White WHEREFORE, the Commission respectfully re

White

WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
I.
Permanently enjoining White and his agents, servants, employees, and attorneys, and all
persons in active concert or participation with any of them, from future violations of Securities Act
Section 17(a) [15 U.S.C. § 77q(a)], Exchange Act Sections 9(a) and 10(b) [15 U.S.C. §§ 78i(a) and
78j(b)], and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-5];
II.
Ordering White to disgorge all ill-gotten gains he received directly or indirectly, with
prejudgment interest thereon, as a result of the alleged violations;
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III.
Ordering White to pay civil money penalties under Securities Act Section 20(d) [15 U.S.C.
§ 78t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)];
IV.
Permanently prohibiting White 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
Securities Act Section 20(e) [15 U.S.C. § 78t(e)] and Exchange Act Section 21(d)(2) [15 U.S.C.
§ 78u(d)(2)];
V.
Permanently prohibiting White 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
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