SEC v. Lawrence Meyers; and Ichabod’s Cranium, Inc., No. 1:21-cv-11125, Southern District of New York (June 6, 2025) — Judgment

1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
________________________________________________
:
SECURITIES AND EXCHANGE COMMISSION, :
: 21-CV-11125-LAK
Plaintiff,  :
:
-against-     :
:
MEDALLION FINANCIAL CORP., :
ANDREW MURSTEIN,   :
LAWRENCE MEYERS,  :
and ICHABOD’S CRANIUM, INC., :
:
Defendants. :
________________________________________________:
FINAL J
UDGMENT AS TO DEFENDANTS
LAWRENCE MEYERS AND ICHABOD’S CRANIUM, INC.
The Securities and Exchange Commission having
filed an Amended Complaint and
Defendants Lawrence Meyers (“Meyers”) and Ichabod’s Cranium, Inc. (together, “Defendants”)
having entered general appearances; consented to the Court’s jurisdiction over Defendants and
the subject matter of
this action; consented to entry of this Final Judgment without admitting or
denying the allegations of the Amended Complaint (except as to jurisdiction and except as
otherwise provided herein in paragraph VI); 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 Defendants are
permanently restrained and enjoined from violating, directly or indirectly, Section 10(b) of the
Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5
promulgated thereunder [17 C.F.R. § 240.10b-5],
by using any means or instrumentality of

05/30/2025

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interstate commerce, or of the mails, or of any facility of any national securities exchange, in
connection with the purchase or sale of any security:
(a) to employ any device, scheme, or artifice to defraud;
(b) to make any untrue statement of a material fact or to omit to state a material fact
 necessary in order to make the statements made, in the light of the circumstances
 under which they were made, not misleading; or
(c) to engage in any act, practice, or course of business which operates or would
 operate as a fraud or deceit upon any person.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in
Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who
receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendants’
officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or
participation with Defendants or with anyone described in (a).
II.
 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that
Defendants are permanently restrained and enjoined from violating Section 17(b) of the
Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)] by using any means or
instruments of transportation or communication in interstate commerce or by use of the mails,
directly or indirectly, to publish, give publicity to, or circulate any notice, circular,
advertisement, newspaper, article, letter, investment service, or communication which, though
not purporting to offer a security for sale, describes such security for a consideration received or
to be received, directly or indirectly, from an issuer, underwriter, or dealer, without fully
disclosing the receipt, whether past or prospective, of such consideration and the amount thereof.

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 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in
Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who
receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendants’
officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or
participation with Defendants or with anyone described in (a).
III.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant Meyers
shall pay a civil penalty in the amount of $100,000 to the Securities and Exchange Commission
pursuant to Section  21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] and Section 20(d) of
the Securities Act [15 U.S.C. § 77t(d)].  Meyers shall make this payment pursuant to the terms of
the payment schedule set forth in paragraph IV below after entry of this Final Judgment.
Meyers 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
.  Meyers 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; Meyers as a defendant in this action; and specifying that payment is made pursuant to
this Final Judgment.
Meyers shall simultaneously transmit photocopies of evidence of payment and case

4

identifying information to the Commission’s counsel in this action.  By making this payment,
Meyers relinquishes all legal and equitable right, title, and interest in such funds and no part of
the funds shall be returned to Meyers.  The Commission shall send the funds paid pursuant to
this Final Judgment to the United States Treasury.
The Commission may enforce the Court’s judgment for penalties by the use of all
collection procedures authorized by law, including the Federal Debt Collection Procedures Act,
28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation of any Court orders
issued in this action.  Meyers shall pay post-judgment interest on any amounts due after 30 days
of the entry of this Final Judgment pursuant to 28 U.S .C . § 1961.
IV.
Defendant Meyers shall pay the total penalty due of $100,000 in twelve installments to
the Commission according to the following schedule:  (1) $20,000, within 30 days of entry of
this Final Judgment; (2) $5,000, within 60 days of entry of this Final Judgment; (3) $5,000,
within 90 days of entry of this Final Judgment; (4) $5,000, within 120 days of entry of this Final
Judgment; (5) $5,000, within 150 days of entry of this Final Judgment; (6) $5,000, within 180
days of entry of this Final Judgment; (7) $5,000, within 210 days of entry of this Final Judgment;
(8) $5,000, within 240 days of entry of this Final Judgment; (9) $5,000, within 270 days of entry
of this Final Judgment; (10) $5,000, within 300 days of entry of this Final Judgment; (11)
$5,000, within 330 days of entry of this Final Judgment; and (12) $30,000, within 360 days of
entry of this Final Judgment.  Payments shall be deemed made on the date they are received by
the Commission and shall be applied first to post judgment interest, which accrues pursuant to 28
U.S.C. § 1961 on any unpaid amounts due after 30 days of the entry of Final Judgment.  Prior to

5

making the final payment set forth herein, Meyers shall contact the staff of the Commission for
the amount due for the final payment.
If Meyers fails to make any payment by the date agreed and/or in the amount agreed
according to the schedule set forth above, all outstanding payments under this Final Judgment,
including post-judgment interest, minus any payments made, shall become due and payable
immediately at the discretion of the staff of the Commission without further application to the
Court.
V.
IT
 IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is
incorporated herein with the same force and effect as if fully set forth herein.
VI.
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 Defendant Meyers, and further, any debt for
disgorgement, prejudgment interest, civil penalty or other amounts due by Meyers 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 Meyers 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).
VII.
 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.

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
________________________________________________
:
SECURITIES AND EXCHANGE COMMISSION, :
: 21-CV-11125-LAK
Plaintiff,  :
:
-against-     :
:
MEDALLION FINANCIAL CORP., :
ANDREW MURSTEIN,   :
LAWRENCE MEYERS,  :
and ICHABOD’S CRANIUM, INC., :
:
Defendants. :
________________________________________________:
CONSENT OF DEFENDANTS LAWRENCE MEYERS
AND ICHABOD’S CRANIUM, INC.
1.D
efendants Lawrence Meyers (“Meyers”) and Ichabod’s Cranium, Inc. (together,
“Defendants”  ) acknowledge having been served with the amended complaint in this action,
acknowledge having entered a general appearance, and admit the Court’s jurisdiction over
Defendants and over the subject matter of this action.
2.Without admitting or denying the allegations of the amended complaint (except as
provided herein in paragraph 11) and except as to personal and subject matter jurisdiction, which
Defendants admit, Defendants hereby consent to the entry of the final Judgment in the form
attached hereto (the “Final Judgment”) and incorporated by reference herein, which, among other
things:
(a)permanently restrains and enjoins Defendants from violation of Section
17(b) of the Securities Act of 1933 (the “Securities Act”) [15 U.S.C.
§ 77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (the
“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated

2

thereunder [17 C.F.R. § 240.10b-5]  , as set forth in the Final Judgment; and
  (b) orders Meyers to pay a civil penalty in the amount of $100,000 under
Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] and Section
20(d) of the Securities Act [15 U.S.C. § 77t(d)].
 3. Meyers agrees that he shall not seek or accept, directly or indirectly,
reimbursement or indemnification from any source, including but not limited to payment made
pursuant to any insurance policy, with regard to any civil penalty amounts that Meyers pays
pursuant to the Final Judgment, regardless of whether such penalty amounts or any part thereof
are added to a distribution fund or otherwise used for the benefit of investors.  Meyers further
agrees that he shall not claim, assert, or apply for a tax deduction or tax credit with regard to any
federal, state, or local tax for any penalty amounts that Meyers pays pursuant to the Final
Judgment, regardless of whether such penalty amounts or any part thereof are added to a
distribution fund or otherwise used for the benefit of investors.
4. Defendants waive the entry of findings of fact and conclusions of law pursuant to
Rule 52 of the Federal Rules of Civil Procedure.
5. Defendants waive the right, if any, to a jury trial and to appeal from the entry of
the Final Judgment.
 6. Defendants enter into this Consent voluntarily and represent that no 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 Defendants to
enter into this Consent.
 7. Defendants agree that this Consent shall be incorporated into the Final Judgment
with the same force and effect as if fully set forth therein.

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 8. Defendants 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 waive any objection based thereon.
 9. Defendants waive service of the Final Judgment and agree that entry of the Final
Judgment by the Court and filing with the Clerk of the Court will constitute notice to Defendants
of its terms and conditions.  Defendants further agree to provide counsel for the Commission,
within thirty days after the Final Judgment is filed with the Clerk of the Court, with an affidavit
or declaration stating that Defendants have received and read a copy of the Final Judgment.
 10. Consistent with 17 C.F.R. § 202.5(f), this Consent resolves only the claims
asserted against Defendants in this civil proceeding.  Defendants acknowledge 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.
Defendants waive any claim of Double Jeopardy based upon the settlement of this proceeding,
including the imposition of any remedy or civil penalty herein.  Defendants further acknowledge
that the Court’s entry of a permanent injunction may have collateral consequences under federal
or state law and the rules and regulations of self-regulatory organizations, licensing boards, and
other regulatory organizations.  Such collateral consequences include, but are not limited to, a
statutory disqualification with respect to membership or participation in, or association with a
member of, a self-regulatory organization.  This statutory disqualification has consequences that
are separate from any sanction imposed in an administrative proceeding.  In addition, in any
disciplinary proceeding before the Commission based on the entry of the injunction in this
action, Defendants understand that they shall not be permitted to contest the factual allegations

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of the amended complaint in this action.
 11. Defendants understand and agree to comply with the terms of 17 C.F.R.
§ 202.5(e), which provides in part that it is the Commission’s policy “not to permit a defendant
or 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 Defendants’ agreement to comply with the terms of Section 202.5(e),
Defendants: (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 Defendants do not admit the allegations of the complaint, or that this Consent
contains no admission of the allegations, without also stating that Defendants do not deny the
allegations; (iii) upon the filing of this Consent, Defendants hereby withdraw any papers filed in
this action to the extent that they deny any allegation in the amended complaint; and
(iv) stipulate 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 amended complaint are true, and
further, that any debt for disgorgement, prejudgment interest, civil penalty or other amounts due
by Defendants 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 by
Defendants 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 Defendants
breach this agreement, the Commission may petition the Court to vacate the Final Judgment and
restore this action to its active docket.  Nothing in this paragraph affects Defendants’:

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(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.
 12. Defendants hereby waive 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 Defendants to defend against this action.  For these purposes,
Defendants agree that Defendants are not the prevailing party in this action since the parties have
reached a good faith settlement.
13. In connection with this action and any related judicial or administrative
proceeding or investigation commenced by the Commission or to which the Commission is a
party, Meyers (i) agrees to appear and be interviewed by Commission staff at such times and
places as the staff requests upon reasonable notice; (ii) will accept service by mail or facsimile
transmission of notices or subpoenas issued by the Commission for documents or testimony at
depositions, hearings, or trials, or in connection with any related investigation by Commission
staff; (iii) appoints Meyers’ undersigned attorney as agent to receive service of such notices and
subpoenas; (iv) with respect to such notices and subpoenas, waives the territorial limits on
service contained in Rule 45 of the Federal Rules of Civil Procedure and any applicable local
rules, provided that the party requesting the testimony reimburses Meyers’ travel, lodging, and
subsistence expenses at the then-prevailing U.S. Government per diem rates; and (v) consents to
personal jurisdiction over Meyers in any United States District Court for purposes of enforcing
any such subpoena.
14. Defendants agree that the Commission may present the Final Judgment to the

1 

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
________________________________________________ 

: 
SECURITIES AND EXCHANGE COMMISSION, : 

: 21-CV-11125-LAK
Plaintiff,  : 

: 
-against-     :         

: 
MEDALLION FINANCIAL CORP., : 
ANDREW MURSTEIN,   : 
LAWRENCE MEYERS,  : 
and ICHABOD’S CRANIUM, INC., : 

: 
Defendants. : 

________________________________________________: 

FINAL JUDGMENT AS TO DEFENDANTS  
LAWRENCE MEYERS AND ICHABOD’S CRANIUM, INC.

The Securities and Exchange Commission having filed an Amended Complaint and 

Defendants Lawrence Meyers (“Meyers”) and Ichabod’s Cranium, Inc. (together, “Defendants”) 

having entered general appearances; consented to the Court’s jurisdiction over Defendants and 

the subject matter of this action; consented to entry of this Final Judgment without admitting or 

denying the allegations of the Amended Complaint (except as to jurisdiction and except as 

otherwise provided herein in paragraph VI); 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 Defendants are 

permanently restrained and enjoined from violating, directly or indirectly, Section 10(b) of the 

Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 

promulgated thereunder [17 C.F.R. § 240.10b-5], by using any means or instrumentality of 

Case 1:21-cv-11125-LAK     Document 125     Filed 05/29/25     Page 1 of 12

05/30/2025

http://www.google.com/search?q=17+c.f.r.++240.10b-5
http://www.google.com/search?q=15+u.s.c.++78j(b)


2 
 

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

connection with the purchase or sale of any security: 

(a) to employ any device, scheme, or artifice to defraud; 

(b) to make any untrue statement of a material fact or to omit to state a material fact 

 necessary in order to make the statements made, in the light of the circumstances 

 under which they were made, not misleading; or 

(c) to engage in any act, practice, or course of business which operates or would 

 operate as a fraud or deceit upon any person. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendants’ 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendants or with anyone described in (a). 

II. 

 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that 

Defendants are permanently restrained and enjoined from violating Section 17(b) of the 

Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)] by using any means or 

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

directly or indirectly, to publish, give publicity to, or circulate any notice, circular, 

advertisement, newspaper, article, letter, investment service, or communication which, though 

not purporting to offer a security for sale, describes such security for a consideration received or 

to be received, directly or indirectly, from an issuer, underwriter, or dealer, without fully 

disclosing the receipt, whether past or prospective, of such consideration and the amount thereof. 

Case 1:21-cv-11125-LAK     Document 125     Filed 05/29/25     Page 2 of 12

http://www.google.com/search?q=FRCP+65(d)(2)
http://www.google.com/search?q=15+u.s.c.++77q(a)


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 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendants’ 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendants or with anyone described in (a). 

III. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant Meyers 

shall pay a civil penalty in the amount of $100,000 to the Securities and Exchange Commission 

pursuant to Section  21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] and Section 20(d) of 

the Securities Act [15 U.S.C. § 77t(d)].  Meyers shall make this payment pursuant to the terms of 

the payment schedule set forth in paragraph IV below after entry of this Final Judgment. 

Meyers 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.  Meyers 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; Meyers as a defendant in this action; and specifying that payment is made pursuant to 

this Final Judgment.   

Meyers shall simultaneously transmit photocopies of evidence of payment and case 

Case 1:21-cv-11125-LAK     Document 125     Filed 05/29/25     Page 3 of 12

http://www.sec.gov/about/offices/ofm.htm
http://www.google.com/search?q=FRCP+65(d)(2)
http://www.google.com/search?q=15+u.s.c.++78u(d)(3)
http://www.google.com/search?q=15+u.s.c.++77t(d)


4 
 

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

Meyers relinquishes all legal and equitable right, title, and interest in such funds and no part of 

the funds shall be returned to Meyers.  The Commission shall send the funds paid pursuant to 

this Final Judgment to the United States Treasury.  

The Commission may enforce the Court’s judgment for penalties by the use of all 

collection procedures authorized by law, including the Federal Debt Collection Procedures Act, 

28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation of any Court orders 

issued in this action.  Meyers shall pay post-judgment interest on any amounts due after 30 days 

of the entry of this Final Judgment pursuant to 28 U.S.C. § 1961.   

IV. 

Defendant Meyers shall pay the total penalty due of $100,000 in twelve installments to 

the Commission according to the following schedule:  (1) $20,000, within 30 days of entry of 

this Final Judgment; (2) $5,000, within 60 days of entry of this Final Judgment; (3) $5,000, 

within 90 days of entry of this Final Judgment; (4) $5,000, within 120 days of entry of this Final 

Judgment; (5) $5,000, within 150 days of entry of this Final Judgment; (6) $5,000, within 180 

days of entry of this Final Judgment; (7) $5,000, within 210 days of entry of this Final Judgment; 

(8) $5,000, within 240 days of entry of this Final Judgment; (9) $5,000, within 270 days of entry 

of this Final Judgment; (10) $5,000, within 300 days of entry of this Final Judgment; (11) 

$5,000, within 330 days of entry of this Final Judgment; and (12) $30,000, within 360 days of 

entry of this Final Judgment.  Payments shall be deemed made on the date they are received by 

the Commission and shall be applied first to post judgment interest, which accrues pursuant to 28 

U.S.C. § 1961 on any unpaid amounts due after 30 days of the entry of Final Judgment.  Prior to 

Case 1:21-cv-11125-LAK     Document 125     Filed 05/29/25     Page 4 of 12

http://www.google.com/search?q=28+u.s.c.++3001
http://www.google.com/search?q=28+u.s.c.++1961
http://www.google.com/search?q=28++u.s.c.++1961
http://www.google.com/search?q=28++u.s.c.++1961


5 
 

making the final payment set forth herein, Meyers shall contact the staff of the Commission for 

the amount due for the final payment.  

If Meyers fails to make any payment by the date agreed and/or in the amount agreed 

according to the schedule set forth above, all outstanding payments under this Final Judgment, 

including post-judgment interest, minus any payments made, shall become due and payable 

immediately at the discretion of the staff of the Commission without further application to the 

Court. 

V. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is 

incorporated herein with the same force and effect as if fully set forth herein. 

VI. 

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 Defendant Meyers, and further, any debt for 

disgorgement, prejudgment interest, civil penalty or other amounts due by Meyers 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 Meyers 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). 

VII. 

 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. 

 

Case 1:21-cv-11125-LAK     Document 125     Filed 05/29/25     Page 5 of 12

http://www.google.com/search?q=11+u.s.c.++523
http://www.google.com/search?q=11+u.s.c.++523(a)(19)




1 

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
________________________________________________ 

: 
SECURITIES AND EXCHANGE COMMISSION, : 

: 21-CV-11125-LAK
Plaintiff,  : 

: 
-against-     :         

: 
MEDALLION FINANCIAL CORP., : 
ANDREW MURSTEIN,   : 
LAWRENCE MEYERS,  : 
and ICHABOD’S CRANIUM, INC., : 

: 
Defendants. : 

________________________________________________: 

CONSENT OF DEFENDANTS LAWRENCE MEYERS 
AND ICHABOD’S CRANIUM, INC. 

1. Defendants Lawrence Meyers (“Meyers”) and Ichabod’s Cranium, Inc. (together,

“Defendants”) acknowledge having been served with the amended complaint in this action, 

acknowledge having entered a general appearance, and admit the Court’s jurisdiction over 

Defendants and over the subject matter of this action. 

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

provided herein in paragraph 11) and except as to personal and subject matter jurisdiction, which 

Defendants admit, Defendants hereby consent to the entry of the final Judgment in the form 

attached hereto (the “Final Judgment”) and incorporated by reference herein, which, among other 

things: 

(a) permanently restrains and enjoins Defendants from violation of Section

17(b) of the Securities Act of 1933 (the “Securities Act”) [15 U.S.C.

§ 77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (the

“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated 

Case 1:21-cv-11125-LAK     Document 125     Filed 05/29/25     Page 7 of 12

http://www.google.com/search?q=15+u.s.c.+++77q(a)
http://www.google.com/search?q=15+u.s.c.+++77q(a)
http://www.google.com/search?q=15+u.s.c.++78j(b)


2 
 

thereunder [17 C.F.R. § 240.10b-5], as set forth in the Final Judgment; and 

  (b) orders Meyers to pay a civil penalty in the amount of $100,000 under 

Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] and Section 

20(d) of the Securities Act [15 U.S.C. § 77t(d)]. 

 3. Meyers agrees that he shall not seek or accept, directly or indirectly, 

reimbursement or indemnification from any source, including but not limited to payment made 

pursuant to any insurance policy, with regard to any civil penalty amounts that Meyers pays 

pursuant to the Final Judgment, regardless of whether such penalty amounts or any part thereof 

are added to a distribution fund or otherwise used for the benefit of investors.  Meyers further 

agrees that he shall not claim, assert, or apply for a tax deduction or tax credit with regard to any 

federal, state, or local tax for any penalty amounts that Meyers pays pursuant to the Final 

Judgment, regardless of whether such penalty amounts or any part thereof are added to a 

distribution fund or otherwise used for the benefit of investors. 

4. Defendants waive the entry of findings of fact and conclusions of law pursuant to 

Rule 52 of the Federal Rules of Civil Procedure. 

5. Defendants waive the right, if any, to a jury trial and to appeal from the entry of 

the Final Judgment. 

 6. Defendants enter into this Consent voluntarily and represent that no 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 Defendants to 

enter into this Consent. 

 7. Defendants agree that this Consent shall be incorporated into the Final Judgment 

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

Case 1:21-cv-11125-LAK     Document 125     Filed 05/29/25     Page 8 of 12

http://www.google.com/search?q=17+c.f.r.++240.10b-5
http://www.google.com/search?q=15+u.s.c.++78u(d)(3)
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 8. Defendants 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 waive any objection based thereon. 

 9. Defendants waive service of the Final Judgment and agree that entry of the Final 

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

of its terms and conditions.  Defendants further agree to provide counsel for the Commission, 

within thirty days after the Final Judgment is filed with the Clerk of the Court, with an affidavit 

or declaration stating that Defendants have received and read a copy of the Final Judgment. 

 10. Consistent with 17 C.F.R. § 202.5(f), this Consent resolves only the claims 

asserted against Defendants in this civil proceeding.  Defendants acknowledge 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.  

Defendants waive any claim of Double Jeopardy based upon the settlement of this proceeding, 

including the imposition of any remedy or civil penalty herein.  Defendants further acknowledge 

that the Court’s entry of a permanent injunction may have collateral consequences under federal 

or state law and the rules and regulations of self-regulatory organizations, licensing boards, and 

other regulatory organizations.  Such collateral consequences include, but are not limited to, a 

statutory disqualification with respect to membership or participation in, or association with a 

member of, a self-regulatory organization.  This statutory disqualification has consequences that 

are separate from any sanction imposed in an administrative proceeding.  In addition, in any 

disciplinary proceeding before the Commission based on the entry of the injunction in this 

action, Defendants understand that they shall not be permitted to contest the factual allegations 

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of the amended complaint in this action. 

 11. Defendants understand and agree to comply with the terms of 17 C.F.R. 

§ 202.5(e), which provides in part that it is the Commission’s policy “not to permit a defendant 

or 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 Defendants’ agreement to comply with the terms of Section 202.5(e),  

Defendants: (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 Defendants do not admit the allegations of the complaint, or that this Consent 

contains no admission of the allegations, without also stating that Defendants do not deny the 

allegations; (iii) upon the filing of this Consent, Defendants hereby withdraw any papers filed in 

this action to the extent that they deny any allegation in the amended complaint; and 

(iv) stipulate 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 amended complaint are true, and 

further, that any debt for disgorgement, prejudgment interest, civil penalty or other amounts due 

by Defendants 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 by 

Defendants 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 Defendants 

breach this agreement, the Commission may petition the Court to vacate the Final Judgment and 

restore this action to its active docket.  Nothing in this paragraph affects Defendants’: 

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http://www.google.com/search?q=17+c.f.r.+++202.5
http://www.google.com/search?q=17+c.f.r.+++202.5
http://www.google.com/search?q=11+u.s.c.++523
http://www.google.com/search?q=11+u.s.c.++523(a)(19)


5 
 

(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. 

 12. Defendants hereby waive 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 Defendants to defend against this action.  For these purposes, 

Defendants agree that Defendants are not the prevailing party in this action since the parties have 

reached a good faith settlement. 

13. In connection with this action and any related judicial or administrative 

proceeding or investigation commenced by the Commission or to which the Commission is a 

party, Meyers (i) agrees to appear and be interviewed by Commission staff at such times and 

places as the staff requests upon reasonable notice; (ii) will accept service by mail or facsimile 

transmission of notices or subpoenas issued by the Commission for documents or testimony at 

depositions, hearings, or trials, or in connection with any related investigation by Commission 

staff; (iii) appoints Meyers’ undersigned attorney as agent to receive service of such notices and 

subpoenas; (iv) with respect to such notices and subpoenas, waives the territorial limits on 

service contained in Rule 45 of the Federal Rules of Civil Procedure and any applicable local 

rules, provided that the party requesting the testimony reimburses Meyers’ travel, lodging, and 

subsistence expenses at the then-prevailing U.S. Government per diem rates; and (v) consents to 

personal jurisdiction over Meyers in any United States District Court for purposes of enforcing 

any such subpoena. 

14. Defendants agree that the Commission may present the Final Judgment to the 

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	Meyers-IC Judgment__ [for filing]
	Meyers-IC Consent [for filing]
	2025.04.21 Meyers-Ichabod's Consent__
	Meyers-SEC Signature Page