On August 27, 2021, the United States Securities and Exchange Commission (the “Plaintiff” or the “SEC”), represented by Pat Huddleston, attorney at the SEC’s Atlanta regional office, filed a civil enforcement action against Jason Dodd Bullard, Angela Romero-Bullard, Bullard Enterprises LLC, (collectively “Defendant”) and DLJ Real Estate LLC, Empire Investments LLC, Empire Racing Stables LLC, T1 13 LLC (collectively, “Relief Defendants”), seeking preliminary and permanent injunction, temporary restraining order and disgorgement of all ill-gotten gains with prejudgment interest, civil penalties and an asset freeze for allegedly engaging in a fraudulent scheme. This case was filed in the U.S. District Court in the District of Minnesota.
In its complaint, the Plaintiff alleged that, “A significant amount of the funds were raised since 2019, including $1,970,000 since 2020. Defendants told investors that their money would be invested in two self-described “investment funds,” each of which purported to trade foreign currencies.”
The Plaintiff further alleged that, “Instead of using the funds as promised, Defendants used most of the investors’ funds to pay other investors and for their own personal uses, including funding four unrelated businesses in which the investors had no stake—DLJ Real Estate L.L.C., Empire Investments L.L.C., Empire Racing Stables L.L.C., and TI 13 L.L.C. (collectively “Relief Defendants”).”
The Plaintiff further alleged that, “Defendants have also provided falsified periodic account statements to investors, misrepresenting that their investments were profitable. In truth, investor funds were not invested or suffered investment losses.”
There are three claims for relief laid down by the Plaintiff. The first claim deals with the alleged violation of section 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)]. The second claim is for alleged violation of section 17 (a)(2) and 17(a)(3) of the Securities Act [15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)]. The third claim is for alleged violations of section 10(b) of the Exchange Act and sections (a), (b), and (c) of Rule 10b-5 [15 U.S.C. § 78j(b) and 17 C.F.R. §§ 240.10b-5(a), (b), and (c)].
In its prayer for relief, the Plaintiff has requested the Court for a temporary restraining order, preliminary and permanent injunctions and enjoining the Defendant with disgorgement of all ill-gotten gains and pre-judgment interest, along with the payment of civil monetary penalties pursuant to Section 21(d) of the Exchange Act [15 U.S.C. §78u(d)] and Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and freezing the assets of the Defendants and Relief Defendants or any other relief that the Court deems just, equitable and appropriate.
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Pending - Other Pending
U.S. Securities and Exchange Commission
Jason D. Bullard
Bullard Enterprises LLC
DLJ Real Estate L.L.C
Empire Investments L.L.C.
Empire Racing Stables L.L.C.
TI 13 L.L.C.
Attorney at Securities and Exchange Commission
950 East Paces Ferry Road, N.E., Ste 900
Atlanta, GA 30326
Civil Cover Sheet
(#1) COMPLAINT against Jason D. Bullard, Bullard Enterprises LLC, DLJ Real Estate L.L.C, Empire Investments L.L.C., Empire Racing Stables L.L.C., Angela Romero-Bullard, TI 13 L.L.C. filed by U.S. Securities and Exchange Commission. Filer requests summons issued. (Attachments: #1 Civil Cover Sheet) (Huddleston, Pat) (Entered: 08/27/2021)
Docket(#1) COMPLAINT against Jason D. Bullard, Bullard Enterprises LLC, DLJ Real Estate L.L.C, Empire Investments L.L.C., Empire Racing Stables L.L.C., Angela Romero-Bullard, TI 13 L.L.C. filed by U.S. Securities and Exchange Commission. Filer requests summons issued. (Attachments: #1 Civil Cover Sheet) (Huddleston, Pat) (Entered: 08/27/2021)Read MoreRead Less
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