Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 1 of 26 PageID 352

fN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

COMMODITY FUTURES 

TRADfNG COMMISS ION, 

Plaintiff, 

V. 

COQUEST INC., BUTTONWOOD LLC, 

WEVA PROPERTIES LTD., DENNIS 

WEINMANN, and JOHN VASSALLO, 

Defendants. 

Case No.: 3:21-cv-2599 

Judge Karen Gren Scholer 

CONSENT ORDER FOR PERMANENT INJUNCTION, CIVIL MONETARY PENALTY 

AND OTHER EQUITABLE RELIEF AGAINST COQUEST INC., BUTTONWOOD 

LLC, WEVA PROPERTIES LTD., DENNIS WEINMANN, AND JOHN VASSALLO ~ 

I. INTRODUCTION 

On October 20, 202 1, Plaintiff Commodity Futures Trading Commission ("Commission" 

or "CFTC") filed a Complaint against Defendants Coquest Inc., Buttonwood LLC, Weva 

Properties Ltd., Dennis Weinmann, and John Vassallo (" Defendants") seeking injunctive and other 

equitable reli ef, 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 (202 1). 

II. CONSENTS AND AGREEMENTS 

To effect settlement of all charges alleged in the Complaint against Defendants without a 

trial on the merits or any fwther judicial proceedings, Defendants: 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 2 of 26 PageID 353

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

Penalty, and Other Equitable Relief Against Defendants Coquest Inc., Buttonwood LLC, Weva 

Properties Ltd., Dennis Weinmann, and John Vassallo ("Consent Order''). 

2. Affirm that they 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 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-l. 

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 Court pursuant to 7 U.S.C. § 13a-l(e). 

7. Waive: 

(a) 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 (2021 ), 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; 

(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. 

2 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 3 of 26 PageID 354

~ 8. Consent to the ~ ction 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 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 fa ils to comply with Rule 65(d) of the Federal Rules of Civil Procedure and hereby 

waives any objection based thereon. 

I 0. 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 the Findings of Fact or Conclusions of Law in this Consent Order, 

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 

CFTC is not a party. Defendants sha ll 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. 

11. Consent to the entry of this Consent Order without admitting or denying the 

allegations of the Complaint or any findings or conclusions in this Consent Order, except as to 

jurisdiction and venue, which they admit. 

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

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

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

effect therein, without further proof. 

3 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 4 of 26 PageID 355

13. Do not consent, however, to the use of this Consent Order, or the findings and 

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

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

proceeding to enforce the terms of this Order. 

14. 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 them 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, as set forth herein. 

THE PARTIES AGREE AND THE COURT HEREBY FINDS: 

A. Findings of Fact 

The Parties to this Consent Order 

15. Plaintiff Commodity Futures Trading Commission is an independent federal 

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

Regulations. 

16. Defendant Coquest Inc. ("Coquest") is a Texas corporation located in Dallas, 

Texas. Coquest has been registered with the Commission as an introducing broker ("IB") since 

1990. Coquest has also been registered with the Commission as a commodity trading advisor 

("CTA") from 1990-2012 and from 2020 to the present, and as a commodity pool operator from 

1990-1994 and from 2010 to the present. Coquest executes block trades in futures and options on 

4 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 5 of 26 PageID 356

behalf of brokerage customers, and Coquest's individual brokers are registered with the 

Commission as APs of Coquest. 

17. Defendant Buttonwood LLC ("Buttonwood") is a Texas limited liability company 

located in Dallas, Texas. Buttonwood has been registered with the Commission as a CT A since 

2014. Buttonwood trades commodity futures and options out of a single account, called the Galaxy 

Plus Fund, which solicits funds from customers. 

18. Defendant Weva Properties Ltd. ("Weva") is a Texas company located in Dallas, 

Texas. Weva is not registered with the Commission. Weva trades commodity futures and options 

in a proprietary account on behalf of its owners, Dennis Weinmann and John Vassallo. 

19. Defendant Dennis Weinmann ("Weinmann") is a 50% owner of Coquest, where he 

serves as vice president and acts as an AP and block trade broker. Weinmann is also a 50% owner 

of Buttonwood and Weva, where he works as a commodities trader. Weinmann has been listed 

with the National Futures Association ("NF A") as a principal and registered with the Commission 

as an AP ofCoquest since 1990. Weinmann has been listed as a principal with NFA and registered 

with the Commission as an AP of Buttonwood since 2014. 

20. Defendant John Vassallo ("Vassallo") is a 50% owner ofCoquest, where he serves 

as, among other things, president and compliance officer, and acts as an AP and block trade broker. 

Vassallo is also a 50% owner of Buttonwood and Weva. Vassallo has been listed as a principal 

with NFA and registered with the Commission as an AP ofCoquest since 1990. Vassallo has been 

listed as a principal with NF A and registered with the Commission as an AP of Buttonwood since 

2014. 

5 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 6 of 26 PageID 357

Coquest's Block Trade Brokerage Business 

21. Coquest facilitates block trades for its brokerage customers in futures contracts and 

options, including natural gas futures listed on CME and ICE. Block trades are privately 

negotiated transactions involving exchange-listed futures contracts that meet the minimum 

quantity threshold determined by the exchange. Block trades are privately negotiated transactions 

which are executed by agreement apart and away from the open outcry or electronic markets, and 

then reported as executed on an exchange' s trading facility, as permitted under exchange rules. 

22. Coquest is a "voice broker" that solicits and receives requests from its customers to 

enter into block trades via phone, voice box, or instant message ("IM"). Coquest then locates 

potential counterparties for the requested block trades either from among Coquest's other 

customers or the customers of another voice broker. 

23. Customers provided Coquest and its brokers with access to such confidential 

information with the understanding and the expectation that the information would be used to 

arrange block trades with third parties, and would not otherwise be used to the customers' 

disadvantage. 

24. When locating potential counterparties for requested block trades, Coquest brokers 

necessarily disclose to other market participants the existence of a potential buyer or seller of a 

particular contract, as well as price and quantity information, but they do not disclose the identity 

of the customer making the block trade request. Coquest is generally, but not always, paid a 

commission for each block trade it executes on behalf of its customers. 

25. Coquest and its customers understood and agreed that Coquest acted as an agent of 

its customers with authority to bind them in transactions involving natural gas futures and other 

products, including block trades in natural gas futures contracts listed on CME and ICE. 

6 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 7 of 26 PageID 358

Weinmann Misappropriated Confidential Customer Information and Unlawfully 

Took the Other Side of His Customers' Block Trades 

26. Between May 28, 2015, and September 25, 2019, Weinmann, acting as an AP of 

Coquest, received block trade requests from Coquest's customers for energy futures contracts. 

27. During this period, Weinmann also traded in the same futures and options contracts 

for which he was brokering block trades for Coquest's customers through two accounts he 

controlled. The first account is managed by Buttonwood, an entity for which Weinmann is a 50% 

owner and the sole trader. Buttonwood trades a single account, called the Galaxy Plus Fund, on 

behalf of investors. Buttonwood keeps a portion of the trading profits from the Galaxy Plus Fund 

as an incentive fee, and also charges a management fee to investors. 

28. The second account is owned by Weva, another entity for which Weinmann is a 

50% owner and the sole trader. The Weva account is a proprietary trading account, with profits 

flowing to Weinmann and Vassallo. 

29. On more than two thousand instances between May 28, 2015 and September 25, 

2019, Weinmann received requests from Coquest customers for block trades in various futures or 

options contracts. Instead of locating a counterparty from among Coquest' s other customers or 

the customers of another voice broker, Weinmann executed block trades on behalf of Buttonwood 

or W eva as a counterparty opposite Coquest customers without their customers' prior consent, 

knowing that the Buttonwood and W eva accounts were taking the other side of the customers' 

block trades. 

30. Weinmann did not disclose to Coquest's customers, either at the time the block 

trades were executed or at any other time, that he was taking the other side of their requested block 

trades in accounts that he controlled. In fact, Weinmann sometimes made statements to customers 

7 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 8 of 26 PageID 359

indicating that there was some other third party on the other side of the requested block trade who 

was negotiating with the brokerage customer. 

31. By executing block trades between the Buttonwood and Weva accounts and 

Coquest's customers in this manner, Weinmann misappropriated material, nonpublic information 

from Coquest customers by trading on the customers' block trade orders in violation of his duties 

to the customers. Weinmann also created the false impression that he was acting as a broker, not 

a potential block trade counterparty, and led Coquest's customers to think that the bids and offers 

he provided reflected bids or offers available from other market participants, when in fact those 

bids and offers reflected prices at which Weinmann was willing to execute a block trade in the 

Buttonwood or Weva account. Weinmann sometimes reinforced this false impression by charging 

his customers brokerage commissions on the block trades between his customers and the 

Buttonwood or Weva account in the same way as he did for trades he brokered between his 

customers and other market participants. 

32. Through this scheme, Weinmann was able to obtain for the Buttonwood and Weva 

accounts block trade prices that would not have been available if Weinmann were openly 

participating as a trader in the block trade market. Weinmann realized trading profits for the 

Buttonwood and Weva accounts by personally offsetting the block trade positions he established 

with Coquest's customers with either other block trades or trades executed on CME's or ICE's 

electronic trading platform. 

33. Defendants represent that prior to the enactment of the Dodd-Frank Wall Street 

Reform and Consumer Protection Act, Pub. L. No. 111-203, § 929P(b), 124 Stat. 1376, 1864-65 

(2010), Defendants routinely disclosed, as was required by CFTC regulations, when one of their 

entities took the other side of a customer's block trade. The Defendants represent, however, that 

8 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 9 of 26 PageID 360

after the Dodd-Frank Act amended the CEA, the Defendants stopped disclosing when Defendants 

were taking the opposite side of customer orders until they were informed in late 2019 that brokers 

were still required to make such disclosures under Commission regulations. The Defendants 

thereafter represent that they have consistently disclosed to customers when they were acting as 

counterparties to their customers' trades. 

Coquest, Buttonwood, Vassallo, and Weinmann Failed to Supervise 

34. As a registered IB, Coquest was obligated under Regulation 166.3, 17 C.F .R. 

§ 166.3 (2021 ), to diligently supervise the handling of all commodity interest accounts introduced 

by Coquest and all other activities of its partners, officers, employees, and agents. 

35. As associated persons ("APs") of Coquest with supervisory duties, Vassallo and 

Weinmann also had a duty to diligently supervise. From at least May 28, 2015 through September 

25, 2019, Coquest, Vassallo, and Weinmann failed to ensure that Coquest had an adequate system 

of oversight in place to detect or prevent its brokers or other affiliated persons from either taking 

the other side of customer block trades in violation of Regulation 155.4, 17 C.F.R. § 155.4 (2021), 

or misappropriating material, nonpublic information from Coquest' s customers. 

36. For example, Coquest did not have written policies in place setting forth 

Commission and exchange rules regarding the duties of a broker and did not have any rules in 

place regarding trading against brokerage customers. Coquest also did not have any procedures in 

place to monitor or review the activities of Coquest's brokers. 

37. Vassallo, Coquest's president, principal, and compliance officer, was generally 

aware that Weinmann was trading for the Buttonwood and Weva accounts while also brokering 

block trades for Coquest's customers. But Vassallo did not supervise Weinmann's brokerage or 

9 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 10 of 26 PageID 361

trading activity or take any other steps to determine whether Weinmann was trading in the 

Buttonwood and Weva accounts in violation of his duties to Coquest's customers. 

38. As a registered CT A, Buttonwood was obligated under 17 C.F .R. § 166.3 to 

diligently supervise the handling of all commodity interest accounts introduced by Coquest and all 

other activities of its partners, officers, employees, and agents. 

39. As associated persons ("APs") of Buttonwood with supervisory duties, Vassallo 

and Weinmann also had a duty to diligently supervise. From at least May 28, 2015 through 

September 25, 2019, Buttonwood, Vassallo, and Weinmann failed to ensure that Buttonwood had 

an adequate system of oversight in place to detect or prevent Weinmann from trading on material, 

nonpublic information that he knew had been misappropriated from Coquest' s customers. 

40. For example, Buttonwood did not have written policies in place setting forth 

Commission and exchange rules regarding trading on material, nonpublic information and also did 

not have any procedures in place to monitor or review the activities of Buttonwood's traders. 

B. Conclusions of Law 

Jurisdiction and Venue 

41. This Court possesses jurisdiction over this action pursuant to 28 U.S.C. § 1331 

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

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

expressly authorized to sue by Act of Congress). Section 6c(a) of the Act, 7 U.S.C. § 13a-l(a), 

provides that the CFTC may bring actions for injunctive relief or to enforce compliance with the 

Act or any rule, regulation, or order thereunder in the proper district court of the United States 

whenever it shall appear to the CFTC that any person has engaged, is engaging, or is about to 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 11 of 26 PageID 362

engage in any act or practice constituting a violation of any provision of the Act or any rule, 

regulation, or order thereunder. 

42. Venue properly lies with this Court pursuant to 7 U.S.C. § 13a-l(e), because 

Defendants reside in this jurisdiction and the acts and practices in violation of the Act occurred 

within this District. 

Fraud by Misappropriation of Material, Nonpublic Information and Failure to 

Supervise 

43. By the conduct described in paragraphs 1 through 41 above, Defendants 

Weinmann, and Vassallo knowingly took the other side of customer orders revealed to Coquest or 

any of its affiliated persons by reason of the customers' relationship with Coquest without the 

customers' prior consent in violation of Regulation 155.4(b)(2)(i), 17 C.F.R. § 155.4(b)(2)(i) 

(2021). 

44. By the conduct described in paragraphs 1 through 41 above, Defendant Weinmann 

cheated and defrauded, or attempted to cheat and defraud, and willfully deceived, or attempted to 

deceive, Coquest's customers by, in connection with contracts for future delivery and options on 

futures on or subject to the rules of any registered entity: (i) intentionally or recklessly trading on 

the basis of material, nonpublic information in breach of a pre-existing duty owed to Coquest 

customers; (ii) intentionally or recklessly trading against Coquest customers at prices less 

favorable than he knew or should have known to be available in the market in order to benefit 

Buttonwood and W eva at the Coquest customers' expense; (iii) intentionally or recklessly 

deceiving or attempting to deceive customers into believing that he was reporting bids and offers 

made by some third party trading counterparty when in fact Weinmann was making the bids or 

offers on behalf of accounts that he traded; and/or (iv) intentionally or recklessly engaging, or 

attempting to engage, in acts, practices, or a course of business which operated or would operate 

11 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 12 of 26 PageID 363

as a fraud or deceit upon other persons in violation of Section 6(c)(l) of the Act, 7 U.S.C. § 9(1) 

and Regulation 180.l(a)(l)-(3), 17 C.F.R. § 180.l(a)(l)-(3) (2021). 

45. By the conduct described in paragraphs 1 through 41 above, Defendant Weinmann 

cheated or defrauded, or attempted to cheat or defraud, willfully made or caused to be made false 

reports and statements to, and willfully deceived, or attempted to deceive, Coquest' s customers in 

connection with orders for or on behalf of other persons to make contracts of sale of commodities 

for future delivery subject to the rules of a designated contract market by, in connection with orders 

for or on behalf of other persons to make contracts of sale of commodities for future delivery 

subject to the rules of a designated contract market: (i) intentionally or recklessly trading on the 

basis of material, nonpublic information in breach of a pre-existing duty owed to Coquest 

customers; (ii) intentionally or recklessly trading against Coquest customers at prices less 

favorable than he knew or should have known to be available in the market in order to benefit 

Buttonwood and Weva at the Coquest customers' expense; (iii) intentionally or recklessly 

deceiving or attempting to deceive customers into believing that he was reporting bids and offers 

made by some third party trading counterparty when in fact Weinmann was making the bids or 

offers on behalf of accounts that he traded; and/or (iv) intentionally or recklessly cheating, 

defrauding, attempting to cheat or defraud, deceiving, and attempting to deceive other persons in 

regard to their orders or executions of orders or in regard to the acts of agency performed for the 

other persons in violation of Section 4b(a)(l)(A)-(C) of the Act, 7 U.S.C. § 6b(a)(l)(A)-(C). 

46. By the conduct described in paragraphs 1 through 41 above, Defendants Weinmann 

and Vassallo failed to diligently supervise the handling of commodity interest accounts and 

activities relating to Coquest and Buttonwood's business as a Commission registrant by: (i) failing 

to establish, implement, and enforce policies or procedures to detect and prevent Weinmann and 

12 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 13 of 26 PageID 364

Vassallo's misuse of confidential customer information; (ii) failing to review Weinmann's trading 

on behalf of Buttonwood and W eva to determine whether it conflicted with his brokerage services 

he provided to Coquest customers; and (iii) failing to establish, implement, or enforce policies or 

procedures governing its brokers' handling of customer orders and the protection of confidential 

customer information in violation of Regulation 166.3, 17 C.F.R. § 166.3 (2021). 

4 7. The foregoing acts, omissions, and failures of Weinmann and Vassallo occurred within 

the scope of their employment, office, or agency with Coquest, Buttonwood, and Weva; therefore, 

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 

(2021 ), Coquest, Buttonwood, and Weva are liable for Weinmann and Vassallo' s acts, omissions, and 

failures in violation of 7 U.S.C. §§ 9(1) and 6b(a)(l)(A)-(C), and 17 C.F.R. §§ 155.4(b)(2)(i), 

180.l(a)(l)-(3), and 166.3. 

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

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. 

IV. PERMANENT INJUNCTION 

IT IS HEREBY ORDERED THAT: 

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

of the Act, 7 U.S.C. § 13a-l, all Defendants are permanently restrained, enjoined and prohibited 

from directly or indirectly: 

a. Knowingly taking the other side of any order of another person revealed to an 

introducing broker or any of its affiliated persons by reason of their relationship to 

such other person, except with such other person's prior consent in violation of 

Regulation 155.4(b)(2)(i), 17 C.F.R. § 155.4(b)(2)(i) (2021). 

13 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 14 of 26 PageID 365

50. Additionally, based upon and in connection with the foregoing conduct, pursuant 

to 7 U.S.C. § 13a-1, Defendants Coquest, Buttonwood, Weva, and Weinmann are permanently 

restrained, enjoined and prohibited from directly or indirectly: 

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

contract of sale of any commodity for future delivery on or subject to the rules of 

any registered entity, any manipulative or deceptive device or contrivance in 

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

b. Intentionally or recklessly 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 connection with any contract for future delivery on or subject to the rules 

of any registered entity in violation of Regulation 180.l(a)(l)-(3), 17 C.F.R. 

§ 180.l(a)(l)-(3) (2021); 

c. Cheating or defrauding, or attempting to cheat or defraud, willfully making or 

causing to be made false reports and statements to, and willfully deceiving, or 

attempting to deceive, other persons in or in connection with any order to make, or 

the making of, any contract of sale of any commodity for future delivery subject to 

the rules of a designated contract market that is made, or to be made, for or on 

behalf of, or with, any other person in violation of Section 4b(a)(l)(A)-(C) of the 

Act, 7 U.S.C. § 6b(a)(l )(A)-(C); 

51. Additionally, based upon and in connection with the foregoing conduct, pursuant 

to 7 U.S.C. § 13a-1, Defendants Coquest, Buttonwood, Weinmann, and Vassallo are permanently 

restrained, enjoined and prohibited from directly or indirectly: 

14 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 15 of 26 PageID 366

a. Failing to diligently supervise the handling by their partners, officers, employees, 

and agents of all commodity interest accounts carried, operated, advised, or 

introduced by these Defendants and all other activities of their partners, officers, 

employees, and agents relating to these Defendants' business as Commission 

registrants in violation of Regulation 166.3, 17 C.F.R. § 166.3 (2021). 

52. With the exception set forth in subparagraph 51 (h)below, Defendant Weinmann is 

also restrained, enjoined and prohibited for a period of six months 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) of the Act, 7 U.S.C. § la(40)); 

b. Entering into any transactions involving "commodity interests" ( as that term is 

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

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

c. Other than for commodity trading interests traded by Buttonwood, having any 

commodity interests traded on his behalf; 

d. Controlling or directing the trading for or on behalf of any other person or entity, 

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

interests; 

e. Soliciting, receiving or accepting any orders or funds from any person for the 

purpose of purchasing or selling any commodity interests, soliciting any 

discretionary accounts, or supervising any person or persons so engaged; 

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

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

15 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 16 of 26 PageID 367

registration or exemption from registration with the Commission, except as 

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

g. Other than for Defendants Coquest and Buttonwood, acting as a principal (as that 

term is defined in Regulation 3.l(a), 17 C.F.R. § 3.l(a) (2021)), agent or any other 

officer or employee of any person (as that term is defined in Section la(38) of the 

Act, 7 U.S.C. § la(38)), registered, exempted from registration or required to be 

registered with the Commission except as provided for in 17 C.F.R. § 4.14(a)(9); 

h. Notwithstanding the foregoing, throughout the six-month period Defendant 

Weinmann may assist in the liquidation of pre-existing positions that were held by 

Buttonwood, LLC at the commencement of the six month period, so long as the 

liquidation trades are not brokered by Coquest, Inc. 

53. In addition to the restraints, injunctions and prohibitions in subparagraph 51 above, 

Defendants Coquest and Weinmann are further restrained, enjoined and prohibited from directly 

or indirectly brokering block trades on behalf of any other person for a period of two years. 

V. RESTITUTION, DISGORGEMENT, AND CIVIL MONETARY PENALTY 

A. Disgorgement 

54. Defendants shall pay, jointly and severally, disgorgement in the amount of four 

hundred ninety-six thousand and twenty-one dollars ($496,021) ("Disgorgement Obligation"), 

representing the gains received in connection with such violations. The Disgorgement Obligation 

will be offset by the amount paid to the CME Group ( or any of its subsidiary exchanges) in 

satisfaction of the disgorgement order in the disciplinary action against the Defendants captioned 

NYMEX 17-0744-BC. Defendants shall provide the CFTC proof of any payment of disgorgement 

to the CME Group ( or any of its subsidiary exchanges), including the case name and number in 

16 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 17 of 26 PageID 368

connection with which such payment has been made, and the amount by which the Disgorgement 

Obligation is to be reduced, within IO days of the entry of this Consent Order. If the Disgorgement 

Obligation is not paid in full immediately, then post-judgment interest shall accrue on the unpaid 

portion of the Disgorgement Obi igation 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. 

55. Defendants shal I pay their Disgorgement Obi igation and any post-judgment interest 

by electronic funds transfer, U.S. postal money order, ce1tified check, bank cashier's check, or 

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

payment shall be made payable to the Commodity Futures Trading Commission and sent to the 

address below: 

MMAC/ESC/ AMK326 

Commodity Futures Trading Commission 

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73169 

9-amz-ar-cftc@faa.gov 

lf payment by electronic funds transfer is chosen, Defendants shall contact Tonia King or her 

successor at the address above to receive payment instructions and shall fully comply with those 

instructions. Defendants shall accompany payment of the Disgorgement Obligation with a cover 

letter that identifies Defendants and the name and docket number of this proceeding. 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. 

17 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 18 of 26 PageID 369

B. Civil Monetary Penalty 

56. Defendants shall pay, jointly and severally, a civil monetary penalty in the amount 

of two million five hundred thousand ($2,500,000) ("CMP Obligation"). The CMP Obligation 

shall be payable as follows: one third of the CMP Obligation ($833,333.33) is due within 30 days 

after the entry of the Consent Order; and additional third of the CMP Obligation ($833,333.33) is 

due within 60 days after the entry of the Consent Order; and the final third of the CMP Obligation 

($833,333.34) is due within 90 days after entry of the Consent Order. If the CMP Obligation is 

not paid in full immediately within 90 days after the entry of this Consent Order, then postjudgment interest shall accrue on the unpaid portion of the CMP Obligation beginning on the date 

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

o n the date of entry of this Consent Order pursuant to 28 U.S.C. § 196 1. 

57. Defendants shall pay their CMP Obligation and any post-judgment inte rest, by 

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

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

shall be made payable to the Commodity Futures Trading Commission and sent to the address 

below: 

MMAC/ESC/AMK326 

Commodity Futures Trading Commission 

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73 I 69 

9-amz-ar-cftc@faa.gov 

If payment by electronic funds transfer is chosen, Defe ndants shall contact Tonia King or her 

successor at the address above to receive payment instructions and shall fully comply with those 

instructions. Defendants shall accompany payment of the CM P Obligation with a cover letter that 

identifies Defe ndants and the name and docket number of this proceeding. Defendants shall 

18 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 19 of 26 PageID 370

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

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

Washington, D.C. 20581. 

C. Provisions Related to Monetary Sanctions 

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

payment of Defendants Restitution Obligation, Disgorgement Obligation, or 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 CFTC's right to seek to compel payment of any remaining balance. 

D. Cooperation 

59. 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. Defendants shall also cooperate in any investigation, civil litigation, or 

administrative matter related to, or arising from, this action. As part of such cooperation, 

Defendants Buttonwood and Weinmann agree to: 

A. Within ten days of the entry of this Consent Order, send the CFTC a report of all positions 

held by Buttonwood, LLC as of the date that this Consent Order is entered; 

B. On a monthly basis during the pendency of the six-month period described in paragraph 

51, above, provide the CFTC with a report of all trades, including identification of the 

trader for each trade, made on behalf of Buttonwood LLC; and 

C. At the conclusion of the six-month period described in paragraph 51, certify to the 

Commission that Weinmann complied with the restrictions described in paragraph 51, 

above. 

19 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 20 of 26 PageID 371

VI. MISCELLANEOUS PROVISIONS 

60. Until such time as Defendants satisfy in full their CMP and disgorgement 

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

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

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 

Legal Division 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st StreetN.W. 

Washington, DC 20581 

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

except as set forth in paragraph 59, above, shall be sent certified mail, return receipt requested, as 

follows: 

Notice to CFTC: 

Robert Howell 

Deputy Director 

77 W Jackson Blvd; Suite 800 

Chicago, IL 60604 

Notice to Defendants: 

Aitan Goelman 

Zuckerman Spaeder LLP 

1800 M Street, NW, Suite 1000 

Washington, DC 20036 

agoelman@zuckerman.com 

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

20 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 21 of 26 PageID 372

62. Change of Address/Phone: Until such time as Defendants satisfy in fu ll the ir 

Restitution Obligation, Disgorgement Obligation, and CMP Obligation as set forth in this Consent 

Order, Defendants shall provide written notice to the Commission by certified mai I of any change 

to their telephone number and mailing address within ten ca lendar days of the change. 

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

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

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

(b) signed by a ll pa1ties hereto; and (c) approved by order of this Cowt. 

64. 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 c ircumstance shall not be affected by the 

holding. 

65. Waiver: The fai lure of any party to this Consent Order at any time to require 

performance of any provision of this Consent Order sha ll in no manner affect the right of the party 

at a later time to enforce the same or any other provision of this Consent Order. No wa iver in one 

or more instances of the breach of any provision conta ined 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. 

21 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 22 of 26 PageID 373

67. Injunctive and Equitable Relief Provisions: 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: (I) Defendants; (2) any officer, 

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

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

68. Authority: John Vassallo hereby warrants that he is Partner at Coquest Inc., 

Buttonwood LLC, and Weva Properties Ltd., and that this Consent Order has been duly authorized 

by Coquest Inc., Buttonwood LLC, and Weva Properties Ltd. and he has been duly empowered to 

sign and submit this Consent Order on behalf of Coquest Inc., Buttonwood LLC, and Weva 

Properties Ltd. 

69. 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 

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. 

70. Contempt: Defendants understand that the terms of the Consent Order, except 

with respect to disgorgement or restitution, are enforceable through contempt proceedings, and 

that, in any such proceedings they may not challenge the validity of this Consent Order. 

71. Agreements and Undertakings: Defendants shall comply with all of the 

undertakings and agreements set forth in this Consent Order. 

22 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 23 of 26 PageID 374

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

Consent Order for Permanent Injunction, Civil Monetary Penalty, and Other Equitable Relief 

Against Coquest Inc., Buttonwood LLC, Weva Properties Ltd., Dennis Weinmann, and John 

Vassallo forthwith and without further notice. 

23 
Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 24 of 26 PageID 375

COl\:SEN l ED ro AND APPROVED BY: 

lohn Vai.?1:1110 

1•11rlncr 11fCo,1u~~, Inc. 

~~v~d4 

(lohn V:1.-,s11l111 

lfnrtncr uf Uuctum, ootl LLC 

_ V (JJ~ ~o 

~lo n \',1<i.snU11 -----·---

lP-:i ·tucr of W crn P ropcrtics Ltd. 

Date: / - 30 · 2.tJ Z3 

"~ / -~:~I' ~ Dennis Weinmann. imli\'ic.lunllv 

Date: / LS-1/ ) . / / _, 

v~~ 

".'~ iton C oclman 

i\lnrk .I. f-easler 

Attomc\'s for nil DefemJants 

Zuc:k~nimo Spai.:di:r LLP 

I ROO \1 E.;trc.ct, N\\', Suite IOOO 

OouglilS 0. Snoc.l~rais 

Nir.a RU\ins~y 

Dmid ,\. T crrdl 

Anomcys for 

Commoc.lil~• ru1uri.:s Trading Commission 

525 W. l\lonroc Strctt. Suite 1100 

Chicago, IL 6066 l 

Telephone: (312) 596-0700 

Facsimile: (312) 5%-0714 

E-mail: llsnodgmss1!;cnc.go,, 

D,1tc 

24 

MJ\•insky@cflc.gO\' 

di err cl l@c lie.yo,· 

-----·-----
25 

Washington, DC 20036

Telephone: (202) 778-1800 

E-mail: agoelman@zuckerman.com 

mfeaster@zuckerman.com

Case 3:21-cv-02599-S Document 51 Filed 03/07/23 Page 25 of 26 PageID 376
John Vassallo 

Partner of Buttonwood LLC 

Date: --------

John Vassallo 

Partner of Weva Properties Ltd. 

Date: --------

Dennis Weinmann, individually 

Date: --------

John Vassallo, individually 

Date: --------

Approved as to form: 

Aitan Goelman 

Mark J. Feaster 

Attorneys for all Defendants 

Zuckerman Spaeder LLP 

1800 M Street, NW, Suite 1000 

Attorneys for 

Commodity Futures Trading Commission 

77 W. Jackson Blvd. Suite 800 

Chicago, IL 60604 

Telephone: (312) 596-0700 

Facsimile: (312) 596-0714 

E-mail: dsnodgrass@cftc.gov 

nruvinsky@cftc.gov 

dterrell@cftc.gov 

Date .3/ ;L/ μ)d-3 ----�--�---

24