Mark Deaton - Renegade Trader Internet

In addition, Key Resource Group, controlled by Lucas, Kilgariff and McNaul, employed Duboise, Bay, Phillips, Hunter, Folkinga and Deaton as agents of issuer, absent registration, and Duboise, Bay, Phillips, Hunter, Folkinga and Deaton acted as agents of issuer, absent registration.  Respondents conduct in connection with the offer and sale of the unregistered securities was egregious.  The investments were sold to investors with no previous experience with these types of investments and Respondents failed to disclose any risk factors to the investors in the investment or that the sales agents were paid as much of 50% of the investment as a commission.  There was monetary harm to the Connecticut investors as a result of their investment in unregistered securities offered and sold by Respondents, since all of the investors lost money as a result of their investment and Respondents did not reimburse the investors losses.
 
Consequently, the Commissioner finds that based upon the nature of Respondents actions in violation of the Act, this order imposing fine against Respondents is necessary and appropriate in the public interest and for the protection of investors and consistent with the purposes fairly intended by the policy and provisions of Sections 36b-2 to 36b-33, inclusive, of the Act.

The Commissioner finds that based upon Duboise, Bay, Phillips, Hunter, Folkinga and Deaton acting as agents of issuer, absent registration, in violation of Section 36b-6(a) of the Act, the facts require the imposition of a fine against (i) Duboise in the amount of Twenty Thousand Dollars ($20,000) for four violations under Section 36b-27(d) of the Act prior to October 1, 2003; (ii) Bay in the amount of One Hundred Five Thousand Dollars ($105,000) for one violation under Section 36b-27(d) of the Act prior to October 1, 2003, and two violations under Section 36b-27(d) of the Act as it currently exists; (iii) Phillips in the amount of Fifty Thousand Dollars ($50,000) for one violation under Section 36b-27(d) of the Act as it currently exists; (iv) Hunter in the amount of One Hundred Fifty Thousand Dollars ($150,000) for three violations under Section 36b-27(d) of the Act as it currently exists; (v) Folkinga in the amount of One Hundred Thousand Dollars ($100,000) for two violations under Section 36b-27(d) of the Act as it currently exists; and (vi) Deaton in the amount of One Hundred Thousand Dollars ($100,000) for two violations under Section 36b-27(d) of the Act as it currently exists.