UNITED STATES OF AMERICA
before the
SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934
Release No. 42878 / June 1, 2000

ADMINISTRATIVE PROCEEDING
File No. 3-10214

_____________________________   In the Matter of   DAVID E. TROTTER   Respondent. ____________________________

: ORDER INSTITUTING : ADMINISTRATIVE PROCEEDINGS : PURSUANT TO SECTIONS 15(b) AND : EXCHANGE ACT OF 1934, MAKING : 19(h) OF THE SECURITIES : FINDINGS AND IMPOSING : REMEDIAL SANCTIONS

I.

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative proceedings be instituted pursuant to Sections 15(b) and 19(h) of the Securities Exchange Act of 1934 ("Exchange Act") against Respondent David E. Trotter ("Trotter" or "Respondent").

II.

In anticipation of the institution of these proceedings, Trotter has submitted an Offer of Settlement ("Offer") for the purpose of resolving these proceedings, which Offer the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the Commission or to which the Commission is a party, Respondent, by his Offer, consents to the entry of this Order Instituting Proceedings Pursuant to Sections 15(b) and 19(h) of the Securities Exchange Act of 1934, Making Findings and Imposing Remedial Sanctions ("Order"), admits the jurisdiction of the Commission and, without admitting or denying the findings set forth herein, except with respect to paragraph III.B., below, which is admitted, consents to the entry of the findings and remedial sanctions set forth below.

Accordingly, it is ordered that proceedings pursuant to Sections 15(b) and 19(h) of the Exchange Act be, and hereby are, instituted.

III.

On the basis of this Order and Respondent's Offer, the Commission finds that:

A. During 1996, Trotter, induced or effected transactions in the sales of securities by recruiting others to sell and who sold, in multiple states, promissory notes issued by LSI Holdings Inc. f/k/a Legend Sports, Inc. and Legend Sports, Inc. f/k/a Sirrine & Associates, Inc. (hereinafter collectively referred to as "Legend Sports").

B. On August 5, 1999, a final judgment of permanent injunction was entered, by consent, against Trotter, permanently enjoining him, directly and indirectly, from violations of Sections 5(a) and 5(c) of the Securities Act of 1933, and Section 15(a) of the Exchange Act SEC v James T. Staples et al., Case No. 98-1061-CV-22-C (M.D. Fla. Sept. 23, 1998).

C. The Commission's complaint alleged, in part, that Trotter, in connection with the offer and sale of securities by Legend Sports, violated the registration and broker-dealer registration provisions of the federal securities laws.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions specified in Respondent's Offer.

ACCORDINGLY, IT IS FURTHER ORDERED that:

A. Trotter be, and hereby is, suspended from association with any broker or dealer for a period of twelve (12) months, effective on the second Monday following the entry of this Order.

B. Trotter shall provide the Commission within thirty (30) days after the end of the twelve (12) month suspension period described above, an affidavit that he has complied fully with the sanction described in Section IV. A. above.

By the Commission.

Jonathan G. Katz
Secretary

http://www.sec.gov/litigation/admin/34-42878.htm