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UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA

COMMODITY FUTURES 

TRADING COMMISSION, 

Plaintiff, 

v.

HIGHRISE ADVANTAGE, LLC, 

BULL RUN ADVANTAGE, LLC, 

GREEN KNIGHT INVESTMENTS, 

LLC, KING ROYALTY LLC, SR&B 

INVESTMENT ENTERPRISES, 

INC., AVINASH SINGH, RANDY 

ROSSEAU, DANIEL COLOGERO, 

HEMRAJ SINGH, and SURUJPAUL 

SAHDEO, 

Defendants.

Case No.: 6:20-cv-01657-CEM-GJK

PLAINTIFF’S [UNOPPOSED] MOTION FOR ENTRY OF CONSENT 

ORDERS FOR PERMANENT INJUNCTION CIVIL MONETARY 

PENALTY AND OTHER EQUITABLE RELIEF AGAINST DEFENDANTS 

BULL RUN ADVANTAGE, LLC, RANDY ROSSEAU, GREEN KNIGHT 

INVESTMENTS, LLC, DANIEL COLOGERO, KING ROYALTY LLC, 

HEMRAJ SINGH, SR&B INVESTMENT ENTERPRISES, INC. AND 

SURUJPAUL SAHDEO 

Plaintiff, Commodity Futures Trading Commission (“Commission” or 

“CFTC”) filed A Complaint (ECF No. 1) against Defendants Highrise Advantage, 

LLC, Bull Run Advantage, LLC, (“Bull Run”),Green Knight Investments, LLC 

(“Green Knight”), King Royalty LLC (“King Royalty”), SR&B Investment 

Enterprises, Inc. (“SR&B”), Avinash Singh, Randy Rosseau (“Rosseau”) , Daniel 

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Cologero (“Cologero”), Hemraj Singh (“Raj”), and Surujpaul Sahdeo (“Sahdeo”) , 

seeking injunctive and other equitable relief, as well as the imposition of civil 

penalties, for violations of the Commodity Exchange Act (“Act”), 7 U.S.C. §§ 1–

26, and the Commission’s Regulations (“Regulations”) promulgated thereunder, 

17 C.F.R. pts. 1–190 (2022). On February 1, 2021, the Commission filed an 

Amended Complaint. (ECF No. 98). In connection therewith, the parties have 

agreed to enter into proposed Consent Orders for Permanent Injunction, and Other 

Equitable Relief Against Bull Run and Rosseau, Green Knight and Cologero, King 

Royalty and Raj, and SR&B and Sahdeo (“Settling Defendants”) as set forth in 

Attachments A through D. Specifically, Settling Defendants agree to findings of 

fact that they operated feeder pools that accepted pool participant funds for the 

purpose of engaging in retail foreign currency transactions (“forex”) in the name of 

the feeder pools and that the operation of those pools operated as frauds or deceits 

on pool participants. The Settling Defendants also agree to the entry of 

conclusions of law that they violated Section 4o(1)(B) of the Act, 7 U.S.C. 

§6o(1)(B) and Regulations 4.20(a)(1),(b), 4.21(a)(1), 17. C.F.R. §§ 4.20(a)(1)(b), 

4.21(a)(1)(2022). In addition, Bull Run, Green Knight, King Royalty and SR&B 

agree that they acted as commodity pool operators (CPOs”) without being 

registered, thereby engaging in violations of Sections 2(c)(2)(C)(iii)(I)(cc) and 

4m(1) of the Act, 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc) and 6m(1), and Regulation 

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5.3(a)(2)(i), 17 C.F.R. § 5.3(a)(2)(i). Moreover, Rosseau, Cologero, Raj and 

Sahdeo agree that they acted as associated persons(“APs”) of a CPO without being 

registered and Bull Run, Green Knight, King Royalty and SR&B that they allowed 

Rosseua, Cologero, Raj and Sahdeo to act as APs of their respective CPOs without 

benefit of registration and thus all Settling Defendants engaged in violations of 

Section 4k(2) of the Act , 7 U.S.C.§ 6k(2) and Regulations 3.12 and 5.3(a)(2)(ii), 

17 C.F.R. §§3.21m 5.3(a)(2)(ii)(2022). 

The parties also agree to the entry of equitable relief in the form of 

permanent injunctions prohibiting the Settling Defendants from further violations 

of the Act and Regulations as charged, and that permanent trading and registration 

bans should be imposed. The parties also agree that the Settling Defendants should 

also be ordered to pay restitution and civil monetary penalties in the amounts set 

forth their respective Consent Orders. 

The stipulated Consent Orders will promote judicial economy by resolving 

all of the contested issues in the case.

WHEREFORE, in light of the parties having agreed upon a resolution of 

this case, the Plaintiff respectfully requests the Court’s consideration and approval 

of the attached Consent Orders. 

Date: June 23, 2023 

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Respectfully submitted, 

By: /s/ Susan B. Padove

Trial Counsel

Senior Trial Attorney

Attorney for Plaintiff 

Commodity Futures Trading 

Commission

77 West Jackson Blvd., Suite 

800

Chicago, IL 60604

Tel. (312) 596-0544

Cell: (202) 390-6885

Fax. (312) 596-0714

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