SEC v. Native American Energy Group, Inc.; Joseph D' Arrigo; David Rudzik; Lisa D' Arrigo; and Lorraine Alejandro, Eastern District of New York (Dec. 23, 2025) — Judgment

[OCR_UNRECOVERABLE method=recover reason=missing_pdf ts=2026-08-11T14:53:34.106Z]                                                           

UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 

SECURITIES AND EXCHANGE COMMISSION, 

Plaintiff, 

v. 

NATIVE AMERICAN ENERGY GROUP, INC., 
JOSEPH D' ARRIGO, and DAVID RUDZIK 

Defendants, 

-and-

LISA D' ARRIGO and LORRAINE 
ALEJANDRO, 

Relief Defendants. 

C.A. No. 23-4455 (NGG)(PK) 

FINAL JUDGMENT AS TO DEFENDANT DAVID HUDZIK 

The Securities and Exchange Commission having filed a Complaint and Defendant David 

Rudzik ("Defendant") having entered a general appearance; consented to the Court's jurisdiction 

over Defendant and the subject matter of this action; consented to entry of this Judgment without 

admitting or denying the allegations of the Complaint ( except as to jurisdiction and except as 

otherwise provided herein in paragraph IX); waived findings of fact and conclusions of law; and 

waived any right to appeal from this Judgment: 

I. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is 

permanently restrained and enjoined from violating, directly or indirectly, Section l0(b) of the 

Securities Exchange Act of 1934 (the "Exchange Act") [15 U.S~G~'},§{7:8)(:6)1 and Rule lOb-5 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 1 of 16 PageID #:
285



promulgated thereunder [17 C.F.R. § 240.lOb-5], by using any means or instrumentality of 

interstate commerce, or of the mails, or of any facility of any national securities exchange, in 

connection with the purchase or sale of any security: 

(a) to employ any device, scheme, or artifice to defraud; 

(b) to make any untrue statement of a material fact or to omit to state a material fact 

necessary in order to make the statements made, in the light of the circumstances 

under which they were made, not misleading; or 

(c) to engage in any act, practice, or course of business which operates or would 

operate as a fraud or deceit upon any person. 

by, directly or indirectly, (i) creating a false appearance or otherwise deceiving any person about 

the price or trading market for any security, or (ii) making any false or misleading statement, or 

disseminating any false or misleading documents, materials, or information, concerning matters 

relating to a decision by an investor or prospective investor to buy or sell securities of any 

company. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65( d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

II. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from violating Section 17(a) of the Securities Act of 1933 

(the "Securities Act") [fs lJ.s:C, § 77q(a)] in the offer or sale of any security by the use of any 

2 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 2 of 16 PageID #:
286



means or instruments of transportation or communication in interstate commerce or by use of the 

mails, directly or indirectly: 

(a) to employ any device, scheme, or artifice to defraud; 

(b) to obtain money or property by means of any untrue statement of a material fact 

or any omission of a material fact necessary in order to make the statements 

made, in light of the circumstances under which they were made, not misleading; 

or 

( c) to engage in any transaction, practice, or course of business which operates or 

would operate as a fraud or deceit upon the purchaser. 

by, directly or indirectly, (i) creating a false appearance or otherwise deceiving any person about 

the price or trading market for any security, or (ii) making any false or misleading statement, or 

disseminating any false or misleading documents, materials, or information, concerning matters 

relating to a decision by an investor or prospective investor to buy or sell securities of any 

company. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65( d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

III. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from violating Sections 5(a) and 5(c) of the Securities Act 

[l.5 U.S:C. §§ 77e(a)1 and 77e(c)] by, directly or indirectly, in the absence of any applicable 

3 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 3 of 16 PageID #:
287



exemption: 

(a) Unless a registration statement is in effect as to a security, making use of any 

means or instruments of transportation or communication in interstate commerce 

or of the mails to sell such security through the use or medium of any prospectus 

or otherwise; 

(b) Unless a registration statement is in effect as to a security, carrying or causing to 

be carried through the mails or in interstate commerce, by any means or 

instruments of transportation, any such security for the purpose of sale or for 

delivery after sale; or 

( c) Making use of any means or instruments of transportation or communication in 

interstate commerce or of the mails to offer to sell or offer to buy through the use 

or medium of any prospectus or otherwise any security, unless a registration 

statement has been filed with the Commission as to such security, or while the 

registration statement is the subject of a refusal order or stop order or (prior to the 

effective date of the registration statement) any public proceeding or examination 

under Section 8 of the Securities Act [,fS U:S.C:':,§ 77h]. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

RederalR.ule of Civil Procedure::65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

4 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 4 of 16 PageID #:
288



IV. 

IT IS HEREBY FURTHER ORDERED, ADWDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from violating, directly or indirectly, Section 15(a) of the 

Exchange Act [15 U.S.C. § 78o(a)] by acting as a broker or dealer within the meaning of Section 

3(a) of the Exchange Act [J,~J\t!Jt\S:'t3{':{f78c] and making use of the mails or any means or 

instrumentality of interstate commerce to effect any transactions in, or to induce or attempt to 

induce the purchase or sale of, any security ( other than an exempted security or commercial 

paper, bankers' acceptances, or commercial bills) without being registered with the Commission 

in accordance with Section 15(b) of the Exchange Act [15:U.S.C. § 78o(b)]. 

IT IS FURTHER ORDERED, ADWDGED, AND DECREED that, as provided in 

iRe<ieraJ.mcu.le o:f CivilJ>roceuiire\tiStfl}t2J, the foregoing paragraph also binds the following who 

receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

V. 

IT IS HEREBY FURTHER ORDERED, ADWDGED, AND DECREED that, pursuant 

to Section 2l(d)(2) of the Exchange Act [15 U.S.C. f78u(d)(2)] and Section 20(e) of the 

Securities Act [15 U.S.C. ,§::77i(e)], Defendant is prohibited from acting as an officer or director 

of any issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act 

[l5U.S:C. §}71{0 or that is required to file reports pursuant to Section 15(d) of the Exchange Act 

[15 u.s.c. § 78o(d)]. 

5 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 5 of 16 PageID #:
289



VI. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently barred from participating in an offering of penny stock, including engaging in 

activities with a broker, dealer, or issuer for purposes of issuing, trading, or inducing or 

attempting to induce the purchase or sale of any penny stock; provided, however, that such bar 

shall not prevent Defendant from purchasing or selling penny stock in his own personal account. 

A penny stock is any equity security that has a price of less than five dollars, except as provided 

in Rule 3a51-1 under the Exchange Act [17 C.F.R, § 240.3a51-l]. 

VII. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is liable for disgorgement of $70,000.00, representing net profits gained as a result of the conduct 

alleged in the Complaint, together with prejudgment interest thereon in the amount of 

$17,472.10, and a civil penalty in the amount of $70,000.00 pursuant to Section 20(d) of the 

Securities Act [15 U.S.C. § 77t(d)] and Section 2l(d)(3) of the Exchange Act [15 U.S.C. § 

78u(d)(3)]. Defendant shall satisfy this obligation by paying $157,472.10 to the Securities and 

Exchange Commission within 30 days after entry of this Final Judgment. 

Defendant may transmit payment electronically to the Commission, which will provide 

detailed ACH transfer/Fedwire instructions upon request. Payment may also be made directly 

from a bank account via Pay.gov through the SEC website at 

http://www.sec.gov/about/offices/ofm.htm. Defendant may also pay by certified check, bank 

cashier's check, or United States postal money order payable to the Securities and Exchange 

Commission, which shall be delivered or mailed to 

Enterprise Services Center 
Accounts Receivable Branch 

6 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 6 of 16 PageID #:
290



6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 

and shall be accompanied by a letter identifying the case title, civil action number, and name of 

this Court; David Budzik as a defendant in this action; and specifying that payment is made 

pursuant to this Final Judgment. 

Defendant shall simultaneously transmit photocopies of evidence of payment and case 

identifying information to the Commission's counsel in this action. By making this payment, 

Defendant relinquishes all legal and equitable right, title, and interest in such funds and no part 

of the funds shall be returned to Defendant. 

The Commission may enforce the Court's judgment for disgorgement and prejudgment 

interest by using all collection procedures authorized by law, including, but not limited to, 

moving for civil contempt at any time after 30 days following entry of this Final Judgment. 

The Commission may enforce the Court's judgment for penalties by the use of all 

collection procedures authorized by law, including the Federal Debt Collection Procedures Act, 

~8:IUJSI~}'if§'.1-Soor et seq., and moving for civil contempt for the violation of any Court orders 

issued in this action. Defendant shall pay post judgment interest on any amounts due after 30 

days of the entry of this Final Judgment pursuant to 28 US.C. § 1961. The Commission shall 

hold the funds, together with any interest and income earned thereon ( collectively, the "Fund"), 

pending further order of the Court. 

The Commission may propose a plan to distribute the Fund subject to the Court's 

approval. Such a plan may provide that the Fund shall be distributed pursuant to the Fair Fund 

provisions of Section 308( a) of the Sarbanes-Oxley Act of 2002. The Court shall retain 

jurisdiction over the administration of any distribution of the Fund and the Fund may only be 

disbursed pursuant to an Order of the Court. 

7 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 7 of 16 PageID #:
291



Regardless of whether any such Fair Fund distribution is made, amounts ordered to be 

paid as civil penalties pursuant to this Judgment shall be treated as penalties paid to the 

government for all purposes, including all tax purposes. To preserve the deterrent effect of the 

civil penalty, Defendant shall not, after offset or reduction of any award of compensatory 

damages in any Related Investor Action based on Defendant's payment of disgorgement in this 

action, argue that he is entitled to, nor shall he further benefit by, offset or reduction of such 

compensatory damages award by the amount of any part of Defendant's payment of a civil 

penalty in this action ("Penalty Offset"). If the court in any Related Investor Action grants such 

a Penalty Offset, Defendant shall, within 30 days after entry of a final order granting the Penalty 

Offset, notify the Commission's counsel in this action and pay the amount of the Penalty Offset 

to the United States Treasury or to a Fair Fund, as the Commission directs. Such a payment shall 

not be deemed an additional civil penalty and shall not be deemed to change the amount of the 

civil penalty imposed in this Judgment. For purposes of this paragraph, a "Related Investor 

Action" means a private damages action brought against Defendant by or on behalf of one or 

more investors based on substantially the same facts as alleged in the Complaint in this action. 

VIII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is 

incorporated herein with the same force and effect as if fully set forth herein, and that Defendant 

shall comply with all of the undertakings and agreements set forth therein. 

IX. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of 

exceptions to discharge set forth in Section 523 of the Bankruptcy Code, {lU.'S.C.'§523!, the 

allegations in the complaint are true and admitted by Defendant, and further, any debt for 

8 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 8 of 16 PageID #:
292



s/Nicholas G. Garaufis

disgorgement, prejudgment interest, civil penalty or other amounts due by Defendant under this 

Judgment or any other judgment, order, consent order, decree or settlement agreement entered in 

connection with this proceeding, is a debt for the violation by Defendant of the federal securities 

laws or any regulation or order issued under such laws, as set forth in Section 523(a)(19) of the 

Bankruptcy Code, 11 U.S.C. § 523(a)(19). 

X. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain 

jurisdiction of this matter for the purposes of enforcing the terms of this Judgment. 

XI. 

There being no just reason for delay, pursuant to Rule 54(b) of the Federal Rules of Civil 

Procedure, the Clerk is ordered to enter this Judgment forthwith and without further notice. 

Dated: ~/D, Lb7-lj' 

iftiITED STATES DISTRIC'tiUDGE 

9 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 9 of 16 PageID #:
293



UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 

SECURITIES AND EXCHANGE COMMISSION, 

Plaintiff, 

v. 

NATIVE AMERICAN ENERGY GROUP, INC., 
JOSEPH D' ARRIGO, and DAVID RUDZIK, 

Defendants, 

-and-

LISA D' ARRIGO and LORRAINE 
ALEJANDRO, 

Relief Defendants. 

C.A, No. 23-4455 (NGG)(PK) 

CONSENT OF DEFENDANT DAVID HUDZIK 

Defendant David Hudzik ("Defendant") acknowledges having been served with 

the complaint in this action, enters a general appearance, and admits the Court's jurisdiction over 

Defendant and over the subject matter of this action. 

Without admitting or denying the allegations of the complaint ( except as provided 

herein in paragraph 12 and except as to personal and subject matter jurisdiction, which 

Defendant admits), Defendant hereby consents to the entry of the Judgment in the form attached 

hereto (the "Judgment'') and incorporated by reference herein, which, among other things: 

( a) permanently restrains and enjoins Defendant from violations of Sections 

5(a), 5(c) and 17(a) of the Securities Act of 1933 ("Securities Act") [15 

U.S.C. §§ 77e(a), 77e(c), and 77q(a)J, Section l0(b) of the Securities 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 10 of 16 PageID #:
294



Exchange Act of 1934 ("Exchange Act") [15 U.S.C. § 78j(b)] and Rule 

lOb-5 thereunder [17 C.F.R. § 240.l0b-5], and Section 15(a) of the 

Exchange Act [15 U.S.C, § 78o(a)], as set forth in the Judgment; 

(b) permanently prohibits Defendant from acting as an officer or director of 

any 1ssuer that has a class of securities registered pursuant to Exchange 

Act Section 12 (15 U.S.C. § 781] or that is required to file reports pursuant 

to Exchange Act Section 15(d) [15 U.S.C. § 78o(d)]; 

( c) permanently bars Defendant from participating in any offering of any 

penny stock, including engaging in activities with a broker, dealer, or 

issuer for purposes of issuing, trading, or inducing or attempting to induce 

the purchase or sale of any penny stock, under Exchange Act Section 

21(d)(6) [15 U.S.C. § 78u(d)(6)], provided, however, that such bar shall 

not prevent Defendant from purchasing or selling penny stock in his own 

personal account; 

(d) orders Defendant to pay disgorgement in the amount of $70,000.00, plus 

prejudgment interest thereon in the amount of $17,472.10; and 

( e) orders Defendant to pay a civil penalty in the amount of $70,000.00 under 

Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 

21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]. 

Defendant acknowledges that the civil penalty paid pursuant to the Final 

Judgment may be distributed pursuant to the Fair Fund provisions of Section 308(a) of the 

Sarbanes-Oxley Act of 2002. Regardless of whether any such Fair Fund distribution is made, the 

civil penalty shall be treated as a penalty paid to the government for all purposes, including all 

2 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 11 of 16 PageID #:
295



tax purposes. To preserve the deterrent effect of the civil penalty, Defendant agrees that he shall 

not, after offset or reduction of any award of compensatory damages in any Related Investor 

Action based on Defendant's payment of disgorgement in this action, argue that he is entitled to, 

nor shall he further benefit by, offset or reduction of such compensatory damages award by the 

amount of any part of Defendant's payment of a civil penalty in this action ("Penalty Offset"). If 

the court in any Related Investor Action grants such a Penalty Offset, Defendant agrees that he 

shall, within 30 days after entry of a final order granting the Penalty Offset, notify the 

Commission's counsel in this action and pay the amount of the Penalty Offset to the United 

States Treasury or to a Fair Fund, as the Commission directs. Such a payment shall not be 

deemed an additional civil penalty and shall not be deemed to change the amount of the civil 

penalty imposed in this action. For purposes of this paragraph, a ''Related Investor Action" 

means a private damages action brought against Defendant by or on behalf of one or more 

investors based on substantially the same facts as alleged in the Complaint in this action. 

4. Defendant agrees that he shall not seek or accept, directly or indirectly, 

reimbursement or indemnification from any source, including but not limited to payment made 

pursuant to any insurance policy, with regard to any civil penalty amounts that Defendant pays 

pursuant to the Final Judgment, regardless of whether such penalty amounts or any part thereof 

are added to a distribution fund or otherwise used for the benefit of investors. Defendant further 

agrees that he shall not claim, assert, or apply for a tax deduction or tax credit with regard to a:ny 

federal, state, or local tax for any penalty amounts that Defendant pays pursuant to the Final 

Judgment, regardless of whether such penalty amounts or any part thereof are added to a 

distribution fund or otherwise used for the benefit of :investors. 

5 Defendant waives the entry of findings of fact and conclusions of law pursuant to 

3 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 12 of 16 PageID #:
296



Rule 52 of the Federal Rules of Civil Procedure. 

6 Defendant waives the right, if any, to a jury trial and to appeal from the entry of 

the Judgment. 

7 Defendant enters into this Consent voluntarily and represents that no threats, 

offers, promises, or inducements of any kind have been made by the Commission or any 

member, officer, employee, agent, or representative of the Commission to induce Defendant to 

enter into this Consent. 

8 Defendant agrees that this Consent shall be incorporated into the Judgment with 

the same force and effect as if fully set forth therein. 

9 Defendant will not oppose the enforcement of the Judgment on the ground, if any 

exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil Proc!';)dure, and hereby 

waives any objection based thereon. 

10. Defendant waives service of the Judgment and agrees that entry of the Judgment 

by the Court and filing with the Clerk of the Court will constitute notice to Defendant of its terms 

and conditions. Defendant further agrees to provide counsel for the Commission, within thirty 

days after the Judgment is filed with the Clerk of the Court, with an affidavit or declaration 

stating that Defendant has received and read a copy of the Judgment. 

11. Consistent with 17 C.F.R. § 202.5(f), this Consent resolves only the claims 

asserted against Defendant in this civil proceeding. Defendant acknowledges that no promise or 

representation has been made by the Commission or any member, officer, employee, agent, or 

representative of the Commission with regard to any criminal liability that may have arisen or 

may arise from the facts underlying this action or immunity from any such criminal liability. 

Defendant waives any claim of Double Jeopardy based upon the settlement of this proceeding, 

4 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 13 of 16 PageID #:
297



including the imposition of any remedy or civil penalty herein. Defendant further acknowledges 

that the Court's entry of a permanent injunction may have collateral consequences under federal 

or state law and the rules and regulations of self-regulatory organizations, licensing boards, and 

other regulatory organizations. Such collateral consequences include, but are not limited to, a 

statutory disqualification with respect to membership or participation in, or association with a 

member of, a self-regulatory organization. This statutory disqualification has consequences that 

are separate from any sanction imposed in an administrative proceeding. In addition, in any 

disciplinary proceeding before the Commission based on the entry of the iajunction in thls 

action, Defendant understands that he shall not be permitted to contest the factual allegations of 

the complaint in this action. 

12. Defendant understands and agrees to comply with the terms of 17 C.F.R. 

§ 202.S(e), which provides in part that it is the Commission's policy "not to permit a defendant 

or respondent to consent to a judgment or order that imposes a sanction while denying the 

allegations in the complaint or order for proceedings," and "a refusal to admit the allegations is 

equivalent to a denial, unless the defendant or respondent states that he neither admits nor denies 

the allegations." As part of Defendant's agreement to comply with the tenns of Section 202.S(e), 

Defendant: (i) will not take any action or make or pennit to be made any public statement 

denying, directly or indirectly, any allegation in the complaint or creating the impression that the 

complaint is without factual basis; (ii) will not make or permit to be made any public statement 

to the effect that Defendant does not admit the allegations .of the complaint, or that this Consent 

contains no admission of the allegations, without also stating that Defendant does not deny the 

allegations; (iii) upon the filing of thls Consent, Defendant hereby withdraws any papers filed in 

this action to the extent that they deny any allegation in the complaint; and (iv) stipulates solely 

5 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 14 of 16 PageID #:
298



for purposes of exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 

U.S.C. § 523, that the allegations in the complaint are true, and further, that any debt for 

disgorgement, prejudgment interest, civil penalty or other amounts due by Defendant under the 

Judgment or any other judgment, order, consent order, decree or settlement agreement entered in 

connection with this proceeding, is a debt for the violation by Defendant of the federal securities 

laws or any regulation or order issued under such laws, as set forth in Section 523(a)(19) of the 

Bankruptcy Code, 11 U.S.C. § 523(a)(19). If Defendant breaches this agreement, the 

Commission may petition the Court to vacate the Judgment and restore this action to its active 

docket. Nothing in this paragraph affects Defendant's: (i) testimonial obligations; or (ii) right to 

take legal or factual positions in litigation or other legal proceedings in which the Commission is 

not a party. 

13. Defendant hereby waives any rights under the Equal Access to Justice Act, the 

Small Business Regulatory Enforcement Fairness Act of 1996, or any other provision of law to 

seek from the United States, or any agency, or any official of the United States acting in his or 

her official capacity, directly or indirectly, reimbursement of attorney's fees or other fees, 

expenses, or costs expended by Defendant to defend against this action. For these purposes, 

Defendant agrees that Defendant is not the prevailing party in this action since the parties have 

reached a good faith settlement. 

14. In connection with this action and any related judicial or administrative 

proceeding or investigation commenced by the Commission or to which the Commission is a 

party, Defendant (i) agrees to appear and be interviewed by Commission staff at such times and 

places as the staff requests upon reasonable notice; (ii) will accept service by mail or facsimile 

transmission of notices or subpoenas issued by the Commission for documents or testimony at 

6 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 15 of 16 PageID #:
299



depositions, hearings, or trials, or in connection with any related investigation by Commission 

staff; (iii) with respect to such notices and subpoenas, waives the territorial limits on service 

contained in Rule 45 of the Federal Rules of Civil Procedure and any applicable local rules, 

provided that the party requesting the testimony reimburses Defendant's travel, lodging, and 

subsistence expenses at the then-prevailing U.S. Government per diem rates; and (iv) consents to 

personal jurisdiction over Defendant in any United States District Court for purposes of 

enforcing any such subpoena. 

15. Defendant agrees that the Commission may present the Judgment to the Court for 

signature and entry without further notice. 

16. Defendant agrees that this Court shall retain jurisdiction over this matter for the 

purpose of enforcing the terms of the Judgment. 

~ 
On Auf sl: 2 5~025, David Hudmi:, a person known to me, personally appeared 

before me and knowledged executing the foregoing Consent. 

Notary Public /. 
Commission expires: / //I, Jo~ b 

7 

LOR~AINE ALEJANDRO 
NOTARY PUBLIC, STATE OF NEW YORK 

Registration No. 01AL6149012 
Qualified in Nassau County 

Commission Expires 12/16/20~6 

Case 1:23-cv-04455-NGG-PK     Document 63     Filed 12/11/25     Page 16 of 16 PageID #:
300