-------------------- BEGINNING OF PAGE #1 ------------------- SECURITIES AND EXCHANGE COMMISSION LITIGATION RELEASE NO. 14650 / September 22, 1995 SECURITIES AND EXCHANGE COMMISSION v. ELLIS L. DEYON, BRADLEY T. GULLETT (INDIVIDUALLY, AND D.B.A. "GULLETT & ASSOCIATES"), WILLIAM HANKE, DOVE INVESTMENT GROUP, INC., AND SHERWOOD H. CRAIG (United States District Court for the District of Maine, Civ. Action No. 95-0164-B). The Securities and Exchange Commission announced that on September 21, 1995, it achieved repatriation of approximately $400,000, which represents all funds held in a Mexican bank account in the name of defendant Ellis L. Deyon. The Honorable Morton A. Brody, U.S. District Judge for the District of Maine, had ordered repatriation of all funds any defendant had transferred outside the United States, as part of the preliminary relief obtained by the Commission when its action was filed on July 25, 1995. The Commission alleged that each of the defendants was participating in an ongoing fraudulent offering of securities in violation of the federal securities laws by soliciting investors to place money in a "special inversion account" in Mexico with the promise of annual returns of up to 300%. The Commission has alleged that the defendants raised several hundred thousand dollars from investors in Maine, Pennsylvania, Texas, California, Florida and perhaps other states. These funds were then transferred to a bank account in Mexico under the control of defendant Deyon. Almost $400,000 was in defendant Deyon's account when repatriated. The Commission acknowledges the assistance of the Comision Nacional de Bancaria y Valores of Mexico, which regulates banking and securities activity, and worked with the Commission's Office of International Affairs to assist in accomplishing the repatriation. The repatriated funds have been placed in the registry of the court. The Commission's Complaint in the case alleges that, beginning no later than mid-May 1995 and continuing at least until the filing of the Commission's Complaint, the defendants fraudulently induced members of the public to invest with them by promising to pay a virtually risk-free annual return of up to 300%. According to the Complaint, the defendants represented that they could pay such extraordinary rates of return because the proceeds of the investment sales would be deposited into a "special" Mexican bank account they control which they claimed generates investment returns or earns interest of approximately 1020% per year. The Commission also alleged that, in some instances, the defendants told investors and potential investors that the account would be used to engage in the trading of instruments referred to as "Prime Bank" securities. The Complaint alleges that, contrary to the Defendants' representations to investors and potential investors, the bank account into which the proceeds of the investment offering were deposited does not earn the extraordinary rate of return described, the investments involve an extraordinary amount of risk, and the existence of legitimate financial instruments known as "Prime Bank" securities is nothing more than a hoax. Moreover, the Commission alleges that at no time relevant hereto has any of the defendants been registered with the Commission as securities broker-dealers -------------------- BEGINNING OF PAGE #2 ------------------- or associated with such a broker-dealer as they were required to be. The defendants allegedly targeted persons active in evangelical Christian ministries of which the defendants purport to be devout followers. According to the Complaint, many of the investors and potential investors solicited by the defendants are of modest economic means and are unsophisticated and inexperienced in financial matters. The defendants allegedly encouraged potential investors to take extraordinary steps to obtain money to invest including obtaining second mortgages on their residences and procuring large cash advances against their credit cards. On August 17, 1995, the court entered a Preliminary Injunction and Order to Continue Asset Freeze and Other Relief ("Order") preliminarily enjoining ELLIS L. DEYON (of Saltillo, Coahuila, Mexico), BRADLEY T. GULLETT (of Maitland, Florida), WILLIAM HANKE and DOVE INVESTMENT GROUP, INC. (of Davenport, Florida) and SHERWOOD H. CRAIG (of Orono, Maine) from continuing their fraudulent offer and sale of securities. The Order also continues a freeze of certain assets originally entered by the Court on July 25, 1995, and grants other relief. The Court entered the Order upon a motion by the Commission and the consent of the defendants. The Commission alleges that the defendants' offering and selling activity violated the antifraud and broker-dealer registration provisions of the federal securities laws - i.e., Section 17(a) of the Securities Act of 1933 and Sections 10(b) and 15(a) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. In its Complaint, the Commission seeks the following ultimate relief: (i) permanent injunctions prohibiting the commission of further violations of the antifraud and broker- dealer registration provisions of the federal securities laws; (ii) disgorgement of the defendants' ill-gotten gains plus prejudgment interest thereon; and (iii) civil monetary penalties in an amount to be determined by the Court. Discovery is currently proceeding in the case, which is scheduled for trial in April, 1996. For further information, please see Litigation Release Nos. 14586 and 14610.