The defendants have violated, are about to by reason of the foregoing

violate, and unless restrained and enjoined will continue to violate area 17(a) for the Securities Act, 15 U.S.C. В§ 77q(a), and area 10(b) of this Exchange Act, 15 U.S.C. В§ 78j(b), and Rule 10b-5 promulgated thereunder, 17 C.F.R. В§ 240.10b-5.

WHEREFORE , Plaintiff Commission respectfully requests that this Court:

A. Grant an Order temporarily and preliminarily, and a Final Judgment forever enjoining defendants, their officers, agents, servants, workers, lawyers, and all sorts of individuals in active concert or participation using them who receive real notice associated with injunction by individual solution or perhaps, and every of those, from future violations of parts 5(a) and (c), 15 U.S.C. §§ 77e(a) and 77e(c), and 17(a) of this Securities Act, 15 U.S.C. § 77q(a).

B. Grant an Order temporarily and preliminarily, and a Final Judgment forever enjoining defendants, their officers, agents, servants, employees, lawyers, and all sorts of persons in active concert or participation from future violations of Section 10(b) of the Exchange Act, 15 U.S.C. В§ 78j(b), and Rule 10b-5 promulgated thereunder, 17 C.F.R. В§ 240.10b-5 with them who receive actual notice of the injunction by personal service or otherwise, and each of them.

C. Grant an Order directing defendants, and every of those, to register using this Court and provide upon plaintiff, within three company times, or within such expansion of the time because the Commission agrees, a confirmed written accounting, signed by them under penalty of perjury, of:

1. All assets, liabilities and home currently held straight or indirectly by and for the main benefit of defendants, and each of these, including although not limited by bank records, brokerage records, opportunities, company passions, loans, credit lines, and genuine and property that is personal situated, describing each https://badcreditloansadvisor.com/payday-loans-ma/ asset and obligation, and its own present location and amount;

2. All cash, home, assets, as well as other income gotten by defendants, and every of these, or even for their direct or indirect advantage, in or at any time from might 22, 2001 to your date of this accounting, explaining the foundation, quantity, disposition and present location of each and every associated with products detailed;

3. The names and final understood addresses of most bailees, debtors, along with other persons and entities that are presently keeping the assets, funds or home of defendants, and every of those; and

4. All assets, funds, securities, genuine or personal property gotten by defendants, and every of these, or just about any other individual managed by them, from individuals whom offered cash to defendants associated with the offer, purchase or purchase of opportunities of all kinds, while the disposition of these assets, funds, assets, and genuine or property that is personal.

Grant a Final Judgment directing defendants to disgorge their unjust enrichment through the conduct that is fraudulent in this issue and also to pay prejudgment interest thereon.

E. Grant a Final Judgment evaluating penalties against defendants pursuant to Section d that is 20( associated with the Securities Act, 15 U.S.C. В§ 77t(d), and Section 21(d)(3) of this Exchange Act, 15 U.S.C. В§ 78u(d)(3), for the violations alleged herein.

F. Grant an Order directing that defendants, and their officers, agents, servants, workers, attorneys-in-fact, and all sorts of people in active concert or participation with every of those, whom get actual notice of these Order by individual service, facsimile solution, or elsewhere, and every of these, hold and retain of their control, and otherwise prevent any withdrawal, transfer, pledge, encumbrance, project, dissipation, concealment, or other disposal of any assets, funds, or any other properties (including money, real or individual home, securities, chooses for action or property of every kind whatsoever) of defendants presently held by them or under their control, whether held in almost any of these names or even for any one of their direct or indirect beneficial interest anywhere situated, and directing each one of the economic or brokerage organizations, debtors, and bailees, or other person or entity keeping such assets, funds, or any other properties of defendants, and every of those, to carry or retain within its control and prohibit the withdrawal, treatment, transfer, or any other disposal of any such assets, funds, or other properties.

G. Grant an Order enjoining and restraining defendants or anyone or entity acting at their direction or for the kids from destroying, changing, concealing or elsewhere interfering with all the access for the plaintiff to any and all sorts of papers, books and documents that are into the control, custody or control of defendants, their agents, employees, servants, accountants, financial or brokerage organizations, and lawyers that refer, reflect or connect with the allegations for the issue, including, although not limited by, papers, publications and documents referring, showing or concerning Ace Payday’s business operations, and its own offer or purchase of securities while the usage of profits therefrom.

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