Aj Capital Management LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or

11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
6927368
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
WEPRIN, ANDREW, JAY
(For individuals, Last, First,
Middle)
CRD
Number:
3092429
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
WEPRIN, BENJAMIN, JASON
(For individuals, Last, First,
Middle)
CRD
Number:
6927370
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HASSBERGER, ERIC, DONALD
(For individuals, Last, First,
Middle)
CRD
Number:
5007528
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
PETERSEN, JUSTIN, DAVID
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
BELFAST MAGISTRATES COURT, PUBLIC PROSECUTION SERVICE, CASE # 1171095
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
10/08/2023
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
ON 8 OCTOBER 2022, THE DIRECTORS OF SDHUK OPERATOR LTD (COMPANY NUMBER NI673203) (THE "COMPANY") WERE CHARGED WITH
FAILURE TO COMPLY WITH SECTION 441 OF THE COMPANIES ACT 2006 IN THAT THE DIRECTORS (ON BEHALF OF THE COMPANY) FAILED TO FILE
ACCOUNTS AND REPORTS FOR THE FINANCIAL YEAR BEFORE THE END OF THE PERIOD FOR FILING THE SAID ACCOUNTS AND REPORTS, CONTRARY
TO SECTION 451 OF THE COMPANIES ACT 2006. EACH OF THE DIRECTORS PLED GUILTY TO SUCH CHARGES, WHICH MAY BE CATEGORIZED
INVESTMENT-RELATED TO THE EXTENT THE COMPANY (1) OWNS AND CONTROLS REAL ESTATE AND (2) IS ITSELF OWNED BY AN INVESTMENT
VEHICLE SPONSORED BY AJ INVESTMENT MANAGER LLC.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
10/17/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
THE CHARGES RESULTED IN A CONVICTION FOR EACH DIRECTOR AS OF 17 OCTOBER 2023 WITH A FINE OF £165 PER DIRECTOR AND PAYMENT TO BE
MADE BEFORE 26 DECEMBER 2023. EACH OF THE DIRECTORS PAID SUCH FINE ON OR BEFORE 29 OCTOBER 2023.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
THE CONVICTION ARISES OUT OF A CHARGE FOR FAILING TO COMPLY WITH THE UNITED KINGDOM'S COMPANIES ACT 2006, AND THE COMPANY'S
OBLIGATION TO DISCLOSE ACCOUNTS AND REPORTS ON TIME. THE RELEVANT ACCOUNTS (YEAR-END 2021) HAVE SUBSEQUENTLY BEEN FILED AND
WITH NO ISSUES RAISED BY CREDITORS. THE ACCOUNTS OUGHT TO HAVE BEEN DELIVERED BY 7 OCTOBER 2022 AND IT WAS ACCEPTED THAT THEY
WERE FILED LATE. THERE WERE A NUMBER OF REASONS FOR THE INADVERTENT LATE FILING. THE COMPANY WAS FORMED AS PART OF THE
INVESTMENT BY AJ RCD FUND LLC, AND ITS ACQUISITION OF THE SLIEVE DONARD HOTEL IN NORTHERN IRELAND. CONSIDERABLE WORK WAS
SUBSEQUENTLY REQUIRED BY THE COMPANY'S ACCOUNTANTS WHEN COMPLETING THEIR AUDIT RELATED TO THE PERIOD OF TIME THAT THE HOTEL
WAS OWNED BY THE PREVIOUS OWNER IN ORDER TO FILE SUFFICIENT ACCOUNTS AND REPORTS. FURTHERMORE, DUE TO THE REQUIREMENT FOR THE
REGISTERED OFFICE OF THE COMPANY TO HAVE BEEN IN NORTHERN IRELAND, THE HOTEL ADDRESS ITSELF HAD TO BE USED AS THE REGISTERED
OFFICE ADDRESS. THE HOTEL WAS GOING THROUGH SUBSTANTIAL RENOVATION FROM LATE 2022 INTO 2023. THIS CAUSED SIGNIFICANT DISRUPTION
WITH ONLY SKELETON STAFF BEING ON SITE, WHICH RESULTED IN THE CORRESPONDENCE FROM COMPANIES HOUSE AND SUBSEQUENTLY THE
PUBLIC PROSECUTION SERVICE BEING MISSED. THE SUBJECT OFFENCE CAN ONLY INCUR A MAXIMUM FINE OF £5,000 WITH NO POTENTIAL FOR
IMPRISONMENT. ALTHOUGH THE COURT WAS BOUND BY THE LAW TO UPHOLD THE CONVICTIONS AS THE ACCOUNTS WERE FILED LATE, AFTER
EXAMINING THE FACTS AND CIRCUMSTANCES BEHIND THE LATE FILINGS, THE COURT DECREED THE LOWEST LEVEL OF FINE POSSIBLE FOR EACH
DIRECTOR (£150 PLUS OFFENDER LEVY OF £15 ­ TOTAL £165 PER DIRECTOR).