Securities Exchange Act of 1934
Release No. 50701 / November 18, 2004

Admin. Proc. File No. 3-11632


In the Matter of

DAVID ABISH, CHRISTOPER BETTS, MARK CHARVAT, JAMES CORCORAN, PAUL FEENY, ROBERT PRATT, MARIO RODRIGUEZ, SCOTT SIEGEL, ANDREW TURSI and DAVID WEEKS

Respondents.



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ORDER MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS PURSUANT TO SECTION 15(b) OF THE SECURITIES EXCHANGE ACT OF 1934 AS TO PAUL FEENY AND DAVID WEEKS

I.

The Securities and Exchange Commission ("Commission") instituted public administrative proceedings on September 3, 2004, pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act") against David Abish, Christopher Betts, Mark Charvat, James Corcoran, Paul Feeny ("Feeny"), Robert Pratt, Mario Rodriguez, Scott Siegel, Andrew Tursi and David Weeks ("Weeks").

II.

Following institution of this proceeding, Feeny and Weeks (collectively, the "Settling Respondents") submitted Offers of Settlement (the "Offers"), which the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the Commission, or to which the Commission is a party, and without admitting or denying the findings herein, except as to the Commission's jurisdiction over them and the subject matter of these proceedings, and the findings contained in Sections III.B. and III.C. below, which are admitted, the Settling Respondents consent to the entry of this Order Making Findings and Imposing Remedial Sanctions Pursuant to Section 15(b) of the Exchange Act (the "Order"), as set forth below.

III.

On the basis of this Order and the Settling Respondents' Offers, the Commission finds that:

A. Each of the Settling Respondents was a registered representative associated with Sterling Foster & Company, Inc. ("Sterling Foster") between October 1994 and February 1997. Sterling Foster was registered with the Commission as a broker-dealer pursuant to Section 15(b) of the Exchange Act.

B. On December 1, 2000, Feeny pled guilty to one count of conspiracy to commit securities fraud, mail fraud and wire fraud, in violation of Title 18 United States Code, Section 371 and one count of securities fraud, in violation of Title 15 United States Code, Section 78j(b) before the United States District Court for the Southern District of New York, in United States v. Feeny, 00 CR 91. On October 29, 2002, Feeny was sentenced to three years of supervised release and ordered to pay $75,411 in restitution.

C. On June 26, 2000, Weeks pled guilty to one count of conspiracy to commit securities fraud, mail fraud and wire fraud in violation of Title 18 United States Code, Section 371 and three counts of securities fraud in violation of Title 15 United States Code Section 78j(b) before the United States District Court for the Southern District of New York, in United States v. Weeks, 00 CR 91. On November 13, 2003, Weeks was sentenced to 36 months probation and ordered to pay $1,151,649 in restitution.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions agreed to in the Settling Respondents' Offers.

Accordingly, it is hereby ORDERED that, pursuant to Section 15(b)(6) of the Exchange Act, Settling Respondents Feeny and Weeks be, and hereby are, barred from association with any broker or dealer.

Any reapplication for association by any of the Settling Respondents will be subject to the applicable laws and regulations governing the reentry process, and reentry may be conditioned upon a number of factors, including, but not limited to, the satisfaction of any or all of the following: (a) any disgorgement ordered against a Settling Respondent, whether or not the Commission has fully or partially waived payment of such disgorgement; (b) any arbitration award related to the conduct that served as the basis for the Order; (c) any self-regulatory organization arbitration award to a customer, whether or not related to the conduct that served as the basis for the Order; and (d) any restitution order by a self-regulatory organization, whether or not related to the conduct that served as the basis for the Order.

For the Commission, by its Secretary, pursuant to delegated authority.

Jonathan G. Katz
Secretary