Securities and Exchange Commission v. Bronson et al
ORDER granting 415 Letter Motion to Compel. The Court grants this request and directs the SEC to submit a proposed order to the Court forthwith. SO ORDERED.. (Signed by Judge Kenneth M. Karas on 11/3/2022) (kv)
Case 7:12-cv-06421-KMK Document 416
415 Filed 11/03/22 Page 1 of 1
November 3, 2022
Hon. Kenneth M. Karas
United States District Court
United States Courthouse
300 Quarropas Street, Chambers 533
White Plains, New York 10601-4150
Re: U.S. Securities and Exchange Commission v. Bronson et al.,
Dear Judge Karas:
I write on behalf of the Securities and Exchange Commission (“SEC”) to ask the
Court to compel witnesses to appear at the evidentiary hearing scheduled for December
As background, the SEC sought an evidentiary hearing after discovering
concerning conduct in connection with the removal of the Court-appointed liquidation
trustee; transfers and sales of securities subject to the Liquidation Order, DE 278; and
additional income generated but not paid to the SEC. What’s more, Bronson’s then
attorney, Rachmuth, appears to have aided in Bronson’s execution of the penny stock
trades subject to the liquidation order and then deposited some of those funds into his
escrow account. To stem any further potential asset dissipation and contempt the SEC
sought and, on November 3, 2022, the Court granted an evidentiary hearing on these
issues. In addition, the Court stated that the Court would order the witnesses to appear
and asked the SEC to submit a letter with the witness’ names.
As such, the SEC respectfully requests that the Court order the following
witnesses to appear and testify if called upon on December 12, 2022 at 10:30 a.m.:
Edward Bronson, Dawn Bronson, John Kellas, Bruce Bent, Paul Strickland, Paul
Rachmuth in his personal capacity, for his law firm and for Phase 1 Operations, Inc.,
Marc Pena, and Ryan Stumphauzer. If so ordered, the SEC will ensure the Court’s Order
is served on each of the witnesses.
s/ Maureen Peyton King
The Court grants this request and directs the SEC to submit a
proposed order to the Court forthwith.
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