Thread: Traffic monsoon. Better than MAPS with trusted admin Charles Scoville

Originally Posted by path2prosperity

There is more chance of the origunal 1960s moon rockets being relaunched.

US or Russian? I might hedge a bet on the Russians.

Md continues the beatdown:
Muhammad Maf Rahman
" Charles, I apologise in advance for this long comment, you seem to be very selective when it comes to choosing which comments you reply to. In the hope that you will address some of the points below I don’t want to entertain the topic of whether or not TM is a ponzi in this comment. You have enthusiastically endorsed Jose’s points about self accountability and taking responsibility, so now is a chance to show some goodwill and make amends by displaying some of these traits yourself.

I also noted with interest a few days ago you claimed that no one has been able to provide evidence of foul play on your part by referencing your own actions and words (whether from your website or videos that you publicised) but rather people are solely using the words and actions of others to pass judgement on you.

Like many others on this forum I can cite multiple examples directly sourced to your actions/words/deeds which show that you deliberately misled people, displayed shocking judgement and were wholly unequipped/unqualified to run a multi-million dollar company. Perhaps I have seriously erred in my conclusion about you, in which case please help us reconcile the following issues which have led many to the same conclusion as me (in fairness I should also divulge that I asked these same questions to your mother, in a respectful tone of course, but did not receive an answer to any of the points):

1. You stated on your personal webpage that ad-packs are a low volume/low demand product; but the truth is TM was designed to primarily sell the ad-pack product (Business Ventures | Charles Scoville)

2. Again as per your website and countless videos, you stated as a matter of fact that revenue from the sale of products apart from the ad-pack is what creates the profit margins for TM and replenishes the revenue share program. But as per your SEC interview the truth was that 99.6% of revenue came from ad-packs and you misled people on this along with concealing the true nature of your business model (Documented in Exhibit A & B of original SEC TRO/complaint)

3. You claimed that TM was only selling advertising products for people’s businesses; but why did you then allow a significant number of the people who signed up, to use the TM ad banner? You must have surely seen a pattern developing where members just brought ad-packs without a business to advertise or without the intention of directing any traffic to their business, but you continued to let these sales go through? Were you more interested in soliciting their money or selling them a genuine service?

4. You continuously turned a blind eye whilst many of your leaders promoted TM as an investment; moreover I have it on good authority that ‘Sheikh’ Imran Ibn Nauth was one of your spiritual/religious teachers as well as a business partner (I’m not sure which of these two relationships was more important for either of you). Imran has publicly stated that he has known you for years and even advised you on how to ensure TM is Sharia compliant. So can you explain why Imran ibn Nauth – your spiritual godfather - also described TM as investment in the following link: https://risingtrafficmonsoon.wordpress.com/tag/halal/; when most of your inner circle refers to TM as an investment (whilst also producing and promoting ‘compounding formulas’ using excel with no reference to advertising) isn’t it then disingenuous for you to claim TM is not an investment?

5. As per Exhibit A and your interview with the SEC, you purposefully misled people on why Paypal had frozen the TM account; you were comfortable with hiding the real reasons behind this break with PP

6. You stated as a matter of fact that TM was moving away from PP as a strategic decision when in truth you were forced into this move because PP cut ties with TM

7. You continued to let people pour money into PP for nearly a whole month, when you knew that this money would be frozen as per the notice given to you by PP in early January. Had you come clean right at the beginning about the PP freeze then a significant number of your customers that you allegedly care about so much (some of them very poor) could have minimised the money they had lost as part of the PP freeze. Is this the type of behaviour expected from a CEO who cares about his members?

8. On numerous occasions immediately following the PP freeze you made definitive statements that the TM World Bank was a formality, on the verge of opening in a few days and even publicly set a date for the bank going live. Only to renege on this promise and then offer an elaborate story of how you were misled by the TM bank setup team. Really, you are the CEO of a company and you can be duped into thinking that your bank was on the verge of opening? How can someone display such reckless lack of oversight in running their own company? You couldn’t even deliver the TM credit cards/TM Allied Wallet cards that you promised on numerous webinars that you held with your gushing fanboys

9. What happened to the TM office that was meant to open in the Dubai World Trade Centre that you so proudly proclaimed?

10. What happened to the prominent member linked to the Emirati Royal Family that had joined TM? What about the time you sat next to your friend Aamer in Dubai and endorsed him while he claimed that TM was a ‘sizzling volcano’ about to burst and become bigger than facebook whilst eradicating poverty? Is it prudent for a CEO to endorse these outlandish claims when they hold no truth?

11. Announcing that Amin Forati was the CFO for TM with an emphasis on his ‘honour, dignity, integrity and exceptional character’ when in reality he did nothing for TM and had questionable credentials along with a controversial business past which include allegations of fraud and embezzlement. Only for you to declare a few weeks later that Forati had no real role and left TM. How can you show such a lack of due diligence in important business decisions? How did you expect the TM community to react when you partnered up with these types of shady characters?

(CONT).......

12. Your questioning by the SEC and their investigation into TM had the potential to massively impact on the livelihoods of TM members, but you hid the fact you were under investigation for months until the asset freeze was made public. Is this a responsible and transparent behaviour of a CEO?

13. Hiding the fact that for over 2 weeks PP had released the company funds, secretively moving these funds into your personal account (in any reputable company this would be seen as suspect at best and embezzlement at worst) whilst continuing to leave TM members under the impression that the PP funds would be released in August. Then providing contradictory reasons for why you had to move the money to your personal account; which includes a dubious text message conversation (with no date/time stamp i.e. could easily be photoshopped) with your bank manager. Which reputable bank conducts business/or notifies customers of potential fraud via informal text messaging?

14. As was evidenced in your deposition and SEC exhibits how can you justify using an excel spreadsheet and the ‘expert’ help of an IT geek to manage nine figures sums? SME’s, local businesses and self employed people with a fraction of the income that TM generated would rely on professional accounting services to manage their finances, but you took the conscious decision to manage this using an MS office tool? Have you not heard of accounting software like Sage? Would any competent CEO manage their company’s finance like the way you did?

15. How do you justify having no company structure, departments, finance managers, operations managers, company board? Instead you chose to run a multi-million dollar revenue company from your laptop and cascaded operational updates via FB, is this a robust and transparent way of running a successful company?

16. You arrogantly claimed on FB to have made $80m (then deleted the post, something i’ll come onto later) even though your questionable tax return filings make no such reference. How do you think people, some of whom who have lost a large chunk of their savings on TM and are struggling, would feel after hearing this from you?

17. You publicly claim to live a frugal and humble lifestyle with no materialistic inclinations and an enthusiasm to rid the world of poverty......but the SEC’s exhibits show that you spent money on multiple properties, cars as well as having 7 figures worth of cash in your personal bank account before the asset freeze. What about the money you no doubt wasted on people who did nothing for the company from the Dubai fiasco? Did you display any frugality in hiring people who did nothing, or in paying Ernie Ganz for providing outsourced customer services which was pretty much non-existent anyway?

18. Displaying a consistent lack of transparency by not publishing any business accounts/annual reports for TM and rushing to delete your history of facebook posts (including deleting posts with outlandish claims immediately after posting them). What would people think about your lack of audit trails especially when they can clearly see you getting rid of anything that could come back to haunt you? Is this the behaviour of an innocent man?

19. You showed a total disregard for data protection and confidentiality by releasing the software code and TM database to third parties which allowed for TM+ and Traffic Hurricane to be setup online. Service managers and company directors are sacked for data breaches that are less severe, how can you justify such reckless handling of sensitive data? Ironically you then cited the example of the data breach involving Hillary Clinton and how no charges were brought against her

20. Finally you’ve had a history of opening similar schemes which ended up failing and also led to people losing their money; but with TM there was a stark difference. Can you admit that you never intended or planned that TM would grow so big? Deep down you probably expected it to be another low level below the radar scheme, but in the end it grew so big that it caught the attention of the authorities, so in essence you were a victim of the very success this scheme garnered

These examples are only a drop in the ocean, all of which can be corroborated from court documents, your own youtube videos and websites that have saved all your previous FB posts. Unfortunately facebook does not allow me to list multiple web links in a comment for some weird reason, but if you do dispute these points then I am happy to list the evidence (youtube videos, websites etc directly sourced to you) for these points in subsequent posts.

Charles in light of the above can you honestly say with a straight face that, people who mistrust you or have raised doubts, have done so purely on the basis of conjecture, speculation and hearsay? Do you still not see why people are venting so much anger and frustration towards you?"
Like · 53 mins

Jose Nonsense responded with a cheezy video. (I only made it a few minutes in)
Filth is aging in dog years. Felling that $ crunch?
He should have budgeted his ponzi $ better.

Sad combination of ignorance and scammer dogma.

Where is this filth from before Wales? Their education system should ashamed.....

If Lynndel to the car wash William works at=he gets the normal wash even though he paid for deluxe.
William will show dem haterz.....

William aint fraid no haters.jpg

Guess William didn't like me exposing his hero being in prison as he just banned me from his group. You can bet my last post was taken down by now.

Hmm, I thought he wasn't afraid of "any haters?" Guess he's afraid of me or he wouldn't have banned me. Just another panty-waist trying to act tough.

Originally Posted by Fat City, LA

Md continues the beatdown:

**** storm snipped just to say if he thinks this is bad, wait til the authorities get done with him. lol

As per normal, the longer the saga goes on, the more nonsensical the fraud defenders need to become in their attempts to defend the indefensible.



William G Bryants' wgbryant page on Facebook

I'll tell you what, Billy, get Scoville to go with the "passion" and "lurve" strategy while the prosecutors go with facts and you can kiss your guru goodbye for a long, long time.

I guess that's what happens when someone gains their legal knowledge from television, rather than real life.

From the courts:

Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 1 of 9
D. Loren Washburn (#10993)
loren@washburnlawgroup.com
THE WASHBURN LAW GROUP LLC
50 West Broadway, Suite 1010
Salt Lake City, UT 84101
Telephone: (801) 477-0997
Facsimile: (801) 477-0988
John E. Durkin (#15308)
jdurkin@smithcorrell.com
SMITH CORRELL, LLP
124 West 1400 South, Suite 204
Salt Lake City, UT 84115
Telephone: (801) 436-5550
Facsimile: (866) 784-6991
Attorneys for Traffic Monsoon, LLC, and
Charles Scoville
IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF UTAH
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.
TRAFFIC MONSOON, LLC, a Utah Limited
Liability Company, and CHARLES DAVID
SCOVILLE, an individual,
Defendants.
DEFENDANT’S SURREPLY TO
PLAINTIFF’S REPLY IN SUPPORT OF
PRELIMINARY INJUNCTION
Civil No.: 2:16-cv-00832 JNP
Judge: Jill N. Parrish
By this motion, Defendant Scoville replies to the arguments raised in the SEC’s Reply
Brief, which were not raised in its Motion for Preliminary Injunction, namely, that Section
929P(b) statutorily overruled the Supreme Court’s opinion in Morrison v. Nat'l Australia Bank
Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 2 of 9
EXHIBIT A
2
Ltd., 561 U.S. 247, 130 S. Ct. 2869, 177 L. Ed. 2d 535 (2010). For the reasons cited below the
SEC’s arguments are unavailing and nothing in the Dodd-Frank legislation changed the effect of
Morrison’s holding on the viability of the SEC’s claims here.
ARGUMENT
In the SEC’s Reply Brief, the Commission spends 18 pages engaging in a tortured attempt
to convince this Court to ignore the two most basic rules of statutory interpretation. First, a court
must analyze the “statutory language, assuming that the ordinary meaning of that language
accurately expresses the legislative purpose.” Hardt v. Reliance Standard Life Ins. Co., 560 U.S.
242, 251, 130 S. Ct. 2149, 2156, 176 L. Ed. 2d 998 (2010) (quoting Gross v. FBL Financial
Services, Inc., 557 U.S. 167, 129 S.Ct. 2343, 2350, 174 L.Ed.2d 119 (2009)). Second, a court must
enforce “plain and unambiguous statutory language according to its terms.” Id.
Because the statutory language the SEC relies on in its brief is clear and unambiguous —
and ultimately supports Defendants’ argument — the SEC’s reply reaches an improper conclusion
of law: that under the Supreme Court’s holding in Morrison v. Nat'l Australia Bank Ltd., 561 U.S.
247, 130 S. Ct. 2869, 177 L. Ed. 2d 535 (2010), that the U.S. Securities laws do not apply to
purchases or sales of securities1
outside the United States is no longer the law. This is not the first
time the SEC has made this same argument, but no Court has yet adopted the SEC’s tortured
reading of the interplay between the Supreme Court’s decision in Morrison and Section 929P(b)
of Dodd-Frank. See e.g. United States Sec. & Exch. Comm'n v. Battoo, 158 F. Supp. 3d 676, 692
n.12 (N.D. Ill. 2016).

1 Scoville argued in his opposition that AdPacks are not securities and that therefore the U.S.
Securities laws don’t apply in any event and he maintains that argument. For purposes of this
surreply that argument need not be resolved since even if AdPacks are securities, since the
purchase and sale of 90% of the Adpacks took place outside the United States, the laws at issue
in the SEC’s complaint do not apply.
Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 3 of 9
EXHIBIT A
3
I. SECTION 929(P)(B) OF THE DODD-FRANK ACT DID NOT CHANGE THE LAW
ESTABLISHED IN MORRISON BECAUSE SECTION 929(P)(B) DEALS SOLELY
WITH JURISDICTION.
A. Morrison Held that Courts Have Jurisdiction Over Extraterritorial Claims
But The Anti-Fraud Provisions Are Not Applicable To Purchases or Sales of
Securities Outside The United States.
In Morrison, the United States Supreme Court decided two issues: (1) the jurisdiction
question: whether a federal court has jurisdiction to hear a case alleging extraterritorial violations
of the securities laws; and (2) the merits question: whether the anti-fraud provisions of the U.S.
Securities laws apply to sales of securities not made in the United States and not listed on a
domestic exchange.
The Supreme Court answered the first question in the affirmative: “[t]he District Court here
had jurisdiction under 15 U.S.C. § 78aa to adjudicate the question whether § 10(b) applies.”
Morrison at 254.
As to the second question, the Court held that “Section 10(b) reaches the use of a
manipulative or deceptive device or contrivance only in connection with the purchase or sale of a
security listed on an American stock exchange, and the purchase or sale of any other security in
the United States.” Morrison at 273. In other words, although the district court in Morrison had
jurisdiction to hear the claim, the plaintiffs could not state a claim because Section 10(b) does not
apply to extraterritorial conduct. The Supreme Court stated its opinion clearly: the anti-fraud
provisions of the U.S. Securities laws did not prohibit extraterritorial conduct, and that this was
not an issue of jurisdiction. Because those substantive provisions of law have not been changed,
this is still the law today.
B. Section 929 of Dodd-Frank Merely Codified the Supreme Court’s Decision in
Morrison That District Courts Have Jurisdiction Over Extraterritorial
Claims, But it Does Not Change The Substantive Prohibitions of Any Law.
After the decision in Morrison, as explained at great length in the SEC’s brief, Congress
passed the Dodd-Frank Act. Section 929 of Dodd-Frank provides (“the “Jurisdiction Provision”),
in relevant part:
Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 4 of 9
EXHIBIT A
4
(b) EXTRATERRITORIAL JURISDICTION.—The district courts of the United
States and the United States courts of any Territory shall have jurisdiction of an
action or proceeding brought or instituted by the Commission or the United States
alleging a violation of the antifraud provisions of this title involving
(1) conduct within the United States that constitutes significant steps in
furtherance of the violation, even if the securities transaction occurs outside the
United States and involves only foreign investors; or
(2) conduct occurring outside the United States that has a foreseeable
substantial effect within the United States.
(Id. (emphasis added).)
This statutory language of the Jurisdiction Provision is clear and unambiguous—it grants
district courts jurisdiction over certain extraterritorial claims, nothing more. The plain language of
the statute merely codified the Supreme Court’s holding in Morrison that district courts have
“jurisdiction under 15 U.S.C. § 78aa to adjudicate the question whether § 10(b) applies.” Morrison
at 254. Thus, while the SEC claims that this section was a Morrison “fix”, in fact the plain language
of the Jurisdiction Provision makes clear it is a codification of the jurisdictional holding in
Morrison. It also bears noting that nothing in Morrison needs to be fixed. Merely from the SEC’s
benighted perspective could it be interpreted that anything that limited their discretion was
necessarily broken and needed to be “fixed.”
“It is well established that ‘when the statute's language is plain, the sole function of the
courts—at least where the disposition required by the text is not absurd—is to enforce it according
to its terms.’” Lamie v. U.S. Tr., 540 U.S. 526, 534, 124 S. Ct. 1023, 1030, 157 L. Ed. 2d 1024
(2004) (quoting Hartford Underwriters Ins. Co. v. Union Planters Bank, N. A., 530 U.S. 1, 6, 120
S.Ct. 1942, 147 L.Ed.2d 1 (2000)). Here, the terms of Jurisdiction Provision are clear and not
absurd. “Section 929P(b), on its face, merely addresses subject matter jurisdiction … rather than
the substantive reach of the U.S. Securities Laws.” SEC v. Chicago Convention Center, LLC, 961
F. Supp. 2d 905 (N.D. Ill. 2013). Because the Jurisdiction Provision’s terms only grant jurisdiction,
that section does not “fix” the SEC’s inability to move forward with 90% of the sales at issue.
Morrison’s holding that the anti-fraud provisions of the Securities and Exchange Acts apply “only
Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 5 of 9
EXHIBIT A
5
in connection with the purchase or sale . . . of a security in the United States.” Morrison, 561 U.S.
at 273.
Because the statute’s language is clear and unambiguous, the SEC’s lengthy brief
recounting statements made during the passing of the law is irrelevant. “When the meaning of the
statute is clear, it is both unnecessary and improper to resort to legislative history to divine
congressional intent.” Edwards v. Valdez, 789 F.2d 1477, 1481 (10th Cir. 1986) (emphasis added).
The Jurisdiction Provision is clear, must be applied according to its terms, and does nothing to cast
doubt on Defendants’ argument that the SEC cannot prevail on more than 90% of its claims.
Moreover, even if examining legislative history were appropriate—which it is not—the
SEC’s examination of legislative history relies entirely on one legislator’s statements. The
statements of a single legislator are an unreliable indication of the meaning of a statute, particularly
where, as here, the statement conflicts with plain language of the statute. Heinz v. Central
Laborers’ Pension Fund, 303 F.3d 802, 809 (7th Cir. 2002) (holding that “undue weight” was
accorded to the statement of a single congressman, whose statement was “at odds with the
straightforward language of the statute.”)
II. DESPITE THE SEC MAKING THE SAME ARGUMENTS THEY MAKE HERE
IN MULTIPLE COURTS, NO COURT HAS HELD THAT SECTION 929
AMENDED THE ANTI-FRAUD PROVISIONS AS WOULD BE NECESSARY TO
“FIX” THE SEC’S MORRISON ISSUES.
Starting on page 3 of the SEC’s Reply, the SEC argues at length that the Jurisdiction
Provision is a “fix” for the problem that U.S. Securities Laws do not apply when the purchases and
sales of over 90% of the AdPacks took place outside the United States; assuming AdPacks are
even securities. In claiming that the Supreme Court’s holding in Morrison has been “fixed” by the
Jurisdiction Provision, the SEC fails to note that in the years since the Jurisdiction Provision
passed, not a single court has ruled as the SEC asks this Court to rule here. The SEC has advanced
the exact same argument they advance here as in other cases—indeed multiple paragraphs in the
SEC’s brief here are word-for-word copies of paragraphs from the SEC’s previous briefing in other
Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 6 of 9
EXHIBIT A
6
districts—multiple times. See Response to Defendants Motion to Dismiss at 16, SEC v. Brown,
No. 14 C 6130 (N.D. Ill. Mar. 4, 2015). To the extent district courts have directly answered the
question, they find the SEC’s arguments lack merit.
For example, in United States Sec. & Exch. Comm'n v. Battoo, 158 F. Supp. 3d 676, 692
n.12 (N.D. Ill. 2016), the court addressed the SEC’s alleged “Morrison fix” argument. As the court
there simply and briefly stated: “There is no binding case law that decides whether the Dodd-Frank
Act reinstated the conduct-and-effects test for actions brought by the SEC. As the SEC
acknowledges, some courts have expressed doubt that Section 929P(b) overruled Morrison.”
(emphasis added). (See id. at n. 12). The Battoo opinion continues, “[T]he Supreme Court did not
decide Morrison on jurisdictional grounds, but rather held that the pertinent securities law did not
cover ‘foreign’ transactions.” (Id. citing SEC v. Chicago Convention Center, LLC, 961 F. Supp.
2d 905 at 2–10 (N.D. Ill. 2013) (analyzing whether Section 929P(b) effectively
superseded Morrison)).
The SEC has heard this response in other cases since the enactment of Dodd-Frank
Jurisdiction Provision. In SEC v. Brown, No. 14 C 6130 (N.D. Ill. Mar. 4, 2015) the court found
that:
construing the Dodd-Frank Act to supersede Morrison may be problematic. The
new language refers specifically to the "jurisdiction" of district courts and appears
in the sections of the ‘33 Act and the ‘34 Act entitled "Jurisdiction of offenses and
suits.” On one reading of the new language, the Dodd-Frank Act merely confirmed
the power of district courts to hear securities law claims without clearly expressing
Congress’ intent to apply the statutes to foreign transactions.
(See also SEC v. Sabrdaran, No. 14-cv-04825-JSC (N.D. Cal. Sept. 14, 2016) reaching
same conclusion).
Without informing the Court that this argument has been presented but never accepted
before, the SEC is asking this Court to be the first court in the nation to ignore the plain language
of the statute and interpret the Jurisdiction Provision to effectively modify the anti-fraud provisions
that were at issue in Morrison even though the plain language of the statute does nothing of the
sort.
Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 7 of 9
EXHIBIT A
7
III. THE SEC’S ARGUMENT IS BOTH ILLOGICAL AND ABSURD.
The SEC suggests to the Court that the Jurisdiction Provision “fixed” their Morrison issue,
which is to say it returned the law to the state it was at before the Supreme Court’s opinion. This
argument makes little sense for two reasons: (1) it makes little sense to “fix” a merits issue by
passing a section affecting only jurisdiction; and (2) the pre-Morrison world to which the SEC
asks the Court to return was characterized by a patchwork of complex, unpredictable, and
inconsistent tests applied across the country.
A. If Congress Wanted To Reverse Morrison, the Supreme Court’s Opinion Gave
a Clear Roadmap of How to Do So, Which Congress Did Not Do.
As noted above, the Supreme Court’s opinion in Morrison was clear and not difficult to
comprehend: the courts of the United States have jurisdiction to hear extraterritorial claims but the
anti-fraud provisions do not apply extraterritorially. The opinion could not have been more clear
that jurisdiction was not the problem, the breadth of the substantive prohibition was. If Congress
wanted to “fix” Morrison, which is to say statutorily reverse it, it merely needed to amend the antifraud
statutes to express a clear intent that they apply to sales of securities outside the United
States. It did not.
The SEC would have the Court believe that Congress “fixed” their Morrison issue not by
addressing the substantive anti-fraud statutes at all. Instead, stupefyingly, according to the SEC’s
version, Congress “fixed” Morrison by passing a statute that, on its face, addressed only
jurisdiction, the part the Supreme Court in Morrison said was not a problem, and not the limitation
the Supreme Court recognized, namely that the anti-fraud sections of the U.S. Securities laws do
not prohibit extraterritorial conduct.
This defies belief. Why would Congress, if it truly wanted to “fix” Morrison, pass a statute
that “fixed” only what was not broken and left alone only what the SEC believes was?
Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 8 of 9
EXHIBIT A
8
B. There is No Conduct and Effects Test; There are multiple contradictory
inconsistent Conduct, Effects, and Conduct and Effects Tests.
The SEC suggests to the Court that Congress intended to effectively reverse Morrison and
reinstate the conduct and effects test. The Supreme Court’s opinion in Morrison noted that the
conducts and effects test “has produced a collection of tests … complex in formulation and
unpredictable in application” (Morrison, 561 U.S. at 248). This is because, prior to Morrison, the
“conduct and effects test” was the subject of a multiple circuit split including the Second2
, Third,3
Eight4
and Ninth Circuit Courts5
. Thus, the SEC is asking this Court to believe that Congress,
through a statute that references only jurisdiction, re-imposed a convoluted, contradictory test for
determining the reach of extraterritoriality of the anti-fraud provisions. This improbable result is
simply not supported by the text of statute that Congress passed.
CONCLUSION
For all the foregoing reasons, Defendant respectfully requests the Court decline the
Commission’s invitation to become the first court in the country to rule that the Jurisdiction
Provision of the Dodd-Frank reversed the Supreme Court’s ruling in Morrison. Defendant further
requests that the Court rule consistent with his Opposition and exclude the over 90% of
transactions that took place outside the United States from any of the relief sought by the SEC.
DATED this 12th day of October, 2016. WASHBURN LAW GROUP, LLC
/s/ D. Loren Washbburn
D. LOREN WASHBURN
Counsel for Defendants

2
Schoenbaum v. Firstbrook 405 F.2d 200, 206,209 (2d Cir. 1968) (using the effects portion of
the test) and Leasco Data Processing Equipment Corp. v. Maxwell, 468 F.2d 1326, 1334 (2d.
Cir. 1972) (using the conduct portion of the test).
3
SEC v. Kasser, 548 F.2d 109, 114 (3d Cir. 1977)
4 Cont’l Grain (Austl.) Pty Ltd. v. Poe Oilseeds, Inc., 592 F.2d 409, 421 (8th Cir. 1979).
5 Grunenthal GmbH v. Hotz, 712 F.2d 421, 424 (9th Cir. 1983)

So, I have a question. Would you report someone to their employers in the UK if you found out they were promoting Traffic Monsoon, and now Traffic Hurricane? Especially if this person is a lawyer in the UK?

I'd report it in an instant.

We're not talking a few guys having fun here, we're talking blatant fraud on a large scale.

For a lawyer to participate in fraud of this nature is unforgiveable, ESPECIALLY if he / she is using their legal expertise to give the fraud credibility, and, in Traffic Monsoons' case at least, deliberately targeting people in poor and third world countries.



UK Solicitors Regulation Authority



UK Law Society

Yeah, it's Immy's nephew Amar Alyas. Heard some complaints from his downline.

Amar Alyas - the Rev Share lawyer - Where to Find Wealth

Mama Shirley set up a Go Fund me page for Charles yesterday. Sharon finally found her calling...

Sharon_James.jpg

Sharon makes it sound like being blocked by a failed ponzi pimp is somehow a bad thing.

Originally Posted by Bestbud

Mama Shirley set up a Go Fund me page for Charles yesterday. Sharon finally found her calling...

Sharon_James.jpg

Similar to SCAMey Williams, she does herself no favors with that profile pic. Arse faced slobs just seem less credible on face value.
Who is that w Sharon? Elena?

Oh, look everyone! ANOTHER PETITION!!

TM 352 Oct 16.jpg TM 353 Oct 16.jpg

And who has started this one? Step forward Pinakee Naik, Traffic Monsooner and former Banner Broker affiliate.

Twenty six signatures so far, petition to be delivered to President Obama. Gosh, that's all he needs in his last few weeks in the Oval Office.

Originally Posted by Bestbud

Mama Shirley set up a Go Fund me page for Charles yesterday. Sharon finally found her calling...

Sharon_James.jpg

And how well is it doing?

TM 354 Oct 16.jpg

So, a bit of a way to go then!

doesnt matter what they donate, the american t w a t is going down, goodnight scoville!

I believe they are violating gofundme's TOC soliciting donations to defend criminal activity. wonder how much more money the scammer has raked in under the guise of 'legal fund'?

Originally Posted by Not So Lucky

From the courts:

Case 2:16-cv-00832-JNP Document 41-1 Filed 10/12/16 Page 1 of 9
D. Loren Washburn (#10993)
loren@washburnlawgroup.com
THE WASHBURN LAW GROUP LLC
50 West Broadway, Suite 1010
Salt Lake City, UT 84101
Telephone: (801) 477-0997
Facsimile: (801) 477-0988
John E. Durkin (#15308)
jdurkin@smithcorrell.com
SMITH CORRELL, LLP
124 West 1400 South, Suite 204
Salt Lake City, UT 84115
Telephone: (801) 436-5550
Facsimile: (866) 784-6991
Attorneys for Traffic Monsoon, LLC, and
Charles Scoville
IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF UTAH
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.
TRAFFIC MONSOON, LLC, a Utah Limited
Liability Company, and CHARLES DAVID
SCOVILLE, an individual,
Defendants.
DEFENDANT’S SURREPLY TO
PLAINTIFF’S REPLY IN SUPPORT OF
PRELIMINARY INJUNCTION

The reply by the SEC was filed the next day.

https://www.scribd.com/document/3276...00832JNP-DOC42

Originally Posted by Fat City, LA

Jose Nonsense responded with a cheezy video. (I only made it a few minutes in)
Filth is aging in dog years. Felling that $ crunch?
He should have budgeted his ponzi $ better.

Sad combination of ignorance and scammer dogma.

Where is this filth from before Wales? Their education system should ashamed.....

Md is back, Jose Nonsense is erasing his posts. I took screenshots before its gone.
I didnt post screenshots MD put up. 2 small to screenshot / repost.
They start here:
https://www.facebook.com/groups/Traf...%3A%22R9%22%7D

charles looks stupid again.jpg
1charles looks stupid again.jpg
2charles looks stupid again.jpg
3charles looks stupid again.jpg
4charles looks stupid again.jpg
"Muhammad Maf Rahman
So you have never claimed that the $50 ad-pack product was a lower volume/lower demand product from the suite of products and services you were selling? Also please address the question about how you fund the 'commission' payouts, where do the profits come from to pay for the 'commission'?"
Like · 12 mins

Cont the post just above

Scamville must be feeling more manic than normal tonight. More nonsense than usual.

1stcharles a sorry sob.jpg
2ndcharles a sorry sob.jpg
3dcharles a sorry sob.jpg
4th.jpg
md sets it right before bed.jpg


Another post? This is fun...
More cluckin from the Shitbird ie Mark Cuban and a totally different fact pattern / bz model.
https://www.facebook.com/groups/Traf...0150752685735/

from
https://www.facebook.com/groups/Traf...%3A%22R0%22%7D

more lies.jpg
2more lies.jpg
3more lies.jpg
4more lies.jpg

Last 1 for tonight. Beautiful in NOLA, headed out to Frenchmens St.

MD just toying w/Scamville & Jose Nonsense.
He has Charles ranting about Satan, Jose just too stupid for anything above name calling.

1laying it on thick.jpg
1Blaying it on thick.jpg
2laying it on thick.jpg
3laying it on thick.jpg
4laying it on thick.jpg

Charlie Scoville has once again given us a perfect example of the ponzi apologists tactics in action.

Scoville said:



And here is the actual wording used in the complaint submitted to (and accepted by) the court.







Don't be distracted, Scoville is being accused of:

a) FIRST CAUSE OF ACTION
EMPLOYMENT OF A DEVICE, SCHEME OR ARTIFICE TO DEFRAUD
Violation of Section 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)]

b) SECOND CAUSE OF ACTION
FRAUD IN THE OFFER OR SALE OF SECURITIES
Violation of Section 17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(3)]

c) THIRD CAUSE OF ACTION
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
Violation of Section 10(b) of the Securities Act [15 U.S.C. § 78j(b)] and Rule 10b-5(a) and
(c) thereunder [17 U.F.R. § 240.10b-5(a) and (c)]

d) FOURTH CAUSE OF ACTION
OFFER AND SALE OF UNREGISTERED SECURITIES
Violation of Sections 5(a) and (c) of the Securities Act [15 U.S.C. § 77e(a) and (c)]

Originally Posted by littleroundman

Charlie Scoville has once again given us a perfect example of the ponzi apologists tactics in action.

Scoville said:

even Madoff wasn't stupid enough to say his ponzi wasn't a ponzi until he couldn't pay anymore. lol