Motion Sickness, Part II: Discovery Dispute Continues; SEC Files Motion to Compel AEHI to Produce and Preserve Documents

Continuing the saga of the discovery dispute from May, the SEC has now filed a Motion to Compel Alternate Energy Holdings, Inc., and its CEO Don "Idunno" Gillispie to produce the shit the SEC has been asking for since, oh, 'round 'bout Dec 27th or so, give or take . The SEC looks to be none too happy with AEHI's attorneys shenanigans, so the SEC fired this motion off, escalating things a bit:

Motion to Compel
Memorandum in support of Motion to Compel
Declaration of SEC Attorney David Berman 
Exhibits A-F
Exhibit G:  Deposition of Don Gillispie, June 28, 2011.
Exhibits H-P


Interesting look at our CEO with 45 years experience who is somehow worth more than $40,000.00 per month:   
Video of SEC attorneys asking Don a simple question.

Q. Is AEHI China incorporated in the United States?
A. N0.
Q. Is it incorporated in China?
A. They have a Chinese business license. I do not know if they are incorporated in China.
Q. Is AEHI China incorporated in any jurisdiction?
MR. ROTH: In the US, you mean?
Q. BY MR. BERMAN: In any jurisdiction anywhere?
A. I really don't know. I just wanted to have a business license in China because that's
what we needed to be able to do this.
Q. When I say "incorporated," that implies that AEHI China may be a corporation. Let me ask a different question. Does AEHI China have a business form other than a corporation?
A. I don't know.
Q. For example, is AEHI China an LLC?
. I don't think so, but I'm not sure.
Or something called a Limited Company? . It may be that. That rings a bell.
Who would know whether AEHI China -

who would know about the corporate structure of AEHI China?

A. I assume Nancy Shi, since she's the one that set it up.

Q. Is AEHI China registered with the Chinese government in any way other than having a business license?
A. All these documents are in Chinese. I've seen the business license, and you can see "AEHI China" and everything else is in Chinese. I don't know exactly, but I know she had to get all of these pieces of paper to make this an existing entity that could operate in China. So whatever was required of it to get a license from the government, I know it took a business license because I've seen that. I think it may be issued from the government, and it is universal. It is not a city license, per se. We may do one in the state, but they do one for the whole country. I think the answer is yes to that question.
Q. I think you testified you don't have perfect understanding of this. S0 if you don't know, that's fine. I'm just going to ask some clarifying questions.
Does AEHI China have a charter from theChinese government?
A. I don't know.
Q. Does AEHI China report to the Chinese government in the way that AEHI reports to the Securities and Exchange Commission in the United States?
A. I don't know that either.
Q. D0 you know if AEHI China pays taxes in China?
A. I assume so.
MR. ROTH: If you don't know -
THE WITNESS: I don't know.
MR. ROTH: He doesn't want any assumptions. He wants to know what you know.
THE WITNESS: I do not. I don't know.
Q. BY MR. BERMAN: Does AEHI China pay taxes in the United States?
A. I don't know that either.

Q. Does AEHI China report to any ' United States based regulators?
A. I've never heard that mentioned.

Q. Does AEHI China work with any entity other than AEHI?
A. No.
Q. And let me clarify that. I'm thinking maybe I saw some hesitation, and I think know

Other than as a counter party, does AEHI China work on behalf of any other entity besides AEHI?
A. I do not believe so.
Q. Does AEHI China have a physical office anywhere?
A. Yes.
Q. And where is that located?
A. It's in Beijing.
Q. Can you tell me the address in Beijing?
A. Not off the top of my head. It is in the Central Business District.

Q. Does it have any other offices anywhere?
A. N0.
Q. Does it maintain files anywhere outside of its Beijing office? 1
A. I don't think so.