Monday, October 18, 2021 4:23:22 PM
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
I.
Permanently enjoining Nutra Pharma and its agents, servants, employees and attorneys and
all persons in active concert or participation with any of them from violating, directly or indirectly,
Securities Act Sections 5(a) and (c) and 17(a)(2) [15 U.S.C. §§ 77e(a), 77e(c), and 77q(a)(2)],
Exchange Act Sections 10(b) and 13(a) [15 U.S.C. §§ 78j(b) and 78m(a)], and Rules 10b-5(b), 13a-11
and 13a-13 thereunder [17 C.F.R. §§ 240.10b-5(b), 240.13a-11, and 240.13a-13].
II.
Permanently enjoining Deitsch and his agents, servants, employees and attorneys and all persons in active concert or participation with any of them from violating, directly or indirectly,
Securities Act Sections 5(a) and (c) and 17(a)(2) [15 U.S.C. §§ 77e(a), 77e(c), and 77q(a)(2)],
Exchange Act Sections 9(a)(2), 10(b), 13(a), 13(d), and 16(a) [15 U.S.C. §§ 78i(a)(2), 78j(b), 78m(a),
78m(d), and 78p(a)], and Rules 10b-5, 13a-14, 13d-2, and 16a-3 thereunder [17 C.F.R. §§ 240.10b-5,
240.13a-14, 240.13d-2, and 240.16a-3] and from aiding and abetting violations of Rules 13a-11 and
13a-13 thereunder [17 C.F.R. §§ 240.13a-11, and 240.13a-13];
III.
Permanently enjoining McManus and his agents, servants, employees and attorneys and all
persons in active concert or participation with any of them from violating, directly or indirectly,
Securities Act Section 17(a)(2) [15 U.S.C. § 77q(a)(2)], Exchange Act Sections 10(b) and 15(a)
[15 U.S.C. §§ 78j(b) and 78o(a)], and Rule 10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)]; IV.
Ordering Defendants to disgorge all ill-gotten gains they received directly or indirectly, with
pre-judgment interest thereon, as a result of the alleged violations;
V.
Ordering Defendants to pay civil monetary penalties under Securities Act Section 20(d)
[15 U.S.C. § 77t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)];
VI.
Permanently prohibiting Deitsch from serving as an officer or director of any company that
has a class of securities registered under Exchange Act Section 12 [15 U.S.C. § 78l] or that is
required to file reports under Exchange Act Section 15(d) [15 U.S.C. § 78o(d)], pursuant to
Securities Act Section 20(e) [15 U.S.C. § 77t(e)] and Exchange Act Section 21(d)(2) [15 U.S.C.
§ 78u(d)(2)];
VII.
Permanently prohibiting Deitsch and McManus from participating in any offering of a penny stock, including engaging in activities with a broker, dealer, or issuer for purposes of issuing, trading,
or inducing or attempting to induce the purchase or sale of any penny stock, under Exchange Act
Section 21(d)(6) [15 U.S.C. § 78u(d)(6)]; and
VIII.
Granting any other and further relief this Court may deem just and proper.
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