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VIII.

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.

IX.

Further Relief

Grant such other and further relief as may be necessary and appropriate.

X.

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.

Respectfully submitted,

March 28, 2005

By:

Roger Cruz Senior Trial Counsel Florida Bar No.157971 Direct Dial: (305) 982-6379

Teresa J. Verges Assistant Regional Director Florida Bar No. 0997651

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