Starkweather. WHEREFORE, the Commission respect

Starkweather.

WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
I.
Permanently enjoining Defendants and their agents, servants, employees, and attorneys, and
all persons in active concert or participation with any of them from violating, directly or indirectly,
Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5];
II.
Ordering Starkweather to disgorge all ill-gotten gains he received directly or indirectly, with
prejudgment interest thereon, as a result of his alleged violations;
III.
Ordering Defendants to pay civil money penalties under Exchange Act Section 21(d)(3)
[15 U.S.C. § 78u(d)(3)];
IV.
Permanently prohibiting Starkweather from serving as an officer or director of any company
that has a class of securities registered under Exchange Act Section 12 [15 U.S.C. § 78l] or that is
required to file reports under Exchange Act Section 15(d) [15 U.S.C. § 78o(d)], pursuant to
Exchange Act Section 21(d)(2) [15 U.S.C. § 78u(d)(2)];
Case 1:19-cv-05528 Document 1 Filed 09/30/19 Page 12 of 13 PageID #: 12
v.
Permanently prohibiting Starkweather from participating in any offering of a penny stock,
including engaging in activities with a broker, dealer, or issuer for purposes of issuing, trading, or
inducing or attempting to induce the purchase or sale of any penny stock, under Exchange Act
Section 21(d) (6) [15 U.S.C. ~ 78u(d) (6)]; and
VI.
Granting any other and further relief this Court may deem just and proper.
https://www.sec.gov/litigation/complaints/201...eather.pdf