Request for Hearing Motion

In the interest of full transparency, this section addresses our formal Request for Hearing following Farm Credit’s attempt to expand the receivership. While Farm Credit was given every opportunity to present supporting evidence, it repeatedly failed to meet even the minimum legal burden required. This filing reaffirms our position: we welcome accountability, but we also insist on fairness and proof. Where there is no evidence, there should be no expansion.

1. Even After Filing Under Seal, Farm Credit Still Failed to Meet Its Burden of Proof

   The Court’s September 30 order required Farm Credit to file any materials supporting its effort to expand the receivership. It filed nothing by the October 21 response deadline—and even what it later filed under seal failed to present a single piece of evidence that meets the legal standard required to justify expansion.

2. The “Receiver’s Memorandum” Was Not Evidence of Wrongdoing—and Was Never Intended for Filing

   The internal memorandum prepared by the Receiver, later attached by Farm Credit, simply identified a few routine transactions and requested clarification. It drew no conclusions of fraud or alter-ego status and, according to the Receiver himself, was never intended for filing with the Court. Had the Receiver requested information from the Weavers or any of the Non-Defendants, it would have been delivered immediately—just as every other request has been handled throughout this process: transparently and forthrightly.

3. Receiver Took No Position on Including Any Non-Defendant in the Receivership

   The Receiver’s own Motion to Clarify explicitly took no position on whether any independent entities should be included. He simply sought the Court’s guidance on scope—undercutting Farm Credit’s claim that expansion is necessary or justified.

4. Farm Credit’s Timing Reveals a Tactic—Not Proof

   Farm Credit did not possess the Receiver’s memorandum when it first argued for expansion in its Statement. Only after our responses did it file materials under seal—an act that was tactical, not evidentiary. And even still, those filings failed to meet even the most basic minimum of the burden of proof required by law.

5. Farm Credit’s Claims Remain Unsupported by Law, Fact, or Any of the Receiver’s Own Filings

   Not a single document submitted by Farm Credit or referenced by the Receiver provides evidence to justify expanding the receivership. The record shows no fraud, no insolvency, and no legal basis to seize independent entities that were never part of the original order.

6. Our Request: Deny the Motion and, If Needed, Set a Hearing

   Given Farm Credit’s repeated failure to meet its burden of proof, the filing requests that the Court reject the motion outright. However, should the Court wish to explore any remaining questions or require clarification, we respectfully request that a formal hearing be set to address those matters directly.