"Part 15" of 8k
3].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court issue
Orders:
I.
Permanently enjoining all defendants, and each of them, and their
officers, agents, servants, employees, attorneys, and those persons in active
concert or participation with them who receive actual notice by personal
service or otherwise, from violating, directly or indirectly, Sections 5(a) and
5(c) of the Securities Act of 1933 [15 U.S.C. Sections 77e(a) and 77e(c)].
II.
Permanently enjoining defendants Huttoe, Huttoe & Assoc., National
Trading Services, Word Corp., SGA Goldstar, Melcher, Terry, Alpha Securities,
Dunbar Holdings, and SOE, and each of them, and their officers, agents,
servants, employees, attorneys, and those persons in active concert or
participation with them who receive actual notice by personal service or
otherwise, from violating, directly or indirectly, Section 17(a) of the
Securities Act [15 U.S.C. Section 77q(a)], Section 10(b) of the Exchange Act
[15 U.S.C. Section 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. Section
240.10b-5].
III.
Permanently enjoining defendants SGA Goldstar, Melcher, Terry, Alpha
Securities, and Dunbar Holdings, and each of them, and their officers, agents,
servants,
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employees, attorneys, and those persons in active concert or participation with
them who receive actual notice by personal service or otherwise, from
violating, directly or indirectly, Section 17(b) of the Securities Act [15
U.S.C. Section 77q(b)].
IV.
Permanently enjoining defendant SOE and its officers, agents,
servants, employees, attorneys, and those persons in active concert or
participation with it who receive actual notice by personal service or
otherwise, from violating, directly or indirectly, Sections 13(a), 13(b)(2)(A),
and 13(b)(2)(B) of the Exchange Act [15 U.S.C. Sections 78m(a), 78m(b)(2)(A),
78m(b)(2)(B)], and Rules 12b-20, 13a-1, 13a-11, and 13a-13, thereunder [17
C.F.R. Sections 240.12b-20, 240.13a-1, 240.13a-11, and 240.13a-13].
V.
Permanently enjoining defendant Huttoe and his agents, servants,
employees, attorneys, and those persons in active concert or participation with
it who receive actual notice by personal service or otherwise, from violating,
directly or indirectly, Sections 13(b)(5) and 16(a) of the Exchange Act [15
U.S.C. Sections 78m(b)(5) and 78p(a)], and Rules 13b2-1, 13b2-2, 16a-2 and
16a-3, thereunder [17 C.F.R. Sections 240.13b2-1, 240.13b2-2, 240.16a-2 and
240.16a-3].
VI.
Directing all defendants, other than SOE, and each of them, and their
officers, agents, servants, employees, and attorneys, to disgorge all illegal
gains, together with prejudgment interest. |
