SEC v. Cast Your Nets Ministries; CYNM Consulting, LLC; Phillip Trujillo; and Jeremy (“Je”) Hammonds, No. 1:24-mc-00122, District of Colorado (Dec. 16, 2024) — Complaint

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLORADO 
Civil Miscellaneous Action No. 24-mc-________ 
SECURITIES AND EXCHANGE COMMISSION, 
            Petitioner,            
v. 
CAST YOUR NETS MINISTRIES;  
CYNM CONSULTING, LLC;  
PHILLIP TRUJILLO; and 
JEREMY (“JE”) HAMMONDS, 
            Respondents.            
APPLICATION FOR ORDER TO SHOW CAUSE AND FOR ORDER COMPELLING 
COMPLIANCE WITH ADMINISTRATIVE SUBPOENAS 
The Securities and Exchange Commission (“Commission” or “SEC”) is investigating 
whether Cast Your Nets Ministries; CYNM Consulting, LLC; Phillip Trujillo; and Jeremy (“Je”) 
Hammonds
1
 are conducting a fraudulent and unregistered securities offering. In furtherance of its 
investigation, the SEC served administrative subpoenas seeking documents from Cast Your Nets 
Ministries; CYNM Consulting, LLC; and Mr. Trujillo and served administrative subpoenas 
seeking testimony from Mr. Trujillo and Dr. Hammonds (collectively, the “Respondents”). Other 
than producing ten documents, Cast Your Nets Ministries; CYNM Consulting, LLC; and Mr. 
1
 We understand Dr. Hammonds’ legal name to be Jeremy Hammonds but that he goes by Je 
Hammonds. Counsel has referred to him as Dr. Hammonds, and he is described on CYNM’s 
website as having a Ph.D. Accordingly, we refer to him as Dr. Hammonds as well. 
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Trujillo have refused to comply with the Commission’s document subpoenas. Further, neither 
Mr. Trujillo nor Dr. Hammonds appeared for their scheduled testimony.  
Counsel for Respondents has informed the SEC staff that Respondents will not comply 
with the subpoenas, will not produce any additional documents, and will not appear for 
testimony. Counsel for the Respondents has acknowledged that Respondents “are fully aware 
that the SEC has reserved its authority to pursue enforcement of the subpoenas in federal court.” 
Declaration of Abigail L.P. Edwards (“Edwards Decl.”) ¶ 24 & Ex. 12. As a result, the SEC has 
no other remedy than the judicial enforcement of the subpoenas. In this case, the SEC needs this 
Court’s assistance to carry out its statutorily authorized mission to protect investors. 
The Commission respectfully requests that the Court: (1) issue an Order to Show Cause 
why Cast Your Nets Ministries; CYNM Consulting, LLC; Mr. Trujillo; and Dr. Hammonds 
should not be compelled to comply with the SEC’s administrative subpoenas; and (2) following 
notice and an opportunity to be heard, order Cast Your Nets Ministries; CYNM Consulting, 
LLC; Mr. Trujillo; and Dr. Hammonds to comply with the Commission’s subpoenas. 
STATEMENT OF FACTS 
I. Respondents 
Cast Your Nets Ministries is a Washington state non-profit corporation with its 
principal office located in Windsor, Colorado. Edwards Decl. ¶ 18. Cast Your Nets Ministries’ 
website lists Mr. Trujillo and Dr. Hammonds as members of its Leadership. Edwards Decl. ¶ 4, 
n.1. That website offered three investment programs and a crypto asset, all of which are 
described further below. Edwards Decl. ¶ 4. Cast Your Nets Ministries is also the parent 
company of CYNM Consulting, LLC. Edwards Decl. ¶ 12 & Ex. 3.  
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CYNM Consulting, LLC is a limited liability corporation registered in the state of 
Delaware with its principal office located in Windsor, Colorado. Edwards Decl. ¶ 10. We 
collectively refer to Cast Your Nets Ministries and CYNM Consulting, LLC as “CYNM.”  
Mr. Trujillo is a board member of Cast Your Nets Ministries. Edwards Decl. ¶ 26. Mr. 
Trujillo was previously charged by the SEC with conducting a fraudulent offering (see SEC v. 
Trujillo, Civ. No. 09-cv-00403-MSK-KMT (D. Colo.) (February 26, 2009)) and subsequently 
convicted by criminal authorities and sentenced to 12 years in prison for the same underlying 
conduct (see Colorado v. Trujillo, D035 2010-CR-000749 (State of Colorado, Larimer County, 
March 7, 2012)). Edwards Decl. ¶ 26.  
Dr. Hammonds is the Chief Operating Officer (“COO”) of Cast Your Nets Ministries. 
Edwards Decl. ¶ 36.  
II. The SEC Formal Order and Investigation 
The SEC is investigating whether the Respondents are conducting a fraudulent and 
unregistered securities offering. Edwards Decl. ¶ 4. CYNM offered three investment programs 
and a crypto asset on its website:  
1) the “CYN Legacy Program,” which was described as “a program partnering with 
Christian churches and organizations to facilitate fund raising projects”;  
2) the “CYN Alternative Savings Plan,” which was described as “a short term, high-
yield program that pays 2% per month up to 6 months for a total of 12%”;  
3) the “Alternative Retirement Program,” which CYNM advertised at various times as 
providing “15% Yearly Returns” or “a 25% return each year for three years”; and  
4) a crypto asset known as the “CYN Token,” which promises to “[d]ouble Your 
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Retirement Savings In Just 5 Years.”
2
  
Edwards Decl. ¶ 4.  
On April 11, 2024, the Commission issued an Order Directing Private Investigation and 
Designating Officers to Take Testimony in an investigation entitled In the Matter of CYNM 
Consulting, LLC. Edwards Decl. ¶ 5 (the “Formal Order”).
3
 A formal order generally describes 
the nature of an investigation and designates specific staff members to act as officers of the 
Commission for purposes of the investigation. The Formal Order empowers the designated staff 
members to administer oaths and affirmations, subpoena witnesses, compel their attendance, take 
evidence, and require the production of documents and other materials. Edwards Decl. ¶ 5. The 
Director of Enforcement approved the Formal Order. Id. The Formal Order was subsequently 
corrected on July 10, 2024, to change the name of the investigation to In the Matter of Cast Your 
Nets Ministries. Edwards Decl. ¶¶ 6–7. 
III. The Administrative Subpoenas 
Following issuance of the Formal Order, a member of the SEC staff designated in the 
Formal Order issued subpoenas to Respondents. Edwards Decl. ¶¶ 10, 18, 27, 37 & Exs. 2, 6, 13, 
19. On May 20 and August 6, 2024, the SEC staff properly served subpoenas seeking documents 
 
2
 Per the CYN Token website, described further in the Edwards Decl. ¶ 26 n.4, the CYN Token 
is a “Faith-Driven Utility” Token, that promises “[a]ccess to alternative savings, retirement, and 
building programs,” “[a]ccess to low interest bridge, car, and home equity loans,” “access to 
CYN exclusive staking and vesting programs,” and other benefits. Edwards Decl. ¶ 4, n.2.   
3
 The SEC staff will provide a copy of the Formal Order or the corrected Formal Order to the 
Court upon request, but respectfully requests that any such review be conducted in camera. 
 
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from CYNM Consulting, LLC and Cast Your Nets Ministries
4
 related to, among other things, the 
structure and business of the entities, the products CYNM offers, and the crypto asset advertised 
on CYNM’s website. Edwards Decl. ¶¶ 10, 18 & Exs. 2, 6. CYNM has only produced ten 
documents in response to these subpoenas. Edwards Decl. ¶¶ 16, 20. 
On September 30, 2024, the SEC staff designated in the Formal Order served a subpoena 
seeking documents and testimony from Mr. Trujillo concerning, among other things, the 
structure and nature of CYNM’s products. Edwards Decl. ¶ 27 & Ex. 13. The subpoena required 
Mr. Trujillo to appear for testimony at the Commission’s Denver Regional Office on October 21, 
2024. Id. Mr. Trujillo has not produced any documents in response to this subpoena and did not 
appear for testimony. Edwards Decl. ¶¶ 31, 34. 
On September 30, 2024, the SEC staff designated in the Formal Order also served a 
subpoena for testimony on Dr. Hammonds. Edwards Decl. ¶ 37 & Ex. 19. The subpoena required 
Dr. Hammonds to appear for testimony at the Commission’s Denver Regional Office on October 
22, 2024. Id. Dr. Hammonds did not appear for testimony as required by the subpoena. Id. ¶ 41. 
On November 1, 2024, counsel for Respondents sent the SEC staff three letters stating 
that CYNM Consulting, LLC; Cast Your Nets Ministries; and Mr. Trujillo would not be 
producing any more documents and that neither Mr. Trujillo nor Dr. Hammonds would be 
appearing for testimony. Edwards Decl. ¶¶ 24, 33, 43 & Exs. 12, 18, 21.  
CYNM has principally argued that the SEC does not have jurisdiction because the 
 
4
 The May 20, 2024 subpoena was served via UPS on CYNM Consulting, LLC’s registered 
agent as well as its principal office located in Windsor, Colorado. Edwards Decl. ¶ 10 & Ex. 2. 
After service of this subpoena, counsel appeared and accepted service of the August 6, 2024 
subpoena. Edwards Decl. ¶ 18 & Ex. 6.    
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products CYNM offers and sells are loans, not securities, and are therefore outside of the 
jurisdiction of the SEC. See Edwards Decl. ¶¶ 12, 16, 19, 20, 22, 24, 28, 33, 38, 43 & Exs. 3, 5, 
7, 8, 9, 10, 12, 14, 18, 20, 21. CYNM has also stated that any documents or information about 
the CYN Token must come from a UK entity issuing the token, CASTYOURNETS, LTD. and 
that counsel could not accept service of a subpoena on behalf of that foreign entity. Edwards 
Decl. ¶¶ 13, 14 & Ex. 4. The SEC staff has explained (1) that Respondents must comply with the 
lawfully issued subpoenas, (2) that the staff has authority to investigate whether or not CYNM is 
offering and selling, or has offered and sold, unregistered securities and whether or not it is 
making false and misleading statements in the offer and sale of securities, or has made such 
statements, and (3) the ten documents produced by CYNM to date is insufficient to assess 
whether CYNM offered and sold securities and made false or misleading statements in 
connection therewith. Edwards Decl. ¶¶ 13, 17. 
Despite the SEC staff’s repeated attempts to secure compliance with the subpoenas, 
Respondents’ counsel informed the SEC staff that his clients would not comply with the 
subpoenas. Edwards Decl. ¶ 22 & Ex. 10. Specifically, on November 1, 2024, counsel stated that 
“CYNM will not be providing any further information to the SEC voluntarily in response to the 
subpoena issued to CYNM. We are fully aware that the SEC has reserved its authority to pursue 
enforcement of the subpoenas in federal court.” Edwards Decl. ¶ 24 & Ex. 12. Counsel reiterated 
this refusal to comply with the SEC subpoenas on behalf of Mr. Trujillo and Dr. Hammonds as 
well. Edwards Decl. ¶¶ 33, 43 & Exs. 18, 21.  
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ARGUMENT 
I.  The Court Has Jurisdiction and a Summary Proceeding is Appropriate. 
The Securities Exchange Act of 1934 (the “Exchange Act”) provides that the SEC “may, 
in its discretion, make such investigations as it deems necessary to determine whether any person 
has violated, is violating, or is about to violate [the Exchange Act].” 15 U.S.C. § 78u(a). As part 
of such investigations, SEC staff who are designated as officers of the SEC for purposes of the 
investigation may, among other things, subpoena documents and testimony. 15 U.S.C. § 78u(b). 
See also SEC v. O’Brien, 467 U.S. 735, 741 (1984) (“Congress has vested the SEC with broad 
authority to conduct investigations into possible violations of the federal securities laws and to 
demand production of evidence relevant to such investigations.”) 
The Court has jurisdiction over this subpoena enforcement action pursuant to 
Section 21(c) of the Exchange Act. See 15 U.S.C. § 78u(c); 15 U.S.C. § 78u(e); Fed. R. Civ. P. 
81(a)(5). The SEC’s investigation is being conducted by the Denver Regional Office, Edwards 
Decl. ¶ 8, and thus jurisdiction and venue are appropriate in this district. See 15 U.S.C. § 78u(c) 
(“[T]he Commission may invoke the aid of any court of the United States within the jurisdiction 
of which such investigation . . . is carried on.”). 
The SEC respectfully requests that its application be considered promptly in a summary 
proceeding. “Federal securities law authorizes the SEC to seek an order from this Court requiring 
compliance with a subpoena in a summary proceeding.” SEC v. Harman Wright Grp., LLC, 
No. 18-mc-00190-CMA, 2018 WL 6102758, at *2 (D. Colo. Nov. 21, 2018) (aff’d, 777 F. App’x 
276 (10th Cir. 2019); see also SEC v. Conway, No. 22-mc-00212-DDD-KAS, 2024 WL 
4252821, at *3 (D. Colo. Sept. 19, 2024) (Report and Recommendation adopted by the District 
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Court Oct. 11, 2024) (same). “Further, a prompt ruling on the SEC’s application is warranted to 
avoid further delay in the investigation.” Harman Wright Grp., LLC, 2018 WL 6102758, at *2 
(citing SEC v. First Sec. Bank, 447 F.2d 166, 168 (10th Cir. 1971); SEC v. Lavin, 111 F.3d 921, 
926 (D.C. Cir. 1997)). 
II.  The Court Should Enforce the Administrative Subpoenas. 
Under well-established Supreme Court and Tenth Circuit precedent, this Court should 
enforce the SEC’s administrative subpoenas because: (1) the investigation is being conducted 
pursuant to a legitimate purpose; (2) the subpoenas seek information that may be relevant to that 
purpose; (3) the information sought is not already in the SEC’s possession; and (4) all required 
administrative steps have been followed. Harman Wright Grp., 2018 WL 6102758, at *2 (citing 
United States v. Powell, 379 U.S. 48, 57–58 (1964); RNR Enter., Inc. v. SEC, 122 F.3d 93, 96 
(2d Cir. 1997); see also Application to Enforce Administrative Subpoenas Duces Tecum of SEC 
v. Knowles, 87 F.3d 413, 415 (10th Cir. 1996)); Conway, 2024 WL 4252821, at *3 (also quoting 
Powell). The SEC’s burden under this framework is a “‘slight one,’ and ‘[t]he requisite showing 
is generally made by affidavit of the agent who issued the summons and who is seeking 
enforcement.’” Harman Wright Grp., 2018 WL 6102758, at *2 (quoting United States v. 
Balanced Fin. Mgmt., Inc., 769 F.2d 1440, 1443 (10th Cir. 1985) (internal quotations omitted)); 
see also Conway, 2024 WL 4252821, at *3. As discussed below, the SEC meets these factors. 
First, the Commission’s investigation is being conducted pursuant to a legitimate 
purpose. “Congress has vested the SEC with broad authority to conduct investigations into 
possible violations of the federal securities laws and to demand production of evidence relevant 
to such investigations.” O’Brien, 467 U.S. at 741. The Formal Order pursuant to which the 
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subpoenas were issued authorizes such an investigation into possible violations of the federal 
securities laws. Edwards Decl. ¶ 5. As discussed above, the SEC is investigating whether 
Respondents are conducting a fraudulent and unregistered securities offering. Edwards Decl. ¶ 4. 
CYNM publicly advertised on its website, and offered and sold, three investment programs and a 
crypto asset, each of which may be a security. Id. The SEC is investigating whether CYNM 
violated the federal securities laws in connection with the offer or sale of a security. 
Second, the subpoenas seek information that may be relevant to the SEC’s legitimate 
investigation. “Administrative agencies vested with investigatory power have broad discretion to 
require the disclosure of information concerning matters within their jurisdiction.” Philips 
Petroleum Co. v. Lujan, 951 F.2d 257, 260 (10th Cir. 1991). Relevance is established when the 
information sought is not “plainly incompetent or irrelevant to any lawful purpose.” Endicott 
Johnson Corp. v. Perkins, 317 U.S. 501, 509 (1943) (cited in Philips Petroleum, 951 F.2d at 
260). The subpoenas seek documents and testimony concerning the structure and business of 
CYNM, the products that they offered and sold, information about investors or customers who 
purchased those products, the crypto asset advertised on the CYNM website, Mr. Trujillo’s 
involvement with CYNM, relevant agreements between Mr. Trujillo and CYNM, Dr. 
Hammonds’ involvement with CYNM, and relevant agreements between Dr. Hammonds and 
CYNM. Edwards Decl. ¶¶ 10, 18, 27, 37 & Exs. 2, 6, 13, 19. That information is relevant to the 
SEC’s investigation into whether the products CYNM is offering and selling (or has offered and 
sold) are securities and whether CYNM has violated the federal securities laws in connection 
with such offers or sales, including by making fraudulent statements and engaging in an 
unregistered securities offering. While there is evidence suggesting that the products are 
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securities, proving one of the products is a security is not the burden at this stage. As discussed 
below, in the federal securities laws, Congress committed the initiation and conduct of 
investigations to the SEC’s “discretion.” See, e.g., Securities Act of 1933 (“Securities Act”) 
Section 20, 15 U.S.C. § 77t(a) (“the Commission . . . may, in its discretion . . . investigate” 
possible violations of the securities laws); Exchange Act Section 21(a), 15 U.S.C. § 78u(a) (“The 
Commission may, in its discretion, make such investigations as it deems necessary to determine 
whether” the securities laws have been violated). Put another way, the SEC is entitled to issue 
subpoenas to determine whether (among other things) the products at issue are securities; it need 
not (as Respondents assume) prove the products are securities in order to secure compliance with 
the subpoenas. Here, the SEC is investigating whether any of the CYNM-offered programs 
violated the federal securities laws, and the subpoenas issued are relevant to that purpose.  
Third, the subpoenas seek information that is not already in the SEC’s possession. 
CYNM has only produced ten documents. Edwards Decl. ¶¶ 16, 20. The SEC has sought, but has 
not received, documents concerning the structure and business of CYNM, the products that they 
offer, the entities’ investments, and the crypto asset advertised on the CYNM website. Edwards 
Decl. ¶¶ 10, 18 & Exs. 2, 6. Mr. Trujillo has not testified under oath nor produced documents 
concerning, among other topics, his involvement with CYNM, the structure and nature of the 
products CYNM has offered, relevant agreements between him and the CYNM entities, 
advertising of the CYNM products, and information related to the CYN Token. Edwards Decl. 
¶¶ 27, 31, 34 & Ex. 13. Dr. Hammonds has not testified under oath concerning, among other 
things, his involvement with CYNM, the structure and nature of the products CYNM has 
offered, relevant agreements between him and the CYNM entities, advertising of the CYNM 
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products, and information related to the CYN Token. Edwards Decl. ¶¶ 37, 41 & Ex. 19. This 
information is in CYNM’s, Mr. Trujillo’s, and Dr. Hammonds’ (and not the SEC’s) possession.  
Fourth, the SEC staff has followed all required administrative steps. The Exchange Act 
authorizes the SEC to initiate investigations and designate officers to, inter alia, subpoena 
witnesses, take evidence, and require the production of records that the SEC deems relevant to its 
investigation. 15 U.S.C. § 78u(a)(1), (b). The Commission delegated this authority to the 
Director of the Division of Enforcement. 17 C.F.R. § 200.30-4(a)(13), (a)(1). The Director of 
Enforcement approved the Formal Order initiating this investigation and authorizing designated 
staff members to subpoena witnesses, take evidence, and require the production of records 
deemed relevant to the investigation. Edwards Decl. ¶ 5. The subpoenas were signed by an SEC 
staff attorney so designated for purposes of this investigation and were properly served on 
CYNM, Mr. Trujillo, and Dr. Hammonds. Id. ¶¶ 10, 18, 27, 37 & Exs. 2, 6, 13, 19. The SEC has 
thus met all administrative requirements. 
Because the SEC readily satisfies its burden, the Court should enforce the Commission’s 
administrative subpoenas. See, e.g., Resolution Trust Corp. v. Thornton, 41 F.3d 1539, 1544 
(D.C. Cir. 1994) (“If an agency’s subpoena satisfies these requirements, we must enforce it.”) 
(emphasis added) (citation omitted); see also, e.g., SEC v. Blackfoot Bituminous, Inc., 622 F.2d 
512, 515–16 (10th Cir. 1980) (affirming district court orders enforcing SEC subpoenas); First 
Sec. Bank of Utah, 447 F.2d at 167–69 (same); SEC v. Conway, No. 22-mc-00212-DDD-KAS, 
2024 WL 4252821, at *13 (D. Colo. Sept. 19, 2024) (Report and Recommendation adopted by 
the District Court Oct. 11, 2024); SEC v. Kimmel, No. 19-mc-00113-CMA, 2020 WL 2800813, 
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at *5 (D. Colo. May 29, 2020) (compelling respondent to comply with SEC administrative 
subpoenas); Harman Wright Grp., 2018 WL 6102758, at *3 (same). 
III.  Respondents Do Not Have a Valid Reason for Refusing to Comply with the 
Subpoenas. 
 
Having established that the SEC satisfies all the criteria to have its subpoenas judicially 
enforced, Respondents may only resist compliance with the subpoenas if they can show that the 
subpoenas are unreasonable, issued in bad faith or for other improper purposes, or that 
“compliance would be ‘unnecessarily burdensome.’” RNR Enter., Inc., 122 F.3d at 97 (quoting 
SEC v. Brigadoon Scotch, 480 F.2d 1047, 1056 (2d Cir. 1973)). It is the burden of the party who 
received the subpoena to establish that the subpoena is unreasonable. See Blackfoot Bituminous, 
622 F.2d at 515; Brigadoon Scotch, 480 F.2d at 1056. That burden is “not easily met” where, as 
here, the SEC’s inquiry is legally authorized, and the information is relevant to the inquiry. 
Brigadoon Scotch, 480 F.2d at 1056. 
In refusing to comply with the Commission’s subpoenas, Respondents have raised two 
arguments: (1) the programs CYNM offered and sold are not securities, and (2) all information 
about the CYN Token must come from CASTYOURNETS, LTD, a related foreign entity. 
Neither argument provides a valid reason for non-compliance. 
First, Respondents assert that the SEC lacks jurisdiction to conduct its investigation 
because the products CYNM offers and sells (or offered and sold) are loans and not securities. 
Edwards Decl. ¶¶ 24, 33, 43 & Exs. 12, 18, 21. However, as noted above, while there is evidence 
suggesting that the products are securities, proving one of the products is a security is not the 
burden at this stage. In the federal securities laws, Congress committed the initiation and conduct 
of investigations to the SEC’s “discretion.” See, e.g., Securities Act of 1933 (“Securities Act”) 
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Section 20 [15 U.S.C. § 77t(a)] (“the Commission . . . may, in its discretion . . . investigate” 
possible violations of the securities laws); Exchange Act Section 21(a) [15 U.S.C. § 78u(a)] 
(“The Commission may, in its discretion, make such investigations as it deems necessary to 
determine whether” the securities laws have been violated); see also O’Brien, 467 U.S. at 745 
(“Congress intended to vest the SEC with considerable discretion in determining when and how 
to investigate possible violations of the statutes administered by the Commission”); Gentile v. 
SEC, 974 F.3d 311, 319 (3rd Cir. 2020) (“an agency’s decision on whether to investigate is a 
matter committed to agency discretion by law”). The SEC “‘can investigate merely on suspicion 
that the law is being violated, or even just because it wants assurance that it is not.’” SEC v. 
Arthur Young & Co., 584 F.2d 1018, 1030 (D.C. Cir. 1978) (quoting Morton Salt Co., 338 U.S. 
at 642–43). Put simply, while the SEC must ultimately prove the products at issue are securities 
in any enforcement action it might bring, at this stage the SEC is entitled to subpoena 
information to develop that proof and proof of any associated securities law violations.  
Second, in seeking enforcement of these subpoenas, the SEC is not seeking documents 
directly from CASTYOURNETS, LTD, the foreign entity. Rather, we have reason to believe that 
Respondents have documents in their custody and control related to the CYN Token. The CYN 
Token is advertised on the Cast Your Nets Ministries website under “services.” Edwards Decl. 
¶ 26, n.4. Mr. Trujillo is listed as the Co-Founder and CEO of the CYN Token. Edwards Decl. 
¶ 26. And Dr. Hammonds is listed as the COO of the CYN Token. Edwards Decl. ¶ 36. We have 
also seen evidence that Cast Your Nets Ministries has received funds designated for the purchase 
of “tokens” and has provided at least one individual with information about the CYN Token. 
Edwards Decl. ¶ 15. Thus, it presumably has relevant information regarding the CYN Token. 
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The fact that another entity or individual may also have relevant information does not excuse the 
Respondents’ obligation to produce relevant information in their possession, custody, or control. 
In sum, the SEC has met its slight burden to show that enforcement of the subpoenas is 
appropriate, and Respondents cannot show that the subpoenas are unreasonable, issued in bad 
faith or for other improper purposes, or that “‘compliance would be ‘unnecessarily 
burdensome.’” RNR Enter., Inc., 122 F.3d at 97 (quoting Brigadoon Scotch, 480 F.2d at 1056). 
CONCLUSION 
For the reasons set forth above, the SEC respectfully requests that the Court: (1) issue an 
Order to Show Cause why this Court should not order Respondents to comply with the SEC’s 
administrative subpoenas; and (2) following receipt of Respondents’ arguments, if any, and a  
reply thereto by the Commission, enter an Order compelling Respondents to comply with the 
subpoenas and directing such other relief as may be appropriate. 
Respectfully submitted this 12 day of December, 2024. 
s/ Jacqueline M. Moessner 
Jacqueline M. Moessner  
Securities and Exchange Commission 
1961 Stout Street, Suite 1700 
Denver, CO 80294 
(303) 844-1031 
[email protected]  
 
Counsel for the Securities and Exchange 
Commission 
  
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CERTIFICATE OF SERVICE 
 
I hereby certify that on December 12, 2024, I caused the foregoing application and supporting 
documents to be electronically filed using the CM/ECF system.  I further certify that I will cause 
a copy of the foregoing to be served by email and U.S. Mail on the following once this case is 
docketed in the Court’s CM/ECF system: 
 
Mr. Keith Barrows 
KO Barrows Law 
16 Chestnut Court 
Jersey Shore, PA  17740 
[email protected] 
 
 
 
       
  s/ Jacqueline M. Moessner 
                                                                                    U.S.            Securities            and            Exchange            Commission            
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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLORADO 

Civil Miscellaneous Action No. 24-mc-________ 

SECURITIES AND EXCHANGE COMMISSION, 

 Petitioner, 

v. 

CAST YOUR NETS MINISTRIES;  
CYNM CONSULTING, LLC;  
PHILLIP TRUJILLO; and 
JEREMY (“JE”) HAMMONDS, 

 Respondents. 

APPLICATION FOR ORDER TO SHOW CAUSE AND FOR ORDER COMPELLING 
COMPLIANCE WITH ADMINISTRATIVE SUBPOENAS 

The Securities and Exchange Commission (“Commission” or “SEC”) is investigating 

whether Cast Your Nets Ministries; CYNM Consulting, LLC; Phillip Trujillo; and Jeremy (“Je”) 

Hammonds1 are conducting a fraudulent and unregistered securities offering. In furtherance of its 

investigation, the SEC served administrative subpoenas seeking documents from Cast Your Nets 

Ministries; CYNM Consulting, LLC; and Mr. Trujillo and served administrative subpoenas 

seeking testimony from Mr. Trujillo and Dr. Hammonds (collectively, the “Respondents”). Other 

than producing ten documents, Cast Your Nets Ministries; CYNM Consulting, LLC; and Mr. 

1 We understand Dr. Hammonds’ legal name to be Jeremy Hammonds but that he goes by Je 
Hammonds. Counsel has referred to him as Dr. Hammonds, and he is described on CYNM’s 
website as having a Ph.D. Accordingly, we refer to him as Dr. Hammonds as well. 

122-DDD

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Trujillo have refused to comply with the Commission’s document subpoenas. Further, neither 

Mr. Trujillo nor Dr. Hammonds appeared for their scheduled testimony.  

Counsel for Respondents has informed the SEC staff that Respondents will not comply 

with the subpoenas, will not produce any additional documents, and will not appear for 

testimony. Counsel for the Respondents has acknowledged that Respondents “are fully aware 

that the SEC has reserved its authority to pursue enforcement of the subpoenas in federal court.” 

Declaration of Abigail L.P. Edwards (“Edwards Decl.”) ¶ 24 & Ex. 12. As a result, the SEC has 

no other remedy than the judicial enforcement of the subpoenas. In this case, the SEC needs this 

Court’s assistance to carry out its statutorily authorized mission to protect investors. 

The Commission respectfully requests that the Court: (1) issue an Order to Show Cause 

why Cast Your Nets Ministries; CYNM Consulting, LLC; Mr. Trujillo; and Dr. Hammonds 

should not be compelled to comply with the SEC’s administrative subpoenas; and (2) following 

notice and an opportunity to be heard, order Cast Your Nets Ministries; CYNM Consulting, 

LLC; Mr. Trujillo; and Dr. Hammonds to comply with the Commission’s subpoenas. 

STATEMENT OF FACTS 

I. Respondents 

Cast Your Nets Ministries is a Washington state non-profit corporation with its 

principal office located in Windsor, Colorado. Edwards Decl. ¶ 18. Cast Your Nets Ministries’ 

website lists Mr. Trujillo and Dr. Hammonds as members of its Leadership. Edwards Decl. ¶ 4, 

n.1. That website offered three investment programs and a crypto asset, all of which are 

described further below. Edwards Decl. ¶ 4. Cast Your Nets Ministries is also the parent 

company of CYNM Consulting, LLC. Edwards Decl. ¶ 12 & Ex. 3.  

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CYNM Consulting, LLC is a limited liability corporation registered in the state of 

Delaware with its principal office located in Windsor, Colorado. Edwards Decl. ¶ 10. We 

collectively refer to Cast Your Nets Ministries and CYNM Consulting, LLC as “CYNM.”  

Mr. Trujillo is a board member of Cast Your Nets Ministries. Edwards Decl. ¶ 26. Mr. 

Trujillo was previously charged by the SEC with conducting a fraudulent offering (see SEC v. 

Trujillo, Civ. No. 09-cv-00403-MSK-KMT (D. Colo.) (February 26, 2009)) and subsequently 

convicted by criminal authorities and sentenced to 12 years in prison for the same underlying 

conduct (see Colorado v. Trujillo, D035 2010-CR-000749 (State of Colorado, Larimer County, 

March 7, 2012)). Edwards Decl. ¶ 26.  

Dr. Hammonds is the Chief Operating Officer (“COO”) of Cast Your Nets Ministries. 

Edwards Decl. ¶ 36.  

II. The SEC Formal Order and Investigation 

The SEC is investigating whether the Respondents are conducting a fraudulent and 

unregistered securities offering. Edwards Decl. ¶ 4. CYNM offered three investment programs 

and a crypto asset on its website:  

1) the “CYN Legacy Program,” which was described as “a program partnering with 
Christian churches and organizations to facilitate fund raising projects”;  

2) the “CYN Alternative Savings Plan,” which was described as “a short term, high-
yield program that pays 2% per month up to 6 months for a total of 12%”;  

3) the “Alternative Retirement Program,” which CYNM advertised at various times as 
providing “15% Yearly Returns” or “a 25% return each year for three years”; and  

4) a crypto asset known as the “CYN Token,” which promises to “[d]ouble Your 

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Retirement Savings In Just 5 Years.”2  

Edwards Decl. ¶ 4.  

On April 11, 2024, the Commission issued an Order Directing Private Investigation and 

Designating Officers to Take Testimony in an investigation entitled In the Matter of CYNM 

Consulting, LLC. Edwards Decl. ¶ 5 (the “Formal Order”).3 A formal order generally describes 

the nature of an investigation and designates specific staff members to act as officers of the 

Commission for purposes of the investigation. The Formal Order empowers the designated staff 

members to administer oaths and affirmations, subpoena witnesses, compel their attendance, take 

evidence, and require the production of documents and other materials. Edwards Decl. ¶ 5. The 

Director of Enforcement approved the Formal Order. Id. The Formal Order was subsequently 

corrected on July 10, 2024, to change the name of the investigation to In the Matter of Cast Your 

Nets Ministries. Edwards Decl. ¶¶ 6–7. 

III. The Administrative Subpoenas 

Following issuance of the Formal Order, a member of the SEC staff designated in the 

Formal Order issued subpoenas to Respondents. Edwards Decl. ¶¶ 10, 18, 27, 37 & Exs. 2, 6, 13, 

19. On May 20 and August 6, 2024, the SEC staff properly served subpoenas seeking documents 

 
2 Per the CYN Token website, described further in the Edwards Decl. ¶ 26 n.4, the CYN Token 
is a “Faith-Driven Utility” Token, that promises “[a]ccess to alternative savings, retirement, and 
building programs,” “[a]ccess to low interest bridge, car, and home equity loans,” “access to 
CYN exclusive staking and vesting programs,” and other benefits. Edwards Decl. ¶ 4, n.2.   
3 The SEC staff will provide a copy of the Formal Order or the corrected Formal Order to the 
Court upon request, but respectfully requests that any such review be conducted in camera. 

 

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from CYNM Consulting, LLC and Cast Your Nets Ministries4 related to, among other things, the 

structure and business of the entities, the products CYNM offers, and the crypto asset advertised 

on CYNM’s website. Edwards Decl. ¶¶ 10, 18 & Exs. 2, 6. CYNM has only produced ten 

documents in response to these subpoenas. Edwards Decl. ¶¶ 16, 20. 

On September 30, 2024, the SEC staff designated in the Formal Order served a subpoena 

seeking documents and testimony from Mr. Trujillo concerning, among other things, the 

structure and nature of CYNM’s products. Edwards Decl. ¶ 27 & Ex. 13. The subpoena required 

Mr. Trujillo to appear for testimony at the Commission’s Denver Regional Office on October 21, 

2024. Id. Mr. Trujillo has not produced any documents in response to this subpoena and did not 

appear for testimony. Edwards Decl. ¶¶ 31, 34. 

On September 30, 2024, the SEC staff designated in the Formal Order also served a 

subpoena for testimony on Dr. Hammonds. Edwards Decl. ¶ 37 & Ex. 19. The subpoena required 

Dr. Hammonds to appear for testimony at the Commission’s Denver Regional Office on October 

22, 2024. Id. Dr. Hammonds did not appear for testimony as required by the subpoena. Id. ¶ 41. 

On November 1, 2024, counsel for Respondents sent the SEC staff three letters stating 

that CYNM Consulting, LLC; Cast Your Nets Ministries; and Mr. Trujillo would not be 

producing any more documents and that neither Mr. Trujillo nor Dr. Hammonds would be 

appearing for testimony. Edwards Decl. ¶¶ 24, 33, 43 & Exs. 12, 18, 21.  

CYNM has principally argued that the SEC does not have jurisdiction because the 

 
4 The May 20, 2024 subpoena was served via UPS on CYNM Consulting, LLC’s registered 
agent as well as its principal office located in Windsor, Colorado. Edwards Decl. ¶ 10 & Ex. 2. 
After service of this subpoena, counsel appeared and accepted service of the August 6, 2024 
subpoena. Edwards Decl. ¶ 18 & Ex. 6.    

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products CYNM offers and sells are loans, not securities, and are therefore outside of the 

jurisdiction of the SEC. See Edwards Decl. ¶¶ 12, 16, 19, 20, 22, 24, 28, 33, 38, 43 & Exs. 3, 5, 

7, 8, 9, 10, 12, 14, 18, 20, 21. CYNM has also stated that any documents or information about 

the CYN Token must come from a UK entity issuing the token, CASTYOURNETS, LTD. and 

that counsel could not accept service of a subpoena on behalf of that foreign entity. Edwards 

Decl. ¶¶ 13, 14 & Ex. 4. The SEC staff has explained (1) that Respondents must comply with the 

lawfully issued subpoenas, (2) that the staff has authority to investigate whether or not CYNM is 

offering and selling, or has offered and sold, unregistered securities and whether or not it is 

making false and misleading statements in the offer and sale of securities, or has made such 

statements, and (3) the ten documents produced by CYNM to date is insufficient to assess 

whether CYNM offered and sold securities and made false or misleading statements in 

connection therewith. Edwards Decl. ¶¶ 13, 17. 

Despite the SEC staff’s repeated attempts to secure compliance with the subpoenas, 

Respondents’ counsel informed the SEC staff that his clients would not comply with the 

subpoenas. Edwards Decl. ¶ 22 & Ex. 10. Specifically, on November 1, 2024, counsel stated that 

“CYNM will not be providing any further information to the SEC voluntarily in response to the 

subpoena issued to CYNM. We are fully aware that the SEC has reserved its authority to pursue 

enforcement of the subpoenas in federal court.” Edwards Decl. ¶ 24 & Ex. 12. Counsel reiterated 

this refusal to comply with the SEC subpoenas on behalf of Mr. Trujillo and Dr. Hammonds as 

well. Edwards Decl. ¶¶ 33, 43 & Exs. 18, 21.  

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ARGUMENT 

I.  The Court Has Jurisdiction and a Summary Proceeding is Appropriate. 

The Securities Exchange Act of 1934 (the “Exchange Act”) provides that the SEC “may, 

in its discretion, make such investigations as it deems necessary to determine whether any person 

has violated, is violating, or is about to violate [the Exchange Act].” 15 U.S.C. § 78u(a). As part 

of such investigations, SEC staff who are designated as officers of the SEC for purposes of the 

investigation may, among other things, subpoena documents and testimony. 15 U.S.C. § 78u(b). 

See also SEC v. O’Brien, 467 U.S. 735, 741 (1984) (“Congress has vested the SEC with broad 

authority to conduct investigations into possible violations of the federal securities laws and to 

demand production of evidence relevant to such investigations.”) 

The Court has jurisdiction over this subpoena enforcement action pursuant to 

Section 21(c) of the Exchange Act. See 15 U.S.C. § 78u(c); 15 U.S.C. § 78u(e); Fed. R. Civ. P. 

81(a)(5). The SEC’s investigation is being conducted by the Denver Regional Office, Edwards 

Decl. ¶ 8, and thus jurisdiction and venue are appropriate in this district. See 15 U.S.C. § 78u(c) 

(“[T]he Commission may invoke the aid of any court of the United States within the jurisdiction 

of which such investigation . . . is carried on.”). 

The SEC respectfully requests that its application be considered promptly in a summary 

proceeding. “Federal securities law authorizes the SEC to seek an order from this Court requiring 

compliance with a subpoena in a summary proceeding.” SEC v. Harman Wright Grp., LLC, 

No. 18-mc-00190-CMA, 2018 WL 6102758, at *2 (D. Colo. Nov. 21, 2018) (aff’d, 777 F. App’x 

276 (10th Cir. 2019); see also SEC v. Conway, No. 22-mc-00212-DDD-KAS, 2024 WL 

4252821, at *3 (D. Colo. Sept. 19, 2024) (Report and Recommendation adopted by the District 

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Court Oct. 11, 2024) (same). “Further, a prompt ruling on the SEC’s application is warranted to 

avoid further delay in the investigation.” Harman Wright Grp., LLC, 2018 WL 6102758, at *2 

(citing SEC v. First Sec. Bank, 447 F.2d 166, 168 (10th Cir. 1971); SEC v. Lavin, 111 F.3d 921, 

926 (D.C. Cir. 1997)). 

II.  The Court Should Enforce the Administrative Subpoenas. 

Under well-established Supreme Court and Tenth Circuit precedent, this Court should 

enforce the SEC’s administrative subpoenas because: (1) the investigation is being conducted 

pursuant to a legitimate purpose; (2) the subpoenas seek information that may be relevant to that 

purpose; (3) the information sought is not already in the SEC’s possession; and (4) all required 

administrative steps have been followed. Harman Wright Grp., 2018 WL 6102758, at *2 (citing 

United States v. Powell, 379 U.S. 48, 57–58 (1964); RNR Enter., Inc. v. SEC, 122 F.3d 93, 96 

(2d Cir. 1997); see also Application to Enforce Administrative Subpoenas Duces Tecum of SEC 

v. Knowles, 87 F.3d 413, 415 (10th Cir. 1996)); Conway, 2024 WL 4252821, at *3 (also quoting 

Powell). The SEC’s burden under this framework is a “‘slight one,’ and ‘[t]he requisite showing 

is generally made by affidavit of the agent who issued the summons and who is seeking 

enforcement.’” Harman Wright Grp., 2018 WL 6102758, at *2 (quoting United States v. 

Balanced Fin. Mgmt., Inc., 769 F.2d 1440, 1443 (10th Cir. 1985) (internal quotations omitted)); 

see also Conway, 2024 WL 4252821, at *3. As discussed below, the SEC meets these factors. 

First, the Commission’s investigation is being conducted pursuant to a legitimate 

purpose. “Congress has vested the SEC with broad authority to conduct investigations into 

possible violations of the federal securities laws and to demand production of evidence relevant 

to such investigations.” O’Brien, 467 U.S. at 741. The Formal Order pursuant to which the 

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subpoenas were issued authorizes such an investigation into possible violations of the federal 

securities laws. Edwards Decl. ¶ 5. As discussed above, the SEC is investigating whether 

Respondents are conducting a fraudulent and unregistered securities offering. Edwards Decl. ¶ 4. 

CYNM publicly advertised on its website, and offered and sold, three investment programs and a 

crypto asset, each of which may be a security. Id. The SEC is investigating whether CYNM 

violated the federal securities laws in connection with the offer or sale of a security. 

Second, the subpoenas seek information that may be relevant to the SEC’s legitimate 

investigation. “Administrative agencies vested with investigatory power have broad discretion to 

require the disclosure of information concerning matters within their jurisdiction.” Philips 

Petroleum Co. v. Lujan, 951 F.2d 257, 260 (10th Cir. 1991). Relevance is established when the 

information sought is not “plainly incompetent or irrelevant to any lawful purpose.” Endicott 

Johnson Corp. v. Perkins, 317 U.S. 501, 509 (1943) (cited in Philips Petroleum, 951 F.2d at 

260). The subpoenas seek documents and testimony concerning the structure and business of 

CYNM, the products that they offered and sold, information about investors or customers who 

purchased those products, the crypto asset advertised on the CYNM website, Mr. Trujillo’s 

involvement with CYNM, relevant agreements between Mr. Trujillo and CYNM, Dr. 

Hammonds’ involvement with CYNM, and relevant agreements between Dr. Hammonds and 

CYNM. Edwards Decl. ¶¶ 10, 18, 27, 37 & Exs. 2, 6, 13, 19. That information is relevant to the 

SEC’s investigation into whether the products CYNM is offering and selling (or has offered and 

sold) are securities and whether CYNM has violated the federal securities laws in connection 

with such offers or sales, including by making fraudulent statements and engaging in an 

unregistered securities offering. While there is evidence suggesting that the products are 

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securities, proving one of the products is a security is not the burden at this stage. As discussed 

below, in the federal securities laws, Congress committed the initiation and conduct of 

investigations to the SEC’s “discretion.” See, e.g., Securities Act of 1933 (“Securities Act”) 

Section 20, 15 U.S.C. § 77t(a) (“the Commission . . . may, in its discretion . . . investigate” 

possible violations of the securities laws); Exchange Act Section 21(a), 15 U.S.C. § 78u(a) (“The 

Commission may, in its discretion, make such investigations as it deems necessary to determine 

whether” the securities laws have been violated). Put another way, the SEC is entitled to issue 

subpoenas to determine whether (among other things) the products at issue are securities; it need 

not (as Respondents assume) prove the products are securities in order to secure compliance with 

the subpoenas. Here, the SEC is investigating whether any of the CYNM-offered programs 

violated the federal securities laws, and the subpoenas issued are relevant to that purpose.  

Third, the subpoenas seek information that is not already in the SEC’s possession. 

CYNM has only produced ten documents. Edwards Decl. ¶¶ 16, 20. The SEC has sought, but has 

not received, documents concerning the structure and business of CYNM, the products that they 

offer, the entities’ investments, and the crypto asset advertised on the CYNM website. Edwards 

Decl. ¶¶ 10, 18 & Exs. 2, 6. Mr. Trujillo has not testified under oath nor produced documents 

concerning, among other topics, his involvement with CYNM, the structure and nature of the 

products CYNM has offered, relevant agreements between him and the CYNM entities, 

advertising of the CYNM products, and information related to the CYN Token. Edwards Decl. 

¶¶ 27, 31, 34 & Ex. 13. Dr. Hammonds has not testified under oath concerning, among other 

things, his involvement with CYNM, the structure and nature of the products CYNM has 

offered, relevant agreements between him and the CYNM entities, advertising of the CYNM 

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products, and information related to the CYN Token. Edwards Decl. ¶¶ 37, 41 & Ex. 19. This 

information is in CYNM’s, Mr. Trujillo’s, and Dr. Hammonds’ (and not the SEC’s) possession.  

Fourth, the SEC staff has followed all required administrative steps. The Exchange Act 

authorizes the SEC to initiate investigations and designate officers to, inter alia, subpoena 

witnesses, take evidence, and require the production of records that the SEC deems relevant to its 

investigation. 15 U.S.C. § 78u(a)(1), (b). The Commission delegated this authority to the 

Director of the Division of Enforcement. 17 C.F.R. § 200.30-4(a)(13), (a)(1). The Director of 

Enforcement approved the Formal Order initiating this investigation and authorizing designated 

staff members to subpoena witnesses, take evidence, and require the production of records 

deemed relevant to the investigation. Edwards Decl. ¶ 5. The subpoenas were signed by an SEC 

staff attorney so designated for purposes of this investigation and were properly served on 

CYNM, Mr. Trujillo, and Dr. Hammonds. Id. ¶¶ 10, 18, 27, 37 & Exs. 2, 6, 13, 19. The SEC has 

thus met all administrative requirements. 

Because the SEC readily satisfies its burden, the Court should enforce the Commission’s 

administrative subpoenas. See, e.g., Resolution Trust Corp. v. Thornton, 41 F.3d 1539, 1544 

(D.C. Cir. 1994) (“If an agency’s subpoena satisfies these requirements, we must enforce it.”) 

(emphasis added) (citation omitted); see also, e.g., SEC v. Blackfoot Bituminous, Inc., 622 F.2d 

512, 515–16 (10th Cir. 1980) (affirming district court orders enforcing SEC subpoenas); First 

Sec. Bank of Utah, 447 F.2d at 167–69 (same); SEC v. Conway, No. 22-mc-00212-DDD-KAS, 

2024 WL 4252821, at *13 (D. Colo. Sept. 19, 2024) (Report and Recommendation adopted by 

the District Court Oct. 11, 2024); SEC v. Kimmel, No. 19-mc-00113-CMA, 2020 WL 2800813, 

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at *5 (D. Colo. May 29, 2020) (compelling respondent to comply with SEC administrative 

subpoenas); Harman Wright Grp., 2018 WL 6102758, at *3 (same). 

III.  Respondents Do Not Have a Valid Reason for Refusing to Comply with the 
Subpoenas. 

 
Having established that the SEC satisfies all the criteria to have its subpoenas judicially 

enforced, Respondents may only resist compliance with the subpoenas if they can show that the 

subpoenas are unreasonable, issued in bad faith or for other improper purposes, or that 

“compliance would be ‘unnecessarily burdensome.’” RNR Enter., Inc., 122 F.3d at 97 (quoting 

SEC v. Brigadoon Scotch, 480 F.2d 1047, 1056 (2d Cir. 1973)). It is the burden of the party who 

received the subpoena to establish that the subpoena is unreasonable. See Blackfoot Bituminous, 

622 F.2d at 515; Brigadoon Scotch, 480 F.2d at 1056. That burden is “not easily met” where, as 

here, the SEC’s inquiry is legally authorized, and the information is relevant to the inquiry. 

Brigadoon Scotch, 480 F.2d at 1056. 

In refusing to comply with the Commission’s subpoenas, Respondents have raised two 

arguments: (1) the programs CYNM offered and sold are not securities, and (2) all information 

about the CYN Token must come from CASTYOURNETS, LTD, a related foreign entity. 

Neither argument provides a valid reason for non-compliance. 

First, Respondents assert that the SEC lacks jurisdiction to conduct its investigation 

because the products CYNM offers and sells (or offered and sold) are loans and not securities. 

Edwards Decl. ¶¶ 24, 33, 43 & Exs. 12, 18, 21. However, as noted above, while there is evidence 

suggesting that the products are securities, proving one of the products is a security is not the 

burden at this stage. In the federal securities laws, Congress committed the initiation and conduct 

of investigations to the SEC’s “discretion.” See, e.g., Securities Act of 1933 (“Securities Act”) 

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Section 20 [15 U.S.C. § 77t(a)] (“the Commission . . . may, in its discretion . . . investigate” 

possible violations of the securities laws); Exchange Act Section 21(a) [15 U.S.C. § 78u(a)] 

(“The Commission may, in its discretion, make such investigations as it deems necessary to 

determine whether” the securities laws have been violated); see also O’Brien, 467 U.S. at 745 

(“Congress intended to vest the SEC with considerable discretion in determining when and how 

to investigate possible violations of the statutes administered by the Commission”); Gentile v. 

SEC, 974 F.3d 311, 319 (3rd Cir. 2020) (“an agency’s decision on whether to investigate is a 

matter committed to agency discretion by law”). The SEC “‘can investigate merely on suspicion 

that the law is being violated, or even just because it wants assurance that it is not.’” SEC v. 

Arthur Young & Co., 584 F.2d 1018, 1030 (D.C. Cir. 1978) (quoting Morton Salt Co., 338 U.S. 

at 642–43). Put simply, while the SEC must ultimately prove the products at issue are securities 

in any enforcement action it might bring, at this stage the SEC is entitled to subpoena 

information to develop that proof and proof of any associated securities law violations.  

Second, in seeking enforcement of these subpoenas, the SEC is not seeking documents 

directly from CASTYOURNETS, LTD, the foreign entity. Rather, we have reason to believe that 

Respondents have documents in their custody and control related to the CYN Token. The CYN 

Token is advertised on the Cast Your Nets Ministries website under “services.” Edwards Decl. 

¶ 26, n.4. Mr. Trujillo is listed as the Co-Founder and CEO of the CYN Token. Edwards Decl. 

¶ 26. And Dr. Hammonds is listed as the COO of the CYN Token. Edwards Decl. ¶ 36. We have 

also seen evidence that Cast Your Nets Ministries has received funds designated for the purchase 

of “tokens” and has provided at least one individual with information about the CYN Token. 

Edwards Decl. ¶ 15. Thus, it presumably has relevant information regarding the CYN Token. 

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The fact that another entity or individual may also have relevant information does not excuse the 

Respondents’ obligation to produce relevant information in their possession, custody, or control. 

In sum, the SEC has met its slight burden to show that enforcement of the subpoenas is 

appropriate, and Respondents cannot show that the subpoenas are unreasonable, issued in bad 

faith or for other improper purposes, or that “‘compliance would be ‘unnecessarily 

burdensome.’” RNR Enter., Inc., 122 F.3d at 97 (quoting Brigadoon Scotch, 480 F.2d at 1056). 

CONCLUSION 

For the reasons set forth above, the SEC respectfully requests that the Court: (1) issue an 

Order to Show Cause why this Court should not order Respondents to comply with the SEC’s 

administrative subpoenas; and (2) following receipt of Respondents’ arguments, if any, and a  

reply thereto by the Commission, enter an Order compelling Respondents to comply with the 

subpoenas and directing such other relief as may be appropriate. 

Respectfully submitted this 12 day of December, 2024. 

s/ Jacqueline M. Moessner 
Jacqueline M. Moessner  
Securities and Exchange Commission 
1961 Stout Street, Suite 1700 
Denver, CO 80294 
(303) 844-1031 
[email protected]  
 
Counsel for the Securities and Exchange 
Commission 

  

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CERTIFICATE OF SERVICE 
 
I hereby certify that on December 12, 2024, I caused the foregoing application and supporting 
documents to be electronically filed using the CM/ECF system.  I further certify that I will cause 
a copy of the foregoing to be served by email and U.S. Mail on the following once this case is 
docketed in the Court’s CM/ECF system: 
 
Mr. Keith Barrows 
KO Barrows Law 
16 Chestnut Court 
Jersey Shore, PA  17740 
[email protected] 
 
 
 

       
  s/ Jacqueline M. Moessner 

       U.S. Securities and Exchange Commission 

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