Repatriation of Investor Proceeds
Issue an Order requiring the Defendants to take such steps as are necessary to repatriate
to the territory of the United States all funds and assets of investors described in the
Commission’s Complaint in this action which are held by them or are under their direct or
indirect control, and deposit such funds into the registry of the United States District Court for
the Southern District of Florida, and provide the Commission and the Court a written description
of the funds and assets so repatriated.
Grant such other and further relief as may be necessary and appropriate.
Retention of Jurisdiction
Further, the Commission respectfully requests that the Court retain jurisdiction over this
action in order to implement and carry out the terms of all orders and decrees that may hereby be
entered, or to entertain any suitable application or motion by the Commission for additional
relief within the jurisdiction of this Court.
March 28, 2005
Roger Cruz Senior Trial Counsel Florida Bar No.157971 Direct Dial: (305) 982-6379
Teresa J. Verges Assistant Regional Director Florida Bar No. 0997651