Tom Lawler FCUSA Criminal

I N T H E U N I T E D S T A T E S D I S T R I C T C O U R F O R T H E N O R T H E R N D I S T R I C T O F G E O R

A T L A N T A D I V I S I O N

FILED IN CLERK'S OFFICE V-S.D.C. Allania

OCT 10 ?M

^ ^ W c i e r k

SECURITIES A N D E X C H A N G E C O M M I S S I O N

Plaintiff

vs.

Thomas J . Lawler and F R E E D O M F O U N D A T I O N USA L L C dba F R E E D O M C L U B USA,

Defendant(s),

D I V I N E S P I R I T L L C , O R D E R P R O C E S S I N G L L C P R O S P E R I T Y S O L U T I O N S L L C , and V I O L E T B L E S S I N G S L L C ,

Relief Defendant(s).

Civil Action File No. l:14-CV-02468-AT

D E F E N D A N T ' S M O T I O N T O R E C O N S I D E R O R D E R D E N Y I N G D E F E N D A N T ' S M O T I O N T O DISMISS

D E F E N D A N T ' S M O T I O N T O R E C O N S I D E R O R D E R D E N Y I N G

D E F E N D A N T ' S M O T I O N T O 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 of 28

employed sparingly, we certainly fmd extraordinary circumstances in this

matter. For this, among other reasons, Defendant Thomas J. Lawler

respectfully submits the following:

S U M M A R Y

1. Defendant(s) have been denied the court appointment of legal

counsel and denied adequate financial provision to secure legal counsel in

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 in 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, A N D OTHER EQUITABLE RELIEF, as well

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as asserting their own spin of language and untruths in order to proffer false

and void allegations, among other things.

4. Plaintiff has infringed upon Defendant's First Amendment

rights.

P A R T I E S

5. Plaintiff: SECURITIES A N D EXCHANGE COMMISSION

("COMMISSION" OR "SEC"),

6. Defendant(s): Thomas John Lawler, Defendant, Pro Se,

domiciled in the State of Georgia, FREEDOM FOUNDATION USA LLC

dba FREEDOM CLUB USA ("THE CLUB"), registered in the state of

Nevada, VIOLET BLESSINGS LLC, ORDER PROCESSING LLC and

D I V I N E SPIRIT LLC, each registered in the state of Missouri.

J U D I C I A L N O T I C E

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 with any order o f 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 in 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.

J U R I S D I C T I O N AND V E N U E

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 A C T AND L E G A L BASIS

12. In an effort to not restate certain BACKGROUND, FACTS

A N D BRIEF I N SUPPORT of Defendant(s)' position previously submitted

to this Court as part of a copy of Defendant(s)' STATEMENT OF C L A I M

I N THE COMMON L A W INTERNATIONAL WORLD COURT,

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Defendant(s) hereby reallege and incorporate by reference herein, attaching

same as EXHIBIT 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

him a court appointed attomey and additionally Ordered a TEMPORARY

RESTRAINING ORDER, still in 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 in law, procedure or technicality.

15. A l 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 : B i 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 o f

legal counsel.

17. During an event hosted Oct. 30, 2009, by the UNC Center on

Poverty, Work and Opportunity in 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 in civil cases.

That should not be acceptable for a country that has "assumed the mantle o f

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 A i 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 in 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. A l l Club benefits/services/programs, none of which are

"investments", are offered ONLY to Club Members who have chosen their

own path o f education. Club benefits/services/programs are NOT offered or

open to the general public. Plaintiffs allegations o f "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 in 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.

Plaintiffs 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 with no promise of outcome, along

with 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 o f doing business and related expenses have been

overlooked by the Plaintiff.

24. To demonstrate the gross misapplication of law used in the

Plaint i ffs effort to support their position. In re: SEC v. ETS Payphones,

Inc., 408 F.3d 727, which is referenced on of PLAINTIFF

SECURITIES A N D EXCHANGE COMMISSION'S M E M O R A N D U M I N

SUPPORT OF ITS APPLICATION FOR A TEMPORARY

RESTRAINING ORDER, ASSET FREEZE, A N D OTHER EQUITABLE

RELIEF, on appeal by petition of THE SECURITIES A N D EXCHANGE

COMMISSION, from the UNITED STATES DISTRICT COURT FOR

THE NORTHERN DISTRICT OF GEORGIA, and in the event that there

was merit in the Plaintiff SEC not lending credibility to the decision of the

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Case 1:14-cv-02468-AT Document 28 Filed 10/10/14 Page 10 of 28

UNITED STATES DISTRICT COURT FOR THE NORTHERN

DISTRICT OF GEORGIA, we can fmd no comparison or application o f

circumstance or law and in fact is void of any practical application in 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, in 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 with 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. Plaintiffs allegations of "Unregistered Securities" are void of

any valid, legal basis.

27. Furthermore, Plaintiff is attempting to conduct a mere witch

hunt with total disregard of true fact or lack of education or both. With

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. NOTARIAL PROTEST, as defined in BLACK'S

L A W DICTIONARY 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 in 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 w i l l , (subsequent to their own research

and conclusions), which is a part of their Membership Contract, and in

accordance with 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. A l l administrative

services are provided to Members on a best effort basis. There is NO

promise of outcome, resuh, for services performed. There IS fu l l disclosure

of the presentment amount o f 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 o f the

service provided. Further, it is not a requirement as a Private Club Member

to participate in any one o f 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 Plaintiffs 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 Plaintiffs allegations. There are not sufficient facts to

support allegations that there are "securities" involved. Plaintiff

SECURITIES A N D 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 in 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

fomm to continue a void COMPLAINT and RESTRAINING ORDER,

ASSET FREEZE, A N D 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 in the very outcome of each of the various

services/programs in 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 in 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 in 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

in 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 in 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 o f "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 in 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 in 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), in 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. In Paragraph 4. o f Plaintiffs APPLICATION FOR

TEMPORARY RESTRAINING ORDER, ASSET FREEZE, A N D OTHER

EQUITABLE RELIEF, Plaintiff refers to certain information as "spinning a

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tale", in Paragraph 5., Plaintiff refers to certain information shared by

Defendant as a "fantastical story" and in Paragraph 12, there is reference to

"the scam". Further, in Plaintiffs COMPLAINT FOR INJUNCTIVE A N D

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 o f 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 with 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 o f 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, in fact, "spinning a tale" and a "fantastical story", to quote the

Plaintiff.

37. Evidence in 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

DECLARATION OF MATTHEW M C N A M A R A and a DECLARATION

OF K A R A Z S. Z A K I , Attachments 1 and 2, respectively.

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38. The DECLARATION OF M A T T H E W M C N A M A R A 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 DECLARATION 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 in same and contact with the "Treasury" with

reference to the "ARs".

39. The DECLARATION OF K A R A Z S. Z A K I , 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. A l 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 in

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 in 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 in

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. A l 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 in roughly the same way

that a book was. It had the added benefit o f additional protection, since it

was an on-demand method of communication.

44. We are a Club that offers a great deal o f information on many

different topics, we implore those who are uneducated to do their own due

diligence and findings of fact in 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 with 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, in THE UNITED

STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF

GEORGIA A T L A N T A DIVISION, rejected insider trading charges o f a

defendant who had a longtime friendship with a chief executive. In 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 in 2014, with 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 o f

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 o f 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.

P R A Y E R FOR R E L I E F

Defendant(s) seek the following relief


12. A n Order l if t ing all restraints and releasing in its entirety, all

pending Orders against Defendants in this matter, including ORDER TO

SHOW CAUSE, TEMPORARY RESTRAINING ORDER, ORDER

FREEZING ASSETS A N D FOR A N ACCOUNTING, ORDER

PROHIBITING DESTRUCTION OF DOCUMENTS, A N D 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 GRANTING dismissal with

prejudice.

14. Court fees and any and all costs o f this action against the

Defendants; and,

15. Any other relief the court deems just and proper.

Dated this 9̂^̂ day of October, 2014.

Isl Thomas J. Lawler Thomas J. Lawler 5077 Tanaga Court Stone Mountain, GA 30087

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C E R T I F I C A T E Q F C O M P L I A N C E

In accordance with 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

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C E R T I F I C A T E O F 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. T R I A L COUNSEL U.S. SECURITIES AND EXCHANGE COMMISSION 950 East Paces Ferry, N.E., Suite 900 Atlanta, GA 30326-1382

MATTHEW McNAMARA 950 East Paces Ferry, N.E., Suite 900 Atlanta, GA 30326-1382

K A R A Z Z A K I 950 East Paces Ferry, N.E., Suite 900 Atlanta, GA 30326-1382

G R E G O R Y S M O L E R 950 East Paces Ferry, N.E., Suite 900 Atlanta, GA 30326-1382

MADISON GRAHAM LOOMIS Regional Trial Counsel 950 East Paces Ferry, N.E., Suite 900 Atlanta, GA 30326-1382

F R E E D O M FOUNDATION USA L L C Dba F R E E D O M C L U B USA Registered Agent Laughlin Associates, Inc. 9120 Double Diamond Parkway Reno, NV 89521

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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

V I O L E T BLESSINGS L L C c/o Diane Lawler 5077 Tanaga Court Stone Mountain GA 30087

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Tom Lawler FCUSA Criminal

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