registered with the SEC at the time they were sold, in violation of the securities registration
provisions of Section 5(a) and (c) of the Securities Act, 15 U.S.C. j 77e(a) and (c), and unless
restrained and enjoined will continue to violate these securities registration provisions.
8. Geivelis, Butts, Anisky, Express Commercial, Banner, and Baggs also acted as broker-
dealers in violation of the registration provisions of Section 15(a)(l) of the Exchange Act, 15
U.S.C. j 78o(a)(l), and unless restrained and enjoined will continue to violate the broker-dealer
9. Relief defendants Benmrd H. Butts, Jr. PA, Butts Holding Corporation, GlobalWorldwide Funding Ventures, lnc., Margaret A. Hering, and PW Consulting Group LLC
received investors' funds to which they had no legitimate claim and were unjustly enriched.
Il. JURISDICTION AND VENUE
10. The SEC blings this action under Section 20(b) of the Securities Act, 15 U.S.C. j 77t(b)
and Section 21(d) and (e) of the Exchange Act, l 5 U.S.C. j 78u(d) and (e), to restrain and enjoin
the defendants from engaging in the acts, practices and courses of business described in this
Complaint, and acts, practices and courses of business of similar purport and object. TheCommission seeks permanent injunctions, disgorgement of ill-gotten gains derived from the
conduct alleged in the Complaint plus prejudgment interest, and third-tier civil penalties under
Section 20(d) of the Securities Act, 15 U.S.C. j 77t(d) and Section 21(d)(3) of the Exchange Act,15 U.S.C. j 78u(d)(3).
11. This Court has jurisdiction under Section 22(a) of the Securities Act, 15 U.S.C. j 77v(a)
and Section 27 of the Exchange Act, 15 U.S.C. j 78aa. The defendants, directly or indirectly,
made use of the means and instrumentalities of interstate commerce or of the mails, incolmection with the acts, practices and courses of business alleged in the Complaint.
Certain of the acts, practices, and courses of business constituting violations of lawalleged in the Complaint occurred within the Southel'n District of Florida. ln addition, Butts
Banner, and Anisky reside in the Southern District of Florida. Express Commercial conducts
business from the Southem District of Florida.111. DEFENDANTS
Defendant Bernard H. Butts, Jr., bol'n in 1941, is an attorney admitted to practice law inFlorida. He resides and transacted business in Miami, Florida. He entered into numerous escrow
Case 1:13-cv-23115-JEM Document 1 Entered on FLSD Docket 08/29/2013 Page 3 of 22