Appointment of a Receiver
Issue an Order appointing a receiver over all assets held in the name of Defendants
Pension Fund, PFA Assurance, PFA International, and Claren to (1) preserve the status quo, (2)
ascertain the financial condition of each of these Defendant entities, (3) prevent further
dissipation of the property and assets of each of these Defendant entities, to prevent loss, damage
and injury to investors, (4) preserve the books, records and documents of each of these
Defendant entities, and (5) be available to respond to investor inquiries.
Records Preservation and Expedited Discovery
Issue an Order requiring the Defendants to preserve any records related to the subject
matter of this lawsuit that are in their custody or possession or subject to their control, and to
respond to discovery on an expedited basis.
Issue an Order directing the Defendants to disgorge all profits or proceeds that they have
received as a result of the acts and/or courses of conduct complained of herein, with prejudgment
Issue an Order directing all Defendants to pay civil money penalties pursuant to Section
20(d) of the Securities Act, 15 U.S.C. § 77t(d); Section 21(d) of the Exchange Act, 15 U.S.C. §
78u(d); and Section 209(e) of the Advisers Act, 15 U.S.C. §§ 80b-9(e).