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 Receivership Information

C. Randel Lewis was appointed as the Receiver for the Mueller Receivership.
 
This website is maintained by Lindquist & Vennum P.L.L.P., attorneys for C. Randel Lewis, in his capacity as Receiver.  The purpose of the site is to provide selected pleadings, documents, key dates and status reports to interested parties regarding this matter.  Neither the Receiver nor his counsel can or will provide legal advice to creditors, investors, or other interested parties.  As the Mueller Receivership proceeding is a complex legal matter, all parties are encouraged to retain and consult with their own legal counsel regarding this matter.

 Pleadings

Howells - FINRA - Amended Statement of Claim 051412.pdf
Howells - FINRA - Amended Statement of Claim 051412Use SHIFT+ENTER to open the menu (new window).
5/14/201231037 KB
Jefferies - FINRA - Statement of Claim.pdf
Jefferies - FINRA - Statement of ClaimUse SHIFT+ENTER to open the menu (new window).
4/16/20127728 KB
Receiver's December 2011 Report.pdf
Receiver's December 2011 ReportUse SHIFT+ENTER to open the menu (new window).
12/9/2011260 KB
Third Submission of Application for Fees and Expenses.pdf
Third Submission of Application for Fees and ExpensesUse SHIFT+ENTER to open the menu (new window).
12/9/201182 KB
Receiver's Status Report Re Pending Cases and Withdrawal of Rule 16 Motion 08302011.pdf
Receiver's Status Report Re Pending Cases and Withdrawal of Rule 16 Motion 08302011Use SHIFT+ENTER to open the menu (new window).
8/30/2011216 KB
Notice of Hiring of Out of State Counsel 071311.pdf
Notice of Hiring of Out of State Counsel 071311Use SHIFT+ENTER to open the menu (new window).
7/13/2011107 KB
Order Approving Settlement Agreements and Dismissal of Actions.pdf
Order Approving Settlement Agreements and Dismissal of ActionsUse SHIFT+ENTER to open the menu (new window).
6/23/201136 KB
Motion to Approve Settlement Agreements (Little, Hemmert, Anderson, Foote).pdf
Motion to Approve Settlement Agreements (Little, Hemmert, Anderson, Foote)Use SHIFT+ENTER to open the menu (new window).
6/21/20112511 KB
Motion Approve Settlement Agreement Angie Mueller.pdf
Motion Approve Settlement Agreement Angie MuellerUse SHIFT+ENTER to open the menu (new window).
6/8/20111151 KB
Second Application for Fees and Expenses.pdf
Second Application for Fees and ExpensesUse SHIFT+ENTER to open the menu (new window).
6/8/2011303 KB
First Amended Complaint - Giglio.pdf
First Amended Complaint - GiglioUse SHIFT+ENTER to open the menu (new window).
6/3/2011575 KB
Motion to Consolidate.pdf
Motion to ConsolidateUse SHIFT+ENTER to open the menu (new window).
6/3/2011744 KB
Complaint - Lewis v Anderson.pdf
Complaint - Lewis v AndersonUse SHIFT+ENTER to open the menu (new window).
4/22/201179 KB
Complaint - Lewis v Gerard C. Lewis.pdf
Complaint - Lewis v Gerard C. LewisUse SHIFT+ENTER to open the menu (new window).
4/22/201178 KB
Complaint - Lewis v Giglio.pdf
Complaint - Lewis v GiglioUse SHIFT+ENTER to open the menu (new window).
4/22/2011486 KB
Complaint - Lewis v Ginsburg.pdf
Complaint - Lewis v GinsburgUse SHIFT+ENTER to open the menu (new window).
4/22/201180 KB
Complaint - Lewis v Hemmert.pdf
Complaint - Lewis v HemmertUse SHIFT+ENTER to open the menu (new window).
4/22/201179 KB
Complaint - Lewis v Holderman.pdf
Complaint - Lewis v HoldermanUse SHIFT+ENTER to open the menu (new window).
4/22/201179 KB
Complaint - Lewis v Hughes.pdf
Complaint - Lewis v HughesUse SHIFT+ENTER to open the menu (new window).
4/22/201180 KB
Complaint - Lewis v KingRogerLee Partnership, et al.pdf
Complaint - Lewis v KingRogerLee Partnership, et alUse SHIFT+ENTER to open the menu (new window).
4/22/2011106 KB
Complaint - Lewis v Little.pdf
Complaint - Lewis v LittleUse SHIFT+ENTER to open the menu (new window).
4/22/201178 KB
Complaint - Lewis v Mountain Shadows MHS LLLP.pdf
Complaint - Lewis v Mountain Shadows MHS LLLPUse SHIFT+ENTER to open the menu (new window).
4/22/201180 KB
Complaint - Lewis v Rocky Mountain Radiologists P-S Plan fbo Pertcheck and Pertcheck.pdf
Complaint - Lewis v Rocky Mountain Radiologists P-S Plan fbo Pertcheck and PertcheckUse SHIFT+ENTER to open the menu (new window).
4/22/201180 KB
Complaint - Lewis v Sweet.pdf
Complaint - Lewis v SweetUse SHIFT+ENTER to open the menu (new window).
4/22/201181 KB
Complaint - Lewis v. Foote 042211.pdf
Complaint - Lewis v. Foote 042211Use SHIFT+ENTER to open the menu (new window).
4/22/201178 KB
Complaint - Stature Multi-Allocation Fund LLC, and Capital Management Group, LLC.pdf
Complaint - Stature Multi-Allocation Fund LLC, and Capital Management Group, LLCUse SHIFT+ENTER to open the menu (new window).
4/22/201180 KB
Order Deny Intervention 112310.pdf
Order Deny Intervention 112310Use SHIFT+ENTER to open the menu (new window).
11/23/201033 KB
Reply in Support of Motion to Intervene 111210.pdf
Reply in Support of Motion to Intervene 111210Use SHIFT+ENTER to open the menu (new window).
11/12/201034 KB
Sec Commr Response to Motion to Intervene.pdf
Sec Commr Response to Motion to InterveneUse SHIFT+ENTER to open the menu (new window).
11/2/2010266 KB
Sec Commrs Response to Motion to Intervene 110210.pdf
Sec Commrs Response to Motion to Intervene 110210Use SHIFT+ENTER to open the menu (new window).
11/2/201048 KB
Receivers Response to Motion to Intervene 102910.pdf
Receivers Response to Motion to Intervene 102910Use SHIFT+ENTER to open the menu (new window).
10/29/201047 KB
Arrest Warrant with Affidavit and Charges 101210.pdf
Arrest Warrant with Affidavit and Charges 101210Use SHIFT+ENTER to open the menu (new window).
10/12/2010638 KB
Motion to Intervene and Complaint 101210.pdf
Motion to Intervene and Complaint 101210Use SHIFT+ENTER to open the menu (new window).
10/12/2010565 KB
Mueller Order Establishing Claims Administration Procedure.pdf
Mueller Order Establishing Claims Administration ProcedureUse SHIFT+ENTER to open the menu (new window).
9/30/201068 KB
Notice re Hein and Associates 081910.pdf
Notice re Hein and Associates 081910Use SHIFT+ENTER to open the menu (new window).
8/19/201023 KB
Order re CH Country Club 081210.pdf
Order re CH Country Club 081210Use SHIFT+ENTER to open the menu (new window).
8/12/201049 KB
Order Staying Proceedings 080910.pdf
Order Staying Proceedings 080910Use SHIFT+ENTER to open the menu (new window).
8/9/201094 KB
Motion Stay Proceedings 080210.pdf
Motion Stay Proceedings 080210Use SHIFT+ENTER to open the menu (new window).
8/2/201078 KB
Mueller Ninety Day Report.pdf
Mueller Ninety Day ReportUse SHIFT+ENTER to open the menu (new window).
7/29/2010253 KB
Order re Office Lease 070710.pdf
Order re Office Lease 070710Use SHIFT+ENTER to open the menu (new window).
7/7/201050 KB
Motion re Office Lease 062410.pdf
Motion re Office Lease 062410Use SHIFT+ENTER to open the menu (new window).
6/24/201099 KB
Order to Continue Hearing 050610.pdf
Order to Continue Hearing 050610Use SHIFT+ENTER to open the menu (new window).
5/6/201065 KB
Mueller Order 043010.pdf
Mueller Order 043010Use SHIFT+ENTER to open the menu (new window).
4/30/201034 KB
Mueller Delay Reduction Order.pdf
Mueller Delay Reduction OrderUse SHIFT+ENTER to open the menu (new window).
4/29/201044 KB
Mueller Emergency Verified Ex Parte Motion Order App Receiver.pdf
Mueller Emergency Verified Ex Parte Motion Order App ReceiverUse SHIFT+ENTER to open the menu (new window).
4/27/20101971 KB
Order Appointing Receiver.pdf
Order Appointing ReceiverUse SHIFT+ENTER to open the menu (new window).
4/27/2010696 KB
Civil Court Cover Sheet 042310.pdf
Civil Court Cover Sheet 042310Use SHIFT+ENTER to open the menu (new window).
4/23/201054 KB
Mueller Complaint 042310.pdf
Mueller Complaint 042310Use SHIFT+ENTER to open the menu (new window).
4/23/2010212 KB
Mueller Ex Parte Verified Combined Motion for TRO.pdf
Mueller Ex Parte Verified Combined Motion for TROUse SHIFT+ENTER to open the menu (new window).
4/23/2010672 KB
Mueller Temporary Restraining Order 042310.pdf
Mueller Temporary Restraining Order 042310Use SHIFT+ENTER to open the menu (new window).
4/23/20102624 KB
Mueller TRO GRANTED.pdf
Mueller TRO GRANTEDUse SHIFT+ENTER to open the menu (new window).
4/23/2010220 KB
Grant ([Proposed] Or.pdf
Grant ([Proposed] OrUse SHIFT+ENTER to open the menu (new window).
39 KB

 Key Dates

Use SHIFT+ENTER to open the menu (new window).
DescriptionFilter
Conference Call, 2:00 PM Mountain Time
Participants Dial: 1-877-941-1468
5/5/2010 2:00 PM5/5/2010 3:00 PM

 Receiver's Reports and Other Documents

Receiver's March 2012 Report.pdf
Receiver's March 2012 ReportUse SHIFT+ENTER to open the menu (new window).
3/21/2012314 KB
Receiver's Report 051211.pdf
Receiver's Report 051211Use SHIFT+ENTER to open the menu (new window).
5/12/2011425 KB
Notice Re Tolling Agreements.docx
Notice Re Tolling AgreementsUse SHIFT+ENTER to open the menu (new window).
3/9/201158 KB
Denver Post Article 111610.pdf
Denver Post Article 111610Use SHIFT+ENTER to open the menu (new window).
11/16/2010139 KB
Denver Post Article 110210.pdf
Denver Post Article 110210Use SHIFT+ENTER to open the menu (new window).
11/2/2010471 KB
Denver Post Article 101510.pdf
Denver Post Article 101510Use SHIFT+ENTER to open the menu (new window).
10/15/2010233 KB
Denver Post Article 10-12-2010.pdf
Denver Post Article 10-12-2010Use SHIFT+ENTER to open the menu (new window).
10/12/2010235 KB
News Release 10-12-2010.pdf
News Release 10-12-2010Use SHIFT+ENTER to open the menu (new window).
10/12/201036 KB
Mueller Claim Form.pdf
Mueller Claim FormUse SHIFT+ENTER to open the menu (new window).
9/30/201082 KB
Mueller Notice of Claims Bar Date.pdf
Mueller Notice of Claims Bar DateUse SHIFT+ENTER to open the menu (new window).
9/30/201045 KB
Mueller Letter re Tax Issues.pdf
Mueller Letter re Tax IssuesUse SHIFT+ENTER to open the menu (new window).
8/18/20101800 KB
Ninety Day Report.pdf
Ninety Day ReportUse SHIFT+ENTER to open the menu (new window).
7/29/2010253 KB
May 5, 2010 Invester Conference Call (MP3 Audio).mp3
May 5, 2010 Invester Conference Call (MP3 Audio)Use SHIFT+ENTER to open the menu (new window).
5/5/201018943 KB
 
 

 FINRA Statement of Claim

On March 2, 2012, the Receiver filed an arbitration proceeding with the Financial Industry Regulatory Authority against M.S. Howells, Inc. and two of its employees.  M.S. Howells was one of the Sham Business’ introducing brokers.  In the FINRA arbitration against M.S. Howells, the Receiver is seeking approximately $13 million in compensatory damages and the same amount in punitive damages.  An Amended Statement of Claim was filed on May 14, 2012.  A copy of the Receiver’s Amended Statement of Claim in the arbitration has been posted on this website under Pleadings. The Receiver continues to investigate the possibility of additional litigation which could bring additional assets into the Estate.

On April 16, 2012, the Receiver filed an arbitration proceeding with the Financial Industry Regulatory Authority against Jefferies & Company, Inc.  A copy of the Receiver's Statement of Claim in the arbitration has been posted on this website under Pleadings.

 Complaints Filed by Receiver

On April 22, 2011, the Receiver filed 15 lawsuits seeking to recover assets of the estate.  Copies of the complaints in those lawsuits are posted here on the website.  As indicated previously on the website, starting in February 2011, Tolling Agreements were sent to and obtained from approximately 35 other investors which extend the statute of limitations to allow further investigation and/or settlement of potential claims against them. 

 2010 Tax Return Information (updated 8/30/11)

On April, 27, 2010, C. Randel Lewis was appointed Receiver for Mueller Capital Management, LLC, Mueller Over Under Fund, LP, as well as any related businesses, including Mueller Partners, LP, MCM, LLC and Mueller Fund, LP, (collectively, "the Estate").  On November 1, 2010, Sean Michael Mueller, who managed the Estate prior to the appointment of the Receiver, pled guilty in Denver District Court to violating the Colorado Organized Crime Control Act, C.R.S. § 18-17-104(3), a class two felony, and Securities Fraud and Theft, both class three felonies.  As part of the Arrest Warrant issued for Sean Michael Mueller, the Colorado Division of Securities stated, "...MUELLER engaged in a classic "Ponzi" strategy of using new investments by new investors to pay off old investors."

We anticipate that by September 15, 2011, K-1s will be issued for all investors in Mueller Partners, LP and Mueller Over Under Fund, LP, for the tax year 2010.  This will be the final K-1 issued to investors by these Mueller entities and will have an ending capital account balance of -0-.  The amount reported to investors on Line 11 of the K-1 will be based on each investor’s capital account balance as stated on the 2009 tax return with adjustments for capital contributions and distributions made in 2010 prior to the appointment of the Receiver.   At this time, no reasonable estimate can be made as to future recoveries; however, future recoveries, if any, will be made through Mueller Capital Management, LLC.

Investments in Mueller Fund, LP will be reported through Mueller Capital Management, LLC.

IRS Revenue Ruling 2009-9 and IRS Revenue Procedure 2009-20 may provide guidance as to the treatment of the amount reported on Line 11 as well as any future recoveries.  However, you should consult your tax advisor as to the proper tax treatment of both the 2010 K-1 and any future distributions based on your individual tax situation.

 Claim Process

The Order Granting Motion to Establish Claims Administration Procedure and to Set Claims Bar Date was entered September 30, 2010.  You may submit a claim until and including November 30, 2010 to the address shown on the Claim Form.  The Claim Form and Notice of Claims Bar Date and Procedure for Filing Claims can be found in the Other Documents section of this page.

 Tolling Agreements

On February 22, 2011, proposed Tolling Agreements were sent to approximately 50 investors in Mueller Capital Management, the Mueller Fund, and the Mueller Over Under Fund.  The Receiver’s preliminary investigation has revealed that these investors may be “net winners” on a cash-in, cash-out basis.  That is, they may have received more money from the Mueller entities than they invested.   The reason the Receiver wants to enter into these Tolling Agreements is to avoid the need to commence litigation against these net winners prior to April 27, 2011.  This will allow the Receiver to complete his investigation and to engage in a dialogue with the net winners about their status before filing litigation against them. 

If you have received a Tolling Agreement, you should discuss it with your legal counsel.  If you wish to discuss the Tolling Agreement or other matters related to the litigation with the Receiver’s counsel, please contact Michael Gilbert at (303) 454-0590 or by e-mail at mgilbert @ lindquist.com.  If Tolling Agreements are not received from preliminarily identified net-winners by April 15, 2011, the Receiver will initiate litigation seeking, among other possible remedies, to recoup amounts received by net-winners above their investment amount.