William L. Gunlicks – Partners Capital Management Company

Before the

On the basis of this Order and Respondent’s Offer, the Commission finds that:

1. In June 2008, Marquardt was a senior vice president and the chief administrative officer for operations of [B]Evergreen Investment Management Company, Inc. (“EIMCO”)[/B], an investment adviser registered with the Commission. From April 1998 through April 2009, Marquardt was a registered representative of Evergreen Investment Services, Inc., a broker-dealer registered with the Commission. Marquardt, 42 years old, is a resident of Cambridge, Massachusetts.

2. On March 11, 2010, a final judgment was entered by consent against Marquardt, permanently enjoining him from future violations of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder in the civil action entitled Securities and Exchange Commission v. Charles J. Marquardt, Civil Action Number 10-cv-10073, in the United States District Court for the District of Massachusetts.

3. The Commission’s complaint alleged that, on or about June 12, 2008, Marquardt redeemed all of the shares he owned in the Evergreen Ultra Short Opportunities Fund (“Ultra Fund”) and caused a family member to do the same while Marquardt was in possession of material, nonpublic information about the Ultra Fund that he had learned from his employer, EIMCO.


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