FRED J. JOSEPH, Securities Commissioner For The State 

Of Colorado. 



Plaintiff 



V. 



SAMEER SETHI, SETHI OIL & GAS. INC., and 

TRAVIS BURT, 



Defendants. COURT USE ONLY 

JOHN W. SUTHERS, Attorney General 



Case No



RUSSELL B. KLEIN, Assistant Attorney General* 

1525 Sherman Street, Floor 

Denver, CO 80203 

Telephone: 303-866-5287 

FAX: 303-866-5395 

E-Mail: Russell.klein@state.co.us 

Registration Number: 31965 



* Counsel of Record 



COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF 



Plaintiff, Fred J. Joseph, Securities Commissioner for the State of Colorado, by and 

through his counsel, the Colorado Attorney General, and for his Complaint against the 

Defendants, alleges as follows: 



JURISDICTION 



1. Plaintiff Fred J. Joseph is the Securities Commissioner for the State of Colorado 

(the “Commissioner”) and is authorized pursuant to § 11-51-703, C.R.S., to administer all 

provisions of the Colorado Securities Act (the “Act”). Pursuant to § 11-51-602, C.R.S., the 

Commissioner is authorized to bring this action against the Defendants and to seek temporary, 

preliminary, and permanent injunctive relief and other equitable relief against the Defendants 

upon sufficient evidence that the Defendants have engaged in or are about to engage in any act or 

practice constituting a violation of any provision of the Act. 



2. Venue is proper pursuant to § 11-51-602(1), C.R.S. in the district court for the 

city and county of Denver, Colorado. 





persistent pattern of fraudulently offering to sell unregistered securities to Colorado investors. 

These attempts to sell unregistered oil and gas securities to Colorado investors continued, 

unabated, even after the Securities Commissioner issued an Order directing Sameer Sethi and 

Sethi Oil & Gas, Inc. to cease and desist from offering to sell and selling securities in violation of 

the Colorado Securities Act. 



4. The offers of securities to investors in the state of Colorado were all conducted in 

violation of the Colorado Securities Act and in violation of an order of the Commissioner. 

Despite the fact that the cease and desist order issued by the Commissioner was for a previous 

offer of unregistered securities, the Defendants continued to attempt to sell unregistered 

securities to Colorado Investors while now failing to disclose the fact that Sameer Sethi and 

Sethi Oil & Gas, Inc. were subject to a cease and desist order from the Colorado Securities 

Commissioner. Moreover, the Defendants failed to disclose the nature of the compensation to 

the defendants and that Travis Burt had previously been convicted of felony arson. The offer of 

the investments constituted violations of the registration provisions of the Colorado Securities 

Act. The omissions by the Defendants constitute violations of the antifraud provisions of the 

Colorado Securities Act. The conduct of the Defendants in offering to sell securities to Colorado 

investors in violation of the registration and antifraud provisions of the Colorado Securities Act 

constituted a violation of an order issued by the Securities Commissioner. 



DEFENDANTS 



5. Defendant Sameer Sethi (“S. Sethi”) is an adult male individual whose last known 

address is 2600 K Avenue, Suite 101, Plano, Texas 75074. 



6. Sethi Oil & Gas, Inc. (“Sethi O&G”) is a Texas corporation with its principal 

place of business at 2600 K Avenue, Suite 101, Piano, Texas 75074. 5. Sethi is the President of 

Sethi O&G. 



7. Travis Burt (“Burt”) is an adult make individual whose last known address is 

1401 E. l4 Street, Apt. 19203, PIano, Texas 75054. Burt is a vice president with Sethi O&G. 



RELATED NON-PARTY JOINT VENTURES 



8. To facilitate the sale of securities, Sethi O&G and S. Sethi have formed dozens of 

joint venture” investments (collectively, lhe various joint ventures are referred to as the “Joint 

Ventures” and individually, a “Joint Venture”). Each Joint Venture interest represents a 

purported investment in an existing or proposed oil or gas well located somewhere in the United 



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the Golden & Champion Reef Joint Venture and Ragle White 1-3 Joint Venture. 



10. While each Joint Venture ostensibly constitutes a separate offering of securities, 

each Joint Venture essentially constitutes the same offering premise that Sethi O&G or a



— 



subsidiary will, upon receipt of investor funds and arrange for the drilling of the prospective 

well. For example, in the Ragle White 1-3 Joint Venture, promoted by Sethi O&G is advertised 

in offering materials as offering 30 available units of investment at the price of $25,018.45 per 

unit. According to the offering documents, the Joint Venture will drill three oil and gas wells in 

Parker and Palo Pinot Counties in Texas, with one boring a “well re-entry” and the other two 

borings being described as developmental wells. For Ragle White 1-3 Joint Venture, Sethi O&G 

is designated as the Joint Venture Manager. 



PRIOR DISCIPLINARY/LEGAL HISTORY 



11. Sethi 0&G and S. Sethi have previously been disciplined for their offers and sales 

of securities throughout the United States. On or about June 1, 2006, the Pennsylvania Securities 

Commission entered a Summary Order to Cease and Desist (the “Pennsylvania C&D”) against 

Sethi O&G, as well as Praveen Sethi, Jeff Cavendar and the Golden & Champion Reef Joint 

Venture (the “Golden JV”). The Pennsylvania C&D was for the offer of unregistered securities 

in violation of the Pennsylvania Securities Act. Based upon the Pennsylvania C&D action, those 

respondents, including Sethi O&G, were directed to stop offering or selling securities in 

violation of the Pennsylvania Act (the “Pennsylvania Order”). 



12. Sethi O&G and S. Sethi have also had an order entered against them by the 

plaintiff in this case, the Colorado Securities Act in case number XY 201 0-CD-04 before the 

Colorado Securities Commissioner (the “Colorado C&D”). The Colorado C&D was directed 

against Sethi O&G and S. Sethi based upon their offer of unregistered securities to a Colorado 

investor in violation of the Colorado Act. Following the execution of a Stipulation for Consent 

Cease and Desist Order Concerning Sethi Oil & Gas, Inc. and Sameer Sethi, a Consent Cease 

and Desist Order (the “Colorado Order”) was entered by the Securities Commissioner, directing 

Sethi O&G and S. Sethi and their agents to permanently cease and desist from offering to sell or 

selling securities in violation of the Act, including the registration, licensing and antifraud 

provisions of the Act. 



13. On or about August 21, 2002, Defendant Travis Burt was convicted of four counts 

of arson, a felony under Texas state law. Based upon his conviction for arson, Burt was 

sentenced to ten (10) years in prison and fined $12,200.00. Based upon the felony convictions, 



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14. This case involves the fraudulent offer of securities in the form of oil and gas 

Joint Ventures through the use of cold-call sales techniques to investors throughout the United 

States, including Colorado. These offers were made in violation of the registration and the 

antifraud provisions of the Act. In addition, these ongoing offers were made in violation of an 

Order issued by the Commissioner, directing that S. Sethi and Sethi O&G cease and desist from 

offering to sell or selling securities in violation of the Act. 



15. The investments offered by Sethi O&G, S. Sethi and Burt are investments in units 

for oil and gas Joint Ventures. Although styled as ‘joint venture” investments, the investment 

being offered is completely passive, requiring no participation from investors, other than the 

actual investment of money. 



16. From at least June, 2009, Sethi O&G and S. Sethi have engaged in cold-call 

solicitations of Colorado investors, offering to sell investment units in the Ragle White 1-3 Joint 

Venture (“Ragle JV”). On June 30, 2009, Colorado resident D.S. received a cold-call from S. 

Sethi, soliciting D.S. to invest in the Ragle JV. Ongoing communications continued with 

between investor D.S. over the summer of 2009, where Sethi O&G forwarded a Confidential 

Private Placement Memorandum for the Ragle JV. The materials were forwarded to investor 



D.S. at his personal residence in the state of Colorado. 



17. Following this solicitation, the Staff of the Division of Securities (“Division 

Staff’) filed a Verified Petition for Order to Show Cause in the Colorado C&D, and on 

November 9, the Division Staff entered into the stipulation with Sethi O&G and S. Sethi. Per the 

stipulation, the Commissioner signed the Colorado Order on November 16. 



18. Almost immediately after entering into the stipulation, Sethi O&G, S. Sethi, and 

Burt, acting as an agent for Sethi O&G and S. Sethi, engaged in additional attempts to solicit 

investments from investor D.S., in disregard of the stipulation and Colorado Order. On 

November 16, 2009, Burt contacted D.S. to once again attempt to solicit a sale in the Ragle JV. 

Additional attempts to contact D.S. occurred on November 20, 2009 and December 2, 2009. 

Contact was finally made between Burt and D.S.’s representative on December 3, 2009, at which 

time Burt offered the sale of 1 Ľ units in the Ragle JV at $25,018.45 per unit. During the 

ongoing communications, Burt confirmed that the-offer and paperwork that had been originally 

provided to D.S. were still the same, with no updates. 



4. 







a. 

S. Sethi and Sethi O&G were subject to a Cease and Desist Order issued 

by the Colorado Securities Commissioner in connection with a claim that 



S. Sethi and Sethi O&G previously offered to sell unregistered securities 

in the State of Colorado. 



b. 

That Defendant Travis Burt was previously convicted of felony arson in 

2002, and was sentenced to ten (10) years in prison in the state of Texas 

and fined $12,200.00. 



c. 

That Defendant Travis Burt’s felony conviction served as a statutory 

disqualification that prevented him from being licensed as a securities 

broker or sales representative. 



d. 

The nature and amount of compensation, including any commissions, to 

each defendant. 



20. The investments are securities as contemplated by § 11-51-201(17), C.R.S. in that 

they are at least investment contracts and certificates of interest or participation in an oil, gas, or 

mining title or lease or in payments out of production under such title or lease. 



FIRST CLAIM FOR RELIEF 

(Offer or sale of Unregistered Securities) 





21. 

Paragraphs 1 through 20 are incorporated herein by reference. 



22. By engaging in the conduct described above, the Defendants have made “offers” 

or “sales” of securities in the State of Colorado pursuant to § 11-51-201(13), C.R.S. 



23. The investments in the Joint Ventures, including the Ragle JV, were securities and 

were not registered nor exempt from registration as required by § 11-51-301, C.R.S. 



24. By engaging in the conduct described herein, the Defendants offered and sold 

securities in and from Colorado in violation of 11-51-301, C.R.S. 



25. The Commissioner is entitled to an award of damages, interest, costs. attorneys 

fees, restitution, disgorgement and other equitable relief on behalf of persons injured by the 

conduct of the Defendants pursuant to § § 11-51-602(2) and 604(1), C.R. S. (based on violations 

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SECOND CLAIM FOR RELIEF 

(Securities Fraud) 



26. Paragraphs 1 through 25 are incorporated herein by reference. 



27. The conduct described above in this Complaint constitutes violations of the 

Colorado Securities Act in that in connection with the offer, sale, or purchase of securities in 

Colorado, the Defendants, directly or indirectly: 



a. employed a device, scheme or artifice to defraud; 



b. made written and oral untrue statements of material fact or omitted to state 

material facts necessary to make the statements made, in light of the circumstances under 

which they were made, not misleading; or 



c. engaged in acts, practices or courses of business which operated and 

would operate as a fraud and deceit on investors; 

all in violation of 11-51-501(1). C.R.S. 



28. The Commissioner is entitled to an award of damages, interest, costs, attorneys 

fees, restitution, disgorgement and other equitable relief on behalf of persons injured by the 

conduct of the Defendants pursuant to § 11-51-602(2), C.R.S. The Commissioner is also 

entitled to a temporary, preliminary and permanent injunction pursuant to § 11-51-602, C.R.S. 

(based on violations of 11-51-501, C.R.S.) against the Defendants, their agents, servants, 

employees, successors and attorneys-in-fact, as may be; any person who, directly or indirectly, 

through one or more intermediaries, controlled, or is controlled by or is under the common 

control with the Defendants; and all those in active concert or participation with the Defendants. 



THIRD CLAIM FOR RELIEF 

(Violation of Cease and Desist Order) 



29. Paragraphs 1 through 28 are incorporated herein by reference. 



30. The conduct described in this Complaint constitutes a violation of the Colorado 

Securities Act in that the Securities Commissioner has issued a consent order, as he is authorized 

to do pursuant to § 1l-51-606(2)(a). C.R.S. Pursuant to the consent order, Sethi O&G and S. 

Sethi, as well as their agents and others acting on their behalf were ordered to cease and desist 

from engaging conduct in violation of the Colorado Securities Act. 



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