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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA - page 16 / 18

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IV.

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.

V.

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.

VI.

Disgorgement

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

interest.

VII.

Penalties

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).

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