From: Edwin Batista 
Date: Monday, December 1, 2025 at 7:38?PM 
To: Secretarys-Office <Secretarys-Office@SEC.GOV> 
Subject: IMPORTANT: Rule 192 Petition – Request for SEC Record Preservation Order for All MMTLP-Related Materials 



Attn: Ms. Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549



Under Rule 192 of the SEC’s Rules of Practice and 5 U.S.C. § 553(e), I respectfully submit this petition requesting that the SEC immediately issue a temporary or permanent record-preservation directive for all materials related to MMTLP, the associated corporate action, and the trading halt that occurred on December 9, 2022.

This request is necessary to ensure that no relevant documents are destroyed while FOIA requests, litigation, oversight inquiries, and investor-harm assessments remain active.



Requested Action
I request that the SEC issue a Commission-level directive requiring all SEC divisions, offices, contractors, and service providers to preserve all records relating to:

MMTLP and the Series A Preferred share structure. The corporate action involving the distribution of Next Bridge Hydrocarbons shares. The U3 trading halt imposed on December 9, 2022. Any short positions, fails-to-deliver, CNS exceptions, or reconciliation issues involving MMTLP. All inter-agency communications among the SEC, FINRA, DTCC, and other regulators regarding MMTLP. All investor complaints, Congressional inquiries, and internal responses concerning MMTLP. All FOIA-processing records, including redactions, denials, and contractor workflows. All drafts, emails, memos, call notes, meeting summaries, or internal discussions connected to the above. 

This preservation requirement should cover every format, including emails, messages, memos, spreadsheets, draft documents, phone-call notes, Teams/Zoom logs, and any data held by C2 Alaska or any other outside vendor handling SEC records.




Reason for Petition


The MMTLP halt resulted in significant investor harm. The event remains the subject of lawsuits, Congressional interest, and ongoing FOIA activity. Public reporting indicates unusually high FOIA denial rates related to MMTLP. Contractors involved in SEC FOIA processing may hold or handle records that could otherwise be deleted under standard retention schedules. A preservation directive imposes minimal burden but ensures public accountability and prevents loss of critical evidence. 




Relief Requested


Please accept this petition and issue a Commission-level order requiring immediate preservation of all SEC and contractor records relating to MMTLP until all investigations, FOIA matters, litigation, and oversight activities have been fully resolved. If there are any associated fees for this request, I’d like to request a fee waiver. 

Thank you for your attention to this matter. I respectfully request written confirmation of receipt and notice of any action taken.

Sincerely,
Edwin Batista