U.S. SECURITIES AND EXCHANGE COMMISSION

Litigation Release No. 20309 /September 27, 2007

Securities and Exchange Commission v. Advance Body Imaging, LP; Consulting Dynamics, Inc.; and Stanley Johnson, Case No. SACV 07-1140 DOC (JTLx) (C.D. Cal.)

SEC Sues Fullerton Man In $3 Million Fraudulent Medical Diagnostic Facility Fundraising Scheme

The Securities and Exchange Commission ("Commission"), on Thursday, September 27, sued Stanley Johnson of Fullerton, California, and two entities he controls for their fraudulent misuse of the more than $3 million in investor monies they raised from their unregistered offering of limited partnership units.

The Commission's complaint alleges that since mid-2004, Johnson, Advanced Body Imaging, LP, and Consulting Dynamics, Inc. have solicited investors with promises of opening a medical diagnostic facility in Southern California that would generate a full return on investment within one year and would return five times their investment when the company went public within two years. The complaint alleges that the defendants misappropriated investor funds to pay for telemarketing lead lists, commissions to Johnson and his sales agents, rent for telemarketing office space, and otherwise fund the solicitation of additional investors. The complaint further alleges that although the defendants opened a Laguna Hills facility in late 2006, it was nothing more than a shell and, as a result of the defendants' misuse of investor monies, quickly fell behind on its rent and equipment leasing obligations.

The Complaint alleges that Johnson, Consulting Dynamics and Advance Body Imaging violated the securities registration provisions of Section 5(a) and 5(c) of the Securities Act of 1933, as well as the antifraud provisions of Section 17(a) of the Securities Act and Section 10(b) of the Securities Exchange Act of 1934. The Complaint further alleges that Johnson and Consulting Dynamics violated the broker-dealer registration requirements of Section 15(a) of the Exchange Act.

The Commission seeks an order permanently enjoining defendants Advance Body Imaging, Consulting Dynamics and Stanley Johnson from violating the provisions with which they have been charged, as well as disgorgement of all ill-gotten gains with prejudgment interest thereon, and civil penalties. The Commission also seeks disgorgement of proceeds of the fraud held by Stanley Johnson's wife, Easter Turnipseed-Johnson, who was named as a relief defendant and not charged with any violation.

SEC Complaint in this matter