SEC v. JOHN DAVID GESSIN (a/k/a John David); EQUIFUNDS, INC.; and ICE FLEET LLC, No. 8:23-cv-00460, Central District of California (Mar. 14, 2023) — Complaint

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MICHELLE ZAMARIN (DC Bar #474042)
pro hac pending
Email:  [email protected]
Attorney for Plaintiff
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
Telephone: (202) 793-0656

LOCAL COUNSEL
Gary Y. Leung (Cal. Bar # 302928)
Email: [email protected]
Securities and Exchange Commission
444 S. Flower Street, Suite 900
Los Angeles, CA 90071
Telephone: (323) 965-3998
Facsimile: (213) 443-1904

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

SECURITIES AND EXCHANGE
COMMISSION,
                    Plaintiff,
          v.
JOHN DAVID GESSIN (a/k/a John
David), an individual, EQUIFUNDS,
INC., a California Corporation, and ICE
FLEET LLC, a Delaware limited liability
company,
                    Defendants.
    Case    No.

COMPLAINT

DEMAND FOR JURY TRIAL

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 Plaintiff Securities and Exchange Commission (“SEC” or the “Commission”)
alleges:
JURISDICTION AND VENUE
1. The Court has jurisdiction over this action pursuant to Sections 20(b),
20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§ 77t(b),
77t(d)(1) & 77v(a), and Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of the Securities
Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. §§ 78u(d)(1), 78u(d)(3)(A), 78u(e)
& 78aa(a).
2. Defendants have, directly or indirectly, made use of the means or
instrumentalities of interstate commerce, of the mails, or of the facilities of a national
securities exchange in connection with the transactions, acts, practices and courses of
business alleged in this complaint.
3. Venue is proper in this district pursuant to Section 22(a) of the Securities
Act, 15 U.S.C. § 77v(a), and Section 27(a) of the Exchange Act, 15 U.S.C. § 78aa(a)
because certain of the transactions, acts, practices and courses of conduct constituting
violations of the federal securities laws occurred within this district.
4. In addition, venue is proper because Defendants Equifunds, Inc.
(“Equifunds”) and Ice Fleet LLC (“Ice Fleet”) are, or were, headquartered in this district,
and Defendant John D. Gessin (“Gessin”) resides in this district.
SUMMARY
5. This is a civil enforcement action concerning securities fraud by Gessin,
Equifunds, and Ice Fleet.  Gessin founded Equifunds and Ice Fleet ostensibly for
engaging in business operations relating to the purchase, sale, and distribution of fuel.
Presenting himself as a successful entrepreneur – and using the alias “John David” so that
prospective investors would not learn of his criminal history or prior lawsuits and
bankruptcies – Gessin raised over $1.6 million on behalf of Ice Fleet and Equifunds
between March 2017 and January 2020, from a small group of inexperienced retail
investors.

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6. Gessin falsely told his investors that the funds they entrusted to him would
be used solely for business purposes, and that he was not using “a dime” of their money
for his personal benefit.
7. In fact, and in direct contradiction to his representations, Gessin plundered
Equifunds and Ice Fleet in order to fund his lifestyle, using company funds to pay for,
among other things:  the mortgage on a home in a gated community, automobiles, hotels
and restaurants, house cleaning services, and gifts and other payments to his friends and
family members.
8. In March 2020, Gessin suddenly stopped paying his investors, falsely telling
them that the COVID-19 pandemic had severely harmed his businesses.  Even after
Equifunds received nearly $1.3 million in COVID-19 Economic Injury Disaster Loans
from the Small Business Administration, Gessin continued to tell investors that he and
Equifunds were heading for bankruptcy, while using Equifunds as his personal
piggybank.
9. As a result of the conduct alleged herein, Defendants have violated Section
17(a) of the Securities Act, 15 U.S.C. § 77q(a), and Section 10(b) of the Exchange Act,
15 U.S.C. § 78j(b), and Rule 10b-5 thereunder, 17 C.F.R. § 240.10b-5.
10. The SEC seeks permanent injunctions prohibiting the Defendants from
committing any future violations of the federal securities laws, an officer and director bar
against Defendant Gessin, and an order requiring Defendants to disgorge their ill-gotten
gains with prejudgment interest thereon pursuant to Sections 21(d)(3), (5) and (7) of the
Exchange Act, 15 U.S.C. §§ 78u(d)(3), (5) and (7), and imposing civil penalties under
Section 21(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3), and Section 20(d) of the
Securities Act, 15 U.S.C. § 77t(d).
THE DEFENDANTS
11. Gessin is a resident of Laguna Niguel, California.  He founded and is the
sole principal of Equifunds.  He has signatory authority over all of Equifunds’ bank
accounts.  Gessin also founded and was the sole principal of Ice Fleet.  He had signatory

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authority over all of Ice Fleet’s bank accounts.
12. Equifunds is a California corporation headquartered in Laguna Niguel,
California.  Gessin is Equifunds’ founder and its sole principal.  He has exclusive
authority and decision-making with respect to Equifunds’ business operations.  Equifunds
is liable for Gessin’s misstatements, acts, and omissions under, among other things,
agency principles and the doctrine of respondeat superior.
13. Ice Fleet is a Delaware LLC headquartered in Beverly Hills, California that
apparently ceased business operations in or around 2020.  Gessin founded Ice Fleet and
was its sole principal.  He had exclusive authority and decision-making with respect to
Ice Fleet’s business operations.  Ice Fleet is liable for Gessin’s misstatements, acts, and
omissions under, among other things, agency principles and the doctrine of respondeat
superior.
FACTS
A. Background and Founding of Equifunds and Ice Fleet
14. Gessin is a self-described entrepreneur with a history of lawsuits and
bankruptcies stemming from allegations that he defrauded and misappropriated funds
from business partners, friends, and acquaintances.
15. In 2010, for example, Gessin was found liable for defrauding a high school
teacher he met on Match.com out of her life savings, which he lost day-trading in the
stock market.  Gessin also has multiple default judgments against him for failure to repay
loans and promissory notes under which he agreed to pay his counterparties substantially
above-market rates.
16. In or around November 2013, Gessin founded Defendant Ice Fleet,
subsequently representing to prospective investors and business partners that Ice Fleet
was in the commercial refueling business.
17. Gessin founded Equifunds in or around March 2017, subsequently
representing to prospective investors and business partners that Equifunds was an entity
through which he was managing investments in commercial fueling operations and

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renewable energy.
18. In fact, as described below, Gessin used Ice Fleet and Equifunds to target
and fleece unsophisticated retail investors—including an artist and her U.S. military
veteran spouse, a real estate agent, a former government employee, and an elderly retired
nurse in an assisted living facility.  Ultimately, Gessin defrauded these individuals of
over $1.2 million.
B. Defendants’ Misrepresentations and Omissions to Investors
i) Investors A and B
19. Investor A is a digital artist who resides in Playa Del Rey, California.  In or
around 2014, she met Defendant Gessin—who was using the alias “John David”—via a
mobile dating and social networking application.  He described himself as a successful
venture capitalist.  Thereafter, Investor A asked Gessin for investment and business
advice from time to time.
20. In or around March 2017, Gessin persuaded Investor A and her U.S. military
veteran spouse, Investor B, to invest $30,000 in Equifunds, explaining that the money
would be used to purchase fuel in support of a commercial shipping business located in
the Port of Long Beach, CA.
21. Gessin offered Investors A and B monthly interest payments on their
investment at an above-market rate of 12% annually.  Although Investors A and B
believed they were investing in Equifunds, Gessin subsequently provided them with a
$30,000 promissory note from Ice Fleet.
22. In April and May 2017, Investors A and B invested an additional $83,995
with Equifunds. They funded most of the new investment with loans and credit card
advances, which Gessin explained would be a profitable strategy in light of the interest
rate he was offering them.  Though Gessin repeatedly promised that he would do so, he
did not provide Investors A and B with any written documentation in support of these
additional investments.
23. In or around late 2018, Investors A and B informed Gessin that they wanted

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to withdraw their investments with him.  Gessin refused and instead said their money was
“tied up” in a new venture to purchase the JH Mitchell & Sons commercial vehicle
refueling depot (“the Mitchell depot”) in Baldwin Park, CA.  Gessin explained that he
intended to use the Mitchell depot to manufacture and distribute biodiesel fuels, which
would allow him to take advantage of new and lucrative government incentives.
24. After providing Investors A and B with a tour of the Mitchell depot, Gessin
offered to increase the interest rate on their investment to 24% annually, but Gessin told
them he would only do so if they invested additional funds with him.  He sweetened his
offer by agreeing to pay a monthly sum to cover the interest owed on their loans and
credit card advances.  In response to Gessin’s offer, Investors A and B invested an
additional $45,550 in Equifunds, funded almost entirely with credit card advances,
bringing their total investment to $159,545.
25. Gessin never disclosed to Investors A and B his true identity, criminal
history, bankruptcies, or that he had been the subject of lawsuits involving allegations of
fraud and misappropriation of funds.
26. Had he done so, Investors A and B would not have invested money with
Gessin, Ice Fleet, or Equifunds.
ii) Investor C
27. Investor C is a real estate agent who resides in Playa Del Rey, CA.  Her
neighbor, Investor A, introduced her to Gessin, who was still using the alias “John
David.”
28. Gessin offered Investor C monthly interest payments at a 15% annual rate in
exchange for a $100,000 investment in Equifunds.  At Gessin’s instruction, Investor C
wired $100,000 to Equifunds in or around July 2017.  Though the funds were wired to
Equifunds, Gessin provided Investor C with a $100,000 promissory note from Ice Fleet,
which he signed on behalf of Ice Fleet as “John David.”
29. In or around November 2018, Investor C invested an additional $20,000
with Gessin in response to an offer to increase the annual interest rate to 18%, wiring the

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funds to Equifunds at his instruction.
30. The investment represented essentially all of Investor C’s life savings.
31. Gessin also offered Investor C equity shares in Equifunds if she introduced
him to other potential investors.
32. Gessin falsely represented to Investor C that:  (1) investor funds would be
used solely to purchase and resell fuel; (2) he had personally invested millions of dollars
in his business enterprises, and (3) he was so committed to their success that he was not
using “a dime” of company funds to pay himself a salary, or even to reimburse his day-
to-day expenses.
33. Investor C relied on these representations when she invested her own funds
with Gessin and when she subsequently recommended him to other potential investors.
34. Gessin also told Investor C that he had an insurance policy on the
receivables for the fuel he was selling and distributing.  He falsely assured Investor C that
her investment would be 100% protected by that policy and claimed that he would add
her as a named beneficiary under the policy.
35. Gessin never disclosed to Investor C his true identity, criminal history,
bankruptcies, or that he had been the subject of lawsuits involving allegations of fraud
and misappropriation of funds.
36. Had he done so, Investor C would not have invested money with Gessin, Ice
Fleet, or Equifunds, or recommended such investments to others.
iii) Investor D
37. Investor D, now recently deceased, was a 92-year-old retired nurse residing
in Palm Desert, CA.  She learned of the investment opportunity with Gessin from her
neighbors, Investors A and C, while all three were living in a condominium community
in Playa Del Rey, CA.
38. In or around November 2018, Gessin took Investor D (accompanied by
Investor C) on a tour of the Mitchell depot, which he said he was in the process of
purchasing.  Gessin told Investor D that he had developed a new technology to improve

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the efficiency of biodiesel fuel.  He also falsely told her that he had a contract with the
large, Mexican-government-owned petroleum company Pemex to supply and distribute
fuel from the Mitchell depot.
39. Gessin also took Investor D (accompanied by Investor C) to an office
located near Los Angeles International Airport, where he showed her a brochure
containing photographs of fuel trucks, as well as storage tanks and signage jointly
branded with the JH Mitchell and Pemex logos.  He also introduced Investor D to a
person he said was a representative of Pemex.
40.    Shortly after her meeting with Gessin, Investor D invested $200,000 in
Equifunds in exchange for monthly interest payments at a 24% annual interest rate.
Gessin provided her with a promissory note, which he signed on behalf of Equifunds.
41. Investor D subsequently moved into an assisted living facility in Palm
Desert, CA.  Gessin visited Investor D at the assisted living facility on multiple
occasions, including on her birthday, taking her out for expensive meals.  Gessin also
took Investor D for a driving tour, showing her gas stations that he said would be
distributing his fuel.  On another occasion, Gessin showed Investor D a video of a
railyard near the Port of Long Beach, from which he said he would be distributing fuel by
rail.
42. Gessin also told Investor D that he had an insurance policy on the
receivables for the fuel he was selling and distributing.  He falsely assured Investor D that
her investment would be 100% protected by that policy and claimed that he would add
her as a named beneficiary under the policy.
43. Relying on Gessin’s false and misleading representations, between
December 2018 and January 2020, Investor D made nine additional investments in
Equifunds, each ranging from $100,000 to $200,000—investing a total of $1.2 million in
Gessin’s fraudulent scheme.  The $1.2 million represented the bulk of her life savings.
44. Gessin never disclosed to Investor D his criminal history, bankruptcies, or
that he had been the subject of lawsuits involving allegations of fraud and

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misappropriation of funds.  Had he done so, Investor D would not have invested money
with Gessin or Equifunds.
iv) Investor E
45. Investor E is a 71 year-old retiree and former government employee who
resides in Culver City, CA.  She is a friend of Investor D and an acquaintance of Investor
C.  After hearing about Investor C’s and D’s investments with “John David” at above-
market rates, Investor E asked for information about the investment opportunity.
46. Investors C and D conveyed to Investor E the oral representations they had
received from Gessin about his business activities and plans, and also showed Investor E
the brochure containing photographs of fuel trucks, and storage tanks and signage jointly
branded with the JH Mitchell and Pemex logos.  Investor E decided to invest in
Equifunds.
47. At Gessin’s oral direction, Investor C informed Investor E that she would
receive monthly interest payments at an annual rate of 20% if she invested at least
$100,000 with Equifunds.  In or around April 2019, Investor E invested $100,000 with
Equifunds.  In September 2019, she increased her investment to $150,000, receiving a
promissory note signed on behalf of Equifunds by “J. David.”  The $150,000 investment
represented substantially all of Investor E’s life savings.
48.   Investor E was not aware of Gessin’s true identity, criminal history,
bankruptcies, or that he had been the subject of prior lawsuits involving allegations of
fraud and misappropriation of funds.  Had she been aware, Investor E would not have
invested money with Gessin or Equifunds.
C. Defendants Suddenly Stopped Paying Investors and Cut Off Contact
49. Through early 2020, Defendants Gessin, Equifunds, and Ice Fleet made
monthly interest payments to Investors A through E (collectively, “the Investors”) per the
agreed-upon terms as described above.  However, in or around March 2020, Defendants
abruptly stopping paying each of the Investors.
50. Initially, Gessin claimed that his business operations at the Mitchell depot

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had been disrupted by the COVID-19 pandemic, and that the payments would resume in
a few months.  However, after the payments did not resume as expected, Investors A and
B contacted the Mitchell depot.  They learned that the facility had been operating
normally throughout the pandemic.
51. They also learned that neither Gessin, Ice Fleet, nor Equifunds had any
ownership interest in the facility.  To the contrary, Gessin had been banned from the
premises in or around May 2019, as a result of an ongoing business dispute Gessin had
with the actual owner of the facility.
52. After being confronted by Investors A and B about his misrepresentations
and omissions concerning the Mitchell depot, Gessin cut off all contact with them.  He
also stopped replying to calls and messages from Investor D.
D. Defendants’ Continuing Misrepresentations
53. Through October 2022, Gessin continued to make false and misleading
statements to Investor C, claiming that the COVID-19 pandemic and other setbacks had
severely damaged his businesses and left him unable to repay investors.  In fact, he
continued to own and operate Equifunds and pursue new business ventures, with the
assistance of large cash infusions from Small Business Administration COVID-19
Economic Injury Disaster Loans (“EIDLs).
54. On or around June 29, 2021, Equifunds received an EIDL payment in the
amount of $484,900.  On or around December 28, 2021, Equifunds received an EIDL
payment in the amount of $793,900.  Although EIDL proceeds may be used for any
ordinary business expense, including to repay debts and make interest payments,
Defendants have not made a single payment to any of the Investors since March 2020.
55. To date, the Investors’ losses exceed $1.2 million, not including the monthly
interest payments they are owed:
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Investor Loss of Investment
Principal
Investors A and B $48,480.00
Investor C $51,450.00
Investor D $998,000.00
Investor E $128,683.00
TOTAL:                            $1,226,613.00
E. Gessin’s Misappropriation of Funds
56. Moreover, contrary to his representations that he would not use “a dime” of
company funds for his personal benefit, Gessin routinely misappropriated funds from Ice
Fleet and Equifunds to pay for, among other things, the mortgage on a home in a gated
community, automobiles, house cleaning services, hotels, restaurant meals, and payments
to friends and family members—including wedding, graduation, and Bar Mitzvah gifts,
and the payoff of a loan on his significant other’s Range Rover.
57. Gessin also routinely commingled funds in his business and personal bank
accounts, with net transfers from Equifunds and Icefleet to his personal accounts in
excess of $137,000.
 Type of Expense
or Activity
Approximate Amount
Spent (2017 to 2021)
Payments and Gifts to
Friends and Family
Members
$450,000
Net Transfers to Personal
Bank Accounts
$137,000
Mortgage and Real Estate
Tax Payments
$117,000
Luxury Automobile
Payments
$18,500
Hotels, Vacations, and
Restaurants
$15,000

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 Type of Expense
or Activity
Approximate Amount
Spent (2017 to 2021)
Shopping (Apparel,
Electronics, Luxury
Brands, Furniture)
$12,000
House Cleaning Services $11,500
58. In fact, within days of receiving the Small Business Administration EIDL
payments described above, Gessin made large transfers from Equifunds to his personal
bank accounts, to his friends and family members, and to another business entity in which
he is a co-owner.
FIRST CLAIM FOR RELIEF
Fraud in Connection with the Sale of Securities in Violation of Section
10(b) of the Exchange Act and Rule 10b-5 Thereunder
59. The SEC realleges and incorporates by reference paragraphs 1 through 58
above.
60. By engaging in the conduct described above, Defendants Gessin, Equifunds,
and Ice Fleet, and each of them, directly or indirectly, in connection with the purchase or
sale of a security, by the use of means or instrumentalities of interstate commerce, of the
mails, or of the facilities of a national securities exchange, with scienter: (a) employed
devices, schemes, or artifices to defraud; (b) made untrue statements of a material fact or
omitted to state a material fact necessary in order to make the statements made, in the
light of the circumstances under which they were made, not misleading; and/or (c)
engaged in acts, practices, or courses of business which operated or would operate as a
fraud or deceit upon other persons.
61. By engaging in the conduct described above, Defendants Gessin, Equifunds,
and Ice Fleet violated Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rules
10b-5(a), 10b-5(b), and 10b-5(c) thereunder, 17 C.F.R. §§ 240.10b-5(a), 240.10b-5(b),
and 240.10b-5(c).
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SECOND CLAIM FOR RELIEF
Fraud in the Offer or Sale of Securities
in Violation of Section 17(a) of the Securities Act
62. The SEC realleges and incorporates by reference paragraphs 1 through 58
above.
63.  By engaging in the conduct described above, Defendants Gessin, Equifunds,
and Ice Fleet, and each of them, directly or indirectly, in the offer or sale of securities,
and by the use of means or instruments of transportation or communication in interstate
commerce or by use of the mails directly or indirectly: (a) with scienter, employed
devices, schemes, or artifices to defraud; (b) obtained money or property by means of
untrue statements of a material fact or by omitting to state a material fact necessary in
order to make the statements made, in light of the circumstances under which they were
made, not misleading; and/or (c) engaged in transactions, practices, or courses of
business which operated or would operate as a fraud or deceit upon the purchaser.
64. By engaging in the conduct described above, Defendants Gessin, Equifunds,
and Ice Fleet violated Sections 17(a)(1), 17(a)(2), and 17(a)(3) of the Securities Act, 15
U.S.C. §§ 77q(a)(1), 77q(a)(2), & 77q(a)(3).
PRAYER FOR RELIEF
WHEREFORE, the SEC respectfully requests that the Court:
I.
Issue judgments, in forms consistent with Fed. R. Civ. P. 65(d), permanently
enjoining Defendants, and their agents, servants, employees, and attorneys, and those
persons in active concert or participation with any of them, who receive actual notice of
the judgment by personal service or otherwise, and each of them, from violating Section
17(a) of the Securities Act, 15 U.S.C. § 77q(a), Section 10(b) of the Exchange Act, 15
U.S.C. §§ 78j(b), and Rule 10b-5 thereunder, 17 C.F.R. § 240.10b-5.
///
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II.
Issue an order, pursuant to Section 20(e) of the Securities Act, 15 U.S.C. § 77t(e),
and Sections 21(d)(2) of the Exchange Act, 15 U.S.C. § 78u(d)(2), prohibiting Defendant
Gessin 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, 15 U.S.C. § 78l, or that is required
to file reports pursuant to Section 15(d) of the Exchange Act, 15 U.S.C. § 78o(d).
III.
Order Defendants to disgorge all ill-gotten gains received from their illegal
conduct, together with prejudgment interest thereon, pursuant to Sections 21(d)(3), (5)
and (7) of the Exchange Act, 15 U.S.C. §§ 78u(d)(3), (5) and (7).
IV.
Order Defendants to pay civil penalties under Section 20(d) of the Securities Act,
15 U.S.C. § 77t(d), and Section 21(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3).
V.  
Pursuant to Section 21(d)(5) of the Exchange Act, permanently restrain and enjoin
Defendant Gessin from directly or indirectly, including, but not limited to, through any
entity owned or controlled by him, participating in the issuance, purchase, offer, or sale
of any security, provided however, that such injunction shall not prevent him from
purchasing or selling securities for his own personal account.
VI.  
Retain jurisdiction of this action in accordance with the principles of equity and the
Federal Rules of Civil Procedure in order to implement and carry out the terms of all
orders and decrees that may be entered, or to entertain any suitable application or motion
for additional relief within the jurisdiction of this Court.
VII.
Grant such other and further relief as this Court may determine to be just and
necessary.
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DEMAND FOR JURY TRIAL
 Pursuant to Federal Rule of Civil Procedure 38 and Local Rule 38-1, the SEC
demands trial by jury.

Dated:  March 14, 2023

/s/ Gary Y. Leung
Gary Y. Leung
Michelle Zamarin
Attorneys for Plaintiff
Securities and Exchan
ge Commission

Complaints and Other Initiating Documents
8:23-cv-00460 Securities and Exchange Commission v. Gessin et al
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Notice of Electronic Filing
The following transaction was entered by Leung, Gary on 3/14/2023 at 9:31 AM PDT and filed on 3/14/2023
Case Name:Securities and Exchange Commission v. Gessin et al
Case Number:8:23-cv-00460
Filer:Securities and Exchange Commission
Document Number:1
Docket Text:
COMPLAINT No Fee Required - US Government, filed by Plaintiff Securities and Exchange
Commission. (Attorney Gary Y. Leung added to party Securities and Exchange
Commission(pty:pla))(Leung, Gary)
8:23-cv-00460 Notice has been electronically mailed to:
Gary Y. Leung     [email protected], [email protected], [email protected], [email protected]
8:23-cv-00460 Notice has been delivered by First Class U. S. Mail or by other means BY THE FILER to :
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:C:\fakepath\Complaint (Final).pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=3/14/2023] [FileNumber=35499937-0
] [1aa11e878171b94311e805d77915a9898f8f160af31390a2e8ec925096c8653c60b
05701ee5ed65f02908508166b294870a4a6f2cfc1837b067cc682f53f11ff]]

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MICHELLE ZAMARIN (DC Bar #474042) 
pro hac pending 
Email:  [email protected] 
Attorney for Plaintiff 
Securities and Exchange Commission 
100 F Street NE 
Washington, DC 20549 
Telephone: (202) 793-0656 
 
LOCAL COUNSEL 
Gary Y. Leung (Cal. Bar # 302928) 
Email: [email protected] 
Securities and Exchange Commission 
444 S. Flower Street, Suite 900 
Los Angeles, CA 90071 
Telephone: (323) 965-3998 
Facsimile: (213) 443-1904  
 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

 

SECURITIES AND EXCHANGE 
COMMISSION, 

  Plaintiff, 

 v. 

JOHN DAVID GESSIN (a/k/a John 
David), an individual, EQUIFUNDS, 
INC., a California Corporation, and ICE 
FLEET LLC, a Delaware limited liability 
company,  

  Defendants. 

 Case No. 
 
COMPLAINT 
 
DEMAND FOR JURY TRIAL 

 

Case 8:23-cv-00460   Document 1   Filed 03/14/23   Page 1 of 15   Page ID #:1



 

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 Plaintiff Securities and Exchange Commission (“SEC” or the “Commission”) 

alleges: 

JURISDICTION AND VENUE 

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

20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§ 77t(b), 

77t(d)(1) & 77v(a), and Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of the Securities 

Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. §§ 78u(d)(1), 78u(d)(3)(A), 78u(e) 

& 78aa(a). 

2. Defendants have, directly or indirectly, made use of the means or 

instrumentalities of interstate commerce, of the mails, or of the facilities of a national 

securities exchange in connection with the transactions, acts, practices and courses of 

business alleged in this complaint.  

3. Venue is proper in this district pursuant to Section 22(a) of the Securities 

Act, 15 U.S.C. § 77v(a), and Section 27(a) of the Exchange Act, 15 U.S.C. § 78aa(a) 

because certain of the transactions, acts, practices and courses of conduct constituting 

violations of the federal securities laws occurred within this district.   

4. In addition, venue is proper because Defendants Equifunds, Inc. 

(“Equifunds”) and Ice Fleet LLC (“Ice Fleet”) are, or were, headquartered in this district, 

and Defendant John D. Gessin (“Gessin”) resides in this district.   

SUMMARY 

5. This is a civil enforcement action concerning securities fraud by Gessin, 

Equifunds, and Ice Fleet.  Gessin founded Equifunds and Ice Fleet ostensibly for 

engaging in business operations relating to the purchase, sale, and distribution of fuel.  

Presenting himself as a successful entrepreneur – and using the alias “John David” so that 

prospective investors would not learn of his criminal history or prior lawsuits and 

bankruptcies – Gessin raised over $1.6 million on behalf of Ice Fleet and Equifunds 

between March 2017 and January 2020, from a small group of inexperienced retail 

investors.   

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6. Gessin falsely told his investors that the funds they entrusted to him would 

be used solely for business purposes, and that he was not using “a dime” of their money 

for his personal benefit.   

7. In fact, and in direct contradiction to his representations, Gessin plundered 

Equifunds and Ice Fleet in order to fund his lifestyle, using company funds to pay for, 

among other things:  the mortgage on a home in a gated community, automobiles, hotels 

and restaurants, house cleaning services, and gifts and other payments to his friends and 

family members.   

8. In March 2020, Gessin suddenly stopped paying his investors, falsely telling 

them that the COVID-19 pandemic had severely harmed his businesses.  Even after 

Equifunds received nearly $1.3 million in COVID-19 Economic Injury Disaster Loans 

from the Small Business Administration, Gessin continued to tell investors that he and 

Equifunds were heading for bankruptcy, while using Equifunds as his personal 

piggybank.  

9. As a result of the conduct alleged herein, Defendants have violated Section 

17(a) of the Securities Act, 15 U.S.C. § 77q(a), and Section 10(b) of the Exchange Act, 

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

10. The SEC seeks permanent injunctions prohibiting the Defendants from 

committing any future violations of the federal securities laws, an officer and director bar 

against Defendant Gessin, and an order requiring Defendants to disgorge their ill-gotten 

gains with prejudgment interest thereon pursuant to Sections 21(d)(3), (5) and (7) of the 

Exchange Act, 15 U.S.C. §§ 78u(d)(3), (5) and (7), and imposing civil penalties under 

Section 21(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3), and Section 20(d) of the 

Securities Act, 15 U.S.C. § 77t(d).  

THE DEFENDANTS 

11. Gessin is a resident of Laguna Niguel, California.  He founded and is the 

sole principal of Equifunds.  He has signatory authority over all of Equifunds’ bank 

accounts.  Gessin also founded and was the sole principal of Ice Fleet.  He had signatory 

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authority over all of Ice Fleet’s bank accounts.  

12. Equifunds is a California corporation headquartered in Laguna Niguel, 

California.  Gessin is Equifunds’ founder and its sole principal.  He has exclusive 

authority and decision-making with respect to Equifunds’ business operations.  Equifunds 

is liable for Gessin’s misstatements, acts, and omissions under, among other things, 

agency principles and the doctrine of respondeat superior.  

13. Ice Fleet is a Delaware LLC headquartered in Beverly Hills, California that 

apparently ceased business operations in or around 2020.  Gessin founded Ice Fleet and 

was its sole principal.  He had exclusive authority and decision-making with respect to 

Ice Fleet’s business operations.  Ice Fleet is liable for Gessin’s misstatements, acts, and 

omissions under, among other things, agency principles and the doctrine of respondeat 

superior. 

FACTS 

A. Background and Founding of Equifunds and Ice Fleet 

14. Gessin is a self-described entrepreneur with a history of lawsuits and 

bankruptcies stemming from allegations that he defrauded and misappropriated funds 

from business partners, friends, and acquaintances.   

15. In 2010, for example, Gessin was found liable for defrauding a high school 

teacher he met on Match.com out of her life savings, which he lost day-trading in the 

stock market.  Gessin also has multiple default judgments against him for failure to repay 

loans and promissory notes under which he agreed to pay his counterparties substantially 

above-market rates.   

16. In or around November 2013, Gessin founded Defendant Ice Fleet, 

subsequently representing to prospective investors and business partners that Ice Fleet 

was in the commercial refueling business.    

17. Gessin founded Equifunds in or around March 2017, subsequently 

representing to prospective investors and business partners that Equifunds was an entity 

through which he was managing investments in commercial fueling operations and 

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renewable energy. 

18. In fact, as described below, Gessin used Ice Fleet and Equifunds to target 

and fleece unsophisticated retail investors—including an artist and her U.S. military 

veteran spouse, a real estate agent, a former government employee, and an elderly retired 

nurse in an assisted living facility.  Ultimately, Gessin defrauded these individuals of 

over $1.2 million.    

B. Defendants’ Misrepresentations and Omissions to Investors 

i) Investors A and B 

19. Investor A is a digital artist who resides in Playa Del Rey, California.  In or 

around 2014, she met Defendant Gessin—who was using the alias “John David”—via a 

mobile dating and social networking application.  He described himself as a successful 

venture capitalist.  Thereafter, Investor A asked Gessin for investment and business 

advice from time to time.  

20. In or around March 2017, Gessin persuaded Investor A and her U.S. military 

veteran spouse, Investor B, to invest $30,000 in Equifunds, explaining that the money 

would be used to purchase fuel in support of a commercial shipping business located in 

the Port of Long Beach, CA.   

21. Gessin offered Investors A and B monthly interest payments on their 

investment at an above-market rate of 12% annually.  Although Investors A and B 

believed they were investing in Equifunds, Gessin subsequently provided them with a 

$30,000 promissory note from Ice Fleet.   

22. In April and May 2017, Investors A and B invested an additional $83,995 

with Equifunds. They funded most of the new investment with loans and credit card 

advances, which Gessin explained would be a profitable strategy in light of the interest 

rate he was offering them.  Though Gessin repeatedly promised that he would do so, he 

did not provide Investors A and B with any written documentation in support of these 

additional investments.   

23. In or around late 2018, Investors A and B informed Gessin that they wanted 

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to withdraw their investments with him.  Gessin refused and instead said their money was 

“tied up” in a new venture to purchase the JH Mitchell & Sons commercial vehicle 

refueling depot (“the Mitchell depot”) in Baldwin Park, CA.  Gessin explained that he 

intended to use the Mitchell depot to manufacture and distribute biodiesel fuels, which 

would allow him to take advantage of new and lucrative government incentives.   

24. After providing Investors A and B with a tour of the Mitchell depot, Gessin 

offered to increase the interest rate on their investment to 24% annually, but Gessin told 

them he would only do so if they invested additional funds with him.  He sweetened his 

offer by agreeing to pay a monthly sum to cover the interest owed on their loans and 

credit card advances.  In response to Gessin’s offer, Investors A and B invested an 

additional $45,550 in Equifunds, funded almost entirely with credit card advances, 

bringing their total investment to $159,545.   

25. Gessin never disclosed to Investors A and B his true identity, criminal 

history, bankruptcies, or that he had been the subject of lawsuits involving allegations of 

fraud and misappropriation of funds.   

26. Had he done so, Investors A and B would not have invested money with 

Gessin, Ice Fleet, or Equifunds. 

ii) Investor C 

27. Investor C is a real estate agent who resides in Playa Del Rey, CA.  Her 

neighbor, Investor A, introduced her to Gessin, who was still using the alias “John 

David.”   

28. Gessin offered Investor C monthly interest payments at a 15% annual rate in 

exchange for a $100,000 investment in Equifunds.  At Gessin’s instruction, Investor C 

wired $100,000 to Equifunds in or around July 2017.  Though the funds were wired to 

Equifunds, Gessin provided Investor C with a $100,000 promissory note from Ice Fleet, 

which he signed on behalf of Ice Fleet as “John David.”   

29. In or around November 2018, Investor C invested an additional $20,000 

with Gessin in response to an offer to increase the annual interest rate to 18%, wiring the 

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funds to Equifunds at his instruction.   

30. The investment represented essentially all of Investor C’s life savings.    

31. Gessin also offered Investor C equity shares in Equifunds if she introduced 

him to other potential investors.   

32. Gessin falsely represented to Investor C that:  (1) investor funds would be 

used solely to purchase and resell fuel; (2) he had personally invested millions of dollars 

in his business enterprises, and (3) he was so committed to their success that he was not 

using “a dime” of company funds to pay himself a salary, or even to reimburse his day-

to-day expenses.   

33. Investor C relied on these representations when she invested her own funds 

with Gessin and when she subsequently recommended him to other potential investors.        

34. Gessin also told Investor C that he had an insurance policy on the 

receivables for the fuel he was selling and distributing.  He falsely assured Investor C that 

her investment would be 100% protected by that policy and claimed that he would add 

her as a named beneficiary under the policy.   

35. Gessin never disclosed to Investor C his true identity, criminal history, 

bankruptcies, or that he had been the subject of lawsuits involving allegations of fraud 

and misappropriation of funds.   

36. Had he done so, Investor C would not have invested money with Gessin, Ice 

Fleet, or Equifunds, or recommended such investments to others.  

iii) Investor D 

37. Investor D, now recently deceased, was a 92-year-old retired nurse residing 

in Palm Desert, CA.  She learned of the investment opportunity with Gessin from her 

neighbors, Investors A and C, while all three were living in a condominium community 

in Playa Del Rey, CA.     

38. In or around November 2018, Gessin took Investor D (accompanied by 

Investor C) on a tour of the Mitchell depot, which he said he was in the process of 

purchasing.  Gessin told Investor D that he had developed a new technology to improve 

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the efficiency of biodiesel fuel.  He also falsely told her that he had a contract with the 

large, Mexican-government-owned petroleum company Pemex to supply and distribute 

fuel from the Mitchell depot.   

39. Gessin also took Investor D (accompanied by Investor C) to an office 

located near Los Angeles International Airport, where he showed her a brochure 

containing photographs of fuel trucks, as well as storage tanks and signage jointly 

branded with the JH Mitchell and Pemex logos.  He also introduced Investor D to a 

person he said was a representative of Pemex.   

40.    Shortly after her meeting with Gessin, Investor D invested $200,000 in 

Equifunds in exchange for monthly interest payments at a 24% annual interest rate.  

Gessin provided her with a promissory note, which he signed on behalf of Equifunds.  

41. Investor D subsequently moved into an assisted living facility in Palm 

Desert, CA.  Gessin visited Investor D at the assisted living facility on multiple 

occasions, including on her birthday, taking her out for expensive meals.  Gessin also 

took Investor D for a driving tour, showing her gas stations that he said would be 

distributing his fuel.  On another occasion, Gessin showed Investor D a video of a 

railyard near the Port of Long Beach, from which he said he would be distributing fuel by 

rail.      

42. Gessin also told Investor D that he had an insurance policy on the 

receivables for the fuel he was selling and distributing.  He falsely assured Investor D that 

her investment would be 100% protected by that policy and claimed that he would add 

her as a named beneficiary under the policy.   

43. Relying on Gessin’s false and misleading representations, between 

December 2018 and January 2020, Investor D made nine additional investments in 

Equifunds, each ranging from $100,000 to $200,000—investing a total of $1.2 million in 

Gessin’s fraudulent scheme.  The $1.2 million represented the bulk of her life savings.   

44. Gessin never disclosed to Investor D his criminal history, bankruptcies, or 

that he had been the subject of lawsuits involving allegations of fraud and 

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misappropriation of funds.  Had he done so, Investor D would not have invested money 

with Gessin or Equifunds.  

iv) Investor E 

45. Investor E is a 71 year-old retiree and former government employee who 

resides in Culver City, CA.  She is a friend of Investor D and an acquaintance of Investor 

C.  After hearing about Investor C’s and D’s investments with “John David” at above-

market rates, Investor E asked for information about the investment opportunity.   

46. Investors C and D conveyed to Investor E the oral representations they had 

received from Gessin about his business activities and plans, and also showed Investor E 

the brochure containing photographs of fuel trucks, and storage tanks and signage jointly 

branded with the JH Mitchell and Pemex logos.  Investor E decided to invest in 

Equifunds.     

47. At Gessin’s oral direction, Investor C informed Investor E that she would 

receive monthly interest payments at an annual rate of 20% if she invested at least 

$100,000 with Equifunds.  In or around April 2019, Investor E invested $100,000 with 

Equifunds.  In September 2019, she increased her investment to $150,000, receiving a 

promissory note signed on behalf of Equifunds by “J. David.”  The $150,000 investment 

represented substantially all of Investor E’s life savings.  

48.   Investor E was not aware of Gessin’s true identity, criminal history, 

bankruptcies, or that he had been the subject of prior lawsuits involving allegations of 

fraud and misappropriation of funds.  Had she been aware, Investor E would not have 

invested money with Gessin or Equifunds.    

C. Defendants Suddenly Stopped Paying Investors and Cut Off Contact  

49. Through early 2020, Defendants Gessin, Equifunds, and Ice Fleet made 

monthly interest payments to Investors A through E (collectively, “the Investors”) per the 

agreed-upon terms as described above.  However, in or around March 2020, Defendants 

abruptly stopping paying each of the Investors.  

50. Initially, Gessin claimed that his business operations at the Mitchell depot 

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had been disrupted by the COVID-19 pandemic, and that the payments would resume in 

a few months.  However, after the payments did not resume as expected, Investors A and 

B contacted the Mitchell depot.  They learned that the facility had been operating 

normally throughout the pandemic.   

51. They also learned that neither Gessin, Ice Fleet, nor Equifunds had any 

ownership interest in the facility.  To the contrary, Gessin had been banned from the 

premises in or around May 2019, as a result of an ongoing business dispute Gessin had 

with the actual owner of the facility.   

52. After being confronted by Investors A and B about his misrepresentations 

and omissions concerning the Mitchell depot, Gessin cut off all contact with them.  He 

also stopped replying to calls and messages from Investor D.   

D. Defendants’ Continuing Misrepresentations 

53. Through October 2022, Gessin continued to make false and misleading 

statements to Investor C, claiming that the COVID-19 pandemic and other setbacks had 

severely damaged his businesses and left him unable to repay investors.  In fact, he 

continued to own and operate Equifunds and pursue new business ventures, with the 

assistance of large cash infusions from Small Business Administration COVID-19 

Economic Injury Disaster Loans (“EIDLs).     

54. On or around June 29, 2021, Equifunds received an EIDL payment in the 

amount of $484,900.  On or around December 28, 2021, Equifunds received an EIDL 

payment in the amount of $793,900.  Although EIDL proceeds may be used for any 

ordinary business expense, including to repay debts and make interest payments, 

Defendants have not made a single payment to any of the Investors since March 2020.    

55. To date, the Investors’ losses exceed $1.2 million, not including the monthly 

interest payments they are owed: 

/// 

/// 

/// 

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Investor Loss of Investment 
Principal 

Investors A and B $48,480.00 

Investor C $51,450.00 

Investor D $998,000.00 

Investor E $128,683.00 

TOTAL: $1,226,613.00 

E. Gessin’s Misappropriation of Funds 

56. Moreover, contrary to his representations that he would not use “a dime” of 

company funds for his personal benefit, Gessin routinely misappropriated funds from Ice 

Fleet and Equifunds to pay for, among other things, the mortgage on a home in a gated 

community, automobiles, house cleaning services, hotels, restaurant meals, and payments 

to friends and family members—including wedding, graduation, and Bar Mitzvah gifts, 

and the payoff of a loan on his significant other’s Range Rover.   

57. Gessin also routinely commingled funds in his business and personal bank 

accounts, with net transfers from Equifunds and Icefleet to his personal accounts in 

excess of $137,000.    

 Type of Expense         
or Activity  

Approximate Amount 
Spent (2017 to 2021)  

Payments and Gifts to 
Friends and Family 

Members 

$450,000 

Net Transfers to Personal 
Bank Accounts 

$137,000 

Mortgage and Real Estate 
Tax Payments 

$117,000 

Luxury Automobile 
Payments 

$18,500 

Hotels, Vacations, and 
Restaurants 

$15,000 

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 Type of Expense         
or Activity  

Approximate Amount 
Spent (2017 to 2021)  

Shopping (Apparel, 
Electronics, Luxury 
Brands, Furniture) 

$12,000 

House Cleaning Services $11,500 

58. In fact, within days of receiving the Small Business Administration EIDL 

payments described above, Gessin made large transfers from Equifunds to his personal 

bank accounts, to his friends and family members, and to another business entity in which 

he is a co-owner.   

FIRST CLAIM FOR RELIEF 

Fraud in Connection with the Sale of Securities in Violation of Section 

10(b) of the Exchange Act and Rule 10b-5 Thereunder 

59. The SEC realleges and incorporates by reference paragraphs 1 through 58 

above.  

60. By engaging in the conduct described above, Defendants Gessin, Equifunds, 

and Ice Fleet, and each of them, directly or indirectly, in connection with the purchase or 

sale of a security, by the use of means or instrumentalities of interstate commerce, of the 

mails, or of the facilities of a national securities exchange, with scienter: (a) employed 

devices, schemes, or artifices to defraud; (b) made untrue statements of a material fact or 

omitted to state a material fact necessary in order to make the statements made, in the 

light of the circumstances under which they were made, not misleading; and/or (c) 

engaged in acts, practices, or courses of business which operated or would operate as a 

fraud or deceit upon other persons. 

61. By engaging in the conduct described above, Defendants Gessin, Equifunds, 

and Ice Fleet violated Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rules 

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

and 240.10b-5(c).  

/// 

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SECOND CLAIM FOR RELIEF 

Fraud in the Offer or Sale of Securities 

in Violation of Section 17(a) of the Securities Act 

62. The SEC realleges and incorporates by reference paragraphs 1 through 58 

above. 

63.  By engaging in the conduct described above, Defendants Gessin, Equifunds, 

and Ice Fleet, and each of them, directly or indirectly, in the offer or sale of securities, 

and by the use of means or instruments of transportation or communication in interstate 

commerce or by use of the mails directly or indirectly: (a) with scienter, employed 

devices, schemes, or artifices to defraud; (b) obtained money or property by means of 

untrue statements of a material fact or by omitting to state a material fact necessary in 

order to make the statements made, in light of the circumstances under which they were 

made, not misleading; and/or (c) engaged in transactions, practices, or courses of 

business which operated or would operate as a fraud or deceit upon the purchaser.  

64. By engaging in the conduct described above, Defendants Gessin, Equifunds, 

and Ice Fleet violated Sections 17(a)(1), 17(a)(2), and 17(a)(3) of the Securities Act, 15 

U.S.C. §§ 77q(a)(1), 77q(a)(2), & 77q(a)(3). 

PRAYER FOR RELIEF 

WHEREFORE, the SEC respectfully requests that the Court: 

I. 

Issue judgments, in forms consistent with Fed. R. Civ. P. 65(d), permanently 

enjoining Defendants, and their agents, servants, employees, and attorneys, and those 

persons in active concert or participation with any of them, who receive actual notice of 

the judgment by personal service or otherwise, and each of them, from violating Section 

17(a) of the Securities Act, 15 U.S.C. § 77q(a), Section 10(b) of the Exchange Act, 15 

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

/// 

/// 

Case 8:23-cv-00460   Document 1   Filed 03/14/23   Page 13 of 15   Page ID #:13



 

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II. 

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

and Sections 21(d)(2) of the Exchange Act, 15 U.S.C. § 78u(d)(2), prohibiting Defendant 

Gessin 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, 15 U.S.C. § 78l, or that is required 

to file reports pursuant to Section 15(d) of the Exchange Act, 15 U.S.C. § 78o(d). 

III. 

Order Defendants to disgorge all ill-gotten gains received from their illegal 

conduct, together with prejudgment interest thereon, pursuant to Sections 21(d)(3), (5) 

and (7) of the Exchange Act, 15 U.S.C. §§ 78u(d)(3), (5) and (7). 

IV. 

Order Defendants to pay civil penalties under Section 20(d) of the Securities Act, 

15 U.S.C. § 77t(d), and Section 21(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3). 

V.  

Pursuant to Section 21(d)(5) of the Exchange Act, permanently restrain and enjoin 

Defendant Gessin from directly or indirectly, including, but not limited to, through any 

entity owned or controlled by him, participating in the issuance, purchase, offer, or sale 

of any security, provided however, that such injunction shall not prevent him from 

purchasing or selling securities for his own personal account. 

VI.  

Retain jurisdiction of this action in accordance with the principles of equity and the 

Federal Rules of Civil Procedure in order to implement and carry out the terms of all 

orders and decrees that may be entered, or to entertain any suitable application or motion 

for additional relief within the jurisdiction of this Court. 

VII. 

Grant such other and further relief as this Court may determine to be just and 

necessary. 

/// 

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DEMAND FOR JURY TRIAL 

 Pursuant to Federal Rule of Civil Procedure 38 and Local Rule 38-1, the SEC 

demands trial by jury. 

 
Dated:  March 14, 2023 

 

 /s/ Gary Y. Leung 
Gary Y. Leung 
Michelle Zamarin 
Attorneys for Plaintiff 
Securities and Exchange Commission 

 

Case 8:23-cv-00460   Document 1   Filed 03/14/23   Page 15 of 15   Page ID #:15



Complaints and Other Initiating Documents
8:23-cv-00460 Securities and Exchange Commission v. Gessin et al

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Notice of Electronic Filing

The following transaction was entered by Leung, Gary on 3/14/2023 at 9:31 AM PDT and filed on 3/14/2023
Case Name: Securities and Exchange Commission v. Gessin et al
Case Number: 8:23-cv-00460
Filer: Securities and Exchange Commission
Document Number:1

Docket Text:
COMPLAINT No Fee Required - US Government, filed by Plaintiff Securities and Exchange
Commission. (Attorney Gary Y. Leung added to party Securities and Exchange
Commission(pty:pla))(Leung, Gary)

8:23-cv-00460 Notice has been electronically mailed to:

Gary Y. Leung     [email protected], [email protected], [email protected], [email protected]

8:23-cv-00460 Notice has been delivered by First Class U. S. Mail or by other means BY THE FILER to :

The following document(s) are associated with this transaction:

Document description:Main Document
Original filename:C:\fakepath\Complaint (Final).pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=3/14/2023] [FileNumber=35499937-0
] [1aa11e878171b94311e805d77915a9898f8f160af31390a2e8ec925096c8653c60b
05701ee5ed65f02908508166b294870a4a6f2cfc1837b067cc682f53f11ff]]

https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?878234
https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?878234
https://ecf.cacd.uscourts.gov/doc1/031139635085?caseid=878234&de_seq_num=6&magic_num=MAGIC