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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA - page 12 / 18

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or sale of securities, as described in this Complaint, knowingly, willfully or recklessly employed

devices, schemes or artifices to defraud.

42.

By reason of the foregoing, the Defendants have directly and indirectly, violated

and, unless enjoined, will continue to violate Section 17(a)(1) of the Securities Act, 15 U.S.C. §

77q(a).

COUNT II

Fraud In Violation Of Sections 17(a)(2) And 17(a)(3) Of The Securities Act

(Against all Defendants)

  • 43.

    The Commission repeats and realleges paragraphs 1 through 39 of its Complaint.

  • 44.

    The Defendants, directly and indirectly, by use of the means or instruments of

transportation or communication in interstate commerce and by the use of the mails, in the offer

or sale of securities, as described in this Complaint, have: (a) obtained money or property by

means of untrue statements of material facts and omissions to state material facts necessary to

make the statements made, in the light of the circumstances under which they were made, not

misleading; and/or (b) engaged in transactions, practices and courses of business which are now

operating and will operate as a fraud or deceit upon purchasers and prospective purchasers of

such securities.

45.

By reason of the foregoing, the Defendants, directly and indirectly, have violated

and, unless enjoined, will continue to violate Sections 17(a)(2) and 17(a)(3) of the Securities Act,

15 U.S.C. §§ 77q(a)(2) and 77q(a)(3).

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