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1
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ORDER
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EXTRACTED KEY WORDS
CORPORATE DEFENDANTS COMMISSION ACT FOREIGN CURRENCY REGULATION MAD CTU INVESTMENT ACCOUNT RISK FUTURES TRADING DIPPOLITO COMMODITY CFTC OPTION CONTRACTS FRAUDULENT PRELIMINARY INJUNCTION RESTRAINING ORDER STATUTORY RESTRAINING ORDER MAD/CTU MONEY TRAIL TRANSFER BINDER CORPORATE DEFENDANTS FAIL ACCOUNT DOCUMENTATION ACT AUTHORIZES CONTRACT MARKET CCH REQUESTED RELIEF TRANSACTION |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
COMMODITY FUTURES TRADING
COMMISSION, CIVIL ACTION NO.
Plaintiff, CIV-HURLEY
v.
MAD FINANCIAL, INC., AKA
MEYERS, ARNOLD, AND
DAVIDSON, FINANCIAL, INC.,
CTU, INC., AKA
COOPER, THOMAS, AND
UNGAR, INC., AND
MICHAEL A. DIPPOLITO,
Defendants.
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFF'S
EX PARTE MOTION FOR STATUTORY RESTRAINING ORDER AND MOTION FOR
PRELIMINARY INJUNCTION AND OTHER EQUITABLE RELIEF
FILED UNDER SEAL
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2
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COMPLAINT
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EXTRACTED KEY WORDS
CORPORATE DEFENDANTS CONTRACTS FOREIGN CURRENCY MAD FUNDS CTU PROFITS COMMODITY DIPPOLITO RISK FLORIDA COMMODITY FUTURES TRADING ACT COMMODITY FUTURES BUSINESS COMMISSION MISAPPROPRIATE INVESTMENT MICHAEL DIPPOLITO COMMISSION REGULATION BUSINESS LOCATION INTERRELATED CORPORATIONS CONTRACT MARKET TRANSACTION FALSE REPRESENTATIONS FRAUDULENT SALES PRACTICES PROMISING EXTRAORDINARY PROFITS EXTRAORDINARY PROFITS INCORPORATION |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
COMMODITY FUTURES TRADING
COMMISSION, CIVIL ACTION NO.
Plaintiff, CIV-HURLEY
v.
MAD FINANCIAL, INC., AKA
MEYERS, ARNOLD, AND
DAVIDSON, FINANCIAL, INC.,
CTU, INC., AKA FILED UNDER SEAL
COOPER, THOMAS, AND
UNGAR, INC., AND
MICHAEL A. DIPPOLITO,
Defendants.
COMPLAINT FOR PERMANENT INJUNCTION
AND OTHER EQUITABLE RELIEF
I. SUMMARY
1. Since at least April 2001 and as recently as January 2002, MAD Financial,
Myers, Arnold, and Davidson Financial, Inc. ("MAD") and CTU Inc., a.k.a., Cooper, Thomas
and Ungar, Inc. ("CTU") (collectively, the "corporate defendants") have fraudulently sold
foreign currency option contracts to customers nationwide from various locations in Florida.
Defendant Michael Dippolito ("Dippolito") is the director of both corporate defendants.
Defendants MAD and CTU appear to be interrelated corporations that do not have a fixed
business location. The corporate defendants solicited and received more than $200,000 from
customers by promising extraordinary profits while minimizing the risk of loss. Despite the
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