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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA - page 15 / 18

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RELIEF REQUESTED

WHEREFORE, the Commission respectfully requests that the Court:

I.

Declaratory Relief

Declare, determine and find that the Defendants have committed the violations of the

federal securities laws alleged herein.

II.

Temporary Restraining Order, Preliminary Injunction and Permanent Injunction

Issue a Temporary Restraining Order, a Preliminary Injunction and a Permanent

Injunction, restraining and enjoining the Defendants, their officers, agents, servants, employees,

attorneys, and all persons in active concert or participation with them, and each of them, from

violating Section 17(a) of the Securities Act, 15 U.S.C. § 77q(a); Section 10(b) and Rule 10b-5

of the Exchange Act, 15 U.S.C. § 78j(b); Section 15(a) of the Exchange Act, 15 U.S.C. §

78o(a)(1); and Sections 206(1) and 206(2) of the Advisers Act, 15 U.S.C. § 80b-6, as indicated

above.

III.

Asset Freeze and Sworn Accountings

Issue an Order freezing the assets of all Defendants until further Order of the Court and

requiring the Defendants to file with this Court, within five business days, sworn written

accountings.

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