IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

SECURITIES AND EXCHANGE COMMISSION ) ) Plaintiff, ) ) v. ) ) VLADIMIR OKHOTNIKOV, ) JANE DOE a/k/a LOLA FERRARI, ) MIKAIL SERGEEV, ) SERGEY MASLAKOV, ) Case No. 22 C 3978 SAMUEL D. ELLIS, ) MARK F. HAMLIN, ) Judge Jorge L. Alonso SARAH L. THEISSEN, ) CARLOS L. MARTINEZ, ) RONALD R. DEERING, ) CHERI BETH BOWEN, and ) ALISHA R. SHEPPERD, ) ) Defendants. ) __________________________________________ )

PLAINTIFF’S AGREED MOTION FOR ENTRY OF PARTIAL JUDGMENT BY CONSENT AS TO DEFENDANT ALISHA R. SHEPPERD

Plaintiff Securities and Exchange Commission respectfully moves the Court for entry of Partial Judgment by Consent as to Defendant Alisha R. Shepperd (“Shepperd”). In support of this motion, the SEC shows the Court as follows: 1. The SEC filed its Complaint in this matter on August 1, 2022 (Dkt# 1) alleging, among other things, violations of the registration and antifraud provisions of the federal securities laws – specifically, Sections 5 and 17(a) of the Securities Act of 1933, 15 U.S.C. §§ 77e, 77q(a); and Section 10(b) and Rule 10b-5 of the Securities Exchange Act of 1934, 15 U.S.C. § 78j(b),

.10b-5. 2. The SEC filed prior Agreed Motions on August 2, 2022 (Dkt# 5), August 10, 2022 (Dkt# 17), September 1, 2022 (Dkt# 29), and November 21, 2022 (Dkt# 62), seeking entry by consent of a final judgment as to Defendant Samuel D. Ellis (“Ellis”), and partial judgments by consent as to Defendants Sarah L. Theissen (“Theissen”), Mark F. Hamlin (“Hamlin”), Cheri Beth Bowen (“Bowen”), and Carlos L. Martinez (“Martinez”). By Minute Entries on August 4, 2022 (Dkt# 8), August 25, 2022 (Dkt# 24), and September 2, 2022 (Dkt# 31), the Court granted the prior Agreed Motions, and subsequently, on August 8, 2022, August 25, 2022, and

September 2, 2022, the Court entered final judgment against Ellis (Dkt# 16), and partial judgments against Theissen (Dkt# 15), Hamlin (Dkt# 25), and Bowen (Dkt# 33).1 3. As with Theissen, Hamlin, Bowen, and Martinez, Shepperd also has agreed to a partial settlement of the SEC’s claims. Attached as Exhibit 1 is her signed consent to the proposed partial judgment. This judgment obviates the need to litigate substantive liability on the part of Shepperd, and permanently enjoins her from violating the federal securities laws at issue in the Complaint as well as from engaging in certain other activity. The proposed judgment further provides that monetary relief sought by the SEC – in the form of disgorgement,

prejudgment interest, and a civil penalty – shall be determined by the Court at a later date on the SEC’s motion. 4. District courts routinely have entered judgments based on this type of “bifurcated” settlement in SEC enforcement actions, and have adopted the procedures described in the attached consent for the monetary relief portion of the proceedings. See, e.g., SEC v. Daubenspeck,

, 860 (N.D. Ill. 2020); SEC v. Zenergy Int’l, Inc., No. 13- 5511,

, at *2-4 (N.D. Ill. Sept. 20, 2016); SEC v. Integrity Fin. AZ, LLC, No. 10-782,

, at *3-4 (N.D. Ohio Jan. 20, 2012). 5. In the attached consent, Shepperd has agreed the SEC “may present the [proposed judgment] to the Court for signature and entry without further notice.” (See Ex. 1, at ¶ 15.) Under Fed. R. Civ. P. 54(b), there is no just reason to delay entry of the proposed judgment, and the SEC submits entry of the judgment will conserve judicial resources and streamline the issues in this litigation. In addition, there is little risk of a piecemeal appeal, as Shepperd has waived her right to appeal from the judgment. (See Ex. 1, at ¶ 7.) 6. This case will proceed in full as to the remaining Defendants – Vladimir

Okhotnikov; Mikail Sergeev; and Ronald R. Deering – and is not affected by entry of the proposed judgment.2 7. Pursuant to the Court’s Individual Practices, the proposed judgment in Word format is being emailed separately to Chambers.

WHEREFORE, for the reasons cited above, the SEC respectfully requests the Court grant this motion and enter the proposed judgment.

DATED: November 22, 2022 Respectfully submitted,

SECURITIES AND EXCHANGE COMMISSION

By /s/ Patrick R. Costello Timothy S. Leiman ([email protected]) (IL #6270153) Chicago Regional Office 175 W. Jackson Blvd., Suite 1450 Chicago, IL 60604 Telephone: (312) 353-5213

2 Defendants Jane Doe a/k/a Lola Ferrari and Sergey Maslakov are in default, and the Court will hear the SEC’s pending motion for default judgment (Dkt# 49) on November 29, 2022. See Dkt# 53. Patrick R. Costello ([email protected]) (FL #75034) Christopher J. Carney ([email protected]) (DC #472294) Washington, DC Office 100 F Street NE Washington, DC 20549-5949 Telephone: (202) 551-3982 Admitted Pro Hac Vice

Attorneys for Plaintiff CERTIFICATE OF SERVICE I certify that on November 22, 2022, I caused to be served the foregoing PLAINTIFF’S AGREED MOTION FOR ENTRY OF PARTIAL JUDGMENT BY CONSENT AS TO DEFENDANT ALISHA R. SHEPPERD on Defendants at the addresses and by the means set

forth on the attached Service List.

/s/ Patrick R. Costello Patrick R. Costello Service List

Vladimir Okhotnikov By CM/ECF c/o James G. Lundy Foley & Lardner LLP 321 North Clark Street, Suite 3000 Chicago, IL 60654 [email protected]

Sergei Kuchinski Kuchinski Law Group, LLC 211 West Wacker Dr., Suite 300 Chicago, IL 60606 [email protected]

Mark F. Hamlin By electronic mail c/o Ryan Willis, Christian Dysart, James Kurosad Dysart Willis 530 Hillsborough Street, Suite 200 Raleigh, NC 27603 [email protected] [email protected] [email protected]

Sarah L. Theissen By CM/ECF c/o Gregg N. Sofer and Patrick Coffey Husch Blackwell LLP 111 Congress Avenue, Suite 1400 Austin, TX 78701-4093 [email protected] [email protected]

Carlos L. Martinez By electronic mail c/o Bruce Lewitas Lewitas Hyman 161 N. Clark St., Suite 1600 Chicago, IL 60601 [email protected]

Ronald R. Deering By CM/ECF c/o Peter King and Cindy Innocent Guerra King P.A. The Towers at Westshore 1408 N. Westshore Blvd., Suite 1010 Tampa, FL 33607 [email protected] [email protected] David A. Baugh O’Hagan Meyer, LLC One E. Wacker Drive, Suite 3400 Chicago, IL 60601 [email protected]

Cheri Beth Bowen By electronic mail c/o Celiza (Lisa) Bragança Bragança Law LLC 5250 Old Orchard Road, Suite 300 Skokie, IL 60077 [email protected]

Alisha R. Shepperd By electronic mail c/o Matthew Mueller Fogarty Mueller Harris, PLLC 100 E Madison St., Suite 202 Tampa, FL 33602-4703 [email protected]