-------------------- BEGINNING OF PAGE #1 ------------------- UNITED STATES SECURITIES AND EXCHANG COMMISSION Litigation Release No. 14757 / December 14, 1995 SEC V. THOMAS W. COLLINS AND EDWARD M. COLLINS, N.D.ILL., 95 CIV 7251(BBD), filed December 11, 1995 The Commission announced the filing of a Complaint on December 11, 1995 in the U.S. District Court for the Northern District of Illinois against Thomas W. Collins (T. Collins) and Edward M. Collins (E. Collins) for violations of Sections 5(a), 5(c) and 17(a) of the Securities Act of 1933, Sections 10(b), 15(a)(1) and 15(c) of the Securities Exchange Act of 1934 and Rules 10b-5 and 15c1-2 promulgated thereunder. Specifically, the Complaint alleges that from December 1984 to June 1994, T. Collins and E. Collins, through their company Lake States, Inc., offered and sold to approximately 460 investors, residing in 15 states, approximately $120 million in unregistered securities, in the form of investment contracts. In connection with the offer and sale of these securities, the Complaint alleges that T. Collins and E. Collins made misstatements and omitted to state material facts to investors regarding the use of proceeds, the rate of return and the risk of the investment. The Complaint alleges that investors were told that their funds would be pooled with other investors' funds to invest in commodity futures and other business ventures. Instead of investing all of the money as represented, the Complaint alleges that T. Collins and E. Collins were running a Ponzi scheme and that most of investor funds were used to pay personal and business expenses and to pay interest and principal to prior investors.