Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): ori 6/2007
Header for Report [Optional - 80 Chars Max];[Furtong - February 1998 sales of HCCA stock
ae fs
Click here for the PIIC FAQ
Click here the memorandum describing the method for calculating interest
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 1 of 1

US. Securities and Exchange Commission

Division of Enforcement

Prejudgment Interest Report

Furlong - February 2000 sales of HCCA stock

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
- —— —
Violation Amount $965,675.00
03/01/2000-03/3 1/2000 8% 0.67% $6,437.83 $972,112.83
04/01/2000-06/30/2000 % 2.25% $21,872.54 $993,985.37
07/01/2000-09/30/2000 9% 2.25% $22,364.67 $1,016,350.04
10/01/2000-12/3 1/2000 9% 2.25% $22,867.88 $1,039,217.92
01/01/2001-03/3 1/2001 9% 2.25% $23,382.40 $1,062,600.32
04/01/2001-06/30/2001 8% 2% $21,252.01 $1,083,852.33
07/01/2001-09/30/2001 Th 1.75% $18,967.42 $1,102,819.75
10/01/2001-12/31/2001 T% 1.75% $19,299.35 $1,122,119.10
01/01/2002-03/3 1/2002 6% 15% $16,831.79 $1,138,950.89
04/01/2002-06/30/2002 6% 1.5% $17,084.26 $1,156,035.15
07/01/2002-09/30/2002 6% 1.5% $17,340.53 $1,173,375.68
10/01/2002-12/3 1/2002 6% 15% $17,600.64 $1,190,976.32
01/01/2003-03/3 1/2003 5% 1.25% $14,887.20 $1,205,863.52
04/01/2003-06/30/2003 5% 1.25% $15,073.29 $1,220,936.81
07/01/2003-09/30/2003 5% 1.25% $15,261.71 $1,236,198.52
10/01/2003-12/3 1/2003 4% 1% $12,361.99 $1,248,560.51
01/01/2004-03/3 1/2004 4% 1% $12,485.61 $1,261,046.12
04/01/2004-06/30/2004 5% 1.25% $15,763.08 $1,276,809.20
07/01/2004-09/30/2004 4% 1% $12,768.09 $1,289,577.29
10/01/2004-12/3 1/2004 5% 1.25% $16,119.72 $1,305,697.01
01/01/2005-03/3 1/2005 5% 1.25% $16,321.21 $1,322,018.22
04/01/2005-06/30/2005 6% 1.5% $19,830.27 $1,341,848.49
07/01/2005-09/30/2005 6% 1.5% $20,127.73 $1,361,976.22
10/01/2005-12/3 1/2005 T% 1.75% $23,834.58 $1,385,810.80
01/01/2006-03/3 1/2006 T% 1.75% $24,251.69 $1,410,062.49
04/01/2006-06/30/2006 Th 1.75% $24,676.09 $1,434,738.58
07/01/2006-09/30/2006 8% 2% $28,694.77 $1,463,433.35
10/01/2006-12/3 1/2006 8% 2% $29,268.67 $1,492,702.02
01/01/2007-03/3 1/2007 8% 2% $29,854.04 $1,522,556.06
04/01/2007-06/30/2007 8% 2% $30,451.12 $1,553,007.18
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
03/01/2000-06/30/2007 $587,332.18 $1,553,007.18

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):

Payoff Date (mm/dd/yyyy): [orne007 |

Header for Report [Optional - 80 Chars Max]:[Furlong - March 1997 sales of HCCA stock

Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html

6/12/2007


L LEGAL ANALYSIS

A. SUMMARY OF VIOLATIONS

The verdict forms indicate that the jury found in favor of the SEC, and against
Furlong and Pietrzak, on the fraud charges, on the aiding and abetting charges, and on the
internal accounting controls violations. Further, the jury’s responses to the verdict
interrogatories indicate that the jury concluded that Furlong and Pietrzak engaged in
knowing or reckless fraud in connection with the recording of all of the assets of HCCA
on the company’s financial statements including: 1) the value of the Advertising Credits;
2) the recording of the Notes Receivable; 3) the value of the Skull Valley, Arizona
mineral asset; 4) the value of the Silver Valley, California mineral asset; and 5) the
recording of, and value of the Real Estate. Finally, the jury found fraud by Furlong and
Pietrzak in connection with HCCA press releases which related to all of the assets
outlined above, except for the Notes Receivable. A summary of the violations follows.

1. The Defendants Violated The Antifraud Provisions

The defendants violated §17(a) of the Securities Act, which proscribes fraudulent
conduct in the offer or sale of securities, and §10(b) of the Exchange Act and Rule 10b-5,
which proscribe fraudulent conduct in connection with the purchase or sale of securities.
Those provisions prohibit essentially the same type of sales practices. See U. S. v. Naftalin,
441 U.S. 768, 773 n.4 (1979). Among other things, those provisions make it unlawful to
make any untrue statement of material fact, or omit to state any material fact necessary in
order to make the statements made, in light of the circumstances under which they were
made, not misleading, in the offer, purchase or sale of securities. Whether a fact is material
depends upon the significance a reasonable investor would place on the withheld or
misrepresented information in making an investment decision. Basic, Inc. v. Levinson, 485
US. 224, 231 (1988). The SEC has proved that defendants Furlong and Pietrzak acted with
scienter, and has established a violation of §17(a)(1) of the Securities Act and §10(b) of the
Exchange Act and Rule 10b-5 thereunder. Aaron v. SEC, 446 U.S. 680, 695 (1980).
Recklessness satisfies the scienter requirement. Hollinger v. Titan Capital Corp., 914
F.2d 1564, 1569 (9" Cir. 1990); McDonald v. Alan Bush, 863 F.2d 809, 814 (11" Cir.
1989). Furlong and Pietrzak violated these antifraud provisions by preparing and filing



2000 Sales By Month, With Prejudgment Interest

Through July 16, 2007


Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): fom 6/2007 _
Header for Report [Optional - 80 Chars Max];Furlong - June 1998 sales of HCCA stock
Click here for FA
Click here for the memorandum describing the method for calculating interest
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Page 2 of 2

Prejudgment Violation Range Quarter Interest Total Prejudgment Total
10/01/1998-06/30/2007 $11,163.92 $25,211.92

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


SUMMARY EVIDENCE #7

AMOUNTS TO BE DISGORGED BY EACH DEFENDANT FOR MISCONDUCT
DURING THE RELEVANT PERIOD

Amount of Relevant Period
Defendant Disgorgement Subject to Disgorgement
Furlong $ 3,452,491 January 1997 — June 2000
Pietrzak $ 1,296,720 January 1997 — June 2000
Jordan $191,400 January 2000 - June 2000

PREJUDGMENT INTEREST OWED BY EACH DEFENDANT, CALCULATED
MONTHLY DURING RELEVANT PERIOD

Prejudgment Relevant Period Subject
Defendant Interest to Prejudgment Interest
Furlong $ 2,515,724 January 1997 — July 16, 2007
Pietrzak $ 836,866 January 1997 — July 16, 2007
Jordan $ 116,529 January 2000 — July 16, 2007

$ 3,469,119



Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): for 6/2007
Header for Report [Optional - 80 Chars Max]:|Furlong - May 2000 sales of HCCA stock
Click here for the PJ IC FAQ
Click here for the memorandum describing the method for calculating interest
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):

Payoff Date (mm/dd/yyyy): [ov16/2007

Header for Report [Optional - 80 Chars Max];[Furlong - August 1998 sales of HCCA stock

feel ae
Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html

6/12/2007


Furlong - May 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $8,262.00
06/01/1997-06/30/1997 9% 0.75% $61.97 $8,323.97
07/01/1997-09/30/1997 9% 2.25% $187.29 $8,511.26
10/01/1997-12/31/1997 9% 2.25% $191.50 $8,702.76
01/01/1998-03/31/1998 9% 2.25% $195.81 $8,898.57
04/01/1998-06/30/1998 8% 2% $177.97 $9,076.54
07/01/1998-09/30/1998 8% 2% $181.53 $9,258.07
10/01/1998-12/31/1998 8% 2% $185.16 $9,443.23
01/01/1999-03/31/1999 TH 1.75% $165.26 $9,608.49
04/01/1999-06/30/1999 8% 2% $192.17 $9,800.66
07/01/1999-09/30/1999 8% 2% $196.01 $9,996.67
10/01/1999-12/3 1/1999 8% 2% $199.93 $10,196.60
01/01/2000-03/3 1/2000 8% 2% $203.93 $10,400.53
04/01/2000-06/30/2000 9% 2.25% $234.01 $10,634.54
07/01/2000-09/30/2000 9% 2.25% $239.28 $10,873.82
10/01/2000-12/3 1/2000 9% 2.25% $244.66 $11,118.48
01/01/2001-03/31/2001 9% 2.25% $250.17 $11,368.65
04/01/2001-06/30/2001 8% 2% $227.37 $11,596.02
07/01/2001-09/30/2001 Th 1.75% $202.93 $11,798.95
10/01/2001-12/31/2001 TM% 1.75% $206.48 $12,005.43
01/01/2002-03/3 1/2002 6% 15% $180.08 $12,185.51
04/01/2002-06/30/2002 6% 15% $182.78 $12,368.29
07/01/2002-09/30/2002 6% 15% $185.52 $12,553.81
10/01/2002-12/31/2002 6% 1.5% $188.31 $12,742.12
01/01/2003-03/3 1/2003 5% 1.25% $159.28 $12,901.40
04/01/2003-06/30/2003 5% 1.25% $161.27 $13,062.67
07/01/2003-09/30/2003 5% 1.25% $163.28 $13,225.95
10/01/2003-12/3 1/2003 4% 1% $132.26 $13,358.21
01/01/2004-03/3 1/2004 4% 1% $133.58 $13,491.79
04/01/2004-06/30/2004 5% 1.25% $168.65 $13,660.44
07/01/2004-09/30/2004 4% 1% $136.60 $13,797.04
10/01/2004-12/31/2004 5% 1.25% $172.46 $13,969.50
01/01/2005-03/31/2005 5% 1.25% $174.62 $14,144.12
04/01/2005-06/30/2005 6% 1.5% $212.16 $14,356.28
07/01/2005-09/30/2005 6% 1.5% $215.34 $14,571.62
10/01/2005-12/31/2005 T% 1.75% $255.00 $14,826.62
01/01/2006-03/3 1/2006 T% 1.75% $259.47 $15,086.09
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - May 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+ Interest
Violation Amount $127,788.00
06/01/1999-06/30/1999 8% 0.67% $851.92 $128,639.92
07/01/1999-09/30/1999 8% 2% $2,572.80 $131,212.72
10/01/1999-12/31/1999 8% 2% $2,624.25 $133,836.97
01/01/2000-03/3 1/2000 8% 2% $2,676.74 $136,513.71
04/01/2000-06/30/2000 9% 2.25% $3,071.56 $139,585.27
07/01/2000-09/30/2000 9% 2.25% $3,140.67 $142,725.94
10/01/2000-12/3 1/2000 9% 2.25% $3,211.33 $145,937.27
01/01/2001-03/31/2001 9% 2.25% $3,283.59 $149,220.86
04/01/2001-06/30/2001 8% 2% $2,984.42 $152,205.28
07/01/2001-09/30/2001 T% 1.75% $2,663.59 $154,868.87
10/01/2001-12/31/2001 T% 1.75% $2,710.21 $157,579.08
01/01/2002-03/3 1/2002 6% 15% $2,363.69 $159,942.77
04/01/2002-06/30/2002 6% 15% $2,399.14 $162,341.91
07/01/2002-09/30/2002 6% 1.5% $2,435.13 $164,777.04
10/01/2002-12/3 1/2002 6% 1.5% $2,471.66 $167,248.70
01/01/2003-03/3 1/2003 5% 1.25% $2,090.61 $169,339.31
04/01/2003-06/30/2003 5% 1.25% $2,116.74 $171,456.05
07/01/2003-09/30/2003 5% 1.25% $2,143.20 $173,599.25
10/01/2003-12/3 1/2003 4% 1% $1,735.99 $175,335.24
01/01/2004-03/3 1/2004 4% 1% $1,753.35 $177,088.59
04/01/2004-06/30/2004 5% 1.25% $2,213.61 $179,302.20
07/01/2004-09/30/2004 4% 1% $1,793.02 $181,095.22
10/01/2004-12/3 1/2004 5% 1.25% $2,263.69 $183,358.91
01/01/2005-03/3 1/2005 5% 1.25% $2,291.99 $185,650.90
04/01/2005-06/30/2005 6% 1.5% $2,784.76 $188,435.66
07/01/2005-09/30/2005 6% 1.5% $2,826.53 $191,262.19
10/01/2005-12/3 1/2005 TMM% 1.75% $3,347.09 $194,609.28
01/01/2006-03/3 1/2006 Th 1.75% $3,405.66 $198,014.94
. 04/01/2006-06/30/2006 TM% 1.75% $3,465.26 $201,480.20
07/01/2006-09/30/2006 8% 2% $4,029.60 $205,509.80
10/01/2006- 12/3 1/2006 8% 2% $4,110.20 $209,620.00
01/01/2007-03/3 1/2007 8% 2% $4,192.40 $213,812.40
04/01/2007-06/30/2007 8% 2% $4,276.25 $218,088.65
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
06/01/1999-06/30/2007 $90,300.65 $218,088.65
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


07/01/2006-09/30/2006

Page 2 of 2

8% 2% $2,243.87 $114,437.21
10/01/2006-12/31/2006 8% 2% $2,288.74 $116,725.95
01/01/2007-03/3 1/2007 8% 2% “$2,334.52 $119,060.47
04/01/2007-06/30/2007 8% 2% $2,381.21 $121,441.68
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
08/01/1997-06/30/2007 $60,152.67 $121,441.68

http://enforcenet/PJIC%20Web/Data_Entry html

6/12/2007


Page 2 of 2

04/01/2007-06/30/2007 8% 2% $1,372.65 $70,005.28
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
04/01/1998-06/30/2007 $32,513.28 $70,005.28

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - June 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page | of 2

_US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $64,491.00
07/01/1997-09/30/1997 9% 2.25% $1,451.05 $65,942.05
10/01/1997-12/31/1997 9% 2.25% $1,483.70 $67,425.75
01/01/1998-03/3 1/1998 9% 2.25% $1,517.08 $68,942.83
04/01/1998-06/30/1998 8% 2% $1,378.86 $70,321.69
07/01/1998-09/30/1998 8% 2% $1,406.43 $71,728.12
10/01/1998-12/31/1998 8% 2% $1,434.56 $73,162.68
01/01/1999-03/31/1999 T% 1.75% $1,280.35 $74,443.03
04/01/1999-06/30/1999 8% 2% $1,488.86 $75,931.89
07/01/1999-09/30/1999 8% 2% $1,518.64 $77,450.53
10/01/1999-12/31/1999 8% 2% $1,549.01 $78,999.54
01/01/2000-03/3 1/2000 8% 2% $1,579.99 $80,579.53
04/01/2000-06/30/2000 9% 2.25% $1,813.04 $82,392.57
07/01/2000-09/30/2000 9% 2.25% $1,853.83 $84,246.40
10/01/2000-12/3 1/2000 9% 2.25% $1,895.54 $86,141.94
01/01/2001-03/31/2001 9% 2.25% $1,938.19 $88,080.13
04/01/2001-06/30/2001 8% 2% $1,761.60 $89,841.73
07/01/2001-09/30/2001 TH 1.75% $1,572.23 $91,413.96
10/01/2001-12/31/2001 T% 1.75% $1,599.74 $93,013.70
01/01/2002-03/3 1/2002 6% 15% $1,395.21 $94,408.91
04/01/2002-06/30/2002 6% 1.5% $1,416.13 $95,825.04
07/01/2002-09/30/2002 6% 1.5% $1,437.38 $97,262.42
10/01/2002-12/3 1/2002 6% 1.5% $1,458.94 $98,721.36
01/01/2003-03/3 1/2003 5% 1.25% $1,234.02 $99,955.38
04/01/2003-06/30/2003 5% 1.25% $1,249.44 $101,204.82
07/01/2003-09/30/2003 5% 1.25% $1,265.06 $102,469.88
10/01/2003-12/3 1/2003 4% 1% $1,024.70 $103,494.58
01/01/2004-03/31/2004 4% 1% $1,034.95 $104,529.53
04/01/2004-06/30/2004 5% 1.25% $1,306.62 $105,836.15
07/01/2004-09/30/2004 4% 1% $1,058.36 $106,894.51
10/01/2004-12/31/2004 5% 1.25% $1,336.18 $108,230.69
01/01/2005-03/3 1/2005 5% 1.25% $1,352.88 . $109,583.57
04/01/2005-06/30/2005 6% 1.5% $1,643.75 $111,227.32
07/01/2005-09/30/2005 6% 1.5% $1,668.41 $112,895.73
10/01/2005-12/3 1/2005 Th 1.75% $1,975.68 $114,871.41
01/01/2006-03/3 1/2006 T% 1.75% $2,010.25 $116,881.66
04/01/2006-06/30/2006 T% 1.75% $2,045.43 $118,927.09
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

04/01/2007-06/30/2007 8% 2% $2,330.60 $118,860.56
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
06/01/1998-06/30/2007 $54,360.56 $118,860.56

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): fori 6/2007

Header for Report [Optional - 80 Chars Max]:[Furlong - April 2000 sales of HCCA stock

Click here for the PIC FAQ

Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Page 2 of 2

10/01/2006-12/3 1/2006 8% 2% $1,338.29 $68,253.02
01/01/2007-03/3 1/2007 8% 2% $1,365.06 $69,618.08
04/01/2007-06/30/2007 ~ 8% 2% $1,392.36 $71,010.44
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
10/01/1997-06/30/2007 $34,635.44 $71,010.44

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - December 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $16,260.00
01/01/1999-03/31/1999 TM% 1.75% $284.55 $16,544.55
04/01/1999-06/30/1999 8% 2% $330.89 $16,875.44
07/01/1999-09/30/1999 8% 2% $337.51 $17,212.95
10/01/1999-12/3 1/1999 8% 2% $344.26 $17,557.21
01/01/2000-03/3 1/2000 8% 2% $351.14 $17,908.35
04/01/2000-06/30/2000 9% 2.25% $402.94 $18,311.29
07/01/2000-09/30/2000 9% 2.25% $412.00 $18,723.29
10/01/2000-12/3 1/2000 9% 2.25% $421.27 $19,144.56
01/01/2001-03/3 1/2001 9% 2.25% $430.75 $19,575.31
04/01/2001-06/30/2001 8% 2% $391.51 $19,966.82
07/01/2001-09/30/2001 TMM% 1.75% $349.42 $20,316.24
10/01/2001-12/31/2001 T% 1.75% $355.53 $20,671.77
01/01/2002-03/3 1/2002 6% 1.5% $310.08 $20,981.85
04/01/2002-06/30/2002 6% 1.5% $314.73 $21,296.58
07/01/2002-09/30/2002 6% 1.5% $319.45 $21,616.03
10/01/2002-12/3 1/2002 6% 1.5% $324.24 $21,940.27
01/01/2003-03/3 1/2003 5% 1.25% $274.25 $22,214.52
04/01/2003-06/30/2003 5% 1.25% $277.68 $22,492.20
07/01/2003-09/30/2003 5% 1.25% $281.15 $22,773.35
10/01/2003-12/3 1/2003 4% 1% $227.73 $23,001.08
01/01/2004-03/3 1/2004 4% 1% $230.01 $23,231.09
04/01/2004-06/30/2004 5% 1.25% $290.39 $23,521.48
07/01/2004-09/30/2004 4% 1% $235.21 $23,756.69
10/01/2004-12/31/2004 5% 1.25% $296.96 $24,053.65
01/01/2005-03/3 1/2005 5% 1.25% $300.67 $24,354.32
04/01/2005-06/30/2005 6% 15% $365.31 $24,719.63
07/01/2005-09/30/2005 6% 15% $370.79 $25,090.42
10/01/2005-12/31/2005 TTM% 1.75% $439.08 $25,529.50
01/01/2006-03/3 1/2006 T% 1.75% $446.77 $25,976.27
04/01/2006-06/30/2006 TTM% 1.75% $454.58 $26,430.85
07/01/2006-09/30/2006 8% 2% $528.62 $26,959.47
10/01/2006-12/3 1/2006 8% 2% $539.19 $27,498.66
01/01/2007-03/3 1/2007 8% 2% $549.97 $28,048.63
04/01/2007-06/30/2007 8% 2% $560.97 $28,609.60
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


sales from 1/1/1997 through 6/30/2000, which reflects prejudgment interest calculations
for each month during which Pietrzak sold the stock, through 7/16/2007. Exhibits C and
D show precisely how Seiden calculated prejudgment interest. Based upon the
calculations as set forth conclusively in Exhibit B, attached hereto, the SEC seeks from
Furlong $3,452,491 in disgorgement, with prejudgment interest thereon in the amount of
$2,515,724, for a total of $5,968,215; and the SEC seeks from Pietrzak $1,296,720 in
disgorgement, with prejudgment interest thereon in the amount of $836,866, for a total of
$2,133,586.

2. Civil Penalties Against Furlong And Pietrzak

The SEC also seeks civil money penalties against Furlong and Pietrzak pursuant
to §20(d) of the Securities Act and §21(d)(3) of the Exchange Act. Civil penalties are
appropriate in this case because of the deceptive nature of their conduct. As discussed
above, the filings at issue in this matter contained fraudulent misrepresentations and
omissions in violation of the antifraud provisions.° Moreover, Furlong and Pietrzak
profited from their fraud by selling HCCA stock.

Section 20(d) of the Securities Act and §21(d)(3) of the Exchange Act provide that
the SEC may seek to have a court impose civil penalties. First tier penalties for any violation
(arising from conduct that, as in this case, occurred before 2/1/2001, but not earlier than
1996) may be imposed up to the larger of $5,500 for a natural person or $55,000 for any
other person, or the amount of ill-gotten gain. When the violation involves fraud, 2TM tier
penalties may be imposed up to $55,000 for a natural person or $275,000 for any other
person, or the amount of the ill-gotten gain. A 3“ tier civil penalty of up to the larger of
$110,000 for a natural person or $550,000 for any other person, or the amount of ill-gotten
gain may be imposed when any provision of the Securities Act or the Exchange Act is
violated, if the violation involved fraud or deceit and the violation resulted in substantial

losses or created a significant risk of substantial losses to other persons.’

© The SEC seeks penalties on the violative conduct that was less than 5 years old when the complaint
was filed. See Johnson v. SEC, 87 F.3d 484 (D.C. Cir. 1996).

7 Civil monetary penalties pursuant to the Securities Act and the Exchange Act are required to be
adjusted for inflation. Furlong’s and Pietrzak’s conduct herein occurred in 1996, 1997, 1998,
1999, and 2000 before the time that the adjustment became effective in early 2001. 17 C.F.R.
201.1001, Adjustment of civil monetary penalties - 1996. LEXSEE 66 FR 8761 at 8762. The

12


internal controls sufficient to allow the preparation of financial statements in conformity
with GAAP.

HCCA violated §13(b)(2)(A) of the Exchange Act by not accurately recording the
mining, real estate, advertising credits, and notes receivable assets on its books and in its
records. From 1997 through 1999, Furlong and Pietrzak provided knowing and
substantial assistance when HCCA violated §13(b)(2)(A) by participating in recording
these assets when they knew, or were reckless not knowing, that the values ascribed to
these assets were substantially overstated. Accordingly, Furlong and Pietrzak are liable
for aiding and abetting HCCA’s 1997 through 1999 violations of §13(b)(2)(A). In
addition, Furlong and Pietrzak shared responsibility for maintaining the books and
records that were used to prepare HCCA's financial statements.

HCCA violated §13(b)(2)(B) of the Exchange Act by failing to devise internal
accounting controls that were sufficient to allow the preparation of its financial
statements in conformity with GAAP. From 1997 through 1999, Furlong and Pietrzak
shared responsibility for establishing and maintaining HCCA’s internal accounting
controls, and they provided knowing and substantial assistance when HCCA violated
§13(b)(2)(B) by not establishing adequate controls when they were aware that HCCA
was recording transactions without all pertinent information and documents concerning
those transactions. Accordingly, Furlong and Pietrzak are liable for aiding and abetting
HCCA’s violations of §13(b)(2)(B). Rule 13b2-1 prohibits any person from directly or
indirectly falsifying or causing the falsification of any books, records or accounts
required by §13(b)(2)(A). HCCA falsified its books, records, and accounts when it did
not properly record the values of its mining, real estate, advertising credit, and notes
receivable assets. Furlong, and Pietrzak directly or indirectly falsified or caused the
falsification of HCCA’s books, records, and accounts by participating in, directing or
approving these improper entries on HCCA’s books and records.

Section 13(b)(5) of the Exchange Act prohibits any person from knowingly
circumventing or knowingly failing to implement a system of internal accounting
controls, and from knowingly falsifying any book, record, or account, required under
§13(b)(2). Furlong and Pietrzak knowingly falsified HCCA’s books, records, or accounts
by participating in the improper entries on HCCA’s books and records. Furlong and


Page 2 of 2

07/01/2006-09/30/2006 8% 2% $3,222.19 $164,331.47
10/01/2006-12/31/2006 8% 2% $3,286.63 $167,618.10
01/01/2007-03/3 1/2007 8% 2% $3,352.36 $170,970.46
04/01/2007-06/30/2007 8% 2% : $3,419.41 $174,389.87
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
09/01/1997-06/30/2007 $85,723.87 $174,389.87
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

Prejudgment Violation Range Quarter Interest Total Prejudgment Total
08/01/1998-06/30/2007 $12,815.66 $28,470.66

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

Prejudgment Violation Range Quarter Interest Total Prejudgment Total
11/01/1998-06/30/2007 $8,808.42 $20,058.42

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

FURLONG,

Defendants.

EASTERN DIVISION

SECURITIES AND EXCHANGE COMMISSION, )

)

Plaintiff, )

) Civil Action No.
vs. ) 03C-1507

)
MICHAEL J. PIETRZAK and MAURICE W. ) Judge Grady

)

)

)

)

SEC’s MOTION AND BRIEF TO IMPOSE PERMANENT INJUNCTIONS,
DISGORGEMENT, PREJUDGMENT INTEREST, CIVIL PENALTIES,
OFFICER-DIRECTOR BARS AND PENNY STOCK BARS AGAINST FURLONG

AND PIETRZAK, AND TO ENTER FINAL JUDGMENT AGAINST THEM

The SEC hereby moves the Court to impose final judgment against Michael
Pietrzak and Maurice Furlong. This motion follows a 3 week jury trial, which resulted in
a verdict for the SEC and against the defendants on all counts, including fraud, reporting,
books and records, and internal accounting controls violations. The jury returned its
verdict on 8/3/2007. Jury responses to the verdict interrogatories indicated that it found
fraud, against both defendants, on every category of assets that HCCA recorded on its
balance sheet between 1996 and 2001. Further, the jury found fraud in virtually all press
releases that the defendants caused HCCA to issue between 1996 and 2001.

The final judgment against Pietrzak and Furlong should include permanent
injunctions for all of the violations alleged by the SEC, and should set disgorgement
against Pietrzak in the amount of $1,296,720, and against Furlong in the amount of $
3,452,491, equaling the gross proceeds they made from the sales of their HCCA stock
between 1/1/1997 and 6/30/2000, during the time the fraud on the public was ongoing.
Further, it should include prejudgment interest on disgorgement, and a substantial civil
penalty against each defendant. Finally, the final judgment should include bars which
prohibit Pietrzak and Furlong from serving as officers or directors of public companies,

or from participating in penny stock offerings in the future.


Page 1 of 1

USS. Securities and Exchange Commission

Division of Enforcement

Prejudgment Interest Report

Furlong - July 1999 sales of HCCA stock

Quarter Range Annual Rate Period Rate Quarter Interest Principal+ Interest
Violation Amount $43,775.00
08/01/1999-09/30/1999 8% 1.33% $583.67 $44,358.67
10/01/1999-12/31/1999 8% 2% $887.17 $45,245.84
01/01/2000-03/3 1/2000 8% 2% $904.92 $46,150.76
04/01/2000-06/30/2000 9% 2.25% $1,038.39 $47,189.15
07/01/2000-09/30/2000 9% 2.25% $1,061.76 $48,250.91
10/01/2000-12/3 1/2000 9% 2.25% $1,085.65 $49,336.56
01/01/2001-03/3 1/2001 9% 2.25% $1,110.07 $50,446.63
04/01/2001-06/30/2001 8% 2% $1,008.93 $51,455.56
07/01/2001-09/30/2001 TM% 1.75% $900.47 $52,356.03 -
10/01/2001-12/3 1/2001 TM% 1.75% $916.23 $53,272.26
01/01/2002-03/3 1/2002 6% 1.5% $799.08° $54,071.34
04/01/2002-06/30/2002 6% 15% $811.07 $54,882.41
07/01/2002-09/30/2002 6% 1.5% $823.24 $55,705.65
10/01/2002-12/3 1/2002 6% 1.5% $835.58 "$56,541.23
01/01/2003-03/3 1/2003 5% 1.25% $706.77 $57,248.00
04/01/2003-06/30/2003 5% 1.25% $715.60 $57,963.60
07/01/2003-09/30/2003 5% 1.25% $724.55 $58,688.15
10/01/2003-12/3 1/2003 4% 1% $586.88 $59,275.03
01/01/2004-03/3 1/2004 4% 1% $592.75 $59,867.78
04/01/2004-06/30/2004 5% 1.25% $748.35 $60,616.13
07/01/2004-09/30/2004 4% 1% $606.16 $61,222.29
10/01/2004-12/3 1/2004 5% 1.25% $765.28 $61,987.57
01/01/2005-03/3 1/2005 5% 1.25% $774.84 $62,762.41
04/01/2005-06/30/2005 6% 1.5% $941.44 $63,703.85
07/01/2005-09/30/2005 6% 1.5% $955.56 $64,659.41
10/01/2005-12/3 1/2005 TMM% 1.75% $1,131.54 $65,790.95
01/01/2006-03/3 1/2006 TH 1.75% $1,151.34 $66,942.29.
04/01/2006-06/30/2006 TMM% 1.75% $1,171.49 $68,113.78
07/01/2006-09/30/2006 8% 2% $1,362.28 $69,476.06
10/01/2006-12/3 1/2006 8% 2% $1,389.52 $70,865.58
01/01/2007-03/3 1/2007 8% 2% $1,417.31 $72,282.89
04/01/2007-06/30/2007 8% 2% $1,445.66 $73,728.55
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
08/01/1999-06/30/2007 $29,953.55 $73,728.55

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Furlong - June 2000 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 1

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+ Interest
Violation Amount $55,200.00
07/01/2000-09/30/2000 % 2.25% $1,242.00 $56,442.00
10/01/2000-12/3 1/2000 9% 2.25% $1,269.95 $57,711.95
01/01/2001-03/3 1/2001 9% 2.25% $1,298.52 $59,010.47
04/01/2001-06/30/2001 8% 2% $1,180.21 $60,190.68
07/01/2001-09/30/2001 TM% 1.75% $1,053.34 $61,244.02
10/01/2001-12/31/2001 T% 1.75% $1,071.77 $62,315.79
01/01/2002-03/3 1/2002 6% 1.5% $934.74 $63,250.53
04/01/2002-06/30/2002 6% 1.5% $948.76 $64,199.29
07/01/2002-09/30/2002 6% 1.5% $962.99 $65,162.28
10/01/2002-12/31/2002 6% 15% $977.43 $66,139.71
01/01/2003-03/3 1/2003 5% 1.25% $826.75 $66,966.46
04/01/2003-06/30/2003 5% 1.25% $837.08 $67,803.54
07/01/2003-09/30/2003 5% 1.25% $847.54 $68,651.08
10/01/2003-12/3 1/2003 4% 1% $686.51 $69,337.59
01/01/2004-03/3 1/2004 4% 1% $693.38 $70,030.97
04/01/2004-06/30/2004 5% 1.25% $875.39 $70,906.36
07/01/2004-09/30/2004 4% 1% $709.06 $71,615.42
10/01/2004-12/3 1/2004 5% 1.25% $895.19 $72,510.61
01/01/2005-03/3 1/2005 5% 1.25% $906.38 $73,416.99
04/01/2005-06/30/2005 6% 15% $1,101.25 $74,518.24
07/01/2005-09/30/2005 6% 1.5% $1,117.77 $75,636.01
10/01/2005-12/3 1/2005 TM% 1.75% $1,323.63 $76,959.64
01/01/2006-03/3 1/2006 Th 1.75% $1,346.79 $78,306.43
04/01/2006-06/30/2006 TMM% 1.75% $1,370.36 $79,676.79
07/01/2006-09/30/2006 8% 2% $1,593.54 $81,270.33
10/01/2006- 12/31/2006 8% 2% $1,625.41 $82,895.74
01/01/2007-03/3 1/2007 8% 2% $1,657.91 $84,553.65
04/01/2007-06/30/2007 8% 2% $1,691.07 $86,244.72
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
07/01/2000-06/30/2007 $31,044.72 $86,244.72
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


disclose whether there were disagreements between HCCA and McGhie, failed to
disclose McGhie’s response letter to the filing of the Form 8-K, and misrepresented
McGhie’s willingness to be associated with previous HCCA financial statements. HCCA
also violated §13(a) of the Exchange Act and Rules 13a-1 and 13a-13 by failing to file
annual and quarterly reports since the September 1999 Form 10-QSB, filed 12/13/1999.

Furlong and Pietrzak aided and abetted HCCA’s violations of §13(a) of the
Exchange Act and Rules 12b-20, 13a-1, 13a-11, and 13a-13. Section 20(e) of the
Exchange Act defines aiding and abetting as knowingly providing substantial assistance
to another person in violation of a provision of the Exchange Act or any rule or regulation
thereunder. See also SEC v. Fehn, 97 F.3d 1276, 1288 (9" Cir. 1996) (noting that
Congress employed language in §20(e) identical to that previously used by lower federal
courts in articulating the elements of aiding and abetting). Substantial assistance can be
rendered knowingly or recklessly. Graham v. SEC, 222 F.3d 994, 1000 (D.C. Cir. 2000)
(recklessness is sufficient scienter for an aiding and abetting charge under the federal
securities laws). They knowingly provided substantial assistance to HCCA when it
violated the reporting provisions. They each prepared and/or signed HCCA’s filings on
Forms 10-SB, 10-KSB and 10-QSB, and Furlong signed the Form 8-K. See Exhibit A.
They knew from documents in their possession and/or personal knowledge that the mining
assets located in Arizona and California had little or no value, the real estate transactions
had not been consummated, the advertising credits were worthless, and the notes receivable
were not collectible. As they prepared and signed HCCA’s filings, Furlong and Pietrzak
ignored warnings provided to them that indicated that the recording of the transactions in
question did not conform with GAAP.

3. Furlong And Pietrzak Aided And Abetted HCCA’s Violations

Of The Internal Accounting Controls And Books And Records
Provisions

Furlong and Pietrzak aided and abetted HCCA’s 1996 through 1999 violations of
Exchange Act §§13(b)(2)(A) and 13(b)(2)(B). They also violated Exchange Act
§13(b)(5) and Rule 13b2-1. Section 13(b)(2)(A) requires reporting companies to make
and keep accounting records that accurately reflect their transactions and the dispositions

of their assets. Section 13(b)(2)(B) requires reporting companies to devise and maintain


Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): loz 16/2007
Header for Report [Optional - 80 Chars Max]:[Furlong - August 1999 sales of HCCA stock
Click here for the PIIC FAQ
ick here for the memorandum describing the method for calculating interest
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

04/01/2006-06/30/2006 M% 1.75% $2,699.83 $156,976.10
07/01/2006-09/30/2006 8% 2% $3,139.52 $160,115.62
10/01/2006-12/3 1/2006 8% 2% $3,202.31 $163,317.93
01/01/2007-03/3 1/2007 8% 2% $3,266.36 $166,584.29
04/01/2007-06/30/2007 8% 2% $3,331.69 $169,915.98
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
05/01/1997-06/30/2007 $86,049.98 $169,915.98
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


1999 Sales By Month, With Prejudgment Interest

Through July 16, 2007


Furlong - November 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $1,500.00
12/01/1998-12/3 1/1998 8% 0.67% $10.00 $1,510.00
01/01/1999-03/31/1999 TMM 1.75% $26.43 $1,536.43
04/01/1999-06/30/1999 8% 2% $30.73 $1,567.16
07/01/1999-09/30/1999 8% 2% $31.34 $1,598.50
10/01/1999-12/31/1999 8% 2% $31.97 $1,630.47
01/01/2000-03/3 1/2000 8% 2% $32.61 $1,663.08
04/01/2000-06/30/2000 % 2.25% $37.42 $1,700.50
07/01/2000-09/30/2000 9% 2.25% $38.26 $1,738.76
10/01/2000-12/3 1/2000 % 2.25% $39.12 $1,777.88
01/01/2001-03/3 1/2001 9% 2.25% $40.00 $1,817.88
04/01/2001-06/30/2001 8% 2% $36.36 $1,854.24
07/01/2001-09/30/2001 TM% 1.75% $32.45 $1,886.69
10/01/2001-12/31/2001 T% 1.75% $33.02 $1,919.71
01/01/2002-03/3 1/2002 6% 1.5% $28.80 $1,948.51
04/01/2002-06/30/2002 6% 15% $29.23 $1,977.74
07/01/2002-09/30/2002 6% 1.5% $29.67 $2,007.41
10/01/2002-12/3 1/2002 6% 1.5% $30.11 $2,037.52
01/01/2003-03/3 1/2003 5% 1.25% $25.47 $2,062.99
04/01/2003-06/30/2003 5% 1.25% $25.79 $2,088.78
07/01/2003-09/30/2003 5% 1.25% $26.11 $2,114.89
10/01/2003-12/3 1/2003 4% 1% $21.15 $2,136.04
01/01/2004-03/3 1/2004 4% 1% $21.36 $2,157.40
04/01/2004-06/30/2004 5% 1.25% $26.97 $2,184.37
07/01/2004-09/30/2004 4% 1% $21.84 $2,206.21
10/01/2004-12/31/2004 5% 1.25% $27.58 $2,233.79
01/01/2005-03/3 1/2005 5% 1.25% $27.92 $2,261.71
04/01/2005-06/30/2005 6% 1.5% $33.93 $2,295.64
07/01/2005-09/30/2005 6% 1.5% $34.43 $2,330.07
10/01/2005-12/3 1/2005 T% 1.75% $40.78 $2,370.85
01/01/2006-03/3 1/2006 TMM% 1.75% $41.49 $2,412.34
04/01/2006-06/30/2006 T% 1.75% $42.22 $2,454.56
07/01/2006-09/30/2006 8% 2% $49.09 $2,503.65
10/01/2006-12/3 1/2006 8% 2% $50.07 $2,553.72
01/01/2007-03/31/2007 8% 2% $51.07 $2,604.79
04/01/2007-06/30/2007 8% 2% $52.10 $2,656.89
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


RESPECTFULLY SUBMITTED,

/s/Edward G. Sullivan
Edward G. Sullivan
Senior Trial Counsel

/s/William P. Hicks
William P. Hicks
Regional Trial Counsel

COUNSEL FOR PLAINTIFF

SECURITIES AND EXCHANGE COMMISSION
3475 Lenox Road, N.E. Suite 1000

Atlanta, Georgia 30326

(404) 842-7612

CERTIFICATE OF SERVICE

I hereby certify that the foregoing SEC’°S MOTION AND BRIEF TO IMPOSE
PERMANENT INJUNCTIONS, DISGORGEMENT, PREJUDGMENT INTEREST,
CIVIL PENALTIES, OFFICER-DIRECTOR BARS AND PENNY STOCK BARS
AGAINST FURLONG AND PIETRZAK, AND TO ENTER FINAL JUDGMENT
AGAINST THEM was served by ECF filing with the Court, which automatically notifies
counsel, on this 27" day of August, 2007, upon the following:

Keith E. Roberts, Esq.

Robert S. Marcott, Esq.

Roberts & Associates, P.C.

104 East Roosevelt Road, Suite 202
Wheaton, IL 60187

/s/Edward G. Sullivan
Edward G. Sullivan
Senior Trial Counsel

Counsel for Plaintiff

Securities and Exchange Commission
3475 Lenox Road, N.E., Suite 1000
Atlanta, Georgia 30326

(404) 842-7612

16


Page 2 of 2

01/01/2007-03/3 1/2007 8% 2% $3,142.50 $160,267.68
04/01/2007-06/30/2007 8% 2% $3,205.35 $163,473.03
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
01/01/1998-06/30/2007 $77,850.03 $163,473.03
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007
Violation Amount: {9600.00
Violation Start Date (mm/dd/yyyy): 03/31/1999

Payoff Date (mm/dd/yyyy): ova 6/2007

Header for Report [Optional - 80 Chars Max],|Furlong - March 1999 sales of HCCA stock

Click here for the PIIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - August 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $9,132.00
09/01/1998-09/30/1998 8% 0.67% $60.88 $9,192.88
10/01/1998-12/31/1998 8% 2% $183.86 $9,376.74
01/01/1999-03/3 1/1999 TMM% 1.75% $164.09 $9,540.83
04/01/1999-06/30/1999 8% 2% $190.82 $9,731.65
07/01/1999-09/30/1999 8% 2% $194.63 $9,926.28
10/01/1999-12/31/1999 8% 2% $198.53 $10,124.81
01/01/2000-03/3 1/2000 8% 2% $202.50 $10,327.31
04/01/2000-06/30/2000 9% 2.25% $232.36 $10,559.67
07/01/2000-09/30/2000 9% 2.25% $237.59 $10,797.26
10/01/2000-12/3 1/2000 9% 2.25% $242.94 $11,040.20
01/01/2001-03/31/2001 9% 2.25% $248.40 $11,288.60
04/01/2001-06/30/2001 8% 2% $225.77 $11,514.37
07/01/2001-09/30/2001 T% 1.75% $201.50 $11,715.87
10/01/2001-12/31/2001 T% 1.75% $205.03 $11,920.90
01/01/2002-03/3 1/2002 6% 1.5% $178.81 $12,099.71
04/01/2002-06/30/2002 6% 1.5% $181.50 $12,281.21
07/01/2002-09/30/2002 6% 1.5% $184.22 $12,465.43
10/01/2002-12/3 1/2002 6% 1.5% $186.98 $12,652.41
01/01/2003-03/3 1/2003 5% 1.25% $158.16 $12,810.57
04/01/2003-06/30/2003 5% 1.25% $160.13 $12,970.70
07/01/2003-09/30/2003 5% 1.25% $162.13 $13,132.83
10/01/2003-12/3 1/2003 4% 1% $131.33 $13,264.16
01/01/2004-03/3 1/2004 4% 1% $132.64 $13,396.80
04/01/2004-06/30/2004 5% 1.25% $167.46 $13,564.26
07/01/2004-09/30/2004 4% 1% $135.64 $13,699.90
10/01/2004-12/3 1/2004 5% 1.25% $171.25 $13,871.15
01/01/2005-03/3 1/2005 5% 1.25% $173.39 $14,044.54
04/01/2005-06/30/2005 6% 15% $210.67 $14,255.21
07/01/2005-09/30/2005 6% 15% $213.83 $14,469.04
10/01/2005-12/3 1/2005 TMM% 1.75% $253.21 $14,722.25
01/01/2006-03/31/2006 T% 1.75% $257.64 $14,979.89
04/01/2006-06/30/2006 T% 1.75% $262.15 $15,242.04
07/01/2006-09/30/2006 8% 2% $304.84 $15,546.88
10/01/2006-12/3 1/2006 8% 2% $310.94 $15,857.82
01/01/2007-03/3 1/2007 8% 2% $317.16 $16,174.98
04/01/2007-06/30/2007 8% 2% $323.50 $16,498.48
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

07/01/2006-09/30/2006 8% 2% $2,378.54 $121,305.63
10/01/2006-12/3 1/2006 8% 2% $2,426.11 $123,731.74
01/01/2007-03/3 1/2007 8% 2% $2,474.63 $126,206.37
04/01/2007-06/30/2007 8% 2% $2,524.13 $128,730.50
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
07/01/1997-06/30/2007 $64,239.50 $128,730.50
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


10/01/2006- 12/31/2006 8%
01/01/2007-03/31/2007 8%
04/01/2007-06/30/2007 8%

2%
2%
2%

Page 2 of 2

$2,392.90 $122,038.04
$2,440.76 $124,478.80
$2,489.58 $126,968.38

Prejudgment Violation Range
11/01/1997-06/30/2007

http://enforcenet/PJIC%20Web/Data_Entry html

Quarter Interest Total Prejudgment Total
$61,448.38 $126,968.38

6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): ova 6/2007,

Header for Report [Optional - 80 Chars Max]:[Furlong - December 1999 sales of HCCA stock

H

Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PIIC%20Web/Data_Entry.html 6/12/2007


Furlong - December 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $85,623.00
01/01/1998-03/3 1/1998 % 2.25% $1,926.52 $87,549.52
04/01/1998-06/30/1998 8% 2% $1,750.99 $89,300.51
07/01/1998-09/30/1998 8% 2% $1,786.01 $91,086.52
10/01/1998-12/3 1/1998 8% 2% $1,821.73 $92,908.25
01/01/1999-03/31/1999 T% 1.75% $1,625.89 $94,534.14
04/01/1999-06/30/1999 8% 2% $1,890.68 $96,424.82
07/01/1999-09/30/1999 8% 2% $1,928.50 $98,353.32
10/01/1999-12/31/1999 8% 2% $1,967.07 $100,320.39
01/01/2000-03/3 1/2000 8% 2% $2,006.41 $102,326.80
04/01/2000-06/30/2000 9% 2.25% $2,302.35 $104,629.15
07/01/2000-09/30/2000 9% 2.25% $2,354.16 $106,983.31
10/01/2000-12/3 1/2000 9% 2.25% $2,407.12 $109,390.43
01/01/2001-03/3 1/2001 9% 2.25% $2,461.28 $111,851.71
04/01/2001-06/30/2001 8% 2% $2,237.03 $114,088.74
07/01/2001-09/30/2001 Th 1.75% $1,996.55 $116,085.29
10/01/2001-12/31/2001 T% 1.75% $2,031.49 $118,116.78
01/01/2002-03/3 1/2002 6% 15% $1,771.75 $119,888.53
04/01/2002-06/30/2002 6% 15% $1,798.33 $121,686.86
07/01/2002-09/30/2002 6% 15% $1,825.30 $123,512.16
10/01/2002- 12/3 1/2002 6% 1.5% $1,852.68 $125,364.84
01/01/2003-03/3 1/2003 3% 1.25% $1,567.06 ‘$126,931.90
04/01/2003-06/30/2003 5% 1.25% $1,586.65 $128,518.55
07/01/2003-09/30/2003 5% 1.25% $1,606.48 $130,125.03
10/01/2003-12/3 1/2003 4% 1% $1,301.25 $131,426.28
01/01/2004-03/3 1/2004 4% 1% $1,314.26 $132,740.54
04/01/2004-06/30/2004 5% 1.25% $1,659.26 $134,399.80
07/01/2004-09/30/2004 4% 1% $1,344.00 $135,743.80
10/01/2004-12/31/2004 5% 1.25% $1,696.80 $137,440.60
01/01/2005-03/3 1/2005 5% 1.25% $1,718.01 $139,158.61
04/01/2005-06/30/2005 6% 1.5% $2,087.38 $141,245.99
07/01/2005-09/30/2005 6% 15% $2,118.69 $143,364.68
10/01/2005-12/3 1/2005 T% 1.75% $2,508.88 $145,873.56
01/01/2006-03/3 1/2006 % 1.75% $2,552.79 $148,426.35
04/01/2006-06/30/2006 T% 1.75% $2,597.46 $151,023.81
07/01/2006-09/30/2006 8% 2% $3,020.48 $154,044.29
10/01/2006-12/31/2006 8% 2% $3,080.89 $157,125.18
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): [ow 6/2007 __

Header for Report [Optional - 80 Chars Max];[Furlong - November 1997 sales of HCCA stock

Click here for the PJIC FAQ

ick here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - September 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $14,048.00
10/01/1998-12/3 1/1998 8% 2% $280.96 $14,328.96
01/01/1999-03/3 1/1999 T% 1.75% $250.76 $14,579.72
04/01/1999-06/30/1999 8% 2% $291.59 $14,871.31
07/01/1999-09/30/1999 8% 2% $297.43 $15,168.74
10/01/1999-12/3 1/1999 8% 2% $303.37 $15,472.11
01/01/2000-03/3 1/2000 8% — 2% $309.44 $15,781.55
04/01/2000-06/30/2000 9% 2.25% $355.08 $16,136.63
07/01/2000-09/30/2000 9% 2.25% $363.07 $16,499.70
10/01/2000-12/3 1/2000 9% 2.25% $371.24 $16,870.94
01/01/2001-03/3 1/2001 9% 2.25% $379.60 $17,250.54
04/01/2001-06/30/2001 8% 2% $345.01 $17,595.55
07/01/2001-09/30/2001 T% 1.75% $307.92 $17,903.47
10/01/2001-12/3 1/2001 T% 1.75% $313.31 $18,216.78
01/01/2002-03/3 1/2002 6% 1.5% $273.25 $18,490.03
04/01/2002-06/30/2002 6% 1.5% $277.35 $18,767.38
07/01/2002-09/30/2002 6% 1.5% $281.51 $19,048.89
10/01/2002-12/3 1/2002 6% 1.5% $285.73 $19,334.62
01/01/2003-03/3 1/2003 5% 1.25% $241.68 $19,576.30
04/01/2003-06/30/2003 5% 1.25% $244.70 $19,821.00
07/01/2003-09/30/2003 5% 1.25% $247.76 $20,068.76
10/01/2003-12/3 1/2003 4% 1% $200.69 $20,269.45
01/01/2004-03/3 1/2004 4% 1% $202.69 $20,472.14
04/01/2004-06/30/2004 5% 1.25% $255.90 $20,728.04
07/01/2004-09/30/2004 4% 1% $207.28 $20,935.32
10/01/2004-12/31/2004 5% 1.25% $261.69 $21,197.01
01/01/2005-03/3 1/2005 5% 1.25% $264.96 $21,461.97
04/01/2005-06/30/2005 6% 1.5% $321.93 $21,783.90
07/01/2005-09/30/2005 6% 15% $326.76 $22,110.66
10/01/2005-12/3 1/2005 TMM 1.75% $386.94 $22,497.60
01/01/2006-03/3 1/2006 T% 1.75% $393.71 $22,891.31
04/01/2006-06/30/2006 Th 1.75% $400.60 $23,291.91
07/01/2006-09/30/2006 8% 2% $465.84 $23,757.75
10/01/2006-12/31/2006 8% 2% $475.16 $24,232.91
01/01/2007-03/3 1/2007 8% 2% $484.66 $24,717.57
04/01/2007-06/30/2007 8% 2% $494.35 $25,211.92
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

01/01/1999-06/30/2007 $12,349.60 $28,609.60

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007

Violation Amount: 36375.00

Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy):

Header for Report [Optional - 80 Chars Max]:{Furlong - September 1997 sales of HCCA stock
in Bone ie

Click here for the PJIC FAQ ;

Click here for the memoran lescribing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - May 2000 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 1

U.S. Securities and Exchange Commission

Principal+Interest

Quarter Range Annual Rate Period Rate Quarter Interest
Violation Amount $120,100.00
06/01/2000-06/30/2000 9% 0.75% $900.75 $121,000.75
07/01/2000-09/30/2000 9% 2.25% $2,722.52 $123,723.27
10/01/2000-12/31/2000 9% 2.25% $2,783.77 $126,507.04
01/01/2001-03/3 1/2001 9% 2.25% $2,846.41 $129,353.45
04/01/2001-06/30/2001 8% 2% $2,587.07 $131,940.52
07/01/2001-09/30/2001 T% 1.75% $2,308.96 $134,249.48
10/01/2001-12/31/2001 Th 1.75% $2,349.37 $136,598.85
01/01/2002-03/3 1/2002 6% 1.5% $2,048.98 $138,647.83
04/01/2002-06/30/2002 6% 1.5% $2,079.72 $140,727.55
07/01/2002-09/30/2002 6% 1.5% $2,110.91 $142,838.46
10/01/2002-12/3 1/2002 6% 1.5% $2,142.58 $144,981.04
01/01/2003-03/3 1/2003 5% 1.25% $1,812.26 $146,793.30
04/01/2003-06/30/2003 5% 1.25% $1,834.92 $148,628.22
07/01/2003-09/30/2003 5% 1.25% $1,857.85 $150,486.07
10/01/2003-12/3 1/2003 4% 1% $1,504.86 $151,990.93
01/01/2004-03/3 1/2004 4% 1% $1,519.91 $153,510.84
04/01/2004-06/30/2004 5% 1.25% $1,918.89 $155,429.73
07/01/2004-09/30/2004 4% 1% $1,554.30 $156,984.03
10/01/2004-12/3 1/2004 5% 1.25% $1,962.30 $158,946.33
01/01/2005-03/3 1/2005 5% 1.25% $1,986.83 $160,933.16
04/01/2005-06/30/2005 6% 15% $2,414.00 $163,347.16
07/01/2005-09/30/2005 6% 1.5% $2,450.21 $165,797.37
10/01/2005-12/31/2005 % 1.75% $2,901.45 $168,698.82
01/01/2006-03/3 1/2006 T% 1.75% $2,952.23 $171,651.05
04/01/2006-06/30/2006 T% 1.75% $3,003.89 $174,654.94
07/01/2006-09/30/2006 8% 2% $3,493.10 $178,148.04
10/01/2006-12/31/2006 8% % $3,562.96 $181,711.00
01/01/2007-03/3 1/2007 8% 2% $3,634.22 $185,345.22
04/01/2007-06/30/2007 8% 2% $3,706.90 $189,052.12
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
06/01/2000-06/30/2007 $68,952.12 $189,052.12
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007
Violation Amount: 20550.00
Violation Start Date (mm/dd/yyyy): 10/29/1999

Payoff Date (mm/dd/yyyy): fom 6/2007,

Header for Report [Optional - 80 Chars Max]Furlong - October 1999 sales of HCCA stock

ine a

Click here for the PJIC FAQ

Click here memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Prejudgment Interest Calculator Page | of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007
Violation Amount: 1965675.00
Violation Start Date (mm/dd/yyyy): 02/29/2000

Payoff Date (mm/dd/yyyy): fom 6/2007, ]

Header for Report [Optional - 80 Chars Max];Furlong - February 2000 sales of HCCA stock

Click here for the PIIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Division of Enforcement

Prejudgment Interest Report

Furlong - April 2000 sales of HCCA stock

Page 1 of 1

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $139,400.00
05/01/2000-06/30/2000 9% 1.5% $2,091.00 $141,491.00
07/01/2000-09/30/2000 9% 2.25% $3,183.55 $144,674.55
10/01/2000-12/3 1/2000 9% 2.25% $3,255.18 $147,929.73
01/01/2001-03/3 1/2001 9% 2.25% $3,328.42 $151,258.15
04/01/2001-06/30/2001 8% 2% $3,025.16 $154,283.31
07/01/2001-09/30/2001 TH 1.75% $2,699.96 $156,983.27
10/01/2001-12/3 1/2001 TMM 1.75% $2,747.21 $159,730.48
01/01/2002-03/3 1/2002 6% 1.5% $2,395.96 $162,126.44
04/01/2002-06/30/2002 6% 1.5% $2,431.90 $164,558.34
07/01/2002-09/30/2002 6% 1.5% $2,468.38 $167,026.72
10/01/2002-12/3 1/2002 6% 1.5% $2,505.40 $169,532.12
01/01/2003-03/3 1/2003 5% 1.25% $2,119.15 $171,651.27
04/01/2003-06/30/2003 5% 1.25% $2,145.64 $173,796.91
07/01/2003-09/30/2003 5% 1.25% $2,172.46 $175,969.37
10/01/2003-12/3 1/2003 4% 1% $1,759.69 $177,729.06
01/01/2004-03/3 1/2004 4% 1% $1,777.29 $179,506.35
04/01/2004-06/30/2004 5% 1.25% $2,243.83 $181,750.18
07/01/2004-09/30/2004 4% 1% $1,817.50 $183,567.68
10/01/2004-12/3 1/2004 5% 1.25% $2,294.60 $185,862.28
01/01/2005-03/3 1/2005 5% 1.25% $2,323.28 $188,185.56
04/01/2005-06/30/2005 6% 15% $2,822.78 $191,008.34
07/01/2005-09/30/2005 6% 15% $2,865.13 $193,873.47
10/01/2005-12/3 1/2005 TMM% 1.75% $3,392.79 $197,266.26
01/01/2006-03/3 1/2006 TM% 1.75% $3,452.16 $200,718.42
04/01/2006-06/30/2006 T% 1.75% $3,512.57 $204,230.99
07/01/2006-09/30/2006 8% 2% $4,084.62 $208,315.61
10/01/2006-12/3 1/2006 8% 2% $4,166.31 $212,481.92
01/01/2007-03/3 1/2007 8% 2% $4,249.64 $216,731.56
04/01/2007-06/30/2007 8% 2% $4,334.63 $221,066.19
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
05/01/2000-06/30/2007 $81,666.19 $221,066.19
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


with the SEC numerous false and misleading annual, quarterly and/or current reports and
registration statements on behalf of HCCA.! Furlong and Pietrzak also issued press
releases and a letter to shareholders that contained similar misrepresentations about
HCCA’s assets. They knew, or were reckless in not knowing, that the filings, the press
releases, and the shareholders’ letter were false. The fraudulent scheme included many
fraudulent acts over a period of 3% years. The fraud continued despite repeated and
explicit warnings from the SEC concerning the misleading nature of HCCA’s disclosures.

2. The Defendants Aided And Abetted Violations Of The

Reporting Provisions

Section 13(a) of the Exchange Act and Rules 13a-1 and 13a-13 require public

companies to file with the SEC annual and quarterly reports containing financial
statements prepared in conformity with the requirements of the SEC's rules and
regulations. In addition, Rule 12b-20 under the Exchange Act requires that such reports
contain, in addition to disclosures expressly required by statute and rules, such other
information as is necessary to ensure that the statements made in those reports are not,
under the circumstances, materially misleading. The requirement that an issuer file
reports under §13(a) embodies the requirement that such reports be true and correct. See
SEC v. IMC International, Inc., 384 F. Supp. 889, 893 (N.D. Tex.), aff'd mem., 505 F.2d
733 (5th Cir. 1974), cert. denied sub nom., Evans v. SEC, 420 U.S. 930 (1975). Rule 13a-

11 requires issuers to file current reports on Form 8-K with the SEC upon the occurrence

of certain specified events, including a change in an issuer’s auditor.

HCCA violated §13(a) and Rules 13a-1 and 13a-13 when it filed annual reports
and quarterly reports that contained financial statements that were not prepared in
conformity with GAAP and contained material misstatements. The financial statements
were false and misleading because they grossly overstated HCCA’s total assets. HCCA
included the inaccurate financial statements in its filings on Form 10-K for the years
1996-1998 and on Form 10-Q for several quarters during the period March 1997 to
September 1999. HCCA violated §13(a) and Rule 13a-11 when it filed a current report
on Form 8-K, which, inter alia, failed to disclose timely a change in auditor, failed to

‘As proved at trial, these filings were signed by Furlong and/or Pietrzak. See Summary Evidence #1,
which was received at trial, and is attached hereto as Exhibit A.


Furlong - June 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 1

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $95,166.00
07/01/1999-09/30/1999 8% 2% $1,903.32 $97,069.32
10/01/1999-12/31/1999 8% 2% $1,941.39 $99,010.71
01/01/2000-03/31/2000 8% 2% $1,980.21 $100,990.92
04/01/2000-06/30/2000 9% 2.25% $2,272.30 $103,263.22
07/01/2000-09/30/2000 9% 2.25% $2,323.42 $105,586.64
10/01/2000-12/3 1/2000 9% 2.25% $2,375.70 $107,962.34
01/01/2001-03/31/2001 9% 2.25% $2,429.15 $110,391.49
04/01/2001-06/30/2001 8% 2% $2,207.83 $112,599.32
07/01/2001-09/30/2001 TMM% 1.75% $1,970.49 $114,569.81
10/01/2001-12/31/2001 TH 1.75% $2,004.97 $116,574.78
01/01/2002-03/3 1/2002 6% 1.5% $1,748.62 $118,323.40
04/01/2002-06/30/2002 6% 1.5% $1,774.85 $120,098.25
07/01/2002-09/30/2002 6% 15% $1,801.47 $121,899.72
10/01/2002-12/3 1/2002 6% 15% $1,828.50 $123,728.22
01/01/2003-03/3 1/2003 5% 1.25% $1,546.60 $125,274.82
04/01/2003-06/30/2003 5% 1.25% $1,565.94 $126,840.76
07/01/2003-09/30/2003 5% 1.25% $1,585.51 $128,426.27
10/01/2003-12/3 1/2003 4% 1% $1,284.26 $129,710.53
01/01/2004-03/3 1/2004 4% 1% $1,297.11 $131,007.64
04/01/2004-06/30/2004 5% 1.25% $1,637.60 $132,645.24
07/01/2004-09/30/2004 4% 1% $1,326.45 $133,971.69
10/01/2004-12/3 1/2004 5% 1.25% $1,674.65 $135,646.34
01/01/2005-03/3 1/2005 5% 1.25% $1,695.58 $137,341.92
04/01/2005-06/30/2005 6% 1.5% $2,060.13 $139,402.05
07/01/2005-09/30/2005 6% 1.5% $2,091.03 $141,493.08
10/01/2005-12/3 1/2005 T% 1.75% $2,476.13 $143,969.21
01/01/2006-03/3 1/2006 TMM% 1.75% $2,519.46 $146,488.67
04/01/2006-06/30/2006 T% 1.75% $2,563.55 $149,052.22
07/01/2006-09/30/2006 8% 2% $2,981.04 $152,033.26
10/01/2006-12/31/2006 8% 2% $3,040.67 $155,073.93
01/01/2007-03/31/2007 8% 2% $3,101.48 $158,175.41
04/01/2007-06/30/2007 8% 2% $3,163.51 $161,338.92
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
07/01/1999-06/30/2007 $66,172.92 $161,338.92
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - May 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $64,500.00
06/01/1998-06/30/1998 8% 0.67% $430.00 $64,930.00
07/01/1998-09/30/1998 8% 2% $1,298.60 $66,228.60
10/01/1998-12/3 1/1998 8% 2% $1,324.57 $67,553.17
01/01/1999-03/31/1999 TMM% 1.75% $1,182.18 $68,735.35
04/01/1999-06/30/1999 8% 2% $1,374.71 $70,110.06
07/01/1999-09/30/1999 8% 2% $1,402.20 $71,512.26
10/01/1999-12/31/1999 8% 2% $1,430.25 $72,942.51
01/01/2000-03/3 1/2000 8% 2% $1,458.85 $74,401.36
04/01/2000-06/30/2000 % 2.25% $1,674.03 $76,075.39
07/01/2000-09/30/2000 % 2.25% $1,711.70 $77,787.09
10/01/2000-12/3 1/2000 9% 2.25% $1,750.21 $79,537.30
01/01/2001-03/31/2001 9% 2.25% $1,789.59 $81,326.89
04/01/2001-06/30/2001 8% 2% $1,626.54 $82,953.43
07/01/2001-09/30/2001 T% 1.75% $1,451.69 $84,405.12
10/01/2001-12/31/2001 MD 1.75% $1,477.09 $85,882.21
01/01/2002-03/3 1/2002 6% 1.5% $1,288.23 $87,170.44
04/01/2002-06/30/2002 6% 1.5% $1,307.56 $88,478.00
07/01/2002-09/30/2002 6% 1.5% $1,327.17 $89,805.17
10/01/2002-12/3 1/2002 6% 1.5% $1,347.08 $91,152.25
01/01/2003-03/3 1/2003 5% 1.25% $1,139.40 $92,291.65
04/01/2003-06/30/2003 5% 1.25% $1,153.65 $93,445.30
07/01/2003-09/30/2003 5% 1.25% $1,168.07 $94,613.37
10/01/2003-12/3 1/2003 4% 1% $946.13 $95,559.50
01/01/2004-03/3 1/2004 4% 1% $955.60 $96,515.10
04/01/2004-06/30/2004 5% 1.25% $1,206.44 $97,721.54
07/01/2004-09/30/2004 4% 1% $977.22 $98,698.76
10/01/2004-12/3 1/2004 5% 1.25% $1,233.73 $99,932.49
01/01/2005-03/3 1/2005 5% 1.25% $1,249.16 $101,181.65
04/01/2005-06/30/2005 6% 15% $1,517.72 $102,699.37
07/01/2005-09/30/2005 6% 15% $1,540.49 $104,239.86
10/01/2005-12/3 1/2005 TM% 1.75% $1,824.20 $106,064.06
* 01/01/2006-03/31/2006 TM% 1.75% $1,856.12 $107,920.18
04/01/2006-06/30/2006 T% 1.75% $1,888.60 $109,808.78 .
07/01/2006-09/30/2006 8% 2% $2,196.18 $112,004.96
10/01/2006-12/3 1/2006 8% 2% $2,240.10 $114,245.06
01/01/2007-03/3 1/2007 8% 2% $2,284.90 $116,529.96
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007
Violation Amount: 185623.00
Violation Start Date (mm/dd/yyyy): 12/26/1997

Payoff Date (mm/dd/yyyy): fornezoo7 |

Header for Report [Optional - 80 Chars Max]:[Furlong - December 1997 sales of HCCA stock

Click here for the PJIC FAQ

Click here for the memorandum describi od for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - March 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount . $85,376.00
04/01/1997-06/30/1997 9% 2.25% $1,920.96 $87,296.96
07/01/1997-09/30/1997 9% 2.25% $1,964.18 $89,261.14
10/01/1997-12/31/1997 % 2.25% $2,008.38 $91,269.52
01/01/1998-03/3 1/1998 9% 2.25% $2,053.56 $93,323.08
04/01/1998-06/30/1998 8% 2% $1,866.46 $95,189.54
07/01/1998-09/30/1998 8% 2% $1,903.79 $97,093.33
10/01/1998-12/31/1998 8% 2% $1,941.87 $99,035.20
01/01/1999-03/31/1999 TMM% 1.75% $1,733.12 $100,768.32
04/01/1999-06/30/1999 8% 2% $2,015.37 $102,783.69
07/01/1999-09/30/1999 8% 2% $2,055.67 $104,839.36
10/01/1999-12/31/1999 8% 2% $2,096.79 $106,936.15
01/01/2000-03/3 1/2000 8% 2% $2,138.72 $109,074.87
04/01/2000-06/30/2000 9% 2.25% $2,454.18 $111,529.05
07/01/2000-09/30/2000 9% 2.25% $2,509.40 $114,038.45
10/01/2000-12/3 1/2000 9% 2.25% $2,565.87 $116,604.32
01/01/2001-03/3 1/2001 9% 2.25% $2,623.60 $119,227.92
04/01/2001-06/30/2001 8% 2% $2,384.56 $121,612.48
07/01/2001-09/30/2001 TMH 1.75% $2,128.22 $123,740.70
10/01/2001-12/31/2001 TH 1.75% $2,165.46 $125,906.16
01/01/2002-03/3 1/2002 6% 1.5% $1,888.59 $127,794.75
04/01/2002-06/30/2002 6% 1.5% $1,916.92 $129,711.67
07/01/2002-09/30/2002 6% 1.5% $1,945.68 $131,657.35
10/01/2002-12/31/2002 6% 1.5% $1,974.86 $133,632.21
01/01/2003-03/31/2003 5% 1.25% $1,670.40 $135,302.61
04/01/2003-06/30/2003 5% 1.25% $1,691.28 $136,993.89
07/01/2003-09/30/2003 5% 1.25% $1,712.42 $138,706.31
10/01/2003-12/3 1/2003 4% 1% $1,387.06 $140,093.37
01/01/2004-03/3 1/2004 4% 1% $1,400.93 $141,494.30
04/01/2004-06/30/2004 5% 1.25% $1,768.68 $143,262.98
07/01/2004-09/30/2004 4% 1% $1,432.63 $144,695.61
10/01/2004-12/3 1/2004 5% 1.25% $1,808.70 $146,504.31
01/01/2005-03/31/2005 5% 1.25% $1,831.30 $148,335.61
04/01/2005-06/30/2005 6% 1.5% $2,225.03 $150,560.64
07/01/2005-09/30/2005 6% 1.5% $2,258.41 $152,819.05
10/01/2005-12/31/2005 TMM% 1.75% $2,674.33 $155,493.38
01/01/2006-03/3 1/2006 TMM 1.75% $2,721.13 $158,214.51
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):

Payoff Date (mm/dd/yyyy): [oz 16/2007,

Header for Report [Optional - 80 Chars Max][Furlong - February 1997 sales of HCCA stock

Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html

6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): 07/16/2007

Header for Report [Optional - 80 Chars Max];[Furlong - June 1999 sales of HCCA stock

Click here for the PJ IC FAQ :
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html

6/12/2007


Prejudgment Interest Calculator _ Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007
Violation Amount: 64491.00
Violation Start Date (mm/dd/yyyy): 06/19/1997

Payoff Date (mm/dd/yyyy): fora 6/2007,

Header for Report [Optional - 80 Chars Max]:[Furlong - June 1997 sales of HCCA stock

Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy):

Header for Report [Optional - 80 Chars Max]:|Furlong - November 1999 sales of HCCA stock

Click here for the PJIC FAQ

Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html

6/12/2007


Page 2 of 2

01/01/2007-03/3 1/2007 8% 2% $3,509.24 $178,971.43
04/01/2007-06/30/2007 8% 2% $3,579.43 $182,550.86
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
02/01/1998-06/30/2007 $86,228.86 $182,550.86
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - September 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page | of 1

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $24,150.00
10/01/1999-12/31/1999 8% 2% $483.00 $24,633.00
01/01/2000-03/31/2000 8% 2% $492.66 $25,125.66
04/01/2000-06/30/2000 9% 2.25% $565.33 $25,690.99
07/01/2000-09/30/2000 9% 2.25% $578.05 $26,269.04
10/01/2000-12/31/2000 9% 2.25% $591.05 $26,860.09
01/01/2001-03/31/2001 9% 2.25% $604.35 $27,464.44
04/01/2001-06/30/2001 8% 2% $549.29 $28,013.73
07/01/2001-09/30/2001 T% 1.75% $490.24 $28,503.97
10/01/2001-12/31/2001 Th 1.75% $498.82 $29,002.79
01/01/2002-03/3 1/2002 6% 1.5% $435.04 $29,437.83
04/01/2002-06/30/2002 6% 1.5% $441.57 $29,879.40
07/01/2002-09/30/2002 6% 1.5% $448.19 $30,327.59
10/01/2002-12/3 1/2002 6% 1.5% $454.91 $30,782.50
01/01/2003-03/3 1/2003 5% 1.25% $384.78 $31,167.28
04/01/2003-06/30/2003 5% 1.25% $389.59. $31,556.87
07/01/2003-09/30/2003 5% 1.25% $394.46 $31,951.33
10/01/2003-12/3 1/2003 4% 1% $319.51 $32,270.84
01/01/2004-03/3 1/2004 4% 1% $322.71 $32,593.55
04/01/2004-06/30/2004 5% 1.25% $407.42 $33,000.97
07/01/2004-09/30/2004 4% 1% $330.01 $33,330.98
10/01/2004-12/3 1/2004 5% 1.25% $416.64 $33,747.62
01/01/2005-03/31/2005 5% 1.25% $421.85 $34,169.47
04/01/2005-06/30/2005 6% 1.5% $512.54 $34,682.01
07/01/2005-09/30/2005 6% 1.5% $520.23 $35,202.24
10/01/2005-12/3 1/2005 T% 1.75% $616.04 $35,818.28
01/01/2006-03/3 1/2006 TMH 1.75% $626.82 $36,445.10
04/01/2006-06/30/2006 TM% 1.75% $637.79 $37,082.89
07/01/2006-09/30/2006 8% 2% $741.66 $37,824.55
10/01/2006-12/3 1/2006 8% 2% $756.49 $38,581.04
01/01/2007-03/3 1/2007 8% 2% $771.62 $39,352.66
04/01/2007-06/30/2007 8% 2% $787.05 $40,139.71
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
10/01/1999-06/30/2007 $15,989.71 $40,139.71
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

Prejudgment Violation Range Quarter Interest Total Prejudgment Total
09/01/1998-06/30/2007 $7,366.48 $16,498.48

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy): .
Payoff Date (mm/dd/yyyy): Joz16/2007 _

Header for Report [Optional - 80 Chars Max]:[Furlong - April 1997 sales of HCCA stock

Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html

6/12/2007


Furlong - February 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $9,850.00
03/01/1999-03/3 1/1999 T% 0.58% $57.46 $9,907.46
04/01/1999-06/30/1999 8% 2% $198.15 $10,105.61
07/01/1999-09/30/1999 8% 2% $202.11 $10,307.72
10/01/1999-12/31/1999 8% 2% $206.15 $10,513.87
01/01/2000-03/3 1/2000 8% - 2% $210.28 $10,724.15
04/01/2000-06/30/2000 9% 2.25% $241.29 $10,965.44
07/01/2000-09/30/2000 9% 2.25% $246.72 $11,212.16
10/01/2000-12/31/2000 9% 2.25% $252.27 $11,464.43
01/01/2001-03/31/2001 9% 2.25% $257.95 $11,722.38
04/01/2001-06/30/2001 8% 2% $234.45 $11,956.83
07/01/2001-09/30/2001 Th 1.75% $209.24 $12,166.07
10/01/2001-12/31/2001 T% 1.75% $212.91 $12,378.98
01/01/2002-03/3 1/2002 6% 15% $185.68 $12,564.66
04/01/2002-06/30/2002 6% 1.5% $188.47 $12,753.13
07/01/2002-09/30/2002 6% 15% $191.30 $12,944.43
10/01/2002-12/3 1/2002 6% 15% $194.17 $13,138.60
01/01/2003-03/3 1/2003 5% 1.25% $164.23 $13,302.83
04/01/2003-06/30/2003 5% 1.25% $166.29 $13,469.12
07/01/2003-09/30/2003 5% 1.25% $168.36 $13,637.48
10/01/2003-12/3 1/2003 4% 1% $136.37 $13,773.85
01/01/2004-03/3 1/2004 4% 1% $137.74 $13,911.59
04/01/2004-06/30/2004 5% 1.25% $173.89 $14,085.48
07/01/2004-09/30/2004 4% 1% $140.85 $14,226.33
10/01/2004-12/3 1/2004 5% 1.25% $177.83 $14,404.16
01/01/2005-03/3 1/2005 5% 1.25% $180.05 $14,584.21
04/01/2005-06/30/2005 6% 15% $218.76 $14,802.97
07/01/2005-09/30/2005 6% 1.5% $222.04 $15,025.01
10/01/2005-12/31/2005 T% 1.75% $262.94 $15,287.95
01/01/2006-03/3 1/2006 T% 1.75% $267.54 $15,555.49
04/01/2006-06/30/2006 Th 1.75% $272.22 $15,827.71
07/01/2006-09/30/2006 8% 2% $316.55 $16,144.26
10/01/2006-12/3 1/2006 8% 2% $322.89 $16,467.15
01/01/2007-03/3 1/2007 8% 2% $329.34 $16,796.49
04/01/2007-06/30/2007 8% 2% $335.93 $17,132.42
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


The SEC requests that the Court order Furlong and Pietrzak to pay civil penalties
in amounts determined by the Court to be appropriate. Their violations clearly involved
fraud and deceit, and created a significant risk of substantial losses to investors in HCCA.
The Court should impose the civil penalty against them based upon the repeated nature of
their violations, and their recording of various essentially worthless assets, at ridiculous
unsubstantiated values, cumulatively at hundreds of millions of dollars. Furlong and
Pietrzak sold millions of shares of their own HCCA stock while materially false and
misleading information about HCCA’s assets was included in the company’s financial
statements filed with the SEC, and in press releases issued by HCCA. Their activities
clearly involved fraud and deceit. The sales continued even after repeated warnings by
the SEC that the disclosures were misleading. Given the repeated incidents of fraudulent
filings of HCCA by both Furlong and Pietrzak, and given the fact that their activities as
to the financial statements and press releases created a significant risk of substantial

losses to investors, a substantial civil penalty is appropriate for each defendant.

4. Officer And Director Bars Against Furlong And Pietrzak
Section 20(e) of the Securities Act and §21(d)(2) of the Exchange Act authorize

courts in SEC civil actions to issue an order prohibiting any person who violated,
respectively, §17(a)(1) of the Securities Act or §10(b) of the Exchange Act, from acting
as an officer or director of any company that has a class of securities registered with the
SEC pursuant to §12 of the Exchange Act,’ or that is required to file reports with the SEC
pursuant to §15(d) of the Exchange Act, if the person’s conduct demonstrates a
substantial unfitness to serve as an officer or director of such an issuer.” Courts generally

consider 6 factors when making a “substantial unfitness” determination: “(1) the

amounts of civil monetary penalties applicable herein are, therefore, the amounts for the relevant
time of the violations.

5 HCCA was registered pursuant to §12 of the Exchange Act.

° Approximately 6 months before the complaint was filed in this case, President Bush signed into law
the Sarbanes-Oxley Act of 2002 [Pub. L. No. 107-204]. Section 305(a) of the Sarbanes-Oxley Act
changed the standard for the SEC to obtain an O&D bar in an injunctive action from “substantial
unfitness” to “unfitness.” While it is not clear whether the Sarbanes-Oxley Act’s modification to the
standard applies retroactively, clearly either standard is met because the conduct of Furlong and
Pietrzak demonstrates “substantial unfitness” to serve as officers or directors of public companies.

13


Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy): 09/30/1998
Payoff Date (mm/dd/yy):
Header for Report [Optional - 80 Chars Max]:[Furiong - September 1998 sales of HCCA stock
Click here for the PIC FAQ
Click here for the memorandum describing the met 1 calculating interest
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): fom 6/2007,

Header for Report [Optional - 80 Chars Max]:|Furlong - November 1998 sales of HCCA stock

Click here for the PJIC FAQ

Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html

6/12/2007


SEC enforcement action would be greatly undermined if securities laws
violators were not required to disgorge illicit profits.

SEC v. Manor Nursing Centers, Inc., 458 F.2d at 1104. It would severely defeat the
purposes of the Act if a violator of Rule 10b-5 were allowed to retain the profits from his

violation. SEC v. Texas Gulf Sulphur Co., 446 F.2d 1301, 1308 (2d Cir. 1971). Furlong
and Pietrzak should be ordered to pay disgorgement equal to gross proceeds of the HCCA
stock they sold, as disgorgement should be based upon pre-tax proceeds.’ See SEC v.
World Gambling Corp., 555 F.Supp. 930, 934-35 (S.D.N.Y. 1883), aff'd 742 F. 2d 1440
(2d Cir. 1983, cert. denied, 465 U.S. 1112 (1984).

Total gross profits, without giving consideration as to whether the defendant may
have squandered and or hidden the ill-gotten gains, has been held to be an appropriate
calculation for disgorgement.’ SEC v. Bocchino, 2002 WL 31528472 (S.D.N.Y. 2002);
SEC v. Thomas James Assoc., Inc., 738 F. Supp. 88, 95 (W.D.N.Y. 1990). Given the
pervasiveness of the fraud by Furlong and Pietrzak in this matter, and the extended period

over which it took place, total gross proceeds as the disgorgement calculation is what this
Court should adopt. While it may consider brokerage commissions as a possible offset on
disgorgement, Furlong and Pietrzak should not be allowed to simply group their claimed
“expenses” under some broad category of “business” costs, without supporting evidence
to prove the amounts they seek to offset. SEC v. Benson, 657 F. Supp. 1122, 1133-34
(S.D.N.Y. 1987). Furthermore, in the case of a patently fraudulent stock offering, such as
is the case with Furlong and Pietrzak, it is appropriate to order disgorgement of the entire

gross proceeds received in connection with the offering. SEC v. Interlink Data Network

of Los Angeles, Inc., 1993 WL 603274 (C.D. Cal. 1993) (ordering disgorgement of gross
amount received from fraudulent securities offering); SEC v. Robinson, 2002 WL
1552049 (S.D.N.Y. 2002) (ordering disgorgement of entire proceeds in patently

* Indeed in this case, there is substantial evidence from Furlong’s and Pietrzak’s discovery
responses (which the jury did not see), that neither Furlong nor Pietrzak filed income tax returns
in the relevant period, and therefore paid no taxes (Furlong) or virtually no taxes (Pietrzak) on the
stock sales earnings.

5 Pietrzak volunteered testimony at trial that he is financially unable to pay disgorgement due to a
current negative net worth. Whether Pietrzak spent or squandered the funds he received from the
fraud is not a relevant consideration, as to whether he should be ordered to pay disgorgement. SEC
vy. Robinson, 2002 WL 1552049, *8 (S.D.N.Y. 2002).


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement

Prejudgment Interest Calculator
Interest Rates Through 6/30/2007

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): fom 6/2007 __

Header for Report [Optional - 80 Chars Max],Furlong - September 1999 sales of HCCA stock

Click here for the PIC FAQ
Click here for the memorandum describing the method for calculating. interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - October 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $11,250.00
11/01/1998-12/3 1/1998 8% 1.33% $150.00 $11,400.00
01/01/1999-03/31/1999 T% 1.75% $199.50 $11,599.50
04/01/1999-06/30/1999 8% 2% $231.99 $11,831.49
07/01/1999-09/30/1999 8% 2% $236.63 $12,068.12
10/01/1999-12/31/1999 8% 2% $241.36 $12,309.48
01/01/2000-03/3 1/2000 8% 2% $246.19 $12,555.67
04/01/2000-06/30/2000 9% 2.25% $282.50 $12,838.17
07/01/2000-09/30/2000 9% 2.25% $288.86 $13,127.03
10/01/2000-12/3 1/2000 9% 2.25% $295.36 $13,422.39
01/01/2001-03/3 1/2001 9% 2.25% $302.00 $13,724.39
04/01/2001-06/30/2001 8% 2% $274.49 $13,998.88
07/01/2001-09/30/2001 T% 1.75% $244.98 $14,243.86
10/01/2001-12/31/2001 T% 1.75% $249.27 $14,493.13
01/01/2002-03/31/2002 6% 1.5% $217.40 $14,710.53
04/01/2002-06/30/2002 6% 1.5% $220.66 $14,931.19
07/01/2002-09/30/2002 6% 1.5% $223.97 $15,155.16
10/01/2002-12/31/2002 6% 1.5% $227.33 $15,382.49
01/01/2003-03/3 1/2003 5% 1.25% $192.28 $15,574.77
04/01/2003-06/30/2003 5% 1.25% $194.68 $15,769.45
07/01/2003-09/30/2003 5% 1.25% $197.12 $15,966.57
10/01/2003-12/3 1/2003 4% 1% $159.67 $16,126.24
01/01/2004-03/3 1/2004 4% 1% $161.26 $16,287.50
04/01/2004-06/30/2004 5% 1.25% $203.59 $16,491.09
07/01/2004-09/30/2004 4% 1% $164.91 $16,656.00
10/01/2004-12/3 1/2004 5% 1.25% $208.20 $16,864.20
01/01/2005-03/3 1/2005 5% 1.25% $210.80 $17,075.00
04/01/2005-06/30/2005 6% 1.5% $256.13 $17,331.13
07/01/2005-09/30/2005 6% 1.5% $259.97 , $17,591.10
10/01/2005-12/3 1/2005 T% 1.75% $307.84 $17,898.94
01/01/2006-03/3 1/2006 Th 1.75% $313.23 $18,212.17
04/01/2006-06/30/2006 T% 1.75% $318.71 $18,530.88
07/01/2006-09/30/2006 8% 2% $370.62 $18,901.50
10/01/2006- 12/3 1/2006 8% 2% $378.03 $19,279.53
01/01/2007-03/3 1/2007 8% 2% $385.59 $19,665.12
04/01/2007-06/30/2007 8% 2% $393.30 $20,058.42
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): [orn 6/2007

Header for Report [Optional - 80 Chars Max]:|Furlong - July 1999 sales of HCCA stock

i

Click here for the PJIC FAQ

lick here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

02/01/1999-06/30/2007 $19,410.04 $45,310.04

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - February 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $100,505.00
03/01/1998-03/3 1/1998 9% 0.75% $753.79 $101,258.79
04/01/1998-06/30/1998 8% 2% $2,025.18 $103,283.97
07/01/1998-09/30/1998 8% 2% $2,065.68 $105,349.65
10/01/1998-12/31/1998 8% 2% $2,106.99 $107,456.64
01/01/1999-03/3 1/1999 TM% 1.75% $1,880.49 $109,337.13
04/01/1999-06/30/1999 8% 2% $2,186.74 $111,523.87
07/01/1999-09/30/1999 8% 2% $2,230.48 $113,754.35
10/01/1999-12/3 1/1999 8% 2% $2,275.09 $116,029.44
01/01/2000-03/3 1/2000 8% 2% $2,320.59 $118,350.03
04/01/2000-06/30/2000 % 2.25% $2,662.88 $121,012.91
07/01/2000-09/30/2000 9% 2.25% $2,722.79 $123,735.70
10/01/2000-12/31/2000 9% 2.25% $2,784.05 $126,519.75
01/01/2001-03/31/2001 9% 2.25% $2,846.69 $129,366.44
04/01/2001-06/30/2001 8% 2% $2,587.33 $131,953.77
07/01/2001-09/30/2001 TH 1.75% $2,309.19 $134,262.96
10/01/2001-12/3 1/2001 T% 1.75% $2,349.60 $136,612.56
01/01/2002-03/3 1/2002 6% 15% $2,049.19 $138,661.75
04/01/2002-06/30/2002 6% 1.5% $2,079.93 $140,741.68
07/01/2002-09/30/2002 6% 1.5% $2,111.13 $142,852.81
10/01/2002-12/3 1/2002 6% 1.5% $2,142.79 $144,995.60
01/01/2003-03/3 1/2003 5% 1.25% $1,812.45 $146,808.05
04/01/2003-06/30/2003 5% 1.25% $1,835.10 $148,643.15
07/01/2003-09/30/2003 5% 1.25% $1,858.04 $150,501.19
10/01/2003-12/3 1/2003 4% 1% $1,505.01 $152,006.20
01/01/2004-03/3 1/2004 4% 1%. $1,520.06 $153,526.26
04/01/2004-06/30/2004 5% 1.25% $1,919.08 $155,445.34
07/01/2004-09/30/2004 4% 1% $1,554.45 $156,999.79
10/01/2004-12/3 1/2004 5% 1.25% $1,962.50 $158,962.29
01/01/2005-03/3 1/2005 5% 1.25% $1,987.03 $160,949.32
04/01/2005-06/30/2005 6% 15% $2,414.24 $163,363.56
07/01/2005-09/30/2005 6% 1.5% $2,450.45 $165,814.01
10/01/2005-12/3 1/2005 T% 1.75% $2,901.75 $168,715.76
01/01/2006-03/3 1/2006 T% 1.75% $2,952.53 $171,668.29
04/01/2006-06/30/2006 TM% 1.75% $3,004.20 $174,672.49
07/01/2006-09/30/2006 8% 2% $3,493.45 $178,165.94
10/01/2006-12/31/2006 8% 2% $3,563.32 $181,729.26
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
: Prejudgment Interest Calculator
. Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): Jo716/2007
Header for Report [Optional - 80 Chars Max];[Furlong - January 1998 sales of HCCA stock
aE ye | F eelevien
Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


1997 Sales By Month, With Prejudgment Interest

Through July 16, 2007


Furlong - October 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal Interest
Violation Amount $65,520.00
11/01/1997-12/31/1997 9% 1.5% $982.80 $66,502.80
01/01/1998-03/3 1/1998 9% 2.25% $1,496.31 $67,999.11
04/01/1998-06/30/1998 8% 2% $1,359.98 $69,359.09
07/01/1998-09/30/1998 8% 2% $1,387.18 $70,746.27
10/01/1998-12/31/1998 8% 2% $1,414.93 $72,161.20
01/01/1999-03/3 1/1999 T% 1.75% $1,262.82 $73,424.02
04/01/1999-06/30/1999 8% 2% $1,468.48 $74,892.50
07/01/1999-09/30/1999 8% 2% $1,497.85 $76,390.35
10/01/1999-12/3 1/1999 “8% 2% $1,527.81 $77,918.16
01/01/2000-03/3 1/2000 8% 2% $1,558.36 $79,476.52
04/01/2000-06/30/2000 9% 2.25% $1,788.22 $81,264.74
07/01/2000-09/30/2000 9% 2.25% $1,828.46 $83,093.20
10/01/2000-12/31/2000 % 2.25% $1,869.60 $84,962.80
01/01/2001-03/31/2001 9% 2.25% $1,911.66 $86,874.46
04/01/2001-06/30/2001 8% 2% $1,737.49 $88,611.95
07/01/2001-09/30/2001 T% 1.75% $1,550.71 $90,162.66
10/01/2001-12/31/2001 TM% 1.75% $1,577.85 $91,740.51
01/01/2002-03/3 1/2002 6% 1.5% $1,376.11 $93,116.62
04/01/2002-06/30/2002 6% 1.5% $1,396.75 $94,513.37
07/01/2002-09/30/2002 6% 1.5% $1,417.70 $95,931.07
10/01/2002-12/3 1/2002 6% 1.5% $1,438.97 $97,370.04
01/01/2003-03/3 1/2003 5% 1.25% $1,217.13 $98,587.17
04/01/2003-06/30/2003 5% 1.25% $1,232.34 $99,819.51
07/01/2003-09/30/2003 5% 1.25% $1,247.74 $101,067.25
10/01/2003-12/31/2003 4% 1% $1,010.67 $102,077.92
01/01/2004-03/3 1/2004 4% 1% $1,020.78 $103,098.70
04/01/2004-06/30/2004 5% 1.25% $1,288.73 $104,387.43
07/01/2004-09/30/2004 4% 1% $1,043.87 $105,431.30
10/01/2004-12/31/2004 5% 1.25% $1,317.89 $106,749.19
01/01/2005-03/3 1/2005 5% 1.25% $1,334.36 $108,083.55
04/01/2005-06/30/2005 6% 15% $1,621.25 $109,704.80
07/01/2005-09/30/2005 6% 1.5% $1,645.57 $111,350.37
10/01/2005-12/3 1/2005 TMM% 1.75% $1,948.63 $113,299.00
01/01/2006-03/3 1/2006 Th 1.75% $1,982.73 $115,281.73
04/01/2006-06/30/2006 T% 1.75% $2,017.43 $117,299.16
07/01/2006-09/30/2006 8% 2% $2,345.98 $119,645.14
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

10/01/2006-12/3 1/2006 8% 2% $1,354.91 $69,100.56
01/01/2007-03/3 1/2007 8% 2% $1,382.01 $70,482.57
04/01/2007-06/30/2007 8% 2% $1,409.65 $71,892.22
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
12/01/1997-06/30/2007 . $34,517.22 $71,892.22

http://enforcenet/PIIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): Jovi 6/2007

Header for Report [Optional - 80 Chars Max];Furlong - October 1998 sales of HCCA stock

Click here for the PIIC FAQ

lick here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


SUMMARY EVIDENCE #1—HCCA FILINGS, WITH SIGNATURES OF ITS
CORPORATE OFFICERS AND DIRECTORS

a0) 1996 Form 10-SB, filed March 11, 1996, and signed by Furlong (P.Ex. #365);

2) 1996 Form 10-SB, filed December 6, 1996, and signed by Furlong (P.Ex. #366);

3) 1996 Form 10-KSB, filed May 2, 1997, and signed by Furlong, Pietrzak and
Berry (P.Ex. #368);

4) Form 10-SB A#1, filed August 29, 1997, and signed by Furlong (P.Ex. #374);

5) March 31, 1997 Form 10-QSB, filed September 12, 1997, and signed by
Furlong and Pietrzak (P. Ex. #370);

6) June 30, 1997 Form 10-QSB, filed October 3, 1997, and signed by Furlong
and Pietrzak (P.Ex. #372);

7) 1996 Form 10-KSB, filed November 14, 1997, and signed by Furlong,
Pietrzak and Berry (P.Ex. #369);

8) March 31, 1997 Form 10-QSB A#1, filed December 13, 1999, and signed by
Furlong and Pietrzak (P.Ex. #371);

9) June 30, 1997 Form 10-QSB A#1, filed December 13, 1999, and signed by
Furlong and Pietrzak (P.Ex. #373);

10) September 30, 1997 Form 10-QSB, filed December 13, 1999, and signed by
Furlong and Pietrzak (P.Ex. #375);

11) March 31, 1998 Form 10-QSB, filed December 13, 1999, and signed by
Furlong and Pietrzak (P.Ex. #377);

sg



1998 Sales By Month, With Prejudgment Interest

Through July 16, 2007


Pietrzak knowingly failed to implement a system of internal accounting controls, which

resulted in the improper recording of assets on HCCA’s books, records, and accounts.

4. Furlong Violated_§16 Of The Exchange Act And Rules 16a-2
And 16a-3

The Court granted directed verdict to the SEC on these violations against Furlong
after the close of the evidence, before the case was submitted to the jury. Section 16(a)
of the Exchange Act and Rules 16a-2 and 16a-3 require directors and officers, and
persons who own more than 10% of a registered class of a company’s equity securities, to
file reports of ownership and changes of beneficial ownership with the SEC. Any person
subject to this requirement must file an initial report on Form 3 within 10 days of
acquiring that status. Once the initial report is filed, changes in holdings must be reported
on Form 4 by the 10% day of the month following the change. An annual report on Form
5 must be filed on or before the 45" day after the end of the issuer’s fiscal year. Furlong
violated §16 of the Exchange Act and Rules 16a-2 and 16a-3 because he owned and
traded HCCA stock and never filed any Forms 3, 4 or 5 with the SEC. See SEC v.
Richard P. Smyth, et al., Litigation Rel. No. 17044 (June 21, 2001), 75 SEC Docket 873,
874 (defendant failed to file certain Forms 4 and 5); SEC v. Solucorp Industries Ltd., et al.,
Litigation Rel. No. 6388 (Dec. 13, 1999), 71 SEC Docket 843, 844 (defendants failed to
disclose equity ownership in company and failed to timely disclose changes in ownership).

B. RELIEF REQUESTED

1. Injunctive Relief Against Furlong And Pietrzak

Injunctions against Furlong and Pietrzak are appropriate. As CEO and general
counsel, Furlong and Pietrzak were responsible for HCCA’s reporting function, and they
were aware that HCCA’s filings were false and misleading. Yet instead of correcting
them, they continued selling their stock into the market. In analyzing the need for
injunctive relief, courts regularly focus on whether there is a reasonable likelihood that the
defendant, if not enjoined, will engage in future illegal conduct. See, e.g., SEC v. Bonastia,
614 F.2d 908, 912 (3d Cir. 1980); SEC v. Commonwealth Chemical Securities, Inc., 574
F.2d 90, 100-01 (2d Cir. 1978). In granting or denying injunctive relief, courts have
considered the egregiousness of the violations, the isolated or repeated nature of the



Furlong - July 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $15,655.00
08/01/1998-09/30/1998 8% 1.33% $208.73 $15,863.73
10/01/1998-12/3 1/1998 8% 2% $317.27 $16,181.00
01/01/1999-03/3 1/1999 MH 1.75% $283.17 $16,464.17
04/01/1999-06/30/1999 8% 2% $329.28 $16,793.45
07/01/1999-09/30/1999 8% 2% $335.87 $17,129.32
10/01/1999-12/3 1/1999 8% 2% $342.59 $17,471.91
01/01/2000-03/3 1/2000 8% 2% $349.44 $17,821.35
04/01/2000-06/30/2000 9% 2.25% $400.98 $18,222.33
07/01/2000-09/30/2000 9% 2.25% $410.00 $18,632.33
10/01/2000-12/3 1/2000 % 2.25% $419.23 $19,051.56
01/01/2001-03/3 1/2001 9% 2.25% $428.66 $19,480.22
04/01/2001-06/30/2001 8% 2% $389.60 $19,869.82
07/01/2001-09/30/2001 TMM% 1.75% $347.72 $20,217.54
10/01/2001-12/3 1/2001 M% 1.75% $353.81 $20,571.35
01/01/2002-03/3 1/2002 6% 1.5% $308.57 $20,879.92
04/01/2002-06/30/2002 6% 1.5% $313.20 $21,193.12
07/01/2002-09/30/2002 6% 1.5% $317.90 $21,511.02
10/01/2002-12/3 1/2002 6% 1.5% $322.67 $21,833.69
01/01/2003-03/3 1/2003 5% 1.25% $272.92 $22,106.61
04/01/2003-06/30/2003 5% 1.25% $276.33 $22,382.94
07/01/2003-09/30/2003 5% 1.25% $279.79 $22,662.73
10/01/2003-12/3 1/2003 4% 1% $226.63 $22,889.36
01/01/2004-03/3 1/2004 4% 1% $228.89 $23,118.25
04/01/2004-06/30/2004 5% 1.25% $288.98 $23,407.23
07/01/2004-09/30/2004 4% 1% $234.07 $23,641.30
10/01/2004-12/3 1/2004 5% 1.25% $295.52 $23,936.82
01/01/2005-03/3 1/2005 5% 1.25% $299.21 $24,236.03
04/01/2005-06/30/2005 6% 1.5% $363.54 $24,599.57
07/01/2005-09/30/2005 6% 15% $368.99 $24,968.56
10/01/2005-12/3 1/2005 T% 1.75% $436.95 $25,405.51
01/01/2006-03/3 1/2006 Th 1.75% $444.60 “ $25,850.11
04/01/2006-06/30/2006 T% 1.75% $452.38 $26,302.49
07/01/2006-09/30/2006 8% 2% $526.05 $26,828.54
10/01/2006-12/3 1/2006 8% 2% $536.57 $27,365.11
01/01/2007-03/3 1/2007 8% 2% $547.30 $27,912.41
04/01/2007-06/30/2007 8% 2% $558.25 $28,470.66
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

04/01/2006-06/30/2006 TH 1.75% $2,768.75 $160,983.26
07/01/2006-09/30/2006 8% 2% $3,219.67 $164,202.93
10/01/2006-12/3 1/2006 8% 2% $3,284.06 $167,486.99
01/01/2007-03/3 1/2007 8% 2% $3,349.74 $170,836.73
04/01/2007-06/30/2007 8% 2% $3,416.73 $174,253.46
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
04/01/1997-06/30/2007 $88,877.46 $174,253.46
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

Prejudgment Violation Range Quarter Interest Total Prejudgment Total
07/01/1998-06/30/2007 $11,187.31 $24,656.31

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Furlong - March 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $37,492.00
04/01/1998-06/30/1998 8% 2% $749.84 $38,241.84
07/01/1998-09/30/1998 8% 2% $764.84 $39,006.68
10/01/1998- 12/31/1998 * 8% 2% $780.13 $39,786.81
01/01/1999-03/31/1999 T% 1.75% $696.27 $40,483.08
04/01/1999-06/30/1999 8% 2% $809.66 $41,292.74
07/01/1999-09/30/1999 8% 2% $825.85 $42,118.59
10/01/1999-12/3 1/1999 8% 2% $842.37 $42,960.96
01/01/2000-03/3 1/2000 8% 2% $859.22 $43,820.18
04/01/2000-06/30/2000 9% 2.25% $985.95 $44,806.13
07/01/2000-09/30/2000 9% 2.25% $1,008.14 $45,814.27
10/01/2000-12/3 1/2000 % 2.25% $1,030.82 $46,845.09
* 01/01/2001-03/31/2001 9% 2.25% $1,054.01 $47,899.10
04/01/2001-06/30/2001 8% 2% $957.98 $48,857.08
07/01/2001-09/30/2001 TTM% 1.75% $855.00 $49,712.08
10/01/2001-12/31/2001 Th 1.75% $869.96 $50,582.04
01/01/2002-03/3 1/2002 6% 1.5% $758.73 $51,340.77
04/01/2002-06/30/2002 6% 1.5% $770.11 $52,110.88
07/01/2002-09/30/2002 6% 1.5% $781.66 $52,892.54
10/01/2002-12/31/2002 6% 1.5% $793.39 $53,685.93
01/01/2003-03/3 1/2003 5% 1.25% $671.07 $54,357.00
04/01/2003-06/30/2003 5% 1.25% $679.46 $55,036.46
07/01/2003-09/30/2003 5% 1.25% $687.96 $55,724.42
10/01/2003-12/3 1/2003 4% 1% $557.24 $56,281.66
01/01/2004-03/3 1/2004 4% 1% $562.82 $56,844.48
04/01/2004-06/30/2004 5% 1.25% $710.56 $57,555.04
07/01/2004-09/30/2004 4% 1% $575.55 $58,130.59
10/01/2004-12/31/2004 5% 1.25% $726.63 $58,857.22
01/01/2005-03/3 1/2005 5% 1.25% $735.72 $59,592.94
04/01/2005-06/30/2005 6% 1.5% $893.89 $60,486.83
07/01/2005-09/30/2005 6% 15% $907.30 $61,394.13
10/01/2005-12/31/2005 TH 1.75% $1,074.40 $62,468.53
01/01/2006-03/3 1/2006 TMM% 1.75% $1,093.20 $63,561.73
04/01/2006-06/30/2006 T% 1.75% $1,112.33 $64,674.06
07/01/2006-09/30/2006 8% 2% $1,293.48 $65,967.54
10/01/2006-12/3 1/2006 8% 2% . $1,319.35 $67,286.89
01/01/2007-03/3 1/2007 8% 2% $1,345.74 $68,632.63
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - January 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $67,555.00
02/01/1997-03/3 1/1997 9% 1.5% $1,013.33 $68,568.33
04/01/1997-06/30/1997 9% 2.25% $1,542.79 $70,111.12
07/01/1997-09/30/1997 9% 2.25% $1,577.50 $71,688.62
10/01/1997-12/31/1997 9% 2.25% $1,612.99 $73,301.61
01/01/1998-03/3 1/1998 9% 2.25% $1,649.29 $74,950.90
04/01/1998-06/30/1998. 8% 2% $1,499.02 $76,449.92
07/01/1998-09/30/1998 8% 2% $1,529.00 $77,978.92
10/01/1998-12/3 1/1998 8% 2% $1,559.58 $79,538.50
01/01/1999-03/3 1/1999 Th 1.75% $1,391.92 $80,930.42
04/01/1999-06/30/1999 8% 2% $1,618.61 $82,549.03
07/01/1999-09/30/1999 8% 2% $1,650.98 $84,200.01
10/01/1999-12/31/1999 8% 2% $1,684.00 $85,884.01
01/01/2000-03/3 1/2000 8% 2% $1,717.68 $87,601.69
04/01/2000-06/30/2000 9% 2.25% $1,971.04 $89,572.73
07/01/2000-09/30/2000 9% 2.25% $2,015.39 $91,588.12
10/01/2000-12/3 1/2000 9% 2.25% $2,060.73 $93,648.85
01/01/2001-03/31/2001 9% 2.25% $2,107.10 $95,755.95
04/01/2001-06/30/2001 8% 2% $1,915.12 $97,671.07
07/01/2001-09/30/2001 T% 1.75% $1,709.24 $99,380.31
10/01/2001-12/3 1/2001 T% 1.75% $1,739.16 $101,119.47
01/01/2002-03/3 1/2002 6% 1.5% - $1,516.79 $102,636.26
04/01/2002-06/30/2002 6% 1.5% | $1,539.54 $104,175.80
07/01/2002-09/30/2002 6% 15% $1,562.64 $105,738.44
10/01/2002-12/3 1/2002 6% 1.5% $1,586.08 $107,324.52
01/01/2003-03/3 1/2003 5% 1.25% $1,341.56 $108,666.08
04/01/2003-06/30/2003 5% 1.25% $1,358.33 $110,024.41
07/01/2003-09/30/2003 5% 1.25% $1,375.31 $111,399.72
10/01/2003-12/3 1/2003 4% 1% $1,114.00 $112,513.72
01/01/2004-03/3 1/2004 4% 1% $1,125.14 $113,638.86
04/01/2004-06/30/2004 5% 1.25% $1,420.49 $115,059.35
07/01/2004-09/30/2004 4% 1% $1,150.59 $116,209.94
10/01/2004-12/3 1/2004 5% 1.25% $1,452.62 $117,662.56
01/01/2005-03/3 1/2005 5% 1.25% $1,470.78 $119,133.34
04/01/2005-06/30/2005 6% 1.5% $1,787.00 $120,920.34
07/01/2005-09/30/2005 6% 1.5% $1,813.81 $122,734.15
10/01/2005-12/3 1/2005 TM% 1.75% $2,147.85 $124,882.00
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest Rates Through 6/30/2007
Violation Amount: 61289.00
Violation Start Date (mm/dd/yyyy): (07/28/1997

Payoff Date (mm/dd/yyyy): pom 6/2007

Header for Report [Optional ’- 80 Chars Max] [Furlong - July 1997 sales of HCCA stock

Click here for the PJIC FA
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Furlong - January 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $96,322.00
02/01/1998-03/31/1998 9% 1.5% $1,444.83 $97,766.83
04/01/1998-06/30/1998 8% 2% $1,955.34 $99,722.17
07/01/1998-09/30/1998 8% 2% $1,994.44 $101,716.61
10/01/1998-12/3 1/1998 8% 2% $2,034.33 $103,750.94
01/01/1999-03/3 1/1999 T% 1.75% $1,815.64 $105,566.58
04/01/1999-06/30/1999 8% 2% $2,111.33 $107,677.91
07/01/1999-09/30/1999 8% 2% $2,153.56 $109,831.47
10/01/1999-12/31/1999 8% 2% $2,196.63 $112,028.10
01/01/2000-03/3 1/2000 8% 2% $2,240.56 $114,268.66
04/01/2000-06/30/2000 9% 2.25% $2,571.04 $116,839.70
07/01/2000-09/30/2000 9% 2.25% $2,628.89 $119,468.59
10/01/2000-12/3 1/2000 9% 2.25% $2,688.04 $122,156.63
01/01/2001-03/3 1/2001 9% 2.25% $2,748.52 $124,905.15
04/01/2001-06/30/2001 8% 2% $2,498.10 $127,403.25
07/01/2001-09/30/2001 T% 1.75% $2,229.56 $129,632.81
10/01/2001-12/3 1/2001 T% 1.75% $2,268.57 $131,901.38
01/01/2002-03/3 1/2002 6% 1.5% $1,978.52 $133,879.90
04/01/2002-06/30/2002 6% 1.5% $2,008.20 $135,888.10
07/01/2002-09/30/2002 6% 1.5% $2,038.32 $137,926.42
10/01/2002-12/3 1/2002 6% 1.5% $2,068.90 $139,995.32
01/01/2003-03/3 1/2003 5% 1.25% $1,749.94 $141,745.26
04/01/2003-06/30/2003 5% 1.25% $1,771.82 $143,517.08
07/01/2003-09/30/2003 5% 1.25% $1,793.96 $145,311.04
10/01/2003-12/3 1/2003 4% 1% $1,453.11 $146,764.15
01/01/2004-03/3 1/2004 4% 1% $1,467.64 $148,231.79
04/01/2004-06/30/2004 5% 1.25% $1,852.90 $150,084.69
07/01/2004-09/30/2004 4% 1% $1,500.85 $151,585.54
10/01/2004-12/3 1/2004 5% 1.25% $1,894.82 $153,480.36
01/01/2005-03/3 1/2005 5% 1.25% $1,918.50 $155,398.86
04/01/2005-06/30/2005 6% 15% $2,330.98 $157,729.84
07/01/2005-09/30/2005 6% 1.5% $2,365.95 $160,095.79
10/01/2005-12/3 1/2005 Mm 1.75% $2,801.68 $162,897.47
01/01/2006-03/3 1/2006 TM% 1.75% $2,850.71 $165,748.18
04/01/2006-06/30/2006 TM% 1.75% $2,900.59 $168,648.77
07/01/2006-09/30/2006 8% 2% $3,372.98 $172,021.75
10/01/2006-12/3 1/2006 8% 2% $3,440.44 $175,462.19
“ http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - February 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $71,151.00
03/01/1997-03/3 1/1997 9% 0.75% $533.63 $71,684.63
04/01/1997-06/30/1997 9% 2.25% $1,612.90 $73,297.53
07/01/1997-09/30/1997 9% 2.25% $1,649.19 $74,946.72
10/01/1997-12/31/1997 9% 2.25% $1,686.30 $76,633.02
01/01/1998-03/31/1998 9% 2.25% $1,724.24 $78,357.26
04/01/1998-06/30/1998 8% 2% $1,567.15 $79,924.41
07/01/1998-09/30/1998 8% 2% $1,598.49 $81,522.90
10/01/1998-12/31/1998 8% 2% $1,630.46 $83,153.36
01/01/1999-03/31/1999 TM% 1.75% $1,455.18 $84,608.54
04/01/1999-06/30/1999 8% 2% $1,692.17 $86,300.71
07/01/1999-09/30/1999 8% 2% $1,726.01 $88,026.72
10/01/1999-12/3 1/1999 8% 2% $1,760.53 $89,787.25
01/01/2000-03/3 1/2000 8% 2% $1,795.75 $91,583.00
04/01/2000-06/30/2000 9% 2.25% $2,060.62 $93,643.62
07/01/2000-09/30/2000 9% 2.25% $2,106.98 $95,750.60
10/01/2000-12/3 1/2000 9% 2.25% $2,154.39 $97,904.99
01/01/2001-03/3 1/2001 9% 2.25% $2,202.86 $100,107.85
04/01/2001-06/30/2001 8% 2% $2,002.16 $102,110.01
07/01/2001-09/30/2001 Th 1.75% $1,786.93 $103,896.94
10/01/2001-12/31/2001 TMM% 1.75% $1,818.20 $105,715.14
01/01/2002-03/3 1/2002 6% 15% $1,585.73 $107,300.87
04/01/2002-06/30/2002 6% 15% $1,609.51 $108,910.38
07/01/2002-09/30/2002 6% 15% $1,633.66 $110,544.04
10/01/2002-12/31/2002 6% 1.5% $1,658.16 $112,202.20
01/01/2003-03/3 1/2003 5% 1.25% $1,402.53 $113,604.73
04/01/2003-06/30/2003 5% 1.25% $1,420.06 $115,024.79
07/01/2003-09/30/2003 5% 1.25% $1,437.81 $116,462.60
10/01/2003-12/3 1/2003 4% 1% $1,164.63 $117,627.23
01/01/2004-03/3 1/2004 4% 1% $1,176.27 $118,803.50
04/01/2004-06/30/2004 5% 1.25% $1,485.04 $120,288.54
07/01/2004-09/30/2004 4% 1% $1,202.89 $121,491.43
10/01/2004-12/31/2004 5% 1.25% $1,518.64 $123,010.07
01/01/2005-03/3 1/2005 5% 1.25% $1,537.63 $124,547.70
04/01/2005-06/30/2005 6% 1.5% $1,868.22 $126,415.92
07/01/2005-09/30/2005 6% 1.5% $1,896.24 $128,312.16
10/01/2005-12/31/2005 Th 1.75% $2,245.46 $130,557.62
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007
Violation Amount: 125900.00
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): lov 6/2007 __.
Header for Report [Optional - 80 Chars Max];[Furlong - January 1999 sales of HCCA stock
Click here for the PIIC FAQ
Click here for the memorandui ibing the method for calculating interest
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - September 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+ Interest
Violation Amount $36,375.00
10/01/1997-12/3 1/1997 9% 2.25% $818.44 $37,193.44
01/01/1998-03/31/1998 9% 2.25% $836.85 $38,030.29
04/01/1998-06/30/1998 8% 2% $760.61 $38,790.90
07/01/1998-09/30/1998 8% 2% $775.82 $39,566.72
10/01/1998-12/31/1998 8% 2% $791.33 $40,358.05
01/01/1999-03/31/1999 Th 1.75% $706.27 $41,064.32
04/01/1999-06/30/1999 8% 2% $821.29 $41,885.61
07/01/1999-09/30/1999 8% 2% $837.71 $42,723.32
10/01/1999-12/31/1999 8% 2% $854.47 $43,577.79
01/01/2000-03/3 1/2000 8% 2% $871.56 $44,449.35
04/01/2000-06/30/2000 % 2.25% $1,000.11 $45,449.46
07/01/2000-09/30/2000 9% 2.25% $1,022.61 $46,472.07
10/01/2000-12/3 1/2000 % 2.25% $1,045.62 $47,517.69
01/01/2001-03/31/2001 9% 2.25% $1,069.15 $48,586.84
04/01/2001-06/30/2001 8% 2% $971.74 $49,558.58
07/01/2001-09/30/2001 TH 1.75% $867.28 $50,425.86
10/01/2001-12/31/2001 TM% 1.75% $882.45 $51,308.31
01/01/2002-03/3 1/2002 6% 15% $769.62 $52,077.93
04/01/2002-06/30/2002 6% 1.5% $781.17 $52,859.10
07/01/2002-09/30/2002 6% 1.5% $792.89 $53,651.99
10/01/2002-12/3 1/2002 6% 1.5% $804.78 $54,456.77
01/01/2003-03/3 1/2003 5% 1.25% $680.71 $55,137.48
04/01/2003-06/30/2003 5% 1.25% $689.22 $55,826.70
07/01/2003-09/30/2003 5% 1.25% $697.83 $56,524.53
10/01/2003-12/3 1/2003 4% 1% $565.25 $57,089.78
01/01/2004-03/3 1/2004 4% 1% $570.90 $57,660.68
04/01/2004-06/30/2004 5% 1.25% $720.76 $58,381.44
07/01/2004-09/30/2004 4% 1% $583.81 $58,965.25
10/01/2004-12/3 1/2004 5% 1.25% $737.07 $59,702.32
01/01/2005-03/31/2005 5% 1.25% $746.28 $60,448.60
04/01/2005-06/30/2005 6% 1.5% $906.73 $61,355.33
07/01/2005-09/30/2005 6% 15% $920.33 + $62,275.66
10/01/2005- 12/31/2005 T% 1.75% $1,089.82 $63,365.48
01/01/2006-03/3 1/2006 T% 1.75% $1,108.90 $64,474.38
04/01/2006-06/30/2006 T% 1.75% $1,128.30 $65,602.68
07/01/2006-09/30/2006 8% 2% $1,312.05 $66,914.73
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

Prejudgment Violation Range Quarter Interest Total Prejudgment Total
12/01/1998-06/30/2007 $1,156.89 $2,656.89

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount: [7492.00
Violation Start Date (mm/dd/yy):

Payoff Date (mm/dd/yyyy): [ov672007 _

Header for Report [Optional - 80 Chars Max]:|Furlong - March 1998 sales of HCCA stock

Click here for the PIC FAQ

Click for the memorandum describing the od for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html

6/12/2007


Prejudgment Interest Calculator . Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007
Violation Amount: 16260.00
Violation Start Date (mm/dd/yyyy): 12/31/1998

Payoff Date (mm/dd/yyyy): or 16/2007

Header for Report [Optional - 80 Chars Max]:[Furlong - December 1998 sales of HCCA stock

Click here for the PIIC FAQ

Click here for the mem cribing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry. html 6/12/2007


Furlong - January 2000 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 1

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $377,901.00
02/01/2000-03/3 1/2000 8% 1.33% $5,038.68 $382,939.68
04/01/2000-06/30/2000 9% 2.25% $8,616.14 $391,555.82
07/01/2000-09/30/2000 9% 2.25% $8,810.01 $400,365.83
10/01/2000-12/31/2000 9% 2.25% $9,008.23 $409,374.06
01/01/2001-03/3 1/2001 9% 2.25% $9,210.92 $418,584.98
04/01/2001-06/30/2001 8% 2% $8,371.70 $426,956.68
07/01/2001-09/30/2001 TM% 1.75% $7,471.74 $434,428.42
10/01/2001-12/31/2001 % 1.75% $7,602.50 $442,030.92
01/01/2002-03/3 1/2002 6% 1.5% $6,630.46 $448,661.38
04/01/2002-06/30/2002 6% 15% $6,729.92 $455,391.30
07/01/2002-09/30/2002 6% 1.5% $6,830.87 $462,222.17
10/01/2002-12/3 1/2002 6% 1.5% $6,933.33 $469,155.50
01/01/2003-03/3 1/2003 5% 1.25% $5,864.44 $475,019.94
04/01/2003-06/30/2003 5% 1.25% $5,937.75 $480,957.69
07/01/2003-09/30/2003 5% 1.25% $6,011.97 $486,969.66
10/01/2003-12/3 1/2003 4% 1% $4,869.70 $491,839.36
01/01/2004-03/3 1/2004 4% 1% $4,918.39 $496,757.75
04/01/2004-06/30/2004 S% 1.25% $6,209.47 $502,967.22
07/01/2004-09/30/2004 4% 1% $5,029.67 $507,996.89
10/01/2004-12/3 1/2004 5% 1.25% $6,349.96 $514,346.85
01/01/2005-03/3 1/2005 5% 1.25% $6,429.34 $520,776.19
04/01/2005-06/30/2005 6% 1.5% $7,811.64 $528,587.83
07/01/2005-09/30/2005 6% 1.5% $7,928.82 $536,516.65
10/01/2005-12/3 1/2005 T% 1.75% $9,389.04 $545,905.69
01/01/2006-03/3 1/2006 % 1.75% $9,553.35 $555,459.04
04/01/2006-06/30/2006 TM% 1.75% $9,720.53 $565,179.57
07/01/2006-09/30/2006 8% 2% $11,303.59 $576,483.16
10/01/2006-12/3 1/2006 8% 2% $11,529.66 $588,012.82
01/01/2007-03/3 1/2007 8% 2% $11,760.26 $599,773.08
04/01/2007-06/30/2007 8% 2% $11,995.46 $611,768.54
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
02/01/2000-06/30/2007 $233,867.54 $611,768.54
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):

Payoff Date (mm/dd/yyyy): Jozner2007

Header for Report [Optional - 80 Chars Max];[Furlong - March 2000 sales of HCCA stock

Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html

6/12/2007


Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): [own 6/2007
Header for Report [Optional - 80 Chars Max]:[Furlong - May 1997 sales of HCCA stock
Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


disgorgement must recognize that separating legal from illegal profits exactly may at
times be a near-impossible task. Id. at 578. Despite the fact that the SEC need only prove
an approximation for disgorgement, the disgorgement calculations in this case can be
proven with a reasonably precise calculation, based on what the defendants made from
their HCCA stock sales during the period of the fraud.

The SEC also seeks prejudgment interest on the disgorgement. Prejudgment
interest is typically granted in securities cases, because it promotes enforcement of the
securities laws by depriving wrongdoers of the use of their ill gotten gains, by preventing
them from using the funds as, essentially, an interest free loan. Furlong and Pietrzak
cannot avoid prejudgment interest by some argument that they did not have continuous
use of the funds prior to the judgment and therefore did not benefit from them. SEC v.
Kenton Capital, Ltd., 69 F.Supp. 1, 16-17 (D.D.C. 1998). For the Court to disallow
prejudgment interest against Furlong and Pietrzak would have the effect of allowing them
interest free use of their ill gotten gains for a period spanning more than a decade, and
would produce an unjust result. SEC v. First Jersey Securities, Inc., 101 F.3d 1450, 1476
(2d Cir. 1996), cert. denied, 118 S. Ct. 37 (1997) (courts have the authority to order
defendants to pay prejudgment interest on ill-gotten gains).

As set forth in the trial testimony of Neal Seiden, the SEC investigating agent
calculated prejudgment interest on the disgorgement amounts of $3,452,491 (Furlong)
and $1,296,720 (Pietrzak). As set forth in Summary Evidence #7 (received at trial, and
attached hereto as Exhibit B) Seiden calculated prejudgment interest from 1/1/1997
through 7/16/2007 to be $2,515,724 (Furlong) and $836,866 (Pietrzak). As explained on
the witness stand in this matter, prejudgment interest on the amounts of disgorgement
was computed at the IRS rate for underpayment of taxes from 1/1/1997 through
7/16/2007, which interest rate was reevaluated quarterly during that time period.
Attached hereto as Exhibit C, are true and correct copies of Seiden’s prejudgment interest
calculations by month, for defendant Furlong for his HCCA stock sales from 1/1/1997
through 6/30/2000, which reflects prejudgment interest calculations for each month
during which Furlong sold the stock, through 7/16/2007 (the day trial began in this
matter). Attached hereto as Exhibit D, are true and correct copies of Seiden’s
prejudgment interest calculations by month, for defendant Pietrzak for his HCCA stock

i


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest Rates Through 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):

Payoff Date (mm/dd/yyyy): fori 6/2007

Header for Report [Optional - 80 Chars Max]:[Furlong - October 1997 sales of HCCA stock

Click here for the PIIC FAQ

Click here for the memor: describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html

6/12/2007


fraudulent stock offering); SEC v. Manor Nursing Centers, Inc., 458 F.2d 1082, 1104 (2d
Cir. 1972) (holding it appropriate for district court to order defendants to disgorge the
proceeds received in connection with the offering). In a similar recent case, after the
defendants were found liable for violations of the antifraud and other provisions, by
overstating assets of the company, profiting from illicitly selling shares of the company,
failing to implement a system of internal accounting controls and knowingly falsifying
books and records accounts and reports filed with the SEC, the court imposed an
injunction, officer and director bars, civil penalties and disgorgement based upon the
reasonable approximation of stock proceeds received by the defendants. SEC v. Levine.
2007 WL 1378462 (D.D.C. May 8, 2007).

Further, the Court should note that there is substantial authority which supports

the proposition that securities laws violators may not offset their disgorgement liability
with business expenses. SEC v. Hughes Capital Corp., 917 F. Supp. 1080, 1086 (D.N.J.
1996); SEC v. Great Lakes Equities Co. et al., 775 F. Supp 211, 214-15 (E.D. Mich.
1991) (rejecting deductions from the disgorgement amount for overhead, commissions
and other expenses); SEC v. Benson, 657 F. Supp. 1122, 1134 (S.D.N.Y. 1987) (stating
that the “manner in which [defendant] chose to spend his misappropriations is irrelevant
to his objection to disgorge”); SEC v. Kenton Capital, Ltd., 69 F.Supp. 1, 16 (D.D.C.
1998) (holding that the SEC had provided ample evidence that the funds were obtained
fraudulently, and that the defendants may not escape disgorgement by asserting that
expenses associated with the fraud were legitimate).

It is well established that disgorgement need only be a reasonable approximation
of profits, or losses avoided, causally connected to the violation. SEC v. First Jersey
Securities, Inc., 101 F.3d at 1475; SEC v. Patel, 61 F.3d at 139. Finally, any risk of

uncertainty in calculating disgorgement should fall on the wrongdoers Furlong and
Pietrzak, whose illegal conduct created that uncertainty. Id. at 140. That the SEC is not
required to prove the precise amount of disgorgement is grounded in the altogether
reasonable observation that that endeavor would be impractical, if not impossible. SEC v.
Antar, 97 F. Supp. 2d 576, 578 (D.N.J.2000). The Antar court further held that “[d]espite

sophisticated and econometric modeling, predicting stock market responses to alternative

variables is .. . speculative at best.” Id. at 578. That court held that rules for calculating

10


Prejudgment Interest Calculator

Division of Enforcement
Prejudgment Interest Calculator

Page 1 of 1

Interest RatesThrough 6/30/2007
Violation Amount: 188666.00
Violation Start Date (mm/dd/yyyy): 08/26/1997

Payoff Date (mm/dd/yyyy): [orn 6/2007 _

Header for Report [Optional - 80 Chars Max]:|Furlong - August 1997 sales of HCCA stock

Click here for the PIIC FAQ

Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html

6/12/2007


Prejudgment Interest Calculator Page 1 of 1
Division of Enforcement
Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007
Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): [own 6/2007,
Header for Report [Optional - 80 Chars Max];Furlong - January 2000 sales of HCCA stock
Click here for the PJIC FAQ
Click here for the memorandum describing the me calculating interest
hittp://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
» Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):

Payoff Date (mm/dd/yyyy): [ov 6/2007

Header for Report [Optional - 80 Chars Max]{Furlong - January 1997 sales of HCCA stock

Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html

6/12/2007


12) June 30, 1998 Form 10-QSB, filed December 13, 1999, and signed by Furlong
and Pietrzak (P.Ex. #378);

13) | September 30, 1998 Form 10-QSB, filed December 13, 1999, and signed by
Furlong and Pietrzak (P.Ex. #379);

14) March 31, 1999 Form 10-QSB, filed December 13, 1999, and signed by
Furlong and Pietrzak (P.Ex. #382);

15) June 30, 1999 Form 10-QSB, filed December 13, 1999, and signed by Furlong
and Pietrzak (P.Ex. #383);

16) September 30, 1999 Form 10-QSB, filed December 14, 1999, and signed by
Furlong and Pietrzak (P.Ex. #384);

17) 1997 Form 10-KSB, filed December 14, 1999, and signed by Furlong and
Pietrzak (P.Ex. #376);

18) 1998 Form 10-KSB, filed December 14, 1999, and signed by Furlong and
Pietrzak (P.Ex. #380);

19) 1998 Form 10-KSB A#1, filed December 14, 1999, and signed by Furlong and
Pietrzak (P.Ex. #381); and

20) Form 10-SB A#2, filed December 16, 1999, and signed by Furlong (P.Ex. #385).


violations, the degree of scienter involved, the sincerity of the defendant's assurances, if any,
against future violations, the defendant's recognition of the wrongful nature of the conduct,
the likelihood that the defendant's occupation will present opportunities (or lack thereof) for
future violations, and the defendant's age and health. SEC v. Bonastia, 614 F.2d at 912; SEC
y. Commonwealth Chemical Securities, Inc., 574 F.2d at 100; SEC v. Youmans, 729 F.2d
413, 415 (6th Cir. 1984).

In this case, every factor weighs in favor of injunctive relief. Their conduct was

egregious. They engaged in a protracted scheme which involved many fraudulent acts over a
period of 3% years. Furlong and Pietrzak directly caused the many misrepresentations and
omissions made in HCCA’s registration statements, periodic reports, current report, press
releases and letter to shareholders, including the overstatement of assets by significantly
material amounts. From a review of the jury’s responses to the verdict interrogatories, it is
clear that the jury found fraud as to every category of asset booked by HCCA, and that
HCCA had no material asset that was not connected to the fraud. Also, as proved at trial,
Furlong and Pietrzak also ignored repeated warnings from the SEC Division of Corporation
Finance. They were repeatedly told that HCCA’s financial statements did not comply with
GAAP. Furlong and Pietrzak nevertheless continued selling HCCA stock, and were also
responsible for HCCA’s delinquency in filing its periodic reports subsequent to the filing of
the September 1999 Form 10-QSB. Moreover, the violations occurred repeatedly over
multiple years beginning in1996 in conjunction with HCCA’s filing of Form 10-SB, and
continued through 2001. Furlong is a recidivist, having been previously enjoined in an SEC
case and subjected to cease-and-desist orders from various states. Both defendants have
criminal records, which the Court should consider in its decision to grant injunctive relief.”

Furlong and Pietrzak each acted with a high degree of scienter. They were
unquestionably the engines behind the fraud in this matter and remained officers and
directors of HCCA for years after the period which gave rise to this litigation. The violations
established by the SEC in this matter demonstrate need for injunctive relief. The violations
were egregious, and occurred over a long period of time. Furlong and Pietrzak engaged ina

? Pietrzak pled guilty to a misdemeanor in Illinois for aiding and abetting others in connection the
misapplication of bank funds. Furlong was sentenced to approximately six months incarceration in
the federal penal system, for failure to file income tax returns, and was released on May 17, 1988.


Furlong - August 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 1

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $29,550.00
09/01/1999-09/30/1999 8% 0.67% $197.00 $29,747.00
10/01/1999-12/31/1999 8% 2% $594.94 $30,341.94
01/01/2000-03/3 1/2000 8% 2% $606.84 $30,948.78
04/01/2000-06/30/2000 9% 2.25% $696.35 $31,645.13
07/01/2000-09/30/2000 9% 2.25% $712.02 $32,357.15
10/01/2000-12/3 1/2000 9% 2.25% $728.04 $33,085.19
01/01/2001-03/3 1/2001 9% 2.25% $744.42 $33,829.61
04/01/2001-06/30/2001 8% 2% $676.59 $34,506.20
07/01/2001-09/30/2001 TM% 1.75% $603.86 $35,110.06
10/01/2001-12/31/2001 T% 1.75% $614.43 $35,724.49
01/01/2002-03/3 1/2002 6% 1.5% $535.87 $36,260.36
04/01/2002-06/30/2002 6% 1.5% $543.91 $36,804.27
07/01/2002-09/30/2002 6% 1.5% $552.06 $37,356.33
10/01/2002-12/3 1/2002 6% 1.5% $560.34 $37,916.67
01/01/2003-03/3 1/2003 5% 1.25% $473.96 $38,390.63
04/01/2003-06/30/2003 5% 1.25% $479.88 $38,870.51
07/01/2003-09/30/2003 5% 1.25% $485.88 $39,356.39
10/01/2003-12/3 1/2003 4% 1% $393.56 $39,749.95
01/01/2004-03/3 1/2004 4% 1% $397.50 $40,147.45
04/01/2004-06/30/2004 5% 1.25% $501.84 $40,649.29
07/01/2004-09/30/2004 A% 1% $406.49 $41,055.78
10/01/2004-12/3 1/2004 5% 1.25% $513.20 $41,568.98
01/01/2005-03/3 1/2005 5% 1.25% $519.61 $42,088.59
04/01/2005-06/30/2005 6% 1.5% $631.33 $42,719.92
07/01/2005-09/30/2005 6% 1.5% $640.80 $43,360.72
10/01/2005-12/3 1/2005 TM% 1.75% $758.81 $44,119.53
01/01/2006-03/3 1/2006 T% 1.75% $772.09 $44,891.62
04/01/2006-06/30/2006 % 1.75% $785.60 $45,677.22
07/01/2006-09/30/2006 8% 2% $913.54 $46,590.76
10/01/2006-12/3 1/2006 8% 2% $931.82 $47,522.58
01/01/2007-03/3 1/2007 8% 2% $950.45 $48,473.03
04/01/2007-06/30/2007 8% 2% $969.46 $49,442.49
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
09/01/1999-06/30/2007 $19,892.49 $49,442.49
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - June 1998 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $13,469.00
07/01/1998-09/30/1998 8% 2% $269.38 $13,738.38
10/01/1998-12/3 1/1998 8% 2% $274.77 $14,013.15
01/01/1999-03/3 1/1999 Th 1.75% $245.23 $14,258.38
04/01/1999-06/30/1999 8% 2% $285.17 $14,543.55
07/01/1999-09/30/1999 8% 2% $290.87 $14,834.42
10/01/1999-12/3 1/1999 8% 2% $296.69 $15,131.11
01/01/2000-03/3 1/2000 8% 2% $302.62 $15,433.73
04/01/2000-06/30/2000 9% 2.25% $347.26 $15,780.99
07/01/2000-09/30/2000 9% 2.25% $355.07 $16,136.06
10/01/2000-12/3 1/2000 9% 2.25% $363.06 $16,499.12
01/01/2001-03/3 1/2001 % 2.25% $371.23 $16,870.35
04/01/2001-06/30/2001 8% 2% $337.41 $17,207.76
07/01/2001-09/30/2001 TMM% 1.75% $301.14 $17,508.90
10/01/2001-12/3 1/2001 Th 1.75% $306.41 $17,815.31
01/01/2002-03/3 1/2002 6% 1.5% $267.23 $18,082.54
04/01/2002-06/30/2002 6% 1.5% $271.24 $18,353.78
07/01/2002-09/30/2002 6% 15% $275.31 $18,629.09
10/01/2002-12/3 1/2002 6% 15% $279.44 $18,908.53
01/01/2003-03/3 1/2003 5% 1.25% $236.36 $19,144.89
04/01/2003-06/30/2003 5% 1.25% $239.31 $19,384.20
07/01/2003-09/30/2003 5% 1.25% $242.30 $19,626.50
10/01/2003-12/3 1/2003 4% 1% $196.27 $19,822.77
01/01/2004-03/3 1/2004 4% 1% $198.23 $20,021.00
04/01/2004-06/30/2004 5% 1.25% $250.26 $20,271.26
07/01/2004-09/30/2004 4% 1% $202.71 $20,473.97
10/01/2004-12/3 1/2004 5% 1.25% $255.92 $20,729.89
01/01/2005-03/3 1/2005 5% 1.25% $259.12 $20,989.01
04/01/2005-06/30/2005 6% 1.5% $314.84 $21,303.85
07/01/2005-09/30/2005 6% 1.5% $319.56 $21,623.41
10/01/2005-12/3 1/2005 T% 1.75% $378.41 $22,001.82
01/01/2006-03/3 1/2006 TM% 1.75% $385.03 $22,386.85
04/01/2006-06/30/2006 % 1.75% $391.77 $22,778.62
07/01/2006-09/30/2006 8% 2% $455.57 $23,234.19
10/01/2006-12/3 1/2006 8% 2% $464.68 $23,698.87
01/01/2007-03/3 1/2007 8% 2% $473.98 $24,172.85
04/01/2007-06/30/2007 8% 2% $483.46 $24,656.31
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

01/01/2006-03/3 1/2006 TMM% 1.75% $2,284.76 $132,842.38
04/01/2006-06/30/2006 TMM% 1.75% $2,324.74 $135,167.12
07/01/2006-09/30/2006 8% 2% $2,703.34 $137,870.46
10/01/2006-12/31/2006 8% 2% $2,757.41 _ $140,627.87
01/01/2007-03/3 1/2007 8% 2% $2,812.56 $143,440.43
04/01/2007-06/30/2007 8% 2% $2,868.81 $146,309.24
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
03/01/1997-06/30/2007 $75,158.24 $146,309.24
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


‘egregiousness’ of the underlying securities law violation; (2) the defendant’s ‘repeat
offender’ status; (3) the defendant’s ‘role’ or position when he engaged in the fraud; (4)
the defendant’s degree of scienter; (5) the defendant’s economic stake in the violation;
and (6) the likelihood that misconduct will recur.” E.g., SEC v. Patel, 61 F.3d at 141 (2d
Cir. 1995). Courts may consider some of these factors, all of them, or additional factors.
Id. at 141.

Analysis of these factors demonstrates that O&D bars against Furlong and
Pietrzak are appropriate. Their violations were egregious; they were and remained
officers of a public company until at least April 2005; they acted with high degrees of
scienter; they had a large economic stake in their violations (Furlong and Pietrzak raised
$3,452,823 and $1,296,720, respectively); and their flagrant violative conduct suggests
likelihood of recurrence. Moreover, Furlong is a recidivist who was previously enjoined
by the SEC in 1988 and was subjected to cease-and-desist orders by 2 states in 1977 and
2 states in 1994. Bars are needed to prevent Furlong and Pietrzak from ever acting as

officers and directors of a public company in the future.

5. Penny Stock Bars Against Furlong And Pietrzak

Federal courts possess broad equitable powers to impose ancillary relief upon
individuals who violate the federal securities laws. SEC v. Manor Nursing Centers, Inc.,
458 F.2d 1082, 1103 (2d Cir. 1972) (“Once the equity jurisdiction of the district court has
been properly invoked by a showing of a securities law violation, the court possesses the
necessary power to fashion an appropriate remedy.”) Therefore, this Court should use its
equitable powers to impose penny stock bars against Furlong and Pietrzak, thereby doing
substantial justice for the benefit of defrauded investors. In SEC v. Posner, 16 F.3d 520
(2d Cir. 1994), the 2d Circuit upheld a district court’s order that imposed O&D bars on
the defendants even though the conduct occurred before the Securities Enforcement
Remedies and Penny Stock Reform Act of 1990, Pub. L. No. 101-429, 104 Stat. 931
(“Remedies Act”), added O&D bars to the available statutory remedies in securities laws.
Rather than decide whether the Remedies Act applied retroactively, the 2d Cir. upheld
the district court because it had used its equitable powers as an alternate basis for

imposing the bar. Id. at 521. Similarly, this court should impose penny stock bars on

14


Page 1 of 2

US. Securities and Exchange Commission

Division of Enforcement

Prejudgment Interest Report

Furlong - April 1997 sales of HCCA stock

Quarter Range Annual Rate Period Rate Quarter Interest Principal+ Interest
Violation Amount $83,866.00
05/01/1997-06/30/1997 9% 15% $1,257.99 $85,123.99
07/01/1997-09/30/1997 9% 2.25% $1,915.29. $87,039.28
10/01/1997-12/31/1997 9% 2.25% $1,958.38 $88,997.66
01/01/1998-03/31/1998 9% 2.25% $2,002.45 $91,000.11
04/01/1998-06/30/1998 8% 2% $1,820.00 $92,820.11
07/01/1998-09/30/1998 8% 2% $1,856.40 $94,676.51
10/01/1998-12/31/1998 8% 2% $1,893.53 $96,570.04
01/01/1999-03/31/1999 T% 1.75% $1,689.98 $98,260.02
04/01/1999-06/30/1999 8% 2% $1,965.20 $100,225.22
07/01/1999-09/30/1999 8% 2% $2,004.50 $102,229.72
10/01/1999-12/3 1/1999 8% 2% $2,044.59 $104,274.31
01/01/2000-03/31/2000 8% 2% $2,085.49 $106,359.80
04/01/2000-06/30/2000 9% 2.25% $2,393.10 $108,752.90
07/01/2000-09/30/2000 9% 2.25% $2,446.94 $111,199.84
10/01/2000-12/31/2000 9% 2.25% $2,502.00 $113,701.84
01/01/2001-03/31/2001 9% 2.25% $2,558.29 $116,260.13
04/01/2001-06/30/2001 8% 2% $2,325.20 $118,585.33
07/01/2001-09/30/2001 - TM% 1.75% $2,075.24 $120,660.57
10/01/2001-12/31/2001 T% 1.75% $2,111.56 $122,772.13
01/01/2002-03/3 1/2002 6% 1.5% $1,841.58 $124,613.71
04/01/2002-06/30/2002 6% 1.5% $1,869.21 $126,482.92
07/01/2002-09/30/2002 6% 1.5% $1,897.24 $128,380.16
10/01/2002-12/3 1/2002 6% 1.5% $1,925.70 $130,305.86
01/01/2003-03/3 1/2003 5% 1.25% $1,628.82 $131,934.68
04/01/2003-06/30/2003 5% 1.25% $1,649.18 $133,583.86
07/01/2003-09/30/2003 5% 1.25% $1,669.80 $135,253.66
10/01/2003-12/3 1/2003 4% 1% $1,352.54 $136,606.20
01/01/2004-03/3 1/2004 4% 1% $1,366.06 $137,972.26
04/01/2004-06/30/2004 5% 1.25% $1,724.65 $139,696.91
07/01/2004-09/30/2004 4% 1% $1,396.97 $141,093.88
10/01/2004-12/3 1/2004 5% 1.25% $1,763.67 $142,857.55
01/01/2005-03/3 1/2005 5% 1.25% $1,785.72 $144,643.27
04/01/2005-06/30/2005 6% 15% $2,169.65 $146,812.92
07/01/2005-09/30/2005 6% 15% $2,202.19 $149,015.11
10/01/2005-12/3 1/2005 T% 1.75% $2,607.76 $151,622.87
01/01/2006-03/3 1/2006 T% 1.75% $2,653.40 $154,276.27
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Furlong - January 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+ Interest
Violation Amount $25,900.00
02/01/1999-03/31/1999 T% 1.17% $302.17 $26,202.17
04/01/1999-06/30/1999 8% 2% $524.04 $26,726.21
07/01/1999-09/30/1999 8% 2% $534.52 $27,260.73
10/01/1999-12/3 1/1999 8% 2% $545.21 $27,805.94
01/01/2000-03/3 1/2000 8% 2% $556.12 $28,362.06
04/01/2000-06/30/2000 9% 2.25% $638.15 $29,000.21
07/01/2000-09/30/2000 9% 2.25% $652.50 $29,652.71
10/01/2000-12/3 1/2000 9% 2.25% $667.19 $30,319.90
01/01/2001-03/31/2001 9% 2.25% $682.20 $31,002.10
04/01/2001-06/30/2001 8% 2% $620.04 $31,622.14
07/01/2001-09/30/2001 T% 1.75% $553.39 $32,175.53
10/01/2001-12/31/2001 T% 1.75% $563.07 $32,738.60
01/01/2002-03/3 1/2002 6% 1.5% $491.08 $33,229.68
04/01/2002-06/30/2002 6% 1.5% $498.45 $33,728.13
07/01/2002-09/30/2002 6% 15% $505.92 $34,234.05
10/01/2002-12/3 1/2002 6% 1.5% $513.51 $34,747.56
01/01/2003-03/3 1/2003 5% 1.25% $434.34 $35,181.90
04/01/2003-06/30/2003 5% 1.25% $439.77 $35,621.67
07/01/2003-09/30/2003 5% 1.25% $445.27 $36,066.94
10/01/2003-12/31/2003 4% 1% $360.67 $36,427.61
01/01/2004-03/3 1/2004 4% 1% $364.28 $36,791.89
04/01/2004-06/30/2004 5% 1.25% $459.90 $37,251.79
07/01/2004-09/30/2004 4% 1% $372.52 $37,624.31
10/01/2004-12/31/2004 5% 1.25% $470.30 $38,094.61
01/01/2005-03/31/2005 5% 1.25% $476.18 $38,570.79
04/01/2005-06/30/2005 6% 1.5% $578.56 $39,149.35
07/01/2005-09/30/2005 6% 1.5% $587.24 $39,736.59
10/01/2005-12/3 1/2005 T% 1.75% $695.39 $40,431.98
01/01/2006-03/3 1/2006 TM% 1.75% $707.56 $41,139.54
04/01/2006-06/30/2006 TMM 1.75% $719.94 $41,859.48
07/01/2006-09/30/2006 8% 2% $837.19 $42,696.67
10/01/2006-12/3 1/2006 8% 2% $853.93 $43,550.60
01/01/2007-03/3 1/2007 8% 2% $871.01 $44,421.61
04/0 1/2007-06/30/2007 8% 2% $888.43 $45,310.04
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong and Pietrzak using its own equitable powers.'° A person participating inan
offering of penny stock includes one who engages “in activities with a[n] . . . issuer for
purposes of the issuing, trading, or inducing or attempting to induce the purchase or sale of,
any penny stock.” §20(g)(2) of the Securities Act and §21(d)(6)(B) of the Exchange Act.

Furlong and Pietrzak violated §17(a) of the Securities Act and §§10(b) and 13(b)(5)
of the Exchange Act and Rules 10b-5 and 13b2-1 thereunder and aided and abetted
violations of §§13(a), 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act and Rules 12b-20,
13a-1, 13a-11 and 13a-13 thereunder by, inter alia, filing several false and misleading
reports and registration statements from 1996 through 1999, publishing false and misleading
press releases and a letter to shareholders, and fraudulently selling their HCCA stock.

During those years, HCCA stock was a penny stock, because its price was less than $5, its
net tangible assets were negligible, and it had no revenues. See §3(a)(51)(A) of the
Exchange Act and Rule 3a51-1(g). As officers of HCCA, Furlong and Pietrzak conducted a
registration of HCCA’s stock on Form 10-SB and issued periodic reports, press releases and
a letter to shareholders, thereby engaging in activities with HCCA for purposes of trading of
its stock, or inducing or attempting to induce the purchase or sale of its stock. Therefore, the
defendants’ violations occurred while they were participating in an offering of penny stock.
See In re Charles D. Ledford, Securities Exchange Act Release No. 41941 (September 29,
1999), 1999 SEC LEXIS 2029 (corporate officer barred for involvement in issuer’s false
and misleading press releases); In re Lynn K. Ross, Securities Exchange Act Release No.
39041 (September 10, 1997), 65 S.E.C. Docket 0987 (Oct. 7, 1997) (corporate officer barred
for involvement in issuer’s false and misleading periodic reports and book and records).
Il. CONCLUSION

This motion follows a jury verdict in favor of the SEC on all of its claims. The
relief now sought, is precisely the relief prayed for in the SEC’s 2/28/2003 Complaint. A
proposed Final Judgment is submitted herewith for the Court’s consideration.

10 Section 603 of the Sarbanes-Oxley Act amended §20 of the Securities Act and §21(d) of the
Exchange Act to provide federal courts with statutory authority to bar an individual from
participating in an offering of penny stock. The SEC seeks penny stock bars against Furlong and
Pietrzak even though their conduct took place prior to the enactment of the Sarbanes-Oxley Act.

15


Furlong - March 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $9,600.00
04/01/1999-06/30/1999 8% 2% $192.00 $9,792.00
07/01/1999-09/30/1999 8% 2% $195.84 $9,987.84
10/01/1999-12/3 1/1999 8% 2% $199.76 $10,187.60
01/01/2000-03/3 1/2000 8% 2% $203.75 $10,391.35
04/01/2000-06/30/2000 9% 2.25% $233.81 $10,625.16
07/01/2000-09/30/2000 9% 2.25% $239.07 $10,864.23
10/01/2000-12/3 1/2000 9% 2.25% $244.45 $11,108.68
01/01/2001-03/3 1/2001 9% 2.25% $249.95 $11,358.63
04/01/2001-06/30/2001 8% 2% $227.17 $11,585.80
07/01/2001-09/30/2001 TMM% 1.75% $202.75 $11,788.55
10/01/2001-12/31/2001 % 1.75% $206.30 $11,994.85
01/01/2002-03/3 1/2002 6% 1.5% $179.92 $12,174.77
, 04/01/2002-06/30/2002 6% 1.5% $182.62 $12,357.39
07/01/2002-09/30/2002 6% 1.5% $185.36 $12,542.75
10/01/2002-12/3 1/2002 6% 1.5% $188.14 $12,730.89
01/01/2003-03/3 1/2003 5% 1.25% $159.14 $12,890.03
04/01/2003-06/30/2003 5% 1.25% $161.13 $13,051.16
07/01/2003-09/30/2003 5% 1.25% $163.14 $13,214.30
10/01/2003-12/3 1/2003 4% 1% $132.14 $13,346.44
01/01/2004-03/3 1/2004 4% 1% $133.46 $13,479.90
04/01/2004-06/30/2004 5% 1.25% $168.50 $13,648.40
07/01/2004-09/30/2004 4% 1% $136.48 $13,784.88
10/01/2004- 12/31/2004 5% 1.25% $172.31 $13,957.19
01/01/2005-03/31/2005 5% 1.25% $174.46 $14,131.65
04/01/2005-06/30/2005 6% 1.5% $211.97 $14,343.62
07/01/2005-09/30/2005 6% 1.5% $215.15 $14,558.77
10/01/2005- 12/31/2005 TMM 1.75% $254.78 $14,813.55
01/01/2006-03/31/2006 T% 1.75% $259.24 $15,072.79
04/01/2006-06/30/2006 T% 1.75% $263.77 $15,336.56
07/01/2006-09/30/2006 8% 2% $306.73 $15,643.29
10/01/2006-12/3 1/2006 8% 2% $312.87 $15,956.16
01/01/2007-03/3 1/2007 8% 2% $319.12 $16,275.28
04/01/2007-06/30/2007 8% 2% $325.51 $16,600.79
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
04/01/1999-06/30/2007 $7,000.79 $16,600.79
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):

Payoff Date (mm/dd/yyyy): [ova 6/2007,

Header for Réport [Optional - 80 Chars Max],Furlong - May 1999 sales of HCCA stock

Click here for the PJIC FAQ

Click here for orandum describing the method for ¢: lating interest

http://enforcenet/PJIC%20Web/Data_Entry.html

6/12/2007


Furlong - December 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 1

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $53,446.00
01/01/2000-03/31/2000 8% 2% $1,068.92 $54,514.92
04/01/2000-06/30/2000 9% 2.25% $1,226.59 $55,741.51
07/01/2000-09/30/2000 9% 2.25% $1,254.18 $56,995.69
10/01/2000- 12/31/2000 9% 2.25% $1,282.40 $58,278.09
01/01/2001-03/31/2001 9% 2.25% $1,311.26 $59,589.35
04/01/2001-06/30/2001 8% 2% $1,191.79 $60,781.14
07/01/2001-09/30/2001 T% 1.75% $1,063.67 $61,844.81
10/01/2001-12/3 1/2001 T% 1.75% $1,082.28 $62,927.09
01/01/2002-03/3 1/2002 6% 15% $943.91 $63,871.00
04/01/2002-06/30/2002 6% 1.5% $958.07 $64,829.07
07/01/2002-09/30/2002 6% 1.5% $972.44 $65,801.51
10/01/2002-12/3 1/2002 6% 1.5% $987.02 $66,788.53
01/01/2003-03/3 1/2003 5% 1.25% $834.86 $67,623.39
04/01/2003-06/30/2003 5% 1.25% $845.29 $68,468.68
07/01/2003-09/30/2003 5% 1.25% $855.86 $69,324.54
10/01/2003-12/3 1/2003 4% 1% $693.25 $70,017.79
01/01/2004-03/3 1/2004 4% 1% $700.18 $70,717.97
04/01/2004-06/30/2004 5% 1.25% $883.97 $71,601.94
07/01/2004-09/30/2004 4% 1% $716.02 $72,317.96
10/01/2004-12/3 1/2004 5% 1.25% $903.97 $73,221.93
01/01/2005-03/3 1/2005 5% 1.25% $915.27 $74,137.20
04/01/2005-06/30/2005 6% 15% $1,112.06 $75,249.26
07/01/2005-09/30/2005 6% 1.5% $1,128.74 $76,378.00
10/01/2005-12/3 1/2005 T% 1.75% $1,336.62 $77,714.62
01/01/2006-03/3 1/2006 TM% 1.75% $1,360.01 $79,074.63
04/01/2006-06/30/2006 % 1.75% $1,383.81 $80,458.44
07/01/2006-09/30/2006 8% 2% $1,609.17 $82,067.61
10/01/2006-12/3 1/2006 8% 2% $1,641.35 $83,708.96
01/01/2007-03/3 1/2007 8% 2% $1,674.18 $85,383.14
04/01/2007-06/30/2007 8% 2% $1,707.66 $87,090.80
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
01/01/2000-06/30/2007 $33,644.80 $87,090.80
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): ova 6/2007

Header for Report [Optional - 80 Chars Max];[Furlong - May 1998 sales of HCCA stock

Click here for the PJIC FA
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement

Prejudgment Interest Calculator
Interest Rates Through 6/30/2007

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): jova 6/2007

Header for Report [Optional - 80 Chars Max];[Furlong - July 1998 sales of HCCA stock

Click here for the PIIC FAQ

Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


AMOUNTS TO BE DISGORGED PLUS PREJUDGMENT INTEREST OWED BY
EACH DEFENDANT, FOR MISCONDUCT DURING THE RELEVANT PERIOD

Amount of Prejudgment.
Defendant § Disgorgement Interest TOTAL
Furlong $ 3,452,491 $ 2,515,724 $ 5,968,215
Pietrzak $ 1,296,720 $ 836,866 $ 2,133,586
Jordan $191,400 $116,529 $307,929
$ 4,940,611 $ 3,469,119 $ 8,409,730



Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy): 04/30/1999
Payoff Date (mm/dd/yyyy): Joma 6/2007

Header for Report [Optional - 80 Chars Max];[Furlong - April 1999 sales of HCCA stock

Click here for the PIC FAQ

Click here for the memorandum describing th: d for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html

6/12/2007


Page 2 of 2

01/01/2006-03/3 1/2006 T% 1.75% $2,185.44 $127,067.44
04/01/2006-06/30/2006 TMM% 1.75% $2,223.68 $129,291.12
07/01/2006-09/30/2006 8% 2% $2,585.82 $131,876.94
10/01/2006-12/3 1/2006 8% 2% $2,637.54 $134,514.48
01/01/2007-03/31/2007 8% 2% $2,690.29 $137,204.77
04/01/2007-06/30/2007 8% 2% $2,744.10 $139,948.87
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
02/01/1997-06/30/2007 $72,393.87 $139,948.87
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - November 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $37,375.00
12/01/1997-12/31/1997 9% 0.75% $280.31 $37,655.31
01/01/1998-03/31/1998 9% 2.25% $847.24 $38,502.55
04/01/1998-06/30/1998 8% 2% $770.05 $39,272.60
07/01/1998-09/30/1998 8% 2% $785.45 $40,058.05
10/01/1998-12/3 1/1998 8% 2% $801.16 $40,859.21
01/01/1999-03/3 1/1999 T% 1.75% $715.04 $41,574.25
04/01/1999-06/30/1999 8% 2% $831.49 $42,405.74
07/01/1999-09/30/1999 8% 2% $848.11 $43,253.85
10/01/1999-12/31/1999 8% 2% $865.08 $44,118.93
01/01/2000-03/3 1/2000 8% 2% $882.38 $45,001.31
04/01/2000-06/30/2000 % 2.25% $1,012.53 $46,013.84
07/01/2000-09/30/2000 % 2.25% _ $1,035.31 $47,049.15
10/01/2000-12/3 1/2000 9% 2.25% $1,058.61 $48,107.76
01/01/2001-03/3 1/2001 % 2.25% $1,082.42 $49,190.18
04/01/2001-06/30/2001 8% 2% $983.80 $50,173.98
07/01/2001-09/30/2001 T% 1.75% $878.04 $51,052.02
10/01/2001-12/3 1/2001 T% 1.75% $893.41 $51,945.43
01/01/2002-03/3 1/2002 6% 1.5% $779.18 $52,724.61
04/01/2002-06/30/2002 6% 15% $790.87 $53,515.48
07/01/2002-09/30/2002 6% 1.5% $802.73 $54,318.21
10/01/2002-12/3 1/2002 6% 1.5% $814.77 $55,132.98
01/01/2003-03/3 1/2003 5% 1.25% $689.16 $55,822.14
04/01/2003-06/30/2003 5% 1.25% $697.78 $56,519.92
07/01/2003-09/30/2003 5% 1.25% $706.50 $57,226.42
10/01/2003-12/3 1/2003 4% 1% $572.26 $57,798.68
01/01/2004-03/3 1/2004 4% 1% $577.99 $58,376.67
04/01/2004-06/30/2004 5% 1.25% $729.71 $59,106.38
07/01/2004-09/30/2004 4% 1% $591.06 $59,697.44
10/01/2004-12/31/2004 5% 1.25% $746.22 $60,443.66
01/01/2005-03/3 1/2005 5% 1.25% $755.55 $61,199.21
04/01/2005-06/30/2005 6% 1.5% $917.99 $62,117.20
07/01/2005-09/30/2005 6% 15% $931.76 $63,048.96
10/01/2005-12/3 1/2005 TMM% 1.75% $1,103.36 $64,152.32
01/01/2006-03/3 1/2006 TM% 1.75% $1,122.67 $65,274.99
04/01/2006-06/30/2006 T% 1.75% $1,142.31 $66,417.30
07/01/2006-09/30/2006 8% 2% $1,328.35 $67,745.65
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Page 2 of 2

03/01/1999-06/30/2007 $7,282.42 $17,132.42

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Page 2 of 2

04/01/2006-06/30/2006 TTM% 1.75% $264.01 $15,350.10
07/01/2006-09/30/2006 8% 2% $307.00 $15,657.10
10/01/2006- 12/3 1/2006 8% 2% $313.14 $15,970.24
01/01/2007-03/3 1/2007 8% 2% $319.40 $16,289.64
04/01/2007-06/30/2007 8% 2% $325.79 $16,615.43
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
06/01/1997-06/30/2007 $8,353.43 $16,615.43
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


PREJUDGMENT INTEREST
CALCULATIONS

FOR DEFENDANT FURLONG



Page 2 of 2

01/01/2007-03/31/2007 8% 2% $3,634.59 $185,363.85
04/01/2007-06/30/2007 8% 2% $3,707.28 $189,071.13
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
03/01/1998-06/30/2007 $88,566.13 $189,071.13
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Prejudgment Interest Calculator Page 1 of 1

Division of Enforcement
Prejudgment Interest Calculator

Interest RatesThrough 6/30/2007

Violation Amount: [5520.00

Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy):

Header for Report [Optional - 80 Chars Max];[Furlong - June 2000 sales of HCCA stock

Click here for the P) iC FAQ

Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - October 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page | of 1

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $20,550.00
11/01/1999-12/3 1/1999 8% 1.33% $274.00 $20,824.00
01/01/2000-03/3 1/2000 8% 2% $416.48 $21,240.48
04/01/2000-06/30/2000 % 2.25% $477.91 $21,718.39
07/01/2000-09/30/2000 % 2.25% $488.66 $22,207.05
10/01/2000-12/3 1/2000 9% 2.25% $499.66 $22,706.71
01/01/2001-03/31/2001 9% 2.25% $510.90 $23,217.61
04/01/2001-06/30/2001 8% 2% $464.35 $23,681.96
07/01/2001-09/30/2001 T% 1.75% $414.43 $24,096.39
10/01/2001-12/31/2001 T% 1.75% $421.69 $24,518.08
01/01/2002-03/3 1/2002 6% 1.5% $367.77 $24,885.85
04/01/2002-06/30/2002 6% 1.5% $373.29 $25,259.14
07/01/2002-09/30/2002 6% 1.5% $378.89 $25,638.03
10/01/2002-12/3 1/2002 6% 1.5% $384.57 $26,022.60
01/01/2003-03/3 1/2003 5% 1.25% $325.28 $26,347.88
04/01/2003-06/30/2003 5% 1.25% $329.35 $26,677.23
07/01/2003-09/30/2003 5% 1.25% $333.47 $27,010.70
10/01/2003-12/3 1/2003 4% 1% $270.11 $27,280.81
01/01/2004-03/3 1/2004 4% 1% $272.81 $27,553.62
04/01/2004-06/30/2004 5% 1.25% $344.42 $27,898.04
07/01/2004-09/30/2004 4% 1% $278.98 $28,177.02
10/01/2004-12/31/2004 5% 1.25% $352.21 $28,529.23
01/01/2005-03/31/2005 5% 1.25% $356.62 $28,885.85
04/01/2005-06/30/2005 6% 15% $433.29 $29,319.14
07/01/2005-09/30/2005 6% 1.5% $439.79 $29,758.93
10/01/2005-12/3 1/2005 TMM% 1.75% $520.78 $30,279.71
01/01/2006-03/31/2006 Th 1.75% $529.89 $30,809.60
04/01/2006-06/30/2006 TH 1.75% $539.17 $31,348.77
07/01/2006-09/30/2006 8% 2% $626.98 $31,975.75
10/01/2006-12/3 1/2006 8% 2% $639.52 $32,615.27
01/01/2007-03/3 1/2007 8% 2% $652.31 $33,267.58
04/01/2007-06/30/2007 8% % $665.35 $33,932.93
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
11/01/1999-06/30/2007 $13,382.93 $33,932.93
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007


Furlong - November 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 1

US. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $27,983.00
12/01/1999-12/3 1/1999 8% 0.67% $186.55 $28,169.55
01/01/2000-03/3 1/2000 8% 2% $563.39 $28,732.94
04/01/2000-06/30/2000 % 2.25% $646.49 $29,379.43
07/01/2000-09/30/2000 % 2.25% $661.04 $30,040.47
10/01/2000-12/3 1/2000 % 2.25% $675.91 $30,716.38
01/01/2001-03/31/2001 9% 2.25% $691.12 $31,407.50
04/01/2001-06/30/2001 8% 2% $628.15 $32,035.65
07/01/2001-09/30/2001 % 1.75% $560.62 $32,596.27
10/01/2001-12/31/2001 TMH 1.75% $570.43 $33,166.70
01/01/2002-03/3 1/2002 6% 15% $497.50 $33,664.20
04/01/2002-06/30/2002 6% 1.5% $504.96 $34,169.16
07/01/2002-09/30/2002 6% 1.5% $512.54 $34,681.70
10/01/2002-12/3 1/2002 6% 1.5% $520.23 $35,201.93
01/01/2003-03/3 1/2003 5% 1.25% $440.02 $35,641.95
04/01/2003-06/30/2003 5% 1.25% $445.52 $36,087.47
07/01/2003-09/30/2003 5% 1.25% $451.09 $36,538.56
10/01/2003-12/3 1/2003 4% 1% $365.39 $36,903.95
01/01/2004-03/3 1/2004 4% 1% $369.04 $37,272.99
04/01/2004-06/30/2004 5% 1.25% $465.91 $37,738.90
07/01/2004-09/30/2004 4% 1% $377.39 $38,116.29
10/01/2004-12/3 1/2004 5% 1.25% $476.45 $38,592.74
01/01/2005-03/3 1/2005 5% 1.25% $482.41 $39,075.15
04/01/2005-06/30/2005 6% 15% $586.13 $39,661.28
07/01/2005-09/30/2005 6% 1.5% $594.92 $40,256.20
10/01/2005-12/31/2005 % “1.75% $704.48 $40,960.68
01/01/2006-03/3 1/2006 T% 1.75% $716.81 $41,677.49
04/01/2006-06/30/2006 T% 1.75% $729.36 $42,406.85
07/01/2006-09/30/2006 8% 2% $848.14 $43,254.99
10/01/2006-12/3 1/2006 8% 2% $865.10 $44,120.09
01/01/2007-03/3 1/2007 8% 2% $882.40 $45,002:49
04/01/2007-06/30/2007 8% 2% $900.05 $45,902.54
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
12/01/1999-06/30/2007 $17,919.54 $45,902.54
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


blatantly fraudulent scheme over a period of more than 3 years. They used their authority as
officers/directors of a public company as swords for their own enrichment, and both are still

relatively young. All relevant factors weigh in favor of injunctive relief.

2. Disgorgement And Prejudgment Interest

Given the Court’s comments following the jury verdict in this matter, it may help
to review to the equity based principle of disgorgement. The broad powers of the federal
courts have been applied in the context of actions brought by the SEC to prevent
securities laws violators from enjoying the fruits of their misconduct. See SEC v.
Comcoa Ltd., Inc., 887 F. Supp. 1521, 1524 (11th Cir. 1995); see also, SEC v. Tome, 638
F. Supp. 638 (S.D.N.Y. 1986), aff'd, 883 F.2d 1086 (2d Cir. 1987), cert. denied, 486 U.S.
1014 (1988); SEC v. Manor Nursing Centers, Inc., 458 F.2d 1082, 1104 (2d Cir. 1972).

Furlong and Pietrzak sold their HCCA stock after making fraudulent misrepresentations
and omissions to investors in HCCA’s filings, press releases, and/or the letter to
shareholders. As proved at trial, Furlong and Pietrzak raised $3,452,491 and $1,296,720,
respectively from the sales of their HCCA stock during the period the fraud was ongoing.
The SEC seeks disgorgement of their ill-gotten gains. Once a district court has found
federal securities laws violations,’ it has broad equitable power to fashion appropriate
remedies, including ordering culpable defendants to disgorge their profits. SEC v. First
Jersey Securities, Inc., 101 F.3d 1450, 1474 (2d Cir. 1996); SEC v. Lorin, 76 F.3d 458,
461-62 (2d Cir. 1996); SEC v. Patel, 61 F.3d 137, 139 (2d Cir. 1995); SEC v. Manor
Nursing Centers, Inc., 458 F.2d 1082, 1104 (2d Cir. 1972). The primary purpose of
disgorgement as a remedy for violation of the securities laws is to deprive violators of
their ill-gotten gains, thereby effectuating the deterrence objectives of those laws. SEC v.
First Jersey Securities, Inc., 101 F.3d at 1474; SEC v. Wang, 944 F.2d 80, 85 (2d Cir.
1991); SEC v. Commonwealth Chemical Securities, Inc., 574 F.2d 90, 102 (2d Cir.

1978). Furthermore, as set forth in the Manor Nursing Centers, Inc. decision:

The effective enforcement of the federal securities laws requires that the
SEC be able to make violations unprofitable. The deterrent effect of an

3 By virtue of the jury verdict in favor of the SEC, Furlong and Pietrzak have been found to have
engaged in securities laws violations.


Prejudgment Interest Calculator

Division of Enforcement

Prejudgment Interest Calculator
Interest RatesThrough 6/30/2007

Page 1 of 1

Violation Amount:
Violation Start Date (mm/dd/yyyy):
Payoff Date (mm/dd/yyyy): [ow 6/2007,

Header for Report [Optional - 80 Chars Max];[Furlong - February 1999 sales of HCCA stock

Click here for the PJIC FAQ
Click here for the memorandum describing the method for calculating interest

http://enforcenet/PJIC%20Web/Data_Entry html

6/12/2007


Furlong - July 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $61,289.00
08/01/1997-09/30/1997 9% 1.5% $919.33 $62,208.34
10/01/1997-12/3 1/1997 9% 2.25% $1,399.69 $63,608.03
01/01/1998-03/3 1/1998 9% 2.25% $1,431.18 $65,039.21
04/01/1998-06/30/1998 8% 2% $1,300.78 $66,339.99
07/01/1998-09/30/1998 8% 2% $1,326.80 $67,666.79
10/01/1998-12/31/1998 8% 2% $1,353.34 $69,020.13
01/01/1999-03/3 1/1999 T% 1.75% ° $1,207.85 $70,227.98
04/01/1999-06/30/1999 8% 2% $1,404.56 $71,632.54
07/01/1999-09/30/1999 8% 2% $1,432.65 $73,065.19
10/01/1999-12/31/1999 8% 2% $1,461.30 $74,526.49
01/01/2000-03/31/2000 8% 2% $1,490.53 $76,017.02
04/01/2000-06/30/2000 9% 2.25% $1,710.38 $77,727.40
07/01/2000-09/30/2000 9% 2.25% $1,748.87 $79,476.27
10/01/2000-12/31/2000 9% 2.25% $1,788.22 $81,264.49
01/01/2001-03/31/2001 9% 2.25% $1,828.45 $83,092.94
04/01/2001-06/30/2001 8% 2% $1,661.86 $84,754.80
07/01/2001-09/30/2001 TM% 1.75% $1,483.21 $86,238.01
10/01/2001-12/3 1/2001 TH 1.75% $1,509.17 $87,747.18
01/01/2002-03/31/2002 6% 1.5% $1,316.21 $89,063.39
04/01/2002-06/30/2002 6% 15% $1,335.95 $90,399.34
07/01/2002-09/30/2002 6% 1.5% $1,355.99 $91,755.33
10/01/2002-12/31/2002 6% 1.5% $1,376.33 $93,131.66
01/01/2003-03/3 1/2003 5% 1.25% $1,164.15 $94,295.81
04/01/2003-06/30/2003 5% 1.25% $1,178.70 $95,474.51
07/01/2003-09/30/2003 5% 1.25% $1,193.43 $96,667.94
10/01/2003-12/3 1/2003 A% 1% $966.68 $97,634.62
01/01/2004-03/31/2004 4% 1% $976.35 $98,610.97
04/01/2004-06/30/2004 5% 1.25% $1,232.64 $99,843.61
07/01/2004-09/30/2004 4% 1% $998.44 $100,842.05
10/01/2004-12/3 1/2004 5% 1.25% $1,260.53 $102,102.58
01/01/2005-03/31/2005 5% 1.25% $1,276.28 $103,378.86
04/01/2005-06/30/2005 6% 15% $1,550.68 $104,929.54
07/01/2005-09/30/2005 6% 15% $1,573.94 $106,503.48
10/01/2005-12/31/2005 % 1.75% $1,863.81 $108,367.29
* 01/01/2006-03/3 1/2006 TM% 1.75% $1,896.43 $110,263.72
04/01/2006-06/30/2006 T% 1.75% $1,929.62 $112,193.34
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - Mardh 2000 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 1

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $174,200.00
04/01/2000-06/30/2000 9% 2.25% $3,919.50 $178,119.50
07/01/2000-09/30/2000 9% 2.25% $4,007.69 $182,127.19
10/01/2000-12/3 1/2000 % 2.25% $4,097.86 $186,225.05
01/01/2001-03/31/2001 9% 2.25% $4,190.06 $190,415.11
04/01/2001-06/30/2001 8% 2% $3,808.30 $194,223.41
07/01/2001-09/30/2001 TMH 1.75% $3,398.91 $197,622.32
10/01/2001-12/31/2001 TMM% 1.75% $3,458.39 $201,080.71
01/01/2002-03/3 1/2002 6% 15% $3,016.21 $204,096.92
04/01/2002-06/30/2002 6% 1.5% $3,061.45 $207,158.37
07/01/2002-09/30/2002 6% 15% $3,107.38 $210,265.75
10/01/2002-12/31/2002 6% 1.5% $3,153.99 $213,419.74
01/01/2003-03/3 1/2003 5% 1.25% $2,667.75 $216,087.49
_ 04/01/2003-06/30/2003 5% 1.25% $2,701.09 $218,788.58
07/01/2003-09/30/2003 5% 1.25% $2,734.86 $221,523.44
10/01/2003-12/3 1/2003 4% 1% $2,215.23 $223,738.67
01/01/2004-03/3 1/2004 4% 1% $2,237.39 $225,976.06
04/01/2004-06/30/2004 5% 1.25% $2,824.70 $228,800.76
07/01/2004-09/30/2004 4% 1% $2,288.01 $231,088.77
10/01/2004-12/31/2004 5% 1.25% $2,888.61 $233,977.38
01/01/2005-03/3 1/2005 5% 1.25% $2,924.72 $236,902.10
04/01/2005-06/30/2005 6% 1.5% $3,553.53 $240,455.63
07/01/2005-09/30/2005 6% 1.5% $3,606.83 $244,062.46
10/01/2005-12/3 1/2005 T% 1.75% $4,271.09 $248,333.55
01/01/2006-03/31/2006 TM% 1.75% $4,345.84 $252,679.39
04/01/2006-06/30/2006 T% 1.75% $4,421.89 $257,101.28
07/01/2006-09/30/2006 8% 2% $5,142.03 $262,243.31
10/01/2006-12/3 1/2006 8% 2% $5,244.87 $267,488.18
01/01/2007-03/3 1/2007 8% 2% $5,349.76 $272,837.94
04/01/2007-06/30/2007 8% 2% $5,456.76 $278,294.70
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
04/01/2000-06/30/2007 $104,094.70 $278,294.70
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - April 1999 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

USS. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $16,575.00
05/01/1999-06/30/1999 8% 1.33% $221.00 $16,796.00
07/01/1999-09/30/1999 8% 2% $335.92 $17,131.92
10/01/1999-12/3 1/1999 8% 2% $342.64 $17,474.56
01/01/2000-03/3 1/2000 8% 2% $349.49 $17,824.05
04/01/2000-06/30/2000 9% 2.25% $401.04 $18,225.09
07/01/2000-09/30/2000 9% 2.25% $410.06 $18,635.15
10/01/2000-12/3 1/2000 9% 2.25% $419.29 $19,054.44
01/01/2001-03/3 1/2001 9% 2.25% $428.72 $19,483.16
04/01/2001-06/30/2001 8% 2% $389.66 $19,872.82
07/01/2001-09/30/2001 T% 1.75% $347.77 $20,220.59
10/01/2001-12/3 1/2001 T% 1.75% $353.86 $20,574.45
01/01/2002-03/3 1/2002 6% 1.5% $308.62 $20,883.07
04/01/2002-06/30/2002 6% 1.5% $313.25 $21,196.32
07/01/2002-09/30/2002 6% 1.5% $317.94 $21,514.26
10/01/2002-12/3 1/2002 6% 1.5% $322.71 $21,836.97
01/01/2003-03/3 1/2003 5% 1.25% $272.96 $22,109.93
04/01/2003-06/30/2003 5% 1.25% $276.37 $22,386.30
07/01/2003-09/30/2003 5% 1.25% $279.83 $22,666.13
10/01/2003-12/3 1/2003 4% 1% $226.66 $22,892.79
01/01/2004-03/3 1/2004 4% 1% $228.93 $23,121.72
04/01/2004-06/30/2004 5% 1.25% $289.02 $23,410.74
07/01/2004-09/30/2004 4% 1% $234.11 $23,644.85
10/01/2004-12/3 1/2004 5% 1.25% $295.56 $23,940.41
01/01/2005-03/3 1/2005 5% 1.25% $299.26 $24,239.67
04/01/2005-06/30/2005 6% 1.5% $363.60 $24,603.27
07/01/2005-09/30/2005 6% 1.5% $369.05 $24,972.32
10/01/2005-12/3 1/2005 T% 1.75% $437.02 $25,409.34
01/01/2006-03/3 1/2006 T% 1.75% $444.66 $25,854.00
04/01/2006-06/30/2006 TM% 1.75% $452.45 $26,306.45
07/01/2006-09/30/2006 8% 2% $526.13 $26,832.58
10/01/2006-12/3 1/2006 8% 2% $536.65 $27,369.23
01/01/2007-03/31/2007 8% 2% $547.38 $27,916.61
04/01/2007-06/30/2007 8% 2% $558.33 $28,474.94
Prejudgment Violation Range Quarter Interest Total Prejudgment Total
05/01/1999-06/30/2007 $11,899.94 $28,474.94
http://enforcenet/PJIC%20Web/Data_Entry.html 6/12/2007


Furlong - August 1997 sales of HCCA stock

Division of Enforcement

Prejudgment Interest Report

Page 1 of 2

U.S. Securities and Exchange Commission

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest
Violation Amount $88,666.00
09/01/1997-09/30/1997 9% 0.75% $665.00 $89,331.00
10/01/1997-12/3 1/1997 9% 2.25% $2,009.95 $91,340.95
01/01/1998-03/3 1/1998 9% 2.25% $2,055.17 $93,396.12
04/01/1998-06/30/1998 8% 2% $1,867.92 $95,264.04
07/01/1998-09/30/1998 8% 2% $1,905.28 $97,169.32
10/01/1998-12/31/1998 8% 2% $1,943.39 $99,112.71
01/01/1999-03/3 1/1999 Th 1.75% $1,734.47 $100,847.18
04/01/1999-06/30/1999 8% 2% $2,016.94 $102,864.12
07/01/1999-09/30/1999 8% 2% $2,057.28 $104,921.40
10/01/1999-12/3 1/1999 8% 2% $2,098.43 $107,019.83
01/01/2000-03/31/2000 8% 2% $2,140.40 $109,160.23
04/01/2000-06/30/2000 9% 2.25% $2,456.11 $111,616.34
07/01/2000-09/30/2000 9% 2.25% $2,511.37 $114,127.71
10/01/2000-12/3 1/2000 9% 2.25% $2,567.87 $116,695.58
01/01/2001-03/3 1/2001 9% 2.25% $2,625.65 $119,321.23
04/01/2001-06/30/2001 8% 2% $2,386.42 $121,707.65
07/01/2001-09/30/2001 T% 1.75% $2,129.88 $123,837.53
10/01/2001-12/3 1/2001 Mm 1.75% $2,167.16 $126,004.69
01/01/2002-03/3 1/2002 6% 1.5% $1,890.07 $127,894.76
04/01/2002-06/30/2002 6% 15% $1,918.42 $129,813.18
07/01/2002-09/30/2002 6% 1.5% $1,947.20 $131,760.38
10/01/2002-12/3 1/2002 6% 1.5% $1,976.41 $133,736.79
01/01/2003-03/3 1/2003 5% 1.25% $1,671.71 $135,408.50
04/01/2003-06/30/2003 5% 1.25% $1,692.61 $137,101.11
07/01/2003-09/30/2003 5% 1.25% $1,713.76 $138,814.87
10/01/2003-12/3 1/2003 4% 1% $1,388.15 $140,203.02
01/01/2004-03/3 1/2004 A% 1% $1,402.03 $141,605.05
04/01/2004-06/30/2004 5% 1.25% $1,770.06 $143,375.11
07/01/2004-09/30/2004 4% 1% $1,433.75 $144,808.86
10/01/2004-12/3 1/2004 5% 1.25% $1,810.11 $146,618.97
01/01/2005-03/3 1/2005 5% 1.25% $1,832.74 $148,451.71
04/01/2005-06/30/2005 6% 1.5% $2,226.78 $150,678.49
07/01/2005-09/30/2005 6% 1.5% $2,260.18 $152,938.67
10/01/2005-12/3 1/2005 Th 1.75% $2,676.43 $155,615.10
01/01/2006-03/3 1/2006 TM% 1.75% $2,723.26 $158,338.36
04/01/2006-06/30/2006 T% 1.75% $2,770.92 $161,109.28
http://enforcenet/PJIC%20Web/Data_Entry html 6/12/2007