Wednesday, July 13, 2011 11:53:20 PM
Fraud In Violation of Section 17(a)(1) of the Securities Act
COUNT I
27. The Commission realleges and incorporates paragraphs 1 through 26 of
this Complaint.
28. From May 2009 through and including June 2009, the Defendants, directly
and indirectly, by use of the means or instruments of transportation or communication in
interstate commerce and by use of the mails, in the offer or sale of securities, as described
in this Complaint, knowingly, willfully or recklessly employed devices, schemes or
artifices to defraud.
Fraud in Violation of Sections 17(a)(2) and 17(a)(3) of the Securities Act
COUNT II
30. The Commission realleges and incorporates paragraphs 1 through 26 of
this Complaint.
31. From May 2009 through and including June 2009, the Defendants, directly
and indirectly, by use of the means or instruments of transportation or communication in
interstate commerce and by the use of the mails, in the offer or sale of securities, as
described in this Complaint:
COUNT III
Fraud in Violation of Section 10(b) and Rule 10b-5 of the Exchange Act
33. The Commission realleges and incorporates paragraphs 1 through 26 of
this Complaint.
34. From May 2009 through and including June 2009, the Defendants, directly
and indirectly, by use of any means or instrumentality of interstate commerce, or of the
mails, in connection with the purchase or sale of securities, knowingly, willfully or
recklessly:
-9-
RELIEF REQUESTED
WHEREFORE, the Commission respectfully requests that the Court:
I.
Declaratory Relief
Declare, determine, and find that the Defendants have committed the violations of
the federal securities laws alleged in this Complaint.
II.
Permanent Injunctive Relief
Issue a Permanent Injunction restraining and enjoining the Defendants, their
officers, agents, servants, employees, attorneys, and all persons in active concert or
participation with them, and each of them, from violating Section 17(a) of the Securities
Act and Section 10(b) and Rule 10b-5 of the Exchange Act, as indicated above.
III.
Disgorgement
Issue an Order directing all Defendants to disgorge all ill-gotten gains, including
prejudgment interest, resulting from the acts or courses of conduct alleged in this
Complaint.
IV.
Penalties
Issue an Order directing the Defendants to pay civil money penalties pursuant to
Section 20(d) of the Securities Act, 15 U.S.C. § 77t(d), and Section 21(d) of the
Exchange Act, 15 U.S.C. § 78u(d).
V.
Penny Stock Bar
Issue an Order barring Schroepfer and Fuentes 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
Section 21(d) of the Exchange Act, 15 U.S.C. § 78u(d), for the violations alleged in this
Complaint.
VI.
Further Relief
Grant such other and further relief as may be necessary and appropriate. ----------------------------------------------------------------------------------------------
Lesson learned......never send a" kickback" through the mail. He would only be facing one count..
Slap on the wrist and TS goes away...
But methinks the story is just beginning......Tune in everyday to watch the story unravel.. I wish it was a just a hooker but on the Smokefree Shores of Sea Biss you never will know.......
The real fraud is what the DTCC does....
Cannabix Technologies and Omega Laboratories Inc. Provide Positive Developments on Marijuana Breathalyzer Testing • BLO • Jul 11, 2024 8:21 AM
ECGI Holdings Enhances Board with Artificial Intelligence (AI) Expert Ahead of Allon Apparel Launch • ECGI • Jul 10, 2024 8:30 AM
Avant Technologies to Meet Unmet Needs in AI Industry While Addressing Sustainability Concerns • AVAI • Jul 10, 2024 8:00 AM
Panther Minerals Inc. Launches Investor Connect AI Chatbot for Enhanced Investor Engagement and Lead Generation • PURR • Jul 9, 2024 9:00 AM
Glidelogic Corp. Becomes TikTok Shop Partner, Opening a New Chapter in E-commerce Services • GDLG • Jul 5, 2024 7:09 AM
Freedom Holdings Corporate Update; Announces Management Has Signed Letter of Intent • FHLD • Jul 3, 2024 9:00 AM