United States Securities and Exchange Commission v. Glick et al
Filing
107
MOTION by Plaintiff United States Securities and Exchange Commission for judgment SEC's Motion for Entry of Judgment Against Defendant Daniel H. Glick, Defendant Financial Management Strategies Inc., and Relief Defendant Glick Accounting Ser vices Inc. (Attachments: # 1 Exhibit 1 -- Consent of Defendant Glick, # 2 Exhibit 2 -- Consent of Defendant Financial Management Strategies, # 3 Exhibit 3 -- Consent of Relief Defendant Glick Accounting Services, # 4 Exhibit 4 -- Proposed Judgment as to Defendant Glick, # 5 Exhibit 5 -- Proposed Judgment as to Defendant Financial Management Strategies, # 6 Exhibit 6 -- Proposed Judgment as to Relief Defendant Glick Accounting Services)(Seeger, Steven)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
_________________________________________
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)
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Plaintiff,
) Case No. 17-cv-2251
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v.
) Hon. Virginia M. Kendall
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DANIEL H. GLICK and
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FINANCIAL MANAGEMENT
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STRATEGIES INC.,
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Defendants,
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and
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GLICK ACCOUNTING SERVICES INC.,
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EDWARD H. FORTE, and
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DAVID B. SLAGTER,
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Relief Defendants.
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_________________________________________ )
UNITED STATES SECURITIES
AND EXCHANGE COMMISSION,
SECURITIES AND EXCHANGE COMMISSION’S
MOTION FOR ENTRY OF JUDGMENT
AGAINST DEFENDANT DANIEL H. GLICK,
DEFENDANT FINANCIAL MANAGEMENT STRATEGIES INC.,
AND RELIEF DEFENDANT GLICK ACCOUNTING SERVICES INC.
The SEC respectfully moves for the entry of judgment against defendant Daniel Glick
and his two companies, defendant Financial Management Strategies Inc. (“FMS”) and relief
defendant Glick Accounting Services Inc. In support of this motion, the SEC states as follows:
1.
As previewed for the Court during the hearing on April 4, 2018, the SEC has
reached a bifurcated settlement with Glick and his two companies. The settlement basically
resolves everything as to those parties, except the monetary relief.
2.
Glick, FMS, and Glick Accounting Services have consented to the entry of
judgment against them. Exhibits 1-3 are executed copies of the consents. Exhibit 1 is the
Consent of Defendant Daniel Glick. Exhibit 2 is the Consent of Defendant Financial
Management Strategies Inc. Exhibit 3 is the Consent of Relief Defendant Glick Accounting
Services Inc.
3.
Exhibits 4-6 are the proposed judgments. Exhibit 4 is the Judgment as to
Defendant Daniel Glick. Exhibit 5 is the Judgment as to Defendant Financial Management
Strategies Inc. Exhibit 6 is the Judgment as to Relief Defendant Glick Accounting Services.
Glick, FMS, and Glick Accounting Services have agreed to the proposed judgments. See
Consent of Defendant Daniel Glick, at ¶ 3 (Ex. 1); Consent of Defendant Financial Management
Strategies Inc., at ¶ 2 (Ex. 2); Consent of Relief Defendant Glick Accounting Services Inc., at ¶ 2
(Ex. 3).
4.
Among other things, Glick and FMS have agreed to the entry of permanent
injunctions restraining them from violating the federal securities laws. See, e.g., Consent of
Defendant Daniel Glick, at ¶ 3 (Ex. 1); Judgment as to Defendant Daniel Glick, at §§ I – III (Ex.
4). There is no permanent injunction against Glick Accounting Services because it is a relief
defendant, and thus was not charged with violating the federal securities laws.
5.
Glick, FMS, and Glick Accounting Services also have agreed to repatriate foreign
assets to the United States. See, e.g., Consent of Defendant Daniel Glick, at ¶ 16 (Ex. 1);
Judgment as to Defendant Daniel Glick, at § V (Ex. 4). In particular, they have agreed to
cooperate with the orderly liquidation, transfer, and repatriation of any foreign assets, including
the Israeli investments identified in this action. All proposed sales would be subject to the
approval of this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.).
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6.
Glick, FMS, and Glick Accounting Services have agreed to the disgorgement of
ill-gotten gains, as well as prejudgment interest. See, e.g., Consent of Defendant Daniel Glick, at
¶ 5 (Ex. 1); Judgment as to Defendant Daniel Glick, at § IV (Ex. 4). This Court will determine
the amount of disgorgement and prejudgment interest at a later date, after the SEC files a motion.
Id. In addition, Glick and FMS have agreed that the Court will decide the amount of any civil
penalty (again, at a future time). Id.
7.
The sentencing of Daniel Glick is currently scheduled for April 17, 2018. See
United States v. Glick, 17-cr-739 (N.D. Ill.) (Gettleman, J.). The sentence may include a
restitution order. After sentencing, the SEC will return to this Court and address the issue of
monetary relief, the last remaining issue for Glick and his two companies.
8.
Glick, FMS, and Glick Accounting Services agreed that the “Commission may
present the Judgment to the Court for signature and entry without further notice.” See Consent
of Defendant Daniel Glick, at ¶ 17 (Ex. 1); Consent of Defendant Financial Management
Strategies, at ¶ 15 (Ex. 2); Consent of Relief Defendant Glick Accounting Services, at ¶ 14 (Ex.
3).
WHEREFORE, the SEC respectfully moves for the entry of judgment against defendant
Daniel Glick, defendant Financial Management Strategies Inc., and relief defendant Glick
Accounting Services Inc.
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Dated: April 11, 2018
Respectfully submitted,
/s/ Steven C. Seeger
Steven C. Seeger (Seegers@sec.gov)
Jeffrey A. Shank (Shankj@sec.gov)
Michelle Muñoz Durk (Munozdurkm@sec.gov)
U.S. Securities and Exchange Commission
175 W. Jackson Blvd., Suite 1450
Chicago, Illinois 60604-2615
Phone: (312) 353-7390
Fax: (312) 353-7398
Attorneys for Plaintiff
U.S. Securities and Exchange Commission
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