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Jetmek_03052

03/08/23 3:35 PM

#290225 RE: Gotham Bay Group #290217

I disagree.

The REASON that most of the decisions by the board align with the ALJ is because in the overwhelming amount of cases, ALJ decisions align with Enforcement’s recommendations.

This case differs because the ALJ screwed up.

First, she went against the precedent established by the overwhelming number of cases she herself ruled in previously.

Second, she called the respondent compliant in filing, even though there is a substantial and reasonable doubt that Corp Fin’s feels the same way.

Thirdly, she did not follow the regulations regarding the sanctioning of delinquent filers, after agreeing (in writing, right there in her ID) with Enforcement that DBMM was guilty of breaking the filing statutes.
Bearish
Bearish