Thanks for admitting EXPL could issue divvy’s.
3. In June 2000, Old Dominion agreed to sell stock in a private placement offering conducted by Investment Recovery Network, Inc., a Tampa, Florida company controlled by Magnan. At the time, Kennedy was aware that the Commission had barred Magnan from association with any broker or dealer.
4. Between June 2000 and December 2000, Old Dominion, aided and abetted
and caused by Kennedy, unlawfully permitted Magnan to become associated with the firm in violation of the Commission's 1995 Order. During that time period, Kennedy operated Old Dominion's Tampa office from Investment Recovery's headquarters and met with Magnan daily to discuss the Investment Recovery offering. Further, Magnan paid all of Old Dominion's expenses related to the Investment Recovery offering, including rent and secretarial services, and referred potential investors to Kennedy. With Kennedy's knowledge, Magnan also conducted a one to three hour sales presentation to potential investors, effectively making the sale of Investment Recovery stock to these investors.
5. As a result of the conduct described above, Kennedy willfully aided and abetted and caused Old Dominion's violation of Section 15(b)(6)(
(ii) of the Exchange Act, which prohibits a broker or dealer to permit a person barred by the Commission to become or remain associated with the broker or dealer without the consent of the Commission.
https://www.sec.gov/litigation/admin/34-47403.htm
3. In June 2000, Old Dominion agreed to sell stock in a private placement offering conducted by Investment Recovery Network, Inc., a Tampa, Florida company controlled by Magnan. At the time, Kennedy was aware that the Commission had barred Magnan from association with any broker or dealer.
4. Between June 2000 and December 2000, Old Dominion, aided and abetted
and caused by Kennedy, unlawfully permitted Magnan to become associated with the firm in violation of the Commission's 1995 Order. During that time period, Kennedy operated Old Dominion's Tampa office from Investment Recovery's headquarters and met with Magnan daily to discuss the Investment Recovery offering. Further, Magnan paid all of Old Dominion's expenses related to the Investment Recovery offering, including rent and secretarial services, and referred potential investors to Kennedy. With Kennedy's knowledge, Magnan also conducted a one to three hour sales presentation to potential investors, effectively making the sale of Investment Recovery stock to these investors.
5. As a result of the conduct described above, Kennedy willfully aided and abetted and caused Old Dominion's violation of Section 15(b)(6)(
(ii) of the Exchange Act, which prohibits a broker or dealer to permit a person barred by the Commission to become or remain associated with the broker or dealer without the consent of the Commission. https://www.sec.gov/litigation/admin/34-47403.htm
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