==========================================START OF PAGE 1====== UNITED STATES SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 14915 / May 21, 1996 SEC v. Mary S. Pate, U.S.D.C. N.D. Ill., No. 96 C 2900, filed May 15, 1996. The Commission announced that on May 15, 1996, it filed a Complaint in the United States District Court for the Northern District of Illinois charging Mary S. Pate (Pate) with violations of Sections 5(a), 5(c) and 17(a) of the Securities Act of 1933 (Securities Act) and Section 10(b) of the Securities Exchange Act of 1934 (Exchange Act) and Rule 10b-5 thereunder in connection with a $15 million Ponzi scheme designed and operated by Pate. Specifically, the Commission's Complaint alleges that from the spring of 1988 until August 1993, Pate, through her interior design business, raised approximately $15 million from over 200 investors in the offer and sale of securities in the form of investment contracts in a fictitious investment which she called the "Mart Bonus Program." The Complaint alleges that Pate told investors that based on the volume of sales her business generated through the Chicago Merchandise Mart, she was eligible to participate in an investment bonus program offered by the Merchandise Mart which would generate returns ranging from 10%- 500%. The Complaint further alleges that Pate frequently told investors that they were guaranteed not to loose any principal when investing in the program. In reality, the Mart Bonus Program was nothing more than an elaborate Ponzi scheme designed by Pate to defraud investors and enable her to misappropriate funds for her personal and business use. As a result, the Complaint alleges that Pate misrepresented and omitted to state material facts to investors concerning, among other things, the nature and existence of the investment, the use of investor proceeds and the safety and profitability of the investment. The Complaint seeks the entry of an order of permanent injunction against Pate. Simultaneous with the filing of the Complaint, Pate consented, without admitting or denying the allegations in the Complaint, to the entry of an Order of Permanent Injunction against her. Accordingly, on May 16, 1996, the Honorable Charles P. Kocoras of the United States District Court for the Northern District of Illinois entered the Order of Permanent Injunction against Pate.