==========================================START OF PAGE 1====== UNITED STATES SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 15094 / September 30, 1996 SECURITIES AND EXCHANGE COMMISSION V. TED E. MONG, ET AL., Case No. C2-96-989 (S.D. OHIO) The Commission announced that on September 30, 1996, it filed a complaint for permanent injunction and other equitable relief, including disgorgement and civil penalties, against Ted E. Mong ("Mong"), Liberty Bell Association, Inc. ("Liberty Bell"), and McKenzie Matthew, Inc. ("McKenzie Matthew") in the U.S. District Court for the Southern District of Ohio. The Commission's complaint seeks to enjoin the Defendants from violations of Section 17(a) of the Securities Act of 1933, Sections 10(b) and 15(a) and (c) of the Securities Exchange Act of 1934, and Rules 10b-5 and 15c1-2 promulgated thereunder. The Commission's complaint alleges that from in or about November 1993 through in or about June 1995 the Defendants raised approximately $1.2 million from the offer and sale of securities to at least one hundred investors in Ohio and elsewhere. During the offer and sale of the securities, the Defendants made materially false and misleading statements and omitted to state material information to investors concerning the use of investor proceeds, the risks involved in making the investment, the return on the investment and the commissions paid to the Defendants. In addition, the Commission alleges that the Defendants used new investor funds to pay earlier investors in a Ponzi-like fashion.