OPINION AND ORDER
BAER, District Judge.
On November 20, 1990, the Securities and Exchange Commission ("SEC") brought this civil injunctive action pursuant to section 20(b) of the Securities Act of 1933 ("Securities Act"), 15 U.S.C. § 77t(b) (1988), and section 21(d) of the Securities and Exchange Act of 1934 ("Exchange Act"), 15 U.S.C. § 78u(d) (Supp.1993). The complaint alleges, in relevant part, that defendants Capital Shares, Inc. ("Capital...
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