SEC v. TREASURE ENTERPRISE LLC; PATRICIA ENRIGHT GRAY; and LARRY ALLEN HOLLEY, Eastern District of Michigan (Mar. 30, 2017) — Complaint

 
   
 
 
  
  
 
 
 
 
 
 
  
 
 
 
 
 
  
  
 
  
 
     
    
  
 
 
   
   
   
UNITED STATES DISTRICT COURT
 
EASTERN DISTRICT OF MICHIGAN
 
UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION, 
Plaintiff, 
v. 
TREASURE ENTERPRISE LLC, 
PATRICIA ENRIGHT GRAY, and LARRY 
ALLEN HOLLEY, 
Defendants, 
and 
KINGDOM ASSET MANAGEMENT LLC 
and CARLEEN RENEE HOLLEY, 
Relief Defendants. 
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No. 17-cv-10963 
: 
: 
Hon. Marianne O. Battani 
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JURY DEMANDED 
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[UNDER SEAL] 
COMPLAINT 
Plaintiff United States Securities and Exchange Commission (“SEC”) alleges: 
1. The SEC brings this civil law enforcement action to shut down an 
ongoing, Michigan-based offering fraud involving at least $6.7 million, much of 
which came from retirees and senior citizens, living in Michigan and elsewhere. The 
fraud is being perpetrated by defendants Treasure Enterprise LLC (“Treasure”), 
Patricia Enright Gray (“Gray”), and Larry Allen Holley (“Holley”). Defendants 
targeted retirees and laid-off auto workers with severance plans, among others. 
2. They targeted these investors in churches. Holley, a pastor who held 

 
 
   
  
   
   
   
  
       
  
 
   
    
 
  
    
    
  
  
   
     
  
  
    
  
himself out as a successful businessman, cloaked his solicitations in faith-based 
rhetoric, replete with references to scripture and biblical figures. Investors were 
drawn to, and put their trust in, Holley and Gray because of their seemingly shared 
spirituality. Holley told prospective investors that, as a person who “prayed for your 
children,” he was more trustworthy than a “banker.” 
3. Prospective investors also found appealing the high interest rates 
defendants promised – far higher than what they could earn from certificates of 
deposit or other, conservative investments. And they found it important that at the 
end of the agreed-upon term of investment, Treasure would return all of their 
principal back to them. 
4. In addition to churches, defendants solicited investors on the internet 
and through social media. Gray advertised on a Flint-based Christian/gospel radio 
station. In the ads, she held herself out as a “personal financial wealth coach.” 
5. Defendants typically touted Treasure as a successful, profitable, real 
estate company with hundreds of residential and commercial properties. Prospective 
investors were told that, given the profitability of Treasure’s real estate business, 
Treasure could offer investors high, fixed, and guaranteed interest payments. 
Investors were told that Treasure had a full, money back guarantee for any 
unsatisfied investor. Gray told investors that an investment in Treasure was risk-free, 
since it had ample cash reserves to cover early redemption requests. Such assurances 
were important to investors. 
6. Prospective investors were told that their money at Treasure would be 
kept in a qualified Individual Retirement Account, which meant retirement proceeds 
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could be rolled over into Treasure tax-free. Gray told at least one investor that 
Treasure’s IRA was monitored by an independent, third-  party custodian. Many 
investors’ willingness to invest with Treasure depended upon it having a qualified 
IRA. Investors expressly told Gray as much. 
7. From February 2015 until recently, approximately 83 individuals 
invested with Treasure. Some turned over their entire life savings. 
8. Only later did investors learn there was nothing guaranteed or risk free 
about their Treasure investment. For most investors, the trouble began when 
Treasure stopped sending them their agreed-upon interest payments, or when they 
tried availing themselves of Treasure’s money back guarantee. Instead of making the 
agreed-upon payments or honoring the redemption requests, however, defendants 
offered only excuses and delays. To date, Treasure owes more than 40 investors 
about $2 million in promissory notes that are past due – and that’s  only Treasure’s 
Michigan-based investors. On information and belief, Treasure also has outstanding 
obligations to its investors living outside the State of Michigan. 
9. As its troubles mounted, defendants continued soliciting new 
investment proceeds in an effort to keep Treasure afloat. They did so by making the 
misrepresentations described above – about Treasure’s success, its profitability, the 
promise of high, guaranteed returns, and at the end of the investment period the safe 
return of an investor’s entire principal. 
10. The SEC brings this lawsuit to put an immediate stop to the defendants’ 
ongoing misconduct; to marshal and safeguard assets; to prevent further harm to 
investors; and to hold defendants accountable for their misdeeds. 
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JURISDICTION AND VENUE 
11. The SEC brings this action pursuant to Section 20(b) of the Securities 
Act of 1933 [15 U.S.C. §77t(b)] (“Securities Act”) and Sections 21(d) and 21(e) of the 
Securities Exchange Act of 1934 [15 U.S.C. §§78u(d) and 78u(e)] (“Exchange Act”). 
12. This Court has jurisdiction over this action pursuant to Section 22 of 
the Securities Act [15 U.S.C. § 77v] and Section 27 of the Exchange Act [15 U.S.C. § 
78aa]. 
13. Venue is proper in this Court pursuant to Section 27 of the Exchange 
Act [15 U.S.C. § 78aa]. Acts, practices and courses of business constituting violations 
alleged herein have occurred within the jurisdiction of the United States District 
Court for the Eastern District of Michigan and elsewhere. 
14. Defendants directly and indirectly made use of the means and 
instrumentalities of interstate commerce and of the mails in connection with the acts, 
practices, and courses of business alleged herein, and will continue to do so unless 
enjoined. 
DEFENDANTS AND RELIEF DEFENDANTS 
15. Defendant Treasure Enterprise LLC is a Michigan limited liability 
company formed by Holley in 2009 and based in Flint, Michigan. Treasure purports 
to purchase, invest in and manage residential and commercial real estate. From 
February 2015 to the present, Treasure raised approximately $6.7 million from 83 
investors. Treasure is not registered with the SEC. 
16. Defendant Larry Allen Holley, age 59, currently resides in Grand 
Blanc, Michigan. Holley is a pastor of Abundant Life Ministries International, Inc. 
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(“Abundant Life”), a church in Flint, Michigan. Holley is also the founder and 
president of Treasure and relief defendant Kingdom Asset Management LLC. Holley 
does not hold any securities licenses and has never been registered with the SEC. 
17. Defendant Patricia Enright Gray, age 55, currently resides in Flint, 
Michigan. Gray is a financial consultant on behalf of Treasure and Kingdom Asset 
Management LLC. Gray is also affiliated with Abundant Life. Gray does not hold 
any securities licenses and has never been registered with the SEC. 
18. Relief Defendant Carleen Renee Holley, age 53, currently resides in 
Grand Blanc, Michigan. Carleen Holley is married to Larry Holley. She is also 
affiliated with Abundant Life, and works for Treasure and Kingdom Asset 
Management LLC. Carleen Holley does not hold any securities licenses and has 
never been registered with the SEC. 
19. Relief Defendant Kingdom Asset Management LLC (“Kingdom 
Asset”) is a Michigan limited liability company formed by Holley and his wife 
Carleen Holley in 2006. It is based in Flint, Michigan. Kingdom Asset purports to 
purchase, invest in and manage residential and commercial real estate. Holley serves 
as its President. Kingdom Asset is an affiliate of Treasure and shares the same 
address as Treasure and Abundant Life. Kingdom Asset’s officers, employees and 
associates are also affiliated with Treasure. On information and belief, Kingdom 
Asset raised funds from investors. Kingdom Asset is not registered with the SEC. 
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FACTS 
Defendants’ Investment Pitch Resonates With Prospective Investors 
20. Defendants broadly advertised over social media websites and bragged 
about their professional success. Holley’s bio, posted on various social media outlets 
and websites, stated that he “has been gifted to inspire thousands of individuals to 
discover God’s promises and apply practical solutions for experiencing financial 
increase.” Holley’s bio also touted that he “has successfully created, managed and 
prospered in various businesses over 30 years.” 
21. Gray advertised on a religious radio station based in Flint, Michigan. 
She claimed to be a “personal wealth coach.” She promised to help listeners “make 
your money work for you!” She singled-out recently laid-off auto workers with 
severance packages to consult her for a “financial increase.” 
22. When prospective investors met with Gray, they were handed her 
business card, on which she boasted: “I’ve helped hundreds of men and women earn, 
save and invest millions of dollars and I can help you.” 
23. Defendants made financial presentations at churches nationwide, which 
Treasure promoted as “Blessed Life Conferences.” Holley – who marketed himself as 
a pastor, businessman and philanthropist – would begin the conferences with a 
sermon to the congregation. 
24. A video of one such sermon is available on the internet. During that 
sermon Holley repeatedly urged congregants to fill out cards detailing their financial 
holdings. Holley promised to pray over the cards. He then promised that Gray would 
take the cards and have one-on-one consultations with any interested congregants. 
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To encourage such one-on-one consultations, Holley recounted how, thanks to Gray, 
one investor who had been earning a mere $300 a month from his savings now 
enjoyed $3000 a month – all from “the same money.” 
25. Holley repeatedly told congregants that his investors were “millionaires 
in the making.” He encouraged congregants to embrace “sowing” their money with 
him and his business. Holley told them that they will “not lose” if they invest in real 
estate. 
26. Holley then handed off selected congregants to Gray for one-on-one 
“consultations.” Gray told prospective investors that she would help them find 
money that they did not know they had. She promised to make their money 
“increase” and “multiply.” 
27. During those sessions, Gray would describe to the prospects how 
Treasure worked. She explained that the investor’s money would be pooled with 
other investor proceeds to purchase real estate, which Treasure would own and 
maintain. Gray described Treasure’s real estate holdings as profitable. Gray 
explained that the real estate generated income, principally from rents. That income, 
she explained, funded the interest payments made to Treasure’s investors. And after 
Treasure finished making the agreed-upon interest payments, Gray explained, it 
would then return all of the principal back to the investor. 
28. During the consultations, Gray showed prospective investors a large 
book filled with photographs of what she represented to be some of Treasure’s 
properties, as well as purported testimonials from satisfied investors and photocopies 
of checks that Treasure had paid to investors. She also showed Treasure’s marketing 
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materials promising high returns. 
29. Gray told at least one investor that her investment with Treasure was 
risk free. She told another that Treasure had ample “reserves” to pay back investors if 
the business struggled or if investors chose to redeem their investment early. 
30. Gray oftentimes represented that Treasure offered a qualified Individual 
Retirement Account (“IRA”), which meant an investor could rollover an IRA or 
401(k) proceeds into Treasure on a tax-free basis. This was particularly important to 
retirees and the beneficiaries of severance agreements – two types of investors 
defendants targeted. 
31. Gray would oftentimes call the securities firm at which a prospective 
investor held an IRA – with the investor on the phone. During that phone call, and as 
part of the rollover process, she represented to the customer service representative – 
and to the prospective investor – that Treasure was a qualified IRA. 
32. Gray told at least one prospective investor that a specific self-directed 
IRA firm – which she identified by name – served as Treasure’s custodian. Gray went 
so far as to have the prospective investor fill out that custodian’s forms, and asked 
that the completed forms be returned to her. Gray said she would forward the forms 
to the custodian. The investor wrote a check to Gray, who in turn gave the investor a 
receipt in which Gray promised to deposit the money “in [the investor’s] new Self 
Directed IRA through Treasure Enterprise via [the IRA custodian] on her behalf.” 
The receipt is signed by Gray and witnessed by a Treasure employee. 
33. None of this was true. Treasure did not have a qualified IRA or an IRA 
custodian. Rather, Treasure simply deposited checks made payable to “Treasure 
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Enterprise IRA f/b/o [investor name]” into its non-IRA business checking account. 
That’s the same account in which Treasure kept the rest of its money, including 
income from its real estate properties. 
34. Holley knew about Gray’s lies about Treasure having a qualified IRA. 
He was a signatory on Treasure’s checking account. Thus, he saw investor checks 
payable to “Treasure Enterprise IRA” deposited into Treasure’s general checking 
account. In December 2014, Holley, Gray, and Treasure were sued by an investor. In 
the complaint the investor alleged that she received tax penalty notices from the 
Internal Revenue Service because Treasure was not an IRA – contrary to Gray’s 
representations. Defendants ultimately settled with the investor. Yet even after the 
lawsuit was settled, Gray continued lying to prospective investors about depositing 
their money in a Treasure IRA, as evidenced by the resulting checks made payable to 
“Treasure Enterprise IRA.” 
35. Those weren’t defendants’ only lies to prospective investors. 
Prospective investors were told that Treasure investors could count on a fixed interest 
payment at regular intervals for a defined period of time. They were told that if 
Treasure investors were ever unsatisfied – even before the promissory note came due 
– Treasure would return the principal upon request. Better still, Treasure would not 
penalize the investor for an early withdrawal. But whenever it was that they chose to 
redeem, defendants told investors, Treasure would promptly return their entire 
principal back to them. As Treasure’s investors have since learned, none of that was 
true. 
36. Gray’s and Holley’s pitches served their intended purpose. Since 
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February 2015, approximately 83 people from at least 14 states collectively invested 
about $6.7 million with Treasure. 
37. Once someone decided to invest in Treasure, the investment would be 
documented with a promissory note reflecting the principal amount, the interest rate, 
and the duration of the note. 
38. Gray or Holley signed the promissory notes on Treasure’s behalf. 
39. Oftentimes defendants would also give the investor an account 
statement projecting the investment’s performance. In the document, defendants 
would compare what the investor would receive from Treasure (which varied, but 
was generally between 7%-10%) with various alternatives, including the investor’s 
returns had they stayed in their previous investment vehicle (generally calculated at 
00.25% rate of return);  had they invested the average rate of return offered by a CD 
(generally calculated at 00.65% rate of return); or had they invested in the stock 
market (generally calculated at 2.5% annual rate of return). In defendants’ 
projections, Treasure always dramatically outperformed the alternative investment 
options. 
Treasure’s Financial Condition Deteriorates,
 
But Defendants Continue Touting It As A Successful,
 
Profitable Investment Opportunity
 
40. Defendants touted Treasure as a real estate company that earned 
significant profits for its investors from income earned on its large and lucrative real 
estate portfolio. Defendants advertised that Holley’s businesses “generated millions 
of dollars in annual sales in business.” The truth was far different. From February 
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2015 to the present, while Treasure’s obligations to its investors grew steadily, the 
income it earned from its real estate in order to meet those obligations did not come 
close to keeping pace. As this chasm grew, Treasure found itself increasingly pinched 
for money. 
41. In response, defendants stopped meeting their obligations to Treasure’s 
investors. They made fewer of the interest payments required of Treasure under the 
promissory notes. And they increasingly disregarded investors’ redemption requests. 
Several investors sued to get their money back. 
42. Investors also filed complaints with the State of Michigan’s Department 
of Licensing and Regulation (“LARA”). On August 11, 2016, LARA issued a cease-
and-desist order against defendants barring them from selling unregistered securities 
in Michigan, and from making any misstatement of material fact in violation of 
Michigan law. On January 13, 2017, LARA instituted a cease-and-desist order 
against Gray, barring her from selling unregistered securities in Michigan and from 
making any misstatement of material fact in violation of Michigan law. 
43. Instead of disclosing this information to investors, defendants lied to 
investors about the LARA proceedings. They did so in order to manufacture a 
pretext for Treasure’s inability to honor investors’ redemptions requests. Gray 
misrepresented to investors that LARA had frozen Treasure’s “millions of dollars in 
assets,” and that it had ordered Treasure to cease repayment to investors pending 
resolution of the action. Gray told another investor that Treasure could not redeem 
any investment until a LARA-ordered audit was completed. She told yet another 
investor that her redemption request could only be honored after Treasure complied 
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with LARA’s demands that Treasure liquidate some or all of its real estate holdings. 
These were all lies. 
Defendants Solicit New Investment Proceeds,
 
Which They Clandestinely Use To Pay Off Earlier Investors
 
44. As Treasure struggled financially, Holley and Gray continued their 
solicitation efforts in an effort to keep their failing enterprise afloat. But they never 
disclosed Treasure’s dire financial state to prospective investors during their 
solicitation efforts. Nor did they disclose that Treasure was defaulting on its 
obligations to its preexisting investors, or that several of these investors were suing 
defendants. 
45. Rather, defendants falsely claimed that Treasure was a successful real 
estate company that was making significant profits for its investors from its portfolio 
of commercial and residential properties. And they continued to advertise Treasure’s 
supposedly “guaranteed” interest payments and its money back guarantee. 
46. These misrepresentations worked, yielding fresh investor proceeds that 
flowed into Treasure’s accounts. 
47. Defendants promised these new investors that their money would be 
used to buy real estate. Oftentimes that was a lie. In some instances, defendants 
instead used new investor proceeds to pay Treasure’s preexisting obligations to its 
preexisting investors – including interest payments and the repayment of principal. 
48. Defendants oftentimes treated fresh investment proceeds as hush money 
to quiet complaining, preexisting investors. In October 2015, for instance, Treasure 
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ignored an investor’s redemption request for her $200,000 investment. The investor 
responded by filing a complaint with the State of Michigan, and by filing a lawsuit 
against defendants. To buy her off, defendants successfully solicited a new investor 
and used $100,000 of his investment proceeds to settle the lawsuit. Defendants never 
told the new investor that his money would be used in this manner. Rather, he was 
told that his money would be deposited in a Treasure IRA account and invested in 
real estate. That was a lie. 
49. As of February 2017, Treasure was past due on approximately 51 
promissory notes for 43 investors, totaling nearly $2 million. Treasure lacks the 
money to repay these past due obligations, let alone the means to honor its 
continuing, significant obligations to its current investors. 
50. The promissory notes constituted securities. Treasure Enterprise pooled 
the investors’ funds into a single bank account. Investors were told both orally and in 
writing that their funds would be used to purchase and manage real estate. Investors 
were led to believe that the profits generated from this purchase and management of 
real estate would be used to pay their promised interest. Thus, the profits and losses 
of each investor were tied to the profits and losses of other investors. The investors 
had no control over how their funds would be used after they invested. 
51. Defendants offered and sold the promissory notes using the mail. 
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COUNT I 
Violations of Section 17(a)(1), (2) and (3) of the Securities Act 
(Against All Defendants) 
52. Paragraphs 1 through 51 are realleged and incorporated by reference as 
though fully set forth herein. 
53. By virtue of the conduct alleged herein, defendants, directly or 
indirectly, singly or in concert with others, in the offer and sale of securities, by use of 
the means and instruments of transportation and communication in interstate 
commerce and by use of the mails, have: (a) employed devices, schemes or artifices 
to defraud; (b) obtained money or property by means of untrue statements of material 
fact or omissions to state material facts 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 operate or 
would operate as a fraud or deceit upon the purchaser. 
54. In engaging in the conduct described herein, defendants acted 
knowingly and/or with a reckless disregard for the truth and/or negligently. 
55. By reason of the foregoing, defendants have violated, and unless 
enjoined will likely again violate, 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) and § 77q(a)(3)]. 
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COUNT II
 
Violations of Section 10(b) of the Exchange Act,
 
and Exchange Act Rule 10b-5
 
(Against All Defendants)
 
56. Paragraphs 1 through 51 are realleged and incorporated by reference. 
57. As more fully described in paragraphs 1 through 51 above, defendants, 
in connection with the purchase and sale of securities, by the use of the means and 
instrumentalities of interstate commerce and by the use of the mails, directly and 
indirectly: used and employed devices, schemes and artifices to defraud; made untrue 
statements of material fact and omitted to state material facts necessary in order to 
make the statements made, in light of the circumstances under which they were 
made, not misleading; and engaged in acts, practices and courses of business which 
operated or would have operated as a fraud and deceit upon purchasers and sellers 
and prospective purchasers and sellers of securities. 
58. Defendants knew, or were reckless in not knowing, of the facts and 
circumstances described in paragraphs 1 through 51 above. 
59. By reason of the foregoing, defendants violated 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]. 
COUNT III 
Violations of Sections 5(a) and 5(c) of the Securities Act 
(Against All Defendants) 
60. Paragraphs 1 through 51 are realleged and incorporated by reference. 
61. Treasure did not file a registration statement, nor was one in effect with 
the SEC, in connection with the aforementioned promissory notes. 
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62. By engaging in the conduct described above, defendants, directly or 
indirectly: (i) made use of means or instruments of transportation or communication 
in interstate commerce or of the mails to sell, through the use or medium of a 
prospectus or otherwise, securities as to which no registration statement was in effect; 
(ii) for the purpose of sale or delivery after sale, carried or caused to be carried 
through the mails or in interstate commerce, by any means or instruments of 
transportation, securities as to which no registration statement was in effect; and (iii) 
made use of any means or instruments of transportation or communication in 
interstate commerce or of the mails to offer to sell or offer to buy, through the use or 
medium of a prospectus or otherwise, securities as to which no registration statement 
had been filed and or was in effect as to such securities, and no exemption from 
registration was available. 
63. By reason of the activities described herein, defendants, singly or in 
concert, directly or indirectly, have violated Sections 5(a) and 5(c) of the Securities 
Act [15 U.S.C. §§ 77e(a) and 77e(c)]. 
COUNT IV 
Control Person Liability 
(Against Holley) 
64. Paragraphs 1 through 51 are realleged and incorporated by reference. 
65. By virtue of the conduct alleged herein, Treasure committed violations 
of Sections 10(b) [15 U.S.C. §78j(b)] and Rules l0b-5 [17 C.F.R. § 240.10b-5] of the 
Exchange Act, and Section 17(a)(1), (2), and (3) of the Securities Act [15 U.S.C. § 
77q(a)(1), § 77q(a)(2) and § 77q(a)(3)] as described in Count I and Count II above, 
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which are incorporated by reference as if fully set forth herein. 
66. As set forth above, during the relevant period, Holley directly or 
indirectly, controlled Treasure. As its president, Holley controlled the day-to -day 
affairs of Treasure. Holley enjoyed the power to direct Treasure’s policies, 
operations, and statements to investors. Indeed, Holley spearheaded and led the 
solicitation efforts that succeeded in attracting many, if not most, of Treasure’s 
investors. Holley was a culpable participant in the fraudulent conduct described 
above and knowingly or recklessly induced many of the material misrepresentations 
alleged herein. 
67. Holley directly or indirectly controlled Treasure within the meaning of 
Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)]. 
68. Holley knowingly or recklessly, directly or indirectly, induced acts 
constituting violations of Section 10(b) and Rule 10b-5 of the Exchange Act [15 
U.S.C. § 78j(b); 17 C.F.R. § 240.10b-5]. 
69. Holley is liable as a control person for Treasure’s violations of Section 
10(b) and Rule 10b-5 of the Exchange Act [15 U.S.C. § 78j(b); 17 C.F.R. § 240.10b-
5]. Accordingly, pursuant to Section 20 of the Exchange Act [15 U.S.C. § 78t(a)], 
Holley is liable jointly and severally with and to the same extent as Treasure and 
Gray. 
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COUNT V 
Equitable Claim With Respect to Relief Defendants 
(Against Relief Defendants) 
70. Paragraphs 1 through 51 are realleged and incorporated by reference. 
71. Relief Defendants, directly or indirectly, received funds or benefited 
from the use of such funds, which are the proceeds, or are traceable to the proceeds, 
of defendants’   unlawful activity alleged in paragraphs 1 through 51. 
72. Relief Defendants have no legitimate claim to these funds that they 
received or from which they otherwise benefited, directly or indirectly. 
73. Based upon the allegations set forth above, the Relief Defendants have 
been unjustly enriched by their direct or indirect receipt of or benefit from investor 
funds. 
74. Carleen Holley is married to defendant Larry Holley, and a substantial 
amount of investor funds have been transferred to Carleen Holley’s joint account 
with Larry Holley. She has also made several cash withdrawals from Treasure’s 
account. While some of the money she received may be related to discrete work she 
has performed for Treasure, there are many money transfers for which there is no 
apparent legitimate purposes. 
75. Kingdom Asset was founded and is controlled by defendant Holley. 
Kingdom Asset shares the same address as Treasure. Its funds have been 
intermingled with Treasure’s funds. Kingdom Asset has been the recipient of ill-
gotten gains. Treasure has transferred funds from its commingled checking account 
to Kingdom Asset. 
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76. The SEC is entitled to an order requiring the Relief Defendants to 
disgorge all of the proceeds of investor funds they received or from which they 
benefited, either directly or indirectly. 
RELIEF REQUESTED 
WHEREFORE, the SEC respectfully requests that this Court: 
I. 
Issue findings of fact and conclusions of law that defendants Treasure 
Enterprise LLC, Patricia Enright Gray, and Larry Allen Holley committed the 
violations charged and alleged herein. 
II. 
Enter an Order of Permanent Injunction restraining and enjoining defendants, 
their officers, agents, servants, employees, attorneys and those persons in active 
concert or participation with defendants who receive actual notice of the Order, by 
personal service or otherwise, and each of them from, directly or indirectly, engaging 
in the transactions, acts, practices or courses of business described above, or in 
conduct of similar purport and object, in violation of Section 5(a) and (c) [15 U.S.C. 
§§ 77e(a) and 77e(c)] and 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] and Rule 10b-5 [17 CFR § 
240.10b-5] thereunder. 
III. 
Issue an Order requiring defendants to disgorge the ill-gotten gains received as 
a result of the violations alleged in this Complaint, including prejudgment interest. 
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IV.
 
With regard to the defendants’ violative acts, practices and courses of business 
set forth herein, issue an Order imposing upon defendants appropriate civil penalties 
pursuant to 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. 
Enter an Order requiring relief defendants Carleen Renee Holley and 
Kingdom Asset Management LLC to disgorge all funds they received from 
defendants’ ill-gotten gains or by which they have been unjustly enriched, including 
all investor funds transferred to them or used for their benefit, wherever located, 
including jurisdictions outside of the United States, including prejudgment interest 
thereon. 
VI. 
Retain jurisdiction of this action in accordance with the principals 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 relief as this Court deems appropriate. 
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JURY DEMAND 
The Commission hereby requests a trial by jury. 
Dated: March 28, 2017 
Respectfully submitted, 
UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION 
By: /s/ Jonathan S. Polish 
Jonathan S. Polish (IL 6237890) 
John E. Birkenheier (IL 6270993) 
Steven L. Klawans (IL 6229593) 
Ana P. Doncic (IL 6297413) 
Attorneys for Plaintiff 
U.S. SECURITIES AND 
EXCHANGE COMMISSION 
175 W. Jackson Boulevard, Suite 1450 
Chicago, Illinois 60604 
Telephone: (312) 353-7390 
Email:  [email protected] 
DANIEL L. LEMISCH 
Acting United States Attorney 
Peter A. Caplan 
Assistant United States Attorney 
211 W. Fort Street, Ste. 2001 
Detroit, MI 48226 
(313) 226-9784 
P-30643 
Email: [email protected] 
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UNITED STATES DISTRICT COURT
 
EASTERN DISTRICT OF MICHIGAN
 

UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION, 

Plaintiff, 

v. 

TREASURE ENTERPRISE LLC, 
PATRICIA ENRIGHT GRAY, and LARRY 
ALLEN HOLLEY, 

Defendants, 

and 

KINGDOM ASSET MANAGEMENT LLC 
and CARLEEN RENEE HOLLEY, 

Relief Defendants. 

: 
: 
: 
: 
: 
: 
: 
: No. 17-cv-10963 
: 
: Hon. Marianne O. Battani 
: 
: 
: JURY DEMANDED 

: 
: 
: 
: 
: 
: 
: 

[UNDER SEAL] 

COMPLAINT 

Plaintiff United States Securities and Exchange Commission (“SEC”) alleges: 

1. The SEC brings this civil law enforcement action to shut down an 

ongoing, Michigan-based offering fraud involving at least $6.7 million, much of 

which came from retirees and senior citizens, living in Michigan and elsewhere. The 

fraud is being perpetrated by defendants Treasure Enterprise LLC (“Treasure”), 

Patricia Enright Gray (“Gray”), and Larry Allen Holley (“Holley”). Defendants 

targeted retirees and laid-off auto workers with severance plans, among others. 

2. They targeted these investors in churches. Holley, a pastor who held 



  

   

  

   

   

   

  

     

  

 

   

    

 

  

    

    

  

  

   

     

  

  

    

  

himself out as a successful businessman, cloaked his solicitations in faith-based 

rhetoric, replete with references to scripture and biblical figures. Investors were 

drawn to, and put their trust in, Holley and Gray because of their seemingly shared 

spirituality. Holley told prospective investors that, as a person who “prayed for your 

children,” he was more trustworthy than a “banker.” 

3. Prospective investors also found appealing the high interest rates 

defendants promised – far higher than what they could earn from certificates of 

deposit or other, conservative investments. And they found it important that at the 

end of the agreed-upon term of investment, Treasure would return all of their 

principal back to them. 

4. In addition to churches, defendants solicited investors on the internet 

and through social media. Gray advertised on a Flint-based Christian/gospel radio 

station. In the ads, she held herself out as a “personal financial wealth coach.” 

5. Defendants typically touted Treasure as a successful, profitable, real 

estate company with hundreds of residential and commercial properties. Prospective 

investors were told that, given the profitability of Treasure’s real estate business, 

Treasure could offer investors high, fixed, and guaranteed interest payments. 

Investors were told that Treasure had a full, money back guarantee for any 

unsatisfied investor. Gray told investors that an investment in Treasure was risk-free, 

since it had ample cash reserves to cover early redemption requests. Such assurances 

were important to investors. 

6. Prospective investors were told that their money at Treasure would be 

kept in a qualified Individual Retirement Account, which meant retirement proceeds 

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could be rolled over into Treasure tax-free. Gray told at least one investor that 

Treasure’s IRA was monitored by an independent, third-party custodian. Many 

investors’ willingness to invest with Treasure depended upon it having a qualified 

IRA. Investors expressly told Gray as much. 

7. From February 2015 until recently, approximately 83 individuals 

invested with Treasure. Some turned over their entire life savings. 

8. Only later did investors learn there was nothing guaranteed or risk free 

about their Treasure investment. For most investors, the trouble began when 

Treasure stopped sending them their agreed-upon interest payments, or when they 

tried availing themselves of Treasure’s money back guarantee. Instead of making the 

agreed-upon payments or honoring the redemption requests, however, defendants 

offered only excuses and delays. To date, Treasure owes more than 40 investors 

about $2 million in promissory notes that are past due – and that’s only Treasure’s 

Michigan-based investors. On information and belief, Treasure also has outstanding 

obligations to its investors living outside the State of Michigan. 

9. As its troubles mounted, defendants continued soliciting new 

investment proceeds in an effort to keep Treasure afloat. They did so by making the 

misrepresentations described above – about Treasure’s success, its profitability, the 

promise of high, guaranteed returns, and at the end of the investment period the safe 

return of an investor’s entire principal. 

10. The SEC brings this lawsuit to put an immediate stop to the defendants’ 

ongoing misconduct; to marshal and safeguard assets; to prevent further harm to 

investors; and to hold defendants accountable for their misdeeds. 

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JURISDICTION AND VENUE 

11. The SEC brings this action pursuant to Section 20(b) of the Securities 

Act of 1933 [15 U.S.C. §77t(b)] (“Securities Act”) and Sections 21(d) and 21(e) of the 

Securities Exchange Act of 1934 [15 U.S.C. §§78u(d) and 78u(e)] (“Exchange Act”). 

12. This Court has jurisdiction over this action pursuant to Section 22 of 

the Securities Act [15 U.S.C. § 77v] and Section 27 of the Exchange Act [15 U.S.C. § 

78aa]. 

13. Venue is proper in this Court pursuant to Section 27 of the Exchange 

Act [15 U.S.C. § 78aa]. Acts, practices and courses of business constituting violations 

alleged herein have occurred within the jurisdiction of the United States District 

Court for the Eastern District of Michigan and elsewhere. 

14. Defendants directly and indirectly made use of the means and 

instrumentalities of interstate commerce and of the mails in connection with the acts, 

practices, and courses of business alleged herein, and will continue to do so unless 

enjoined. 

DEFENDANTS AND RELIEF DEFENDANTS 

15. Defendant Treasure Enterprise LLC is a Michigan limited liability 

company formed by Holley in 2009 and based in Flint, Michigan. Treasure purports 

to purchase, invest in and manage residential and commercial real estate. From 

February 2015 to the present, Treasure raised approximately $6.7 million from 83 

investors. Treasure is not registered with the SEC. 

16. Defendant Larry Allen Holley, age 59, currently resides in Grand 

Blanc, Michigan. Holley is a pastor of Abundant Life Ministries International, Inc. 

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(“Abundant Life”), a church in Flint, Michigan. Holley is also the founder and 

president of Treasure and relief defendant Kingdom Asset Management LLC. Holley 

does not hold any securities licenses and has never been registered with the SEC. 

17. Defendant Patricia Enright Gray, age 55, currently resides in Flint, 

Michigan. Gray is a financial consultant on behalf of Treasure and Kingdom Asset 

Management LLC. Gray is also affiliated with Abundant Life. Gray does not hold 

any securities licenses and has never been registered with the SEC. 

18. Relief Defendant Carleen Renee Holley, age 53, currently resides in 

Grand Blanc, Michigan. Carleen Holley is married to Larry Holley. She is also 

affiliated with Abundant Life, and works for Treasure and Kingdom Asset 

Management LLC. Carleen Holley does not hold any securities licenses and has 

never been registered with the SEC. 

19. Relief Defendant Kingdom Asset Management LLC (“Kingdom 

Asset”) is a Michigan limited liability company formed by Holley and his wife 

Carleen Holley in 2006. It is based in Flint, Michigan. Kingdom Asset purports to 

purchase, invest in and manage residential and commercial real estate. Holley serves 

as its President. Kingdom Asset is an affiliate of Treasure and shares the same 

address as Treasure and Abundant Life. Kingdom Asset’s officers, employees and 

associates are also affiliated with Treasure. On information and belief, Kingdom 

Asset raised funds from investors. Kingdom Asset is not registered with the SEC. 

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FACTS 

Defendants’ Investment Pitch Resonates With Prospective Investors 

20. Defendants broadly advertised over social media websites and bragged 

about their professional success. Holley’s bio, posted on various social media outlets 

and websites, stated that he “has been gifted to inspire thousands of individuals to 

discover God’s promises and apply practical solutions for experiencing financial 

increase.” Holley’s bio also touted that he “has successfully created, managed and 

prospered in various businesses over 30 years.” 

21. Gray advertised on a religious radio station based in Flint, Michigan. 

She claimed to be a “personal wealth coach.” She promised to help listeners “make 

your money work for you!” She singled-out recently laid-off auto workers with 

severance packages to consult her for a “financial increase.” 

22. When prospective investors met with Gray, they were handed her 

business card, on which she boasted: “I’ve helped hundreds of men and women earn, 

save and invest millions of dollars and I can help you.” 

23. Defendants made financial presentations at churches nationwide, which 

Treasure promoted as “Blessed Life Conferences.” Holley – who marketed himself as 

a pastor, businessman and philanthropist – would begin the conferences with a 

sermon to the congregation. 

24. A video of one such sermon is available on the internet. During that 

sermon Holley repeatedly urged congregants to fill out cards detailing their financial 

holdings. Holley promised to pray over the cards. He then promised that Gray would 

take the cards and have one-on-one consultations with any interested congregants. 

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To encourage such one-on-one consultations, Holley recounted how, thanks to Gray, 

one investor who had been earning a mere $300 a month from his savings now 

enjoyed $3000 a month – all from “the same money.” 

25. Holley repeatedly told congregants that his investors were “millionaires 

in the making.” He encouraged congregants to embrace “sowing” their money with 

him and his business. Holley told them that they will “not lose” if they invest in real 

estate. 

26. Holley then handed off selected congregants to Gray for one-on-one 

“consultations.” Gray told prospective investors that she would help them find 

money that they did not know they had. She promised to make their money 

“increase” and “multiply.” 

27. During those sessions, Gray would describe to the prospects how 

Treasure worked. She explained that the investor’s money would be pooled with 

other investor proceeds to purchase real estate, which Treasure would own and 

maintain. Gray described Treasure’s real estate holdings as profitable. Gray 

explained that the real estate generated income, principally from rents. That income, 

she explained, funded the interest payments made to Treasure’s investors. And after 

Treasure finished making the agreed-upon interest payments, Gray explained, it 

would then return all of the principal back to the investor. 

28. During the consultations, Gray showed prospective investors a large 

book filled with photographs of what she represented to be some of Treasure’s 

properties, as well as purported testimonials from satisfied investors and photocopies 

of checks that Treasure had paid to investors. She also showed Treasure’s marketing 

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materials promising high returns. 

29. Gray told at least one investor that her investment with Treasure was 

risk free. She told another that Treasure had ample “reserves” to pay back investors if 

the business struggled or if investors chose to redeem their investment early. 

30. Gray oftentimes represented that Treasure offered a qualified Individual 

Retirement Account (“IRA”), which meant an investor could rollover an IRA or 

401(k) proceeds into Treasure on a tax-free basis. This was particularly important to 

retirees and the beneficiaries of severance agreements – two types of investors 

defendants targeted. 

31. Gray would oftentimes call the securities firm at which a prospective 

investor held an IRA – with the investor on the phone. During that phone call, and as 

part of the rollover process, she represented to the customer service representative – 

and to the prospective investor – that Treasure was a qualified IRA. 

32. Gray told at least one prospective investor that a specific self-directed 

IRA firm – which she identified by name – served as Treasure’s custodian. Gray went 

so far as to have the prospective investor fill out that custodian’s forms, and asked 

that the completed forms be returned to her. Gray said she would forward the forms 

to the custodian. The investor wrote a check to Gray, who in turn gave the investor a 

receipt in which Gray promised to deposit the money “in [the investor’s] new Self 

Directed IRA through Treasure Enterprise via [the IRA custodian] on her behalf.” 

The receipt is signed by Gray and witnessed by a Treasure employee. 

33. None of this was true. Treasure did not have a qualified IRA or an IRA 

custodian. Rather, Treasure simply deposited checks made payable to “Treasure 

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Enterprise IRA f/b/o [investor name]” into its non-IRA business checking account. 

That’s the same account in which Treasure kept the rest of its money, including 

income from its real estate properties. 

34. Holley knew about Gray’s lies about Treasure having a qualified IRA. 

He was a signatory on Treasure’s checking account. Thus, he saw investor checks 

payable to “Treasure Enterprise IRA” deposited into Treasure’s general checking 

account. In December 2014, Holley, Gray, and Treasure were sued by an investor. In 

the complaint the investor alleged that she received tax penalty notices from the 

Internal Revenue Service because Treasure was not an IRA – contrary to Gray’s 

representations. Defendants ultimately settled with the investor. Yet even after the 

lawsuit was settled, Gray continued lying to prospective investors about depositing 

their money in a Treasure IRA, as evidenced by the resulting checks made payable to 

“Treasure Enterprise IRA.” 

35. Those weren’t defendants’ only lies to prospective investors. 

Prospective investors were told that Treasure investors could count on a fixed interest 

payment at regular intervals for a defined period of time. They were told that if 

Treasure investors were ever unsatisfied – even before the promissory note came due 

– Treasure would return the principal upon request. Better still, Treasure would not 

penalize the investor for an early withdrawal. But whenever it was that they chose to 

redeem, defendants told investors, Treasure would promptly return their entire 

principal back to them. As Treasure’s investors have since learned, none of that was 

true. 

36. Gray’s and Holley’s pitches served their intended purpose. Since 

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February 2015, approximately 83 people from at least 14 states collectively invested 

about $6.7 million with Treasure. 

37. Once someone decided to invest in Treasure, the investment would be 

documented with a promissory note reflecting the principal amount, the interest rate, 

and the duration of the note. 

38. Gray or Holley signed the promissory notes on Treasure’s behalf. 

39. Oftentimes defendants would also give the investor an account 

statement projecting the investment’s performance. In the document, defendants 

would compare what the investor would receive from Treasure (which varied, but 

was generally between 7%-10%) with various alternatives, including the investor’s 

returns had they stayed in their previous investment vehicle (generally calculated at 

00.25% rate of return); had they invested the average rate of return offered by a CD 

(generally calculated at 00.65% rate of return); or had they invested in the stock 

market (generally calculated at 2.5% annual rate of return). In defendants’ 

projections, Treasure always dramatically outperformed the alternative investment 

options. 

Treasure’s Financial Condition Deteriorates,
 
But Defendants Continue Touting It As A Successful,
 

Profitable Investment Opportunity
 

40. Defendants touted Treasure as a real estate company that earned 

significant profits for its investors from income earned on its large and lucrative real 

estate portfolio. Defendants advertised that Holley’s businesses “generated millions 

of dollars in annual sales in business.” The truth was far different. From February 

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2015 to the present, while Treasure’s obligations to its investors grew steadily, the 

income it earned from its real estate in order to meet those obligations did not come 

close to keeping pace. As this chasm grew, Treasure found itself increasingly pinched 

for money. 

41. In response, defendants stopped meeting their obligations to Treasure’s 

investors. They made fewer of the interest payments required of Treasure under the 

promissory notes. And they increasingly disregarded investors’ redemption requests. 

Several investors sued to get their money back. 

42. Investors also filed complaints with the State of Michigan’s Department 

of Licensing and Regulation (“LARA”). On August 11, 2016, LARA issued a cease-

and-desist order against defendants barring them from selling unregistered securities 

in Michigan, and from making any misstatement of material fact in violation of 

Michigan law. On January 13, 2017, LARA instituted a cease-and-desist order 

against Gray, barring her from selling unregistered securities in Michigan and from 

making any misstatement of material fact in violation of Michigan law. 

43. Instead of disclosing this information to investors, defendants lied to 

investors about the LARA proceedings. They did so in order to manufacture a 

pretext for Treasure’s inability to honor investors’ redemptions requests. Gray 

misrepresented to investors that LARA had frozen Treasure’s “millions of dollars in 

assets,” and that it had ordered Treasure to cease repayment to investors pending 

resolution of the action. Gray told another investor that Treasure could not redeem 

any investment until a LARA-ordered audit was completed. She told yet another 

investor that her redemption request could only be honored after Treasure complied 

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with LARA’s demands that Treasure liquidate some or all of its real estate holdings. 

These were all lies. 

Defendants Solicit New Investment Proceeds,
 
Which They Clandestinely Use To Pay Off Earlier Investors
 

44. As Treasure struggled financially, Holley and Gray continued their 

solicitation efforts in an effort to keep their failing enterprise afloat. But they never 

disclosed Treasure’s dire financial state to prospective investors during their 

solicitation efforts. Nor did they disclose that Treasure was defaulting on its 

obligations to its preexisting investors, or that several of these investors were suing 

defendants. 

45. Rather, defendants falsely claimed that Treasure was a successful real 

estate company that was making significant profits for its investors from its portfolio 

of commercial and residential properties. And they continued to advertise Treasure’s 

supposedly “guaranteed” interest payments and its money back guarantee. 

46. These misrepresentations worked, yielding fresh investor proceeds that 

flowed into Treasure’s accounts. 

47. Defendants promised these new investors that their money would be 

used to buy real estate. Oftentimes that was a lie. In some instances, defendants 

instead used new investor proceeds to pay Treasure’s preexisting obligations to its 

preexisting investors – including interest payments and the repayment of principal. 

48. Defendants oftentimes treated fresh investment proceeds as hush money 

to quiet complaining, preexisting investors. In October 2015, for instance, Treasure 

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ignored an investor’s redemption request for her $200,000 investment. The investor 

responded by filing a complaint with the State of Michigan, and by filing a lawsuit 

against defendants. To buy her off, defendants successfully solicited a new investor 

and used $100,000 of his investment proceeds to settle the lawsuit. Defendants never 

told the new investor that his money would be used in this manner. Rather, he was 

told that his money would be deposited in a Treasure IRA account and invested in 

real estate. That was a lie. 

49. As of February 2017, Treasure was past due on approximately 51 

promissory notes for 43 investors, totaling nearly $2 million. Treasure lacks the 

money to repay these past due obligations, let alone the means to honor its 

continuing, significant obligations to its current investors. 

50. The promissory notes constituted securities. Treasure Enterprise pooled 

the investors’ funds into a single bank account. Investors were told both orally and in 

writing that their funds would be used to purchase and manage real estate. Investors 

were led to believe that the profits generated from this purchase and management of 

real estate would be used to pay their promised interest. Thus, the profits and losses 

of each investor were tied to the profits and losses of other investors. The investors 

had no control over how their funds would be used after they invested. 

51. Defendants offered and sold the promissory notes using the mail. 

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COUNT I 

Violations of Section 17(a)(1), (2) and (3) of the Securities Act 
(Against All Defendants) 

52. Paragraphs 1 through 51 are realleged and incorporated by reference as 

though fully set forth herein. 

53. By virtue of the conduct alleged herein, defendants, directly or 

indirectly, singly or in concert with others, in the offer and sale of securities, by use of 

the means and instruments of transportation and communication in interstate 

commerce and by use of the mails, have: (a) employed devices, schemes or artifices 

to defraud; (b) obtained money or property by means of untrue statements of material 

fact or omissions to state material facts 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 operate or 

would operate as a fraud or deceit upon the purchaser. 

54. In engaging in the conduct described herein, defendants acted 

knowingly and/or with a reckless disregard for the truth and/or negligently. 

55. By reason of the foregoing, defendants have violated, and unless 

enjoined will likely again violate, 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) and § 77q(a)(3)]. 

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COUNT II
 

Violations of Section 10(b) of the Exchange Act,
 
and Exchange Act Rule 10b-5
 

(Against All Defendants)
 

56. Paragraphs 1 through 51 are realleged and incorporated by reference. 

57. As more fully described in paragraphs 1 through 51 above, defendants, 

in connection with the purchase and sale of securities, by the use of the means and 

instrumentalities of interstate commerce and by the use of the mails, directly and 

indirectly: used and employed devices, schemes and artifices to defraud; made untrue 

statements of material fact and omitted to state material facts necessary in order to 

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

made, not misleading; and engaged in acts, practices and courses of business which 

operated or would have operated as a fraud and deceit upon purchasers and sellers 

and prospective purchasers and sellers of securities. 

58. Defendants knew, or were reckless in not knowing, of the facts and 

circumstances described in paragraphs 1 through 51 above. 

59. By reason of the foregoing, defendants violated 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]. 

COUNT III 

Violations of Sections 5(a) and 5(c) of the Securities Act 
(Against All Defendants) 

60. Paragraphs 1 through 51 are realleged and incorporated by reference. 

61. Treasure did not file a registration statement, nor was one in effect with 

the SEC, in connection with the aforementioned promissory notes. 

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62. By engaging in the conduct described above, defendants, directly or 

indirectly: (i) made use of means or instruments of transportation or communication 

in interstate commerce or of the mails to sell, through the use or medium of a 

prospectus or otherwise, securities as to which no registration statement was in effect; 

(ii) for the purpose of sale or delivery after sale, carried or caused to be carried 

through the mails or in interstate commerce, by any means or instruments of 

transportation, securities as to which no registration statement was in effect; and (iii) 

made use of any means or instruments of transportation or communication in 

interstate commerce or of the mails to offer to sell or offer to buy, through the use or 

medium of a prospectus or otherwise, securities as to which no registration statement 

had been filed and or was in effect as to such securities, and no exemption from 

registration was available. 

63. By reason of the activities described herein, defendants, singly or in 

concert, directly or indirectly, have violated Sections 5(a) and 5(c) of the Securities 

Act [15 U.S.C. §§ 77e(a) and 77e(c)]. 

COUNT IV 

Control Person Liability 
(Against Holley) 

64. Paragraphs 1 through 51 are realleged and incorporated by reference. 

65. By virtue of the conduct alleged herein, Treasure committed violations 

of Sections 10(b) [15 U.S.C. §78j(b)] and Rules l0b-5 [17 C.F.R. § 240.10b-5] of the 

Exchange Act, and Section 17(a)(1), (2), and (3) of the Securities Act [15 U.S.C. § 

77q(a)(1), § 77q(a)(2) and § 77q(a)(3)] as described in Count I and Count II above, 

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which are incorporated by reference as if fully set forth herein. 

66. As set forth above, during the relevant period, Holley directly or 

indirectly, controlled Treasure. As its president, Holley controlled the day-to-day 

affairs of Treasure. Holley enjoyed the power to direct Treasure’s policies, 

operations, and statements to investors. Indeed, Holley spearheaded and led the 

solicitation efforts that succeeded in attracting many, if not most, of Treasure’s 

investors. Holley was a culpable participant in the fraudulent conduct described 

above and knowingly or recklessly induced many of the material misrepresentations 

alleged herein. 

67. Holley directly or indirectly controlled Treasure within the meaning of 

Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)]. 

68. Holley knowingly or recklessly, directly or indirectly, induced acts 

constituting violations of Section 10(b) and Rule 10b-5 of the Exchange Act [15 

U.S.C. § 78j(b); 17 C.F.R. § 240.10b-5]. 

69. Holley is liable as a control person for Treasure’s violations of Section 

10(b) and Rule 10b-5 of the Exchange Act [15 U.S.C. § 78j(b); 17 C.F.R. § 240.10b-

5]. Accordingly, pursuant to Section 20 of the Exchange Act [15 U.S.C. § 78t(a)], 

Holley is liable jointly and severally with and to the same extent as Treasure and 

Gray. 

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COUNT V 

Equitable Claim With Respect to Relief Defendants 
(Against Relief Defendants) 

70. Paragraphs 1 through 51 are realleged and incorporated by reference. 

71. Relief Defendants, directly or indirectly, received funds or benefited 

from the use of such funds, which are the proceeds, or are traceable to the proceeds, 

of defendants’ unlawful activity alleged in paragraphs 1 through 51. 

72. Relief Defendants have no legitimate claim to these funds that they 

received or from which they otherwise benefited, directly or indirectly. 

73. Based upon the allegations set forth above, the Relief Defendants have 

been unjustly enriched by their direct or indirect receipt of or benefit from investor 

funds. 

74. Carleen Holley is married to defendant Larry Holley, and a substantial 

amount of investor funds have been transferred to Carleen Holley’s joint account 

with Larry Holley. She has also made several cash withdrawals from Treasure’s 

account. While some of the money she received may be related to discrete work she 

has performed for Treasure, there are many money transfers for which there is no 

apparent legitimate purposes. 

75. Kingdom Asset was founded and is controlled by defendant Holley. 

Kingdom Asset shares the same address as Treasure. Its funds have been 

intermingled with Treasure’s funds. Kingdom Asset has been the recipient of ill-

gotten gains. Treasure has transferred funds from its commingled checking account 

to Kingdom Asset. 

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76. The SEC is entitled to an order requiring the Relief Defendants to 

disgorge all of the proceeds of investor funds they received or from which they 

benefited, either directly or indirectly. 

RELIEF REQUESTED 

WHEREFORE, the SEC respectfully requests that this Court: 

I. 

Issue findings of fact and conclusions of law that defendants Treasure 

Enterprise LLC, Patricia Enright Gray, and Larry Allen Holley committed the 

violations charged and alleged herein. 

II. 

Enter an Order of Permanent Injunction restraining and enjoining defendants, 

their officers, agents, servants, employees, attorneys and those persons in active 

concert or participation with defendants who receive actual notice of the Order, by 

personal service or otherwise, and each of them from, directly or indirectly, engaging 

in the transactions, acts, practices or courses of business described above, or in 

conduct of similar purport and object, in violation of Section 5(a) and (c) [15 U.S.C. 

§§ 77e(a) and 77e(c)] and 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] and Rule 10b-5 [17 CFR § 

240.10b-5] thereunder. 

III. 

Issue an Order requiring defendants to disgorge the ill-gotten gains received as 

a result of the violations alleged in this Complaint, including prejudgment interest. 

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IV.
 

With regard to the defendants’ violative acts, practices and courses of business 

set forth herein, issue an Order imposing upon defendants appropriate civil penalties 

pursuant to 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. 

Enter an Order requiring relief defendants Carleen Renee Holley and 

Kingdom Asset Management LLC to disgorge all funds they received from 

defendants’ ill-gotten gains or by which they have been unjustly enriched, including 

all investor funds transferred to them or used for their benefit, wherever located, 

including jurisdictions outside of the United States, including prejudgment interest 

thereon. 

VI. 

Retain jurisdiction of this action in accordance with the principals 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 relief as this Court deems appropriate. 

20JURY DEMAND 

The Commission hereby requests a trial by jury. 

Dated: March 28, 2017 

Respectfully submitted, 

UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION 

By: /s/ Jonathan S. Polish 
Jonathan S. Polish (IL 6237890) 
John E. Birkenheier (IL 6270993) 
Steven L. Klawans (IL 6229593) 
Ana P. Doncic (IL 6297413) 
Attorneys for Plaintiff 
U.S. SECURITIES AND 
EXCHANGE COMMISSION 
175 W. Jackson Boulevard, Suite 1450 
Chicago, Illinois 60604 
Telephone: (312) 353-7390 
Email:  [email protected] 

DANIEL L. LEMISCH 
Acting United States Attorney 

Peter A. Caplan 
Assistant United States Attorney 
211 W. Fort Street, Ste. 2001 
Detroit, MI 48226 
(313) 226-9784 
P-30643 
Email: [email protected] 

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mailto:[email protected]
mailto:[email protected]