Tom Lawler FCUSA Criminal

I N THE UNI TED STATES DI STRI CT COUR
FOR THE NORTHERN DI STRI CT OF GEOR

ATLANTA DI VI SI ON
FILED I N CLERK' S OFFICE
V-S.D.C. Allania
OCT 10 ?M
^ ^ Wc i e r k
SECURITIES AND EXCHANGE
COMMI SSI ON
Plaintiff
vs.
Thomas J . Lawler and F RE E DOM
FOUNDATI ON USA L L C dba
F RE E DOM CLUB USA,
Defendant(s),
DI VI NE SPI RI T L L C ,
ORDER PROCESSI NG L L C
PROS PERI TY SOLUTI ONS L L C , and
V I OL E T BLESSI NGS L L C ,
Relief Defendant(s).
Ci vi l Action File
No. l:14-CV-02468-AT
DEFENDANT' S MOTI ON
TO RECONS I DER ORDER
DENYI NG DEFENDANT' S
MOTI ON TO DI SMI SS
DEFENDANT' S MOTI ON TO RECONS I DER ORDER DENYI NG
DEFENDANT' S MOTI ON TO DISMISS
Defendant Thomas J. Lawler, Pro Se, hereby files this Motion to Reconsider
Order Denying Defendant's Motion To Dismiss. While we recognize that
reconsideration of a previous order is an extraordinary remedy to be
Case 1:14-cv-02468-AT Document 28 Filed 10/10/14 Page 1 of 28
employed sparingly, we certainly f md extraordinary circumstances i n this
matter. For this, among other reasons, Defendant Thomas J. Lawler
respectfully submits the following:
SUMMARY
1. Defendant(s) have been denied the court appointment of legal
counsel and denied adequate financial provision to secure legal counsel i n
order to provide for and present a proper defense. Defendant(s) have been
denied due process.
2. Plaintiff has offered NO real valid basis or evidence, as it
relates to a "Private Club" or otherwise to bring said allegations against a
Private Club or its Founder, Members, Agents, et al.
3. Plaintiff has engaged i n egregious, reckless actions by
knowingly and intentionally ignoring and omitting substantial truth and facts
thereby bringing great harm upon the very people they state they are
protecting by and through the ongoing TEMPORARY RESTRAINING
ORDER, ASSET FREEZE, AND OTHER EQUI TABLE RELIEF, as wel l
2
as asserting their own spin of language and untruths in order to proffer false
and voi d allegations, among other things.
4. Plaintiff has infringed upon Defendant's First Amendment
rights.
PARTI ES
5. Plaintiff: SECURITIES AND EXCHANGE COMMISSION
("COMMISSION" OR "SEC"),
6. Defendant(s): Thomas John Lawler, Defendant, Pro Se,
domiciled in the State of Georgia, FREEDOM FOUNDATI ON USA LLC
dba FREEDOM CLUB USA ("THE CLUB"), registered i n the state of
Nevada, VIOLET BLESSINGS LLC, ORDER PROCESSING LLC and
DI VI NE SPIRIT LLC, each registered in the state of Missouri.
J UDI CI AL NOTI CE
7. Defendant(s) claim all rights at all times and waive none of
them at any time for any cause or reason.
8. Defendant(s) claim substantial Due Process rights to have
Findings of Facts and Conclusions of Law published wi t h any order of this
court.
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9. Thomas Lawler, Defendant, Pro Se, who is unschooled in law,
asks the court to take Judicial Notice of the enunciation of principles as
stated in Haines v. Kemer, 404 U.S. 519, wherein the court has directed that
those who are unschooled i n law making pleadings and/or complaints shall
have the court look to the substance of the pleadings rather than the form.
10. Defendant reserve the right to supplement and/or amend as
needed.
JURI SDI CTI ON AND VENUE
11. Defendant disputes jurisdiction and venue. Plaintiff has placed
an incorrect emphasis on an unassociated jurisdiction. Change of jurisdiction
has previously been established and ignored. Parties await Order from The
Common Law Intemational World court for removal of this matter.
F ACT AND L E G A L BASIS
12. In an effort to not restate certain BACKGROUND, FACTS
AND BRIEF I N SUPPORT of Defendant(s)' position previously submitted
to this Court as part of a copy of Defendant(s)' STATEMENT OF CLAI M
I N THE COMMON LAW I NTERNATI ONAL WORLD COURT,
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Defendant(s) hereby reallege and incorporate by reference herein, attaching
same as EXHI BI T A.
13. Defendants' have been denied Due Process. Defendant Lawler
comes before the Court Pro Se due to the fact that this Court has DENIED
hi m a court appointed attomey and additionally Ordered a TEMPORARY
RESTRAINING ORDER, still i n force as of this date, disallowing enough
liquidity of funds to secure proper legal representation, that which far
exceeds what this Court has allowed as available. Since all other named
Defendants are non-living entities, cannot speak for themselves and can only
be represented by Court recognized legal counsel, they too have been denied
proper legal counsel by the unjust restraint and freeze of available fiinds.
There is no valid fact entered to support this order of action.
14. Mr. Lawler did not appear at a hearing due to the restraint and
deprivation of legal counsel so as not to fiirther incriminate himself, not
being schooled i n law, procedure or technicality.
15. Al l Defendants have been denied the right and ability to
provide for, much less present, a proper legal defense. Hence, Thomas J.
Lawler presents Pro Se.
16. As taught and published, by Georgia Perimeter College,
accredited by the Southem Association of Colleges and Schools
Commission on Colleges, the first paragraph of Article I : Bi l l of Rights,
(http://facstaffgpc.edu/~wbroadwe/State&Local%20Ch.%202.pdf).:
"Article I: Bill of Rights of The Georgia
Constitution guarantees no Georgian will be
deprived of Life, Liberty, or Property
without Due Process of law. This basically
means, a citizen must:
- be notified of intended govt, action,
- have a right to a hearing,
- be able to dispute the state's action,
- call witnesses and present evidence, and
- have the benefit of legal counsel."
(emphasis added)
Defendant(s) in this matter have been intentionally deprived of the benefit of
legal counsel.
17. During an event hosted Oct. 30, 2009, by the UNC Center on
Poverty, Work and Opportunity i n Chapel Hi l l , N. C, Associate Justice
Patricia Timmons-Goodson noted that the United States is one of the few
Westem democracies that do not guarantee the right to counsel i n ci vi l cases.
That should not be acceptable for a country that has "assumed the mantle of
equality," said Gene R. Nichol, past Dean of UNO' s law school. "You can
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call it justice because someone in a robe decides the case," said George
Hausen, the executive director of Legal Ai d of North Carolina, "but really,
there's no adversarial process taking place." It would not be difficult to
establish a prima facie case when no adversarial process takes place", as was
the case in this matter.
18. Plaintiff offers NO valid basis or evidence to estabHsh this
cause of action much less continue their effort to support void allegations, as
they relate to a "Private Club" or otherwise i n order for the Court to proceed
against a Private Club or its Founder, Members, Agents, et al. When asked
by Judge Totenberg during the emergency phone hearing, i f he had any
experience or case law as it relates to a "CLUB", counsel for Plaintiff, Pat
Huddleston, I I responded to the negative.
19. Al l Club benefits/services/programs, none of which are
"investments", are offered ONLY to Club Members who have chosen their
own path of education. Club benefits/services/programs are NOT offered or
open to the general public. Pl ai nt i ffs allegations of "Unregistered
Securities" are void of any valid, legal basis.
20. "Howey Test". Justice Murphy formulated one of the U.S.
Supreme Court's earliest tests to determine whether an instrument qualifies
as an "investment contract" for the purposes of the Securities Act (which
later came to be referred to as the Howey test): The "Howey Test" clearly
proves that the contracts i n question do not meet at least 3 of the 4 prongs of
the test: Plaintiff offers NO valid basis or evidence to establish this cause of
action much less continue their effort to support void allegations, as they
relates to the actual noted cause of "Securities Fraud" and the allegation,
specifically "COUNT I - UNREGISTERED OFFERING OF SECURITIES.
Pl ai nt i ffs allegation is void of any valid findings of material fact and fails
the very test that their allegation is based upon. No registration statement
need be filed or in effect as there was and is no offering of securities.
21. Since the definitions of "Investmenf and "Security" are so
broad, the authorities utilize these phrases/law as a catch-all whenever
convenient, as well as the widely used "Howey Test". In this matter, there is
no 1) investment money (Club Members pay for administrative services
provided), 2) due to an expectation of profits (there are none expected or
promised), 3) there is a common enterprise obligated to cure the judgments
processed (which is the United States Department of Treasury and NOT the
Defendant(s) and 4) does NOT depend solely on the efforts of a third party
(but does depend on individual education, documentation, information and
the accuracy thereof and calculations of what they deem is correct, provided
by each individual who wish to engage the administrative services and
process, done on a "best efforts" basis wi t h no promise of outcome, along
wi t h The United States Department of Treasury and what they deem is just
and proper in each individual instance).
22. To draw a parallel, i f one engages a resume service/recruiter,
for example, who touts that their service is superior, that they have expertise,
information or connections where others do not (choosing to keep that
confidential and proprietary) and would help one to obtain the monetary
salary level or result they desire - would that service provider/contract also
then be guilty of selling a security? Would it also be deemed fraudulent
and/or deceptive i f that individual did not obtain desired results? One did
invest money, in an organization's or individual's services, wishing to
achieve a certain monetary results derived from the efforts of the service
provider. This, a parallel drawn demonstrating the broad application or
misapplication that can occur. This parallel can apply to most any service
organization or service provider i f one wishes to enhance the circumstance
to f i t their need.
23. Plaintiff also uses the term "ill-gotten gains" to describe monies
paid, categorizing all as such, and calls for the "disgorgement" of same
alleging that all Defendants and Relief Defendants have been unjustly
enriched. Perhaps the cost of doing business and related expenses have been
overlooked by the Plaintiff.
24. To demonstrate the gross misapplication of law used i n the
Pl ai nt i ffs effort to support their position. In re: SEC v. ETS Payphones,
Inc., 408 F.3d 727, which is referenced on Page 10 of PLAINTIFF
SECURITIES AND EXCHANGE COMMISSION' S MEMORANDUM I N
SUPPORT OF ITS APPLICATION FOR A TEMPORARY
RESTRAINING ORDER, ASSET FREEZE, AND OTHER EQUI TABLE
RELIEF, on appeal by petition of THE SECURITIES AND EXCHANGE
COMMISSION, from the UNITED STATES DISTRICT COURT FOR
THE NORTHERN DISTRICT OF GEORGIA, and i n the event that there
was merit i n the Plaintiff SEC not lending credibility to the decision of the
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UNI TED STATES DISTRICT COURT FOR THE NORTHERN
DISTRICT OF GEORGIA, we can f md no comparison or application of
circumstance or law and i n fact is void of any practical application i n this
matter.
"First, if the seller's purpose is to raise
money for the general use of a business or to
finance substantial investments "and the buyer is
interested primarily in the profit the note is
expected to generate, the instrument is likely to be
a 'security.'" 494 U.S at 66. Here, "ETS's
investors" bought phones "for the purpose of
earning a return on the purchase price"(Op. 7),
not to use the phones, and ETS raised the money to
use in operating the business. "
"Second, it is sufficient for the required
"common trading" element if the interests are
"offered and sold to a broad segment of the
public," as were the ETS units. 494 U.S. at 68. "
"Third, because Edwards promoted them as
"investments," the ETS units meet the
"fundamental essence of a 'security.'" Id at 68-
69."
25. First, i n this matter, fiinds were not generated or used to finance
investments but were generated were used to pay for services provided.
Secondly, the Club offers and sells nothing to the general public wi t h the
exception of Private Club Memberships. Benefits/Services/Programs are
available only to Private Club Members. Third, the Club does NOT promote
"investments" or "securities".
26. Pl ai nt i ffs allegations of "Unregistered Securities" are void of
any valid, legal basis.
27. Furthermore, Plaintiff is attempting to conduct a mere witch
hunt wi t h total disregard of true fact or lack of education or both. Wi t h
specific regard to the "Administrative Remedy" ("A/R"), the process by
which these void allegations are based, the facts are indisputable that
administrative services are provided to effect a long standing, legal process
called "Notarial Protesf. NOTARI AL PROTEST, as defined i n BLACK' S
LAW DI CTI ONARY FIRST EDITION:
"PROTEST. 2. A notarial act, being a
formal statement in writing made by a
notary under his seal of office, at the request
of the holder of a bill or note, in which such
bill or note is described, and it is declared
that the same was on a certain day
presented for payment, (or acceptance, as
the case may be,) and that such payment or
acceptance was refused, and stating the
reasons, if any, given for such refusal,
whereupon the notary protests against all
parties to such instrument, and declares that
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they will be held responsible for all loss or
damage arising from its dishonor. "
28. One must be a Club Member to engage i n this process and
utilize these administrative services. A Club Member may engage this
process and utilize these administrative services as well as other Club
benefits/services/programs, at their wi l l , (subsequent to their own research
and conclusions), which is a part of their Membership Contract, and in
accordance wi t h the mles and specific details of each level of service. One
cannot question that there is most certainly a strict intent of understanding
and meeting of the minds after reviewing agreements. Al l administrative
services are provided to Members on a best effort basis. There is NO
promise of outcome, resuh, for services performed. There IS f ul l disclosure
of the presentment amount of the Member's claim. There is NO promise for
payment of benefit derived from any benefit/service/program as that is the
sole discretion of the US Treasury. Payment is for the administration of the
service provided. Further, it is not a requirement as a Private Club Member
to participate i n any one of the many programs. Participation is solely by
choice, subsequent to one's own research, education, decision and ultimately
information and calculation that they themselves provide. Ignoring these
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facts would be the Pl ai nt i ffs own admission to knowingly, intentionally
and/or recklessly omitting and/or disregarding truth and fact.
29. The fact remains that there was no valid basis and is still no
valid basis for Pl ai nt i ffs allegations. There are not sufficient facts to
support allegations that there are "securities" involved. Plaintiff
SECURITIES AND EXCHANGE COMMISSION has no legal basis and
allegations are void of legal standing or merit and truth and should not be
accepted as such. There are no proven violations of the Securities Act of
1933 and in fact are disproven i n Paragraph 14 herein. While, "on a motion
to dismiss, a complaint is viewed in the light most favorable to the plaintiff, "
anything can be well-pleaded, but the facts of the matter must be tme. The
SEC has not proven a prima facie case of violations of the antifraud
provisions of federal securities laws and therefore should not be given the
f omm to continue a void COMPLAINT and RESTRAINING ORDER,
ASSET FREEZE, AND OTHER EQUITABLE RELIEF. They have proven
nothing more than a Private Club, offering and providing educational and
administrative services/programs/benefits and Private Club Members
engaging in same as they so choose, subsequent to their own research, and
whose participation plays a role i n the very outcome of each of the various
services/programs i n which they engage.
30. Plaintiff inappropriately and untruthfully uses and assert their
own language, such as "investment" and "promise", among other phrases,
that are not used, not referred to, not mentioned, insinuated or otherwise
intended by anyone other than themselves. The Club does not advocate,
allow or perpetuate such language. In fact. Club contracts and
documentation clearly absolve themselves of same. I f Defendants became
aware of individuals engaging i n untruthful language as such, that would
provide grounds for Membership termination from the Club.
31. The facts are clear. There is no investment, unregistered or
otherwise, no security, as proven by the Howey Test, and there is no fraud.
Therefore, any reference of law to support the void allegation of
"unregistered securities" is moot. What there is, is a Private Club, Private
Club / Membership and Contracts, information and education from credible
3'"'^ parties so that Members may do their own research, draw their own
conclusions and participate i n whichever of the many benefits/services
offered by the Club to Club Members Only. Funds secured by Membership
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fees and product/service fees are utilized, as any organization would - to
support the Club and provide for the many services/products/benefits
offered, to provide for usual and customary business expenses and overhead
i n order to continue offering same to existing and new Members and to
perpetuate organization growth. Plaintiff is not a Club Member.
32. Regarding COUNT I I - FRAUD and COUNT I I I - FRAUD,
which appears to be standard charges and often times regurgitated i n matters
of the like, Defendant(s) have been paid for services performed, researched
and provided education and information and 3'"'^ party materials for Club
Members to do their own research and draw their own conclusions.
Defendant(s) have made no known untrue statements of fact nor leamed
omissions during the course of providing information and resources. The
Club may stand accused only of "leading" and not "misleading" Private
Club Members to do their own research, due diligence and form their own
conclusions based on many other resources. Members must take their own
initiative to engage any benefit or service following their own research and
decision to do so. SoUcitation is strictly prohibited and grounds for
termination from the Club. Members continue to provide additional
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resources for the benefit of other fellow Club Members. Much of the
information and education offered by the Club was and is in fact contributed
by Club Members. We are a Club of Club Members and not "investors" as is
referred to and misstated throughout Plaintiff documents and Court Orders.
33. Defendant(s) have not engaged i n transactions, practices and
courses of business of fraud and deceit. The Club has openly engaged in
processes of researched truths and fact. The use of means or
instrumentalities of interstate commerce ... directly and indirectly, is
admitted as there was no fraud or deception or any reason to hide as one
might do i f i n fact there were something unlawfril to hide.
34. In the case of an injured party, involving one who can only be a
Club Member (the Plaintiff not a Club Member nor injured party), i n the
event of a dispute, all Club contracts clearly define Arbitration and United
States Arbitration and Mediation Rules of Arbitration as the only remedy.
The Commission is neither a Private Club Member nor an injured party.
35. I n Paragraph 4. of Plaintiffs APPLICATION FOR
TEMPORARY RESTRAINING ORDER, ASSET FREEZE, AND OTHER
EQUI TABLE RELIEF, Plaintiff refers to certain information as "spinning a
17
tale", in Paragraph 5., Plaintiff refers to certain information shared by
Defendant as a "fantastical story" and i n Paragraph 12, there is reference to
"the scam". Further, in Pl ai nt i ffs COMPLAINT FOR INJUNCTIVE AND
OTHER RELIEF, Page 5., under FACTS, A. refers to "The Investment
Scheme. Paragraphs 19 - 21, further poorly attempts to defme bits and
pieces of information and education; none of which has been proven as not
factual or untrue by Plaintiff Just because they say it isn' t so doesn't make it
untrue. Plaintiff presents no factual evidence disproving or to the contrary
nor enjoins in the suppression the millions of publications, websites,
organizations, individuals, etc., sharing and publishing the same and/or
closely related information.
36. Bank statements clearly show funds transfers and recipients
thereof Plaintiff has certainly established that Mr. Lawler has taken some
personal funds, no real salary, but fiinds that, upon agreement, were
personally withdrawn totaling approximately $5,000 to $10,000 per year.
They also reveal that Mrs. Lawler received funds totaling approximately
$5,000 per year for the 10 years of her related work. There are no lavish
vehicles, no fancy home or lavish vacations. Funds received by the Club
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were used to support the organization, usual and customary expenses and
overhead, and the multiple benefits/services/programs, serving Club
Members. There are no hidden funds, no personal luxuries. Bank statements
and funds activity has been reviewed, transfers of funds reasonably
explained wi t h no evidence of misuse of Club funds or hidden funds that the
Plaintiff seems to have convinced the Court of, despite reviewing bank
statements. Yet the Plaintiff continues to muster some believability for Court
consideration and continuation of an unjust cause void of any real fact to
support their position, inflicting ongoing harm and hardship on the
Defendant(s). Absent any real, factual evidence to support these allegations,
this is, i n fact, "spinning a tale" and a "fantastical story", to quote the
Plaintiff.
37. Evidence i n support of the "emergency" actions taken against
the Defendants and Relief Defendants, were derived from a one sided story,
presented in a most enticing manner, including language and enhancements
far beyond that of the truth. The evidence offered by the Plaintiff included a
DECLARATI ON OF MATTHEW MCNAMARA and a DECLARATI ON
OF KARAZ S. ZAKI , Attachments 1 and 2, respectively.
19
38. The DECLARATI ON OF MATTHEW MCNAMARA refers to
swom testimony of both Thomas and Diane Lawler, both of whose
testimony was taken while under great duress and without the benefit of
legal counsel. The DECLARATI ON regurgitates and highlights certain
chosen excerpts and establishes that there is no securities registration.
Questions seemed to escalate into a financial and taxation witch hunt,
revealing reasonably explained supported staff and business expenditures
and focusing heavily on very minor personal expenditures, no salary noted,
or any real unusual activity noted. Defendant Thomas Lawler' s testimony
reveals cooperation and explanation, under great duress, revealing years of
research, and great belief i n same and contact wi t h the "Treasury" wi t h
reference to the "ARs".
39. The DECLARATI ON OF KARAZ S. ZAKI , CPA, employed
by the "Commission", reveals a cursory review of ten bank accounts,
identifying authority signatories, deposits and transfers, and a few specific
focal transactions, including a few personal transfers, not including any
salary paid to Mr. Lawler, since there was none. Just a vanilla summary of
sums, dates and select transactions. Al l of which were questioned and
explained under oath by Mr. Lawler.
40. Clearly there were and are no grounds for restraint of funds,
asset freeze or any other equitable relief The TEMPORARY
RESTRAINING ORDER, which was founded on mere supposition and void
of any wrongdoing or factual evidence to support such extraordinary
measures much less the allegations proffered by the Plaintiff, remains i n
effect to date and should immediately be lifted.
41. Plaintiff and this Court have sorely infringed upon Defendant(s)
First Amendment rights by ordering suppression of certain information and
statements, orally or i n writing, statements of which have not been rebutted,
have not been proven as not factual supported by any material fact to the
contrary and thus stands as material fact. Certain statements and information
that have been researched and made public for years and can be found i n
many resources, publications and other websites. Yet the Defendants are
suppressed and denied their First Amendment rights to speak on these
matters. Are all those who have done their due diligence and communicate.
either written or verbally on these same matters to be suppressed as well?
Are they all deemed fraudulent?
42. One can easily search the intemet and YouTube videos where
thousands of resources may be found and explored, specific to the very
information that we are being unduly restrained from sharing and in large
part what these void "Fraud" charges are based upon. Al l , including
Defendants' information, is provided for and is intended as information and
education only, for those who choose to do their own research.
43. In the landmark case of Reno v. American Civil Liberties
Union, 521 U.S. 844 the Supreme Court found, in summary, that the
Intemet was a "protected" form of communication i n roughly the same way
that a book was. It had the added benefit of additional protection, since it
was an on-demand method of communication.
44. We are a Club that offers a great deal of information on many
different topics, we implore those who are uneducated to do their own due
diligence and findings of fact i n order to draw their own conclusions.
However, suppression and denial of First Amendment rights is no doubt a
serious matter.
SUMMARY
45. The Commission has no real interest in this matter and has not
established good cause to continue. The allegations are void and without
merit and standing and thus, as a matter of law, must be dismissed. It is clear
that the Plaintiff moved this Court on assumption, without adequate findings
of fact and in a most expedited manner, in concert wi t h the deprivation of
the Defendant(s) to secure and provide adequate legal defense. The ability
for the Defendant(s) to secure legal counsel at all has been denied and
fiirther railroaded. The Court based its decision on a one sided, skewed
story, unethical spin, contrived language and assumption, presented by the
Plaintiff to fit their need. The story spun and the continuance of an action
void of substantial evidence in support is a travesty.
46. In a trial last November, 2013, Judge Duffey, i n THE UNITED
STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF
GEORGIA ATLANTA DIVISION, rejected insider trading charges of a
defendant who had a longtime friendship wi t h a chief executive. I n S.E.C. v.
Schvacho, on January 7, 2014, the Court found for the Defendant because
the SEC did not meet the burden of proof
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47. While the natures of the matters clearly differ, the law does not.
The SEC failed to meet the burden of proof in this matter.
48. It is a Imown fact that the Commission did not enjoy a winning
year i n 2014, wi t h several notable losses taking center stage and would look
to put a winning feather in their cap. In one article published by Law360,
New York on June 09, 2014, Thomas Gorman, former SEC trial counsel is
quoted saying, " I f you don't have the facts, you don't have the facts".
49. In consideration of the overwhelming argument showing that
the Plaintiff was unable to prove their claims and did not meet the burden of
proof to establish a prima facie case, but was nothing more than a
preponderance of one sided twisted bits of information spun into a palatable
presentation to suit their needs, and as a matter of law, this action should be
dismissed and the Plaintiff sanctioned for misuse of law and deceptive
practices, at the very least.
50. As a fmal note, the Defendant(s) may never recover from the
harm inflicted by this action.
PRAYER FOR RE L I E F
Defendant(s) seek the following relief
12. An Order l i ft i ng all restraints and releasing i n its entirety, all
pending Orders against Defendants i n this matter, including ORDER TO
SHOW CAUSE, TEMPORARY RESTRAINING ORDER, ORDER
FREEZING ASSETS AND FOR AN ACCOUNTING, ORDER
PROHIBITING DESTRUCTION OF DOCUMENTS, AND ORDER
EXPEDITING DISCOVERY. The Club is an operation of about 10,000
private memberships encompassing about 20,000 people. Club Members are
being unduly harmed alongside the Defendants and Relief Defendants.
13. Reconsideration and an order GRANTI NG dismissal wi t h
prejudice.
14. Court fees and any and all costs of this action against the
Defendants; and,
15. Any other relief the court deems just and proper.
Dated this 9^^^ day of October, 2014.
Isl Thomas J. Lawler
Thomas J. Lawler
5077 Tanaga Court
Stone Mountain, GA 30087
25
CERTI FI CATE QF COMPLI ANCE
I n accordance wi t h Local Rule 7. I D and 5.1C, I hereby certify that the
foregoing has been prepared using Times New Roman 14 point font.
This 9* day of October, 2014.
Isl Thomas J. Lawler
Thomas J. Lawler
5077 Tanaga Court
Stone Mountain, GA 30087
26
CERTI FI CATE OF SERVICE
I hereby certify that on October 9*, 2014, I have mailed the foregoing
document to the Clerk of this Court and served the same, via U.S. Postal
Service on the following:
PAT HUDDLESTON, II, SR. TRI AL COUNSEL
U.S. SECURI TI ES AND EXCHANGE COMMISSION
950 East Paces Ferry, N.E., Suite 900
Atlanta, GA 30326-1382
MATTHEW McNAMARA
KARAZ ZAKI
GREGORY SMOLER
MADISON GRAHAM LOOMIS
Regional Trial Counsel
FREEDOM FOUNDATION USA L L C
Dba FREEDOM CLUB USA
Registered Agent
Laughlin Associates, Inc.
9120 Double Diamond Parkway
Reno, NV 89521
27
DIVINE SPIRIT L L C
Registered Agent
Incorp Services
2847 S. Ingram Mill Road, Suite AlOO
Springfield, MO 65804-4006
ORDER PROCESSING L L C
Registered Agent
Incorp. Services, Inc.
2000 Riveredge Parkway, NW, Suite 885
Atlanta, GA 30328
PROSPERITY SOLUTIONS L L C
Registered Agent
Judith Harris
950 Herrington Road, C-197
Lawrenceville, GA 30044
VI OLET BLESSINGS L L C
c/o Diane Lawler
5077 Tanaga Court
Stone Mountain GA 30087
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