SEC v. Peter D. Krieger, No. 9:23-cv-80398, Southern District of Florida (Mar. 15, 2023) — Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 9:23-cv-80398
SECURITIES AND EXCHANGE COMMISSION, )
)
Plaintiff, )
)
v.        )
)
PETER D. KRIEGER      )
)
)
Defendant.      )
______________________________________________    )
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF AND
DEMAND FOR JURY TRIAL
Plaintiff Securities and Exchange Commission (“Commission”) alleges:
I.INTRODUCTION
1.From  May  2016  through  August  2020,  Oban Energies,  LLC  (“Oban”),  a
Florida-based entity managed by Defendant Peter D. Kreiger, raised approximately $15 million
from 23 investors. Investors, some of whom were elderly, were told that their funds would be
used to develop an oil refinery and storage facility in the Bahamas (the “Project”).
2.In reality, from January 2017 through August 2020, Defendant misappropriated
approximately $5.2 million of investor funds to pay for personal expenses, such as luxury cars,
jewelry, and vacations.
3.By engaging in this conduct, Defendant violated Sections 17(a)(1) and 17(a)(3)
of the Securities Act of 1933 (“Securities Act”),15 U.S.C. §§ 77q(a)(1) and 77q(a)(3); Section
10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”),15 U.S.C. § 78j(b); and

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Exchange  Act  Rules  10b-5(a)  and  10b-5(c)  promulgated  thereunder, 17  C.F.R.  §§  240.10b-
5(a)  and  240.10b-5(c).  Unless  enjoined,  Defendant  will  continue  to  violate  the  federal
securities laws.
II. DEFENDANT
4. Krieger, age 49, is a resident of Jupiter, Florida. Krieger was Oban’s manager,
ran its day-to-day operations from 2017 through 2018, and maintained exclusive control over
Oban’s bank account from January 2017 through August 2020.
III. RELEVANT ENTITY
5. Oban  was  a  Florida  limited  liability  company  formed  in  June  2016 with  its
principal  place  of  business  in  Palm  Beach  Gardens,  Florida.   Oban  was  dissolved in  March
2021, and its assets and liabilities were purchased by Lucayan Trans Fuels LLC (“Lucayan”),
which was formed by certain Oban investors.
IV. JURISDICTION AND VENUE
6. The  Court  has  jurisdiction  over  this  action  pursuant  to  Sections  20(b),  20(d),
and 22(a) of the Securities Act, 15 U.S.C. §§ 77t(b), 77t(d), and 77v(a), and Sections 21(d),
21(e), and 27 of the Exchange Act, 15 U.S.C. §§ 78u(d), 77u(e) and 78aa.
7. This Court has personal jurisdiction over Defendant and venue is proper in this
district because  many  of  Defendant’s  actions  and  transactions  constituting  violations  of  the
Securities Act and the Exchange Act occurred in this district, Defendant resides in this district,
and Oban’s principal place of business was in this district.

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8. In connection with the conduct alleged in this Complaint, Defendant, directly
and indirectly, made use of the means or instrumentalities of interstate commerce, the means
or instruments of transportation and communication in interstate commerce, and the mails.
V. FACTS

A. Defendant Led Oban’s Efforts to Develop the Project in the Bahamas
9. In   2009,   Defendant   and   the   Bahamian   government   began   discussing
Defendant’s interest in developing the Project with capital raised from U.S. investors.
10. After  years-long  discussions  progressed, Oban  was  formed  in  mid-2016  to
develop the Project and started raising money from investors to fund the Project.
11. Most investors   in Oban are friends with Defendant and each other, live at least
part-time in the same community, and were solicited by word-of-mouth.
12. Investors entered into a written Operating Agreement, which was last amended
on  March  12,  2018. The  Operating  Agreement  refers  to  investors  as  “Members,”  who  each
received a “Member Interest”   in Oban in exchange for their capital contribution. The Operating
Agreement is an investment contract. Investors relied solely on Oban to generate profits and
Oban’s ability to do so depended entirely on its ability to successfully develop the Project. As
an  investment  contract,  the Operating  Agreement  is  a  security  within  the  meaning  of  the
Securities Act and the Exchange Act.
13. Defendant ran Oban’s day-to-day operations and led its efforts to develop the
Project. In February 2018, Oban and the Bahamian Government signed a Heads of Agreement
(the  “Agreement”) awarding  Oban  the  rights    to  develop  the  Project.  Shortly  thereafter,
however, the Bahamian Government sought to renegotiate the terms of the Agreement.

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14. In the meantime, Oban formalized a board of managers (the “ Board”) in March
2018. The Board consisted of four investors who were to provide oversight over the Project
and status updates to members while renegotiation discussions with the Bahamian Government
ensued.
15.   The Board had exclusive authority to manage and control all aspects of Oban’s
business and operations, including but not limited to, overseeing Oban’s day-to day operations,
making expenditures to conduct Oban’s business, and investing Oban’s assets.
16. Despite  stepping  back  as  the  face  of  Oban  in  early 2018 shortly  after  the
Agreement was executed, Krieger continued to spearhead the Project on behalf of Oban and
maintain exclusive control over its bank account.
17. In  late  2020,  Oban’s  Board  discovered  that  Defendant was  misappropriating
investor funds for personal use and immediately took steps to remove him from Oban.
B. Defendant Misappropriated Investor Funds
18. From January 2017 through August 2020, Defendant was the sole signatory on
Oban’s bank account and exercised exclusive control over it.
19. During that time, Defendant misappropriated at least $5.2 million of investor
funds to pay for personal expenses, such as luxury cars, jewelry, designer clothing, vacations
to Aspen and Hawaii, and day-to-day living expenses.
20. Specifically, Defendant diverted approximately $3.7 million of investor funds
through various means to the bank account of an unrelated entity he controlled, Mid Atlantic
Group, Inc. (“MAG”). For instance, Defendant deposited approximately $795,000 of investor
funds  directly  into  MAG’s  bank  account.  Defendant also diverted through  hundreds  of

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electronic  funds  transfers approximately  $1.37  million of  investor  funds  from  Oban’s  bank
account to MAG’s bank account.  Furthermore, in an effort to conceal his misappropriation,
Defendant transferred $1.5 million of investor funds from Oban’s bank account to an account
for  another  entity  he  controlled,  S&P  Projects,  LLC  (“S&P”).  From  there,  Defendant
transferred the $1.5 million to the trust accounts of Oban’s outside attorney, who then routed
the money back to MAG.
21. Additionally, Defendant transferred another $1.5 million in investor funds from
Oban’s bank account to pay credit card charges for S&P.
22. Defendant’s  transfers  of approximately  $5.2  million  of  investor  funds  for  his
personal use were not disclosed to or authorized by Oban’s Board.
VI. CLAIMS FOR RELIEF
COUNT 1
VIOLATIONS OF SECTION 17(a)(1) OF THE SECURITIES ACT
23. The   Commission   adopts   by   reference   paragraphs   1   through   22 of   this
Complaint.
24. Defendant, in the offer or sale of securities by use of any means or instruments
of transportation or communication in interstate commerce or by use of the mails, directly or
indirectly, knowingly or recklessly employed devices, schemes, or artifices to defraud.
25. By  reason  of  the  foregoing,  Defendant,  directly  or  indirectly,  violated  and,
unless enjoined, is reasonably likely to continue to violate Section 17(a)(1) of the Securities
Act, 15 U.S.C. § 77q(a)(1).

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COUNT 2
VIOLATIONS OF SECTION 17(a)(3) OF THE SECURITIES ACT
26. The   Commission   adopts   by   reference   paragraphs   1   through   22 of   this
Complaint.
27. Defendant, in the offer or sale of securities by use of any means or instruments
of transportation or communication in interstate commerce or by use of the mails, directly or
indirectly,  negligently  engaged  in  transactions,  practices,  or  courses  of  business  which
operated or would have operated as a fraud or deceit upon the purchasers.
28. By  reason  of  the  foregoing,  Defendant,  directly  or  indirectly,  violated  and,
unless enjoined, is reasonably likely to continue to violate Section 17(a)(3) of the Securities
Act, 15 U.S.C. § 77q(a)(3).
COUNT 3
VIOLATIONS OF SECTION 10(b) AND RULE 10b-5(a) OF THE EXCHANGE ACT
29. The   Commission   adopts   by   reference   paragraphs   1   through   22 of   this
Complaint.
30. Defendant, directly or indirectly, by the use of any means or instrumentality of
interstate commerce, or of the mails, knowingly or recklessly employed devices, schemes or
artifices to defraud in connection with the purchase or sale of securities.
31. By  reason  of  the  foregoing,  Defendant,  directly  or  indirectly,  violated  and,
unless enjoined, is reasonably likely to continue to violate Section 10(b) of the Exchange Act,
15 U.S.C. § 78j(b), and Exchange Act Rule 10b-5(a), 17 C.F.R. § 240.10b-5(a).

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COUNT 4
VIOLATIONS OF SECTION 10(b) AND RULE 10b-5(c) OF THE EXCHANGE ACT
32. The   Commission   adopts   by   reference   paragraphs   1   through   22 of   this
Complaint.
33. Defendant, directly or indirectly, by the use of any means or instrumentality of
interstate commerce, or of the mails, knowingly or recklessly engaged in acts, practices, and
courses of business which have operated, are now operating and will operate as a fraud upon
the purchasers of such securities.
34. By  reason  of  the  foregoing,  Defendant,  directly  or  indirectly,  violated  and,
unless enjoined, is reasonably likely to continue to violate Section 10(b) of the Exchange Act,
15 U.S.C. § 78j(b), and Exchange Act Rule 10b-5(c), 17 C.F.R. § 240.10b-5(c).
VII. RELIEF REQUESTED
WHEREFORE,  the  Commission  respectfully  requests  that  the  Court  find  the
Defendant committed the violations alleged and:
A. Permanent Injunction
Issue  a  Permanent  Injunction,  restraining  and  enjoining  Defendant  from  violating
Sections 17(a)(1) and 17(a)(3) of the Securities Act, Section 10(b) of the Exchange Act, and
Exchange Act Rules 10b-5(a) and 10b-5(c) promulgated thereunder.
B. Conduct-Based Injunction
 Issue  a  Conduct-Based  Injunction,  restraining  and  enjoining  Defendant  from  (i)
participating in the issuance, purchase, offer, or sale of any security provided, however, that
such injunction shall not prevent Defendant from purchasing or selling securities for his own

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personal  account,  and (ii)  participating  in  the  management,  supervision  of,  or  otherwise
exercising any control over, any commercial enterprise or project that issues, purchases or sells
securities, pursuant to Section 21(d)(5) of the Exchange Act.
C.     Disgorgement
 Issue   an   Order   directing   Defendant   to   disgorge   all   ill-gotten   gains,   including
prejudgment interest, resulting from the acts or courses of conduct alleged in this Complaint.
D. Civil Penalty
Issue  an  Order  directing  Defendant  to  pay  civil  money  penalties  pursuant  to  Section
20(d)  of  the  Securities  Act,  15  U.S.C.  §  77t(d),  and  Section  21(d)  of  the  Exchange  Act,  15
U.S.C. § 78(d).
E. Officer and Director Bar
Issue an Order, pursuant to Section 20(e) of the Securities Act, 15 U.S.C. § 77t(e), and
Section 21(d)(2) of the Exchange Act, 15 U.S.C. § 78u(d)(2), barring Defendant from acting
as an officer or director of any issuer that has a class of securities registered pursuant to Section
12  of  the  Exchange  Act  or  that  is  required  to  file  reports  pursuant  to  Section  15(d)  of  the
Exchange Act.
F. Further Relief
Grant such other and further relief as may be necessary and appropriate.
G. 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 it may
enter, or to entertain any suitable application or motion by the Commission for additional relief
within the jurisdiction of this Court.

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VIII.   DEMAND FOR JURY TRIAL
The Commission hereby demands a trial by jury on any and all issues in this action so
triable.
March 13, 2023    Respectfully submitted,

     By: /s/ Stephanie N. Moot
      Stephanie N. Moot
      Senior Trial Counsel
      Fla. Bar No.  30377
      Direct Dial:  (305) 982-6313
E-  mail: [email protected]

      Steven J. Meiner
      Senior Counsel
      New York Bar No. 2785806
      Direct Dial:  (305) 982-6336
E-  mail: [email protected]

 Attorneys for Plaintiff
      Securities and Exchange Commission
      801 Brickell Avenue, Suite 1950
Miami, FL 33131
Telephone:  (305) 982-6300
     Facsimile:  (305) 536-4154

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 9:23-cv-80398

SECURITIES AND EXCHANGE COMMISSION, ) 
) 

Plaintiff, ) 
) 

v.        ) 
) 

PETER D. KRIEGER      ) 
) 
) 

Defendant.      ) 
______________________________________________ ) 

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF AND 
DEMAND FOR JURY TRIAL  

Plaintiff Securities and Exchange Commission (“Commission”) alleges: 

I. INTRODUCTION

1. From May 2016 through August 2020, Oban Energies, LLC (“Oban”), a

Florida-based entity managed by Defendant Peter D. Kreiger, raised approximately $15 million 

from 23 investors. Investors, some of whom were elderly, were told that their funds would be 

used to develop an oil refinery and storage facility in the Bahamas (the “Project”).  

2. In reality, from January 2017 through August 2020, Defendant misappropriated

approximately $5.2 million of investor funds to pay for personal expenses, such as luxury cars, 

jewelry, and vacations.  

3. By engaging in this conduct, Defendant violated Sections 17(a)(1) and 17(a)(3)

of the Securities Act of 1933 (“Securities Act”),15 U.S.C. §§ 77q(a)(1) and 77q(a)(3); Section 

10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”),15 U.S.C. § 78j(b); and 

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Exchange Act Rules 10b-5(a) and 10b-5(c) promulgated thereunder, 17 C.F.R. §§ 240.10b-

5(a) and 240.10b-5(c). Unless enjoined, Defendant will continue to violate the federal 

securities laws. 

II. DEFENDANT 

4. Krieger, age 49, is a resident of Jupiter, Florida. Krieger was Oban’s manager, 

ran its day-to-day operations from 2017 through 2018, and maintained exclusive control over 

Oban’s bank account from January 2017 through August 2020. 

III. RELEVANT ENTITY 

5. Oban was a Florida limited liability company formed in June 2016 with its 

principal place of business in Palm Beach Gardens, Florida.  Oban was dissolved in March 

2021, and its assets and liabilities were purchased by Lucayan Trans Fuels LLC (“Lucayan”), 

which was formed by certain Oban investors.   

IV. JURISDICTION AND VENUE 

6. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), 

and 22(a) of the Securities Act, 15 U.S.C. §§ 77t(b), 77t(d), and 77v(a), and Sections 21(d), 

21(e), and 27 of the Exchange Act, 15 U.S.C. §§ 78u(d), 77u(e) and 78aa. 

7. This Court has personal jurisdiction over Defendant and venue is proper in this 

district because many of Defendant’s actions and transactions constituting violations of the 

Securities Act and the Exchange Act occurred in this district, Defendant resides in this district, 

and Oban’s principal place of business was in this district. 

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8. In connection with the conduct alleged in this Complaint, Defendant, directly 

and indirectly, made use of the means or instrumentalities of interstate commerce, the means 

or instruments of transportation and communication in interstate commerce, and the mails. 

V. FACTS 
 

A. Defendant Led Oban’s Efforts to Develop the Project in the Bahamas 

9. In 2009, Defendant and the Bahamian government began discussing 

Defendant’s interest in developing the Project with capital raised from U.S. investors. 

10. After years-long discussions progressed, Oban was formed in mid-2016 to 

develop the Project and started raising money from investors to fund the Project.  

11. Most investors in Oban are friends with Defendant and each other, live at least 

part-time in the same community, and were solicited by word-of-mouth.  

12. Investors entered into a written Operating Agreement, which was last amended 

on March 12, 2018. The Operating Agreement refers to investors as “Members,” who each 

received a “Member Interest” in Oban in exchange for their capital contribution. The Operating 

Agreement is an investment contract. Investors relied solely on Oban to generate profits and 

Oban’s ability to do so depended entirely on its ability to successfully develop the Project. As 

an investment contract, the Operating Agreement is a security within the meaning of the 

Securities Act and the Exchange Act.  

13. Defendant ran Oban’s day-to-day operations and led its efforts to develop the 

Project. In February 2018, Oban and the Bahamian Government signed a Heads of Agreement 

(the “Agreement”) awarding Oban the rights to develop the Project. Shortly thereafter, 

however, the Bahamian Government sought to renegotiate the terms of the Agreement.   

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4 
 

14. In the meantime, Oban formalized a board of managers (the “Board”) in March 

2018. The Board consisted of four investors who were to provide oversight over the Project 

and status updates to members while renegotiation discussions with the Bahamian Government 

ensued. 

15.   The Board had exclusive authority to manage and control all aspects of Oban’s 

business and operations, including but not limited to, overseeing Oban’s day-to day operations, 

making expenditures to conduct Oban’s business, and investing Oban’s assets. 

16. Despite stepping back as the face of Oban in early 2018 shortly after the 

Agreement was executed, Krieger continued to spearhead the Project on behalf of Oban and 

maintain exclusive control over its bank account. 

17. In late 2020, Oban’s Board discovered that Defendant was misappropriating 

investor funds for personal use and immediately took steps to remove him from Oban.    

B. Defendant Misappropriated Investor Funds 

18. From January 2017 through August 2020, Defendant was the sole signatory on 

Oban’s bank account and exercised exclusive control over it.   

19. During that time, Defendant misappropriated at least $5.2 million of investor 

funds to pay for personal expenses, such as luxury cars, jewelry, designer clothing, vacations 

to Aspen and Hawaii, and day-to-day living expenses.    

20. Specifically, Defendant diverted approximately $3.7 million of investor funds 

through various means to the bank account of an unrelated entity he controlled, Mid Atlantic 

Group, Inc. (“MAG”). For instance, Defendant deposited approximately $795,000 of investor 

funds directly into MAG’s bank account. Defendant also diverted through hundreds of 

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5 
 

electronic funds transfers approximately $1.37 million of investor funds from Oban’s bank 

account to MAG’s bank account.  Furthermore, in an effort to conceal his misappropriation, 

Defendant transferred $1.5 million of investor funds from Oban’s bank account to an account 

for another entity he controlled, S&P Projects, LLC (“S&P”). From there, Defendant 

transferred the $1.5 million to the trust accounts of Oban’s outside attorney, who then routed 

the money back to MAG. 

21. Additionally, Defendant transferred another $1.5 million in investor funds from 

Oban’s bank account to pay credit card charges for S&P.  

22. Defendant’s transfers of approximately $5.2 million of investor funds for his 

personal use were not disclosed to or authorized by Oban’s Board.  

VI. CLAIMS FOR RELIEF 

COUNT 1 

VIOLATIONS OF SECTION 17(a)(1) OF THE SECURITIES ACT 

23. The Commission adopts by reference paragraphs 1 through 22 of this 

Complaint. 

24. Defendant, in the offer or sale of securities by use of any means or instruments 

of transportation or communication in interstate commerce or by use of the mails, directly or 

indirectly, knowingly or recklessly employed devices, schemes, or artifices to defraud. 

25. By reason of the foregoing, Defendant, directly or indirectly, violated and, 

unless enjoined, is reasonably likely to continue to violate Section 17(a)(1) of the Securities 

Act, 15 U.S.C. § 77q(a)(1). 

 

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COUNT 2 

VIOLATIONS OF SECTION 17(a)(3) OF THE SECURITIES ACT 

26. The Commission adopts by reference paragraphs 1 through 22 of this 

Complaint. 

27. Defendant, in the offer or sale of securities by use of any means or instruments 

of transportation or communication in interstate commerce or by use of the mails, directly or 

indirectly, negligently engaged in transactions, practices, or courses of business which 

operated or would have operated as a fraud or deceit upon the purchasers. 

28. By reason of the foregoing, Defendant, directly or indirectly, violated and, 

unless enjoined, is reasonably likely to continue to violate Section 17(a)(3) of the Securities 

Act, 15 U.S.C. § 77q(a)(3). 

COUNT 3 

VIOLATIONS OF SECTION 10(b) AND RULE 10b-5(a) OF THE EXCHANGE ACT 

29. The Commission adopts by reference paragraphs 1 through 22 of this 

Complaint. 

30. Defendant, directly or indirectly, by the use of any means or instrumentality of 

interstate commerce, or of the mails, knowingly or recklessly employed devices, schemes or 

artifices to defraud in connection with the purchase or sale of securities. 

31. By reason of the foregoing, Defendant, directly or indirectly, violated and, 

unless enjoined, is reasonably likely to continue to violate Section 10(b) of the Exchange Act, 

15 U.S.C. § 78j(b), and Exchange Act Rule 10b-5(a), 17 C.F.R. § 240.10b-5(a). 

 

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COUNT 4 

VIOLATIONS OF SECTION 10(b) AND RULE 10b-5(c) OF THE EXCHANGE ACT 

32. The Commission adopts by reference paragraphs 1 through 22 of this 

Complaint. 

33. Defendant, directly or indirectly, by the use of any means or instrumentality of 

interstate commerce, or of the mails, knowingly or recklessly engaged in acts, practices, and 

courses of business which have operated, are now operating and will operate as a fraud upon 

the purchasers of such securities. 

34. By reason of the foregoing, Defendant, directly or indirectly, violated and, 

unless enjoined, is reasonably likely to continue to violate Section 10(b) of the Exchange Act, 

15 U.S.C. § 78j(b), and Exchange Act Rule 10b-5(c), 17 C.F.R. § 240.10b-5(c). 

VII. RELIEF REQUESTED 

WHEREFORE, the Commission respectfully requests that the Court find the 

Defendant committed the violations alleged and: 

A. Permanent Injunction 

Issue a Permanent Injunction, restraining and enjoining Defendant from violating 

Sections 17(a)(1) and 17(a)(3) of the Securities Act, Section 10(b) of the Exchange Act, and 

Exchange Act Rules 10b-5(a) and 10b-5(c) promulgated thereunder.  

B. Conduct-Based Injunction 

 Issue a Conduct-Based Injunction, restraining and enjoining Defendant from (i) 

participating in the issuance, purchase, offer, or sale of any security provided, however, that 

such injunction shall not prevent Defendant from purchasing or selling securities for his own 

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8 
 

personal account, and (ii) participating in the management, supervision of, or otherwise 

exercising any control over, any commercial enterprise or project that issues, purchases or sells 

securities, pursuant to Section 21(d)(5) of the Exchange Act. 

C. Disgorgement 

 Issue an Order directing Defendant to disgorge all ill-gotten gains, including 

prejudgment interest, resulting from the acts or courses of conduct alleged in this Complaint. 

D. Civil Penalty 

Issue an Order directing Defendant to pay civil money penalties pursuant to Section 

20(d) of the Securities Act, 15 U.S.C. § 77t(d), and Section 21(d) of the Exchange Act, 15 

U.S.C. § 78(d). 

E. Officer and Director Bar 

Issue an Order, pursuant to Section 20(e) of the Securities Act, 15 U.S.C. § 77t(e), and 

Section 21(d)(2) of the Exchange Act, 15 U.S.C. § 78u(d)(2), barring Defendant from acting 

as an officer or director of any issuer that has a class of securities registered pursuant to Section 

12 of the Exchange Act or that is required to file reports pursuant to Section 15(d) of the 

Exchange Act. 

F. Further Relief 

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

G. 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 it may 

enter, or to entertain any suitable application or motion by the Commission for additional relief 

within the jurisdiction of this Court. 

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VIII. DEMAND FOR JURY TRIAL 

The Commission hereby demands a trial by jury on any and all issues in this action so 

triable. 

March 13, 2023    Respectfully submitted, 

 
     By: /s/ Stephanie N. Moot 
      Stephanie N. Moot 
      Senior Trial Counsel 
      Fla. Bar No.  30377 
      Direct Dial:  (305) 982-6313 

E-mail: [email protected] 
 
      Steven J. Meiner  
      Senior Counsel 
      New York Bar No. 2785806  
      Direct Dial:  (305) 982-6336 

E-mail: [email protected] 
     

 Attorneys for Plaintiff 
      Securities and Exchange Commission 
      801 Brickell Avenue, Suite 1950 

Miami, FL 33131 
Telephone:  (305) 982-6300 

     Facsimile:  (305) 536-4154 

Case 9:23-cv-80398-XXXX   Document 1   Entered on FLSD Docket 03/13/2023   Page 9 of 9

mailto:[email protected]