Please find relevant points and background for the matters with the Illinois Securities Division . For the record, after an exhaustive 3 year period the Hearing Officer Soula Spryopolous) found in my favor and stated that there wasn’t any fraud. However, Maria Pavone, the same person who brought the proceedings with the multiple mistakes flatly rejected the hearing officers findings. Included are a series of email which I kept on the matter and have compiled. I wanted you to have this for your own edification.. Please find the relevant points below:

  1. Investors put money in a unregulated entity and signed contracts for loans with that company.

  1. Maria Pavone put the wrong company in the proceedings, a formerly regulated firm that wasn’t a party to the transaction.  The regulated company had been closed for a number of years. Ms Pavone related this to Tom Benigno an advisor to the Secretary of State. The two investors stated that FINRA officials directed them to the Illinois Securities division for matters outside their purview and then told the individualto “keep in touch with them” for settled matters as well. They have signed and notarized affidavits stating such along with other relevant statements by Ms. Pavone and Mr. Nix.

  1. Ms. Pavone wrote several factually incorrect postings which used the wrong company but failed to show the actual account which had millions of firm dollars at Goldman Sachs and literally over $100 million of client’s assets in a separate brokerage account while Baldwin’s personal account had over $457,000.00.. Ms.Pavone instead published information from a closed account from a separate entity not involved in the transaction that had a negative balance.‎ Ms. Pavone additionally misspelled Baldwin’s name, used an incorrect address, wrong company and incorrect names for investors.

  1. Ms. Pavone started the postings in 2011 but delayed actually having the hearings‎ after requests for over 8 months. After some significant political pressure the hearings were finally started. During the proceedings Ms. Pavone made many incorrect statements including that Baldwin never responded to any questions. Baldwin provided 5 binders of information to the Secretary of State with Tom Benigno along with providing copies to the senior members of the office.

  1. The investors were paid, signed settlements made Maria Pavone and James Nix aware in December of 2012. Mr. Baldwin called to confirm and shared this with the Hearing Officer Ms. Spryopolous, Mr.Nix and Ms. Pavone. Ms. Pavone attempted to block payments to investors and she along with Mr. Nix called investors yelling because they were upset that they took settlements. When Baldwin initially made the offer Nix and Pavone called the offers not real and refused to forward them to investors, while in the proceedings Mr. Nix said that the payments weren’t real and called for sanctions. The checks and wires to investors state otherwise.

  1. Investors have signed affidavits contradicting  all the points that Pavone and Nix posted.

  1. Hearing Officer ( Soula Spryopolous) found in  favor of Baldwin and said there was no fraud.

  1. Nix tried to get Baldwin to settle for fraud and initially wrote a document stating that Baldwin had committed an omission of fact along with the correct company‎. The document doesn’t state fraud and only uses the correct company. Mr. Nix wanted Baldwin to blindly agree to terms not presented with a caveat that Baldwin accept jurisdiction and a bar. Baldwin politely refused.

  1. Due to Baldwin’s refusal to sign the document, Pavone rejected the Hearing Officers findings and stated that the investors weren’t paid and once again posted incorrect information knowingly. Ms. Pavone then fined the company that the Illinois Secretary of State didn’t regulate and had been dissolved years ago along with fining Baldwin.

  1. Mr. Nix delayed sending the final order document to me after multiple requests—eventually the final order was delivered by Mr. Sianis–more than 28 days late.‎ I noted this and made them aware that it would harm my response time. My request for an appeal was later denied because it was deemed to be too late.

  1. Although Baldwin vehemently disagrees with the finding, Baldwin requests multiple times on how he can have the company comply with the Final Order after the last 3 years of proceedings multiple times for over 9 months—no response is ever given from anyone at the Illinois Secretary of State.

In closing, the investors settled, were paid and have contradicted everything that Ms. Pavone wrote in her postings about the loans. Ms. Pavone additionally compelled them to testify to the Attorney General and asked them to where wires to record Baldwin.. The Illinois Attorney General looked into the matter and saw they were paid and never contacted Baldwin again.

Please find the orders attached, a side by side comparison shows the gross mistakes. As a final point, Ms. Pavone used an incorrect name for one of the investors, the individual tha FINRA directed to the Illinois Secretary of State.. On a very base level, the postings and final order are riddled with so many factual inaccuracies that the Illinois Secretary of State should be corrected if the organization wants an accurate record reflected.

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