Can a disgorgement order be made against a defendant for failing to pay criminal restitution?
MultiRegion, United States of America
The following excerpt is from Sec. & Exch. Comm'n v. Anthony Vassallo, Kenneth Kenitzer, & Equity Inv. Mgmt. & Training, Inc., No. CIV. S-09-0665 LKK/DAD (E.D. Cal. 2014):
4. Accord, SEC v. C.J.'s Fin., 2012 WL 3600239 at *9 (E.D. Mich.) (Whalen, M.J.), (approving disgorgement order, so long as defendant is given credit for amounts paid in criminal restitution), adopted 2012 WL 3597644 (E.D. Mich. 2012).
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