.3 million 

of that was during Donelson’s tenure. (Id. at 24.) In many cases, Long Leaf solicited retirees to 

open and fund accounts using their retirement accounts. (See Doc. 82-4, Donelson Test. 99:17–

102:22 (discussing profile of typical Long Leaf customer).)

The penalties in similar cases counsel in favor of the maximum penalty, which in this 

case is three times Defendants’ ill-gotten gains. See, e.g., Li, 2016 WL 8256392, at *8 (imposing 

CMP in the amount of 3x ill-gotten gains in trader’s scheme to defraud employer through 

fictitious trading); CFTC v. Sarvey, No. 08 C 192, 2012 WL 426746, at *6 (N.D. Ill. Feb. 10, 

2012) (imposing CMP in the amount of 3X ill-gotten gains in brokers’ scheme to defraud clients 

through prearranged trading).

7

 Defendants’ ill-gotten gains are, respectively, $1,235,413 for 

 6 The Court need not assess the collectability of a CMP against Defendants. See Sarvey, 2012 WL 

426746, at *6 n.8 (“In determining the amount of the civil monetary penalty, ‘the financial worth of the 

defendant or the collectability of any fine are no longer relevant considerations.’”) (quoting Brenner v. 

CFTC, 338 F.3d 713, 723 (7th Cir. 2003)); see also Li, 2016 WL 8256392, at *8 n.7 (same). Imposing a 

lower CMP on the basis of a defendant’s ability to pay creates a strong incentive for the defendant to 

dissipate assets in anticipation of a judgment. It also allows a defendant who comes into money after the 

judgment to retain the benefit of that windfall despite earlier misconduct. Moreover, consideration of a 

defendant’s ability to pay would lead to potentially lengthy and burdensome asset discovery during the 

merits phase of the case. The CFTC respectfully submits that such discovery is better reserved for postjudgment collection proceedings. 

7 See also McDonnell, 332 F. Supp. 3d at 728 (imposing 3X CMP “[i]n light of the core relationship of 

the anti-fraud regulations to the purpose of the Act”); Hunter Wise, 21 F. Supp. 3d at 1353 (imposing 3X 

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Donelson, $4,010,994 for Long Leaf Trading, and $301,541 for Ruth. (Doc. 106, S.J. Order at 

24, 28-29.) That means Donelson should be required to pay a CMP of $3,706,239; Long Leaf 

should be required to pay a CMP of $12,032,982; and Ruth should be required to pay a CMP of 

$904,624.17. 

To impose a lesser penalty would fail to appropriately penalize Defendants for their 

protracted, willful misconduct. Imposing a lesser penalty would also encourage would-be 

fraudsters to try their luck; if the penalty for fraud is simply returning what a fraudster owes to 

customers plus ill-gotten gains, that simply restores the parties to the status quo.8 

For the foregoing reasons, the CFTC respectfully requests that the Court enter permanent 

injunctive relief and CMPs against Defendants Donelson, Long Leaf Trading, and Ruth, with the 

specific terms of such relief consistent with the prayer for relief set forth in the CFTC’s 

complaint. 

 

CMP on defendants involved in “well thought-out scheme” to defraud retail customers); Driver, 877 F. 

Supp. 2d at 983 (“Courts and the CFTC have found that a high civil monetary penalty is warranted where 

customers have been defrauded of a substantial amount of money.”).

8 Another important reason to impose a CMP is that it cannot be discharged in bankruptcy. See 11 U.S.C. 

§§ 523(a)(7) (exception to discharge for a penalty “payable to ... a governmental unit”); see SEC v. 

CMKM Diamonds, Inc., 635 F. Supp. 2d 1185, 1193 (D. Nev. 2009) (holding that civil monetary penalty 

owed to SEC non-dischargeable in bankruptcy). 

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/s/ Ashley J. Burden

Ashley J. Burden

aburden@cftc.gov

Elizabeth M. Streit

estreit@cftc.gov

Jody Platt

jplatt@cftc.gov

Counsel for Plaintiff CFTC

Commodity Futures Trading Commission

Division of Enforcement

77 West Jackson Blvd.

Suite 800

Chicago, IL 60604 

(312) 596-0700

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CERTIFICATE OF SERVICE

I hereby certify that on August 23, 2022, I provided service to the persons listed below, 

and by the following means:

Via the Court’s electronic CM/ECF system: Via email, pursuant to agreement, to:

Jim Falvey 

Falvey Law Office

200 S. Wacker Dr., Ste. 3100

Chicago, IL 60606-5877

jimfalvey@yahoo.com

Charles E. McElvenny

Law Office of Charles E. McElvenny

33 N. Dearborn St., Ste. 1000

Chicago, IL 60602

Counsel to James A. Donelson and Long Leaf 

Trading Group, Inc.9

Jeremey S. Ruth

11220 Brista Way

Austin, TX 78726

jeremysruth@hotmail.com

Pro se

/s/ Ashley J. Burden

Ashley J. Burden

Commodity Futures Trading Commission

Division of Enforcement

77 West Jackson Blvd.

Suite 800

Chicago, IL 60604 

(312) 596-0700

aburden@cftc.gov

 9 Mr. McElvenny is counsel to Defendant Donelson only, and not to Long Leaf Trading.

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