UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF TEXAS 

HOUSTON DIVISION 

COMMODITY FUTURES TRADING 

COMMISSION, 

Plaintiff, 

v. 

MAYCO ALEXIS MALDONADO 

GARCIA, et al. jointly d/b/a GLOBAL 

TRADING CLUB, 

Defendants. 

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) Civil Action No. 4:20-cv-03185 

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) _______________ ) 

CONSENT ORDER FOR PERMANENT INJUNCTION, RESTITUTION 

AND ANCILLARY EQUITABLE RELIEF AGAINST 

DEFENDANTS CESAR CASTANEDA AND JOEL CASTANEDA GARCIA 

I. INTRODUCTION 

On September 11, 2020, Plaintiff Commodity Futures Trading Commission 

("Commission" or "CFTC") filed a Complaint (ECF No. 1) against Defendants Cesar Castaneda, 

Joel Castaneda Garcia ( collectively, "the Castaneda Defendants"), and others jointly d/b/a Global 

Trading Club ("GTC"). The Complaint seeks 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 (2018), and the Commission's Regulations ("Regulations") promulgated thereunder, 17 

C.F.R. pts. 1-190 (2020). 

United States District Court

Southern District of Texas

ENTERED

July 26, 2021

Nathan Ochsner, Clerk

Case 4:20-cv-03185 Document 56 Filed on 07/26/21 in TXSD Page 1 of 20
II. CONSENTS AND AGREEMENTS 

To effect settlement of all charges alleged in the Complaint against the Castaneda 

Defendants without a trial on the merits or any fu1ther judicial proceedings, the Castaneda 

Defendants: 

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

and Ancillary Equitable Relief Against the Castaneda Defendants ("Consent Order"); 

2. Affirm that they understand and agree to this Consent Order voluntarily, and that 

no promise, other than as specifically contained herein, or threat, has been made by the CFTC or 

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

to this Consent Order; 

3. Acknowledge service of the summons and Complaint; 

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

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

5. Admit the jurisdiction of the CFTC over the conduct and transactions at issue in 

this action pursuant to the Act; 

6. Admit that venue properly lies with this Comt pursuant to 7 U.S.C. § 13a-l(e); 

7. Waive: 

(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 CFTC in conformity therewith, Part 148 of the 

Regulations, 17 C.F.R. pt. 148 (2020), relating to, or arising from, this 

action; 

(b) 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, 

§§ 201-253, 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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(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. 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 and for any other 

purpose relevant to this action, even if the Castaneda Defendants now or in the future reside 

outside the jurisdiction of this Court; 

9. 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; 

10. Agree to provide immediate notice to this CoUii and the CFTC by certified mail, 

in the manner required by paragraph 51 of this Consent Order, of any bankruptcy proceeding 

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

11. Agree 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 the Castaneda 

Defendants, separately or together, in any other proceeding. 

III. FINDINGS OF FACT AND CONCLUSIONS OF LAW 

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. 

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THE PARTIES AGREE AND THE COURT HEREBY FINDS: 

A. Findings of Fact 

The Parties to this Consent Order 

12. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency charged by Congress with responsibility for administering and enforcing the 

provisions of the Act and Regulations. 

13. Defendant Cesar Castaneda is an individual residing in Conroe, Texas. Cesar 

Castaneda is also known by the name Cesar Castaneda Garcia. He has never been registered 

with the CFTC. 

14. Defendant Joel Castaneda Garcia is an individual residing in Port St. Lucie, 

Florida. During at least some portion of the period August 2016 through October 2017 (the 

"Relevant Period"), he resided in Houston, Texas. He is the brother of Cesar Castaneda and is 

also known by the name Joel Castaneda. He has never been registered with the CFTC. 

The Castaneda Defendants Solicited Customers to Purchase Bitcoin with GTC 

15. In 2016, the Castaneda Defendants began to market a new business called GTC. 

The stated purpose of GTC was to offer customers an opportunity to profit from speculative 

trading that was based upon price fluctuations in Bitcoin. 

16. Although the Castaneda Defendants marketed Bitcoin trading using the GTC 

name, GTC did not exist as a separate legal entity. Instead, the Castaneda Defendants used 

separate corporate entities, and opened bank accounts in the names of those entities, through 

which they accepted deposits from GTC customers. 

17. During the Relevant Period, the Castaneda Defendants continued to promote the 

GTC business usirig numerous channels, including a web site, www.gtcexchange.com ("GTC 

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web site"); a sma11phone app called "GTC Digital"; videos posted to a YouTube channel; and a 

Facebook page called Global Trading Club. 

18. Additionally, throughout the Relevant Period, the Castaneda Defendants made 

representations directly to actual and potential customers during GTC "cryptocurrency" seminars 

held by GTC in Houston and elsewhere in the United States. During these seminars, the 

Castaneda Defendants shared a GTC marketing presentation, which contained the same 

representations found on the GTC web site and in the Y ouTube videos. 

19. The GTC seminars in which the Castaneda Defendants participated included the 

following: 

• In September 2016, the Castaneda Defendants co-hosted a seminar at Drury 

Inn and Suites in Houston; and 

• In December 2016, the Castaneda Defendants co-hosted a GTC holiday party 

for potential customers at a hotel in Houston. 

20. The Castaneda Defendants marketed the GTC business to non-English-speaking 

residents of the United States. The GTC web site highlighted Korean- and Spanish-speaking 

representatives of the business. Defendant Mayco Alexis Maldonado Garcia circulated Spanish 

and Korean translations of the GTC marketing presentation to the Castaneda Defendants, as well 

as other individuals who marketed the GTC business. The YouTube videos were also translated 

into Spanish, Korean, and other languages. 

The Castaneda Defendants Made False and Misleading Representations when 

Soliciting GTC Customers 

21. The GTC web site, YouTube videos, marketing presentations, and/or other GTC 

marketing materials included the following representations: 

• GTC employed "over 75 master traders" 

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• These traders had years of trading experience in "crypto currency" trading; 

• GTC customer "capital is continuously being traded in a real time 

environment, by our expert traders and cutting edge trading robots 24 hours a 

day, 7 days a week." 

• "With our automated trading software and monitoring system, trades are done 

automatic [sic] for members with no risk. Finally the best way to trade with 

no experience. 'Put your bitcoin to work for you'." ( emphasis in original) 

22. The GTC marketing materials further represented that customers could join one of 

multiple GTC membership levels, ranging from $250 ("Entrepreneur" level) to $31,000 

("Founder Trader" level). The GTC marketing materials set forth guaranteed specific daily 

earnings, which would increase based on the customer's membership level at GTC. 

23. The GTC marketing materials offered further earnings through its multi-level 

marketing structure, under which customers could earn additional money by referring new 

customers to GTC. Customers were promised a cash bonus for each direct referral, in the 

amount of 20 percent of the deposit made by the referred customer. Customers were further 

offered bonuses for indirect referrals and a "binary matching bonus" for multi-level marketing 

"teams." The amount of the bonuses increased if customers made additional deposits with GTC, 

which placed them at a higher membership level within GTC. 

24. The Castaneda Defendants made representations similar to those set forth in 

Paragraphs 21-23 above during the GTC seminars described in Paragraph 1 9. 

25. The representations set forth in Paragraphs 21-23 above are false. GTC employed 

no traders, and neither created nor used any trading robots. Accordingly, GTC customer capital 

was not "being traded in a real time environment, by our expert traders and cutting edge trading 

robots 24 hours a day, 7 days a week." Additionally, one or more GTC customers did not 

receive any daily earnings or referral bonuses. 

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26. The Castaneda Defendants concealed their fraudulent conduct by causing 

misleading trading statements to be posted online. GTC customers could access the online 

statements by logging into a web site and/or the GTC Digital app, using a username and 

password. Once logged in, customers could see how much money they had earned from GTC's_ 

purported trading on their behalf. These misleading trading statements did not accurately reflect 

the Bitcoin trading purportedly undertaken by the Castaneda Defendants and led at least certain 

customers to believe they were earning significant profits from their Bitcoin trading. 

B. Conclus~nsofLaw 

Jurisdiction and Venue 

27. The Court has jurisdiction over this action pursuant to 28 U .S.C. § 1331 (2018) 

(federal questionjurisdiction) and 28 U.S.C. § 1345 (2018) (district coLn1s have original 

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

authorized to sue by Act of Congress). In addition, Section 6c of the Act, 7 U.S.C. § 13a-1 

(2018), provides that United States district courts possess jurisdiction to hear actions brought by 

the CFTC for injunctive relief or to enforce compliance with the Act whenever it shall appear to 

the CFTC 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. 

28. Venue properly lies with this Cou11 pursuant to 7 U.S.C. § 13a-l(e) because the 

Castaneda Defendants reside in this District, transact or transacted business in this District, 

and/or certain transactions, acts, practices and courses of business alleged in this Complaint 

occurred within this District, among other places. 

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Fraud by Deceptive Device or Contrivance 

Violations of Section 6(c)(l) of the Act, 7 U.S.C. § 9(1) (2018) 

and Regulation 180.l(a), 17 C.F.R. § 180.l(a) (2020) 

29. 7 U.S.C. § 9(1) provides, in relevant part: 

It shall be unlawful for any person, directly or indirectly, to use or 

employ or attempt to use or employ, in connection with any swap, 

or a 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, in 

contravention of such rules and regulations as the Commission shall 

promulgate .... 

30. 17 C.F.R. § 180.1 provides, in relevant part: 

(a) It shall be unlawful for any person, directly or indirectly, in 

connection with any swap, or contract of sale of any commodity 

in interstate commerce, or contract for future delivery on or 

subject to the rules of any registered entity, to intentionally or 

recklessly: 

(I) 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; 

(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, .... 

31. Digital assets such as Bitcoin are encompassed in the definition of "commodity" 

under Section la(9) of the Act, 7 U.S.C. § la(9) (2018). 

32. During the Relevant Period, the Castaneda Defendants intentionally or recklessly 

used or employed manipulative or deceptive devices or contrivances, in connection with 

contracts of sale of a commodity in interstate commerce, including: 

a. Misrepresenting that GTC employed "over 75 master traders" who had years of 

trading experience; 

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b. Misrepresenting that GTC customer moneys were being traded "by our expert 

traders and cutting edge trading robots 24 hours a day, 7 days a week"; 

c. Misrepresenting that GTC customers could achieve specific daily earnings; 

d. Misrepresenting that GTC customers could earn bonuses by referring other 

customers to GTC; and 

e. Causing falsified information to be posted to a GTC web site and GTC Digital 

app that misrepresented the purported profits being earned by and for 

customers. 

33. By the conduct described in paragraphs 14 through 26 above, the Castaneda 

Defendants violated 7 U.S.C. § 9(1) by directly or indirectly employing or attempting to use or 

employ, in connection with a swap, or a contract of sale of a commodity in interstate commerce, 

or for future delivery on or subject to the rules of any registered entity, a manipulative or 

deceptive device or contrivance upon customers of GTC. 

IV. PERMANENT INJUNCTION 

IT IS HEREBY ORDERED THAT: 

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

of the Act, 7 U.S.C. § 13a-l (2018), the Castaneda Defendants are permanently restrained, 

enjoined and prohibited from directly or indirectly: 

a. Using or employing or attempting to use or employ, in connection with any swap, 

or a 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, in violation of 6(c)(l) of the Act, 7 U.S.C. § 9(1) 

(2018); 

b. In connection with any swap, or contract of sale of any commodity in interstate 

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

registered entity, to intentionally or recklessly: (i) using or employing, or 

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attempting to use or employ, any manipulative device, scheme, or artifice to 

defraud; (ii) 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 (iii) 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, in violation of Regulation 180.1 (a), 

17 C.F.R. § 180.1 (a) (2020); 

35. The Castaneda 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 la(40) ofthe Act, 7 U.S.C. § la(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 (2020), 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 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; 

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 CFTC 

in any capacity, and engaging in any activity requiring such registration or 

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exemption from registration with the CFTC, except as provided for in Regulation 

4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2020); and/or 

g. Acting as a principal (as that term is defined in Regulation 3. l(a), 17 C.F.R. 

§ 3.l(a) (2020)), agent or any other officer or employee of any person (as that 

term is defined in 7 U.S.C. § la(38)), registered, exempted from registration or 

required to be registered with the CFTC except as provided for in 17 C.F.R. 

§ 4.14(a)(9) (2020). 

V. RESTITUTION 

36. The Castaneda Defendants, jointly and severally, shall pay restitution in the 

amount of nine hundred, eighty-nine thousand, five-hundred, fifty dollars ($989,550) 

("Restitution Obligation"). 

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

restitution payments to GTC's customers, the Court appoints the National Futures Association 

("NF A") as Monitor ("Monitor"). The Monitor shall receive restitution payments from the 

Castaneda Defendants and make distributions as set fo11h below. Because the Monitor is acting 

as an officer of this Court in performing these services, the NF A shall not be liable for any action 

or inaction arising from NF A's appointment as Monitor, other than actions involving fraud. 

38. The Castaneda Defendants shall make Restitution Obligation payments under this 

Consent Order to the Monitor in the name "Castaneda, Cesar and Joel - 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 

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proceeding. The paying Defendant 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. 

39. 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 GTC's customers 

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

appropriate. 

40. The Castaneda Defendants shall cooperate with the Monitor as appropriate to 

provide such information as the Monitor deems necessary and appropriate to identify GTC's 

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

distribution of any Restitution Obligation payments. The Castaneda Defendants 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. 

41. The Monitor shall provide the CFTC at the beginning of each calendar year with a 

report detailing the disbursement of funds to GTC's 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. 

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

customer from proving that a greater amount is owed from the Castaneda Defendants or any 

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

rights of any GTC customer that exist under state or common law. 

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43. Pursuant to Rule 71 of the Federal Rules of Civil Procedure, each OTC 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 the Castaneda Defendants to ensure continued 

compliance with any provision of this Consent Order and to hold the Castaneda Defendants in 

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

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

Castaneda Defendants' Restitution Obligation, such funds shall be transferred to the Monitor for 

disbursement in accordance with the procedures set forth above. 

VI. CIVIL MONETARY PENALTY 

45. Cesar Castaneda and Joel Castaneda Garcia shall each pay a civil monetary 

penalty in the amount of one-hundred, eighty thousand dollars ($180,000.00) ("CMP 

Obligations"), plus post-judgment interest. 

46. Post-judgment interest shall accrue on the CMP Obligations 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. 

47. The Castaneda Defendants shall pay their respective CMP Obligations 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: 

MAC/ESC/ AMK326 

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Commodity Futures Trading Commission 

Division of Enforcement 

6500 S. MacArthur Blvd. 

HQ Room 181 

Oklahoma City, OK 73169 

(405) 954-6569 office 

(405) 954-1620 fax 

9-AMC-AR-CFTC@faa.gov 

48. If payment by electronic funds transfer is chosen, the Castaneda Defendants shall 

contact Marie Thorne or her successor at the address above to receive payment instructions and 

shall fully comply with those instructions. The Castaneda Defendants shall accompany payment 

of the CMP Obligation with a cover letter that identifies the paying Defendant and the name and 

docket number of this proceeding. The paying Defendant 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, N.W., Washington, D.C. 20581, 

and Aimee Latimer-Zayets, Chief Trial Attorney, Commodity Futures Trading Commission, 

Division of Enforcement, 1155 2l5t Street, N.W., Washington, D.C. 20581. 

VII. MISCELLANEOUS PROVISIONS 

49. Partial Satisfaction: Acceptance by the CFTC or the Monitor of any partial 

payment of the Castaneda Defendants' Restitution Obligation shall not be deemed a waiver of 

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

CFTC's right to seek to compel payment of any remaining balance. 

50. The Castaneda Defendants shall cooperate fully and expeditiously with the CFTC, 

including the CFTC's Division of Enforcement, in this action, and in any current or future CFTC 

investigation or action related thereto. The Castaneda Defendants shall also cooperate in any 

investigation, civil litigation, or administrative matter related to, or arising from, the subject 

matter of this action. 

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

shall be sent ce11ified mail, return receipt requested, as follows: 

Notice to CFTC: 

Richard Glaser, Deputy Director 

Division of Enforcement 

Commodity Futures Trading Commission 

1155 21 st Street, NW 

Washington, DC 20581 

Notice to the Castaneda Defendants: 

J. Mark Brewer 

800 Bering Dr., Suite 201 

Houston, TX 77057 

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

52. Change of Address/Phone: Until such time as the Castaneda Defendants satisfy in 

full their Restitution Obligation as set fo11h in this Consent Order, the Castaneda Defendants 

shall provide written notice to the CFTC by certified mail of any change to their respective 

telephone numbers and mailing addresses within ten calendar days of the change. 

53. 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 par1ies hereto; and (c) approved by order of this Com1. 

54. 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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55. Waiver: The failure of any party to this Consent Order or of any client at any 

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

right of the party or client 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. 

56. Waiver of Service, and Acknowledgement: The Castaneda Defendants waive 

service of this Consent Order and agree that entry of this Consent Order by the Court and filing 

with the Clerk of the Court will constitute notice to the Castaneda Defendants of its terms and 

conditions. 

57. 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 either of the Castaneda Defendants to modify or for relief from 

the terms of this Consent Order. 

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

provisions of this Consent Order shall be binding upon the Castaneda Defendants, upon any 

person under their 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 the Castaneda Defendants. 

59. 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 

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 

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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. 

60. Contempt: The Castaneda Defendants understand that the terms of the Consent 

Order are enforceable through contempt proceedings, and that, in any such proceedings they may 

not challenge the validity of this Consent Order. 

61. Agreements and Undertakings: The Castaneda Defendants shall comply with all 

of the undertakings and agreements set fo11h in this Consent Order. 

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 against Defendants Cesar 

Castaneda and Joel Castaneda Garcia forthwith and without further notice. 

IT IS SO ORDERED on this 2,+~day of_~-"~\Y1-------' 2021. 

SIM AKE 

UNITED STATES DISTRICT JUDGE 

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CONSENTED TO AND APPROVED 

BY: 

Aimee Latimer-Zayets Cesar Castaneda 

James A. Garcia 

Commodity Futures Trading Commission 

1155 2 I st Street, NW Dated: ------------- Washington, DC 20581 

Tel: (202) 418-7626 

(202) 418-5362 

Email: alatimer-zayets@cftc.gov 

jgarcia@cftc.gov 

Counsel for Commodity Futures 

Trading Commission 

Dated: 7/23/2021 ------------

Joel Castaneda Garcia 

Dated: -------------

J. Mark Brewer 

800 Bering Dr., Suite 201 

Houston, TX 77057 

Tel: (713) 725-4788 

Email: brewer@bplaw.com 

Counsel for Cesar Castaneda and 

Joel Castaneda Garcia 

Dated: --------------

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Case 4:20-cv-03185 Document 56 Filed on 07/26/21 in TXSD Page 18 of 20
CONSENTED TO AND APPROVED 

BY: 

Aimee Latimer-Zayets 

James A. Garcia 

Commodity Futures Trading Commission 

1155 2l81 Street, NW 

Washington, DC 20581 

Tel: (202) 418-7626 

(202) 418-5362 

Email: alatimer-zayets@cftc.gov 

jgarcia@cftc.gov 

Counsel for Commodity Futures 

Trading Commission 

Dated: -----------

Cesar Castaneda 

Dated: ------------

Joel Ca~eda Garcia 

Dated: Q ¢1/ioJJ 

J.~Pif!?~ 

Br9Wer & Pritchard, P.C. 

Tfb S. Post Oak Lane, Suite 620 

Houston, TX 770561. 

Tel: (713) 209-2910 

Email: brewer@bplaw.com 

Counsel for Cesar Castaneda and 

Joel Castaneda Garcia 

Dated: _s;;;._idc..::__d'_( _,_)ec:;__l1-------

18 

Case 4:20-cv-03185 Document 56 Filed on 07/26/21 in TXSD Page 19 of 20
CONSENTED TO AND APPROVED 

BY: 

Aimee Latimer-Zayets 

James A. Garcia 

Commodity Futures Trading Commission 

1155 21 st Street, N\V 

Washington, DC 20581 

Tel: (202) 418-7626 

(202) 418-5362 

Email: alatimer-zayets@cftc.gov 

jgarcia@cftc.gov 

Counsel for Commodity Futures 

Trading Commission 

Dated: ------------

Cesar Castaneda 

Dated: 05/19/2021 

Joel Castaneda Garcia 

Dated: 

J. ark rewer 

89 Bering Dr., Suite 201 

If ouston, TX 77057 

Tel: (713) 725-4788 

Email: brewer@bplaw.com 

Counsel for Cesar Castaneda and 

Joel Castaneda Garcia 

Dated: *c/2,( I 

18 

Case 4:20-cv-03185 Document 56 Filed on 07/26/21 in TXSD Page 20 of 20