SEC v. Hunter Haithcock, No. 1:24-cv-02585-JRR, District of Maryland (Sept. 9, 2024) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MARYLAND

SECURITIES AND EXCHANGE
COMMISSION,
1617 JFK Boulevard, Suite 520
Philadelphia, PA 19103,

Plaintiff,

v.

HUNTER HAITHCOCK
a/k/a Hunter Elliot and Hunter
   Allen Haithcock,
2810 Selwyn Avenue, Unit 321
Charlotte, NC 28209,

Defendant.

             Civil Action No. 1:24-cv-2585

            JURY TRIAL DEMANDED

COMPLAINT
Plaintiff Securities and Exchange Commission (the “Commission”) files this
Complaint against defendant Hunter Haithcock, a/k/a Hunter Elliott and Hunter Allen
Haithcock (“Haithcock”), and alleges as follows:
SUMMARY
1. Beginning in September 2019 and through at least November 2022, Haithcock,
while acting as an unregistered investment adviser, fraudulently induced at least 50 individuals
into investing over $520,000 with him by posing as a licensed securities professional associated
with a registered broker-dealer and investment adviser.  He promised that clients’ investment
principal was guaranteed and offered exorbitant returns on their investments.

2

2. Haithcock fraudulently induced clients to invest in his scheme by feigning
professional credentials, fabricating account opening documents, and opening personal accounts
with the company through which he claimed to have an affiliation.
3. To attract clients, he relied on word-of-mouth referrals, meeting and pitching
prospective clients in-person or by text.
4. In reality, Haithcock -- who has never held any securities license and or been
associated with any broker-dealer, investment adviser or other entity registered with the
Commission -- never traded any securities on behalf of the clients who invested funds with him.
5. Instead, Haithcock deposited the funds into his personal accounts and then
fraudulently used the money with which he was entrusted for his own benefit, such as for credit
card payments, food and other personal expenses.
6. Haithcock also furthered and concealed his fraudulent scheme by making false
representations to his clients about his trading activity and their investment returns and by
providing clients with falsified account statements showing fictitious investment activity and
account performance.
7. From time to time, in a Ponzi-like fashion, Haithcock also used new client funds
to repay prior clients, making himself seem successful.
8. Later in the scheme, Haithcock transferred client funds to his personal brokerage
accounts, which he used to engage in largely unsuccessful day trading for himself.
9. Ultimately, Haithcock violated the securities laws by fraudulently obtaining over
$520,000 in funds from at least 50 clients, most of whom sustained significant losses, as detailed
further below.

3

10. By engaging in the conduct alleged, Haithcock violated and, unless restrained and
enjoined, will continue to violate, Section 17(a) of the Securities Act of 1933 (the “Securities
Act”), Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) and Rule 10b-
5 thereunder, and Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 (“Advisers
Act”).
11. Based on these violations, the Commission seeks: (a) permanent injunctions; (b)
disgorgement of Haithcock’s ill-gotten gains, plus prejudgment interest; (c) civil penalties due to
the egregious nature of Haithcock’s violations; and (d) such other and further relief as the Court
deems just and proper.
JURISDICTION AND VENUE
12. The Commission brings this action pursuant to the enforcement authority
conferred upon it by Sections 20(b) and 20(d) of the Securities Act [15 U.S.C. § § 77t(b) and
77t(d)], Sections 21(d) and 21(e) of the Exchange Act [15 U.S.C. § § 78u(d) and 78u(e)], and
Section 209(d) of the Advisers Act [15. U.S.C. §80b-9(d)].
13. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), and
22(a) of the Securities Act [15 U.S.C. § §  77t(b), 77t(d), and 77v(a)], Sections 21(d), 21(e), and
27(a) of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78aa(a)], and Sections 209(d), 209(e),
and 214 of the Advisers Act [15 U.S.C. §§ 80b-9(d), 80b-9(e), 80b-14].  Haithcock has, directly
or indirectly, made use of the means and instrumentalities of interstate commerce, of the mails,
or of facilities of a national securities exchange in connection with the acts, practices, and course
of business alleged in this Complaint.
14. Venue lies in this District pursuant to Section 22(a) of the Securities Act [15
U.S.C. § 77v(a)], Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)], and Section 214 of

4

the Advisers Act [15 U.S.C. § 80b-14].  Among other things, certain of the acts, practices, and
courses of business constituting the violations of the federal securities laws alleged herein
occurred within Maryland, including that Haithcock resided within the District during the
relevant time period and made misrepresentations to clients residing within this District.
DEFENDANT
15. Hunter Haithcock, age 23, is a former resident of Aberdeen, Maryland and
currently resides in Charlotte, North Carolina.  Despite holding himself out as an investment
adviser and/or “broker,” Haithcock has never held a securities license or been associated with
any entity registered with the Commission.
FACTS
A. Haithcock Pretends To Be A Successful Investment Adviser And Broker
And Falsifies Bank Account Documentation In Furtherance Of His Scheme

16. Beginning in September of 2019, Haithcock solicited those in his social circle,
including friends, coworkers, and churchgoers, to invest money with him by falsely claiming to
be a registered investment professional with or otherwise have an affiliation with Company A, a
well-known registered brokerage firm.
17. Specifically, Haithcock solicited investments by falsely holding himself out as a
licensed securities professional with a “CFA” [Chartered Financial Analyst] credential affiliated
with Company A.  He also claimed to be working under another individual, “Individual A.”
Individual A is an actual registered representative, formerly employed by Company A in
Chicago, Illinois, from February 2020 to October 2021.
18. For instance, in February 2021, Haithcock texted a prospective client, “I’m a full
time day trader and client investment adviser with [Company A] Series 63/SIE under Adviser
[Individual A] CRD#[redacted].”

5

19. In November 2021, Haithcock texted another prospective client, “I’m a [Company
A] Client investment advisor under my Brokerage Advisor [Individual A] CRC[sic]#[redacted],
are you familiar with [Company A].”
20. Haithcock was never affiliated with or employed by Company A.
21. Haithcock has never taken a securities license exam or been associated with any
broker-dealer or investment adviser.
22. Individual A does not know Haithcock nor did that individual ever work with
Haithcock at Company A.
23. After making the fraudulent representations, Haithcock provided prospective
clients with a falsified Company A Client Agreement form to create the illusion that he was
associated with Company A with the ability to buy and sell stocks for a fee for clients.
24. On information and belief, Haithcock downloaded an actual Company A Client
Agreement, available on Company A’s website, altering parts of it, and passing it off as a
legitimate agreement.
25. Haithcock altered the name of the document from “Client Agreement” to “Client
Broker Agreement” (the “Client Broker Agreement”) and inserted one of his aliases, Hunter
Elliott, and his home address of Aberdeen, Maryland on the top of the form.
26. Below this, Haithcock inserted a client signature line and broker signature
line.  He signed his name as “Hunter Elliott” and typed “HUNTER ELLIOTT ‘Company
A  Broker’”  below  his  signature.    At  the  bottom  of  the  page,  Haithcock  inserted  the
following language in bold:
THIS  AGREEMENT  IS  A  CONFIRMATION  TO  INVEST  UNDER  BROKER
‘Hunter  Elliott’  YOU  WILL  RECEIVE  A  [Company  A]  RECEIPT  OF  THE
FUNDS YOU INVEST WITH [Company A] BROKER ‘Hunter Elliott.’

6

27. For most of his clients, Haithcock provided the Client Broker Agreements to
clients via email and asked each client to, “review, sign, and complete this document.”
28. For some clients, Haithcock modified an actual form Company A Deposit Slip
(non-IRAs) (“the Deposit Slip”) downloaded from Company A’s website with the client’s name,
amount of investment, a false account number, and the ticker symbols of the securities he
claimed he would purchase.
29. Haithcock then emailed the fraudulent Deposit Slip to the client for an electronic
signature.
30. Then Haithcock provided the client with wire instructions that included account
and routing numbers as well as the direction to include references in the memo line to accounts
that ultimately belonged to Haithcock.
31. Haithcock’s use of falsified account documentation in the name of Company A
fraudulently induced his clients to invest funds with him under the impression that they were
opening a brokerage or investment account with Company A.
B. Haithcock Makes False Statements About The Safety Of The
Funds Invested And Boasts About The Expected Returns To Clients

32. As Haithcock lured potential clients, he falsely made misrepresentations that he
guaranteed investors their principal investment and was engaging in highly profitable trading
activity on their behalf that would result in exorbitant profits generated over the lifetime of the
investment.
33. Generally, Haithcock requested that clients make a minimum investment of
$5,000 and keep their money with him for at least 1 to 5 years (the “required time period”).

7

34. Haithcock also encouraged clients to contribute above this $5,000 minimum in
their initial investment by highlighting his purported “no loss guarantee” by which he assured
clients that he would return their initial investment regardless of amount and market
performance.
35. Haithcock made these promises orally, in text messages and in the falsified Client
Broker Agreement, while encouraging his victims to give him as much money up front as they
could.  To emphasize this misrepresentation, he inserted the following language in bold at the
end of the sham Client Broker Agreement:
DISCLOSURE: *THIS AGREEMENT IS A NO LOSS GUARANTEE. MEANING THE
INITIAL INVESTMENT IS SECURED AND AT ANY TIME THE MARKET HAS A
CRASH THERE IS NO LOSS TO YOU.*

36. Haithcock told clients that, provided they kept their funds with him for the
required time period, they would only incur capital gains and loss taxes, Company A fees, and an
8% “brokerage fee” on the total account value that would only be payable upon withdrawal.
37. To entice clients to invest funds and to inspire confidence in his investment
strategies, he often texted fictitious and exorbitant return projections of his purported future
trades.
38. One such text Haithcock sent a prospective client in November 2021 read:
AVERAGE YEARLY EXPECTED RETURN:
2:1 – 0.5 RISK LEVEL (MEDIUM:HIGH) NO REINVESTMENTS/RELINQUISHED
EQUITY
***No including Compound gains and tax appropriations****

$5,000 INVESMENT
YEAR 1
$9,700
YEAR 2
$16,562
YEAR 3
$31,147

8

YEAR 4
$57,311
YEAR 5
$71,804

39. As word of Haithcock’s investment opportunity spread through the family and
friends of his clients, more and more clients invested with Haithcock.
C. Haithcock Opens Personal Accounts To   Deposit Client Funds And
Misleads Investors Into Believing Funds Are Deposited On Their Behalf

40. At the outset of Haithcock’s scheme, he deposited client funds in a personal
savings account he opened in his own name on July 1, 2019, with Company B.  Haithcock
transferred client funds from his savings account with Company B to a checking account he
opened in his own name on July 25, 2019, with Company C, an entity with an ownership interest
in Company A.
41. In furtherance of his fraudulent scheme, on February 24, 2020, Haithcock then
opened two personal accounts with Company C in the name of Hunter Allen Haithcock using his
address in Aberdeen, Maryland.
42. Haithcock used his personal accounts with Company B and Company C to receive
wire transfers directly from his clients.
43. For example, Client 1 was introduced to Haithcock through an employer who
previously invested money with Haithcock and claimed to have made a profit.
44. Haithcock sent Client 1 a falsified Client Broker Agreement, as detailed above,
purporting to be a “broker” with Company A.
45. After executing the Client Broker Agreement that Haithcock falsified, Client 1
wrote a check to Haithcock for a $5,000 investment, which was dated December 29, 2020.
Haithcock deposited it in his personal account with Company B.

9

46. Haithcock also sent a fabricated Client Broker Agreement to Client 2, who was
introduced to Haithcock through family members who knew Haithcock.  Client 2 signed the
Client Broker Agreement in February 2021.
47. On or about February 2021, Client 2 initially invested $50,000 via wire transfer to
Haithcock, which he deposited in his personal account with Company C that Client 2 believed to
be an investment account opened by Haithcock on Client 2’s behalf.   Haithcock provided the
client with wire instructions and the direction: “[P]LEASE ADD PORT MEMO VERY
IMPORTANT! (XXXXXXXXXXX SIE)”.
48. Unbeknownst to Client 2, the wire instructions and memo line directed all funds
to Haithcock’s personal account with Company C.
49. In November 2021, Haithcock texted Client 3, who was introduced to Haithcock
through another of Haithcock’s clients, that $5,000 was his current minimum investment.
Haithcock stated that he preferred investments to be long term and kept up to 5 years.  Haithcock
falsely advised Client 3 that he could expect a 40-140% return on his investment in one year.
Client 3 then invested $5,000 on or about November 23, 2021 with Haithcock, which Haithcock
also deposited into his personal account with Company C.
50. Haithcock advised Client 3 that he would do an internal transfer from Haithcock’s
Company C account to an account he would open with Company C on behalf of Client 3.  That
never occurred.
51. In total, at Haithcock’s direction, the defrauded investors sent over $308,000 to
Haithcock’s two personal accounts with Company C, and over $164,000 to Haithcock’s personal
savings account with Company B.  Clients also gave Haithcock funds in cash and through
electronic payments, such as Venmo, Zelle and CashApp, for the purpose of investment.

10

D. Haithcock Makes False Representations About The Status Of The Investments
52. Haithcock lulled his clients and induced them to invest even more funds by
creating false account statements that showed profitable trading and concealed his
misappropriation of funds.
53. On a periodic basis, Haithcock also emailed or texted clients a “Statement
Report” or a “Summary Report” with their purported balance, a summary of supposed recent
investment activity, and a summary of market conditions.  These reports were signed “Hunter
Elliott, IA Investment Strategist,” “Hunter Elliott, CFA Investment Advisor,” or “Hunter.”  None
of the purported trading activity had occurred.
54. For instance, Haithcock texted Client 1 falsified information about the returns on
Client 1’s investment throughout 2021.  Believing the investment was profitable and the
principal was secure, Client 1 then invested over $14,000 in additional money with Haithcock,
through cash and via Venmo, including transfers directly to Haithcock’s Venmo account on
January 20, 2021, April 23, 2021, October 7, 2021, and April 7, 2022.
55. As another example, on October 9, 2021, Haithcock emailed Client 2 a
“Statement Report” purporting to show over $80,000 in funds available – a $30,000 gain from
his $50,000 initial investment.  This was false.  There had been no trading and no gains.
Believing Haithcock’s representation that he was earning significant returns, Client 2 invested an
additional $40,000 in July 2021 and an additional $20,000 in February 2022, for a total
investment of $110,000 that was transferred to Haithcock’s personal account with Company C.
56. Similarly, on February 8, 2022, Client 3, who as noted above previously invested
$5,000 with Haithcock, received an email from Haithcock, which was titled “Statement Report:
1/21/22 – 2/2/22” and purported to show a balance of $7,984.58 based on supposed trading

11

profits.  But Haithcock made no investments of any kind on Client C’s behalf and earned no
profits.  The Statement Report was a complete fabrication.  The Statement Report was signed by
“Hunter Elliott, CFA, Investment Advisor.”  He also advised that going forward reports would be
sent on a biweekly basis.
57. Client 3’s report showed that 10% of the funds were invested in a money market
account and 90% of their funds were invested in options.  The report also claimed that the
month’s most profitable trades were in the following stocks (identified by ticker symbol): TSLA,
SPY, AMD, NVDA and MRNA.
58. Given the purportedly rapid growth shown in that report generated by Haithcock,
as well as in a Statement Report, dated April 29, 2022, which reflects a balance of $9,367.95,
signed by “Hunter Elliott, IA, Investment Strategist”, Client 3 liquidated his 401(k) account and
wired an additional $40,000 to Haithcock’s account with Company C in May 2022 and another
$5,000 to the same account in June 2022, for a total investment of $50,000.
59. These “Statement Reports” were entirely fictional, as Haithcock did not invest
any of the funds he received from Clients 1, 2 or 3 or from any other clients.  Instead, Haithcock
simply fabricated the return-on-investment information, including the Statement Reports and
Summary Reports that falsely showed investments and phenomenal returns.
E. Haithcock Misappropriates  The Funds Of His Purported Clients
60. Contrary to what Haithcock promised, he never deposited any of the funds with
which his purported clients entrusted him into an account with Company A to be used for the
benefit of clients or to purchase securities for their benefit.
61. Instead, Haithcock kept and/or directed all client funds to his personal accounts,
including bank accounts with Company B and Company C.

12

62. Haithcock made frequent transfers of the funds among his accounts to pay for
personal expenses, such as credit card payments, food purchases, and Zelle payments to himself.
63. At all times, Haithcock acted knowingly or recklessly in committing his fraud
through fabricated documents he created and false statements orally and in writing.  He also
knew, or was reckless in not knowing, that his false statements regarding his credentials, his
guarantees, and his supposed trading profits were material to his clients.
64. By holding himself as an investment adviser who actively managed investors’
money in return for a fee, Haithcock met the definition of an investment adviser under the
Advisers Act.   Thus, Haithcock owed his clients fiduciary duties.
65. Haithcock breached his fiduciary duties to his clients through his fraudulent
scheme to misappropriate his clients’ money while lulling them with false performance
statements and attempting to induce further investment.
66. In furtherance of his scheme, Haithcock used a small portion of the client funds
he received to pay back some investors to support the illusion that he was generating trading
profits.  In particular, he made payments at the outset of the scheme, which appeared to bolster
the incredible opportunity he presented and increased the word-of-mouth referrals.  Between
August 2020 and May 2022, Haithcock made approximately $44,000 in Ponzi-like payments
using client funds.
67. As the scheme progressed, beginning in May of 2021, Haithcock began using his
clients’ funds to engage in day trading for his own benefit, which proved to be largely
unsuccessful.
68. On May 24, 2021, Haithcock opened a trading account in his own name with
Company D.  Haithcock then used this account primarily to engage in day trading.

13

69. Haithcock transferred client funds from his personal accounts with Company A
directly to his personal Company D trading account.
70. Between May 2021 and November 2022, Haithcock transferred over $70,000 of
client funds to his personal Company D trading account.
71. Haithcock subsequently lost over $55,000 of the client funds he traded on his own
behalf through Company D.
72. Toward the end of the scheme, some of Haithcock’s clients, including Client 1,
began asking for their funds, which he had guaranteed.  As Haithcock had already spent or lost
the funds of most of his clients, Haithcock then falsely communicated to his clients, including
Client 1, that he was in the process of returning the funds, continually providing false
justifications as to why this process was stalled.
73. Instead, Haithcock eventually left the District and ceased all communication with
his victims.
FIRST CLAIM FOR RELIEF
Violation of Section 17(a) of the Securities Act

74. The Commission repeats and realleges the preceding paragraphs of its Complaint
as if fully set forth herein.
75. By reason of the foregoing, Haithcock, directly or indirectly, by use of the means
or instruments of transportation or communication in interstate commerce or by the use of the
mails, in the offer or sale of securities has:
(a) Knowingly or recklessly employed one or more devices, schemes or
artifices to defraud;

14

(b) Knowingly, recklessly, or negligently obtained money or property by
means of one or more untrue statements of material fact or omitted to state
one or more material facts necessary in order to make the statements
made, in light of the circumstances under which they were made, not
misleading; and/or
(c) Knowingly, recklessly, or negligently engaged in one or more transactions,
practices or courses of business which operate or would operate as a fraud
or deceit upon a purchaser.
76. By reason of the conduct described above, Haithcock has violated and, unless
enjoined, will continue to violate Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].

SECOND CLAIM FOR RELIEF
Violations of Section 10(b) and Rule 10b-5 of the Exchange Act

77. The Commission repeats and realleges the preceding paragraphs of its Complaint
as if fully set forth herein.
78. By reason of the foregoing, Haithcock, directly or indirectly, acting intentionally,
knowingly or recklessly, in connection with the purchase or sale of securities, by the use of the
means or instrumentalities of interstate commerce or the facilities of a national securities
exchange or the mail has:
(a) employed one or more devices, schemes, or artifices to defraud;
(b) made one or more untrue statements of a material fact or has omitted to
state one or more material facts necessary in order to make the statements
made, in light of the circumstances under which they were made, not
misleading; and/or

15

(c) engaged in one or more acts, practices, or courses of business which
operated or would operate as a fraud or deceit upon other persons,
including purchasers and sellers of securities.
79. By engaging in the conduct described above, Haithcock has violated and, unless
enjoined will continue to violate Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and
Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
THIRD CLAIM FOR RELIEF
Violations of Sections 206(1) and 206(2) of the Advisers Act

80. The Commission repeats and realleges the preceding paragraphs of its Complaint
as if fully set forth herein.
81. At all relevant times, Haithcock was an “investment adviser” within the meaning
of Section 202(a)(11) of the Advisers Act [15 U.S.C. § 80b-2(a)(11)].
82. By reason of the foregoing, Haithcock directly or indirectly, and by use of the
means or instruments of transportation or communication in interstate commerce or by the use of
the mails, as an investment adviser: (1) knowingly or recklessly employed or is employing any
device, scheme, or artifice to defraud a client or prospective client; and (2) knowingly, recklessly,
or negligently engaged or is engaging in any transaction, practice, or course of business which
operates as a fraud or deceit upon a client or prospective client.
83. By engaging in the conduct described above, Haithcock violated and, unless
enjoined, will continue to violate Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C.  §§
80b-6(1), 80b-6(2)].

16

RELIEF REQUESTED
 WHEREFORE, the Commission respectfully requests that the Court find the Defendant
committed the violations alleged and enter a final judgment:
(i) permanently restraining and enjoining Haithcock, his officers, agents, servants,
employees, attorneys, and all persons in active concert or participation with him,
and each of them, from directly or indirectly violating the federal securities laws
alleged in this Complaint; and further permanently restraining and enjoining
Haithcock, his officers, agents, servants, employees, attorneys, and all persons in
active concert or participation with him, who receive actual notice of the Final
Judgment by personal service or otherwise, and each of them, from engaging in
transactions, acts, practices, and courses of business described herein, and from
engaging in conduct of similar purpose and object in violation of Section 17(a) of
the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of the Exchange Act [15
U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections
206(1) and 206(2) of the Advisers Act [15 U.S.C.  §§ 80b-6(1), 80b-6(2)];
(ii) ordering Haithcock to disgorge all ill-gotten gains he received directly or
indirectly, with prejudgment interest thereon, as a result of the alleged violations,
pursuant to Sections 21(d)(5) and (7) of the Exchange Act [15 U.S.C. §§ 78u(5)
and (7)];
(iii) ordering Haithcock to pay civil money penalties pursuant to Section 20(d) of the
Securities Act [15 U.S.C. § 77t(d)]; Section 21(d)(3)(A) of the Exchange Act [15
U.S.C. § 78u(d)(3)(A)], and Section 209(e) of the Advisers Act [15 U.S.C. 80b-
9(e)]; and
(iv) granting any other and further relief this Court may deem just and proper.

17

DEMAND FOR JURY TRIAL
Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, the Commission hereby
requests a trial by jury.
Dated:  September 6, 2024
Respectfully submitted,
SECURITIES AND
EXCHANGE COMMISSION
/s/ Gregory R. Bockin
Gregory R. Bockin (Bar No. 17993)
             Kara F. Sweet
Kingdon Kase
Paulina L. Jerez
Samantha K. Keleher
Philadelphia Regional Office
1617 JFK Boulevard, Suite 520
Philadelphia, PA 19103
215.597.3100
215.597.2740 (fax)
[email protected]

[email protected]

Counsel for Plaintiff Securities
and Exchange Commission

UNITED STATES DISTRICT COURT 
DISTRICT OF MARYLAND 

 
  

 
SECURITIES AND EXCHANGE 
COMMISSION, 
1617 JFK Boulevard, Suite 520  
Philadelphia, PA 19103, 
 

Plaintiff, 
 

v. 
 

HUNTER HAITHCOCK 
a/k/a Hunter Elliot and Hunter 
   Allen Haithcock, 
2810 Selwyn Avenue, Unit 321 
Charlotte, NC 28209, 
 

Defendant. 
 

 
 
 
 
 
             Civil Action No. 1:24-cv-2585 

 
 

 
 
            JURY TRIAL DEMANDED 
 
 

 

COMPLAINT 

Plaintiff Securities and Exchange Commission (the “Commission”) files this 

Complaint against defendant Hunter Haithcock, a/k/a Hunter Elliott and Hunter Allen 

Haithcock (“Haithcock”), and alleges as follows: 

SUMMARY 

1. Beginning in September 2019 and through at least November 2022, Haithcock, 

while acting as an unregistered investment adviser, fraudulently induced at least 50 individuals 

into investing over $520,000 with him by posing as a licensed securities professional associated 

with a registered broker-dealer and investment adviser.  He promised that clients’ investment 

principal was guaranteed and offered exorbitant returns on their investments.  

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 1 of 17



2 
 

2. Haithcock fraudulently induced clients to invest in his scheme by feigning 

professional credentials, fabricating account opening documents, and opening personal accounts 

with the company through which he claimed to have an affiliation.   

3. To attract clients, he relied on word-of-mouth referrals, meeting and pitching 

prospective clients in-person or by text.   

4. In reality, Haithcock -- who has never held any securities license and or been 

associated with any broker-dealer, investment adviser or other entity registered with the 

Commission -- never traded any securities on behalf of the clients who invested funds with him.   

5. Instead, Haithcock deposited the funds into his personal accounts and then 

fraudulently used the money with which he was entrusted for his own benefit, such as for credit 

card payments, food and other personal expenses.   

6. Haithcock also furthered and concealed his fraudulent scheme by making false 

representations to his clients about his trading activity and their investment returns and by 

providing clients with falsified account statements showing fictitious investment activity and 

account performance.   

7. From time to time, in a Ponzi-like fashion, Haithcock also used new client funds 

to repay prior clients, making himself seem successful.  

8. Later in the scheme, Haithcock transferred client funds to his personal brokerage 

accounts, which he used to engage in largely unsuccessful day trading for himself.   

9. Ultimately, Haithcock violated the securities laws by fraudulently obtaining over 

$520,000 in funds from at least 50 clients, most of whom sustained significant losses, as detailed 

further below. 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 2 of 17



3 
 

10. By engaging in the conduct alleged, Haithcock violated and, unless restrained and 

enjoined, will continue to violate, Section 17(a) of the Securities Act of 1933 (the “Securities 

Act”), Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) and Rule 10b-

5 thereunder, and Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 (“Advisers 

Act”).  

11. Based on these violations, the Commission seeks: (a) permanent injunctions; (b) 

disgorgement of Haithcock’s ill-gotten gains, plus prejudgment interest; (c) civil penalties due to 

the egregious nature of Haithcock’s violations; and (d) such other and further relief as the Court 

deems just and proper. 

JURISDICTION AND VENUE 

12. The Commission brings this action pursuant to the enforcement authority 

conferred upon it by Sections 20(b) and 20(d) of the Securities Act [15 U.S.C. § § 77t(b) and 

77t(d)], Sections 21(d) and 21(e) of the Exchange Act [15 U.S.C. § § 78u(d) and 78u(e)], and 

Section 209(d) of the Advisers Act [15. U.S.C. §80b-9(d)]. 

13. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), and 

22(a) of the Securities Act [15 U.S.C. § §  77t(b), 77t(d), and 77v(a)], Sections 21(d), 21(e), and 

27(a) of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78aa(a)], and Sections 209(d), 209(e), 

and 214 of the Advisers Act [15 U.S.C. §§ 80b-9(d), 80b-9(e), 80b-14].  Haithcock has, directly 

or indirectly, made use of the means and instrumentalities of interstate commerce, of the mails, 

or of facilities of a national securities exchange in connection with the acts, practices, and course 

of business alleged in this Complaint. 

14. Venue lies in this District pursuant to Section 22(a) of the Securities Act [15 

U.S.C. § 77v(a)], Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)], and Section 214 of 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 3 of 17



4 
 

the Advisers Act [15 U.S.C. § 80b-14].  Among other things, certain of the acts, practices, and 

courses of business constituting the violations of the federal securities laws alleged herein 

occurred within Maryland, including that Haithcock resided within the District during the 

relevant time period and made misrepresentations to clients residing within this District. 

DEFENDANT 

15. Hunter Haithcock, age 23, is a former resident of Aberdeen, Maryland and 

currently resides in Charlotte, North Carolina.  Despite holding himself out as an investment 

adviser and/or “broker,” Haithcock has never held a securities license or been associated with 

any entity registered with the Commission. 

FACTS 

A. Haithcock Pretends To Be A Successful Investment Adviser And Broker 
And Falsifies Bank Account Documentation In Furtherance Of His Scheme  
 

16. Beginning in September of 2019, Haithcock solicited those in his social circle, 

including friends, coworkers, and churchgoers, to invest money with him by falsely claiming to 

be a registered investment professional with or otherwise have an affiliation with Company A, a 

well-known registered brokerage firm. 

17. Specifically, Haithcock solicited investments by falsely holding himself out as a 

licensed securities professional with a “CFA” [Chartered Financial Analyst] credential affiliated 

with Company A.  He also claimed to be working under another individual, “Individual A.” 

Individual A is an actual registered representative, formerly employed by Company A in 

Chicago, Illinois, from February 2020 to October 2021.      

18. For instance, in February 2021, Haithcock texted a prospective client, “I’m a full 

time day trader and client investment adviser with [Company A] Series 63/SIE under Adviser 

[Individual A] CRD#[redacted].”   

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 4 of 17



5 
 

19. In November 2021, Haithcock texted another prospective client, “I’m a [Company 

A] Client investment advisor under my Brokerage Advisor [Individual A] CRC[sic]#[redacted], 

are you familiar with [Company A].”   

20. Haithcock was never affiliated with or employed by Company A. 

21. Haithcock has never taken a securities license exam or been associated with any 

broker-dealer or investment adviser.   

22. Individual A does not know Haithcock nor did that individual ever work with 

Haithcock at Company A.   

23. After making the fraudulent representations, Haithcock provided prospective 

clients with a falsified Company A Client Agreement form to create the illusion that he was 

associated with Company A with the ability to buy and sell stocks for a fee for clients.   

24. On information and belief, Haithcock downloaded an actual Company A Client 

Agreement, available on Company A’s website, altering parts of it, and passing it off as a 

legitimate agreement.   

25. Haithcock altered the name of the document from “Client Agreement” to “Client 

Broker Agreement” (the “Client Broker Agreement”) and inserted one of his aliases, Hunter 

Elliott, and his home address of Aberdeen, Maryland on the top of the form.   

26. Below this, Haithcock inserted a client signature line and broker signature 

line.  He signed his name as “Hunter Elliott” and typed “HUNTER ELLIOTT ‘Company 

A Broker’” below his signature.  At the bottom of the page, Haithcock inserted the 

following language in bold: 

THIS AGREEMENT IS A CONFIRMATION TO INVEST UNDER BROKER 
‘Hunter Elliott’ YOU WILL RECEIVE A [Company A] RECEIPT OF THE 
FUNDS YOU INVEST WITH [Company A] BROKER ‘Hunter Elliott.’ 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 5 of 17



6 
 

 
27. For most of his clients, Haithcock provided the Client Broker Agreements to 

clients via email and asked each client to, “review, sign, and complete this document.” 

28. For some clients, Haithcock modified an actual form Company A Deposit Slip 

(non-IRAs) (“the Deposit Slip”) downloaded from Company A’s website with the client’s name, 

amount of investment, a false account number, and the ticker symbols of the securities he 

claimed he would purchase.   

29. Haithcock then emailed the fraudulent Deposit Slip to the client for an electronic 

signature.   

30. Then Haithcock provided the client with wire instructions that included account 

and routing numbers as well as the direction to include references in the memo line to accounts 

that ultimately belonged to Haithcock.   

31. Haithcock’s use of falsified account documentation in the name of Company A 

fraudulently induced his clients to invest funds with him under the impression that they were 

opening a brokerage or investment account with Company A. 

B. Haithcock Makes False Statements About The Safety Of The 
Funds Invested And Boasts About The Expected Returns To Clients  

 
32. As Haithcock lured potential clients, he falsely made misrepresentations that he 

guaranteed investors their principal investment and was engaging in highly profitable trading 

activity on their behalf that would result in exorbitant profits generated over the lifetime of the 

investment.  

33. Generally, Haithcock requested that clients make a minimum investment of 

$5,000 and keep their money with him for at least 1 to 5 years (the “required time period”).   

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 6 of 17



7 
 

34. Haithcock also encouraged clients to contribute above this $5,000 minimum in 

their initial investment by highlighting his purported “no loss guarantee” by which he assured 

clients that he would return their initial investment regardless of amount and market 

performance.  

35. Haithcock made these promises orally, in text messages and in the falsified Client 

Broker Agreement, while encouraging his victims to give him as much money up front as they 

could.  To emphasize this misrepresentation, he inserted the following language in bold at the 

end of the sham Client Broker Agreement: 

DISCLOSURE: *THIS AGREEMENT IS A NO LOSS GUARANTEE. MEANING THE 
INITIAL INVESTMENT IS SECURED AND AT ANY TIME THE MARKET HAS A 
CRASH THERE IS NO LOSS TO YOU.* 
 
36. Haithcock told clients that, provided they kept their funds with him for the 

required time period, they would only incur capital gains and loss taxes, Company A fees, and an 

8% “brokerage fee” on the total account value that would only be payable upon withdrawal. 

37. To entice clients to invest funds and to inspire confidence in his investment 

strategies, he often texted fictitious and exorbitant return projections of his purported future 

trades.   

38. One such text Haithcock sent a prospective client in November 2021 read: 

AVERAGE YEARLY EXPECTED RETURN: 
2:1 – 0.5 RISK LEVEL (MEDIUM:HIGH) NO REINVESTMENTS/RELINQUISHED 
EQUITY 
***No including Compound gains and tax appropriations**** 
 
$5,000 INVESMENT 
YEAR 1 
$9,700 
YEAR 2 
$16,562 
YEAR 3 
$31,147 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 7 of 17



8 
 

YEAR 4 
$57,311 
YEAR 5 
$71,804 
 
39. As word of Haithcock’s investment opportunity spread through the family and 

friends of his clients, more and more clients invested with Haithcock.  

C. Haithcock Opens Personal Accounts To Deposit Client Funds And  
Misleads Investors Into Believing Funds Are Deposited On Their Behalf 

 
40. At the outset of Haithcock’s scheme, he deposited client funds in a personal 

savings account he opened in his own name on July 1, 2019, with Company B.  Haithcock 

transferred client funds from his savings account with Company B to a checking account he 

opened in his own name on July 25, 2019, with Company C, an entity with an ownership interest 

in Company A.   

41. In furtherance of his fraudulent scheme, on February 24, 2020, Haithcock then 

opened two personal accounts with Company C in the name of Hunter Allen Haithcock using his 

address in Aberdeen, Maryland.   

42. Haithcock used his personal accounts with Company B and Company C to receive 

wire transfers directly from his clients.     

43. For example, Client 1 was introduced to Haithcock through an employer who 

previously invested money with Haithcock and claimed to have made a profit.   

44. Haithcock sent Client 1 a falsified Client Broker Agreement, as detailed above, 

purporting to be a “broker” with Company A. 

45. After executing the Client Broker Agreement that Haithcock falsified, Client 1 

wrote a check to Haithcock for a $5,000 investment, which was dated December 29, 2020.  

Haithcock deposited it in his personal account with Company B.  

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 8 of 17



9 
 

46. Haithcock also sent a fabricated Client Broker Agreement to Client 2, who was 

introduced to Haithcock through family members who knew Haithcock.  Client 2 signed the 

Client Broker Agreement in February 2021.   

47. On or about February 2021, Client 2 initially invested $50,000 via wire transfer to 

Haithcock, which he deposited in his personal account with Company C that Client 2 believed to 

be an investment account opened by Haithcock on Client 2’s behalf.   Haithcock provided the 

client with wire instructions and the direction: “[P]LEASE ADD PORT MEMO VERY 

IMPORTANT! (XXXXXXXXXXX SIE)”. 

48. Unbeknownst to Client 2, the wire instructions and memo line directed all funds 

to Haithcock’s personal account with Company C.   

49. In November 2021, Haithcock texted Client 3, who was introduced to Haithcock 

through another of Haithcock’s clients, that $5,000 was his current minimum investment.  

Haithcock stated that he preferred investments to be long term and kept up to 5 years.  Haithcock 

falsely advised Client 3 that he could expect a 40-140% return on his investment in one year.  

Client 3 then invested $5,000 on or about November 23, 2021 with Haithcock, which Haithcock 

also deposited into his personal account with Company C.   

50. Haithcock advised Client 3 that he would do an internal transfer from Haithcock’s 

Company C account to an account he would open with Company C on behalf of Client 3.  That 

never occurred. 

51. In total, at Haithcock’s direction, the defrauded investors sent over $308,000 to 

Haithcock’s two personal accounts with Company C, and over $164,000 to Haithcock’s personal 

savings account with Company B.  Clients also gave Haithcock funds in cash and through 

electronic payments, such as Venmo, Zelle and CashApp, for the purpose of investment.   

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 9 of 17



10 
 

D. Haithcock Makes False Representations About The Status Of The Investments 

52. Haithcock lulled his clients and induced them to invest even more funds by 

creating false account statements that showed profitable trading and concealed his 

misappropriation of funds.  

53. On a periodic basis, Haithcock also emailed or texted clients a “Statement 

Report” or a “Summary Report” with their purported balance, a summary of supposed recent 

investment activity, and a summary of market conditions.  These reports were signed “Hunter 

Elliott, IA Investment Strategist,” “Hunter Elliott, CFA Investment Advisor,” or “Hunter.”  None 

of the purported trading activity had occurred.   

54. For instance, Haithcock texted Client 1 falsified information about the returns on 

Client 1’s investment throughout 2021.  Believing the investment was profitable and the 

principal was secure, Client 1 then invested over $14,000 in additional money with Haithcock, 

through cash and via Venmo, including transfers directly to Haithcock’s Venmo account on 

January 20, 2021, April 23, 2021, October 7, 2021, and April 7, 2022. 

55. As another example, on October 9, 2021, Haithcock emailed Client 2 a 

“Statement Report” purporting to show over $80,000 in funds available – a $30,000 gain from 

his $50,000 initial investment.  This was false.  There had been no trading and no gains.  

Believing Haithcock’s representation that he was earning significant returns, Client 2 invested an 

additional $40,000 in July 2021 and an additional $20,000 in February 2022, for a total 

investment of $110,000 that was transferred to Haithcock’s personal account with Company C. 

56. Similarly, on February 8, 2022, Client 3, who as noted above previously invested 

$5,000 with Haithcock, received an email from Haithcock, which was titled “Statement Report: 

1/21/22 – 2/2/22” and purported to show a balance of $7,984.58 based on supposed trading 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 10 of 17



11 
 

profits.  But Haithcock made no investments of any kind on Client C’s behalf and earned no 

profits.  The Statement Report was a complete fabrication.  The Statement Report was signed by 

“Hunter Elliott, CFA, Investment Advisor.”  He also advised that going forward reports would be 

sent on a biweekly basis. 

57. Client 3’s report showed that 10% of the funds were invested in a money market 

account and 90% of their funds were invested in options.  The report also claimed that the 

month’s most profitable trades were in the following stocks (identified by ticker symbol): TSLA, 

SPY, AMD, NVDA and MRNA.  

58. Given the purportedly rapid growth shown in that report generated by Haithcock, 

as well as in a Statement Report, dated April 29, 2022, which reflects a balance of $9,367.95, 

signed by “Hunter Elliott, IA, Investment Strategist”, Client 3 liquidated his 401(k) account and 

wired an additional $40,000 to Haithcock’s account with Company C in May 2022 and another 

$5,000 to the same account in June 2022, for a total investment of $50,000.   

59. These “Statement Reports” were entirely fictional, as Haithcock did not invest 

any of the funds he received from Clients 1, 2 or 3 or from any other clients.  Instead, Haithcock 

simply fabricated the return-on-investment information, including the Statement Reports and 

Summary Reports that falsely showed investments and phenomenal returns. 

E. Haithcock Misappropriates The Funds Of His Purported Clients 

60. Contrary to what Haithcock promised, he never deposited any of the funds with 

which his purported clients entrusted him into an account with Company A to be used for the 

benefit of clients or to purchase securities for their benefit.   

61. Instead, Haithcock kept and/or directed all client funds to his personal accounts, 

including bank accounts with Company B and Company C.   

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 11 of 17



12 
 

62. Haithcock made frequent transfers of the funds among his accounts to pay for 

personal expenses, such as credit card payments, food purchases, and Zelle payments to himself.   

63. At all times, Haithcock acted knowingly or recklessly in committing his fraud 

through fabricated documents he created and false statements orally and in writing.  He also 

knew, or was reckless in not knowing, that his false statements regarding his credentials, his 

guarantees, and his supposed trading profits were material to his clients.   

64. By holding himself as an investment adviser who actively managed investors’  

money in return for a fee, Haithcock met the definition of an investment adviser under the 

Advisers Act.  Thus, Haithcock owed his clients fiduciary duties. 

65. Haithcock breached his fiduciary duties to his clients through his fraudulent 

scheme to misappropriate his clients’ money while lulling them with false performance 

statements and attempting to induce further investment.    

66. In furtherance of his scheme, Haithcock used a small portion of the client funds 

he received to pay back some investors to support the illusion that he was generating trading 

profits.  In particular, he made payments at the outset of the scheme, which appeared to bolster 

the incredible opportunity he presented and increased the word-of-mouth referrals.  Between 

August 2020 and May 2022, Haithcock made approximately $44,000 in Ponzi-like payments 

using client funds.  

67. As the scheme progressed, beginning in May of 2021, Haithcock began using his 

clients’ funds to engage in day trading for his own benefit, which proved to be largely 

unsuccessful.   

68. On May 24, 2021, Haithcock opened a trading account in his own name with 

Company D.  Haithcock then used this account primarily to engage in day trading. 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 12 of 17



13 
 

69. Haithcock transferred client funds from his personal accounts with Company A 

directly to his personal Company D trading account.  

70. Between May 2021 and November 2022, Haithcock transferred over $70,000 of 

client funds to his personal Company D trading account. 

71. Haithcock subsequently lost over $55,000 of the client funds he traded on his own 

behalf through Company D. 

72. Toward the end of the scheme, some of Haithcock’s clients, including Client 1, 

began asking for their funds, which he had guaranteed.  As Haithcock had already spent or lost 

the funds of most of his clients, Haithcock then falsely communicated to his clients, including 

Client 1, that he was in the process of returning the funds, continually providing false 

justifications as to why this process was stalled.  

73. Instead, Haithcock eventually left the District and ceased all communication with 

his victims. 

FIRST CLAIM FOR RELIEF 
Violation of Section 17(a) of the Securities Act 

 
 

74. The Commission repeats and realleges the preceding paragraphs of its Complaint 

as if fully set forth herein. 

75. By reason of the foregoing, Haithcock, directly or indirectly, by use of the means 

or instruments of transportation or communication in interstate commerce or by the use of the 

mails, in the offer or sale of securities has: 

(a) Knowingly or recklessly employed one or more devices, schemes or 

artifices to defraud; 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 13 of 17



14 
 

(b) Knowingly, recklessly, or negligently obtained money or property by 

means of one or more untrue statements of material fact or omitted to state 

one or more material facts necessary in order to make the statements 

made, in light of the circumstances under which they were made, not 

misleading; and/or 

(c) Knowingly, recklessly, or negligently engaged in one or more transactions, 

practices or courses of business which operate or would operate as a fraud 

or deceit upon a purchaser. 

76. By reason of the conduct described above, Haithcock has violated and, unless 

enjoined, will continue to violate Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

 
SECOND CLAIM FOR RELIEF 

Violations of Section 10(b) and Rule 10b-5 of the Exchange Act 
 
 

77. The Commission repeats and realleges the preceding paragraphs of its Complaint 

as if fully set forth herein. 

78. By reason of the foregoing, Haithcock, directly or indirectly, acting intentionally, 

knowingly or recklessly, in connection with the purchase or sale of securities, by the use of the 

means or instrumentalities of interstate commerce or the facilities of a national securities 

exchange or the mail has: 

(a) employed one or more devices, schemes, or artifices to defraud; 

(b) made one or more untrue statements of a material fact or has omitted to 

state one or more material facts necessary in order to make the statements 

made, in light of the circumstances under which they were made, not 

misleading; and/or 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 14 of 17



15 
 

(c) engaged in one or more acts, practices, or courses of business which 

operated or would operate as a fraud or deceit upon other persons, 

including purchasers and sellers of securities. 

79. By engaging in the conduct described above, Haithcock has violated and, unless 

enjoined will continue to violate Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and 

Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

THIRD CLAIM FOR RELIEF 
Violations of Sections 206(1) and 206(2) of the Advisers Act 

 

80. The Commission repeats and realleges the preceding paragraphs of its Complaint 

as if fully set forth herein. 

81. At all relevant times, Haithcock was an “investment adviser” within the meaning 

of Section 202(a)(11) of the Advisers Act [15 U.S.C. § 80b-2(a)(11)]. 

82. By reason of the foregoing, Haithcock directly or indirectly, and by use of the 

means or instruments of transportation or communication in interstate commerce or by the use of 

the mails, as an investment adviser: (1) knowingly or recklessly employed or is employing any 

device, scheme, or artifice to defraud a client or prospective client; and (2) knowingly, recklessly, 

or negligently engaged or is engaging in any transaction, practice, or course of business which 

operates as a fraud or deceit upon a client or prospective client. 

83. By engaging in the conduct described above, Haithcock violated and, unless 

enjoined, will continue to violate Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C.  §§ 

80b-6(1), 80b-6(2)]. 

  

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 15 of 17



16 
 

RELIEF REQUESTED 

 WHEREFORE, the Commission respectfully requests that the Court find the Defendant 

committed the violations alleged and enter a final judgment: 

(i) permanently restraining and enjoining Haithcock, his officers, agents, servants, 

employees, attorneys, and all persons in active concert or participation with him, 

and each of them, from directly or indirectly violating the federal securities laws 

alleged in this Complaint; and further permanently restraining and enjoining 

Haithcock, his officers, agents, servants, employees, attorneys, and all persons in 

active concert or participation with him, who receive actual notice of the Final 

Judgment by personal service or otherwise, and each of them, from engaging in 

transactions, acts, practices, and courses of business described herein, and from 

engaging in conduct of similar purpose and object in violation of Section 17(a) of 

the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of the Exchange Act [15 

U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 

206(1) and 206(2) of the Advisers Act [15 U.S.C.  §§ 80b-6(1), 80b-6(2)]; 

(ii) ordering Haithcock to disgorge all ill-gotten gains he received directly or 

indirectly, with prejudgment interest thereon, as a result of the alleged violations, 

pursuant to Sections 21(d)(5) and (7) of the Exchange Act [15 U.S.C. §§ 78u(5) 

and (7)]; 

(iii) ordering Haithcock to pay civil money penalties pursuant to Section 20(d) of the 

Securities Act [15 U.S.C. § 77t(d)]; Section 21(d)(3)(A) of the Exchange Act [15 

U.S.C. § 78u(d)(3)(A)], and Section 209(e) of the Advisers Act [15 U.S.C. 80b-

9(e)]; and 

(iv) granting any other and further relief this Court may deem just and proper. 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 16 of 17



17 
 

DEMAND FOR JURY TRIAL 

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, the Commission hereby 

requests a trial by jury. 

Dated: September 6, 2024    

Respectfully submitted, 

SECURITIES AND 
EXCHANGE COMMISSION 

/s/ Gregory R. Bockin   
Gregory R. Bockin (Bar No. 17993)  

             Kara F. Sweet 
Kingdon Kase 
Paulina L. Jerez 
Samantha K. Keleher 
Philadelphia Regional Office 
1617 JFK Boulevard, Suite 520 
Philadelphia, PA 19103 
215.597.3100 
215.597.2740 (fax) 
[email protected] 
[email protected] 
 
Counsel for Plaintiff Securities  
and Exchange Commission 

  

 

Case 1:24-cv-02585-JRR   Document 1   Filed 09/06/24   Page 17 of 17