FOIAengine: How a Grassroots Movement Saw New Evidence of a Conspiracy
In December, a retired California Highway Patrol officer named Wilma Stone filed an unusual Freedom of Information Act request with the Securities and Exchange Commission.
Stone asked the agency for any records in its possession that mentioned Jeffrey Epstein and Kathryn Ruemmler, the former White House counsel who currently serves as general counsel of Goldman Sachs, as well as the keywords “S-1, Fraud, Oversold Position, Phantom Shares, and Ghost Shares.”
At first glance, Stone’s request seemed puzzling. Epstein died in federal custody in 2019. At the time of Stone’s FOIA request last December 14, Ruemmler’s connection to the notorious sex offender wasn’t fully known. Although the Wall Street Journal revealed ties between the two as early as 2023, Ruemmler had deflected efforts to link her closely to Epstein, and the Goldman Sachs leadership team unequivocally supported their general counsel.
But Stone, one of many disgruntled investors in an obscure microcap stock known as Meta Materials, had been hearing rumors about Epstein and Ruemmler in the live audio chatrooms known as “Spaces” on the social-media platform X.
“They were talking about FOIAs, and they were talking about Epstein, and they were talking about Kathy Ruemmler having a relationship with him,” Stone told us. “What kind of relationship? I have no idea, but it sounded like they were pretty tight.
“So that’s when I thought, well, I’ll check out a FOIA.”
Stone’s FOIA request became a signal six weeks before the Justice Department released over 3 million pages of records, along with thousands of videos and images, in compliance with the Epstein Files Transparency Act. Ruemmler, the fourth highest-paid executive at Goldman ($22.5 million in 2024), resigned last month, effective on June 30. (Ruemmler has said that her communications with Epstein were limited and that she was unaware of any ongoing misconduct. She has denied any wrongdoing and hasn’t been charged with any crime.)
DOJ’s trove of documents revealed just how close the friendship was between Ruemmler and the man from whom she accepted expensive gifts and sometimes called “Uncle Jeffrey.” As a Bloomberg columnist put it last month, “Ruemmler’s ties to Epstein continued until his end: She was one of three calls he made the night he was arrested in 2019. She sat near his legal team when he was arraigned that same year on a charge of sex trafficking minors. . . . A version of Epstein’s will from 2019 named Ruemmler as a backup executor.”
But Stone’s interest wasn’t in the salacious aspects of the friendship between Ruemmler and her pedophile friend. Rather, the key words that Stone was asking about – S-1, Fraud, Oversold Position, Phantom Shares, and Ghost Shares – were code words familiar to the thousands of investors involved one of the most persistent grassroots investigations ever mounted by retail traders.
In essence, Stone was using the federal open-records act to explore a deep-state conspiracy theory. She wanted to see if Epstein and his vast circle of acquaintances could somehow be tied to the still-unfolding saga involving Meta Materials.
Activist investor groups have spent years looking for trading records, regulatory filings, and corporate disclosures related to Meta Materials and its predecessor company, Torchlight Energy Resources. The controversy has pitted ordinary people against regulators at the SEC and the Financial Industry Regulatory Authority over what the activists see as a botched stock conversion and trading halt.
We’ve been tracking the Meta Materials controversy because it remains the single largest source of FOIA requests that come into the SEC each month. (See our previous stories, A Grassroots FOIA Campaign Swarms the SEC, and MMTLP Investors Question SEC’s FOIA Denials.)
According to PoliScio Analytics’ competitive-intelligence database FOIAengine, which tracks FOIA requests in as close to real-time as their availability allows, so far in 2026 there have been over 200 FOIA requests to the SEC mentioning the Meta Materials ticker MMTLP – and at least 1,900 such requests since 2022. The requesters don’t have much to show for their efforts. “We’ve been obstructed from Day One,” MMTLP activist Leo Zinga told us.
Recent FOIA requests have begun to mention Ruemmler and Epstein, indicating a new line of inquiry.
And yes – spoiler alert here – it turns out that Wilma Stone was on to something. Jeffrey Epstein does, indeed, play a role in the story. Even though Epstein is likely just a bit player, his walk-on is enough to keep the conspiracy theories alive, and to generate still more lines of inquiry.
Here’s a recap of what’s happened thus far: Torchlight Energy Resources was a small oil-and-gas exploration company trading under the ticker TRCH during the 2010s. In 2021, the company executed a reverse-merger with a Canadian technology firm, Metamaterial Inc., effectively transforming Torchlight into Meta Materials Inc.
As part of the deal, Torchlight shareholders received a special preferred dividend intended to capture the value of Torchlight’s oil assets. Those preferred shares later began trading under the symbol MMTLP.
In December 2022, just days before those shares were scheduled to convert into equity in a private company called Next Bridge Hydrocarbons, FINRA halted trading in MMTLP.
The halt, under a rarely used FINRA rule known as “U3,” prevented many investors from closing their positions. FINRA’s action triggered lawsuits, congressional inquiries, and the ongoing online campaign demanding regulatory explanations. Normally, a U3 halt is temporary. But in the case of MMTLP, the halt was permanent. Because the security never resumed trading, the halt effectively froze the market and became the central grievance among investors who say they were prevented from closing positions. The stock never resumed trading, and the ticker symbol was canceled.
Next Bridge Hydrocarbons now holds the oil-and-gas assets originally tied to Torchlight, while lawsuits and investor complaints continue over the 2022 trading halt. Retail investors have filed petitions with regulators, pursued litigation against brokerage firms, and sought congressional investigations into the circumstances surrounding the halt.
Despite all that pressure, the activist investors so far have been stymied in their efforts to dig up more information about who within the SEC and FINRA ordered the trading halt, and why. Social media, chat rooms, and audio forums have filled the void and fueled the conspiracy theories about the 2022 trading halt.
That was how Wilma Stone got the idea to file her FOIA request with the SEC.
Stone’s FOIA request sought “all emails, texts, memos, meeting notes, calendar entries, Microsoft Teams chats, and Bloomberg messages (or similar communication platforms) sent or received between Kathryn Ruemmler, current Goldman Sachs Chief Legal Officer, and Jeffrey Epstein (American financier) that contain any of the following keywords: S-1, Fraud, Oversold Position, Phantom Shares, and Ghost Shares.”
Stone said she hasn’t received anything back from the SEC, other than an acknowledgment.
But then came the newly released Justice Department records, adding fresh fuel to the MMTLP conspiracy theories.
Among the millions of pages of documents published by the Justice Department from Epstein’s financial files was a June 2014 Ameriprise brokerage statement showing that Epstein once held a $213,004 position in Torchlight Energy Resources, the small oil exploration company whose corporate lineage would later produce MMTLP.
At the time, Torchlight was a relatively obscure oil-and-gas exploration company, and there is no public evidence that Epstein had any operational role at the company. The brokerage record appears to show a standard investor position rather than any insider relationship. There is also no public evidence linking Ruemmler to Torchlight Energy, Meta Materials, or the MMTLP trading controversy.
But the historical significance of Epstein’s bet on Torchlight lies in what it would later become: another dataset to examine, and another touchstone for multiple sagas – Epstein, MMTLP, take your pick – that resist ending.
Additional Reporting by Isabella Pietro.
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John A. Jenkins, co-creator of FOIAengine, is a Washington journalist and publisher whose work has appeared in The New York Times Magazine, GQ, and elsewhere. He is a four-time recipient of the American Bar Association’s Gavel Award Certificate of Merit for his legal reporting and analysis. His most recent book is The Partisan: The Life of William Rehnquist. His next book, Summer of ’71: Five Months That Changed America, about the fateful year before Watergate, will be out in June. Jenkins founded Law Street Media in 2013. Prior to that, he was President of CQ Press, the textbook and reference publishing enterprise of Congressional Quarterly. FOIAengine is a product of PoliScio Analytics (PoliScio.com), a new venture specializing in U.S. political and governmental research, co-founded by Jenkins and Washington lawyer Randy Miller. Learn more about FOIAengine here. To review FOIA requests mentioned in this article, subscribe to FOIAengine.
Write to John A. Jenkins at JAJ@PoliScio.com.