UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA

COMMODITY FUTURES TRADING 

COMMISSION,

Plaintiff,

v. 

THE ALISTA GROUP, LLC, MARVIN W. 

COURSON III, CHRISTOPHER A. 

KERTATOS, AND LUIS M. PINEDA 

PALACIOS, a/k/a LUIS PINEDA,

Defendants.

 

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Case No. 2:20-cv-00503-JES-NPM

CONSENT ORDER FOR PERMANENT INJUNCTION, RESTITUTION, CIVIL 

MONETARY PENALTY, AND OTHER EQUITABLE RELIEF AGAINST

DEFENDANT CHRISTOPHER A. KERTATOS

I. INTRODUCTION

On July 16, 2020, Plaintiff Commodity Futures Trading Commission (“Commission” or 

“CFTC”) filed a Complaint against Defendants The Alista Group LLC (“Alista”), Marvin W. 

Courson III (“Courson”), Christopher A. Kertatos (“Kertatos”), and Luis M. Pineda Palacios, a/k/a 

Luis Pineda (“Pineda”), seeking injunctive and other equitable relief, as well as the imposition of 

restitution and civil monetary penalties, for violations of the Commodity Exchange Act (“Act”), 

7 U.S.C. §§ 1-26 (2018). 

II. CONSENTS AND AGREEMENTS

To effect settlement of all charges alleged in the Complaint against him without a trial on 

the merits or any further judicial proceedings, Kertatos: 

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1. Consents to the entry of this Consent Order for Permanent Injunction, Restitution, 

Civil Monetary Penalty, and Other Equitable Relief Against Defendant Christopher A. Kertatos 

(“Consent Order”);

2. Affirms that he has read and agreed to this Consent Order voluntarily, and that no 

promise, other than as specifically contained herein, or threat, has been made by the Commission 

or any member, officer, agent or representative thereof, or by any other person, to induce consent 

to this Consent Order; 

3. Acknowledges service of the summons and Complaint; 

4. Admits the jurisdiction of this Court over him and the subject matter of this action 

pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1 (2018), and pursuant to 28 U.S.C. §§ 1331 and 

1345 (2018); 

5. Admits the jurisdiction of the Commission over the conduct and transactions at 

issue in this action pursuant to the Act, 7 U.S.C. §§ 1-26 (2018); 

6. Admits that venue properly lies with this Court pursuant to Section 6c(e) of the Act, 

7 U.S.C. § 13a-1(e) (2018);

7. Waives:

(a) Any and all claims that he may possess under the Equal Access to Justice Act, 

5 U.S.C. § 504 (2018) and 28 U.S.C. § 2412 (2018), and/or the rules promulgated by the 

Commission in conformity therewith, Part 148 of the Regulations, 17 C.F.R. pt. 148 

(2021), relating to, or arising from, this action; 

(b) Any and all claims that he may possess under the Small Business Regulatory 

Enforcement Fairness Act of 1996, Pub. L. No. 104-121, tit. II, §§ 201-253, 110 Stat. 847, 

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857-74 (1996) (codified as amended at 28 U.S.C. § 2412 and in scattered sections of 5 

U.S.C. and 15 U.S.C.), relating to, or arising from, this action; 

(c) Any claim of Double Jeopardy based upon the institution of this action or the entry 

in this action of any order imposing a civil monetary penalty or any other relief, including 

this Consent Order; and 

(d) Any and all rights of appeal from this action; 

8. Consents to the continued jurisdiction of this Court over him for the purpose of 

implementing and enforcing the terms and conditions of this Consent Order and for any other 

purpose relevant to this action, even if Kertatos now or in the future resides outside the jurisdiction 

of this Court; 

9. Agrees that he will not oppose enforcement of this Consent Order on the ground, if 

any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil Procedure and 

hereby waives any objection based thereon; 

10. Agrees that neither he nor any of his agents or employees under his authority or 

control shall take any action or make any public statement denying, directly or indirectly, any 

allegation in the Complaint, or creating or tending to create the impression that the Complaint 

and/or this Consent Order is without a factual basis; provided, however, that nothing in this 

provision shall affect his: (a) testimonial obligations; or (b) right to take legal positions in other 

proceedings to which the Commission is not a party; 

11. Agrees that he shall comply with this Consent Order and shall undertake all steps 

necessary to ensure that all of his agents and/or employees under his authority or control 

understand and comply with this Consent Order; 

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12. Consents to the entry of this Consent Order, without admitting or denying the 

allegations of the Complaint or the Findings of Fact and Conclusions of Law in this Consent Order, 

except as to jurisdiction and venue, which he admits; 

13. Consents to the use of the findings and conclusions in this Consent Order in this 

proceeding and in any other proceeding brought by the Commission or to which the Commission 

is a party or claimant, and agrees that they shall be taken as true and correct and be given preclusive 

effect therein, without further proof;

14. Does not consent, however, to the use of this Consent Order, or the findings and 

conclusions herein, as the sole basis for any other proceeding brought by the Commission or to 

which the Commission is a party, other than a proceeding in bankruptcy or receivership, or a 

proceeding to enforce the terms of this Order; 

15. Agrees to provide immediate notice to this Court and the Commission by certified 

mail, in the manner required by Paragraph 47 of Part VI of this Consent Order, of any bankruptcy 

proceeding filed by, on behalf of, or against him, whether inside or outside the United States; and

16. Agrees that no provision of this Consent Order shall in any way limit or impair the 

ability of any other person or entity to seek any legal or equitable remedy against Kertatos in any 

other proceeding.

III. FINDINGS AND CONCLUSIONS

The Court, being fully advised in the premises, finds that there is good cause for the entry 

of this Consent Order and that there is no just reason for delay. The Court therefore directs the 

entry of the following Findings of Fact, Conclusions of Law, permanent injunction and equitable 

relief pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1 (2018), as set forth herein. The findings 

and conclusions in this Consent Order are not binding on any other party to this action. 

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THE COURT HEREBY FINDS:

A. FINDINGS OF FACT

The Parties to This Consent Order

17. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency that is charged by Congress with administering and enforcing the Act and the 

Regulations. 

18. Defendant Christopher A. Kertatos is an individual who resides in Port St. Lucie, 

Florida. Kertatos has never been registered with the CFTC. 

Defendant Misappropriated Customer Funds 

19. From at least July 2016 through at least January 2018 (the “Relevant Period”), 

Alista, by and through the actions of its employees and agents, including but not limited to, 

Kertatos, offered to enter into, and conducted an office or business in the United States for the 

purpose of soliciting or accepting orders from retail customers for contracts for the purchase or 

sale of precious metals on a leveraged or financed basis (“leveraged precious metals transactions”). 

20. During the Relevant Period, Alista, by and through the actions of its employees and 

agents, including but not limited to, Kertatos, solicited and accepted at least $890,500 from at least 

nineteen customers. Of this amount, $639,500 was sent by customers through checks or wire 

transfers directly to Alista’s bank accounts (“Alista Accounts”). In addition to those customers 

who sent cash to Alista, at least one customer sent Alista numismatic coins as payment for his 

transactions. These coins were sent to Alista with the intention that they would be sold by Alista 

on behalf of the customer and the proceeds of such sale would be used to purchase leveraged 

precious metals for the customer’s account. 

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21. Kertatos was an authorized signatory on several Alista Accounts into which 

customer funds were deposited. During the Relevant Period, Kertatos misappropriated $69,988 

from these accounts through signed cash withdrawal tickets, checks made out to cash, and checks 

made out to himself. None of the money obtained by Kertatos in this manner was used for the 

purchase or storage of precious metals on behalf of Alista’s customers.

22. In addition, Kertatos used individual and/or corporate bank accounts under his 

personal control to accept Alista customer funds and then misappropriated those funds to pay for 

personal and other expenses unrelated to leveraged precious metals transactions on behalf of 

Alista’s customers.

23. Specifically, Kertatos received a total of $79,500 from Alista Accounts into a bank 

account maintained in the name of Sirap Global, Inc. (“Sirap”), a company of which Kertatos was 

the incorporator and President. Of this amount, Kertatos subsequently returned $12,000 to Alista.

The remaining $67,500 was either withdrawn by Kertatos via ATM withdrawals, used by Kertatos 

to pay personal expenses, including payments for travel, hotels, and restaurants, or used to make 

payments to certain Alista employees. None of this money was used for the purchase or storage of 

precious metals on behalf of Alista’s customers.

24. Kertatos also took certain coins which had been sent to Alista by a customer for the 

purpose of purchasing leveraged precious metals and sold them to a coin and jewelry exchange for 

$173,500. Of this amount, Kertatos deposited $120,000 into his personal bank account. Kertatos 

subsequently sent $36,000 of the $120,000 to Alista. The remaining $84,000 was either withdrawn 

by Kertatos via ATM withdrawals or used by Kertatos to pay personal expenses, including 

purchases at restaurants, hotels, airlines, and supermarkets. 

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25. Kertatos deposited $53,500 of the money received from the coin and jewelry 

exchange into his Sirap bank account. Of this amount, Kertatos sent $33,000 to a straw account 

established at a Cayman Islands precious metals dealer in the name of a foreign individual who 

was an acquaintance of Kertatos. This individual was not the individual whose coins had been sold 

by Kertatos, was not a customer of Alista, and had never sent any money to Alista. 

26. The remaining $20,500 of the money deposited into the Sirap bank account was 

either withdrawn by Kertatos via ATM withdrawals, used by Kertatos to pay personal expenses, 

including payments for travel, hotels, and restaurants, or used to make payments to certain Alista 

employees. None of this money was used for the purchase or storage of precious metals on behalf 

of Alista’s customers.

B. CONCLUSIONS OF LAW

Jurisdiction and Venue

27. The Court possesses jurisdiction pursuant to 28 U.S.C. § 1331 (2018) (codifying 

federal question jurisdiction) and 28 U.S.C. § 1345 (2018) (providing that U.S. district courts have 

original jurisdiction over civil actions commenced by the United States or by any agency expressly 

authorized to sue by Act of Congress). The Commission has jurisdiction over the transactions at 

issue in this case pursuant to Section 2(c)(2)(D) of the Act, 7 U.S.C. § 2(c)(2)(D) (2018). 

28. Venue properly lies with this Court pursuant to Section 6c(e) of the Act, 7 U.S.C. 

§ 13a-1(e) (2018), because Kertatos resided in this jurisdiction during the Relevant Period and 

certain transactions, acts, and practices alleged in the Complaint occurred, are occurring, and/or 

are about to occur within this District.

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Violations of Section 4b(a)(2)(A) and (C) of the Act, 7 U.S.C. § 6b(a)(2)(A) 

and (C) (2018) 

29. Section 4b(a)(2)(A) and (C) of the Act, 7 U.S.C. § 6b(a)(2)(A) and (C) (2018) 

provides, in relevant part, that it is unlawful: 

[F]or any person, in or in connection with any order to make, or the making 

of, any contract of sale of any commodity for future delivery, or swap, that 

is made, or to be made, for or on behalf of, or with, any other person, other 

than on or subject to the rules of a designated contract market — 

(A) to cheat or defraud or attempt to cheat or defraud the other person . . . 

or ... 

(C) willfully to deceive or attempt to deceive the other person by any means 

whatsoever in regard to any order or contract or the disposition or execution 

of any order or contract, or in regard to any act of agency performed, with 

respect to any order or contract for or, in the case of paragraph (2), with the 

other person . . . . 

 

30. Pursuant to Section 2(c)(2)(D)(iii) of the Act, 7 U.S.C. § 2(c)(2)(D)(iii) (2018), the 

leveraged precious metals transactions engaged in by Alista are subject to 7 U.S.C. § 6b(a)(2)(A) 

and (C) (2018) as if they are contracts of sale of a commodity for future delivery. 

31. By the conduct described above, Kertatos cheated and defrauded, or attempted to 

cheat and defraud, and willfully deceived, or attempted to deceive, customers by misappropriating 

their funds in connection with leveraged precious metals transactions in violation of 7 U.S.C. § 

6b(a)(2)(A) and (C). 

Need for Injunction

32. Unless restrained and enjoined by this Court, there is a reasonable likelihood that 

Kertatos will continue to engage in the acts and practices alleged in the Complaint and in similar 

acts and practices in violation of the Act. 

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IV. PERMANENT INJUNCTION

IT IS HEREBY ORDERED THAT:

33. Based upon and in connection with the foregoing conduct, pursuant to Section 6c 

of the Act, 7 U.S.C. § 13a-1 (2018), Kertatos is permanently restrained, enjoined, and prohibited 

from, directly or indirectly, in or in connection with any order to make, or the making of, any 

contract of sale of any commodity for future delivery, or swap, that is made, or to be made, for or 

on behalf of, or with, any other person, other than on or subject to the rules of a designated contract 

market: (1) cheating or defrauding or attempting to cheat or defraud the other person; or (2) 

willfully deceiving or attempting to deceive the other person by any means whatsoever in regard 

to any order or contract or the disposition or execution of any order or contract, or in regard to any 

act of agency performed, with respect to any order or contract for or with the other person, in 

violation of Section 4b(a)(2)(A) and (C) of the Act, 7 U.S.C. § 6b(a)(2)(A) and (C) (2018). 

34. Kertatos is also permanently restrained, enjoined, and prohibited from directly or 

indirectly: 

(a) Trading on or subject to the rules of any registered entity (as that term is 

defined in Section 1a(40) of the Act, 7 U.S.C. § 1a(40) (2018));

(b) Entering into any transactions involving “commodity interests” (as that term 

is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2021)), for his own personal account 

or for any account in which he has a direct or indirect interest; 

(c) Having any commodity interests traded on his behalf; 

(d) Controlling or directing the trading for or on behalf of any other person or 

entity, whether by power of attorney or otherwise, in any account involving 

commodity interests;

(e) Soliciting, receiving or accepting any funds from any person for the purpose 

of purchasing or selling any commodity interests; 

(f) Applying for registration or claiming exemption from registration with the 

Commission in any capacity, and engaging in any activity requiring such 

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registration or exemption from registration with the Commission, except as 

provided for in Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2021); and/or 

(g) Acting as a principal (as that term is defined in Regulation 3.1(a), 17 C.F.R. 

§ 3.1(a) (2021)), agent or any other officer or employee of any person (as that term 

is defined in Section 1a(38) of the Act, 7 U.S.C. § 1a(38) (2018)), registered, 

exempted from registration or required to be registered with the Commission except 

as provided for in Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2021). 

V. RESTITUTION AND CIVIL MONETARY PENALTY

A. Restitution

35. Kertatos shall pay restitution in the amount of two hundred seventy-four thousand, 

nine hundred eighty-eight dollars ($274,988) (“Restitution Obligation”), representing the Alista 

customer losses that he caused through misappropriation of Alista customer funds in connection 

with such violations, plus post-judgment interest. If the Restitution Obligation is not paid 

immediately, post-judgment interest shall accrue on the Restitution Obligation beginning on the 

date of entry of this Consent Order and shall be determined by using the Treasury Bill rate 

prevailing on the date of entry of this Consent Order pursuant to 28 U.S.C. § 1961 (2018).

Kertatos’s Restitution Obligation shall be joint and several with the restitution order imposed on 

Alista by this Court’s Opinion and Order of March 2, 2021 (Dkt. #31). 

36. To effect payment of the Restitution Obligation and the distribution of any 

restitution payments to Alista customers by Kertatos, the Court appoints the National Futures 

Association (“NFA”) as Monitor (“Monitor”). The Monitor shall receive restitution payments from 

Kertatos and make distributions as set forth below. Because the Monitor is acting as an officer of 

this Court in performing these services, the NFA shall not be liable for any action or inaction 

arising from NFA’s appointment as Monitor, other than actions involving fraud. 

37. Kertatos shall make Restitution Obligation payments, and any post-judgment 

interest, under this Consent Order to the Monitor in the name “Christopher A. Kertatos Restitution

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Fund” and shall send such Restitution Obligation payments by electronic funds transfer, or by U.S. 

postal money order, certified check, bank cashier’s check, or bank money order, to the Office of 

Administration, National Futures Association, 300 South Riverside Plaza, Suite 1800, Chicago, 

Illinois 60606, under cover letter that identifies the paying Defendant and the name and docket 

number of this proceeding. Kertatos shall simultaneously transmit copies of the cover letter and 

the form of payment to the Chief Financial Officer, Commodity Futures Trading Commission, 

Three Lafayette Centre, 1155 21st Street, NW, Washington, D.C. 20581. 

38. The Monitor shall oversee the Restitution Obligation and shall have the discretion 

to determine the manner of distribution of such funds in an equitable fashion to Alista Customers

identified by the Commission or may defer distribution until such time as the Monitor deems 

appropriate. In the event that the amount of Restitution Obligation payments to the Monitor are of 

a de minimis nature such that the Monitor determines that the administrative cost of making a 

distribution to eligible customers is impractical, the Monitor may, in its discretion, treat such

restitution payments as civil monetary penalty payments, which the Monitor shall forward to the 

Commission following the instructions for civil monetary penalty payments set forth in Part V. B. 

below. 

39. Kertatos shall cooperate with the Monitor as appropriate to provide such 

information as the Monitor deems necessary and appropriate to identify the Alista customers to 

whom the Monitor, in its sole discretion, may determine to include in any plan for distribution of 

any Restitution Obligation payments. Kertatos shall execute any documents necessary to release 

funds that he has in any repository, bank, investment or other financial institution, wherever 

located, in order to make partial or total payment toward the Restitution Obligation. 

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40. The Monitor shall provide the Commission at the beginning of each calendar year 

with a report detailing the disbursement of funds to Alista customers during the previous year. The 

Monitor shall transmit this report under a cover letter that identifies the name and docket number 

of this proceeding to the Chief Financial Officer, Commodity Futures Trading Commission, Three 

Lafayette Centre, 1155 21st Street, NW, Washington, D.C. 20581. 

41. The amounts payable to each Alista customer shall not limit the ability of any Alista 

customer from proving that a greater amount is owed from Kertatos or any other person or entity, 

and nothing herein shall be construed in any way to limit or abridge the rights of any participant 

that exist under state or common law. 

42. Pursuant to Rule 71 of the Federal Rules of Civil Procedure, each Alista customer 

who suffered a loss is explicitly made an intended third-party beneficiary of this Consent Order 

and may seek to enforce obedience of this Consent Order to obtain satisfaction of any portion of 

the restitution that has not been paid by Kertatos to ensure continued compliance with any 

provision of this Consent Order and to hold Kertatos in contempt for any violations of any 

provision of this Consent Order. 

43. To the extent that any funds accrue to the U.S. Treasury for satisfaction of Kertatos’

Restitution Obligation, such funds shall be transferred to the Monitor for disbursement in 

accordance with the procedures set forth above. 

B. Civil Monetary Penalty 

44. Kertatos shall pay a civil monetary penalty in the amount of two hundred seventyfour thousand, nine hundred eighty-eight dollars ($274,988) (“CMP Obligation”), plus postjudgment interest. Post-judgment interest shall accrue on the CMP Obligation beginning on the

date of entry of this Consent Order and shall be determined by using the Treasury Bill rate 

prevailing on the date of entry of this Consent Order pursuant to 28 U.S.C. § 1961 (2018).

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45. Kertatos shall pay his CMP Obligation and any post-judgment interest by electronic 

funds transfer, U.S. postal money order, certified check, bank cashier’s check, or bank money 

order. If payment is to be made other than by electronic funds transfer, then the payment shall be 

made payable to the Commodity Futures Trading Commission and sent to the address below: 

MMAC/ESC/AMK326

Commodity Futures Trading Commission 

Division of Enforcement 

6500 S. MacArthur Blvd. 

HQ Room 181 

Oklahoma City, OK 73169 

(405) 954-6569 office 

9-AMC-AR-CFTC@faa.gov

If payment by electronic funds transfer is chosen, Kertatos shall contact 9-AMC-ARCFTC@faa.govat the address above to receive payment instructions and shall fully comply with 

those instructions. Kertatos shall accompany payment of the CMP Obligation with a cover letter 

that identifies Kertatos and the name and docket number of this proceeding. Kertatos shall 

simultaneously transmit copies of the cover letter and the form of payment to the Chief Financial 

Officer, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st Street, NW, 

Washington, D.C. 20581. 

C. Provisions Related to Monetary Sanctions 

46. Partial Satisfaction: Acceptance by the Commission or the Monitor of any partial 

payment of Kertatos’ Restitution Obligation or CMP Obligation shall not be deemed a waiver of 

his obligation to make further payments pursuant to this Consent Order, or a waiver of the 

Commission’s right to seek to compel payment of any remaining balance.

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VI. MISCELLANEOUS PROVISIONS

47. Notice: All notices required to be given by any provision in this Consent Order 

shall be sent certified mail, return receipt requested, as follows: 

Notice to Commission: 

Rick Glaser

Deputy Director

Commodity Futures Trading Commission 

1155 21st Street, N.W.

Washington, D.C. 20581

Notice to Defendant Christopher A. Kertatos: 

 Christopher A. Kertatos 

 150 SE Duval Ave 

 Port St Lucie, FL 34983 

All such notices to the Commission shall reference the name and docket number of this action.

63. Change of Address/Phone: Until such time as Kertatos satisfies in full his 

Restitution Obligation and CMP Obligation as set forth in this Consent Order, Kertatos shall 

provide written notice to the Commission by certified mail of any change to his telephone number 

and mailing address within ten calendar days of the change.

64. Entire Agreement and Amendments: This Consent Order incorporates all of the 

terms and conditions of the settlement among the parties hereto to date. Nothing shall serve to 

amend or modify this Consent Order in any respect whatsoever, unless: (a) reduced to writing; 

(b) signed by all parties hereto; and (c) approved by order of this Court. 

65. Invalidation: If any provision of this Consent Order, or if the application of any 

provision or circumstance, is held invalid, then the remainder of this Consent Order and the 

application of the provision to any other person or circumstance shall not be affected by the 

holding. 

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66. Waiver: The failure of any party to this Consent Order or of any customer at any 

time to require performance of any provision of this Consent Order shall in no manner affect the 

right of the party or customer at a later time to enforce the same or any other provision of this 

Consent Order. No waiver in one or more instances of the breach of any provision contained in 

this Consent Order shall be deemed to be or construed as a further or continuing waiver of such 

breach or waiver of the breach of any other provision of this Consent Order. 

67. Waiver of Service, and Acknowledgement: Kertatos waives service of this Consent 

Order and agrees that entry of this Consent Order by the Court and filing with the Clerk of the 

Court will constitute notice to Kertatos of its terms and conditions. Kertatos further agrees to 

provide counsel for the Commission, within thirty (30) days after this Consent Order is filed with 

the Clerk of Court, with an affidavit or declaration stating that he has received and read a copy of 

this Consent Order. 

68. Continuing Jurisdiction of this Court: This Court shall retain jurisdiction of this 

action to ensure compliance with this Consent Order and for all other purposes related to this 

action, including any motion by Kertatos to modify or for relief from the terms of this Consent 

Order.

69. Injunctive and Equitable Relief Provisions: The injunctive and equitable relief 

provisions of this Consent Order shall be binding upon Kertatos, upon any person under his 

authority or control, and upon any person who receives actual notice of this Consent Order, by 

personal service, e-mail, facsimile or otherwise insofar as he or she is acting in active concert or 

participation with Kertatos. 

70. Counterparts and Facsimile Execution: This Consent Order may be executed in 

two or more counterparts, all of which shall be considered one and the same agreement and shall 

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become effective when one or more counterparts have been signed by each of the parties hereto 

and delivered (by facsimile, e-mail, or otherwise) to the other party, it being understood that all 

parties need not sign the same counterpart. Any counterpart or other signature to this Consent 

Order that is delivered by any means shall be deemed for all purposes as constituting good and 

valid execution and delivery by such party of this Consent Order. 

71. Contempt: Kertatos understands that the terms of the Consent Order are 

enforceable through contempt proceedings, and that, in any such proceedings he may not challenge 

the validity of this Consent Order. 

72. Agreements and Undertakings: Keratos shall comply with all of the undertakings 

and agreements set forth in this Consent Order. 

There being no just reason for delay, the Clerk of the Court is hereby ordered to enter

Judgment by attaching this Consent Order for Permanent Injunction, Restitution, Civil Monetary 

Penalty, and Other Equitable Relief Against Defendant Christopher A. Kertatos as the Judgment

without further notice. 

IT IS SO ORDERED on this 1st day of March 2022. 

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E. STEELE 

IOR UNITED STATES DISTRICT JUDGE 
Case 2:20-cv-00503-JES-NPM Document 45 Filed 03/01/22 Page 17 of 17 PageID 608

CONSENTED TO AND APPROVED BY: 

Prose j / 

Date: / / :2_ 7 L d. 0 ~ / 

I I 

18 

Alan 

Senior 

Edelman 

Trial Attorney 

~ 

Commodity Futures Trading Commission 

1155 2 !51 Street, N. W. 

Washington, D.C. 20581 

Telephone: (202) 418-5000 

Facsimile: (202) 418-5523 

Date 2. f 2g f '2.. 2-.