1 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF DELAWARE 

COMMODITY FUTURES TRADING COMMISSION,

Plaintiff, 

v. 

FIRST STATE DEPOSITORY COMPANY, LLC, 

ARGENT ASSET GROUP LLC, AND 

ROBERT LEROY HIGGINS, 

Defendants. 

Case No. 1:22-cv-1266-RGA 

CONSENT ORDER OF 

PERMANENT 

INJUNCTION AND OTHER 

STATUTORY EQUITABLE 

RELIEF 

On September 27, 2022, Plaintiff Commodity Futures Trading Commission (the 

“Commission”) filed a Complaint charging First State Depository Company, LLC (“FSD”), 

Argent Asset Group LLC (“Argent”), and Robert Leroy Higgins (“Higgins,” collectively, 

“Defendants”) with 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). D.I. 2. 

I. CONSENTS AND AGREEMENTS

1. To effect settlement of all charges alleged in the Complaint against FSD and

Argent (the “Settling Defendants”), without a trial on the merits or any further judicial 

proceedings, the Settling Defendants: 

2. Consent to the entry of this Consent Order for Permanent Injunction and Other

Equitable Relief Against the Settling Defendants (“Consent Order”); 

3. Affirm that they have 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 

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

induce consent to this Consent Order; 

4. Acknowledge service of the Summons, Complaint, and all other filings and orders 

entered herein; 

5. Admit the jurisdiction of this Court over them and the subject matter of this action 

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

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

Act, 7 U.S.C. § 13a-1(e); 

7. Admit the jurisdiction of the Commission over the conduct and transactions at 

issue in this action pursuant to the Act; 

8. Waive: 

a. the entry of findings of fact and conclusions of law in this action under Fed. 

R. Civ. P. 52(a)(2); 

b. Any and all claims that they may possess under the Equal Access to Justice 

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

the Commission in conformity therewith, Part 148 of the Regulations, 17 

C.F.R. pt. 148 (2022), relating to, or arising from, this action; 

c. Any and all claims that they may possess under the Small Business 

Regulatory Enforcement Fairness Act of 1996, Pub. L. No. 104-121, tit. II, §§ 

201–53, 110 Stat. 847, 857–74 (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; 

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d. 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 

e. Any and all rights of appeal from this action; 

9. Consent to the continued jurisdiction of this Court over them for the purpose of 

implementing and enforcing the terms and conditions of this Consent Order, the terms and 

conditions of the Statutory Restraining Order (“SRO”) and Preliminary Injunction entered in this 

matter, D.I. 12, D.I. 57, and for any other purpose relevant to this action, even if the Settling 

Defendants now or in the future reside outside the jurisdiction of this Court; 

10. Agree that they 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 waive any objection based thereon; 

11. Agree that neither they nor any of their agents or employees under their 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 their: (a) testimonial obligations; or (b) right to take legal positions in 

other proceedings to which the Commission is not a party. Settling Defendants shall comply 

with this agreement, and shall undertake all steps necessary to ensure that all of their agents 

and/or employees under their authority or control understand and comply with this agreement; 

12. By consenting to entry of this Consent Order, Settling Defendants neither admit 

nor deny the allegations of the Complaint or any Findings of Fact or Conclusions of Law in this 

Consent Order, except the admissions as to jurisdiction and venue above; 

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13. Consent to the use of the Findings of Facts and Conclusions of Law in this 

Consent Order in this proceeding and in any other proceeding brought by the Commission or by 

Kelly M. Crawford (the “Receiver”) or to which the Commission or the Receiver is a party or 

claimant, and agree that they shall be taken as true and correct and be given preclusive effect 

therein, without further proof; 

14. Do not consent, however, to the use of this Consent Order, or the Findings of Fact 

and Conclusions of Law herein, as the sole basis for any other proceeding brought by the 

Commission or to which the Commission is a party, other than a: statutory disqualification 

proceeding, proceeding in bankruptcy, or proceeding to enforce the terms of this Consent Order; 

15. Do not consent to the use of this Consent Order, or the Findings of Fact or 

Conclusions of Law herein, by any other party in any other proceeding; 

16. Agree that this Consent Order shall not limit or impair the ability of any other 

person or entity to seek any legal or equitable remedy against Settling Defendants in any other 

proceeding. 

II. FINDINGS OF FACT AND CONCLUSIONS OF LAW 

17. 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, as set forth herein. 

A. Findings of Fact 

1. The Parties to This Consent Order 

18. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency charged by Congress with the administration and enforcement of the Act and 

Regulations. 

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19. Defendant First State Depository Company, LLC is a Delaware limited liability 

company, organized on or about January 25, 2006, with an address of 100 Todds Lane, 

Wilmington, Delaware. FSD’s website describes itself as a “private depository” that offers “a 

full range of precious metals custody, shipping and accounting services to both commercial and 

individual participants in the rare coin and precious metals markets.” FSD has never been 

registered with the Commission in any capacity. 

20. Defendant Argent Asset Group LLC is a Delaware limited liability company, 

organized on or about September 24, 2013, with an address of 100 Todds Lane, Wilmington, 

Delaware. Argent engages in the business of buying, selling, and leasing coins, bullion, bars, 

and other precious metals. Argent has never been registered with the Commission in any 

capacity. 

2. Other Parties 

21. Non-Settling Defendant Robert Leroy Higgins is the owner, and was the 

operator and principal for FSD and Argent. Higgins has never been registered with the 

Commission in any capacity. 

3. Settling Defendants’ Scheme 

22. From at least January 2014 through the present (the “Relevant Period”) Settling 

Defendants, by and through their employee and agents, engaged in a fraudulent and deceptive 

scheme (the “Scheme”) that involved extensive misappropriation and other fraudulent and 

deceptive conduct in connection with the purchase and sale of precious metals. As described in 

more detail below, Settling Defendants defrauded participants in two silver leasing programs 

(“Customers”) as well as clients who were not involved in the silver leasing programs 

(“Clients”). Settling Defendants misappropriated tens of millions of dollars of assets that were 

supposedly stored at FSD for safekeeping, diverted those assets to their own use, and issued 

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statements and reports to Customers and Clients falsely indicating that the assets remained safely 

stored at FSD. On several occasions, Settling Defendants falsely led Customers and Clients to 

believe that Settling Defendants had obtained assets for them, when in fact Settling Defendants 

had not. Settling Defendants also deceived and misled Customers who enrolled in the silver 

leasing programs known as the Maximus Program and Silver Lease Program (the “Programs”), 

and made misrepresentations to Customers and Clients about FSD’s insurance coverage. In 

instances when Customers or Clients tried to withdraw their assets, Settling Defendants lied in 

order to conceal the misappropriation. 

23. The fraud and deception in Settling Defendants’ Scheme was material to 

Customers and Clients. As FSD itself said in marketing materials: 

We know that asset safety, transaction accuracy and expeditious fulfillment are of 

paramount importance to every depository customer, whether they are 

commercial enterprises conducting frequent, high volume business transactions or 

individuals simply seeking a highly secure facility to hold their personal coin and 

bullion investments. 

24. But instead of storing assets safely, reporting transactions accurately, and 

fulfilling transactions expeditiously, Settling Defendants misappropriated tens of millions of 

dollars, took steps to conceal that misappropriation, and made numerous misrepresentations and 

material omissions. 

4. Misappropriation of Customer and Client Assets 

25. In the course of conducting an inventory of assets stored at 100 Todds Lane, 

Baker Tilly, the public accounting firm retained by the Receiver, has discovered that as much as 

$112.7 million of Customer and Client assets are missing from FSD. See D.I. 82-1 at 14. In 

some instances, they found empty boxes at FSD with a Customer’s or Client’s name on it, or 

boxes that did not contain metal but instead held an “IOU” of sorts—a piece of paper stating the 

quantity of metal that should have been stored there. D.I. 78-1 at 22. In other instances, nothing 

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could be found for a particular Customer or Client, not even empty boxes. Settling Defendants 

misappropriated these assets, diverted them to their own uses, and sold them for their own 

benefit. 

26. Some of the missing assets were purchased directly through Argent to be stored at 

FSD, while other assets were obtained from other precious metals dealers, and then sent by 

Customers and Clients to FSD for storage. For the missing assets purportedly purchased from 

Argent, it is not clear whether Settling Defendants obtained the assets and then subsequently 

misappropriated them, or if Settling Defendants instead misappropriated the funds sent for the 

purpose of obtaining assets, failed to obtain the assets, and sent invoices and account statements 

that falsely indicated the assets had been obtained. There is some indication that Settling 

Defendants used both methods. Whatever the method used, Settling Defendants misappropriated 

tens of millions of dollars of assets from Customers and Clients. Settling Defendants concealed 

their misappropriation by sending account statements to Customers and Clients that falsely 

indicated that their assets were stored at FSD, when in fact they were not. When Customers and 

Clients sought to withdraw their assets, Settling Defendants attempted to delay the return of 

assets for as long as possible. Settling Defendants offered false and misleading excuses for why 

the assets could not be returned immediately. 

5. The Maximus Program 

27. Starting in or around November 2013, Argent promoted an investment program 

called the Maximus Program and solicited individuals to participate in it. The Maximus Program 

purported to offer Customers guaranteed monthly payments in exchange for their agreement to 

lease to Argent silver that the Customers purchased or owned. Maximus Customers were 

supposed to receive a monthly “lease” payment based on a sliding scale that in part depended on 

the amount of silver the Maximus Customers leased to Argent. 

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28. All of the leased silver in the Maximus Program was in the form of American 

Silver Eagles (“ASEs”).1 The ASE, also referred to as a “Silver Eagle” or “SAE,” is the 

official silver bullion coin issued by the United States Mint. Each coin weighs one ounce and is 

a minimum of 99.9% pure silver. The weight and purity of ASEs is guaranteed by the United 

States government. 

29. Maximus Customers signed an agreement with Argent that was known and 

referred to as the “Maximus Agreement” or “Maximus Silver Agreement.” The Maximus 

Agreements set forth the terms and conditions of the leasing relationship and included various 

representations and warranties. Maximus Customers also entered into a Depository Account 

Agreement with FSD regarding the purported storage of assets at FSD. In accordance with the 

Depository Account Agreement, FSD provided Maximus Customers with weekly or monthly 

“Holdings Reports” that purported to show each Customer’s account balance and holdings at 

FSD, and “Activity Reports” that were purportedly distributed every time a transaction occurred 

in their account (collectively, the “Reports”). 

30. In February 2014, Argent entered into a Maximus Agreement with Metals Dealer 

1, an entity owned and controlled by Individual 1. Pursuant to the Maximus Agreement between 

Argent and Metals Dealer 1, Argent agreed to pay Metals Dealer 1 twenty cents ($0.20) per 

month for each ASE that Metals Dealer 1 pledged to the Maximus Program. Argent told Metals 

Dealer 1 that Argent used the Leased Silver to fulfill short-term sales of ASEs to third parties as 

needed, and that if Leased Silver was sold, an equivalent amount of ASEs would promptly be 

returned to the account. 

 

1

 This Consent Order uses the term “Leased Silver” to refer to the ASEs that were part of either the Maximus 

Program or the Silver Lease Program. 

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31. At or around the same time, Metals Dealer 1 began soliciting prospective 

Customers for a silver leasing program of its own that operated in parallel to Argent’s Maximus 

Program. The result of this arrangement was a set of back-to-back leases, through which Metals 

Dealer 1’s customers leased ASEs to Metals Dealer 1, and Metals Dealer 1 exclusively leased 

those ASEs to Argent. 

32. Metals Dealer 1 agreed to provide Silver Lease Customers with a monthly 

payment of between one cent and ten cents per ASE invested in the Silver Lease Program, with 

the rate set in tiers based on the quantity of the ASEs leased to Metals Dealer 1 (the “Silver 

Lease Payment”). For example, a Silver Lease Customer who pledged between 1,000 and 1,999 

ASEs received a monthly payment of $0.01 per coin; a Silver Lease Customer who pledged 

between 9,000 and 9,999 ASEs received a monthly payment of $0.09 per coin, and a Silver 

Lease Customer who pledged more than 10,000 ASEs received a monthly payment of $0.10 per 

coin. Silver Lease Customers had the option to receive this monthly payment in cash, or instead 

to have additional ASEs put into their account. 

33. From 2014 to present, Silver Lease Customers collectively sent millions of dollars 

of money, silver, or other assets to Metals Dealer 1 or FSD to join the Silver Lease Program. At 

the time of the Commission’s complaint, there were approximately 200 Silver Lease Customers 

who collectively enrolled more than 537,000 ASEs in the Silver Lease Program, worth more than 

$10 million at prevailing market prices. 

34. Although certain iterations of the Lease Agreements were silent as to what Metals 

Dealer 1 intended do with the Leased Silver, and others permitted Metals Dealer 1 to transfer the 

Leased Silver to non-specified “customers desiring to purchase silver,” in every case and without 

fail, Metals Dealer 1 pledged the Leased Silver to the Maximus Program. 

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35. In other words, Metals Dealer 1 essentially served as a vehicle for directing ASEs 

to Argent’s Maximus Program. Consequently, a large majority of the ASEs in the Maximus 

Program came from Metals Dealer 1 and Silver Lease Customers. In light of Argent’s agreement 

to pay Metals Dealer 1 $0.20 for each ASE pledged to the Maximus Program, Metals Dealer 1’s 

Silver Lease Payments to Customers were essentially a pass-through arrangement in which 

Argent paid $0.20 to Metals Dealer 1 for each ASE that Silver Lease Customers held, and Metals 

Dealer 1 paid up to $0.10 per ASE to Silver Lease Customers, keeping the rest as profit. 

36. If Silver Lease Customers asked how leasing of the Leased Silver worked, Metals 

Dealer 1 told them the same thing that Argent told Metals Dealer 1—that the Leased Silver was 

used to fulfill short-term sales of ASEs as needed, but that if this occurred, an equivalent amount 

of ASEs would promptly be returned to their account. Based on representations by Settling 

Defendants, Metals Dealer 1 also told Silver Lease Customers that their ASEs were insured for 

100% of their value and stored in physically segregated storage at FSD. 

a) Fraud Regarding ASEs Held at FSD 

37. Settling Defendants led Customers to believe that their ASEs were held securely 

at FSD. FSD’s website unequivocally states that “your coins and bullion always remain 

physically stored in our depository, in your account and your legal property at all times,” and 

Argent’s Maximus Agreements (both with Metals Dealer 1 and with other Maximus Customers) 

required Argent to “maintain, in its possession and/or control, the specific property borrowed or 

property of similar nature that is fungible with the property borrowed.” 

38. FSD represented that it was “fully transparent” in reporting transactions, that it 

engaged in “full disclosure” and “accurate and timely reporting” and that an account owner could 

rely on the Reports to know the “exact status of all holdings secured at FSD.” Consistent with 

those representations, FSD sent monthly account statements to Customers indicating that the 

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Leased Silver remained in Customers’ accounts at all times. All of these representations, taken 

together, were intended to give Customers the impression that all of their Leased Silver was 

physically and securely stored in their accounts at FSD at all times. 

39. In fact, the exact opposite was true. To the extent Settling Defendants even 

obtained ASEs for Customers in the first place, Settling Defendants’ practice was to transfer all 

of the Leased Silver to Argent and for Argent to sell that Leased Silver to third parties and 

remove it from 100 Todds Lane. After this occurred, neither the Leased Silver, metal similar to 

the Leased Silver, nor assets roughly equivalent in value to the Leased Silver were returned to 

the Customers’ account at FSD. This is confirmed by the fact that after the Complaint in this 

case was filed, only 2,500 ASEs were found in Silver Lease Customers’ accounts, despite FSD’s 

records and Reports indicating there should have been more than 537,000. D.I. 78-1 at 94. 

40. In other words, Settling Defendants did not temporarily remove Leased Silver 

from Customer accounts to satisfy specific orders by third parties, and then replace the Leased 

Silver with other ASEs shortly thereafter, as Settling Defendants led Customers to believe they 

were doing. Nor did Settling Defendants replace Customers’ ASEs with other assets of an 

equivalent value. Instead, Settling Defendants misappropriated the Leased Silver, simply taking 

it and diverting it to their own use. None of this was disclosed to Customers, either on the 

Reports or elsewhere. FSD repeatedly sent Customers false and misleading Holdings Reports 

showing that the Customers’ ASEs were securely stored in their account at FSD, when in fact no 

such metal was there. FSD also sent false and misleading Activity Reports showing that ASEs 

were added to Customers’ accounts, when in fact no metal had been moved to the accounts, and 

no metal was there. FSD’s failure to inform Customers that their metal was not actually stored at 

FSD was also a deceptive omission, in light of their representations to the contrary on the 

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Holdings Reports. Settling Defendants knew that the Reports were false and misleading or were 

reckless as to their truth or falsity. Settling Defendants knew that the Leased Silver was not 

stored at FSD, and knew that they were nonetheless sending Holdings Reports that gave 

Customers the contrary impression. 

b) Fraud Regarding the Acquisition of ASEs 

41. Settling Defendants’ Scheme also involved several occasions in which Settling 

Defendants never obtained ASEs for Customers in the first place. Settling Defendants instead 

misappropriated the money and assets they received for the purpose of purchasing ASEs, 

diverting those assets to Higgins or the general use of FSD and Argent. 

42. In those instances, Settling Defendants deceived Metals Dealer 1, Customers, and 

IRA Custodians about their acquisition of ASEs. Settling Defendants directly deceived Silver 

Lease Customers by sending false and misleading Reports. Settling Defendants also deceived 

Metals Dealer 1 and IRA Custodians with the knowledge that those parties would rely on 

Settling Defendants’ deception and make representations to Silver Lease Customers that were 

misleading. Settling Defendants’ deception involved issuing invoices and purchase orders 

falsely indicating that Argent had obtained ASEs, falsely stating in communications that ASEs 

had been obtained or were being delivered to Settling Defendants’ offices at 100 Todds Lane, 

and issuing Reports that indicated that ASEs had been deposited to Customers’ accounts. 

Settling Defendants knew that Argent had not in fact obtained those ASEs, but instead simply 

created fake invoices and made fictitious “paper entries” in FSD’s inventory management 

system. 

43. For example, between October 1, 2018 and April 30, 2019, the number of ASEs 

pledged to Metals Dealer 1’s Silver Lease Program increased by more than 100,000. The vast 

majority of the new ASEs came from four separate Customers. Those four Customers 

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collectively transferred more than $1.53 million of money or other assets to Metals Dealer 1 with 

the understanding that those assets would be used to acquire ASEs for the Silver Lease Program. 

Metals Dealer 1, in turn, wired funds and transferred assets to Argent with the understanding that 

Argent would use those assets to acquire ASEs. 

44. Rather than obtaining ASEs for Customers 1-4, Settling Defendants 

misappropriated their assets, made fictitious entries in IBMS, and sent false and misleading 

emails and Reports to Metals Dealer 1, Customers 1-4, and IRA Custodian 1, purporting to show 

that the ASEs had been transferred into the accounts of Customers 1-4 at FSD, and were stored 

there. In fact, Settling Defendants did not obtain the required ASEs for Customers 1-4 and 

deposit them into their accounts. 

45. During the Relevant Period, Argent received millions of dollars in Customer 

funds and assets for the purpose of obtaining ASEs for the Programs. The four transactions 

identified above were not the only time that Settling Defendants failed to obtain ASEs for 

Customers. Indeed, as noted above, of the 537,000 ASEs enrolled in the Silver Lease Program, 

almost none of those ASEs were stored at FSD. Whether Settling Defendants actually obtained 

ASEs for Customers and then subsequently misappropriated them, or whether Argent simply 

misappropriated Customers’ funds and fraudulently failed to obtain ASEs, Settling Defendants 

did not store Leased Silver at FSD on behalf of Customers, as they led Customers to believe they 

were doing. 

6. Fraud Regarding Insurance 

46. Settling Defendants led Customers and Clients to believe that their assets were 

insured for 100% of their value. During the Relevant Period, FSD’s publicly-visible website 

advertised that “[a]ll Accounts [are] Insured for 100% of value,” stated that “assets are stored in 

insured accounts,” and said that “First State is fully insured, with an approximate insured 

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contents limit of $400 million, depending on the ‘mix’ of assets held.” In marketing materials 

and communications with potential Customers and Clients, FSD made similar assertions, stating 

that “[a]ll assets stored in First State’s vaults are insured for 100% of its [sic] value through our 

ALL RISK policy with Lloyds of London.” 

47. FSD made similar representations in the standard Depository Account Agreement 

it entered into with Customers and Clients, which provided that “First State agrees to maintain in 

effect all-risk insurance on Assets stored in Account for Client.” FSD’s Depository Account 

Agreements also stated that upon request, FSD would “provide a Certificate of Insurance 

evidencing insurance coverage for Assets held by First State.” On numerous occasions 

Customers or Clients requested these certificates, which were referred to as “Evidences of 

Insurance.” The Evidences of Insurance listed FSD as the “Insured,” and typically identified the 

Customer or Client as a “Memorandum Holder and Loss Payee.” When requested, FSD 

provided these Evidences of Insurance, intending to reassure them that the Customer’s and 

Client’s assets were fully insured. 

48. Settling Defendants’ representations regarding insurance were false and 

misleading. Settling Defendants deceived Customers and Clients regarding insurance in at least 

three ways. 

49. First, despite the fact that throughout the Relevant Period FSD’s website has 

touted and continues to tout an “approximate insured contents limit of $400 million,” in actuality 

FSD’s insurance policy limit has not been close to that from at least November 2014 through the 

present. To the contrary, FSD’s insurance policy limit was $85 million from approximately 

November 2014 to November 2016, $100 million from approximately November 2016 through 

May 2021, and $75 million from May 2021 through the filing of the Commission’s complaint. 

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FSD’s misrepresentations regarding the purported $400 million insurance policy impacted all 

FSD Customers and Clients. Settling Defendants knew their representations regarding a $400 

million policy limit were false, or were reckless as to their truth or falsity. 

50. Second, FSD’s representations that “[a]ll Accounts [are] Insured for 100% of 

value,” that “First State is fully insured,” and that “[a]ll assets stored in First State’s vaults are 

insured for 100% of its [sic] value” were false. Not only did FSD not have a $400 million policy 

limit, FSD’s actual, much lower policy limits were insufficient to cover the full value of assets 

that FSD purportedly held for Customers and Clients. Like the misrepresentation regarding the 

$400 million insurance policy, this deception impacted all FSD Customers and Clients. 

51. For example, according to FSD records, as of March 2021, the total value of 

inventory purportedly stored at FSD was more than $176 million, and the total insured value of 

inventory was more than $158 million, at least $50 million more than the then-applicable policy 

limit of $100 million. Likewise, in October 2022, when FSD’s policy limit was $75 million, 

FSD’s own records indicated that the total value of inventory purportedly stored at FSD was 

more than $138 million, and the total insured value of inventory was more than $125 million. 

52. In short, Settling Defendants falsely represented that all assets purportedly stored 

at FSD were fully insured for 100% of their value. Settling Defendants made this 

misrepresentation repeatedly: on FSD’s website, in marketing materials, in communications 

with prospective Customers and Clients, in FSD’s standard agreement with Customers and 

Clients, and elsewhere. As with FSD’s misrepresentations regarding the $400 million policy 

limit, this misrepresentation impacted all Customers and Clients. 

53. Third, FSD provided Evidences of Insurance to Customers with the intent to give 

a misleading assurance that their Leased Silver was insured, when Settling Defendants knew it 

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was not insured, or when the risk that it was not insured was so high that they must have been 

aware of it. 

54. For the Relevant Period, FSD’s primary insurance policy limit only covered assets 

stored at 100 Todds Lane. But as explained above, FSD and Argent did not store the Leased 

Silver in FSD’s vault at 100 Todds Lane (to the extent it was bought in the first place), but 

instead systematically and immediately transferred those ASEs to Argent’s offices at 100 Todds 

Lane, where the Leased Silver was briefly stored before being sold to third parties. But none of 

FSD’s insurance policies covered metal that was sold by Argent, delivered to third parties, and 

removed from the possession, custody, or control of FSD and Argent. 

55. In addition, assets that were misappropriated from Clients who were not part of 

the Programs were also removed from FSD’s premises and diverted to Settling Defendants’ own 

use. But none of FSD’s insurance policies covered metal that was misappropriated. Settling 

Defendants’ provision of Evidences of Insurance upon request thus provided false assurances 

that assets were insured by FSD’s insurance policies.

7. FSD and Argent Operated as a Common Enterprise 

56. FSD and Argent did not conduct business at arm’s length or observe corporate 

formalities, but rather were commonly controlled by a single individual who owned both entities, 

had ultimate decision-making authority over both entities, and controlled and was the signatory 

on both entities’ bank accounts. 

57. FSD and Argent shared the same address and office at 100 Todds Lane. FSD and 

Argent also shared employees, consultants, or agents, including Higgins. One of Higgins’ sons 

served as nominal operational head of FSD, and another son served as nominal operational head 

of Argent. Higgins’ sister performed services on behalf of both FSD and Argent, and a third son 

and Higgins’ wife worked for FSD and/or Argent at various points during the Relevant Period. 

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58. FSD and Argent commingled corporate funds—on various occasions throughout 

the Relevant Period, Argent paid bills for FSD or wired money to FSD in order to ensure its bank 

account balance remained positive. FSD and Argent also transferred Customer funds between 

them. Settling Defendants’ misappropriation was at least partially premised on Higgins taking 

Customer and Client assets from FSD and selling them through Argent.

B. Conclusions of Law 

1. Jurisdiction and Venue 

59. This Court has jurisdiction over this action pursuant to Section 6c(a) of the Act, 7 

U.S.C. § 13a-1(a), which authorizes the Commission to seek injunctive and other relief in United 

States district court against any person whenever it shall appear to the Commission that such 

person has engaged, is engaging, or is about to engage in any act or practice constituting a 

violation of any provision of the Act, or any rule, regulation, or order thereunder, and provides 

that district courts “shall have jurisdiction to entertain such actions.” This Court also has 

jurisdiction pursuant to 28 U.S.C. § 1331 (federal question) and 28 U.S.C. § 1345 (United States 

as plaintiff). 

60. Venue lies properly with this Court pursuant to Section 6c(e) of the Act because 

Settling Defendants can be found in this District, transacted business in this District, and certain 

transactions, acts, practices, and courses of business alleged in this Complaint occurred, are 

occurring, or are about to occur in this District. 

2. Count I—Fraud by Manipulative or Deceptive Device or Contrivance 

61. Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), makes it unlawful for any person, 

directly or indirectly, to: 

[U]se or employ, or attempt to use or employ, in connection with any . . . contract 

of sale of any commodity in interstate commerce . . . any manipulative or 

deceptive device or contrivance, in contravention of such rules and regulations as 

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the Commission shall promulgate by not later than 1 year after [July 21, 2010, the 

date of enactment of the Dodd-Frank Wall Street Reform and Consumer 

Protection Act]. 

62. Regulation 180.1(a)(1)-(3), 17 C.F.R. § 180.1(a)(1)-(3) (2022) provides, in part: 

It shall be unlawful for any person, directly or indirectly, in connection with any . 

. . contract of sale of any commodity in interstate commerce . . . to intentionally or 

recklessly: (1) Use or employ, or attempt to use or employ, any manipulative 

device, scheme, or artifice to defraud; (2) Make, or attempt to make, any untrue or 

misleading statement of a material fact or to omit to state a material fact necessary 

in order to make the statements made not untrue or misleading; [or] (3) Engage, or 

attempt to engage, in any act, practice, or course of business, which operates or 

would operate as a fraud or deceit upon any person . . . . 

63. As described above, during the Relevant Period Settling Defendants, by and 

through their employees and agents, violated Section 6(c)(1) of the Act and Regulation 

180.1(a)(1)-(3) by, among other things, in connection with contracts of sale of a commodity 

(e.g., precious metals) in interstate commerce, using or employing, or attempting to use or 

employ, a device, scheme, or artifice to defraud and engaging, or attempt to engage, in an act, 

practice, or course of business, which operates or would operate as a fraud or deceit upon any 

person, including by: 

a. Misappropriating precious metals and other assets owned by Customers and 

Clients; 

b. Misappropriating funds that were sent by Customers and Clients for the 

purpose of obtaining precious metals and other assets, and instead diverting 

those funds to Higgins or the general use of FSD and Argent; 

c. Leading Metals Dealer 1, other Customers, and IRA Custodians to believe 

that ASEs had been obtained for the Programs, and that ASEs for the 

Programs were stored at FSD, when in fact they were not; and 

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d. Leading Metals Dealer 1, other Customers, IRA Custodians, and Clients to 

believe that their assets were fully insured for 100% of their value, when in 

fact they were not. 

64. During the Relevant Period, Settling Defendants, by and through their employees 

and agents, violated Section 6(c)(1) of the Act and Regulation 180.1(a)(1)-(3), by, among other 

things, in connection with contracts of sale of a commodity (e.g., precious metals) in interstate 

commerce, making or attempting to make untrue or misleading statements of material fact or 

omitting to state or attempting to omit material facts necessary in order to make statements made 

not untrue or misleading, including by: 

a. Making false and misleading statements that Customer and Client assets were 

stored at FSD when in fact they were not; 

b. Making false and misleading statements that assets had been acquired for 

Customers and Clients when in fact they had not; 

c. Making false and misleading statements regarding insurance coverage that 

applied to Customer and Client assets; and 

d. Making false and misleading statements in connection with certain 

Customers’ and Clients’ attempts to retrieve their assets from FSD. 

65. Settling Defendants engaged in the acts and practices described above willfully, 

knowingly or with reckless disregard for the truth. 

66. Each misappropriation, misrepresentation or omission of material fact, false 

statement, or other act in furtherance of Settling Defendants’ Scheme is a separate and distinct 

violation of Section 6(c)(1) and Regulation 180.1(a)(1)-(3). 

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67. The foregoing acts, omissions, and failures of Argent’s employees and agents 

occurred within the scope of their employment, agency, or office with Argent. Therefore, Argent 

is liable pursuant to Section 2(a)(l)(B) of the Act, 7 U.S.C. § 2(a)(l)(B), and Regulation 1.2, 17 

C.F.R. § 1.2 (2022), as principal for the violative actions and omissions of Argent’s employees 

and agents. 

68. The foregoing acts, omissions, and failures of FSD’s employees and agents 

occurred within the scope of their employment, agency, or office with FSD. Therefore, FSD is 

liable pursuant to Section 2(a)(l)(B) of the Act and Regulation 1.2, as principal for the violative 

actions and omissions of FSD’s employees and agents. 

69. Because FSD and Argent operated as a common enterprise, each is liable for the 

violative acts of each member of the enterprise. 

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

Settling Defendants will continue to engage in the acts and practices alleged in the Complaint 

and in similar acts and practices in violation of the Act and Regulations. 

III. PERMANENT INJUNCTION 

IT IS HEREBY ORDERED THAT: 

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

of the Act, 7 U.S.C. § 13a-1, Settling Defendants are permanently restrained, enjoined and 

prohibited from directly or indirectly:

a. directly or indirectly, using or employing, or attempting to use or employ, in 

connection with any swap or contract of sale of any commodity in interstate 

commerce, or for future delivery on or subject to the rules of any registered 

entity, any manipulative or deceptive device or contrivance, including by 

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intentionally or recklessly: (1) using or employing, or attempting to use or 

employ, any manipulative device, scheme, or artifice to defraud; (2) making, 

or attempting to make, any untrue or misleading statement of a material fact or 

to omit to state a material fact necessary in order to make the statements made 

not untrue or misleading; or (3) engaging, or attempting to engage, in any act, 

practice, or course of business, which operates or would operate as a fraud or 

deceit upon any person, or otherwise violating Section 6(c)(1) of the Act, 7 

U.S.C. § 9(1), and Regulation 180.1(a)(1)-(3), 17 C.F.R. §180.1(a)(1)-(3) 

(2022).

72. Settling Defendants are 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 of the Act, 7 U.S.C. § 1a (40)); 

b. entering into any transactions involving “commodity interests” (as that term is 

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2022), or precious metals that are 

commodities, as that term is defined herein, for their own personal account or 

for any account in which they have a direct or indirect interest; 

c. having any commodity interests, or precious metals that are commodities, as 

that term is defined herein, traded on their 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, or precious metals that are commodities, as that term is 

defined herein; 

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e. soliciting, receiving or accepting any funds from any person for the purpose of 

purchasing or selling any commodity interests or precious metals that are 

commodities, as that term is defined herein; 

f. applying for registration or claiming exemption from registration with the 

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

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) (2022); and/or 

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

§ 3.1(a) (2022)), 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)), registered, 

exempted from registration or required to be registered with the Commission 

except as provided for in Regulation 4.14(a)(9). 

IV. RESTITUTION AND CIVIL MONETARY PENALTY 

A. Restitution 

73. Settling Defendants shall pay, jointly and severally, restitution in the amount of 

one hundred and twelve million seven hundred thousand dollars ($112,700,000) (“Restitution 

Obligation”). Settling Defendants’ Restitution Obligation also will be joint and several with any 

restitution obligation imposed by this Court on Higgins. If the Restitution Obligation is not paid 

immediately in full, post-judgment interest shall accrue on the unpaid portion of 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. 

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

restitution payments to Defendants’ customers, the Court appoints the National Futures 

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Association (“NFA”) as Monitor (“Monitor”). Subject to Paragraph 79 herein, and the 

Receiver’s duties under the SRO, the Monitor shall receive restitution payments from 

Defendants 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. 

75. Settling Defendants shall make Restitution Obligation payments, and any postjudgment interest payments, under this Order to the Monitor in the name “FSD/Argent/Higgins 

Settlement/Restitution Fund” and shall send such 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. Settling Defendants 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. 

76. 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 Defendants’ 

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 below. 

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77. Settling Defendants shall cooperate with the Monitor as appropriate to provide 

such information as the Monitor deems necessary and appropriate to identify Defendants’ 

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

distribution of any Restitution Obligation payments. Settling Defendants shall execute any 

documents necessary to release funds that they have in any repository, bank, investment or other 

financial institution, wherever located, in order to make partial or total payment toward the 

Restitution Obligation. 

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

with a report detailing the disbursement of funds to Defendants’ 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. 

79. Settling Defendants shall receive dollar-for-dollar credit against the Restitution 

Obligation for any funds that are disbursed by the Receiver to customers as the result of the 

liquidation of any assets of Defendants by the Receiver. The Receiver shall, under a cover letter 

that identifies the name and docket number of this proceeding, transmit to the Chief Financial 

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

NW, Washington, D.C. 20581, copies of the form of payment to those customers. 

80. Upon the termination of the receivership estate, the Receiver shall provide the 

Commission with a report detailing the disbursement of funds to Defendants’ customers. The 

Receiver 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. 

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

from proving that a greater amount is owed from Settling Defendants or any other person or 

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

customer that exist under state or common law. 

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

Settling Defendants 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 Settling Defendants to 

ensure continued compliance with any provision of this Consent Order and to hold Settling 

Defendants in contempt for any violations of any provision of this Consent Order. 

83. To the extent that any funds accrue to the U.S. Treasury for satisfaction of 

Settling Defendants’ Restitution Obligation, such funds shall be disbursed in accordance with the 

procedures set forth above. 

B. Civil Monetary Penalty 

84. Settling Defendants shall pay, jointly and severally, a civil monetary penalty in 

the amount of thirty-three million dollars ($33,000,000) (“CMP Obligation”). Settling 

Defendants’ CMP Obligation also will be joint and several with any civil monetary penalty 

obligation imposed by this Court on Higgins. If the CMP Obligation is not paid in full within ten 

(10) days of the date of the entry of this Consent Order, then 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. 

85. Settling Defendants shall pay their CMP Obligation and any post-judgment 

interest by electronic funds transfer, U.S. postal money order, certified check, bank cashier’s 

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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 

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73169 

9-AMC-AR-CFTC@faa.gov 

 

86. If payment is to be made by electronic funds transfer, Settling Defendants shall 

contact Tonia King or her successor at the above email address to receive payment instructions 

and shall fully comply with those instructions. Settling Defendants shall accompany payment of 

the CMP Obligation with a cover letter that identifies Settling Defendants and the name and 

docket number of this proceeding. Settling Defendants 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. 

Settling Defendants shall also transmit a copy of the cover letter and the form of payment to Rick 

Glaser, Deputy Director, Commodity Futures Trading Commission, Three Lafayette Centre, 

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

C. Provisions Related to Monetary Sanctions 

87. Partial Satisfaction: Acceptance by the Commission of any partial payment of the 

CMP Obligation shall not be deemed a waiver of their 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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V. CONTINUATION OF RELIEF FROM STATUTORY RESTRAINING ORDER 

A. Asset Freeze Order Prohibiting the Withdrawal, Transfer, Removal, Dissipation, 

and Disposal of Assets

88. Except as otherwise modified by this Order and subsequent court orders, the SRO, 

D.I. 12, shall remain in full force and effect. 

89. Settling Defendants and their agents, servants, employees, assigns, attorneys, and 

persons in active concert or participation with them, including any successor thereof, who 

receive actual notice of this Consent Order by personal service or otherwise, are immediately 

restrained and enjoined, except as otherwise ordered by this Court, from directly or indirectly 

withdrawing, transferring, removing, dissipating or otherwise disposing of any assets, wherever 

located, including but not limited to assets held in the names of Settling Defendants, or other 

property held outside the United States, in accordance with the Court’s SRO. 

90. At the request of the Receiver, Settling Defendants and any other person who has 

possession, custody, or control of any of Settling Defendants’ funds, assets, or other property 

shall transfer possession of all funds, assets, or other property subject to this Order to the 

Receiver in accordance with the SRO. 

91. The funds, assets, or other property affected by this Consent Order shall include 

both existing funds, assets or other property, and funds, assets, or other property acquired after 

the effective date of this Consent Order. 

VI. MISCELLANEOUS PROVISIONS 

92. Cooperation: Settling Defendants shall cooperate fully and expeditiously with 

the Commission, including the Commission’s Division of Enforcement, and any other 

governmental agency or any self-regulatory organization, in this action, and in any current or 

future Commission investigation or action related thereto. Settling Defendants shall also 

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28 

cooperate in any investigation, civil litigation, or administrative matter related to, or arising 

from, this action. 

93. Until such time as Settling Defendants satisfies in full their CMP and Restitution

obligations under this Consent Order, upon the commencement by or against Settling Defendants 

of insolvency, receivership or bankruptcy proceedings or any other proceedings for the 

settlement of Settling Defendants debts, all notices to creditors required to be furnished to the 

Commission under Title 11 of the United States Code or other applicable law with respect to 

such insolvency, receivership bankruptcy or other proceedings, shall be sent to the address 

below: 

Secretary of the Commission 

Office of the General Counsel 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street N.W. 

Washington, DC 20581 

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

except as set forth in the previous paragraph, shall be sent certified mail, return receipt requested, 

as follows: 

Notice to Commission: 

Rick Glaser 

Deputy Director, Division of Enforcement 

Commodity Futures Trading Commission 

1155 21st Street, NW 

Washington, D.C. 20581 

Telephone: (202) 418-5000 

Notice to Settling Defendants: 

First State Depository Company, LLC 

Argent Asset Group LLC 

c/o Receiver Kelly M. Crawford 

500 North Akard, Suite 2700 

Dallas, TX 75201 

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Telephone: (214) 706-4200 

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

95. Change of Address/Phone: Until such time as Settling Defendants satisfy in full

the Restitution Obligation and CMP Obligation, Settling Defendants shall provide written notice 

to the Commission by reasonable means of any change to their telephone numbers and mailing 

addresses within ten calendar days of the change. 

96. 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. 

97. 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. 

98. Waiver: The failure of any party to this Consent Order to require performance of

any provision of this Consent Order shall not affect the right of the party to later 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. 

99. 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 Defendants to modify or for relief from the terms of this 

Consent Order. 

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100. Injunctive and Equitable Relief: The injunctive and equitable relief provisions

of this Consent Order shall be binding upon the following persons who receive actual notice of 

this Consent Order, by personal service or otherwise: (1) Settling Defendants; (2) any officer, 

agent, servant, employee, or attorney of Settling Defendants; and (3) any other persons who are 

in active concert or participation with any persons described in subsections (1) and (2) above. 

101. Authority for Settling Defendants: Kelly M. Crawford hereby warrants that he

is the court appointed Receiver for Settling Defendants, and that this Consent Order has been 

duly authorized by him as the Receiver for FSD and Argent, and that he has been duly 

empowered to sign and submit this Consent Order on behalf of Settling Defendants; that 

pursuant to the SRO he has assumed full control of FSD and Argent; and as such signs and 

submits this Consent Order on behalf of Settling Defendants. 

102. Counterparts and Electronic 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 become effective when one or more counterparts have been signed by each of the parties 

hereto and delivered (by 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. 

103. Contempt: Settling Defendants understand that the terms of the Consent Order,

except with respect to restitution, are enforceable through contempt proceedings, and that, in any 

such proceedings they may not challenge the validity of this Consent Order. 

104. Agreements and Undertakings: Settling Defendants shall comply with all of

the undertakings and agreements set forth in this Consent Order. 

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

enter this Consent Order for Permanent Injunction and Other Equitable Relief forthwith and 

without further notice. 

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Ju

e 7, 

0

3

20th

June

/s/ Richard G. Andrews

Brian A. Hunt 

Rick Glaser 

COMMODITY FUTURES 

TRADING COMMISSION 

Three Lafayette Centre 

1155 21st Street NW 

Washington, DC 20581 

bhunt@cftc.gov 

rglaser@cftc.gov 

DEFENDANTS FIRST STATE DEPOSITORY 

COMPANY, LLC AND 

ARGENT ASSET GROUP LLC 

. Crawford 

kard, Suite 2 0 

Dallas, T 75201 

Receiver on Behalf of First State 

Depository Company, LLC and 

Argent Asset Group LLC 

ated: 

Dated: May 9, 2023 

IT SO ORDERED, at Wilmington, Delaware on this ___ day of __ , 2023, at 

.m. 

UNITED ST ATES DISTRICT JUDGE 

32