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1
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COMPLAINT
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EXTRACTED KEY WORDS
AMERICAN PROMETHEUS SECURITIES JAMES NORVILLE MABEL NORVILLE ACT OFFERING INVESTORS VIOLATE MATERIALS LIMITED PARTNERSHIP EXCHANGE ACT STOCK COMMISSION BUSINESS WISCONSIN ENJOINING FUNDS SECURITIES FRAUD SALE DIRECTORS COURT COURSES PRACTICES RESTRAINING DISCLOSE CENTRAL CITY OFFICERS CONNECTION MAILS |
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. ___________
SECURITIES AND
EXCHANGE COMMISSION,
Plaintiff,
v.
AMERICAN PROMETHEUS CORP.,
JAMES P. NORVILLE AND
MABEL R. NORVILLE,
Defendants.
COMPLAINT FOR PERMANENT INJUNCTION
AND OTHER EQUITABLE RELIEF
Plaintiff Securities and Exchange Commission ("Commission") alleges the following for
its complaint:
I. SUMMARY OF THE ACTION
1. James P. Norville and his wife, Mabel R. Norville, formed American Prometheus
Corporation and a related entity, American Prometheus Limited Partnership, in 1996
purportedly to develop a hotel and casino in Central City, Colorado.
2. Between April 1997 and April 2000, the Norvilles offered more than $3.6 million in
unregistered American Prometheus securities and raised approximately $1.1 million from
investors through a series of purported private placement offerings and through the
Norvilles' sale of more than 900,000 shares of American Prometheus stock that they
owned.
3. In American Prometheus' offering materials and in presentations to investors, the
Norvilles made numerous material misrepresentations and omissions, including touting
James Norville's successful career in finance while failing to disclose: (1) that criminal
securities fraud charges were pending against him as of April 1998 relating to one of the
Norvilles' previous companies; (2) his subsequent guilty plea in August 1999 to one
count of securities fraud; or (3) the existence of a 1995 administrative order prohibiting
him from selling securities in Wisconsin.
4. The Norvilles further represented in American Prometheus' offering materials and in
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