MEMORANDUM AND ORDER
GRAHAM, District Judge.
This is an action for injunctive and other equitable relief filed by the Securities and Exchange Commission ("SEC") against S. Robert Davis, Charles R. Davis and Douglas A. Davis. Count I of the complaint alleges violations of Section 17(a)(1) of the Securities Act of 1933, 15 U.S.C. § 77q(a)(1). Count II alleges violations of Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933, 15 U.S.C. §...
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