Sweetwater Private Equity

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 
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
p
g
g
(
)
OR
p
p
p
,
,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
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. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
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:
4374373
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GAMETT, JAMES, BUNKER
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SWEETWATER CARE RESOURCE,
LLC
(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.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4),
and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in
Item 11 that occurred more than ten years ago.
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.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CALIFORNIA DEPARTMENT OF JUSTICE, OFFICE OF THE ATTORNEY GENERAL
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, INJUNCTION, RESTITUTION, APPOINTMENT OF RECEIVER/COMPLIANCE MONITOR.
3.
Date Initiated (MM/DD/YYYY): 
06/23/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
25CU033612N, SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SAN DIEGO
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
SWEETWATER CARE RESOURCE, LLC
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CALIFORNIA DEPARTMENT OF JUSTICE FILED A CIVIL ACTION ALLEGING THAT SWEETWATER CARE RESOURCE, LLC, 17 AFFILIATED SKILLED NURSING
FACILITY LICENSEES OPERATING IN CALIFORNIA, AND THE INDIVIDUAL OWNERS, INCLUDING JAMES GAMETT, ENGAGED IN VIOLATIONS OF CALIFORNIA'S
UNFAIR COMPETITION LAW (BUS. & PROF. CODE §§ 17200, 17500 ET SEQ.) IN CONNECTION WITH THE OPERATION OF SKILLED NURSING FACILITIES. THE
COMPLAINT ALLEGES THAT BETWEEN 2020 AND 2024, THE DEFENDANTS FAILED TO COMPLY WITH CALIFORNIA'S MINIMUM NURSING STAFFING
REQUIREMENTS (3.5 AGGREGATE DIRECT CARE NURSING HOURS PER PATIENT PER DAY, OF WHICH 2.4 HOURS MUST BE PROVIDED BY CERTIFIED NURSE
ASSISTANTS), FAILED TO HAVE A REGISTERED NURSE PRESENT FOR AT LEAST 8 HOURS PER DAY, AND THAT CERTAIN PATIENT CARE WAS AFFECTED BY THE
ALLEGED STAFFING DEFICIENCIES. THE COMPLAINT SEEKS INJUNCTIVE RELIEF, CIVIL PENALTIES, AND RESTITUTION.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
07/20/2026
 Exact
 Explanation
If not exact, provide explanation:

12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 15,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE MATTER WAS RESOLVED BY A STIPULATED FINAL JUDGMENT ENTERED AS AN ORDER OF THE SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN
DIEGO ON 07/20/2026 FOLLOWING MEDIATION BEFORE THE HONORABLE HERBERT HOFFMAN (RET.). THE AGGREGATE COURT-ORDERED FINANCIAL
OBLIGATION OF $15,000,000 COMPRISES TWO SEPARATE COMPONENTS: (1) A $12,500,000 PENALTY PAYMENT OWED JOINTLY AND SEVERALLY BY
SWEETWATER CARE RESOURCE, LLC AND THE 17 AFFILIATED CALIFORNIA SKILLED NURSING FACILITY LICENSEES; AND (2) A SEPARATE $2,500,000
COMPLIANCE SPENDING OBLIGATION REQUIRING DEFENDANTS TO SPEND THAT AMOUNT DURING THE MONITORING PERIOD ON QUALIFIED
RECRUITING, TRAINING, RETENTION, STAFFING INFRASTRUCTURE, AND INCREMENTAL WAGE EXPENDITURES, WITH ANY SHORTFALL DEEMED A
DELAYED PENALTY PAYABLE TO THE STATE. THE JUDGMENT ALSO IMPOSES A FINAL INJUNCTION APPLICABLE ONLY TO THE OPERATION OF THE
NAMED CALIFORNIA SKILLED NURSING FACILITIES; THE INJUNCTIVE TERMS DO NOT RESTRICT OR AFFECT ANY INVESTMENT ADVISORY ACTIVITY.
JAMES GAMETT WAS DISMISSED WITHOUT PREJUDICE UPON ENTRY OF THE FINAL JUDGMENT, WITH NO FINDINGS AGAINST HIM AND NO INDIVIDUAL
FINANCIAL, INJUNCTIVE, OR MONITORING OBLIGATION. THE MATTER IS NOT INVESTMENT-RELATED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must
fit within the space provided).
BETWEEN MAY AND OCTOBER 2024, SWEETWATER CARE RESOURCE, LLC AND 17 AFFILIATED SKILLED NURSING FACILITIES OPERATING IN CALIFORNIA
RECEIVED INVESTIGATIVE SUBPOENAS FROM THE CALIFORNIA DEPARTMENT OF JUSTICE ("DOJ") REGARDING COMPLIANCE WITH CALIFORNIA'S MANDATED
STAFFING REQUIREMENTS. DESPITE COMPREHENSIVE COOPERATION, INCLUDING THE PRODUCTION OF HUNDREDS OF THOUSANDS OF DOCUMENTS, THE
DOJ FILED SUIT ON JUNE 23, 2025, IN THE SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO (CASE NO. 25CU033612N), ALLEGING VIOLATIONS
OF CALIFORNIA'S UNFAIR COMPETITION LAW AND SEEKING INJUNCTIVE RELIEF, CIVIL PENALTIES, AND RESTITUTION FOR ALLEGED FAILURES TO COMPLY
WITH CALIFORNIA'S NURSING STAFFING REQUIREMENTS BETWEEN 2020 AND 2024. AN INTERNAL REVIEW DETERMINED THAT THE ALLEGED DEFICIENCIES
WERE ATTRIBUTABLE TO INADEQUATE SYSTEMS FOR DOCUMENTING THE PRESENCE OF STAFF RATHER THAN THE ACTUAL ABSENCE OF STAFF. BEGINNING
IN MID-2024, SUBSTANTIAL RESOURCES WERE INVESTED TO IMPLEMENT COMPREHENSIVE COMPLIANCE TRACKING SYSTEMS. SINCE IMPLEMENTATION,
THE CALIFORNIA FACILITIES HAVE ACHIEVED A STAFFING COMPLIANCE RATE OF 99.5% OR GREATER, EXCEEDING THE AVERAGE FOR CALIFORNIA SKILLED
NURSING PROVIDERS AND FALLING WELL WITHIN THE ENFORCEMENT GUIDELINES OF THE CALIFORNIA DEPARTMENT OF PUBLIC HEALTH. FOLLOWING
MULTIPLE MEDIATION SESSIONS WITH THE HONORABLE HERBERT HOFFMAN (RET.), THE PARTIES RESOLVED THE MATTER THROUGH A STIPULATED FINAL
JUDGMENT ENTERED AS AN ORDER OF THE COURT ON JULY 20, 2026. UNDER THE JUDGMENT, SWEETWATER CARE RESOURCE, LLC AND THE 17 AFFILIATED
CALIFORNIA SNF LICENSEES ARE JOINTLY AND SEVERALLY OBLIGATED TO PAY $12,500,000 IN CIVIL PENALTIES INTO THE CALIFORNIA UNFAIR
COMPETITION LAW FUND ON A DEFINED INSTALLMENT SCHEDULE THROUGH JULY 2029, AND ARE SEPARATELY OBLIGATED TO SPEND $2,500,000 ON
QUALIFIED COMPLIANCE-RELATED EXPENDITURES DURING THE MONITORING PERIOD, WITH ANY SHORTFALL PAYABLE TO THE STATE AS A DELAYED
PENALTY. THE JUDGMENT ALSO IMPOSES A FINAL INJUNCTION GOVERNING OPERATION OF THE NAMED CALIFORNIA SKILLED NURSING FACILITIES FOR A
MINIMUM OF THREE YEARS FOLLOWING ENTRY, SUPERVISED BY AN INDEPENDENT COMPLIANCE MONITOR AT DEFENDANTS' EXPENSE, WITH JUDGE
HOFFMAN APPOINTED AS SPECIAL MASTER TO ADDRESS DISPUTES REGARDING MONITORING. THE COURT RETAINED JURISDICTION UNDER CALIFORNIA
CODE OF CIVIL PROCEDURE § 664.6 TO ENFORCE THE JUDGMENT UNTIL FULL PERFORMANCE. JAMES GAMETT WAS DISMISSED WITHOUT PREJUDICE UPON
ENTRY OF THE FINAL JUDGMENT, WITH NO FINDINGS AGAINST HIM AND NO INDIVIDUAL FINANCIAL, INJUNCTIVE, OR MONITORING OBLIGATION. THE
INJUNCTIVE TERMS DO NOT RESTRICT OR AFFECT ANY INVESTMENT ADVISORY ACTIVITY, AND THE MATTER IS NOT INVESTMENT-RELATED.