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Defendants allegedly raised over $14 million in at least 18 fraudulent oil-and-gas joint ventures, on the strength of offering documents containing untrue and misleading statements about the investments. For example, according to the complaint, the documents misrepresented the use of the offering proceeds, misrepresented who held title to the working interests, overstated expected well costs, and failed to disclose preferential treatment given to certain investors. Defendant Hudnall was also administratively barred.