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Pawel P. Dynkowski, et al.

Court Enters Consent Judgment Against Richard A. Bailey

Litigation Release No. 24036/ January 30, 2018

Securities and Exchange Commission v. Pawel P. Dynkowski, et al., Civil Action No. 1:09-361 (D. Del.)

The U.S. District Court for the District of Delaware entered a consent judgment on January 23, 2018 in a penny stock manipulation case brought by the Securities and Exchange Commission against Richard A. Bailey, a former officer of GH3 International, Inc. The SEC's complaint alleges that Bailey participated in a pump-and-dump scheme involving GH3's common stock, generating more than $700,000 of illicit proceeds for Bailey and seven other named defendants involved in the fraudulent scheme.

Without admitting or denying the allegations, Bailey consented to the entry of a judgment permanently enjoining him from violating Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder and Sections 5 and 17(a) of the Securities Act of 1933; barring him from participating in any offering of a penny stock; and barring him from serving as an officer or a director of a public company. The judgment provides that upon subsequent motion by the SEC the Court will determine issues relating to monetary relief.

The SEC thanks the following agencies for their cooperation and assistance in connection with this matter: the U.S. Attorney's Office for the District of Delaware; the Delaware State Police; United States Immigration and Customs Enforcement, Department of Homeland Security, Homeland Security Investigations; and the Department of the Treasury, Internal Revenue Service, Criminal Investigation.

For further information, see Litigation Release Nos. 21053 (May 21, 2009), 21463 (March 29, 2010), 22256 (Feb. 10, 2012), 22421 (July 25, 2012), 22626 (Feb. 27, 2013), 23348 (Sept. 15, 2015), 23350 (Sept. 16, 2015), 23412 (Nov. 23, 2015), and 23563 (June 9, 2016).