SEC v. George Stubos; and Dori-Ann Stubos, No. 1:22-cv-04674, Southern District of New York (Apr. 15, 2024) — Judgment

1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

SECURITIES AND EXCHANGE
COMMISSION,
   Plaintiff,
 v.

GEORGE STUBOS,
   Defendant,
and

DORI-ANN STUBOS,
   Relief Defendant.

    Civil Action No. 22-cv-4674-LJL

FINAL JUDGMENT AS TO RELIEF DEFENDANT DORI-ANN STUBOS

The Securities and Exchange Commission having filed a Complaint and Relief Defendant
Dori-Ann Stubos (“Relief Defendant”) having entered a general appearance; consented to the
Court’s jurisdiction over Relief Defendant and the subject matter of this action; consented to
entry of this Final Judgment without admitting or denying the allegations of the Complaint
(except as to jurisdiction and except as otherwise provided herein in Section III); waived findings
of fact and conclusions of law; and waived any right to appeal from this Final Judgment:
I.
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that, of the $6,174,034
payable by Defendant George Stubos to the Commission under the Final Judgment as to
Defendant George Stubos ( ECF No. 69) (the “George Stubos Judgment”),  Relief Defendant is
jointly and severally liable for $2,308,108, representing disgorgement of $1,775,000 in benefits
gained as a result of conduct as alleged in the Complaint, together with prejudgment interest
thereon in the amount of $533,108.  No later than June 10, 2024 (i.e., within 275 days after entry

2

of the George Stubos Judgment), Relief Defendant, joint-and-severally with George Stubos
under paragraph VII(3) of the George Stubos Judgment, shall effect payment to the Commission
totaling $2,308,108 in disgorgement and prejudgment interest.  Payments shall be deemed made
on the date they are received by the Commission and shall be applied first to post judgment
interest, if any, which shall begin to accrue pursuant to 28 U.S.C. §1961 on any unpaid amounts
due beginning 30 days after entry of this Final Judgment.  Prior to making final payment in full
satisfaction of the Final Judgment, Relief Defendant shall contact the staff of the Commission to
obtain the Commission’s calculation of post-judgment interest, if any, to determine the total
amount then due to satisfy this Final Judgment in full.
Relief Defendant may transmit payment electronically to the Commission, which will
provide detailed ACH transfer/Fedwire instructions upon request.  Payment may also be made
directly from a bank account via Pay.gov through the SEC website at
http://www.sec.gov/about/offices/ofm.htm
.  Relief Defendant may also pay by certified check,
bank cashier’s check, or United States postal money order payable to the Securities and
Exchange Commission, which shall be delivered or mailed to
Enterprise Services Center
Accounts Receivable Branch
6500 South MacArthur Boulevard
Oklahoma City, OK 73169

and shall be accompanied by a letter identifying the case title, civil action number, and name of
this Court; Dori-Ann Stubos as a relief defendant in this action; and specifying that payment is
made pursuant to this Final Judgment.
Relief Defendant shall simultaneously transmit photocopies of evidence of payment and
case identifying information to the Commission’s counsel in this action.  By making this
payment, Relief Defendant relinquishes all legal and equitable right, title, and interest in such

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funds and no part of the funds shall be returned to Relief Defendant.
The Commission may enforce the Court’s judgment for disgorgement and prejudgment
interest by using all collection procedures authorized by law, including, but not limited to,
moving for civil contempt at any time following a breach of the provisions of this Final
Judgment.
The Commission shall hold the funds (collectively, the “Fund”) until further order of this
Court.  The Commission may propose a plan to distribute the Fund subject to the Court’s
approval and the Court shall retain jurisdiction over the administration of any distribution of the
Fund.
II.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent of Relief
Defendant Dori-Ann Stubos, attached hereto as Exhibit 1, is incorporated with the same force
and effect as if fully set forth herein, and that Relief Defendant shall comply with all of the
undertakings and agreements set forth therein.
III.
IT
 IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of
exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. §523, the
allegations in the complaint are true and admitted by Relief Defendant, and further, any debt for
disgorgement, prejudgment interest, civil penalty or other amounts due by Relief Defendant
under this Final Judgment or any other judgment, order, consent order, decree or settlement
agreement entered in connection with this proceeding, is a debt for the violation by Defendant
George Stubos of the federal securities laws or any regulation or order issued under such laws, as
set forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. §523(a)(19).

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IV.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Stipulation and
Order for Entry of Preliminary Injunction Freezing Assets (ECF No. 41) (the “Preliminary
Injunction”) is hereby fully vacated as to: (i) that certain real property listed as   the first item
under the heading “Asset Description” in the table beginning on the third page of
the Preliminary
Injunction; and (ii) all  accounts with Canaccord Genuity Corp. owned by Dori-Ann Stubos (i.e.,
those accounts identified at   page 4 of the Preliminary Injunction with account numbers ending in
7AE1, 7AF1, 7AV1, 7AV2, 69A8, 69V2, 34V1, and 23A0).  The Preliminary Injunction shall
remain in effect as to
 the properties in Vancouver, British Columbia, listed as   the second and
third items under the heading “Asset Description” in the table beginning on the third page of the
Preliminary Injunction, until  all  amounts due to plaintiff under the George Stubos Judgment have
been satisfied,
after which the parties shall notify the Court of such satisfaction and the
Preliminary Injunction shall thereafter be fully vacated in all respects, including as to the
Vancouver properties.
V.
IT
IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain
ju
risdiction of this matter for the purposes of enforcing the terms of this Final Judgment.
Dated:  April 12, 2024
____________________________________

UNITED STATES DISTRICT JUDGE

EXHIBIT 1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.
GEORGE STUBOS,
Defendant,
and
DORI-ANN STUBOS,
Relief Defendant.
Civil Action No. 22-cv-4674-LJL
CONSENT OF RELIEF DEFENDANT DORI-ANN STUBOS
1.
Relief Defendant Dori-Ann Stubos ("Relief Defendant") acknowledges having
been served with the complaint in this action and, for the limited purpose of this action, consents
to the Court's jurisdiction over Relief Defendant and over the subject matter of this action.
2.
Without admitting or denying the allegations of the complaint (except as provided
herein in paragraph 15  and except as to subject matter jurisdiction, which Relief Defendant
admits), Relief Defendant hereby consents to the entry of the Final Judgment as to Relief
Defendant Dori-Ann Stubos (the "Final Judgment"), attached hereto and incorporated by
reference herein.
3.
Pursuant to Section I of the Final Judgment, no later than June 10, 2024,
(i.e., within 275 days after entry of the Final Judgment as to  Defendant George Stubos (ECF
No. 69) (the "George Stubos Judgment")), Relief Defendant, joint-and-severally with
George Stubos under Section Vll(3) of the George Stubos Judgment, shall effect payment to
the Commission totaling $2,308,108 in disgorgement and prejudgment interest (the "Stubos
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Settlement Amount" ) by: (i) liquidating that certain real property listed as the first item under the
heading " Asset Description" in the table beginning on the third page
of the Stipulation and Order
for Entry
of Preliminary Injunction Freezing Assets (ECF No. 41) (the "Preliminary Injunction")
(the "Settlement Property");
or (ii) otherwise paying the foregoing amount to the Commission.
For avoidance of doubt, if the Stubos Settlement Amount is not paid to the Commission in
accordance with the schedule set forth in Section I
of the Final Judgment, all outstanding
amounts due under the Final Judgment shall become due and payable immediately at the
discretion
of the staff of the Commission without further application to the Court.
4. As reflected in Section I of the Final Judgment, payments thereunder shall be
deemed made on the date they are received by the Commission and shall
be applied first to post-
judgment interest, if any, which shall begin to accrue pursuant to 28 U.S.C. § 1961 on any unpaid
amounts due beginning 30 days after entry
of the Final Judgment. Prior to making final payment
in full satisfaction
of the Final Judgment, Relief Defendant shall contact the staff of the
Commission
to obtain the Commission' s calculation of post-judgment interest, if any, to
determine the total amount then due
to satisfy the Final Judgment in full.
5. To secure the liability of Relief Defendant under Section I of the Final Judgment,
Relief Defendant has executed a deed of trust in favor of the SEC on the Settlement Property in
the amount of $2,308, 108 ("Deed of Trust") and deed of trust agreement in forms acceptable to
the Commission.  Further, Relief Defendant has represented to the SEC that the Deed of Trust is
the only encumbrance
on the Settlement Property.  The Deed of Trust, which is currently held in
escrow by Relief Defendant's counsel, s  hall be recorded promptly by Relief Defendant's counsel
upon entry
of the Final Judgment on the Court' s docket in this action.
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6. The parties agree to cooperate with each other to effectuate the terms of the Final
Judgment, including by performing any further act and executing and delivering any further
document that either is required by the Final Judgment
or may reasonably be necessary or
desirable to effectuate the purposes of the Final Judgment. In the event that Relief Defendant
fails
to effect payment to the Commission of the Stubos Settlement Amount as set forth in
Section I
of the Final Judgment, until such payment obligation has been satisfied, Relief
Defendant shall consent to all Commission efforts to exercise its rights under the Deed of Trust,
including,
but not limited to, the use of one or more liquidation agents proposed by the
Commission and appointed by the Court
to sell the Settlement Property for fair market value. If
the Stubos Settlement Amount is paid by means other than by sale of the Settlement Property,
the Commission shall, upon receiving such payment, promptly (i) file a release
of the lien in the
local jurisdiction in which the Deed
of Trust was originally recorded such that the Deed of Trust
shall be deemed
to have no further force or effect and (ii) file with the Court a satisfaction of
judgment as to Relief Defendant's financial obligations under the Final Judgment.
7. Relief Defendant agrees that the Preliminary Injunction shall remain in effect
until all payments due under the George Stubos Judgment and the attached Final Judgment are
satisfied in full, except for and subject to the following:
(a) Upon entry
of the Final Judgment, the Preliminary Injunction shall be
immediately vacated as
to: (i) the Settlement Property; and (ii) all accounts with
Canaccord Genuity Corp. owned by
Relief Defendant (i.e., the Canaccord Genuity Corp.
accounts identified in the Preliminary Injunction with account numbers ending in 7AE1,
7AF1, 7AV1, 7AV2, 69A8, 69V2, 34V1, and 23A0);
3

(b) After all amounts due to the Commission under the Final Judgment and
the George Stubos Judgment
have been satisfied, the Preliminary Injunction shall be fully
vacated in all remaining respects, including but not limited
to as to the residential
properties in Vancouver, British Columbia, listed as the second and third items under the
heading "Asset Description" in the table beginning on the third page
of the Preliminary
Injunction (collectivel
y, the " Vancouver Properties"); and
( c)
At any time prior to full satisfaction of all payment obligations under the
Final Judgment and the George Stubos Judgment, Relief Defendant
or Defendant George
Stubos may apply
to the Court for an order vacating the Preliminary Injunction as to any
asset listed therein, including the Vancouv
er Properties, or any portion thereof, to enable
Relief Defendant or Defendant to liquidate such asset in order to satisfy any payment
obligation under the Final Judgment
or the George Stubos Judgment. For avoidance of
doubt, while Relief Defendant consents herein to the continued application of the
Preliminary Injunction
to the Vancouver Properties until the Final Judgment and the
George Stubos Judgment are fully satisfied, the parties specifically do not address herein,
and they each reserve their respective rights concerning, whether the Vancouver
Properties may, without
Relief Defendant's consent, be liquidated to satisfy the George
Stubos Judgment in the event
of a default thereunder.
8 . Relief Defendant waives the entry
of findings of fact and conclusions of law
pursuant to Rule 52
of the Federal Rules of Civil Procedure.
9. Relief Defendant waives the right,
if any, to a jury trial and to appeal from the
entry
of the Final Judgment.
10. Relief Defendant enters into this Consent voluntarily and represents that no
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threats, offers, promises, or inducements of any kind have been made by the Commission or any
member, officer, employee, agent,
or representative of the Commission to induce Relief
Defendant to enter into this Consent.
11. Relief Defendant agrees that this Consent shall be incorporated into the Final
Judgment with the same force and effect as
if fully set forth therein.
12. Relief Defendant will not oppose the enforcement
of the Final Judgment on the
ground,
if any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil
Procedure, and hereby waives any objection based thereon.
13. Relief Defendant waives service
of the Final Judgment and agrees that entry of
the Final Judgment by the Court and filing with the Clerk of the Court will constitute notice to
Relief Defendant
of its terms and conditions. Relief Defendant further agrees to provide counsel
for the Commission, within thirty (30) days after the Final Judgment is filed with
the Clerk of the
Court, with an affidavit
or declaration stating that Relief Defendant has received and read a copy
of the Final Judgment.
14. Consistent with 17 C.F.R. 202.S(f), this Consent resolves only the claims asserted
against
Relief Defendant in this civil proceeding. Relief Defendant acknowledges that no
promise or representation has been made by the Commission or any member, officer, employee,
agent,
or representative of the Commission with regard to any criminal liability that may have
arisen
or may arise from the facts underlying this action or immunity from any such criminal
liability.
Relief Defendant waives any claim of Double Jeopardy based upon the settlement of
this proceeding, including the imposition of any remedy or civil penalty herein.
15. Relief Defendant understands and agrees to comply with the terms of 17 C.F.R.
§202.S(e), which provides in part that it is the Commission's policy "not to permit a defendant or
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respondent to consent to a judgment or order that imposes a sanction while denying the
allegations in the complaint or order for proceedings," and "a refusal to admit the allegations
is
equivalent to a denial, unless the defendant or respondent states that he neither admits nor denies
the allegations." As part
of Relief Defendant's agreement to comply with the tenns of Section
202.S(e),  Relief Defendant: (i) will not take any action
or make or permit to be made any public
statement denying, directly
or indirectly, any allegation in the complaint or creating the
impression that the complaint is without  factual basis; (ii) will not make
or permit to be made
any public statement to the effect that Relief Defendant does not admit the allegations
of the
complaint,
or that this Consent contains no admission of the allegations, without also stating that
Relief Defendant does not deny the allegations; (iii) hereby withdraws any papers filed in this
action to the extent that they deny any allegation in the complaint; and (iv) stipulates solely for
purposes
of exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C.
§523, that the allegations in the complaint are true, and further, that any debt for disgorgement,
prejudgment interest, civil penalty
or other amounts due by Relief Defendant under the Final
Judgment
or any other judgment, order, consent order, decree or settlement agreement entered in
connection with this proceeding, is a debt for the violation of the federal securities laws or any
regulation
or order issued under such laws, as set forth in Section 523(a)(19) of the Bankruptcy
Code,
11 U.S.C. §523(a)(19) If Relief Defendant breaches this Consent, the Commission may
petition the Court
to vacate the Final Judgment and restore this action to its active docket.
Nothing in this paragraph affects Relief Defendant's: (i) testimonial obligations;
or (ii) right to
take legal
or factual positions in litigation or other legal proceedings in which the Commission is
not a party.
6

16. Relief Defendant hereby waives any rights under the Equal Access to Justice Act,
the Small Business Regulatory Enforcement Fairness Act
of 1996, or any other provision of law
to seek from the United States, or any agency, or any official of the United States acting in his or
her official capacity, directly or indirectly, reimbursement of attorney' s fees or other fees,
expenses,
or costs expended by Relief Defendant to defend against this action. For these
purposes, Relief Defendant agrees that
Relief Defendant is not the prevailing party in this action
since the parties have reached a good faith settlement.
17. Relief Defendant agrees that the Commission may present the Final Judgment to
the Court for signature and entry without further notice.
18. Relief Defendant agrees that this Court shall retain jurisdiction over this matter
for the purpose
of enforcing the terms of the Preliminary Injunction and the Final Judgment,
including the terms
of this Consent.
Dated:
C3 -.,:2 \-..JC>~ 4-
Dori-Ann Stubos
On
C 3  -~ \ , 2024, Dori-Ann Stubos, a person known to me, personally
appeared before
me and acknowledged executing the foregoing Consent.
Notary Public
?
Commission e  pires: tRMANENT COMMISS!Otl
SUSHANT RAJ
NOT ARY PUBLIC
FOR BRITISH COLUMBIA
202-2309 WEST 41ST AVENUE
VA
NCOUVER, B.C. V6M 2A3
604-263-9317
7
Sushant  Raj
Notary _Publ ic for the Province
of Bnt1sh Columbia, Canada

1 
 

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

 
 
SECURITIES AND EXCHANGE 
COMMISSION, 
   Plaintiff, 
 v. 
 
GEORGE STUBOS, 
   Defendant, 
and 
 
DORI-ANN STUBOS, 
   Relief Defendant. 
 

 
 
    Civil Action No. 22-cv-4674-LJL 
 
 
 

 
 

FINAL JUDGMENT AS TO RELIEF DEFENDANT DORI-ANN STUBOS 

 
The Securities and Exchange Commission having filed a Complaint and Relief Defendant 

Dori-Ann Stubos (“Relief Defendant”) having entered a general appearance; consented to the 

Court’s jurisdiction over Relief Defendant and the subject matter of this action; consented to 

entry of this Final Judgment without admitting or denying the allegations of the Complaint 

(except as to jurisdiction and except as otherwise provided herein in Section III); waived findings 

of fact and conclusions of law; and waived any right to appeal from this Final Judgment: 

I. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that, of the $6,174,034 

payable by Defendant George Stubos to the Commission under the Final Judgment as to 

Defendant George Stubos (ECF No. 69) (the “George Stubos Judgment”), Relief Defendant is 

jointly and severally liable for $2,308,108, representing disgorgement of $1,775,000 in benefits 

gained as a result of conduct as alleged in the Complaint, together with prejudgment interest 

thereon in the amount of $533,108.  No later than June 10, 2024 (i.e., within 275 days after entry 

Case 1:22-cv-04674-LJL   Document 85   Filed 04/12/24   Page 1 of 12



2 
 

of the George Stubos Judgment), Relief Defendant, joint-and-severally with George Stubos 

under paragraph VII(3) of the George Stubos Judgment, shall effect payment to the Commission 

totaling $2,308,108 in disgorgement and prejudgment interest.  Payments shall be deemed made 

on the date they are received by the Commission and shall be applied first to post judgment 

interest, if any, which shall begin to accrue pursuant to 28 U.S.C. §1961 on any unpaid amounts 

due beginning 30 days after entry of this Final Judgment.  Prior to making final payment in full 

satisfaction of the Final Judgment, Relief Defendant shall contact the staff of the Commission to 

obtain the Commission’s calculation of post-judgment interest, if any, to determine the total 

amount then due to satisfy this Final Judgment in full. 

Relief Defendant may transmit payment electronically to the Commission, which will 

provide detailed ACH transfer/Fedwire instructions upon request.  Payment may also be made 

directly from a bank account via Pay.gov through the SEC website at 

http://www.sec.gov/about/offices/ofm.htm.  Relief Defendant may also pay by certified check, 

bank cashier’s check, or United States postal money order payable to the Securities and 

Exchange Commission, which shall be delivered or mailed to  

Enterprise Services Center 
Accounts Receivable Branch 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 
 

and shall be accompanied by a letter identifying the case title, civil action number, and name of 

this Court; Dori-Ann Stubos as a relief defendant in this action; and specifying that payment is 

made pursuant to this Final Judgment.   

Relief Defendant shall simultaneously transmit photocopies of evidence of payment and 

case identifying information to the Commission’s counsel in this action.  By making this 

payment, Relief Defendant relinquishes all legal and equitable right, title, and interest in such 

Case 1:22-cv-04674-LJL   Document 85   Filed 04/12/24   Page 2 of 12

http://www.sec.gov/about/offices/ofm.htm


3 
 

funds and no part of the funds shall be returned to Relief Defendant.   

The Commission may enforce the Court’s judgment for disgorgement and prejudgment 

interest by using all collection procedures authorized by law, including, but not limited to, 

moving for civil contempt at any time following a breach of the provisions of this Final 

Judgment. 

The Commission shall hold the funds (collectively, the “Fund”) until further order of this 

Court.  The Commission may propose a plan to distribute the Fund subject to the Court’s 

approval and the Court shall retain jurisdiction over the administration of any distribution of the 

Fund.    

II. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent of Relief 

Defendant Dori-Ann Stubos, attached hereto as Exhibit 1, is incorporated with the same force 

and effect as if fully set forth herein, and that Relief Defendant shall comply with all of the 

undertakings and agreements set forth therein. 

III. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of 

exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. §523, the 

allegations in the complaint are true and admitted by Relief Defendant, and further, any debt for 

disgorgement, prejudgment interest, civil penalty or other amounts due by Relief Defendant 

under this Final Judgment or any other judgment, order, consent order, decree or settlement 

agreement entered in connection with this proceeding, is a debt for the violation by Defendant 

George Stubos of the federal securities laws or any regulation or order issued under such laws, as 

set forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. §523(a)(19). 

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IV. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Stipulation and 

Order for Entry of Preliminary Injunction Freezing Assets (ECF No. 41) (the “Preliminary 

Injunction”) is hereby fully vacated as to: (i) that certain real property listed as the first item 

under the heading “Asset Description” in the table beginning on the third page of the Preliminary 

Injunction; and (ii) all accounts with Canaccord Genuity Corp. owned by Dori-Ann Stubos (i.e., 

those accounts identified at page 4 of the Preliminary Injunction with account numbers ending in 

7AE1, 7AF1, 7AV1, 7AV2, 69A8, 69V2, 34V1, and 23A0).  The Preliminary Injunction shall 

remain in effect as to the properties in Vancouver, British Columbia, listed as the second and 

third items under the heading “Asset Description” in the table beginning on the third page of the 

Preliminary Injunction, until all amounts due to plaintiff under the George Stubos Judgment have 

been satisfied, after which the parties shall notify the Court of such satisfaction and the 

Preliminary Injunction shall thereafter be fully vacated in all respects, including as to the 

Vancouver properties. 

V. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain 

jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment. 

Dated:  April 12, 2024 

____________________________________ 
UNITED STATES DISTRICT JUDGE 

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EXHIBIT 1 

Case 1:22-cv-04674-LJL   Document 85   Filed 04/12/24   Page 5 of 12



UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

SECURITIES AND EXCHANGE 

COMMISSION, 

Plaintiff, 

v. 

GEORGE STUBOS, 

Defendant, 

and 

DORI-ANN STUBOS, 

Relief Defendant. 

Civil Action No. 22-cv-4674-LJL 

CONSENT OF RELIEF DEFENDANT DORI-ANN STUBOS 

1. Relief Defendant Dori-Ann Stubos ("Relief Defendant") acknowledges having

been served with the complaint in this action and, for the limited purpose of this action, consents 

to the Court's jurisdiction over Relief Defendant and over the subject matter of this action. 

2. Without admitting or denying the allegations of the complaint (except as provided

herein in paragraph 15 and except as to subject matter jurisdiction, which Relief Defendant 

admits), Relief Defendant hereby consents to the entry of the Final Judgment as to Relief 

Defendant Dori-Ann Stubos (the "Final Judgment"), attached hereto and incorporated by 

reference herein. 

3. Pursuant to Section I of the Final Judgment, no later than June 10, 2024,

(i.e., within 275 days after entry of the Final Judgment as to Defendant George Stubos (ECF 

No. 69) (the "George Stubos Judgment")), Relief Defendant, joint-and-severally with 

George Stubos under Section Vll(3) of the George Stubos Judgment, shall effect payment to 

the Commission totaling $2,308,108 in disgorgement and prejudgment interest (the "Stubos 

l

Case 1:22-cv-04674-LJL   Document 85   Filed 04/12/24   Page 6 of 12



Settlement Amount") by: (i) liquidating that certain real property listed as the first item under the 

heading "Asset Description" in the table beginning on the third page of the Stipulation and Order 

for Entry of Preliminary Injunction Freezing Assets (ECF No. 41) (the "Preliminary Injunction") 

(the "Settlement Property"); or (ii) otherwise paying the foregoing amount to the Commission. 

For avoidance of doubt, if the Stubos Settlement Amount is not paid to the Commission in 

accordance with the schedule set forth in Section I of the Final Judgment, all outstanding 

amounts due under the Final Judgment shall become due and payable immediately at the 

discretion of the staff of the Commission without further application to the Court. 

4. As reflected in Section I of the Final Judgment, payments thereunder shall be 

deemed made on the date they are received by the Commission and shall be applied first to post­

judgment interest, if any, which shall begin to accrue pursuant to 28 U.S.C. § 1961 on any unpaid 

amounts due beginning 30 days after entry of the Final Judgment. Prior to making final payment 

in full satisfaction of the Final Judgment, Relief Defendant shall contact the staff of the 

Commission to obtain the Commission' s calculation of post-judgment interest, if any, to 

determine the total amount then due to satisfy the Final Judgment in full. 

5. To secure the liability of Relief Defendant under Section I of the Final Judgment, 

Relief Defendant has executed a deed of trust in favor of the SEC on the Settlement Property in 

the amount of $2,308,108 ("Deed of Trust") and deed of trust agreement in forms acceptable to 

the Commission. Further, Relief Defendant has represented to the SEC that the Deed of Trust is 

the only encumbrance on the Settlement Property. The Deed of Trust, which is currently held in 

escrow by Relief Defendant's counsel, shall be recorded promptly by Relief Defendant's counsel 

upon entry of the Final Judgment on the Court' s docket in this action. 

2 

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6. The parties agree to cooperate with each other to effectuate the terms of the Final 

Judgment, including by performing any further act and executing and delivering any further 

document that either is required by the Final Judgment or may reasonably be necessary or 

desirable to effectuate the purposes of the Final Judgment. In the event that Relief Defendant 

fails to effect payment to the Commission of the Stubos Settlement Amount as set forth in 

Section I of the Final Judgment, until such payment obligation has been satisfied, Relief 

Defendant shall consent to all Commission efforts to exercise its rights under the Deed of Trust, 

including, but not limited to, the use of one or more liquidation agents proposed by the 

Commission and appointed by the Court to sell the Settlement Property for fair market value. If 

the Stubos Settlement Amount is paid by means other than by sale of the Settlement Property, 

the Commission shall, upon receiving such payment, promptly (i) file a release of the lien in the 

local jurisdiction in which the Deed of Trust was originally recorded such that the Deed of Trust 

shall be deemed to have no further force or effect and (ii) file with the Court a satisfaction of 

judgment as to Relief Defendant's financial obligations under the Final Judgment. 

7. Relief Defendant agrees that the Preliminary Injunction shall remain in effect 

until all payments due under the George Stubos Judgment and the attached Final Judgment are 

satisfied in full, except for and subject to the following: 

(a) Upon entry of the Final Judgment, the Preliminary Injunction shall be 

immediately vacated as to: (i) the Settlement Property; and (ii) all accounts with 

Canaccord Genuity Corp. owned by Relief Defendant (i.e. , the Canaccord Genuity Corp. 

accounts identified in the Preliminary Injunction with account numbers ending in 7AE1, 

7AF1, 7AV1 , 7AV2, 69A8, 69V2, 34V1 , and 23A0); 

3 

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(b) After all amounts due to the Commission under the Final Judgment and 

the George Stubos Judgment have been satisfied, the Preliminary Injunction shall be fully 

vacated in all remaining respects, including but not limited to as to the residential 

properties in Vancouver, British Columbia, listed as the second and third items under the 

heading "Asset Description" in the table beginning on the third page of the Preliminary 

Injunction (collectively, the "Vancouver Properties"); and 

( c) At any time prior to full satisfaction of all payment obligations under the 

Final Judgment and the George Stubos Judgment, Relief Defendant or Defendant George 

Stubos may apply to the Court for an order vacating the Preliminary Injunction as to any 

asset listed therein, including the Vancouver Properties, or any portion thereof, to enable 

Relief Defendant or Defendant to liquidate such asset in order to satisfy any payment 

obligation under the Final Judgment or the George Stubos Judgment. For avoidance of 

doubt, while Relief Defendant consents herein to the continued application of the 

Preliminary Injunction to the Vancouver Properties until the Final Judgment and the 

George Stubos Judgment are fully satisfied, the parties specifically do not address herein, 

and they each reserve their respective rights concerning, whether the Vancouver 

Properties may, without Relief Defendant' s consent, be liquidated to satisfy the George 

Stubos Judgment in the event of a default thereunder. 

8. Relief Defendant waives the entry of findings of fact and conclusions of law 

pursuant to Rule 52 of the Federal Rules of Civil Procedure. 

9. Relief Defendant waives the right, if any, to a jury trial and to appeal from the 

entry of the Final Judgment. 

10. Relief Defendant enters into this Consent voluntarily and represents that no 

4 

Case 1:22-cv-04674-LJL   Document 85   Filed 04/12/24   Page 9 of 12



threats, offers, promises, or inducements of any kind have been made by the Commission or any 

member, officer, employee, agent, or representative of the Commission to induce Relief 

Defendant to enter into this Consent. 

11. Relief Defendant agrees that this Consent shall be incorporated into the Final 

Judgment with the same force and effect as if fully set forth therein. 

12. Relief Defendant will not oppose the enforcement of the Final Judgment on the 

ground, if any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil 

Procedure, and hereby waives any objection based thereon. 

13. Relief Defendant waives service of the Final Judgment and agrees that entry of 

the Final Judgment by the Court and filing with the Clerk of the Court will constitute notice to 

Relief Defendant of its terms and conditions. Relief Defendant further agrees to provide counsel 

for the Commission, within thirty (30) days after the Final Judgment is filed with the Clerk of the 

Court, with an affidavit or declaration stating that Relief Defendant has received and read a copy 

of the Final Judgment. 

14. Consistent with 17 C.F.R. 202.S(f), this Consent resolves only the claims asserted 

against Relief Defendant in this civil proceeding. Relief Defendant acknowledges that no 

promise or representation has been made by the Commission or any member, officer, employee, 

agent, or representative of the Commission with regard to any criminal liability that may have 

arisen or may arise from the facts underlying this action or immunity from any such criminal 

liability. Relief Defendant waives any claim of Double Jeopardy based upon the settlement of 

this proceeding, including the imposition of any remedy or civil penalty herein. 

15. Relief Defendant understands and agrees to comply with the terms of 17 C.F.R. 

§202.S(e), which provides in part that it is the Commission's policy "not to permit a defendant or 

5 

Case 1:22-cv-04674-LJL   Document 85   Filed 04/12/24   Page 10 of 12



respondent to consent to a judgment or order that imposes a sanction while denying the 

allegations in the complaint or order for proceedings," and "a refusal to admit the allegations is 

equivalent to a denial, unless the defendant or respondent states that he neither admits nor denies 

the allegations." As part of Relief Defendant's agreement to comply with the tenns of Section 

202.S(e), Relief Defendant: (i) will not take any action or make or permit to be made any public 

statement denying, directly or indirectly, any allegation in the complaint or creating the 

impression that the complaint is without factual basis; (ii) will not make or permit to be made 

any public statement to the effect that Relief Defendant does not admit the allegations of the 

complaint, or that this Consent contains no admission of the allegations, without also stating that 

Relief Defendant does not deny the allegations; (iii) hereby withdraws any papers filed in this 

action to the extent that they deny any allegation in the complaint; and (iv) stipulates solely for 

purposes of exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. 

§523, that the allegations in the complaint are true, and further, that any debt for disgorgement, 

prejudgment interest, civil penalty or other amounts due by Relief Defendant under the Final 

Judgment or any other judgment, order, consent order, decree or settlement agreement entered in 

connection with this proceeding, is a debt for the violation of the federal securities laws or any 

regulation or order issued under such laws, as set forth in Section 523(a)(19) of the Bankruptcy 

Code, 11 U.S.C. §523(a)(19) If Relief Defendant breaches this Consent, the Commission may 

petition the Court to vacate the Final Judgment and restore this action to its active docket. 

Nothing in this paragraph affects Relief Defendant's: (i) testimonial obligations; or (ii) right to 

take legal or factual positions in litigation or other legal proceedings in which the Commission is 

not a party. 

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16. Relief Defendant hereby waives any rights under the Equal Access to Justice Act, 

the Small Business Regulatory Enforcement Fairness Act of 1996, or any other provision of law 

to seek from the United States, or any agency, or any official of the United States acting in his or 

her official capacity, directly or indirectly, reimbursement of attorney ' s fees or other fees, 

expenses, or costs expended by Relief Defendant to defend against this action. For these 

purposes, Relief Defendant agrees that Relief Defendant is not the prevailing party in this action 

since the parties have reached a good faith settlement. 

17. Relief Defendant agrees that the Commission may present the Final Judgment to 

the Court for signature and entry without further notice. 

18. Relief Defendant agrees that this Court shall retain jurisdiction over this matter 

for the purpose of enforcing the terms of the Preliminary Injunction and the Final Judgment, 

including the terms of this Consent. 

Dated: C3 - .,:2 \ -..JC>~ 4-
Dori-Ann Stubos 

On C 3 - ~ \ , 2024, Dori-Ann Stubos, a person known to me, personally 
appeared before me and acknowledged executing the foregoing Consent. 

Notary Public ? 
Commission e pires: tRMANENT COMMISS!Otl 

SUSHANT RAJ 
NOT ARY PUBLIC 

FOR BRITISH COLUMBIA 
202-2309 WEST 41ST AVENUE 

VANCOUVER, B.C. V6M 2A3 
604-263-9317 

7 

Sushant Raj 
Notary _Public for the Province 
of Bnt1sh Columbia, Canada 

Case 1:22-cv-04674-LJL   Document 85   Filed 04/12/24   Page 12 of 12