UNITED STATES DISTRICT COURT EASTERN DISTRICT OF L

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
TREATY ENERGY CORPORATION, *
* CIVIL ACTION
Plaintiff, * NO.
*
VERSUS * SECTION “ ”
*
JEFFREY D. BOLER, * MAG. DIV.
*
Defendant. * !
*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"!
!
COMPLAINT
NOW INTO COURT, through undersigned counsel, comes Plaintiff, Treaty Energy
Corporation, who respectfully represents the following to this Honorable Court:
PARTIES
1.
Plaintiff, Treaty Energy Corporation, is a Nevada Corporation with its principal place of
business in the Parish of Orleans, State of Louisiana.
2.
Upon information and belief, defendant Jeffrey D. Boler (“Boler”) is a person of the full
age of majority and a resident of the State of Mississippi.
Case 2:12-cv-02428 Document 1 Filed 10/03/12 Page 1 of 10
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JURISDICTION AND VENUE
3.
This Honorable Court has jurisdiction over this civil action pursuant to 28 U.S.C. § 1332,
in that this is a civil action, upon information and belief, between citizens of different states
wherein the amount in controversy exceeds the sum or value of $75,000, exclusive of interest
and costs.
4.
Venue is proper in this judicial district under 28 U.S.C. § 1391(b), in that a substantial
part of the events or omissions giving rise to this claim occurred in this district.
FACTUAL BACKGROUND
5.
Treaty Energy Corporation (“TECO”) is a publicly traded corporation whose common
shares trade at less than one dollar as a “penny stock.”
6.
Because the market for TECO’s penny stock is thin, the price per share can be subject to
wide fluctuation as a result of single investor activity. As a result, disparaging and defamatory
comments that reach TECO investors or potential investors can substantially impact the price per
share of TECO stock.
7.
InvestorsHub.com (“iHub”) is a financial investment forum website through which
investors, potential investors and others can discuss stock market activity and investment
opportunities. According to the iHub website, iHub “is built to provide a forum for serious

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investors to gather and share market insights in a dynamic environment using an advanced
discussion platform. The site is designed to be clean and simple, allowing you to get the realtime
market information you need, quickly and easily.”
8.
Boler, who claims to be a drilling consultant and full-time investor, is a member of and
actively posts public messages to the TECO forum on iHub under the screen name
“geopressure”, posting over 1,300 messages since November 2010, including over 200 messages
regarding TECO since starting in July 2011.
9.
In those iHub posts, which are available to and viewed by the public, including investors
and potential investors of TECO stock, Boler has made numerous comments of purported fact
concerning TECO and its officers that are false, defamatory, and libelous on their face.
10.
For instance, in one post dated August 2, 2011, Boler made a statement about an article
written by a TECO officer, claiming that TECO was just a “scheme” and a “well-engineered
pump & dump,” which refers to a fraudulent scheme by the company’s officers to increase the
stock value and then sell their personal stock before the price crashes. (Post #18126).
11.
On February 7, 2012, Boler again charged – as an “Oil & Gas Professional” – that TECO
was just a fraudulent securities scheme by its officers: “I think that it is important that [TECO
shareholders] realize what TECO is - and that is an elaborate Pump & Dump that was planned &
is currently being executed by TECO's management.” (Post #26730).


12.
Yet again, on April 11, 2012, Boler erroneously accused TECO of issuing fraudulent
press releases: “TECO is in the business of producing good news to pump their market-cap…”
(Post #30435).
13.
A month later, on May 13, 2012, Boler began targeting TECO’s officers, alleging that
one officer’s “resume’ is BS just like every other document that TECO generates.” (Post
#32078)
14.
In a post dated May 14, 2012, Boler took his attacks a step further by declaring that
TECO’s CEO has a “drug dealer” and has paid another iHub poster to “promote [his] stocks &
lie about them when necessary…,” which is categorically false. (Post #32139).
15.
Then, in a lengthy post dated May 27, 2012, Boler proclaimed that TECO’s CEO “chose
to intentionally mislead shareholders” in company press releases and that TECO’s
“management” attempted to “cover up” a “fraudulent discovery” in violation of federal securities
regulations, all of which is also false. (Post #32739).
16.
In that same post, Boler falsely charged that TECO’s CEO sabotaged the company’s
logging operations in order to “avoid[] a Federal Prison sentence for Securities Fraud”, which is

likewise false, and that there’s a “high probability” that he “ends up spending a few years in
Federal Prison after this is all said & done…”
17.
In a post dated July 2, 2012, Boler frankly admitted that he “did not come to this board
today to bash the stock,” confirming that he purposefully posted on the TECO forum to “bash”
its stock on all other days. (Post #35250).
18.
Two weeks later, on July 17, 2012, Boler did “bash” TECO again when he reposted his
entire post from May 27, 2012 discussed above, in which he baselessly claimed TECO’s officers
were committing fraud and would end up in federal prison. (Post #37456)
19.
The following day, on July 18, 2012, Boler wrote another defamatory post, falsely stating
that TECO’s managers were “marking up the price” of “marginal oil & gas leases” through an
affiliated company and then selling those lease to TECO, which he claimed would allow the
affiliated company’s investors to “walk away with significant gains.” (Post #37553)
20.
In the last month, Boler, who claims he does not own TECO stock yet has a profound
interest in defaming and disparaging the company, significantly increased the frequency of his
posts on the TECO message board, posting over 80 times since September 1, 2012, many of
which continue to be false, defamatory and libelous on their face.

21.
For example, in a post dated September 5, 2012, Boler again made the libelous claim that
TECO’s managers decided not to purchase a lucrative oil and gas lease in the company’s name,
but instead started a separate company to purchase the lease so they could “let the money flow
straight into [the managers’] pockets.” (Post #41397).
22.
In a post the next day, September 6, 2012, Boler called one of TECO’s managers a “conman”.
(Post #41465).
23.
A few days later, on September 10, 2012, Boler again charged that TECO was
committing the illegal act of “insider trading” because he speciously claimed it was telling
investors when they could expect a new press release. (Post #41693).
24.
Later that same day, September 10, 2012, Boler falsely stated that “TECO Management
has lied about their Belize Operations once before” and suggested that “they would do it again.”
(Post #41739).
25.
In a post dated September 14, 2012, Boler stated that “TECO’s [press release] wording is
always very deceptive.” (Post #42159)
26.
That same day, September 14, 2012, Boler again maliciously claimed that TECO was
committing securities fraud when he posted the following: “Same story with every other

venture [TECO] has attempted … spinning the numbers to keep the share price inflated while
diluting …” (Post #42165).
27.
On September 16, 2012, Boler continued on that same theme, announcing that TECO
“will put anything into a press release if they thing it will boost share price ..” and that “[e]very
past [press release] has some sort of inconstancy [sic], everything TECO says or releases is
misleading.” (Post #42306).
28.
In a post on September 19, 2012, Boler again falsely claimed that TECO was again
committing illegal acts by lying in its press releases about its oil wells in Belize:
One of the 2 parties (TECO Management or the [Government of Belize]) is not
telling the truth …
-Which of these parties has a history of run-ins with the SEC & other regulatory
agencies?
-Which of these parties claimed in a [press release] that they were producing 50
[Barrels of Oil Per Day] in West Texas, but the Texas [Railroad Commission]
never showed anything remotely close?
-Which of these Parties negotiated/brokered a $7,000,000 deal between their own
private company & TECO, selling TECO leases at $12,000.00/acre?
-Which of these parties just ‘officially’ shut their only East Texas Producer in so
[that] 3rd Quarter financials wouldn’t be a valid means for shareholders to verify
potential?
(Post #42690).
29.
On September 27, 2012, Boler stated that TECO was a “scam”. (Post #43113).

30.
The following day, September 28, 2012, Boler declared that TECO issued a press release
“to manipulate TECO’s weekly close/chart …” (Post #43168).
31.
In his latest post, dated October 2, 2012, Boler again referred to “false” press releases by
TECO and asserted that the Securities and Exchange Commission (SEC) should be “all over
these guys” and should have “agents hiding in the bushes behind TECO Management’s Houses”.
He then proclaimed that “these guys are going to prison”. (Post #43420).
CLAIM FOR DEFAMATION
32.
Plaintiff adopts by reference and incorporate the allegations of Paragraphs 1-31 above as
if fully set forth herein.
33.
The above false, defamatory and libelous statements by Boler were designed to injure the
business reputation of TECO.
34.
Boler, at all relevant times, knew that these statements quoted above were false or acted
in reckless disregard as to the truth or falsity of the statements. Boler’s acts in doing so were not
privileged.
35.
The comments quoted above were made intentionally and with actual or implied malice,
or, in the alternative, negligently.

36.
Boler’s comments quoted above are statements of fact, not opinion, that TECO and its
officers have engaged in dishonest, unethical, and illegal conduct and, thus, are defamatory per
se.
37.
Boler’s false, defamatory and libelous statements are, and at all relevant times were, of a
character that have substantially harmed the reputation of TECO and its officers, lowered their
status in the estimation of the community, deterred others from associating or dealing with them,
and otherwise exposed them to contempt or ridicule.
38.
As a proximate cause of Boler’s publication of these false, defamatory, and libelous
statements quoted above, TECO has been damaged, including without limitation the decrease in
value of TECO stock, and the business reputation of TECO and its officers has been injured.
CLAIM FOR CIVIL CONSPIRACY
39.
Plaintiff adopts by reference and incorporate the allegations of Paragraphs 1-30 above as
if fully set forth herein.
40.
Upon information and belief, Boler has conspired with others to commit intentional
willful acts causing harm to Treaty, and as such are subject to liability as co-conspirators
pursuant to Louisiana Civil Code Article 2324.

JURY DEMAND
41.
Plaintiff hereby demands a trial by jury of all issues triable by a jury in the captioned
matter.
PRAYER
WHEREFORE, plaintiff Treaty Energy Corporation respectfully prays that, after all due
proceedings, judgment be entered in its favor and against defendant Jeffrey D. Boler, as follows:
(1) Awarding plaintiff damages sufficient to redress the injuries caused by the
defamatory statements;
(2) Issuing a permanent injunction enjoining defendant from making any future
defamatory statements against TECO, its officers and employees; and
(3) Awarding all other legal and equitable relief to which plaintiff may be entitled.
Respectfully submitted,
__________________________________
Andrew L. Kramer (La. Bar # 23817)
Binford E. Parker III (La. Bar # 31908)
201 St. Charles Avenue, Suite 2504
New Orleans, Louisiana 70170
Telephone: (504) 599-5623
Facsimile: (866) 667-3890
Email: akramer@kramerllc.com
tparker@kramerllc.com
Counsel for Plaintiff Treaty
Energy Corporation
Case 2:12-cv-02428 Document 1 Filed 10/03/12 Page 10 of 10