12 Retech Corp (fka RETC)

[mtlebomac]

Case Updated: Thanks SHEEPWOLF for posting on Twitter

https://drive.google.com/file/d/1ThGaw6FrA8wrByKYZc4qMSkKDVSuTm_i/view

Case 1:18-cv-12058-RGS Document 54 Filed 11/15/18

PRAYER FOR RELIEF

WHEREFORE, the Commission respectfully requests that this Court:

A. Temporarily, preliminarily, and permanently restrain Knox and Wintercap SA,
their officers, agents, servants, employees and attorneys, and those persons in active concert or
participation with them who receive actual notice of the injunction by personal service or
otherwise, and each of them, from violating Sections 5(a), 5(c), and 17(a) of the Securities Act
[15 U.S.C. §§ 77e(a), (c), and 77q], and Sections 10(b) and 15(a) of the Exchange Act [15 U.S.C.
§ 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. 240.10b-5].

B. Temporarily, preliminarily, permanently restrain the Defendants, their officers,
agents, servants, employees and attorneys, and those persons in active concert or participation
with them who receive actual notice of the injunction by personal service or otherwise, and each
of them, from violating Section 15(b) of the Securities Act [15 U.S.C. § 77o(b)] and Section
20(e) of the Exchange Act [15 U.S.C. § 78t(e)].

C. Order the Defendants to disgorge, with prejudgment interest, all ill-gotten gains
obtained by reason of the unlawful conduct alleged in this Complaint, and order the Relief
Defendants to disgorge, with prejudgment interest, all ill-gotten gains obtained by reason of the
unlawful conduct alleged in this Complaint;

D. Order the Defendants to pay civil monetary penalties pursuant to Section 20(d) of
the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C.§ 78u(d)(3)];

E. Enter an order barring the Knox and Wintercap SA from participating in any
offering of a penny stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)]
and/or 21(d) of the Exchange Act [15 U.S.C. § 78u(d)];

F. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and

G. Grant such other and further relief as this Court may deem just and proper.

JURY DEMAND

The Commission demands a jury in this matter for all claims so triable.

DATED: November 15, 2018.