Appendix A to the Motion is the Amended Complaint, and Appendix B (immediately following A in the same .pdf in the link) is the original Complaint with the proposed changes shown as strikethrough or underline for deleted or added material.
Lots of new shit has come to light in the amended complaint. A couple of highlights:
One of the more interesting additions is paragraph 82, on page 20 of the Amended Complaint: (emphasis added)
AEHI Continues to Issue New Press Relaeases
82. On or around September 22, 2010, after raising the issue with Gillispie and company management, AEHI's securities lawyers and investor relations firm resigned over their concerns about the volume and and nature of AEHI's press releases.On page 12, the SEC adds a new laundry list of Private Placement Memoranda that, according to the SEC, "falsely state" "that they have funding."
83. Following these resignations, AEHI continued to issue a new press release almost every business day, including on October 4, 11, 14, 15, 18, 19, 25, 27, 28; November 1, 2, 8, 9, 11, 15, 17, 22, 29; and December 1, 2, 3, 6, 10, and 13, 2010.
As more new shit comes to light, the Dude will post it here.