SEC v. James P. Anglim, No. 1:23-cv-11598, Eastern District of New York (July 17, 2023) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE
COMMISSION,
   Plaintiff,
 v.

JAMES P. ANGLIM,

   Defendant.

      Civil Action No. 23-CV-

COMPLAINT
 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the
following against defendant, James P. Anglim (“Anglim” or “Defendant”):
SUMMARY
1. This is a securities fraud enforcement action.  Starting in November 2016 and
continuing through at least February 2022 (the “Relevant Period”), Anglim engaged in multiple
deceptive and manipulative schemes to assist various people who controlled large blocks of
public company stock (“Control Persons”) to sell that stock to investors in the public over-the-
counter (or “OTC”) markets while concealing that they were behind those sales.
2. During the Relevant Period, Anglim was employed as a registered representative
of two different United States-based brokerage firms that engaged in “market making” activities.
A “market maker” is a broker-dealer firm that provides liquidity to stock markets by publicly
quoting both a buy price (a “bid”) and a sell price (an “offer” or an “ask”) for stocks and offering
to trade with the public at those prices.  Anglim’s job was to trade stocks on behalf of the two
firms that employed him.
3. Anglim abused his position as a trader working for market makers to facilitate the

2

illegal sale of stock into the public markets by several Control Persons in at least five different
public companies’ shares.  Anglim’s conduct helped those Control Persons to dump large
quantities of stock into the public markets while concealing that they were the source of all of
those sales, thus avoiding disclosure requirements imposed by the federal securities laws.  The
Control Persons were not customers of the brokerage firms where Anglim was employed.
Nonetheless, Anglim entered into repeated arrangements with several Control Persons whereby:
1) the Control Persons would tell Anglim they wanted to sell a particular company’s stock, how
much they wanted to sell, and often at what prices they wanted to sell; 2) Anglim would use his
position as a trader at a market maker firm to sell short the shares of that company’s stock, at
prices directed by the Control Persons; and 3) Anglim would cover his short positions in that
company’s stock by arranging with the Control Persons to purchase shares of that company’s
stock from them -- often at pre-arranged prices.
4. Anglim’s trading often resulted in riskless profits for him and for his employers
and facilitated the Control Persons’ dumping of their shares at manipulated prices into the
market.
5. On behalf of Control Persons, Anglim engaged in at least $53.85 million of
trading in the securities of at least the following companies: Proto Script Pharmaceutical Corp.,
Digatrade Financial Corp., 12 Retech Corp., Homie Recipes Inc. and Charlestowne Premium
Beverages, Inc.
6. As a result of the conduct alleged herein, Anglim violated, and unless restrained
and enjoined will continue to violate, Section 17(a)(1) and (3) of the Securities Act of 1933
(“Securities Act”) [15 U.S.C. §77q(a)(1), (3)], Section 9(a)(1) of the Securities Exchange Act of
1934 (“Exchange Act”) [15 U.S.C. §78i(a)] and Section 10(b) of the Exchange Act and Rules

3

10b- 5(a) and (c) thereunder [[15 U.S.C. §§78j(b); 17 C.F.R. §240.10b-5(a), (c)].
7. The Commission seeks permanent injunctions against Anglim, enjoining him
from engaging in the transactions, acts, practices, and courses of business of the type alleged in
this Complaint, disgorgement of ill-gotten gains from the unlawful conduct set forth in this
Complaint pursuant to Section 21(d)(7) of the Exchange Act [15 U.S.C. §78u(d)(7)], together
with prejudgment interest, an order barring Anglim from participating in any offering of a penny
stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. §77t(g)] and/or 21(d) of the
Exchange Act [15 U.S.C. §78u(d)], and such other relief as the Court may deem appropriate.
JURISDICTION AND VENUE
8. This Court has jurisdiction over this action pursuant to Section 22(a) of the
Securities Act [15 U.S.C. §77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act [15
U.S.C  §78u(d), 78u(e) and 78aa].
9. Venue lies in this Court pursuant to Section 22(a) of the Securities Act [15 U.S.C.
§77v(a)] and Section 27 of the Exchange Act [15 U.S.C  §78aa].  Certain of the acts, practices,
transactions and courses of business alleged in this Complaint occurred with the District of
Massachusetts, and were effected, directly, or indirectly, by making use of means of
instrumentalities of transportations or communication in interstate commerce, or the mails.  For
example, during the periods of manipulative activity described in this Complaint, individuals
who reside in the Commonwealth of Massachusetts purchased the stock of Proto Script
Pharmaceuticals, Inc., Digatrade Financial Corp., Homie Recipes Inc., and Charlestowne
Premium Beverages, Inc.
THE DFENDANT
10. James P. Anglim, age 50, resides in Manasquan, New Jersey.  From May 2019

4

until October 2022, Anglim was a registered representative of a broker-dealer firm that was
registered with the Commission and that acted as a market maker dealing in OTC and other
securities.  From January 2015 to April 2019, Anglim was a registered representative of a second
broker-dealer firm that was also registered with the Commission and that also acted as a market
maker dealing in OTC and other securities.  Anglim was active in the financial services industry
as a broker-dealer registered representative between March 1998 and October 2022.
BACKGROUND
11. The stock involved in the scheme was “penny stock,” which generally refers to
companies with low market capitalizations, and with stock that trades at less than $5 per share.
Some of the stock involved in this scheme was “restricted stock” that was originally issued by a
company (the stock’s “issuer”) in a private transaction that was not registered with the
Commission.  Absent an exemption under the federal securities laws and rules, restricted stock
cannot legally be offered or sold to the public unless a securities registration statement has been
filed with the Commission (for an offer) or is in effect (for a sale).  Such registration statements
are often filed with the Commission on Form S-1 and are often referred to as “S-1 registration
statements.”  S-1 registration statements contain important information about an issuer’s business
operations, financial condition, results of operation, risk factors, and management.  They also
disclose any person or group who is the beneficial owner of more than 5% of the company’s
securities.
12. An “affiliate” of an issuer is a person or entity that directly or indirectly through
one or more intermediaries, controls, is controlled by, or is under common control with, such
issuer (i.e., a control person).  “Control” means the power to direct the management and policies
of the company in question.  Affiliates include officers, directors and controlling shareholders, as

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well as any person who is under “common control” with, or has common control of, an issuer.
As used herein, the term “Control Persons” means people or a group of people who collectively
were an “affiliate” of an issuer.
13. During the entire Relevant Period, Anglim worked at broker-dealer firms that
acted as market makers for certain securities.  Section 3(a)(38) of the Exchange Act defines a
market maker as “any specialist permitted to act as a dealer, any dealer acting in the capacity of
block positioner, and any dealer who, with respect to a security, holds himself out (by entering
quotations in an inter-dealer communications system or otherwise) as being willing to buy and
sell such security for his own account on a regular or continuous basis.”
14. A market maker provides market liquidity in an equity security by publicly
quoting both a buy and sell price in that equity security.  A market maker expects to profit by
receiving the difference between the highest price that a buyer is willing to pay for that stock and
the lowest price that a seller is willing to accept (called the “bid-ask spread”).
15. High stock price volatility or a lack of liquidity will tend to increase the size of
the bid-ask spread, while smaller spreads indicate higher liquidity.
16. The Over-the-Counter (“OTC”) Market is a stock quotation service that facilitates
public trading of shares in small companies that are not listed on national securities exchanges
(like NASDAQ or the New York Stock Exchange).  Stock traded on the OTC Market is often
thinly traded, meaning it trades at a lower volume and can therefore be susceptible to price
manipulation by undisclosed Control Persons, who secretly amass large amounts of stock.
17. “Public float” refers to the number of shares of an issuer’s stock that is on deposit
with broker-dealers and available for trading in the marketplace, including on the OTC Market.
An issuer’s public float is distinct from its total outstanding shares, which also includes restricted

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stock issued by the company but not available for public trading.
18. The buying and selling of penny stocks traded on the OTC Market relies on
brokerage firms that engage in market making activities.  Traders, like Anglim, involved in
making a market can facilitate investors’ orders during periods of high demand by engaging in
short selling, which is selling shares that the market maker does not yet own.  If the market
maker can sell short at one price, and later purchase shares at a lower price, the market maker
will earn a profit.  Anglim had a secret backchannel arrangement with certain Control Persons to
use the trading accounts at his brokerage firms to engage in market-making activity for stock
being sold in large amounts by the Control Persons.
FACTUAL ALLEGATIONS
19. During the Relevant Period, Anglim communicated regularly with certain Control
Persons that dominated the supply of stock for certain small publicly-traded companies.
Through the use of various nominee entities, the Control Persons held enough shares of stock to
be undisclosed affiliates of the issuer.  In numerous instances, the Control Persons did not
register the offer or sale of the shares they were selling and could not rely on an exemption from
registration.
20. The Control Persons engaged in deceptive schemes to make it appear that the
shares they actually controlled were owned by multiple unaffiliated entities when, in reality,
those entities held the stock as nominees for the Control Persons.  The Control Persons typically
controlled virtually all of the public float for each company in their respective schemes.  The
Control Persons then engaged in fraudulent schemes to mislead the market regarding their
ownership of the stock and to sell those millions of shares at manipulated prices through Anglim
under the cover of his firms’ market making activities.

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21. While the Control Persons were not actual customers of the broker-dealers firms
where Anglim worked, Anglim entered into arrangements with them to facilitate the sale of the
Control Persons’ shares through his firms.
22. Anglim communicated with these Control Persons using secure mobile
communications applications like WhatsApp and Silent Circle, an encrypted application with a
feature that allows users to destroy sensitive messages after a certain time.  These
communications methods were outside of his firms’ authorized methods of business
communications, were not monitored by his firms and were used to evade his firms’ monitoring
requirements.  Thus, Anglim’s communications with these Control Persons were not supervised
by his employers.
23. Anglim knew, or was at least reckless as to whether, the Control Persons with
whom he communicated controlled the supply, or public float, of the stock they asked him to
sell.  Anglim knew about, or was at least reckless as to the fact of, their control in part because
he was aware that these securities were infrequently traded, or did not trade at all, before he
began trading in them at the Control Persons’ requests.
24. In each instance, the Control Persons’ schemes began by accumulating enough of
an issuer’s shares that they controlled the public float, and depositing such shares with multiple
offshore brokerage firms, in the names of nominees, to disguise the Control Persons’ actual
ownership and control over those shares.  In certain instances, the Control Group then stoked
artificial demand for the issuer’s stock through manipulative trading and stock promotions using
aggressive sales communications or boiler rooms.
25. Retail investors then typically purchased the issuer’s stock on the basis of the
manipulated price and volume information, which retail investors typically rely upon to make

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investment decisions.
26. While he did not participate in the Control Persons’ stock promotions, Anglim’s
trading on behalf of the Control Persons made it appear to the market that the increase in trading
volume was solely the result of independent investors’ demand for the shares.
27. Anglim’s role in each deal was the same.  A Control Person initially tipped him
off that they, or their group, had shares to sell, indicating the number of shares that would be
available for purchase, and often specific prices Anglim should quote or a target bid price for the
company’s shares.
28. Anglim then sold short the shares of the company identified by the Control
Persons, through his firm’s proprietary trading accounts, at prices suggested by the Control
Persons.  Anglim traded with the expectation that he would cover his short position by
purchasing at the end of the day from the Control Persons who intended to liquidate huge blocks
of stock.
29. At the end of the trading day, Anglim typically arranged trades with Control
Persons to cover his short positions by buying from the Control Persons, often at pre-arranged
prices.  Once a Control Person had liquidated the number of shares he wanted to sell each day,
the Control Person told Anglim temporarily to stop placing trades in the stock.  Anglim
understood that the Control Persons’ limits were related to the quantity of shares their brokerage
firms would permit them to sell in a particular day.  Anglim obliged and would then wait for
instructions about when the Control Persons would have more shares available to sell, sometimes
referred to as “re-loading” more shares.
30. In addition, Anglim sometimes placed trades at prices directed by the Control
Persons to help manipulate the price of a stock or give the appearance of a more liquid market

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for the stock.  For example, Anglim was occasionally asked to, and did, place trades at the end of
the trading day to lift a stock’s price so that its reported “closing price” would be increased.
31. At other times, Anglim also used his firms’ trading accounts to make purchases at
the request of the Control Persons in order to manipulate increases in a stock’s price.  Anglim
also participated in several arranged “first trades” with Control Persons.  A first trade is the
initial trade in a stock, or a trade made in a security that has not been traded in a long time, often
after a major corporate action like a name change or stock split.
32. In addition to trading in his employers’ trading accounts, Anglim sometimes also
traded in his personal brokerage account in the stocks he was trading at the Control Persons’
request.  Anglim would sometimes buy shares in the companies he knew the Control Persons
were selling, and then would sell those shares during the Control Persons’ promotions.  As a
result, he reaped additional personal gains.
33. Some examples of the schemes are detailed below.
Example 1: Proto Script Pharmaceutical Corp.
34. By  December 2016, Control Persons led by Luis Carrillo
1
 (“Carrillo Control
Group”) had amassed over 85% of Proto Script Pharmaceutical Corp.’s (OTC: PSCR) (“Proto
Script”) purportedly unrestricted stock and deposited the shares with a Switzerland-based entity
called Wintercap SA,
2
 which claimed to be an asset manager.  Thus the Carrillo Control Group,

1
 Carrillo is a defendant in pending criminal and civil fraud cases.  See United States v. Sharp et al., No.
1:21-mj-07182-JCB-2 (D. Mass. filed Aug. 4, 2021); SEC v. Carrillo et. al., No. 1:21-cv-11272-WGY
(D. Mass. filed Aug. 4, 2021).
2
 The principal of Wintercap SA, Roger Knox, pled guilty to securities fraud and conspiracy to commit
securities fraud in connection with the activities of Wintercap SA that are described in the Complaint.
United States v. Knox, 18-cr-10385-NMG (D. Mass.) (guilty plea entered Jan. 13, 2020).  Knox and
Wintercap also consented to civil judgments imposing remedies for securities fraud.  See SEC v. Knox et.
al., No. 1:18-cv-12058 (D. Mass.) (judgments entered Dec. 21, 2022).

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through nominee accounts at Wintercap, controlled more than 85% of Proto Script’s public float.
35. On December 14, 2016, the Carrillo Control Group began promoting Proto
Script’s stock by hiring a boiler room based in Medellin, Colombia to solicit investors (the
“Medellin Room”).
3
  Though there was very little trading in Proto Script prior to the promotion,
over 5.8 million shares of Proto Script stock traded during the first three days of the promotion
from December 14 to 16, 2016.
36. The Carrillo Control Group’s efforts to promote Proto Script stock led to a
significant increase in the price and volume of that stock from December 2016 to February 2017,
as shown in the chart below.

37. Anglim first began actively quoting Proto Script stock on December 14, 2016

3
 The Commission filed civil fraud charges against five individuals in connection with the Medellin
Room.  See SEC v. Biller, et al., No. 1:22-cv-01406 (E.D.N.Y. filed March 14, 2022).
 -
 500,000
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PSCR -Price and Volume (Nov 2016 -Mar 2017
VolumeClose

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under his employer’s market maker code.  The Carrillo Control Group sold over 1.9 million
shares of Proto Script stock during the first three days of the promotion while Anglim, though his
firm, facilitated the Carrillo Control Group’s liquidation by buying and selling over 1.8 million
shares of Proto Script stock during the same time three-day span.
38. The Carrillo Control Group sold approximately 7 million shares of Proto Script
from December 14, 2016 through February 17, 2017 for a total of more than $2.8 million in
trading proceeds.  Anglim ceased trading in Proto Script stock shortly after the Carrillo Control
Group stopped selling Proto Script stock.
39. Approximately 97% of Anglim’s total sales volume of Proto Script stock was
conducted during the period of time in which the Carrillo Control Group was selling in
coordination with the Medellin Room promotion for which it paid.  Anglim’s last trade in Proto
Script was on March 6, 2017.  Between August 2016 and March 2017, Anglim’s firm’s
proprietary trading account bought and sold approximately 9.5 million shares of Proto Script,
which resulted in net trading profits of $145,126 to the firm, of which Anglim’s commission
constituted $72,563.
40. In addition to facilitating trades for the Carrillo Control Group through his
employer’s market making capabilities, Anglim also traded in advance of the Proto Script
promotion in his personal brokerage account.  Before the Carrillo Control Group’s promotion
began, Anglim bought 47,000 shares of Proto Script at $0.32 per share for a total of $15,040.
Anglim later sold his 47,000 shares of Proto Script during the promotional period (from
December 16, 2016 to January 10, 2017) for a total of $41,918, netting a profit of $26,878.
Combined with the $72,563 in commissions he received from his employer, Anglim’s profits
from trading in Proto Script for and with the Carrillo Control Group totaled $99,441.

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Example 2: Digatrade Financial Corp.
41. During the Relevant Period, Bradley J. Moynes
4
 was the Chief Executive Officer
and Chairman of Digatrade Financial Corp. (OTC: DIGAF) (“Digatrade”), a publicly traded
company based in Vancouver, British Columbia, Canada.
42. Between about September 2014 and April 2016, Moynes engaged in a fraudulent
scheme to sell Digatrade securities into the public markets while concealing his control of those
shares through nominee companies.  Moynes’ scheme used the services of Frederick Sharp and
his employees to sell his Digatrade shares illegally.
5
  Carrillo became involved in Moynes’
scheme in mid-2016.  In July and August 2016, Moynes took steps to re-establish his control
over the public float of Digatrade by decreasing the number of Digatrade’s shares and then
causing Digatrade to issue new, and purportedly unrestricted, shares to nominee entities that
Moynes and Carrillo could control.
43. By the end of 2016, Moynes, Carrillo and their associates (the “Digatrade Control
Group”) controlled approximately 97% of Digatrade’s public float and Moynes also controlled a
significant block of Digatrade’s restricted shares.  The Digatrade Control Group owned their
shares of the public float through various overseas brokerage accounts they controlled through
their associates.  The Digatrade Control Group then began to promote and sell the Digatrade

4
 The Commission charged and obtained judgments against Moynes and Digatrade in a separate case
alleging that they engaged in a deceptive scheme to hide their sales of Digatrade stock to unsuspecting
retail investors.  Without admitting or denying the allegations of the Commission's complaint, Moynes
and Digatrade consented to the entry of final judgments enjoining them from violating the securities laws.
The final judgments also imposed penny stock bars against Moynes and Digatrade and imposed an officer
and director bar, disgorgement, and a civil penalty against Moynes.  See SEC v. Moynes, et al., No. 1:22-
cv-11006 (D. Mass. judgments entered Mar. 8, 2023).
5
 Sharp and his associates are defendants in a Commission action alleging that they facilitated unlawful
stock sales to retail investors for many different Control Persons.  See SEC v. Sharp et al., No. 1:21-cv-
11276 (D. Mass. Filed Aug. 5, 2021).

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shares they controlled.
44. Carrillo hired the Medellin Room to solicit investors in a promotional campaign
that started on November 1, 2016.  In the two months prior to the promotion, trading in
Digatrade was sparse.  However, in the first two days of the Digatrade promotion, the price and
volume of Digatrade soared.
45. In particular, over two days, November 1 and 2, 2016, brokerage accounts
controlled by the Digatrade Control Group sold approximately 4.5 million shares of Digatrade
(over 50% of the company’s public float), generating approximately $2.3 million in trading
proceeds.  Despite that heavy selling, Digatrade’s stock price rose from a closing price of $0.13
per share on October 31, 2016 to a closing price of $0.59 per share on November 1, and peaked
at $0.96 per share on November 14, 2016, as reflected in the chart below.

 -
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 $-
 $0.20
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 $1.20
3-Oct-16
3-Nov-16
3-Dec-16
3-Jan-173-Feb-17
3-Mar-173-Apr-173-May-17
Digatrade Financial Corp (DIGAF)
-
Price and Volume
VolumeClose

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46. Through his firm’s proprietary trading account, Anglim initiated quoting on
Digatrade on the first day of the Digatrade Control Group’s promotion.  Trading records show
that Anglim’s firm was leading the bid price increases for Digatrade shares that day.  In other
words, Anglim offered to buy Digatrade shares in the market at increasing prices throughout the
day on November 1, 2016.
47. Over 8.2 million shares of Digatrade traded in the market during November 1-2,
2016 compared to less than 32,000 shares for the whole month of October.  Over those two days,
the Digatrade Control Group sold approximately 4.5 million shares of Digatrade and Anglim
facilitated their liquidation by buying and selling approximately 3 million shares of Digatrade
using his firm’s market maker trading account.
48. From November 1, 2016 through May 1, 2017, the period in which Anglim was
trading in Digatrade using his firm’s market maker trading account, the Digatrade Control Group
sold approximately 12.3 million shares of Digatrade for approximately $3.4 million in proceeds.
49. Anglim’s firm’s market maker trading account bought and sold approximately
11.2 million shares of Digatrade between November 2016 and May 2017 and the firm’s net
trading profit totaled $123,862, of which $61,931 was paid to Anglim in commissions.
50. Anglim also traded in Digatrade in his personal brokerage account.  On or about
December 6, 2016, after the initial promotion, Digatrade’s price dropped to a low of $0.28 a
share.  That day, Anglim bought on the dip in price by purchasing 98,000 shares of Digatrade at
an average price of $0.29 per share in his personal brokerage account.
51. On the same day, December 6, 2016, Anglim continued to trade Digatrade for the
Digatrade Control Group by buying 403,714 shares and selling 392,850 shares in his firm’s
proprietary trading account.  By the end of that day, the price had increased and Anglim switched

15

to selling Digatrade shares in his personal brokerage account.  That day, he sold 22,600
Digatrade shares at an average price of $0.37 per share, resulting in a single day gain of 29% per
share.
52. The total trading volume for Digatrade on December 6 amounted to 1,364,894
total shares, of which Anglim’s market making and personal trading accounted for 917,164
shares, or approximately 67% of total volume.  Digatrade shares closed at $0.40 on December 6,
2016, up 25% from the prior day’s close.
53. In his personal brokerage account, Anglim sold most of the rest of his shares of
Digatrade over the next week and by the end of December 2016, Anglim had made a total profit
of $14,222 on his initial $28,473 purchase of Digatrade shares.  Anglim’s Digatrade
commissions and personal trading profits thus totaled $76,153.
Example 3: 12 Retech Corporation
54. By the end of June 2017, Carrillo and his associates (the “12 Retech Control
Group”) controlled over 99% of the public float of 12 Retech Corporation (OTC: RETC) (“12
Retech”).  The 12 Retech Control Group held all of those shares through brokerage accounts in
the names of nominee entities at Wintercap SA.  The first-ever trading day of 12 Retech was on
June 27, 2017.  On that day, the 12 Retech Control Group began selling the shares of 12 Retech
that they controlled.
55. The efforts of the 12 Retech Control Group to sell their shares, most likely in
connection with promotional activities, was successful for a short time at increasing the price and
volume of 12 Retech shares, as shown in the chart below.

16

56. On June 27, 2017, Anglim first began actively acting as a market maker for 12
Retech through his firm’s account by quoting both bid and ask prices for that stock.
57. Communications among Carrillo and Wintercap SA personnel confirm that
Carrillo was directing Anglim’s firm regarding selling shares of 12 Retech.  In one September 1,
2017 communication using an encrypted application, a Wintercap employee messaged Carrillo,
“Want to chip away at some RETC today?” to which Carrillo replied, “I have MICA in there.
Will send order soon.”
58. MICA was the code word that Carrillo and Wintercap personnel used for Anglim.
About thirty minutes later, Carrillo wrote, “Sell 250k retc at .062.”  Indeed, Anglim and his firm
were active in trading 12 Retech that day – by buying a total of 165,900 shares at an average
price of $.062 per share and by selling 170,416 shares of 12 Retech at an average price of $.071
 -
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12 Retech Corporation (OTC: RETC)
-Price and Volume
VolumeClose

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per share.
59. Between June 27, 2017 and November 21, 2017, the 12 Retech Control Group
sold approximately 19.2 million shares of 12 Retech for total proceeds of approximately $8.2
million.  During the same period, Anglim facilitated the 12 Retech Control Group’s liquidation
by using his firm’s market maker trading account to buy and sell 12,635,964 shares of 12 Retech
for a net trading profit of $241,591, of which Anglim’s commissions amounted to $120,795.
Example 4: Homie Recipes Inc.
60.  As of August 1, 2017, Carrillo and his associates controlled over 99% of the
public float of Homie Recipes Inc. (OTC: HOMR) (“Homie”) shares through nominee entities
Carrillo had the authority to direct, including through Wintercap.
61. Carrillo and his associates began actively trading in Homie stock on August 4,
2017.  They continued to sell their shares through late September 2017.  As shown in the chart
below, the efforts of Carrillo and his associates to sell their shares of Homie stock, most likely in
connection with promotional activities, were successful in increasing the price and volume of
Homie stock.

18

62. The same day C arrillo began trading H omie stock, August 4, 2017, Anglim first
began acting as a market maker for Homie stock through his firm’s account by quoting both bid
and ask prices for that stock.  That day, Anglim bought 4,000 shares of Homie stock in his firm’s
market maker trading account at a price of $0.60 a share.  Four days later, on August 8, 2017,
Anglim sold those 4,000 shares for $1.05 per share.
63. Communications between Carrillo and Wintercap personnel confirm that Carrillo
was directing Anglim to buy and sell shares of Homie, like Carrillo had directed Anglim to trade
in 12 Retech.  In one September 11, 2017 communication using an encrypted application,
Carrillo, who was directing Wintercap’s sales of Homie stock, told Wintercap personnel that
“MICA was hungry,” indicating that Anglim had traded a significant number of Homie shares
that day.  Trading records for September 11, 2017 confirm that Anglim’s purchases and sales of

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Homie stock through his firm’s market maker trading account created volume of just over
400,000 shares that day.
64. Between August 4, 2017 and September 28, 2017, Carrillo sold approximately
11.84 million shares of Homie for total proceeds of approximately $5.2 million.  During the
same period, Anglim facilitated Carrillo’s liquidation by using his firm’s proprietary trading
account to buy and sell 6,245,077 shares of Homie stock for a net trading profit of $112,471, of
which Anglim’s commissions amounted to $56,235.
Example 5: Charlestowne Premium Beverages, Inc.
65. In December 2019 and January 2020, Charlestowne Premium Beverages, Inc.
(OTC: FPWM) (“Charlestowne”) issued two share certificates for 2,500,000 shares each to two
Hungarian companies: Wellesley Holdings, Ltd. and Porrima, Ltd., which were nominee entities
used by a securities law recidivist who, at the time, was paying for Charlestowne’s business
expenses.
6
  Though the shares were issued to Wellesley and Porrima as unrestricted shares, the
shares should have been restricted because Wellesley and Porrima were affiliates of
Charlestowne.  Wellesley and Porrima then deposited their shares with a Cayman Islands-based
broker-dealer named Valor Capital.
66. By early 2021, over 97% of Charlestowne’s float had been deposited with
accounts at Valor Capital.  Valor Capital was secretly controlled, in part, by Joseph Padilla, a
recidivist securities law violator.
7

6
 Both Wellesley and Porrima were charged by the Commission with securities fraud.  See SEC v. Page, et al, No.
1:21-cv-05294 (E.D.N.Y. filed Sept. 23, 2021).  The clerk has entered default against them and the Commission has
sought the entry of default judgments against them.
7
 Padilla has been charged twice by the Commission.  The first time, he was charged with violating the registration
provisions of the Securities Act.
 Padilla agreed to a settlement of that action, including a bar from association with
any broker-dealer.  See SEC v. Ruettiger et. al., No. 2:11-cv-02011 (D. Nev. filed Dec. 16, 2011).  More recently,

20

67. Charlestowne’s stock had very little trading activity until mid-February 2021.
From January 1, 2021 through February 17, 2021, trading in Charlestowne was very limited and
consisted of only 20 days of trading with average volume of 270 shares traded per day at prices
ranging from $0.36 - $0.58 per share.  On February 17, 2021, the price of Charlestowne’s stock
closed at $0.36 per share.
68. Beginning on February 18, 2021, Padilla orchestrated purchases of Charlestowne
shares through his own brokerage account, and at least 4 other brokerage accounts he controlled.
Padilla’s actions in making these purchases at progressively increasing prices caused
Charlestowne’s stock price to rise significantly.
69. Anglim also began publishing a quoted price for Charlestowne on behalf of his
firm during the day on February 18, 2021.  At Padilla’s direction, Anglim used his firm’s market
making trading account to purchase Charlestowne stock during that day.
70. Charlestowne’s stock price rose to $1.80 per share during the day on February 18,
2021 and closed at $0.90 per share (a 150% increase from the prior day) on 25,003 shares of
volume (nearly five times the total volume from January 1 – February 17).  Padilla -controlled
accounts were responsible for over 80% of the buy-side volume.
71. After increasing Charlestowne’s price through manipulative trading, Padilla then
began directing sales of Charlestowne stock from the Valor Capital accounts into the market.
Anglim began facilitating Padilla’s liquidation of Charlestowne stock starting on February 25,
2021 by acting as a market maker for Charlestowne stock through his firm’s account by quoting
both bid and ask prices for that stock.  On that day, Padilla directed sales of 28,000 shares of

the Commission sued Padilla for securities fraud, including conduct relating to Charlestowne.  See SEC v. Padilla et
al., No. 23-cv-11331-RGS (D. Mass. filed June 13, 2023).

21

Charlestowne stock at a price of $1.97 per share on behalf of Valor Capital.  Anglim sold short
and then bought 28,000 shares through his firm’s market making trading account at a price of
$1.97 per share.   Later that day, Padilla also directed sales of an additional 45,689 shares
through Valor Capital at an average price of $2.43 per share.
72. Valor Capital’s sales during March and April 2021 took place during a period
when Charlestowne Beverages was the subject of a promotional emails and online articles,
including those from companies named pennystockbargain.com and the-financialnews.com.  For
instance, an April 15, 2021 promotional article described Charlestowne Beverages stock as being
“poised to jump over 700%.”
73. The effects of Padilla’s and Anglim’s trading, in combination with the
promotions, are shown in the chart below.

 -
 200,000
 400,000
 600,000
 800,000
 1,000,000
 1,200,000
 1,400,000
 $-
 $1.00
 $2.00
 $3.00
 $4.00
 $5.00
 $6.00
 $7.00
 $8.00
 $9.00
Charlestowne Premium Beverages (FPWM) -Price and Volume
VolumeClose

22

74. Between February 22, 2021 and April 19, 2021, Padilla directed sales of
approximately 2.3 million shares of Charlestowne stock through Valor Capital accounts for
proceeds of over $7 million.  Between February 18 and May 5, 2021, Anglim used his firm’s
market making account to buy and sell    approximately 1.28 million shares of Charlestowne.  In
total, Anglim’s firm netted $106,734 in proceeds, of which $53,367 was paid in commissions to
Anglim.
FIRST CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
(Violations of Section 17(a)(1) and (3) of the Securities Act)

75. Paragraphs 1 through 74 above are re-alleged and incorporated by reference as if
fully set forth herein.
76. During the Relevant Period, the stock of Proto Script, Digatrade, 12 Retech,
Homie, and Charlestowne was each a security under Section 2(a)(1) of the Securities Act [15
U.S.C. §77b(a)(1)].
77. By reason of the conduct described above, Anglim, in the offer or sale of
securities, by the use of the means or instrumentalities of interstate commerce or of the mails,
directly or indirectly, acting with the requisite state of mind (i) employed devices, schemes, or
artifices to defraud; and (ii) engaged in transactions, practices, or courses of business which
operated or would operate as a fraud or deceit upon any persons, including purchasers or sellers
of the securities.
78. By reason of the conduct described above, Anglim violated Securities Act
Sections 17(a)(1) and (3) [15 U.S.C. §77q(a)(1) and (3)].
SECOND CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
(Violations of Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder)

23

79. Paragraphs 1 through 74 above are re-alleged and incorporated by reference as if
fully set forth herein.
80. During the Relevant Period, the stock of Proto Script, Digatrade, 12 Retech,
Homie, and Charlestowne was each a security under Section 3(a)(1) of the Exchange Act [15
U.S.C. §78c(a)(10)].
81. By reason of the conduct described above, Anglim, directly or indirectly, in
connection with the purchase or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, or of any facility of any national securities exchange,
intentionally, knowingly, or recklessly, (i) employed devices, schemes, or artifices to defraud;
and (ii) engaged in acts, practices, or courses of business which operated or would operate as a
fraud or deceit upon any persons, including purchasers or sellers of the securities.
82. By reason of the conduct described above, Anglim violated Exchange Act Section
10(b) [15 U.S.C. §78j(b)] and Rules 10b-5(a) and (c) [17 C.F.R §240.10b-5(a) and (c)]
thereunder.
THIRD CLAIM FOR RELIEF
MARKET MANIPULATION
(Violations of Section 9(a)(1) of the Exchange Act)

83. Paragraphs 1 through 74 above are re-alleged and incorporated by reference as if
fully set forth herein.
84. During the Relevant Period, the stock of Proto Script, Digatrade, 12 Retech,
Homie, and Charlestowne was each a security under Section 3(a)(1) of the Exchange Act [15
U.S.C. §78c(a)(10)].
85. By reason of the conduct described above, Anglim, directly or indirectly, by the
use of the mails or any means or instrumentality of interstate commerce, or of any facility of any

24

national securities exchange, for the purpose of creating a false or misleading appearance of
active trading in any security other than a government security, or a false or misleading
appearance with respect to the market for any such security: (A) effected any transaction in such
security which involves no change in the beneficial ownership thereof, or (B) entered an order or
orders for the purchase of such security with the knowledge that an order or orders of
substantially the same size, at substantially the same time, and at substantially the same price, for
the sale of any such security, has been or will be entered by or for the same or different parties,
or (C) entered any order or orders for the sale of any such security with the knowledge that an
order or orders of substantially the same size, at substantially the same time, and at substantially
the same price, for the purchase of such security, has been or will be entered by or for the same
or different parties.
86. By reason of the conduct described above, Anglim violated Exchange Act Section
9(a) [15 U.S.C. §78i(a)].
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully requests that this Court:
A. Permanently restrain Anglim, his agents, servants, employees and attorneys, and
those persons in active concert of participation with them who receive actual notice of the
injunction by personal services or otherwise, and each of them, from violating Section 17(a) of
the Securities Act [15 U.S.C. §77q(a)], and Sections 9(a) and 10(b) of the Exchange Act [15
U.S.C. §§78i(a), 78j(b)], and Rule 10b-5 thereunder [17 C.F.R §240.10b-5];
B. Order Anglim to disgorge, with prejudgment interest, all ill-gotten gains obtained
by reason of the unlawful conduct alleged in this Complaint, pursuant to Section 21(d)(7) of the
Exchange Act [15 U.S.C. §78u(d)(7)];

25

C. Enter an order barring Anglim from participating in any offering of a penny stock,
pursuant to Section 20(g) of the Securities Act [15 U.S.C. §77t(g)] and/or Section 21(d) of the
Exchange Act [15 U.S.C. §78u(d)];
D. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and
E. Grant such other further relief as the Court may deem just and proper.
JURY DEMAND
 The Commission demands a jury in this matter for all claims so triable.
DATED: July 17, 2023
      Respectfully submitted,
      /s/ Kathleen Burdette Shields
      Kathleen Burdette Shields (Mass Bar No. 637438)
      William J. Donahue (Mass Bar No. 631229)
      SECURITIES AND EXCHANGE COMMISSION
      Boston Regional Office
      33 Arch Street, 24
th
 Floor
      Boston, MA 02110
      Phone: (617) 573-8904 (Shields direct)
      (617) 573-8915 (Donahue direct)
(617) 573-4590 (fax)
      [email protected]
 (Shields email)
      [email protected] (Donahue email)

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 
 
SECURITIES AND EXCHANGE 
COMMISSION, 
   Plaintiff, 
 v. 
 
JAMES P. ANGLIM,  
 
   Defendant. 
 

 
 
      Civil Action No. 23-CV- 
 
 
 

 
COMPLAINT 

 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the 

following against defendant, James P. Anglim (“Anglim” or “Defendant”): 

SUMMARY 

1. This is a securities fraud enforcement action.  Starting in November 2016 and 

continuing through at least February 2022 (the “Relevant Period”), Anglim engaged in multiple 

deceptive and manipulative schemes to assist various people who controlled large blocks of 

public company stock (“Control Persons”) to sell that stock to investors in the public over-the-

counter (or “OTC”) markets while concealing that they were behind those sales.  

2. During the Relevant Period, Anglim was employed as a registered representative 

of two different United States-based brokerage firms that engaged in “market making” activities.  

A “market maker” is a broker-dealer firm that provides liquidity to stock markets by publicly 

quoting both a buy price (a “bid”) and a sell price (an “offer” or an “ask”) for stocks and offering 

to trade with the public at those prices.  Anglim’s job was to trade stocks on behalf of the two 

firms that employed him. 

3. Anglim abused his position as a trader working for market makers to facilitate the 

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 1 of 25



2 
 

illegal sale of stock into the public markets by several Control Persons in at least five different 

public companies’ shares.  Anglim’s conduct helped those Control Persons to dump large 

quantities of stock into the public markets while concealing that they were the source of all of 

those sales, thus avoiding disclosure requirements imposed by the federal securities laws.  The 

Control Persons were not customers of the brokerage firms where Anglim was employed.  

Nonetheless, Anglim entered into repeated arrangements with several Control Persons whereby: 

1) the Control Persons would tell Anglim they wanted to sell a particular company’s stock, how 

much they wanted to sell, and often at what prices they wanted to sell; 2) Anglim would use his 

position as a trader at a market maker firm to sell short the shares of that company’s stock, at 

prices directed by the Control Persons; and 3) Anglim would cover his short positions in that 

company’s stock by arranging with the Control Persons to purchase shares of that company’s 

stock from them -- often at pre-arranged prices.   

4. Anglim’s trading often resulted in riskless profits for him and for his employers 

and facilitated the Control Persons’ dumping of their shares at manipulated prices into the 

market. 

5. On behalf of Control Persons, Anglim engaged in at least $53.85 million of 

trading in the securities of at least the following companies: Proto Script Pharmaceutical Corp., 

Digatrade Financial Corp., 12 Retech Corp., Homie Recipes Inc. and Charlestowne Premium 

Beverages, Inc. 

6. As a result of the conduct alleged herein, Anglim violated, and unless restrained 

and enjoined will continue to violate, Section 17(a)(1) and (3) of the Securities Act of 1933 

(“Securities Act”) [15 U.S.C. §77q(a)(1), (3)], Section 9(a)(1) of the Securities Exchange Act of 

1934 (“Exchange Act”) [15 U.S.C. §78i(a)] and Section 10(b) of the Exchange Act and Rules 

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 2 of 25



3 
 

10b- 5(a) and (c) thereunder [[15 U.S.C. §§78j(b); 17 C.F.R. §240.10b-5(a), (c)]. 

7. The Commission seeks permanent injunctions against Anglim, enjoining him 

from engaging in the transactions, acts, practices, and courses of business of the type alleged in 

this Complaint, disgorgement of ill-gotten gains from the unlawful conduct set forth in this 

Complaint pursuant to Section 21(d)(7) of the Exchange Act [15 U.S.C. §78u(d)(7)], together 

with prejudgment interest, an order barring Anglim from participating in any offering of a penny 

stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. §77t(g)] and/or 21(d) of the 

Exchange Act [15 U.S.C. §78u(d)], and such other relief as the Court may deem appropriate. 

JURISDICTION AND VENUE 

8. This Court has jurisdiction over this action pursuant to Section 22(a) of the 

Securities Act [15 U.S.C. §77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act [15 

U.S.C  §78u(d), 78u(e) and 78aa].   

9. Venue lies in this Court pursuant to Section 22(a) of the Securities Act [15 U.S.C. 

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

transactions and courses of business alleged in this Complaint occurred with the District of 

Massachusetts, and were effected, directly, or indirectly, by making use of means of 

instrumentalities of transportations or communication in interstate commerce, or the mails.  For 

example, during the periods of manipulative activity described in this Complaint, individuals 

who reside in the Commonwealth of Massachusetts purchased the stock of Proto Script 

Pharmaceuticals, Inc., Digatrade Financial Corp., Homie Recipes Inc., and Charlestowne 

Premium Beverages, Inc. 

THE DFENDANT 

10. James P. Anglim, age 50, resides in Manasquan, New Jersey.  From May 2019 

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 3 of 25



4 
 

until October 2022, Anglim was a registered representative of a broker-dealer firm that was 

registered with the Commission and that acted as a market maker dealing in OTC and other 

securities.  From January 2015 to April 2019, Anglim was a registered representative of a second 

broker-dealer firm that was also registered with the Commission and that also acted as a market 

maker dealing in OTC and other securities.  Anglim was active in the financial services industry 

as a broker-dealer registered representative between March 1998 and October 2022. 

BACKGROUND 

11. The stock involved in the scheme was “penny stock,” which generally refers to 

companies with low market capitalizations, and with stock that trades at less than $5 per share.  

Some of the stock involved in this scheme was “restricted stock” that was originally issued by a 

company (the stock’s “issuer”) in a private transaction that was not registered with the 

Commission.  Absent an exemption under the federal securities laws and rules, restricted stock 

cannot legally be offered or sold to the public unless a securities registration statement has been 

filed with the Commission (for an offer) or is in effect (for a sale).  Such registration statements 

are often filed with the Commission on Form S-1 and are often referred to as “S-1 registration 

statements.”  S-1 registration statements contain important information about an issuer’s business 

operations, financial condition, results of operation, risk factors, and management.  They also 

disclose any person or group who is the beneficial owner of more than 5% of the company’s 

securities.   

12. An “affiliate” of an issuer is a person or entity that directly or indirectly through 

one or more intermediaries, controls, is controlled by, or is under common control with, such 

issuer (i.e., a control person).  “Control” means the power to direct the management and policies 

of the company in question.  Affiliates include officers, directors and controlling shareholders, as 

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 4 of 25



5 
 

well as any person who is under “common control” with, or has common control of, an issuer.  

As used herein, the term “Control Persons” means people or a group of people who collectively 

were an “affiliate” of an issuer. 

13. During the entire Relevant Period, Anglim worked at broker-dealer firms that 

acted as market makers for certain securities.  Section 3(a)(38) of the Exchange Act defines a 

market maker as “any specialist permitted to act as a dealer, any dealer acting in the capacity of 

block positioner, and any dealer who, with respect to a security, holds himself out (by entering 

quotations in an inter-dealer communications system or otherwise) as being willing to buy and 

sell such security for his own account on a regular or continuous basis.”   

14. A market maker provides market liquidity in an equity security by publicly 

quoting both a buy and sell price in that equity security.  A market maker expects to profit by 

receiving the difference between the highest price that a buyer is willing to pay for that stock and 

the lowest price that a seller is willing to accept (called the “bid-ask spread”).   

15. High stock price volatility or a lack of liquidity will tend to increase the size of 

the bid-ask spread, while smaller spreads indicate higher liquidity. 

16. The Over-the-Counter (“OTC”) Market is a stock quotation service that facilitates 

public trading of shares in small companies that are not listed on national securities exchanges 

(like NASDAQ or the New York Stock Exchange).  Stock traded on the OTC Market is often 

thinly traded, meaning it trades at a lower volume and can therefore be susceptible to price 

manipulation by undisclosed Control Persons, who secretly amass large amounts of stock. 

17. “Public float” refers to the number of shares of an issuer’s stock that is on deposit 

with broker-dealers and available for trading in the marketplace, including on the OTC Market.  

An issuer’s public float is distinct from its total outstanding shares, which also includes restricted 

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6 
 

stock issued by the company but not available for public trading.     

18. The buying and selling of penny stocks traded on the OTC Market relies on 

brokerage firms that engage in market making activities.  Traders, like Anglim, involved in 

making a market can facilitate investors’ orders during periods of high demand by engaging in 

short selling, which is selling shares that the market maker does not yet own.  If the market 

maker can sell short at one price, and later purchase shares at a lower price, the market maker 

will earn a profit.  Anglim had a secret backchannel arrangement with certain Control Persons to 

use the trading accounts at his brokerage firms to engage in market-making activity for stock 

being sold in large amounts by the Control Persons. 

FACTUAL ALLEGATIONS 

19. During the Relevant Period, Anglim communicated regularly with certain Control 

Persons that dominated the supply of stock for certain small publicly-traded companies.  

Through the use of various nominee entities, the Control Persons held enough shares of stock to 

be undisclosed affiliates of the issuer.  In numerous instances, the Control Persons did not 

register the offer or sale of the shares they were selling and could not rely on an exemption from 

registration.     

20. The Control Persons engaged in deceptive schemes to make it appear that the 

shares they actually controlled were owned by multiple unaffiliated entities when, in reality, 

those entities held the stock as nominees for the Control Persons.  The Control Persons typically 

controlled virtually all of the public float for each company in their respective schemes.  The 

Control Persons then engaged in fraudulent schemes to mislead the market regarding their 

ownership of the stock and to sell those millions of shares at manipulated prices through Anglim 

under the cover of his firms’ market making activities.  

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 6 of 25



7 
 

21. While the Control Persons were not actual customers of the broker-dealers firms 

where Anglim worked, Anglim entered into arrangements with them to facilitate the sale of the 

Control Persons’ shares through his firms.   

22. Anglim communicated with these Control Persons using secure mobile 

communications applications like WhatsApp and Silent Circle, an encrypted application with a 

feature that allows users to destroy sensitive messages after a certain time.  These 

communications methods were outside of his firms’ authorized methods of business 

communications, were not monitored by his firms and were used to evade his firms’ monitoring 

requirements.  Thus, Anglim’s communications with these Control Persons were not supervised 

by his employers. 

23. Anglim knew, or was at least reckless as to whether, the Control Persons with 

whom he communicated controlled the supply, or public float, of the stock they asked him to 

sell.  Anglim knew about, or was at least reckless as to the fact of, their control in part because 

he was aware that these securities were infrequently traded, or did not trade at all, before he 

began trading in them at the Control Persons’ requests. 

24. In each instance, the Control Persons’ schemes began by accumulating enough of 

an issuer’s shares that they controlled the public float, and depositing such shares with multiple 

offshore brokerage firms, in the names of nominees, to disguise the Control Persons’ actual 

ownership and control over those shares.  In certain instances, the Control Group then stoked 

artificial demand for the issuer’s stock through manipulative trading and stock promotions using 

aggressive sales communications or boiler rooms.   

25. Retail investors then typically purchased the issuer’s stock on the basis of the 

manipulated price and volume information, which retail investors typically rely upon to make 

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 7 of 25



8 
 

investment decisions.     

26. While he did not participate in the Control Persons’ stock promotions, Anglim’s 

trading on behalf of the Control Persons made it appear to the market that the increase in trading 

volume was solely the result of independent investors’ demand for the shares. 

27. Anglim’s role in each deal was the same.  A Control Person initially tipped him 

off that they, or their group, had shares to sell, indicating the number of shares that would be 

available for purchase, and often specific prices Anglim should quote or a target bid price for the 

company’s shares.   

28. Anglim then sold short the shares of the company identified by the Control 

Persons, through his firm’s proprietary trading accounts, at prices suggested by the Control 

Persons.  Anglim traded with the expectation that he would cover his short position by 

purchasing at the end of the day from the Control Persons who intended to liquidate huge blocks 

of stock.    

29. At the end of the trading day, Anglim typically arranged trades with Control 

Persons to cover his short positions by buying from the Control Persons, often at pre-arranged 

prices.  Once a Control Person had liquidated the number of shares he wanted to sell each day, 

the Control Person told Anglim temporarily to stop placing trades in the stock.  Anglim 

understood that the Control Persons’ limits were related to the quantity of shares their brokerage 

firms would permit them to sell in a particular day.  Anglim obliged and would then wait for 

instructions about when the Control Persons would have more shares available to sell, sometimes 

referred to as “re-loading” more shares.  

30. In addition, Anglim sometimes placed trades at prices directed by the Control 

Persons to help manipulate the price of a stock or give the appearance of a more liquid market 

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 8 of 25



9 
 

for the stock.  For example, Anglim was occasionally asked to, and did, place trades at the end of 

the trading day to lift a stock’s price so that its reported “closing price” would be increased. 

31. At other times, Anglim also used his firms’ trading accounts to make purchases at 

the request of the Control Persons in order to manipulate increases in a stock’s price.  Anglim 

also participated in several arranged “first trades” with Control Persons.  A first trade is the 

initial trade in a stock, or a trade made in a security that has not been traded in a long time, often 

after a major corporate action like a name change or stock split. 

32. In addition to trading in his employers’ trading accounts, Anglim sometimes also 

traded in his personal brokerage account in the stocks he was trading at the Control Persons’ 

request.  Anglim would sometimes buy shares in the companies he knew the Control Persons 

were selling, and then would sell those shares during the Control Persons’ promotions.  As a 

result, he reaped additional personal gains. 

33. Some examples of the schemes are detailed below. 

Example 1: Proto Script Pharmaceutical Corp. 

34. By  December 2016, Control Persons led by Luis Carrillo1 (“Carrillo Control 

Group”) had amassed over 85% of Proto Script Pharmaceutical Corp.’s (OTC: PSCR) (“Proto 

Script”) purportedly unrestricted stock and deposited the shares with a Switzerland-based entity 

called Wintercap SA,2 which claimed to be an asset manager.  Thus the Carrillo Control Group, 

                                                           
1 Carrillo is a defendant in pending criminal and civil fraud cases.  See United States v. Sharp et al., No. 
1:21-mj-07182-JCB-2 (D. Mass. filed Aug. 4, 2021); SEC v. Carrillo et. al., No. 1:21-cv-11272-WGY 
(D. Mass. filed Aug. 4, 2021). 

2 The principal of Wintercap SA, Roger Knox, pled guilty to securities fraud and conspiracy to commit 
securities fraud in connection with the activities of Wintercap SA that are described in the Complaint.  
United States v. Knox, 18-cr-10385-NMG (D. Mass.) (guilty plea entered Jan. 13, 2020).  Knox and 
Wintercap also consented to civil judgments imposing remedies for securities fraud.  See SEC v. Knox et. 
al., No. 1:18-cv-12058 (D. Mass.) (judgments entered Dec. 21, 2022). 

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 9 of 25



10 
 

through nominee accounts at Wintercap, controlled more than 85% of Proto Script’s public float.  

35. On December 14, 2016, the Carrillo Control Group began promoting Proto 

Script’s stock by hiring a boiler room based in Medellin, Colombia to solicit investors (the 

“Medellin Room”).3  Though there was very little trading in Proto Script prior to the promotion, 

over 5.8 million shares of Proto Script stock traded during the first three days of the promotion 

from December 14 to 16, 2016. 

36. The Carrillo Control Group’s efforts to promote Proto Script stock led to a 

significant increase in the price and volume of that stock from December 2016 to February 2017, 

as shown in the chart below.  

 

37. Anglim first began actively quoting Proto Script stock on December 14, 2016 

                                                           
3 The Commission filed civil fraud charges against five individuals in connection with the Medellin 
Room.  See SEC v. Biller, et al., No. 1:22-cv-01406 (E.D.N.Y. filed March 14, 2022).   

 -

 500,000

 1,000,000

 1,500,000

 2,000,000

 2,500,000

 3,000,000

 3,500,000

 $-

 $0.50

 $1.00

 $1.50

 $2.00

 $2.50

PSCR - Price and Volume (Nov 2016 - Mar 2017

Volume Close

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 10 of 25



11 
 

under his employer’s market maker code.  The Carrillo Control Group sold over 1.9 million 

shares of Proto Script stock during the first three days of the promotion while Anglim, though his 

firm, facilitated the Carrillo Control Group’s liquidation by buying and selling over 1.8 million 

shares of Proto Script stock during the same time three-day span.   

38. The Carrillo Control Group sold approximately 7 million shares of Proto Script 

from December 14, 2016 through February 17, 2017 for a total of more than $2.8 million in 

trading proceeds.  Anglim ceased trading in Proto Script stock shortly after the Carrillo Control 

Group stopped selling Proto Script stock.   

39. Approximately 97% of Anglim’s total sales volume of Proto Script stock was 

conducted during the period of time in which the Carrillo Control Group was selling in 

coordination with the Medellin Room promotion for which it paid.  Anglim’s last trade in Proto 

Script was on March 6, 2017.  Between August 2016 and March 2017, Anglim’s firm’s 

proprietary trading account bought and sold approximately 9.5 million shares of Proto Script, 

which resulted in net trading profits of $145,126 to the firm, of which Anglim’s commission 

constituted $72,563. 

40. In addition to facilitating trades for the Carrillo Control Group through his 

employer’s market making capabilities, Anglim also traded in advance of the Proto Script 

promotion in his personal brokerage account.  Before the Carrillo Control Group’s promotion 

began, Anglim bought 47,000 shares of Proto Script at $0.32 per share for a total of $15,040.  

Anglim later sold his 47,000 shares of Proto Script during the promotional period (from 

December 16, 2016 to January 10, 2017) for a total of $41,918, netting a profit of $26,878.  

Combined with the $72,563 in commissions he received from his employer, Anglim’s profits 

from trading in Proto Script for and with the Carrillo Control Group totaled $99,441. 

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Example 2: Digatrade Financial Corp. 

41. During the Relevant Period, Bradley J. Moynes4 was the Chief Executive Officer 

and Chairman of Digatrade Financial Corp. (OTC: DIGAF) (“Digatrade”), a publicly traded 

company based in Vancouver, British Columbia, Canada.   

42. Between about September 2014 and April 2016, Moynes engaged in a fraudulent 

scheme to sell Digatrade securities into the public markets while concealing his control of those 

shares through nominee companies.  Moynes’ scheme used the services of Frederick Sharp and 

his employees to sell his Digatrade shares illegally.5  Carrillo became involved in Moynes’ 

scheme in mid-2016.  In July and August 2016, Moynes took steps to re-establish his control 

over the public float of Digatrade by decreasing the number of Digatrade’s shares and then 

causing Digatrade to issue new, and purportedly unrestricted, shares to nominee entities that 

Moynes and Carrillo could control.  

43. By the end of 2016, Moynes, Carrillo and their associates (the “Digatrade Control 

Group”) controlled approximately 97% of Digatrade’s public float and Moynes also controlled a 

significant block of Digatrade’s restricted shares.  The Digatrade Control Group owned their 

shares of the public float through various overseas brokerage accounts they controlled through 

their associates.  The Digatrade Control Group then began to promote and sell the Digatrade 

                                                           
4 The Commission charged and obtained judgments against Moynes and Digatrade in a separate case 
alleging that they engaged in a deceptive scheme to hide their sales of Digatrade stock to unsuspecting 
retail investors.  Without admitting or denying the allegations of the Commission's complaint, Moynes 
and Digatrade consented to the entry of final judgments enjoining them from violating the securities laws.  
The final judgments also imposed penny stock bars against Moynes and Digatrade and imposed an officer 
and director bar, disgorgement, and a civil penalty against Moynes.  See SEC v. Moynes, et al., No. 1:22-
cv-11006 (D. Mass. judgments entered Mar. 8, 2023).  

5 Sharp and his associates are defendants in a Commission action alleging that they facilitated unlawful 
stock sales to retail investors for many different Control Persons.  See SEC v. Sharp et al., No. 1:21-cv-
11276 (D. Mass. Filed Aug. 5, 2021). 

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13 
 

shares they controlled.   

44. Carrillo hired the Medellin Room to solicit investors in a promotional campaign 

that started on November 1, 2016.  In the two months prior to the promotion, trading in 

Digatrade was sparse.  However, in the first two days of the Digatrade promotion, the price and 

volume of Digatrade soared.   

45. In particular, over two days, November 1 and 2, 2016, brokerage accounts 

controlled by the Digatrade Control Group sold approximately 4.5 million shares of Digatrade 

(over 50% of the company’s public float), generating approximately $2.3 million in trading 

proceeds.  Despite that heavy selling, Digatrade’s stock price rose from a closing price of $0.13 

per share on October 31, 2016 to a closing price of $0.59 per share on November 1, and peaked 

at $0.96 per share on November 14, 2016, as reflected in the chart below. 

 

 -

 1,000,000

 2,000,000

 3,000,000

 4,000,000

 5,000,000

 6,000,000

 $-

 $0.20

 $0.40

 $0.60

 $0.80

 $1.00

 $1.20

3-Oct-16 3-Nov-16 3-Dec-16 3-Jan-17 3-Feb-17 3-Mar-17 3-Apr-17 3-May-17

Digatrade Financial Corp (DIGAF) - Price and Volume

Volume Close

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46. Through his firm’s proprietary trading account, Anglim initiated quoting on 

Digatrade on the first day of the Digatrade Control Group’s promotion.  Trading records show 

that Anglim’s firm was leading the bid price increases for Digatrade shares that day.  In other 

words, Anglim offered to buy Digatrade shares in the market at increasing prices throughout the 

day on November 1, 2016.   

47. Over 8.2 million shares of Digatrade traded in the market during November 1-2, 

2016 compared to less than 32,000 shares for the whole month of October.  Over those two days, 

the Digatrade Control Group sold approximately 4.5 million shares of Digatrade and Anglim 

facilitated their liquidation by buying and selling approximately 3 million shares of Digatrade 

using his firm’s market maker trading account.   

48. From November 1, 2016 through May 1, 2017, the period in which Anglim was 

trading in Digatrade using his firm’s market maker trading account, the Digatrade Control Group 

sold approximately 12.3 million shares of Digatrade for approximately $3.4 million in proceeds. 

49. Anglim’s firm’s market maker trading account bought and sold approximately 

11.2 million shares of Digatrade between November 2016 and May 2017 and the firm’s net 

trading profit totaled $123,862, of which $61,931 was paid to Anglim in commissions. 

50. Anglim also traded in Digatrade in his personal brokerage account.  On or about 

December 6, 2016, after the initial promotion, Digatrade’s price dropped to a low of $0.28 a 

share.  That day, Anglim bought on the dip in price by purchasing 98,000 shares of Digatrade at 

an average price of $0.29 per share in his personal brokerage account.   

51. On the same day, December 6, 2016, Anglim continued to trade Digatrade for the 

Digatrade Control Group by buying 403,714 shares and selling 392,850 shares in his firm’s 

proprietary trading account.  By the end of that day, the price had increased and Anglim switched 

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to selling Digatrade shares in his personal brokerage account.  That day, he sold 22,600 

Digatrade shares at an average price of $0.37 per share, resulting in a single day gain of 29% per 

share.   

52. The total trading volume for Digatrade on December 6 amounted to 1,364,894 

total shares, of which Anglim’s market making and personal trading accounted for 917,164 

shares, or approximately 67% of total volume.  Digatrade shares closed at $0.40 on December 6, 

2016, up 25% from the prior day’s close.  

53. In his personal brokerage account, Anglim sold most of the rest of his shares of 

Digatrade over the next week and by the end of December 2016, Anglim had made a total profit 

of $14,222 on his initial $28,473 purchase of Digatrade shares.  Anglim’s Digatrade 

commissions and personal trading profits thus totaled $76,153. 

Example 3: 12 Retech Corporation 

54. By the end of June 2017, Carrillo and his associates (the “12 Retech Control 

Group”) controlled over 99% of the public float of 12 Retech Corporation (OTC: RETC) (“12 

Retech”).  The 12 Retech Control Group held all of those shares through brokerage accounts in 

the names of nominee entities at Wintercap SA.  The first-ever trading day of 12 Retech was on 

June 27, 2017.  On that day, the 12 Retech Control Group began selling the shares of 12 Retech 

that they controlled. 

55. The efforts of the 12 Retech Control Group to sell their shares, most likely in 

connection with promotional activities, was successful for a short time at increasing the price and 

volume of 12 Retech shares, as shown in the chart below.   

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56. On June 27, 2017, Anglim first began actively acting as a market maker for 12 

Retech through his firm’s account by quoting both bid and ask prices for that stock.  

57. Communications among Carrillo and Wintercap SA personnel confirm that 

Carrillo was directing Anglim’s firm regarding selling shares of 12 Retech.  In one September 1, 

2017 communication using an encrypted application, a Wintercap employee messaged Carrillo, 

“Want to chip away at some RETC today?” to which Carrillo replied, “I have MICA in there.  

Will send order soon.”  

58. MICA was the code word that Carrillo and Wintercap personnel used for Anglim.  

About thirty minutes later, Carrillo wrote, “Sell 250k retc at .062.”  Indeed, Anglim and his firm 

were active in trading 12 Retech that day – by buying a total of 165,900 shares at an average 

price of $.062 per share and by selling 170,416 shares of 12 Retech at an average price of $.071 

 -

 2,000,000

 4,000,000

 6,000,000

 8,000,000

 10,000,000

 12,000,000

 14,000,000

 $-

 $0.50

 $1.00

 $1.50

 $2.00

 $2.50

 $3.00

12 Retech Corporation (OTC: RETC) - Price and Volume

Volume Close

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per share.   

59. Between June 27, 2017 and November 21, 2017, the 12 Retech Control Group 

sold approximately 19.2 million shares of 12 Retech for total proceeds of approximately $8.2 

million.  During the same period, Anglim facilitated the 12 Retech Control Group’s liquidation 

by using his firm’s market maker trading account to buy and sell 12,635,964 shares of 12 Retech 

for a net trading profit of $241,591, of which Anglim’s commissions amounted to $120,795. 

Example 4: Homie Recipes Inc.  

60.  As of August 1, 2017, Carrillo and his associates controlled over 99% of the 

public float of Homie Recipes Inc. (OTC: HOMR) (“Homie”) shares through nominee entities 

Carrillo had the authority to direct, including through Wintercap.    

61. Carrillo and his associates began actively trading in Homie stock on August 4, 

2017.  They continued to sell their shares through late September 2017.  As shown in the chart 

below, the efforts of Carrillo and his associates to sell their shares of Homie stock, most likely in 

connection with promotional activities, were successful in increasing the price and volume of 

Homie stock. 

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62. The same day Carrillo began trading Homie stock, August 4, 2017, Anglim first 

began acting as a market maker for Homie stock through his firm’s account by quoting both bid 

and ask prices for that stock.  That day, Anglim bought 4,000 shares of Homie stock in his firm’s 

market maker trading account at a price of $0.60 a share.  Four days later, on August 8, 2017, 

Anglim sold those 4,000 shares for $1.05 per share. 

63. Communications between Carrillo and Wintercap personnel confirm that Carrillo 

was directing Anglim to buy and sell shares of Homie, like Carrillo had directed Anglim to trade 

in 12 Retech.  In one September 11, 2017 communication using an encrypted application, 

Carrillo, who was directing Wintercap’s sales of Homie stock, told Wintercap personnel that 

“MICA was hungry,” indicating that Anglim had traded a significant number of Homie shares 

that day.  Trading records for September 11, 2017 confirm that Anglim’s purchases and sales of 

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Homie stock through his firm’s market maker trading account created volume of just over 

400,000 shares that day.   

64. Between August 4, 2017 and September 28, 2017, Carrillo sold approximately 

11.84 million shares of Homie for total proceeds of approximately $5.2 million.  During the 

same period, Anglim facilitated Carrillo’s liquidation by using his firm’s proprietary trading 

account to buy and sell 6,245,077 shares of Homie stock for a net trading profit of $112,471, of 

which Anglim’s commissions amounted to $56,235. 

Example 5: Charlestowne Premium Beverages, Inc. 

65. In December 2019 and January 2020, Charlestowne Premium Beverages, Inc. 

(OTC: FPWM) (“Charlestowne”) issued two share certificates for 2,500,000 shares each to two 

Hungarian companies: Wellesley Holdings, Ltd. and Porrima, Ltd., which were nominee entities 

used by a securities law recidivist who, at the time, was paying for Charlestowne’s business 

expenses.6  Though the shares were issued to Wellesley and Porrima as unrestricted shares, the 

shares should have been restricted because Wellesley and Porrima were affiliates of 

Charlestowne.  Wellesley and Porrima then deposited their shares with a Cayman Islands-based 

broker-dealer named Valor Capital.   

66. By early 2021, over 97% of Charlestowne’s float had been deposited with 

accounts at Valor Capital.  Valor Capital was secretly controlled, in part, by Joseph Padilla, a 

recidivist securities law violator.7   

                                                           
6 Both Wellesley and Porrima were charged by the Commission with securities fraud.  See SEC v. Page, et al, No. 
1:21-cv-05294 (E.D.N.Y. filed Sept. 23, 2021).  The clerk has entered default against them and the Commission has 
sought the entry of default judgments against them.  

7 Padilla has been charged twice by the Commission.  The first time, he was charged with violating the registration 
provisions of the Securities Act. Padilla agreed to a settlement of that action, including a bar from association with 
any broker-dealer.  See SEC v. Ruettiger et. al., No. 2:11-cv-02011 (D. Nev. filed Dec. 16, 2011).  More recently, 

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67. Charlestowne’s stock had very little trading activity until mid-February 2021.  

From January 1, 2021 through February 17, 2021, trading in Charlestowne was very limited and 

consisted of only 20 days of trading with average volume of 270 shares traded per day at prices 

ranging from $0.36 - $0.58 per share.  On February 17, 2021, the price of Charlestowne’s stock 

closed at $0.36 per share.  

68. Beginning on February 18, 2021, Padilla orchestrated purchases of Charlestowne 

shares through his own brokerage account, and at least 4 other brokerage accounts he controlled.  

Padilla’s actions in making these purchases at progressively increasing prices caused 

Charlestowne’s stock price to rise significantly.   

69. Anglim also began publishing a quoted price for Charlestowne on behalf of his 

firm during the day on February 18, 2021.  At Padilla’s direction, Anglim used his firm’s market 

making trading account to purchase Charlestowne stock during that day.     

70. Charlestowne’s stock price rose to $1.80 per share during the day on February 18, 

2021 and closed at $0.90 per share (a 150% increase from the prior day) on 25,003 shares of 

volume (nearly five times the total volume from January 1 – February 17).  Padilla -controlled 

accounts were responsible for over 80% of the buy-side volume.   

71. After increasing Charlestowne’s price through manipulative trading, Padilla then 

began directing sales of Charlestowne stock from the Valor Capital accounts into the market.  

Anglim began facilitating Padilla’s liquidation of Charlestowne stock starting on February 25, 

2021 by acting as a market maker for Charlestowne stock through his firm’s account by quoting 

both bid and ask prices for that stock.  On that day, Padilla directed sales of 28,000 shares of 

                                                           
the Commission sued Padilla for securities fraud, including conduct relating to Charlestowne.  See SEC v. Padilla et 
al., No. 23-cv-11331-RGS (D. Mass. filed June 13, 2023).   

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Charlestowne stock at a price of $1.97 per share on behalf of Valor Capital.  Anglim sold short 

and then bought 28,000 shares through his firm’s market making trading account at a price of 

$1.97 per share.   Later that day, Padilla also directed sales of an additional 45,689 shares 

through Valor Capital at an average price of $2.43 per share. 

72. Valor Capital’s sales during March and April 2021 took place during a period 

when Charlestowne Beverages was the subject of a promotional emails and online articles, 

including those from companies named pennystockbargain.com and the-financialnews.com.  For 

instance, an April 15, 2021 promotional article described Charlestowne Beverages stock as being 

“poised to jump over 700%.”  

73. The effects of Padilla’s and Anglim’s trading, in combination with the 

promotions, are shown in the chart below. 

 

 -

 200,000

 400,000

 600,000

 800,000

 1,000,000

 1,200,000

 1,400,000

 $-

 $1.00

 $2.00

 $3.00

 $4.00

 $5.00

 $6.00

 $7.00

 $8.00

 $9.00

Charlestowne Premium Beverages (FPWM) - Price and Volume

Volume Close

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74. Between February 22, 2021 and April 19, 2021, Padilla directed sales of 

approximately 2.3 million shares of Charlestowne stock through Valor Capital accounts for 

proceeds of over $7 million.  Between February 18 and May 5, 2021, Anglim used his firm’s 

market making account to buy and sell approximately 1.28 million shares of Charlestowne.  In 

total, Anglim’s firm netted $106,734 in proceeds, of which $53,367 was paid in commissions to 

Anglim.  

FIRST CLAIM FOR RELIEF 
FRAUD IN THE OFFER OR SALE OF SECURITIES 

(Violations of Section 17(a)(1) and (3) of the Securities Act) 
 

75. Paragraphs 1 through 74 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

76. During the Relevant Period, the stock of Proto Script, Digatrade, 12 Retech, 

Homie, and Charlestowne was each a security under Section 2(a)(1) of the Securities Act [15 

U.S.C. §77b(a)(1)]. 

77. By reason of the conduct described above, Anglim, in the offer or sale of 

securities, by the use of the means or instrumentalities of interstate commerce or of the mails, 

directly or indirectly, acting with the requisite state of mind (i) employed devices, schemes, or 

artifices to defraud; and (ii) engaged in transactions, practices, or courses of business which 

operated or would operate as a fraud or deceit upon any persons, including purchasers or sellers 

of the securities. 

78. By reason of the conduct described above, Anglim violated Securities Act 

Sections 17(a)(1) and (3) [15 U.S.C. §77q(a)(1) and (3)]. 

SECOND CLAIM FOR RELIEF 
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES  

(Violations of Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder) 
 

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79. Paragraphs 1 through 74 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

80. During the Relevant Period, the stock of Proto Script, Digatrade, 12 Retech, 

Homie, and Charlestowne was each a security under Section 3(a)(1) of the Exchange Act [15 

U.S.C. §78c(a)(10)]. 

81. By reason of the conduct described above, Anglim, directly or indirectly, in 

connection with the purchase or sale of securities, by the use of the means or instrumentalities of 

interstate commerce or of the mails, or of any facility of any national securities exchange, 

intentionally, knowingly, or recklessly, (i) employed devices, schemes, or artifices to defraud; 

and (ii) engaged in acts, practices, or courses of business which operated or would operate as a 

fraud or deceit upon any persons, including purchasers or sellers of the securities. 

82. By reason of the conduct described above, Anglim violated Exchange Act Section 

10(b) [15 U.S.C. §78j(b)] and Rules 10b-5(a) and (c) [17 C.F.R §240.10b-5(a) and (c)] 

thereunder. 

THIRD CLAIM FOR RELIEF 
MARKET MANIPULATION 

(Violations of Section 9(a)(1) of the Exchange Act) 
 

83. Paragraphs 1 through 74 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

84. During the Relevant Period, the stock of Proto Script, Digatrade, 12 Retech, 

Homie, and Charlestowne was each a security under Section 3(a)(1) of the Exchange Act [15 

U.S.C. §78c(a)(10)]. 

85. By reason of the conduct described above, Anglim, directly or indirectly, by the 

use of the mails or any means or instrumentality of interstate commerce, or of any facility of any 

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national securities exchange, for the purpose of creating a false or misleading appearance of 

active trading in any security other than a government security, or a false or misleading 

appearance with respect to the market for any such security: (A) effected any transaction in such 

security which involves no change in the beneficial ownership thereof, or (B) entered an order or 

orders for the purchase of such security with the knowledge that an order or orders of 

substantially the same size, at substantially the same time, and at substantially the same price, for 

the sale of any such security, has been or will be entered by or for the same or different parties, 

or (C) entered any order or orders for the sale of any such security with the knowledge that an 

order or orders of substantially the same size, at substantially the same time, and at substantially 

the same price, for the purchase of such security, has been or will be entered by or for the same 

or different parties. 

86. By reason of the conduct described above, Anglim violated Exchange Act Section 

9(a) [15 U.S.C. §78i(a)]. 

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that this Court: 

A. Permanently restrain Anglim, his agents, servants, employees and attorneys, and 

those persons in active concert of participation with them who receive actual notice of the 

injunction by personal services or otherwise, and each of them, from violating Section 17(a) of 

the Securities Act [15 U.S.C. §77q(a)], and Sections 9(a) and 10(b) of the Exchange Act [15 

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

B. Order Anglim to disgorge, with prejudgment interest, all ill-gotten gains obtained 

by reason of the unlawful conduct alleged in this Complaint, pursuant to Section 21(d)(7) of the 

Exchange Act [15 U.S.C. §78u(d)(7)]; 

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C. Enter an order barring Anglim from participating in any offering of a penny stock, 

pursuant to Section 20(g) of the Securities Act [15 U.S.C. §77t(g)] and/or Section 21(d) of the 

Exchange Act [15 U.S.C. §78u(d)]; 

D. Retain jurisdiction over this action to implement and carry out the terms of all 

orders and decrees that may be entered; and  

E. Grant such other further relief as the Court may deem just and proper. 

JURY DEMAND 

 The Commission demands a jury in this matter for all claims so triable. 

DATED: July 17, 2023 

      Respectfully submitted, 

      /s/ Kathleen Burdette Shields    
      Kathleen Burdette Shields (Mass Bar No. 637438) 
      William J. Donahue (Mass Bar No. 631229) 
      SECURITIES AND EXCHANGE COMMISSION 
      Boston Regional Office 
      33 Arch Street, 24th Floor 
      Boston, MA 02110 
      Phone: (617) 573-8904 (Shields direct) 
      (617) 573-8915 (Donahue direct) 

(617) 573-4590 (fax) 
      [email protected] (Shields email) 
      [email protected] (Donahue email) 

Case 1:23-cv-11598   Document 1   Filed 07/17/23   Page 25 of 25

mailto:[email protected]
mailto:[email protected]