Securities And Exchange Commission v. Carlson, Jr.

Filing 17

MOTION by Plaintiff Securities And Exchange Commission for judgment (Attachments: # 1 Appendix OF DEFENDANT WILLIAM P. CARLSON, Jr., # 2 Text of Proposed Order FINAL JUDGMENT AS TO DEFENDANT WILLIAM P. CARLSON, Jr.)(Ablaev, Arsen)

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
____________________________________
:
SECURITIES AND EXCHANGE
:
COMMISSION,
:
:
Plaintiff,
:
:
Civil Action No. 17-cv-1328
v.
:
:
Hon. Sharon Johnson Coleman
WILLIAM P. CARLSON, Jr.,
:
:
Defendant.
:
____________________________________:
SECURITIES AND EXCHANGE COMMISSION’S
MOTION FOR ENTRY OF JUDGMENT
Plaintiff Securities and Exchange Commission hereby respectfully moves this Court for
entry of judgment as to Defendant William P. Carlson, Jr. Defendant Carlson has consent to the
entry of judgment against him. In support thereof, the SEC states as follows:
1.

On November 7, 2017, Defendant Carlson signed the Consent of Defendant

William P. Carlson, Jr., an executed copy of which is attached hereto as Exhibit 1.
2.

In the Consent, Defendant Carlson agreed to the entry of judgment against him.

In particular, Defendant Carlson expressly agreed to the entry of the judgment attached hereto as
Exhibit 2. (Ex. 1, ¶ 3) (stating that “Defendant hereby consents to the entry of the final
Judgment in the form attached hereto”).
3.

Among other things, Defendant Carlson agreed to the issuance of a permanent

injunction restraining him from violating Section 10(b) of the Securities Exchange Act of 1934
and Rule 10b-5 promulgated thereunder. (Ex. 1, ¶ 3.) He also agreed to a judgment requiring
him to pay disgorgement in the amount of $711,000, together with prejudgment interest in the

amount of $21,326.04, which obligation shall be deemed satisfied upon entry of an Order of
Restitution against Defendant Carlson in United States v. William Carlson, Jr., Case No. 17-CR106 (N.D. Ill.). (Id.)
4.

Pursuant to the Court’s Standing Order, a Microsoft Word copy of the Judgment

has been emailed to [e-mail].
WHEREFORE, Plaintiff United States Securities and Exchange Commission respectfully
requests that the Court grant its Motion and enter the Judgment set forth in Exhibit 2.

Dated: December 1, 2017

Respectfully submitted,

UNITED STATES SECURITIES AND
EXCHANGE COMMISSION
/s/ Arsen R. Ablaev
Arsen R. Ablaev (Ill. Bar No. 6302267)
Michael D. Foster (Ill. Bar No. 6257063)
175 W. Jackson Blvd., Suite 1450
Chicago, IL 60604
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
U.S. Securities and Exchange Commission

2

CERTIFICATE OF SERVICE
I, Arsen R. Ablaev, an attorney, hereby certify that on this day I filed the foregoing
Securities and Exchange Commission’s Motion for Entry of Judgment through the Court’s
CM/ECF system, and served this document on William P. Carlson, Jr., by UPS and electronic
mail.

December 1, 2017
/s/ Arsen R. Ablaev
Arsen R. Ablaev
175 W. Jackson Blvd., Suite 1450
Chicago, IL 60604
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff
U.S. Securities and Exchange Commission

3