Rick Varnell

Sources searched: CourtListener bulk data (RECAP dockets as of 2026-09-30; recall-first rule 10-24) — federal district + bankruptcy courts State courts: not covered (one-tap state court links under Look further). PACER: not searched. · Last checked Oct 24, 2026, 2:47 AM ET.

Court records show docket facts only; we never restate allegations as facts. Outcome wording comes from the docket feed; where it does not state a disposition we say so.

State courts: not covered (one-tap state court links under Look further). No state offers a lawful automated statewide source PartnerFacts can use today. Texas (re:SearchTX) terms prohibit storing results in a database open to third parties; New York (WebCivil) and Massachusetts (MassCourts) require a browser check that blocks scripted queries; California has no statewide index (58 county portals; Rule of Court 2.503 grants name-based access case by case); Florida, Utah and Illinois offer paid or partial access whose terms for automated use are unverified. Washington (dw.courts.wa.gov; bulk index reports under a JISC data-dissemination agreement), Delaware (CourtConnect; Court of Chancery not included) and Arizona (apps.azcourts.gov/publicaccess, which has an official channel to request high-volume access) are the candidates; PartnerFacts will request written permission before any automated search. Federal courts are searched through CourtListener / RECAP.

SEC enforcement searched: SEC litigation releases and administrative proceedings — respondent names in the sec.gov index titles (30,205 releases, 1995-09-19 to 2026-10-23); release text is read only to confirm a candidate. Names that appear only in the body of a release are not found. — Searched SEC litigation releases and administrative proceedings (1995→ / 2007→) (30,205 records as of Oct 24, 2026, 2:50 AM ET) — nothing matched Rick Varnell..

State securities regulators searched: AZ (Corporation Commission Securities Division), CA (DFPI — 16 of 12,159 DFPI respondent pages read so far; sponsor-name matches are read first), DE (DOJ Investor Protection Unit), TX (State Securities Board), WA (DFI) — last crawled Oct 23, 2026, 9:57 PM ET. Other states are not covered.

Sources searched: Federal bankruptcy courts via CourtListener / RECAP archive (federal district courts, federal bankruptcy courts). State courts: not covered (one-tap state court links under Look further). PACER: not searched (RECAP only). · Last checked Oct 24, 2026, 2:47 AM ET.

Court records show docket facts only; we never restate allegations as facts. Outcome wording comes from the docket feed; where it does not state a disposition we say so.

State courts: not covered (one-tap state court links under Look further). No state offers a lawful automated statewide source PartnerFacts can use today. Texas (re:SearchTX) terms prohibit storing results in a database open to third parties; New York (WebCivil) and Massachusetts (MassCourts) require a browser check that blocks scripted queries; California has no statewide index (58 county portals; Rule of Court 2.503 grants name-based access case by case); Florida, Utah and Illinois offer paid or partial access whose terms for automated use are unverified. Washington (dw.courts.wa.gov; bulk index reports under a JISC data-dissemination agreement), Delaware (CourtConnect; Court of Chancery not included) and Arizona (apps.azcourts.gov/publicaccess, which has an official channel to request high-volume access) are the candidates; PartnerFacts will request written permission before any automated search. Federal courts are searched through CourtListener / RECAP.

Counts come from Form D Items 12–15 on the filings in our index (latest filing per offering; one offering = one SEC file number; an amendment updates its offering rather than adding one). "To insiders" = gross proceeds used for payments to executive officers, directors or promoters. "—" = not reported on that filing. Amounts marked (est.) were reported as estimates. "Paid to sell it" = sales compensation recipients named on that filing (Item 12), each linked to FINRA BrokerCheck when a CRD number is reported.