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JURISDICTION AND VENUE EVN 3. The ATTORNEY GENERAL brings this action pursuant to 28 U.S.C. 1345 and Section 8(f) of the Registration Act, 22 U.S.C. 618(f), to enjoin such acts and practices. 4. This Court has jurisdiction over this action pursuant to 28 U.S.C. 1345 and Section 8(f) of the Registration Act, 22 U.S.C. 618(£). 5. Certain of the acts, practices, courses of business and transactions alleged herein to constitute violations of the Registration Act occurred within the District of Columbia. 6. Section 8(f) of the Registration Act, 22 U.S.C. 618(f£), provides that enforcement actions shall be made a preferred cause and expedited in every way. THE DEFENDANT 7. Defendant WILLIAM A. (BILLY) CARTER, III, is an individual domiciled in the State of Georgia. CAUSE OF ACTION Section 2(a) of the Registration Act 22 U.S.C. 612(a) and Rules 200 and 201 thereunder, 28 C.F.R. 5.200 and 5.201 respectively. 8. Paragraphs 1 through 7 are hereby realleged and incorporated herein by reference. 9. At some time or times unknown to the ATTORNEY GENERAL, the defendant Singly and in concert with others, reached an understanding to act within the United States as an ‘agent of the Socialist People's Libyan Arab Jamahiriya ("Libya") and Mu'ammar al Qadhafi, its Chief of State, ana individually and through his agents, employees, officers, servants and assigns did undertake specific activities calculated to promote Libyan foreign policy objectives by attempting to improve the image of Libya within the United States.