The Securities and Exchange Commission

[Stock]

34-55510 Mar. 22, 2007 Paul E. Johnson

UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 55510 / March 22, 2007
ADMINISTRATIVE PROCEEDING
File No. 3-12392
In the Matter of
Paul E. Johnson,
Respondent.
ORDER MAKING FINDINGS AND
IMPOSING REMEDIAL SANCTIONS
PURSUANT TO SECTION 15(b)(6) OF
THE SECURITES EXCHANGE ACT OF
1934
I.
On August 11, 2006, the Securities and Exchange Commission (“Commission”) instituted
public administrative proceedings pursuant to Section 15(b) of the Securities Exchange Act of
1934 (“Exchange Act”) against Paul E. Johnson (“Johnson” or the “Respondent”).
II.
Respondent has submitted an Offer of Settlement (the “Offer”) which the Commission has
determined to accept. Solely for the purpose of these proceedings and any other proceedings
brought by or on behalf of the Commission, or to which the Commission is a party, Respondent
consents to the Commission’s jurisdiction over him and over the subject matter of these
proceedings, and further consents to the entry of this Order Making Findings and Imposing
Remedial Sanctions Pursuant to Section 15(b) of the Securities Exchange Act of 1934 (the
“Order”), as set forth below.
III.
On the basis of this Order and Respondent’s Offer, the Commission finds that:
1. Respondent, age 46, resides in New York, New York. From 1994 until June 2002,
Respondent was a managing director and senior equity analyst at Robertson Stephens, Inc. (“RSI”),
a broker-dealer registered with the Commission pursuant to Section 15(b) of the Exchange Act.
2. On July 24, 2006, a final judgment was entered against Respondent in the civil
action entitled Securities and Exchange Commission v. Paul E. Johnson, Civil Action Number 03-
0177, by the United States District Court for the Southern District of New York, enjoining him for
a period of five years from future violations of Section 17(a) of the Securities Act of 1933, Section
10(b) of the Exchange Act and Rule 10b-5 thereunder.
3. The Commission’s Complaint alleged that, in 1999, 2000, and 2001, Respondent
failed to properly disclose his financial interest in three companies that he covered as a research
analyst.
IV.
In view of the foregoing, the Commission deems it appropriate and in the public interest to
impose the sanctions agreed to in Respondent’s Offer.
Accordingly, it is hereby ORDERED:
Pursuant to Section 15(b)(6) of the Exchange Act, that Respondent be, and hereby is barred
from association with any broker or dealer with the right to reapply for association after five (5)
years to the appropriate self-regulatory organization, or if there is none, to the Commission.
Any reapplication for association by the Respondent will be subject to the applicable laws
and regulations governing the reentry process, and reentry may be conditioned upon a number of
factors, including, but not limited to, the satisfaction of any or all of the following: (a) the
disgorgement ordered against the Respondent in the Amended Final Judgment, in the civil action
entitled Securities and Exchange Commission v. Paul E. Johnson, Civil Action Number 03-0177,
by the United States District Court for the Southern District of New York; (b) any arbitration
award related to the conduct that served as the basis for the Commission order; (c) any selfregulatory
organization arbitration award to a customer, whether or not related to the conduct that
served as the basis for the Commission order; and (d) any restitution order by a self-regulatory
organization, whether or not related to the conduct that served as the basis for the Commission
order.
By the Commission.
Nancy M. Morris
Secretary

http://www.sec.gov/litigation/admin/2007/34-55510.pdf