Plaintiff, the United States Securities and Exchange Commission (“SEC”), hereby moves the Court to enter the Final Judgment submitted herewith.

The proposed Final Judgment includes: (a) permanent injunctive relief precluding Sargent from violating the securities laws provisions charged in the Complaint and (b) a civil penalty of $215,174.90.

Given the allegations in the Complaint, which Sargent neither admits or denies, the relief set forth in paragraph 4 is a fair and reasonable resolution of this matter.

In the Consent, Sargent agrees that the SEC “may present the [proposed] Final Judgment to the Court for signature and entry without further notice.” (Ex. 1, ¶ 13).

WHEREFORE, the SEC respectfully requests that the Court grant this Motion and enter the proposed Final Judgment attached hereto as Exhibit 2.

FOR THE Northern District of Illinois − CM/ECF NextGen 1.7.1.1 Eastern Division

Unopposed Motion for Entry of Preliminary Order of Forfeiture [466] is granted.

No appearance by Shradha Agarwal is needed at the 6/16/2023 Forfeiture Hearing.

If a minute order or other document is enclosed, please refer to it for additional information.

For scheduled events, motion practices, recent opinions and other information, visit our web site at www.ilnd.uscourts.gov.

The following property is to be applied toward satisfaction of the personal money judgment: a. All right, title, and interest in Investment Fund A, held in the name of Jumpstart Ventures II, LLC, including, but not limited to, approximately $60,000.00 in capital contributions submitted on or around May 31, 2018; b.

Funds in the amount of $194,616.25 seized on July 8, 2021, and all remaining right, title, and interest in Investment Company C, held in the name of Jumpstart Ventures II, LLC, including, but not limited to, $50,000 in capital contributions submitted on or about January 5, 2017; y.

All right, title, and interest in Investment Fund O, held in the name of Jumpstart Ventures II, LLC, including, but not limited to, $158,879.00 in capital contributions submitted between August 8, 2016, and April 28, 2017; bb.

Specifically, the following accounts shall be liquidated and distributed as follows: a. All right, title, and interest in Investment Fund A, held in the name of Jumpstart Ventures II, LLC, including, but not limited to, approximately $60,000.00 in capital contributions submitted on or around May 31, 2018; b.

Funds in the amount of $194,616.25 seized on July 8, 2021, and all remaining right, title, and interest in Investment Company C, held in the name of Jumpstart Ventures II, LLC, including, but not limited to, $50,000 in capital contributions submitted on or about January 5, 2017; y.

When faced with a similar argument, the Coe court pointed to the “well-established principle that statements of coconspirators before a defendant joins the conspiracy are nonetheless admissible against him.” 718 F.2d at 839; see also ...

Pursuant to Paragraph 58 of the Consent Decree (Dkt. No. 10), the Court-appointed Monitor, Neil M. Barofsky, respectfully submits to the Court this eleventh status report (“Eleventh Report”) concerning the monitorship of the International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America (the “Union” or the “UAW”).

* * * Following a U.S. Department of Justice (“DOJ”) investigation that resulted in the criminal convictions of numerous senior Union officials, including two past Presidents, the UAW agreed to a Consent Decree and the appointment of a Monitor beginning on May 12, 2021.

Under that decree, the Monitor was given three responsibilities upon appointment: (1) to investigate and address suspected past and present misconduct; (2) to help the UAW ensure that its compliance regime can prevent and remove fraud and corruption; and (3) to administer a referendum vote to decide the manner in which the Union would choose its senior-most leaders, implement any change arising from that referendum, and oversee the Union’s elections of its leadership during the monitorship.1 This Report provides a brief update on the Monitor’s work since the last report.

Motion practice ensued and, after extensive briefing and oral argument, the Court issued an Order dated December 16, 2024, rejecting the Union’s position and ruling that the Union had to provide the Monitor with all responsive documents, including those that the Union had previously redacted.4 In summary, the Court found that: The Consent Decree confers upon the Monitor broad authority to investigate complaints of fraud, corruption, illegal behavior, dishonesty, and unethical practices by the UAW and its constituent entities.

meetings that involve discussions of collective bargaining strategy or attorney- client privileged conversations.5 Since the Court’s Order,6 the Union has produced the documents in full to the Monitor that were previously redacted.

As used in this Order, “copies” includes electronic images, duplicates, extracts, summaries or descriptions that contain the Confidential Information.

Defendants, defendants’ counsel, and authorized persons shall not disclose any notes or records of any kind that they make in relation to the contents of the materials or Confidential Information, other than to authorized persons, and all such notes or records are to be treated in the same manner as the original materials or Confidential Information.

Upon conclusion of all stages of this case, all of the Confidential Information and all copies made thereof shall be disposed of in one of three ways, unless otherwise ordered by the Court.

The restrictions set forth in this Order do not apply to documents that are or become part of the public court record, including documents that have been received in evidence at other trials, nor do the restrictions in this Order limit the government or defense counsel in the use of discovery materials in judicial proceedings in this case, except that any document filed by any party which attaches or otherwise discloses Confidential Information shall be filed under seal to the extent necessary to protect such information, absent prior permission from this Court.

Nothing contained in this Order shall preclude any party or nonparty from applying to this Court for further relief or for modification of any provision hereof.

AGARWAL, and BRAD PURDY

Case No. 19 CR 864 Hon.

Thomas M. Durkin United States District Judge

Defendant Shradha Agarwal respectfully joins defendant Shah's Motion to Exclude Evidence and for Related Relief (Doc. 688) and his Motion to Continue Evidentiary Hearing (Doc. 690).

Respectfully submitted,