Come on now, it's in black and white
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)(I) of the
Securities Act and Section lO(b) and Rule lOb-5(a) and (c) of the Exchange Act, as
indicated above.
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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. § 78( d)(3).
V.
Penny Stock Bar
Issue an Order barring Cotton from participating in any offering of 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.
VII.
Retention of Jurisdiction
Further, the Commission respectfully requests that the Court retain jurisdiction
over this action in order to implement and carry out the tenns of all orders and decrees
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that it may enter, or to entertain any suitable application or motion by the Commission for
additional relief within the jurisdiction of this Court.
