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the insurance component of the retirement trust plans. PFA Assurance has also recently assumed

the role of issuer, and serves as adviser and manager of the plans.

6.

PFA International, Ltd. (“PFA International”) is a Cayman Islands corporation

formed in 2003, with its principal place of business in Coral Gables, Florida. PFA International

is a shell company Pension Fund and PFA Assurance use to pay their sales agents.

7.

Claren TPA, LLC (“Claren”) is a Florida limited liability corporation formed in

April 2004, with its principal place of business in Coral Gables, Florida. Claren purportedly

serves as third-party administrator for the investment plans Pension Fund and PFA Assurance

issue.

8.

Luis M. Cornide (“Cornide”) is 39 years old and resides in Coral Gables, Florida.

Cornide is President of Pension Fund and serves as manager of Claren. He is also President of

PFA Assurance and Chairman of PFA International.

9.

Robert de la Riva (“de la Riva”) is 31 years old and resides in Coral Gables, Florida.

He is Senior Vice President of Pension Fund and serves as manager of Claren. He is also a

director of PFA Assurance and Secretary of PFA International.

JURISDICTION AND VENUE

10.

This Court has jurisdiction over this action pursuant to Sections 20(b), 20(d) and

22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§ 77t(b), 77t(d) and 77v(a);

Sections 21(d), 21(e), and 27 of the Securities Exchange Act of 1934 (“Exchange Act”), 15

U.S.C. §§ 78u(d), 78u(e) and 78aa; and Section 214 of the Investment Advisers Act of 1940

(“Advisers Act”), 15 U.S.C. § 80b-14.

11.

Venue

is

proper

in

the

Southern

District

of

Florida

because

many

of

the

Defendants’ acts and transactions constituting violations of the Securities Act, the Exchange Act,

3

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