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

STATEMENT OF UNDISPUTED FACTS PURSUANT TO L.R. 56.1 IN SUPPORT OF 

PLAINTIFF CFTC’S MOTION FOR PARTIAL SUMMARY JUDGEMENT AGAINST 

DEFENDANT JAMES A. DONELSON

I. RELEVANT PARTIES

1. Plaintiff Commodity Futures Trading Commission (“CFTC” or “Commission”) is 

an independent federal regulatory agency charged by Congress with administering and enforcing 

the Commodity Exchange Act (“Act”) and accompanying Regulations. (Doc. 30, Donelson 

Corrected Ans. ¶ 15.)

2. Defendant Long Leaf Trading Group, Inc. (“Long Leaf”) is an Illinois corporation 

with its principal place of business in Chicago, Illinois. (Id. ¶ 16.) 

3. Long Leaf was at all times relevant to the motion, and continues to be, registered

with the Commission as an introducing broker (“IB”). (Id.) Long Leaf has never been registered 

with the Commission as a commodity trading advisor (“CTA”). (Id. ¶ 105.)

4. Defendant James A. Donelson has been the CEO of Long Leaf from December 

2017 through the present. (Id. ¶ 18.) During that period, Donelson possessed and exercised, 

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directly or indirectly, the power to direct or cause the direction of the management and policies 

of Long Leaf. (Id., e.g., ¶ 86.) As such, Donelson controlled Long Leaf during that period. (Id.) 

Donelson was also a principal of Long Leaf during that period. (Id. ¶ 1.) 

5. Donelson was registered with the Commission as an associated person (“AP”) of 

Long Leaf from June 2018 through December 2019. (Id. ¶ 18.)

II. JURISDICTION

6. This Court has jurisdiction over this action under 28 U.S.C. § 1331 (codifying

federal question jurisdiction) and 28 U.S.C. § 1345 (providing that U.S. district courts have

original jurisdiction over civil actions commenced by the United States or by any agency 

expressly authorized to sue by Act of Congress). 

7. In addition, 7 U.S.C. § 13a-1(a) provides that U.S. district courts have jurisdiction 

to hear actions brought by the Commission for injunctive and other relief or to enforce 

compliance with the Act whenever it shall appear to the Commission that any 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 properly lies with this Court pursuant to 7 U.S.C. § 13a-1(e) because 

Defendants transacted business in this District, and certain of the acts and practices in violation 

of the Act have occurred, are occurring, or are about to occur within this District, among other 

places. (Doc. 30, Donelson Corrected Ans. ¶ 14.)

III. LONG LEAF INTRODUCED ACCOUNTS AND GENERATED COMMISSIONS

9. Throughout the Relevant Period, Long Leaf was an IB, and was registered as such 

with the Commission. (Id. ¶ 21.) 

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10. An IB cannot place customer orders on a designated contract market. (Id. ¶ 22.) 

Rather, an IB introduces its customers to a futures commission merchant (“FCM”), where each 

customer must open an account for trading on a designated contract market. (Id.) 

11. An IB earns revenue in the form of a commission when a customer places a trade 

(or when the IB places a trade on behalf of the customer) in an account with the FCM. (Id. ¶ 23.) 

12. Commissions are typically assessed on a per-trade basis, on whatever terms are 

agreed to between the IB and the customer. (Id. ¶ 24.) Commissions are deducted from the 

customer’s account by the FCM, with a portion retained by the FCM and the balance forwarded 

to the IB. (Id.) 

13. During the Relevant Period, Long Leaf introduced customers to certain FCMs and 

received commissions for orders executed in those customer accounts. (Id.) 

IV. LONG LEAF’S TRADING PROGRAM

14. During the period that Donelson was CEO of Long Leaf, Long Leaf 

recommended trades to customers as part of a “trading program.” (CFTC Ex. 5281

, Long Leaf’s 

Ans. and Objs. to CFTC’s First RFAs at 4.) 

15. Long Leaf provided customers that agreed to participate in the trading program 

with trading recommendations, typically four recommendations every month. (Doc. 30, 

Donelson Corrected Ans. ¶ 27; see also CFTC Ex. 528, Long Leaf’s Ans. and Objs. to CFTC’s 

First RFAs at 4; CFTC Ex. 529, Long Leaf 30(b)(6) Dep. 120:23–121:4.)

 1 All exhibits cited herein are appended to this statement of facts unless otherwise noted. All page 

numbers for exhibits other than transcripts are to the PDF exhibit and not to any internal pagination the 

exhibit may have. 

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16. Each recommendation was for a different spread trade, with each trade typically 

involving four out-of-the-money options on futures contracts traded on designated contract 

markets, i.e., exchanges, such as the Chicago Mercantile Exchange and New York Mercantile 

Exchange. (Doc. 30, Donelson Corrected Ans. ¶ 27; see also CFTC Ex. 530, Donelson Test. 

106:21–107:4; CFTC Ex. 529, Long Leaf 30(b)(6) Dep. 109:23–110:7.)

17. Every customer participating in the trading program received the same 

recommendations as every other customer. (CFTC Ex. 529, Long Leaf 30(b)(6) Dep. 150:6–

150:20; see also, e.g., CFTC Ex. 65, Email from J. Donelson to various associated persons 

(“APs”), March 27, 2018, attaching “trade recommendations”; CFTC Ex. 66, Email from J. 

Donelson to APs, attaching “trade recommendations” and “customer analysis,” May 24, 2018; 

CFTC Ex. 67, Email from J. Donelson to APs attaching “trade recommendations,” Jan. 24, 2019;

CFTC Ex 530, Donelson Test. 172:23–175:12, 196:13–199:11, 202:8–202:12.) 

18. The only difference was in the number of contracts recommended per spread 

trade; customers with more equity, i.e., value, in their accounts would be advised to trade more 

contracts; customers with less equity would be advised to trade fewer contracts. Supra citations 

to para. 17. 

19. Long Leaf’s APs typically provided the recommendations to Long Leaf customers 

by email or over the phone. (Doc. 30, Donelson Corrected Ans. ¶ 30.) Long Leaf’s APs 

instructed customers to simply respond “yes” in a text or email to accept the recommended 

trades. (Id. ¶ 31; see also CFTC Ex. 528, Long Leaf’s Ans. and Objs. to CFTC’s First RFAs at 

5.)

20. Long Leaf would forward the customer orders to its FCM, either over the phone 

or via an electronic trading platform. (Doc. 30, Donelson Corrected Ans. ¶ 32; CFTC Ex. 528, 

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Long Leaf’s Ans. and Objs. to CFTC’s First RFAs at 4.) The FCM would then place the orders 

on the exchange to be executed. (Doc. 30, Donelson Corrected Ans. ¶ 32; CFTC Ex. 528, Long 

Leaf’s Ans. and Objs. to CFTC’s First RFAs at 5.) 

21. Long Leaf provided these recommendations to customers for compensation on a 

per-trade basis if those recommendations were accepted and acted upon by customers. (Doc. 30, 

Donelson Corrected Ans. ¶ 88; see also id. ¶ 51.)

22. The trading program was instituted in June 2015 by Long Leaf’s prior 

management, from whom Donelson had bought the firm. (See Doc. 30, Donelson Corrected 

Ans. ¶ 26.) The trading program had been continuing in substantially the same form, i.e., four 

recommended spread trades per month, since that time. (Id. ¶¶ 26-32.)

23. When Donelson started at Long Leaf, approximately 80% of the firm’s customers 

participated in the trading program. (CFTC Ex. 530, Donelson Test. 97:16–97:23.) After July 

2018, all new Long Leaf customers were participants in the trading program. (CFTC Ex. 531, 

Donelson Dep. 131:19–131:24; see also CFTC Ex. 530, Donelson Test. 97:16–98:2.)

24. The customers who participated in trading program accepted Long Leaf’s trading 

recommendations 80% to 85% of the time. (CFTC Ex. 529, Long Leaf 30(b)(6) Dep. 121:10–

121:19; see also CFTC Ex. 528, Long Leaf’s Ans. and Objs. to CFTC’s First RFAs at 6.) 

25. If a customer did not accept a trading recommendation, it was because he or she

failed to respond in time, elected not to trade at all, or, approximately 5% of the time, elected to 

trade fewer contracts than recommended. (CFTC Ex. 529, Long Leaf 30(b)(6) Dep. 121:24–

122:7.) No participant in the trading program ever sought to change the structure of the 

recommended trade, i.e., by requesting an option on a different future, or different strikes on the 

option. (Id. at 122:8–123:7.)

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V. CUSTOMER LOSSES

26. By the time Donelson started as CEO in December 2017, customers participating 

in Long Leaf’s trading program had lost $3,390,407. (Ex. 535, Patrick Decl. ¶ 18.) 

27. Substantially all Long Leaf customers who participated in the trading program 

lost money during Donelson’s tenure as well. (CFTC Ex. 531, Donelson Dep. 97:17–97:19.) 

28. In 2018, Long Leaf customers lost $1,511,837. (CFTC Ex. 535, Patrick Decl., 

Ex. C.) 

29. In 2019, Long Leaf customers lost $915,564. (Id.)

30. During the period Donelson was CEO, customers who participated in the program 

lost a total of $2,376,738. (Id. ¶ 23.) 

31. During that same period, Long Leaf collected $1,235,413 in commissions from 

customers who participated in the trading program. (Id. ¶ 29.)

VI. DONELSON’S AWARENESS OF CUSTOMER LOSSES

32. Donelson started receiving customer account statements on a daily basis shortly 

after starting at Long Leaf. (CFTC Ex. 530, Donelson Test. 217:20–218:2 see also Doc. 30, 

Donelson Corrected Ans. ¶ 40.) When Donelson reviewed the statements, he saw that 

substantially all customers who participated in Long Leaf’s trading program had been losing

money. (CFTC Ex. 530, Donelson Test. 221:3–222:3.) 

33. In January 2018, Donelson did a “five-month look-back,” and saw that customers 

were “consistently losing money.” (CFTC Ex. 531, Donelson Dep. 62:7–62:22.)

34. Donelson began receiving calls and emails from customers complaining about 

account performance almost as soon as he arrived at Long Leaf. (Id. at 62:2–62:6; see also Doc. 

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30, Donelson Corrected Ans. ¶ 40.) In his first few months at Long Leaf, Donelson received 

emails from customers complaining:

a. “It appears my account which started at $25,000 is now worth less than $5,000.” 

(CFTC Ex. 71, group exhibit of customer complaints, at 2.)

b. “I agreed to try your trading/investment service for a year with an initial 

investment of $25,000. I have seen the account value diminish precariously over 

the last 12 months by roughly 90%, combining trade losses, fees and 

commissions.” (Id. at 3.)

c. “I am not sure if you know, but I went with every recommendation in 2017 and 

lost over $31,000 after having lost $9,000 from 2016.” (Id. at 8.)

35. As Long Leaf and its trading program continued under Donelson’s leadership, 

Donelson continued to receive daily account statements showing losses in substantially all 

customer accounts. ((Doc. 30, Donelson Corrected Ans. ¶ 40.) Donelson also monitored the 

performance of Long Leaf’s recommended trades in real time. (Id.)

36. Donelson likewise continued to receive emails and phone calls from customers 

complaining of poor account performance. (Id.; see also Ex. 530, Donelson Test. 247:23–248:2;

Donelson Corrected Ans. ¶ 40; CFTC Ex. 71 at 20-41.) 

37. In those emails, customers complained as follows:

a. “In reviewing my statements I am reading you have lost about $50,000 in the time 

I have been with you. This is TOTALLY unacceptable and I want to know where 

the 78% winning rate has been all this time.” (CFTC Ex. 71 at 23.)

b. “I’m down [approx.] $10,000, and not happy about the loss as you can imagine. 

The strategy that was explained to me is there would be multiple trades made that 

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could generate some wins and some losses, but overall gains. All I’ve seen over 

the past few months are losses.” (Id. at 36.)

VII. AP SOLICITATIONS

38. Long Leaf marketed its trading program to the general public through the firm’s 

website. (CFTC Ex. 528, Long Leaf’s Ans. and Objs. to CFTC’s First RFAs at 7-8.) 

39. Long Leaf also employed a staff of APs whose duties included soliciting members 

of the general public to participate in the trading program through oral and written presentations. 

(Id. at 8.)

40. Donelson required the APs to make 200 calls to prospective customers per day. 

(CFTC Ex. 274, Email from Donelson to APs, July 27, 2018, at 2.) Donelson assigned leads to 

the APs “based on effort,” and reviewed statistics to see which APs were soliciting the most 

customers. (Id. at 4.)

41. At the end of each month, Donelson would review all written communications 

that APs made to customers and prospective customers. (CFTC Ex. 536, Donelson’s Resp. to 

CFTC’s 3d RFP at 4.) 

42. Donelson also listened to recorded calls between APs and customers on a monthly 

basis. (Id. at 5; see also CFTC Ex. 531, Donelson Dep. 37:5–39:24.) 

43. Long Leaf APs told prospective customers that “76.5 percent of options expired 

worthless,” which “increased the customer’s statistical likelihood of success.” (CFTC Ex. 531, 

Donelson Dep. 12:10–12:17.) Donelson was aware that APs were telling customers this. (Id.) 

44. Long Leaf APs told prospective customers that “one of Long Leaf’s values was to 

create a strong return for customers.” (Id. at 41:10–41:17.) Donelson overheard APs saying this 

to prospective customers, and was okay with it. (Id.) 

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45. In August 2018, a power point presentation was distributed to the Long Leaf APs 

by Donelson or at Donelson’s direction. (CFTC Ex. 397; CFTC Ex. 531, Donelson Dep. 

102:23–104:2, 113:1–113:5.) The presentation was intended for use in soliciting prospective 

customers and featured slides showing returns of 6% to 12% on a hypothetical trading account at

Long Leaf. (CFTC Ex. 397 at 12, 14; see CFTC Ex. 531, Donelson Dep. 102:23–104:2, 113:1–

113:5.)

46. Consistent with the presentation, Long Leaf APs told customers that their 

“strategies” “target 6 to 12 percent return on an annual basis.” (CFTC Ex. 531, Donelson Dep.

42:12–42:18.) Donelson was aware that APs were saying this and approved of it. (Id.) 

VIII. PAST PERFORMANCE OMISSION

47. Although substantially all Long Leaf customers lost money in the trading 

program, customers and prospective customers were not told this. (Id. at 97:17–97:21.)

48. By February 2018, the results from Long Leaf’s trading recommendations were 

“very bad.” (Id. at 65:22–66:2.) Early that month, Donelson held a “sales meeting” with Long 

Leaf’s APs. (Id. at 63:19–65:6.) At that meeting Donelson instructed the APs not to provide 

customers with any information in response to requests for “past performance.” (Id.)

49. If customers asked about it, Donelson told the APs they should say that it is Long 

Leaf’s policy not to provide information on past performance. (Id. at 65:16–65:21.)

50. This was consistent with Long Leaf’s existing policy, instituted by prior 

management, not to provide such information to customers or prospective customers. (Id. at 

63:19–65:6.)

51. This prohibition against providing customers or prospective customers with past 

performance requests continued until June of 2019, when Donelson started telling his APs to 

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provide customers with the “track records” described below in paragraphs 58-66. (Id. at 64:24–

65:5.)

52. Long Leaf did not provide disclosures required by 17 C.F.R. § 4.31(a) to 

customers or prospective customers required by. (Doc. 30, Donelson Corrected Ans. ¶ 34.)

IX. QUALIFICATIONS OMISSION

53. On February 22, 2018, Donelson drafted a letter to Long Leaf’s customers, which 

he distributed via the APs. (CFTC Ex. 52, see also CFTC Ex. 531, Donelson Dep. 68:2–68:10.) 

In the letter, Donelson writes that he has “10 years of financial and business development 

experience at two of the largest proprietary trading companies.” (CFTC Ex. 52.) The letter goes 

on to say that Donelson is “working closely with Scott Gecas,” then a Long Leaf AP, “on 

redesigning the trading processes to provide improved returns ....” (Id.) “Scott and Jim share in 

the development of the monthly trades and management of the trades after they are made.” (Id.) 

54. Consistent with the letter, Donelson and Gecas worked together on the trade 

recommendations through December 2018, when Gecas left Long Leaf. (CFTC Ex. 531, 

Donelson Dep. 69:9–69:12, 74:20–75:5.) After that, Donelson alone generated the trade 

recommendations that were provided to Long Leaf customers. (Id. at 74:20–75:5.)

55. Before joining Long Leaf, Donelson’s only prior experience in options trading 

was limited to a single trade in 2016 in which he lost $30,000. (Id. at 75:10–77:1, 79:23–80:12.) 

To the extent Donelson had done any futures trading, that trading was not profitable. (Id. at 

75:10–77:1.)

56. Donelson’s association with “two of the largest proprietary trading companies” 

was in an accounting role. (CFTC Ex. 530, Donelson Test. 10:9–11:15.) Donelson had not done 

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any trading for those companies, and in fact had never worked as a trader for any company. 

(CFTC Ex. 531, Donelson Dep. 75:10–77:1, 75:10–75:13.) 

57. Donelson did not share any of this information with customers or prospective 

customers. (Id. at 80:13–80:16; CFTC Ex. 537, LLT’s Answers and Objections to CFTC’s 2d 

RFAs at 5.) Donelson acknowledged that Long Leaf customers would not have wanted to take 

his recommendations if they knew that he had no profitable experience trading. (CFTC Ex. 531, 

Donelson Dep. 81:19–81:23.)

X. 2019 HYPOTHETICAL AND CHERRY-PICKED TRACK RECORDS

58. On February 18, 2019, Donelson sent prospective customer “eric” an email 

attaching a description of a “bond replacement strategy” used by Long Leaf. (CFTC Ex. 409.) 

In the description, Donelson claims that “[]the targeted return for this type of trade is 6-10% per 

year after fees and commissions.” (Id.) Donelson tells “eric” that, “[t]he profitability is 

primarily driven by the time decay variable and therefore creates a higher probability of 

success.” (Id.) The email includes a “trade history” which reflects seven trades from August 

2018 through January 2019 with a net P&L of $701.99 and an average return of 1.68% over a 

seventh month period. (Id.)

59. The results reflected in the “trade history” represent a small number of the trades 

made by Long Leaf on behalf of customers. (CFTC Ex. 531, Donelson Dep. 144:17–145:24 

(noting this is history of “gut strangle” trades made by three customers).) During the period 

August 2018 through February 2019—the period reflected in the “trade history”—customers lost 

$323,932. (CFTC Ex. 535, Patrick Decl., Exs. A, C.) By February 2019, Long Leaf customers 

had lost a total of more than $1.57 million since the start of Donelson’s tenure, and over $4.9 

million since the start of Long Leaf’s trading program. (Id.) Donelson did not disclose these 

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losses to “eric” or any other prospective customer. (See CFTC Ex. 531, Donelson Dep. 147:20–

148:14.)

60. On May 20, 2019, Donelson sent an email to his APs titled “new track record,” 

and attaching a file named “track record – core strategy – 5-20-2019.” (CFTC Ex. 414.) The 

attached file reflects a series of trades from July 2018 through May 2019 reflecting a total P&L 

of $460.23. (Id.) Donelson sent this email to the APs so they could distribute the “new track 

record” to customers and prospective customers. (CFTC Ex. 531, Donelson Dep. 159:22–

160:14.) The APs did so. (Id.; see also, e.g., CFTC Ex. 470, email from J. Hatzigiannis to 

“ejshafter,” May 20, 2019.)

61. This new “track record” reflects hypothetical results from a subset of trades that 

Long Leaf recommended during the period July 2018 through May 2019. (CFTC Ex. 531,

Donelson Dep. 157:15–158:21, 159:22–162:14, 169:20–170:11.) In reality, Long Leaf 

customers lost $538,618 during that period. (CFTC Ex. 535, Patrick Decl., Exs. A, C.) By May 

2019, Long Leaf customers had lost $1.74 million during Donelson’s tenure and $5.1 million 

since the start of the trading program. (Id.) These facts were not disclosed to customers or 

prospective customers. (CFTC Ex. 531, Donelson Dep. 162:11 – 163:21.)

62. On August 28, 2019, Long Leaf AP Alexander Stemper sent an email to 

prospective customer Jack Lattner. (CFTC Ex. 300.) Stemper’s email included an “updated 

performance report for one of our larger accounts.” (Id.) The “performance report” shows 

trades from April through August 2019, and reflects profits of $37,719.45. (Id.) The attached 

report was created by Donelson, and provided to Stemper to give to Mr. Lattner. (CFTC Ex. 

531, Donelson Dep. 171:5–172:4.) 

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63. The so-called performance report was based on an account belonging to a single 

Long Leaf customer, whose account was temporarily up (though it was eventually wiped out). 

(CFTC Ex. 531, Donelson Dep. 172:8–173:23.) During the period April through August 2019—

the period reflected in the “performance report”—Long Leaf customers lost $148,234. (CFTC 

Ex. 535, Patrick Decl., Exs. A, C.) By this point, Long Leaf customers had lost a total of $1.78 

million under Donelson and $5.1 million since the start of Long Leaf’s trading program. (Id.) 

Customers were not apprised of these facts. (See CFTC Ex 300.)

64. On September 10, 2019, Long Leaf AP Hatzigiannis sent an email to prospective 

customer “Wally.” (CFTC Ex. 200.) Hatzigiannis writes “I wanted to provide you an update of 

what we have been doing. Attached is a track record of our recent performance.” (Id.) 

Hatzigiannis goes on to say, “The reason we have seen so much success as of late is because of 

the current market conditions and the way we are able to manage this.” (Id.) 

65. The attached track record shows trades from June through September 2019, and 

profits from those trades of $5,978.50. (Id.) The track record was created by Donelson, and 

provided to Hatzigiannis to distribute to prospective customers, which Hatzigiannis continued to 

do through October. (CFTC Ex. 531, Donelson Dep. 175:7–176:23, 179:9–180:13; see also

CFTC Ex. 201, Email from Hatzigiannis to “Tim,” Oct 7, 2019.) 

66. The track record does not reflect actual trading results; rather, it reflects 

hypothetical results. (CFTC Ex. 531, Donelson Dep. at 178:12–178:17.) By September 2019, 

Long Leaf customers had lost $1.63 million during Donelson’s tenure and $5.02 million since 

the start of the trading program. (Id.) These facts were not disclosed to customers or prospective 

customers. (See CFTC Exs. 200, 201.)

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XI. DONELSON PAYMENTS TO SELF

67. During Donelson’s tenure at Long Leaf, Long Leaf paid $240,000 to Donelson 

Enterprises, a company owned by Donelson, as a “management fee.” (CFTC Ex. 529, Long Leaf 

30(b)(6) Dep. 21:12–22:15.)

68. Long Leaf paid Donelson approximately $150,000 in wages. (Id. at 23:1–23:12.)

XII. NELSON AP REGISTRATION

69. Andrew Nelson worked at Long Leaf from September 2017 through November 

2018, soliciting customers for participation in the trading program. (Doc. 23, Long Leaf Ans. ¶ 

20.)

70. Nelson was not registered as an AP of Long Leaf. (Id.)

71. On July 18, 2018, NFA sent an email to Nelson, stating that, “based on NFA’s 

discovery this week that you have been acting as an AP without being registered as such, staff 

will not be recommending to the Membership Committee that you be conditionally registered.” 

(CFTC Ex. 538.) Nelson forwarded the email to Donelson the same day. (Id.)

72. Donelson nonetheless allowed Nelson to continue soliciting customers for another 

four months without registration. (Doc. 23, Long Leaf Ans. ¶ 20.)

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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

525 W. Monroe St., Ste. 1100

Chicago, IL 60661

(312) 596-0700

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CERTIFICATE OF SERVICE

I hereby certify that on November 5, 2021, 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 D.E. 13, to:

Jim Falvey 

Falvey Law Office

200 S. Wacker Dr., Ste. 3100

Chicago, IL 60606-5877

jimfalvey@yahoo.com

Counsel to Long Leaf Trading Group, Inc. 

and James A. Donelson

Jeremey S. Ruth

11220 Brista Way

Austin, TX 78726

jeremysruth@hotmail.com

Pro se

Andrew D. Nelson

267 May St. E.

Elmhurst, IL 60126

adnelson0503@gmail.com

Pro se

/s/ Ashley J. Burden

Ashley J. Burden

Commodity Futures Trading Commission

Division of Enforcement

525 W. Monroe St., Ste. 1100

Chicago, IL 60661

(312) 596-0700

aburden@cftc.gov

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