SEC v. Paul Ricky Mata; David Kayatta; Mario Pincheira; Logos Real Estate Holdings, LLC; Logos Wealth Advisors Inc.; Lifetime Enterprises, Inc. (dba Logos Lifetime University), et al., Central District of California (Jan. 1, 2015) — Complaint

p.6 
Sep 02 2015 1:56PM PIP Printing Riverside 
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L~M. DEAN, Cal. Bar No. 205562 ~ i") 
1
ua \\. 01 
Emml: deanllalsec~v ·!11~ St.r -" 1\fl • 
BRENT W. WILNER, Cal. Bar No. ~30093 ,. T couRT 
Email: [email protected] ·... CLtR~·~~t: %\~1~61 c,\LW. 
.    . CEK RlVE.RS\0,;. 
Attorneys for Plcunttff 
Securities and Exchange CommissiollY:----~-----· 
Michele Wein Layne
1 
Re_gional Director 
Lorraine 
B. Echavama, Associate Regional Director 
John W. Berryl,Regional Trial Counsel 
444 S. Flower ~treet, Suite 900 
Los Angeles, California 90071 
TelephQne: (323) 965-3998 
Facsumle: {213) 443-1904 
UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA 
---~__........_._,cvt5-01792 \J~? 

SECURITIES AND EXCHANGE 
Case No. 
COMMISSION, 
Plaintiff, 
COMPLAINT 
vs. 
PAUL MATA'rpAV1D KAYATTA, 
~~L~~EJMt:~'§Uff8.
LOGOS REAL ESTATE HOLDINGS, 
LLC. LOGOSWEALTH 
ADViSORS INC. LIFETIME 
ENTERPRI~~~~LC(dba LOGOS 
LIFETIME u1~~ vERSITY), 
Defendants. 

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Plaintiff Securities and Exchange Commission (the "SEC") alleges as follows: 
JURISDICTION AND VENUE 
1. This 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){l) and 77v(a); Sections 21(d){l), 21(d)(3)(A), 21(e) and 27 ofthe 
Securities Exchange Act of 1934 ("Exchange Act"), 15 U .S.C. § § 78u( d)( 1), 
78u(d)(3)(A), 78u(e), and 78aa; and Sections 209(d)-(e) and 214 of the Investment 
Advisers Act 
of 1940 ("Advisers Act"), 15 U.S.C. §§ 80b-9(d)-(e) and 80b-14. 
2. Defendants have, directly or indirectly, made use of the means or 
instrumentalities 
of interstate commerce or of the mails, 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); Section 27 of the Exchange Act, 15 U.S.C. § 78aa; and 
Section 214 
ofthe Advisers Act, 15 U.S.C. § 80b-14, because certain of the 
transactions, acts, practices and courses 
of conduct constituting violations ofthe 
federal securities laws occurred within this district. In addition, venue is  proper 
in 
this district because all of the defendants reside in this district. 
SU~RY 
4. This is an action to halt an ongoing offering fraud orchestrated by 
defendant Paul Ricky Mata, a former registered investment adviser with an extensive 
disciplinary history. Undeterred by his termination from Ameriprise Financial and 
disciplinary suspensions, Mata formed two unregistered advisory firms, Logos 
Wealth Advisors, Inc. ("Wealth Advisors") and Lifetime Enterprises, Inc., 
dba Logos 
Lifetime University ("Lifetime University"), and together with David Kayatta 
("Kayatta") and Mario Pincheira ("Pincheira") defrauded investors. 
5. From 2008 through the present, defendants raised over $14 million from 
over 100 investors from California and several other states, by soliciting investments 
in two unregistered funds Mata controlled, defendant Secured Capital Investments, 
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LLC ("SCI") and defendant Logos Real Estate Holdings, LLC ("LREH") 
(collectively, the "Funds"). 
6. Mata, Kayatta, Wealth Advisors, and Lifetime University are actively 
soliciting investments in SCI and LREH. They have induced investors, many 
of them 
retirees, into selling their existing securities holdings and investing in the Funds, 
using online videos, investment seminars promising "Indestructible 
Wealth," and 
presentations to church groups promising "Finances God's Way." Mata, Kayatta, 
Wealth Advisors, and Lifetime University induced investors by falsely promising 
"guaranteed" returns, misrepresenting SCI's use 
of proceeds, and failing to disclose 
Mata's disciplinary history and his control 
of SCI to his advisory clients. 
7. Mata, Kayatta, Wealth Advisors, and Lifetime University are defrauding 
investors by misusing investor funds, transferring money from SCI to other 
businesses controlled by Mata, and otherwise dissipating Fund assets. They are 
lulling investors into keeping their money with the Funds by touting their success, 
despite the fact that the Funds' have not made a profit. They have also lied to 
investors who expressed concern about the withdrawal 
of the Funds' IRA custodian. 
Mata and Kayatta engaged in further fraudulent conduct 
by allowing new investors to 
invest in LREH after the fund's closing date despite knowing that doing so would 
dilute the accounts 
of original investors. 
8. 
In addition, Mata, Kayatta, and Pincheira are misappropriating investor 
money for their personal use by incurring personal expenses on Pincheira' s personal 
American Express account and paying 
off the balances with SCI investor funds. 
9. Finally, the offer and sale of investments in SCI and LREH has never 
been registered with the SEC, 
as is required under the registration provisions of the 
federal securities laws. 
10. By engaging in this conduct, Mata, Kayatta, and Pincheira violated, and 
unless enjoined, will continue to violate the antifraud provisions 
of the federal 
securities laws, and Mata, Wealth Advisors, and Lifetime University has violated, 
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and unless enjoined, will continue to violate the provisions prohibiting fraud by an 
investment adviser. In addition, all of the defendants have violated, and unless 
enjoined, will continue to violate, the registration provisions 
of the federal securities 
laws. Therefore, with this action, the SEC seeks emergency relief against defendants, 
including a temporary restraining order, an asset freeze, accountings, expedited 
discovery, an order prohibiting the destruction 
of documents, and the appointment of 
a receiver over the entity defendants and other entities Mata controls. The SEC also 
seeks preliminary and permanent injunctions, disgorgement with prejudgment interest 
and civil penalties against defendants, and a conduct-based injunction as to Mata, 
Kayatta, and Pincheira prohibiting them from selling securities to investors or raising 
funds from investors for any entity they control. 
THE DEFENDANTS 
11. Paul Ricky Mata is a resident ofUpland, California. Mata is the 
founder and manager 
of SCI and LREH. 
12. From August 1988 until his termination in March 2009, Mata was the 
registered principal and supervisor for 
an independent contractor investment advisory 
branch office 
of Ameriprise Financial. Ameriprise terminated Mata for violating 
company policies 
by selling away, recommending that clients take out risky loans to 
finance investments, presenting unapproved seminars, employing individuals without 
conducting proper background checks, and operating SCI as a competing investment 
company. Thereafter, Mata formed Wealth Advisors, where he served as principal 
and investment adviser representative. 
13. On July 30, 2010, the Nevada Secretary of State obtained a cease-and­
desist order against Mata, Kayatta, SCI, and Wealth Advisors for soliciting 
investment in 
an unregistered security and engaging in unlicensed investment 
advising. On March 22, 2011, FINRA suspended Mata from association with any 
member firm for one-year and fined him $10,000, citing Mata's misconduct at 
Ameriprise. Mata also was suspended 
in 2014 for five months by California 
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Department of Business Oversight based on FINRA's suspension. Mata previously 
held Series 
7, 9, 10, 24, and 63 securities licenses, which expired in 2012. 
14. Despite his suspensions and the lapse of his licenses, Mata continues to 
serve as the adviser for Wealth Advisors' clients. 
15. In addition, Mata founded Lifetime University, which also provides 
financial planning seminars and investment advisory services. 
16. David Francis Kayatta is a resident of Claremont, California. Kayatta 
worked under Mata at  Ameriprise until July 2007. In December 2009, Kayattajoined 
Mata at Wealth Advisors and currently serves as the fund manager for SCI and 
LREH. In 2010, Kayatta was ordered by the Nevada Secretary 
of State to cease-and­
desist from soliciting Nevada investors in unregistered securities and from engaging 
in unlicensed investment advisory conduct. Kayatta previously held Series 7, 65, and 
66 securities licenses. 
17. Mario Pincheira is a resident of Alta Lorna, California. Pincheira is 
designated as SCI's director of client relations and property manager, with 
responsibilities for overseeing the fund's residential and commercial holdings. 
Pincheira was Wealth Advisors's director 
of client relations until Mata sold Wealth 
Advisors, and Pincheira also signed documents as Wealth Advisors's corporate 
secretary. Pincheira is  a co-signatory, along with Mata, to SCI's primary bank 
account and several affiliated accounts. Pincheira has never held any securities 
licenses or registrations. 
18. Secured Capital Investments, LLC is a Nevada LLC headquartered in 
Rancho Cucamonga, California formed in 2008 and controlled by Mata. Neither SCI, 
nor any 
of its securities, have been registered with the Commission. SCI's operative 
private placement memorandum dated 
1anuary 201 0 ("SCI PPM") describes SCI as a 
private equity fund. SCI was ordered by the Nevada Secretary 
of State to cease-and­
desist from soliciting Nevada investors 
to invest in unregistered securities. 
19. Logos Real Estate Holdings, LLC is a California LLC headquartered in 
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Rancho Cucamonga, California formed in 2010, also managed by Mata and Kayatta 
through their entity Logos Management Group, LLC. Neither LREH nor any 
of its 
securities are registered with the Commission. LREH's operative private placement 
memorandum dated August 2011 ("LREH PPM") describes LREH as a private 
investment fund. In addition to Mata controlling both SCI and LREH, there is 
extensive overlap between these two entities: SCI and LREH share common assets, 
and LREH has received loans and expense payments from SCI. 
20. 
Logos Wealth Advisors, Inc. is a California corporation headquartered 
in Rancho Cucamonga, California and was formed 
by Mata as a California registered 
investment adviser in 2009. Mata transferred Wealth Advisors to his administrative 
. 	assistant in March 2012, but continued to exert control over the firm up to and 
following the administrative assistant's departure from the firm in February 2015. 
Wealth Advisors is  listed in numerous documents as investment adviser or sponsor 
for SCI and LREH. 
21. Logos Lifetime Enterprises, LLC (dba "Logos Lifetime University") 
is a Nevada LLC founded and managed by Mata, which offers wealth management 
educational seminars and investment advisory services for fees ranging from several 
hundred to tens 
ofthousands of dollars. 
OTHER RELEVANT ENTITIES 
22. Indestructible Peak Management, Inc. is a California corporation 
headquartered in Rancho Cucamonga, California. It was formed in 2002 and 
provides staffing and administrative support 
to certain Mata entities. Mata is its sole 
owner and President, and has caused money to be transferred to it from SCI. 
23. 
Renaissance Management, LLC is  a Nevada LLC headquartered in 
Rancho Cucamonga, California. It was fanned in 2007. Mata has been its managing 
member from inception and has caused money to be transferred to 
it from SCI. 
24. 9327 
Fairway View Place, LLC is  a California LLC headquartered in 
Rancho Cucamonga, California. It was fanned in 2010 and until June 2015 held the 
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title to 38th Street, despite Defendants' representations to investors that 38th Street 
was owned by SCI. Mata has been its managing member since inception. 
25. 
Logos Management Group, LLC is a California LLC headquartered in 
Rancho Cucamonga, California. It was formed in 2010 and manages defendant 
LREH. Mata has been its managing member since inception, and has caused money 
to be transferred to it from LREH. 
26. 
Logos Insurance Group, Inc. is  a Nevada corporation headquartered in 
Rancho Cucamonga, California. 
It was formed in 2010. Mata was its President 
from 2010 to May 2012, and he owns 100% 
of the company. 
27. 
World Gardens Cafe, LLC is  a Nevada LLC headquartered in Rancho 
Cucamonga, California. 
It was formed in 20 11 as a mail order food delivery service. 
Mata's owns 70% 
ofthe company and has been its managing member since inception 
and has caused money to be transferred to it from SCI. 
28. 
ChefRavi's Recipes, LLC is a Nevada LLC headquartered in Rancho 
Cucamonga, California. It was formed in 2011 as a supplier for World Gardens Cafe. 
Mata owns 49% 
ofthe company and has been its managing member since inception 
and has caused money to be transferred 
to it from SCI. 
29. 
Destiny With a Purpose, LLC is a Nevada LLC headquartered in 
Rancho Cucamonga, California. 
It was formed in 20 11 to invest in second trust 
deeds. Mata has been its managing member since inception. SCI has an ownership 
interest in Destiny With A Purpose, LLC. 
THEFRAUDULENTSCHEME 
30. Since at least 2008 through the present, Defendants have raised 
roughly $14.5 million from approximately 
102 United States investors through 
unregistered securities offerings 
of two private investment funds, SCI and LREH. 
Defendants' solicitations 
of investors for SCI are ongoing. 
A. 
The SCI Offering 
31. Mata formed SCI in 2008, while working for Ameriprise, and 
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subsequently hired Kayatta as the fund's manager and Pincheira as the fund's 
property manager. 
32. Wealth Advisors 
is the investment advisory firm or sponsor for SCI. 
Through Mata, it provides investment advice 
to SCI. 
33. Wealth Advisors and Lifetime University, through Mata, provide 
investment adviser services 
to investors who invested in SCI. Both firms also direct 
clients 
to invest in SCI. 
34. Between 2008 and the present, approximately 
90 investors invested 
approximately $12.5 million 
in SCI. 
35. According to the SCI PPM, SCI 
is "a private equity firm that allows 
qualified investors to invest. 
..."  The PPM also states that the Fund was a "real estate 
investing program," and investing in "government backed tax liens," "asset backed 
deed certificates," and "distressed commercial and residential properties." 
36. For a minimum investment 
of $200,000, investors purportedly receive 
two promissory notes paying a 5% annual return and maturing in two years. The SCI 
PPM further represents that the annual return 
is "guaranteed" based on a seven-year 
reinvestment plan with the rate 
of return capped at 1 0%, and with principal repaid at 
maturity. 
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7. The SCI PPM claimed exemption from registration pursuant to Rule 506 
of Regulation D ofthe Securities Act. The SCI PPM further indicated that the notes 
could be sold to no more than 
35 non-qualified investors, yet at least 40 appear to 
have been issued to non-qualified investors. 
38. Mata directly solicits investments 
in SCI during meetings with his 
advisory clients, during which he performs analyses 
of their portfolios and then 
directs the clients to sell their existing securities holdings and invest in the Funds.  He 
also attracted investors by using online videos, seminars, and church presentations. 
3
9. Mata disseminated the SCI PPM, promissory note agreements, and 
investor suitability questionnaires 
to prospective investors. Certain subscription 
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agreements were returned with incomplete investor suitability forms, and some 
investors did not complete the investor suitability questionnaires attributed to them at 
all. Mata relied on his purported familiarity with the clients 
to conclude they were 
qualified investors, rather than verifying their net worth. 
40. Defendants' solicitations for SCI are ongoing. 
41. SCI maintains an online presence where defendants solicit investors for 
the Fund, including a website and a Y ouTube channel on which Kayatta appears 
touting the SCI Fund. 
42. Mata and Kayatta appeared at  a three-day seminar in Los Angeles, 
California in May 2015 called "Indestructible Wealth Bootcamp," where they 
solicited investors. 
43. A website managed by Mata advertises that he plans to offer another 
three-day "Indestructible Wealth Bootcamp" seminar in Los Angeles California on 
October 2-4, 2015. 
44. Kayatta participates in the Mata-led investment seminars, where Mata 
introduces him as the Funds' manager. Kayatta 
is also identified in the LREH PPM 
as that Fund's manager. 
45. Pincheira also participates in the Mata-led investment seminars, where 
Mata introduces him as the SCI's property manager. 
B. The LREH Offering 
46. In August 2010, Mata and Kayatta, through Logos Management Group, 
LLC, formed LREH as a private investment fund providing investors a variable 
return. 
47. Wealth Advisors and Lifetime University, through Mata, provide 
investment adviser services to investors who invested 
in LREH. Both firms also 
directed clients to invest in LREH. 
48. From 2011 through at least 2013, 
12 investors invested approximately $2 
million in LREH. 
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49. For a minimum investment of $200,000, investors receive membership 
interests redeemable after a defined period. Like SCI, many 
of the investments were 
made through self-directed IRAs. 
50. According to the LREH PPM, LREH makes real-estate investments, 
including underperforming mortgage notes and asset-back deed certificates secured 
by real property. Wealth Advisors was listed as LREH's investment adviser 
responsible for reviewing assets prior 
to acquisition. 
51. Unlike the SCI PPM, the LREH PPM explicitly identified Mata and 
Kayatta by name as key personnel, touting their respective 22 and 
25 years of 
experience in financial services. But the LREH PPM made no mention of Mata or 
Kayatta' s disciplinary history. 
52. As with SCI, Mata disseminated the LREH PPM, which indicated that 
the interests were exempt from registration pursuant to Rule 506 
of Regulation D of 
the Securities Act and were purportedly limited to accredited investors. Mata did not 
verify whether the potential investors were accredited investors. 
C. Defendants' Misuse and Misappropriation of Investor Funds 
53. Mata, Kayatta, Pincheira, and Wealth Advisors have engaged in 
additional fraudulent conduct 
by misusing and misappropriating investors' funds. 
1. Misuse of Funds 
54. Mata, Kayatta, and Wealth Advisors are misusing investor funds in 
several ways. They used $250,000 
of SCI investor money to make an equity 
investment in "ieCrowd," a crowdsource funding start -up where Kayatta is  a director. 
This investment was a direct violation 
of the use of proceeds promised in the SCI 
PPM, which stated that SCI would invest 
in real-estate related investments. 
55. Mata, Kayatta, and Wealth Advisors have also dissipated SCI money and 
assets by commingling them with LREH and other entities controlled by Mata. 
Although SCI and LREH have separate bank accounts, Mata directed that SCI 
investor funds be used to pay LREH expenses. Over 
$1 million of SCI investor 
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monies have gone to subsidize LREH's operations. As of early 2014, when LREH's 
accounting firm resigned, LREH had not repaid SCI for any 
of the money advanced 
to it. 
56. Mata, Kayatta, and Wealth Advisors also misuse investor money to 
subsidize other entities that Mata controls. Mata is a managing member or principal 
of several businesses that operate out of the same office space as defendants. These 
entities 
'.ire identified at paragraphs 22 through 29 above. SCI investor funds have 
been used 
to pay the rent and expenses of several of these businesses. For example, in 
2013 alone, defendants authorized roughly $25,000 
in payments to Lifetime University 
and over $120,000 combined in payments 
to Indestructible Peak Management, Inc., 
Renaissance Management, LLC, and World Gardens Cafe, LLC. The SCI PPM did 
not disclose that investor funds could be used for loans 
of any kind, and did not 
disclose that investor funds would be used to pay the expenses 
of other entities 
controlled by Mata. 
57. Mata, Kayatta, and Wealth Advisors have also encumbered or sold away 
Fund assets. For example, as recently 
as April2015, SCI claimed as an asset Superior 
Apartments, a four-unit apartment complex in Excelsior Springs, Missouri. But 
property records show that this property was sold 
to a third-party in a delinquent tax 
salein2014. 
58. Another example of asset dissipation is  a property known as "38th 
Street," a condominium complex located in Jacksonville, Florida. Mata and Kayatta 
touted the 38th Street property online and 
in marketing materials as a central 
component 
of SCI's portfolio. In an April2015 asset summary, SCI stated that 38th 
Street comprised over 17% of SCI's purported value. 
59. SCI purported to have acquired 
38th Street in November 2010, but since 
November 20 I 
0, title to 38th Street has been held by 9327 Fairway View Place, LLC 
("Fairway"), a separate entity controlled by Mata, which itself had several investors, 
some 
ofwhom have separate direct equity interests in 38th Street. There is no evidence 
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that the fact that an entity controlled by Mata owned 38th Street was ever disclosed to 
SCI investors. 
60. In addition, in February 2011, LREH acquired the mortgage note 
to 38th 
Street for $650,000. Because LREH had insufficient funds to purchase the note, SCI 
lent LREH the funds. Kayatta represented 
to LREH's former accounting firm that 38th 
Street was, in fact, an asset belonging to LREH rather than SCI, and Mata conceded to 
the accountant that LREH owned the "note" on the property. In April 20 
12, Mata 
described the situation to LREH' s accountant 
as follows: 
SCI has lent money to LREH to purchase a note from the bank that SCI owed 
on an apartment building in Flonda. So LREH owns the mortgage now, but 
SCI owes LREH $1,010,183.72. SCI is  in default because it  has notmtid 
LREH 
aJ:!Y mortgage payipents, after LREH bought the loan. But LREH still 
owes SCl, for the money it lent LREH to buy the mortgage (on the property 
that SCI owns). (HELP!). 
There is  no evidence that the fact that LREH held the mortgage on 38th Street, and 
that SCI lent funds to LREH to purchase that mortgage, was ever disclosed 
to SCI or 
LREH investors. 
61. Then, in June 2015, Mata caused Fairway to borrow $500,000 from a 
third-party. Mata then caused Fairway to grant that third-party a $500,000 mortgage in 
38th Street and assigned all 
ofthe rent and lease payments from the property as security 
for the loan. 
62. Finally, LREH purports to own two assets, Villager North, 
aka Justina 
Court, an apartment complex in Jacksonville, Missouri, and Superior Park Residential 
Care Facility, located in in Excelsior Springs, Missouri. But according 
to county 
property records, LREH is  not the title holder to either 
of these properties. In addition, 
LREH's accountant questioned the valuations defendants assigned 
to both properties. 
Moreover, SCI is also apparently also "invested" in both properties, which led Mata and 
Kayatta 
to seek LREH's accountant's opinion on whether the entities could serve as 
"co-owners." !d. Ex. 38. 
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2. Mata, Kayatta, and Pincheira's Misappropriation 
63. Mata, Kayatta, and Pincheira have also misappropriated monies invested 
in SCI for their personal use. 
64. Mata and Pincheira are the sole signatories 
to the SCI bank account 
where investor monies are deposited. 
65. Because Mata, Kayatta, and 
SCI had insufficient credit 
to open a business 
credit card account, Pincheira added Mata and Kayatta as authorized users on 
Pincheira' s personal American Express account. In return, Mata directed Pincheira 
to 
pay the card balances using SCI's funds. Mata did not set parameters for legitimate 
uses 
of the card, question any of the expenditures, or direct that SCI be reimbursed. 
66. Mata, Kayatta, and Pincheira use the American Express card for 
personal charges wholly unrelated to SCI business expenses. The personal charges 
include dinners, personal travel, entertainment, and cultural events. The personal 
charges also ranged from the extravagant (Pincheira's airplane tickets 
to Chile for 
$2,246.90) to the mundane (Mata's Netflix account charges). 
67. SCI Investor monies are used 
to pay the American Express balances that 
include the personal charges 
ofMata, Kayatta, and Pincheira. 
68. Between 2012 and 2014, Mata incurred at least $71,693.16 
in personal 
charges that were paid for with SCI investor funds. 
69. Between 2012 and 2014, Pincheira incurred at least $57,169.33 
in 
personal charges that were paid for with SCI investor funds. 
70. Between 2012 and 2014, Kayatta incurred at least $31,529.40 in personal 
charges that were paid for with SCI investor funds. 
71. In total, between 2012 and 2014, SCI investors paid for at least 
$160,391.89 
in personal charges incurred by Mata, Kayatta, ad Pincheira 
72. In fact, this total may understate the misappropriation as they only include 
charges Mata, Kayatta, and Pincheira themselves characterized as personal expenses. 
The underlying American Express records from this time frame reflect numerous other 
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charges that appear to have no relationship to the operation of SCI's business. 
73. In addition, Mata, Kayatta, and Pincheira also each received monthly 
payments from 
SCI 
in purported consulting fees. 
74. Since 2013, Kayatta has received payments ranging from $7,500 
to 
$8,500 per month for supposed consulting fees. 
75. Since 2013, Pincheira has received payments of$4,000 per month for 
supposed consulting fees. 
76. 
Since 2013, Mata has received sporadic payments as high 
as $25,000 for 
supposed consulting fees. 
D. Defendants' Fraudulent Lulling of Investors 
77. Mata, Kayatta, Wealth Advisors, and Lifetime University are lulling 
investors by claiming SCI is performing well in emails, oral communications, and 
account statements which give the impression that an investor's principal investment 
is safe, and that the investor's account continues to accrue at the "guaranteed" rate. 
78. In fact, SCI has not made a profit since at least 2011. SCI's bank 
records reflect that defendants are spending money 
as quickly as it comes in, and 
have not added any new revenue generating assets since 2013. Moreover, investors' 
requests to redeem out 
ofthe funds have been met with delay or unfulfilled. 
79. Mata, Kayatta, Wealth Advisors, and Lifetime University have also 
concealed from investors the concerns raised by the Funds' IRA custodian. 
80. Prior to resigning in July 2014, SCI and LREH's IRA custodian sent 
numerous emails regarding problems with accounts invested in the Funds, including 
insufficient balances and erratic account fluctuations. When investors asked why the 
IRA custodian had resigned, Mata fabricated reasons for the resignation. 
81. Mata and Kayatta also engaged 
in additional fraudulent conduct with 
respect 
to LREH by knowingly diluting the value of investments of the original LREH 
investors by allowing new investors after LREH's closing date of December 31, 2012. 
The accounts for six investors who had joined LREH prior to the closing date showed 
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dramatic reductions in the value of their investments exceeding tens ofthousands of 
dollars during the first quarter of 2013. 
82. Mata and Kayatta failed 
to obtain the consent of the early LREH investors 
to these late-added investments, despite being aware of the detrimental impact adding 
investors would have on the initial investors. Rather than prevent the dilution by 
adhering to the fund's closing date, Kayatta sought to manipulate the asset valuations 
to minimize the visibility ofthe impact on the initial investors. 
83. Both LREH's accountant and attorney questioned LREH management 
regarding the additional investors, yet Mata and Kayatta took no steps 
to remediate the 
problem or notify the affected investors. 
E. 	Mata, Kayatta, Wealth Advisors, and Lifetime University's 
Misrepresentations 
and Omissions 
84. Mata, Kayatta, Wealth Advisors, and Lifetime University have made 
numerous other materially false and misleading statements regarding the Funds 
to 
induce investments and to prevent investors from withdrawing their money. 
85. First, the SCI PPM falsely states that the Fund returns are "guaranteed." 
Specifically, it states that "[t]he yearly rate 
of return guaranteed under this Offering 
is  based on seven 
(7) year reinvestment plan with a minimum maturity date of 
twenty-four (24) months, and a cap rate of return of 10%." The SCI PPM also 
provides a chart titled "Guaranteed Rate 
ofReturn Schedule," that indicated a 
$200,000 investment was 
guaranteed to generate a balance of$339,269.30 after 7 
years. None 
of this was true. Investments in SCI have significant risk of loss. 
Further, Mata knew that he, Kayatta, SCI, and Wealth Advisors had been sanctioned 
by the State 
of Nevada in 2009 for touting SCI's guaranteed returns. 
86. Second, the SCI PPM omits material information regarding Mata and 
Kayatta's control over the Fund. The SCI PPM also omits Mata's disciplinary 
history. Finally, Mata failed 
to disclose his control over SCI or his disciplinary 
history in meetings with clients. 
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87. Third, although the LREH PPM discloses Mata and Kayatta's 
involvement in the Fund, and touted that "Paul [Mata]'s 22 years 
of experience as a 
Financial Advisor gives him a unique perspective and expertise," it does not disclose 
Mata or Kayatta's disciplinary history. 
88. Finally, Mata, Kayatta, Wealth Advisors, and Lifetime University are 
making misrepresentations regarding the use 
of SCI offering proceeds. The SCI PPM 
and SCI's online marketing materials state that the fund invests in real-estate related 
assets. The SCI PPM does not disclose that the investor money would be used 
to pay 
the expenses 
of other entities controlled by management or that SCI would invest in 
businesses unrelated 
to real estate, such as ieCrowd. 
89. Mata, Kayatta, Wealth Advisors, and Lifetime University's 
misrepresentations and omissions are material, as they are central 
to investors' 
decisions 
to invest, and to their decisions to keep their money invested in the Funds. 
90. Mata, Kayatta, Wealth Advisors, and Lifetime University knew, or were 
reckless or negligent in not knowing, that these misrepresentations and omissions 
were false and misleading when made. 
F. 	
Mata, Ka__yatta, SCI, and LREH Offered and Sold the Funds 
Without Registration or Exemption 
91. 
Mata, Kayatta, SCI, and LREH did not register with the SEC any of the 
transactions or securities they offered or sold for either Fund, and the offers and sales 
were not exempt from registration. 
92. The SCI PPM stated that it would be offered to no more than 
35 non-
qualified investors, but SCI's documents reflect that at least 40 actual investors were 
non-qualified. 
93. The LREH PPM also stated that it would be offered to 
no more than 35 
non-qualified investors, but defendants made no effort to verify that the investors 
were qualified. 
94. 	
In soliciting investors in the Funds, Mata completed investor suitability 
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questionnaires on the investors' behalf without their consent, failed to inquire 
regarding certain investors' financial condition or sophistication, and failed 
to 
maintain documentation of the investors' suitability. 
G. 	Mata, Wealth Advisors, and Lifetime Universicy Acted As 
Investment Advisers To Fraudulently 
Obtain Investments in the 
Funds 
95. Wealth Advisors, Lifetime University, and Mata acted as investment 
advisers to individuals who came to Mata to analyze their investment portfolios and 
make recommendations. Mata established an investment advisory relationship with 
these potential clients, then directed them to sell their existing securities holdings and 
reinvest in SCI or LREH using the misrepresentations detailed above. 
96. Mata founded Wealth Advisors to provide investment advisory services 
to clients after his termination from Ameriprise in April 2009. Mata solicited his 
former Ameriprise clients to transfer their accounts to Wealth Advisors, without 
disclosing the reasons for his termination. 
97. Soon after forming Wealth Advisors 
in April2009, Mata was disciplined 
by regulators including the Nevada Secretary of State, FINRA, the California 
Department 
of Business Oversight, and from professional organizations including the 
Certified Financial Planning Board. 
98. In early 2012, Wealth Advisors's counsel advised the firm that Mata 
could not continue 
to provide financial planning services for a fee without being 
registered. In response, Mata "sold" Wealth Advisors to his administrative assistant, 
while still retaining actual control 
of Wealth Advisors. Mata continued to provide 
investment advice to new and existing clients 
of Wealth Advisors, including 
providing advice about market trends and the merits 
of investing in securities, in 
particular 
of investing in SCI and LREH. 
99. After he 
"sold" Wealth Advisors to his administrative assistant, Mata 
founded Lifetime University, which also provides financial planning seminars and 
investment advisory services. Through Lifetime University, Mata obtained 
new 
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clients by offering investment seminars. Seminar attendees become Mata' s clients 
through subsequent one-on-one financial coaching services that he offers. 
100. When meeting with advisory clients, Mata obtains the clients' current 
holdings and prepares individualized portfolio analyses for them. Although the 
portfolio analyses recommend that clients invest in publically-traded securities, Mata 
instead diverts their money 
to SCI and LREH. Mata did not always disclose his 
control over SCI to his advisory clients at  Wealth Advisors or Lifetime University. 
101. Mata receives compensation for these unregistered investment advisory 
services in various ways. Clients pay Mata for financial planning packages ranging 
from $750 to $50,000 offered through Lifetime University. Mata also receives 
Wealth Advisors's client management fees. 
1 02. As set forth in detail above, in their capacity as investment advisers, Mata, 
Wealth Advisors, and Lifetime University make material misrepresentations regarding 
the Funds to clients who depended on them 
to allocate their portfolios and retirement 
savings. They mislead current and prospective clients by asserting that SCI offers 
guaranteed returns, misrepresent SCI's use 
ofproceeds, mislead clients about the 
profitability 
oftheir investment, and conceal Mata and Kayatta's connection to SCI and 
omit information about their disciplinary records. In addition, they have diverted client 
money to Mata, Kayatta and Pincheira and 
to other entities that Mata or Kayatta 
control. 
103. Mata, Wealth Advisors, and Lifetime University knew, or were reckless 
or negligent in not knowing, that their misrepresentations and omissions to their 
advisory clients were false and misleading when made. 
104. Mata, Wealth Advisors, and Lifetime University's misrepresentations 
and omissions were material, as they were central to investors' decisions to invest, 
and 
to their decisions to keep their moneys invested in the Funds. 
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FIRST CLAIM FOR RELIEF 

Unregistered Offer and Sale of Securities 

Violations 
of Section S(a) and (c) of the Securities Act 

(against Defendants Mata, Kayatta, SCI, 
and LREH) 

105. The SEC realleges and incorporates by reference paragraphs 1 through 
104 above. 
I 06. Defendants Mata, Kayatta, SCI, and LREH, 
by engaging in the conduct 
described above, directly or indirectly, singly and in concert with others, made use 
of 
the means or instruments of transportation or communication in interstate commerce, 
or ofthe mails, to offer to sell or to sell securities, or carried or caused to be carried 
through the mails or in interstate commerce, by means or instruments 
oftransportation, 
securities for the purpose 
ofsale or for delivery after sale. 
1 07. No registration statement had been filed or was in effect as to such 
securities, and no exemption from registration was applicable. 
108. 
By engaging in the conduct described above, Defendants Mata, Kayatta, 
SCI, and LREH, violated, and unless restrained and enjoined, will continue to violate, 
Section 5(a) and (c) 
ofthe Securities Act, 15 U.S.C. §§ 77e. 
SECOND CLAIM FOR RELIEF 

Fraud in the Offer or Sale of Securities 

Violations 
of Section 17(a)(l) and (3) of the Securities Act 

(against Defendants Mata, Kayatta, 
and Pincheira) 

109. The SEC realleges and incorporates by reference paragraphs 1 
through 1 04 above. 
110. Defendants Mata, Kayatta, and Pincheira, and each 
ofthem, by engaging 
in the conduct described above, directly or indirectly, in the offer or sale of securities 
by the use 
of means or instruments of transportation or communication in interstate 
commerce or by use 
of the mails: 
(a) with scienter, employed devices, schemes, 
or artifices to defraud; or 
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(b) engaged in transactions, practices, or courses ofbusiness which operated 
or would operate as a fraud or deceit upon the purchaser. 
111. By engaging in the conduct described above, Defendants violated, and 
unless 
restrain~d and enjoined, will continue to violate, Section 17(a)(1) and (3) of 
the Securities Act, 15 U.S.C. § 77q(a) (1) and (3). 
THIRD CLAIM FOR RELIEF 

Fraud in the Offer or Sale of Securities 

Violations 
of Section 17(a)(2) of the Securities Act 

(against Defendants 
Mata and Kayatta) 

112. The SEC realleges and incorporates by reference paragraphs 1 
through 1 
04 above. 
113. Defendants Mata and Kayatta, and each 
ofthem, by engaging in the 
conduct described above, directly or indirectly, in the offer or sale 
ofsecurities by the 
use 
of means or instruments oftransportation or communication in interstate 
commerce or by use 
of the mails, to obtain money or property by means of any untrue 
statement 
of a material fact necessary in order to make the statements made, in light 
ofthe circumstances under which they were made, not misleading. 
114. By engaging in the conduct described above, Defendants Mata and 
Kayatta violated, and unless restrained and enjoined, will continue to violate, 
Section 17(a)(2) 
of the Securities Act, 15 U.S.C. § 77q(a)(2). 
FOURTH CLAIM FOR RELIEF 

Fraud in Connection with the Purchase or Sale of Securities 

Violations 
of Section 1 O(b) of the Exchange Act 

and Rules 10b-5(a) and (c) thereunder 

(against Defendants Mata, Kayatta, and Pincheira) 

115. The SEC realleges and incorporates by reference paragraphs 1 through 
104 above. 
116. Defendants Mata, Kayatta, and Pincheira, by engaging 
in the conduct 
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described above, directly or indirectly, in connection with the purchase or sale ofa 
security, 
by the use of means or instrumentalities or interstate commerce, ofthe 
mails, 
or ofthe facilities ofa national securities exchange, with scienter: 
(a) employed devices, schemes, 
or artifices to defraud; or 
(b) engaged in acts, practices or courses 
ofbusiness which operated or 
would operate as a fraud 
or deceit upon other persons. 
117. 
By engaging in the conduct described above, Defendants violated, and 
unless restrained and enjoined, will continue to violate, Section 1 
O(b) ofthe 
Exchange Act, 
15 U.S.C. § 78j(b), and Rule 10b-5(a) and (c) thereunder, 17 C.F.R. 
§ 240.10b-5(a) and (c). 
FIFTH CLAIM FOR RELIEF 

Fraud in Connection with the Purchase or Sale of Securities 

Violations 
of Section 1 O(b) of the Exchange Act and Rules lOb-S(b) thereunder 

(against Defendants Mata 
and Kayatta) 

118. The SEC realleges and incorporates by reference paragraphs 1 
through 1 04 above. 
119. Defendants 
Mata and Kayatta, by engaging in the conduct described 
above, directly 
or indirectly, in connection with the purchase or sale of a security, by 
the use ofmeans or instrumentalities or interstate commerce, ofthe mails, or ofthe 
facilities 
of a national securities exchange, with scienter made untrue statements ofa 
material fact 
or omitted to state a material fact necessary in order to make the 
statements made, in the light 
ofthe circumstances under which they were made, not 
misleading. 
120. 
By engaging in the conduct described above, Defendants Mata and 
Kayatta violated, and unless restrained and enjoined, will continue to violate, 
Section 10(b) 
of the Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5(b) thereunder, 
17 C.P.R.§ 240.10b-5(b). 
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SIXTH CLAIM FOR RELIEF 
Prohibited Transactions by Investment Advisers 

Violation 
of Section 206(1) and (2) 

(against Defendants 
Mata, Wealth Advisors, and Lifetime University) 

121. The SEC realleges and incorporates by reference paragraphs 1 
through 1 04 above. 
122. Defendants Mata, Wealth Advisors, and Lifetime University, 
by 
engaging in the conduct described above, while acting as an investment adviser, by 
use 
of means or instrumentalities of interstate commerce, directly or indirectly: 
(a) employed a device, scheme, or artifice 
to defraud a client or 
prospective client; or 
(b) engaged in a transaction, practice, or course 
ofbusiness, which 
operates 
as a fraud or deceit upon a client or prospective client. 
123. By engaging in the conduct described above, Defendants Mata, Wealth 
Advisors, and Lifetime University violated, and unless restrained and enjoined, will 
continue to violate, Section 206(1) and (2) 
of the Advisers Act, 15 U.S.C. § 80b-6(1) 
& (2). 
PRAYER FOR RELIEF 

WHEREFORE, the SEC respectfully requests that the Court: 

I. 
Issue findings of fact and conclusions of law that Defendants committed the 
alleged violations. 
II. 
Issue orders, in a form consistent with Fed. 
R. Civ. P. 65(d), temporarily, 
preliminarily, and permanently enjoining Defendants Mata, Kayatta, SCI, and 
LREH, 
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 5, 15 
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U.S.C. §§ 77e, ofthe Securities Act. 
III. 
Issue orders, in a  form consistent with Fed. R. Civ. P. 65(d), temporarily, 
preliminarily, and permanently enjoining Defendants Mata, Kayatta, and Pincheira, 
and their agents, servants, employees, and attorneys, and those persons in active 
concert 
or participation with any of them, who receive actual notice ofthe judgment 
by personal service or otherwise, and each 
of them, from violating Section 17(a) of 
the Securities Act, 15 U.S.C. §§ 77e(a), and Section lO(b) of the Exchange Act, 15 
U.S.C. § 78j(b ), and Rule 1Ob-5 thereunder, 17 C.F.R. §§ 240. i Ob-5. 
IV. 
Issue orders, in a form consistent with Fed. R. Civ. P. 65(d), temporarily, 
preliminarily, and permanently enjoining Defendants Mata, Wealth Advisors, and 
Lifetime University and their agents, servants, employees, and attorneys, and those 
persons in active concert 
or participation with any ofthem, who receive actual notice 
of the judgment by personal service or otherwise, and each ofthem, from violating 
Sections 206(1), 206(2), 
ofthe Advisers Act, 15 U.S.C. §§ 80b-6(1), (2). 
v. 
Issue orders, in a form consistent with Fed. R. Civ. P. 65(d), temporarily, 
preliminarily, and permanently enjoining Defendants Mata, Kayatta, and Pincheira 
and their agents, servants, employees, and attorneys, and those persons in active 
concert 
or participation with any ofthem, who receive actual notice ofthe judgment 
by personal service 
or otherwise, and each ofthem, from soliciting, accepting, or 
depositing any monies from actual or prospective investors in connection with any 
offering 
of securities pursuant to Section 20(b) ofthe Securities Act and 
Section 
21 (d) ofthe Exchange Act; provided, however, that such injunction shall not 
prevent Defendants Mata, Kayatta, and Pincheira from purchasing or selling 
securities listed on a national securities exchange for their own personal accounts. 
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VI. 
Issue in a form consistent with Fed. 
R. Civ. P. 65, a temporary restraining order 
and a preliminary injunction freezing the assets of each of the Defendants; prohibiting 
each 
of the Defendants from destroying documents; ordering expedited discovery; 
ordering accountings by each 
of the Defendants; and appointing a receiver over 
Defendants SCI, 
LREH, Wealth Advisors, and Lifetime University, and any entities 
controlled by them or by Defendants Mata, Kayatta, or 
Pincheira. 
VII. 
Order Defendants to disgorge all ill-gotten gains from their illegal conduct, 
together with prejudgment interest thereon. 
VIII. 
Order Defendants to pay civil penalties under Section 20( d) of the Securities 
Act, 
15 U.S.C. § 77t(d); Section 2l(d)(3) ofthe Exchange Act, 15 U.S.C. § 78u(d)(3); 
and Section 209(e) 
ofthe Advisers Act, 15 U.S.C. §80b-9{e). 
IX. 
Retain jurisdiction ofthis action in accordance with the principles of equity and 
the Federal Rules 
ofCivil 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 
I 
motion for additional relief within the jurisdiction of this Court. 
X. 
Grant such other and further relief as this Court may determine to be just and 
necessary. 
Dated: September 2, 2015 
pectfully submitted, 
ltfAJLQ-GL-_ 
n M. Dean 
Attorneys for Plaintiff 
Securities and Exchange Commission 
24 

p.6 Sep 02 2015 1:56PM PIP Printing Riverside 9516821619 
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L~ M. DEAN, Cal. Bar No. 205562 ~ i") 1ua \\. 01 
Emml: deanllalsec~v ·!11~ St.r -" 1\fl • 

BRENT W. WILNER, Cal. Bar No. ~30093 ,. T couRT 
Email: [email protected] ·... CLtR~·~~t: %\~1~61 c,\LW. 

. . CEK RlVE.RS\0,;. 
Attorneys for Plcunttff 
Securities and Exchange CommissiollY:- ---~-----· 
Michele Wein Layne1 Re_gional Director 
Lorraine B. Echavama, Associate Regional Director 
John W. Berryl,Regional Trial Counsel 
444 S. Flower ~treet, Suite 900 
Los Angeles, California 90071 
TelephQne: (323) 965-3998 
Facsumle: {213) 443-1904 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

---~__........_._,cvt5-01792 \J~? 

SECURITIES AND EXCHANGE Case No. 
COMMISSION, 

Plaintiff, COMPLAINT 

vs. 

PAUL MATA'rpAV1D KAYATTA, 

~~L~~EJMt:~'§Uff8.
LOGOS REAL ESTATE HOLDINGS, 
LLC. LOGOSWEALTH 
ADViSORS INC. LIFETIME 
ENTERPRI~~~~LC (dba LOGOS 
LIFETIME u1~~ vERSITY), 

Defendants. 

mailto:[email protected]


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Plaintiff Securities and Exchange Commission (the "SEC") alleges as follows: 

JURISDICTION AND VENUE 

1. This 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){l) and 77v(a); Sections 21(d){l), 21(d)(3)(A), 21(e) and 27 ofthe 

Securities Exchange Act of 1934 ("Exchange Act"), 15 U .S.C. § § 78u( d)( 1), 

78u(d)(3)(A), 78u(e), and 78aa; and Sections 209(d)-(e) and 214 of the Investment 

Advisers Act of 1940 ("Advisers Act"), 15 U.S.C. §§ 80b-9(d)-(e) and 80b-14. 

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

instrumentalities of interstate commerce or of the mails, 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); Section 27 of the Exchange Act, 15 U.S.C. § 78aa; and 

Section 214 of the Advisers Act, 15 U.S.C. § 80b-14, because certain of the 

transactions, acts, practices and courses of conduct constituting violations of the 

federal securities laws occurred within this district. In addition, venue is proper in 

this district because all of the defendants reside in this district. 

SU~RY 

4. This is an action to halt an ongoing offering fraud orchestrated by 

defendant Paul Ricky Mata, a former registered investment adviser with an extensive 

disciplinary history. Undeterred by his termination from Ameriprise Financial and 

disciplinary suspensions, Mata formed two unregistered advisory firms, Logos 

Wealth Advisors, Inc. ("Wealth Advisors") and Lifetime Enterprises, Inc., dba Logos 

Lifetime University ("Lifetime University"), and together with David Kayatta 

("Kayatta") and Mario Pincheira ("Pincheira") defrauded investors. 

5. From 2008 through the present, defendants raised over $14 million from 

over 100 investors from California and several other states, by soliciting investments 

in two unregistered funds Mata controlled, defendant Secured Capital Investments, 

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LLC ("SCI") and defendant Logos Real Estate Holdings, LLC ("LREH") 

(collectively, the "Funds"). 

6. Mata, Kayatta, Wealth Advisors, and Lifetime University are actively 

soliciting investments in SCI and LREH. They have induced investors, many of them 

retirees, into selling their existing securities holdings and investing in the Funds, 

using online videos, investment seminars promising "Indestructible Wealth," and 

presentations to church groups promising "Finances God's Way." Mata, Kayatta, 

Wealth Advisors, and Lifetime University induced investors by falsely promising 

"guaranteed" returns, misrepresenting SCI's use of proceeds, and failing to disclose 

Mata's disciplinary history and his control of SCI to his advisory clients. 

7. Mata, Kayatta, Wealth Advisors, and Lifetime University are defrauding 

investors by misusing investor funds, transferring money from SCI to other 

businesses controlled by Mata, and otherwise dissipating Fund assets. They are 

lulling investors into keeping their money with the Funds by touting their success, 

despite the fact that the Funds' have not made a profit. They have also lied to 

investors who expressed concern about the withdrawal of the Funds' IRA custodian. 

Mata and Kayatta engaged in further fraudulent conduct by allowing new investors to 

invest in LREH after the fund's closing date despite knowing that doing so would 

dilute the accounts of original investors. 

8. In addition, Mata, Kayatta, and Pincheira are misappropriating investor 

money for their personal use by incurring personal expenses on Pincheira' s personal 

American Express account and paying off the balances with SCI investor funds. 

9. Finally, the offer and sale of investments in SCI and LREH has never 

been registered with the SEC, as is required under the registration provisions of the 

federal securities laws. 

10. By engaging in this conduct, Mata, Kayatta, and Pincheira violated, and 

unless enjoined, will continue to violate the antifraud provisions of the federal 

securities laws, and Mata, Wealth Advisors, and Lifetime University has violated, 

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and unless enjoined, will continue to violate the provisions prohibiting fraud by an 

investment adviser. In addition, all of the defendants have violated, and unless 

enjoined, will continue to violate, the registration provisions of the federal securities 

laws. Therefore, with this action, the SEC seeks emergency relief against defendants, 

including a temporary restraining order, an asset freeze, accountings, expedited 

discovery, an order prohibiting the destruction of documents, and the appointment of 

a receiver over the entity defendants and other entities Mata controls. The SEC also 

seeks preliminary and permanent injunctions, disgorgement with prejudgment interest 

and civil penalties against defendants, and a conduct-based injunction as to Mata, 

Kayatta, and Pincheira prohibiting them from selling securities to investors or raising 

funds from investors for any entity they control. 

THE DEFENDANTS 

11. Paul Ricky Mata is a resident ofUpland, California. Mata is the 

founder and manager of SCI and LREH. 

12. From August 1988 until his termination in March 2009, Mata was the 

registered principal and supervisor for an independent contractor investment advisory 

branch office of Ameriprise Financial. Ameriprise terminated Mata for violating 

company policies by selling away, recommending that clients take out risky loans to 

finance investments, presenting unapproved seminars, employing individuals without 

conducting proper background checks, and operating SCI as a competing investment 

company. Thereafter, Mata formed Wealth Advisors, where he served as principal 

and investment adviser representative. 

13. On July 30, 2010, the Nevada Secretary of State obtained a cease-and­

desist order against Mata, Kayatta, SCI, and Wealth Advisors for soliciting 

investment in an unregistered security and engaging in unlicensed investment 

advising. On March 22, 2011, FINRA suspended Mata from association with any 

member firm for one-year and fined him $10,000, citing Mata's misconduct at 

Ameriprise. Mata also was suspended in 2014 for five months by California 

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Department of Business Oversight based on FINRA's suspension. Mata previously 

held Series 7, 9, 10, 24, and 63 securities licenses, which expired in 2012. 

14. Despite his suspensions and the lapse of his licenses, Mata continues to 

serve as the adviser for Wealth Advisors' clients. 

15. In addition, Mata founded Lifetime University, which also provides 

financial planning seminars and investment advisory services. 

16. David Francis Kayatta is a resident of Claremont, California. Kayatta 

worked under Mata at Ameriprise until July 2007. In December 2009, Kayattajoined 

Mata at Wealth Advisors and currently serves as the fund manager for SCI and 

LREH. In 2010, Kayatta was ordered by the Nevada Secretary of State to cease-and­

desist from soliciting Nevada investors in unregistered securities and from engaging 

in unlicensed investment advisory conduct. Kayatta previously held Series 7, 65, and 

66 securities licenses. 

17. Mario Pincheira is a resident of Alta Lorna, California. Pincheira is 

designated as SCI's director of client relations and property manager, with 

responsibilities for overseeing the fund's residential and commercial holdings. 

Pincheira was Wealth Advisors's director of client relations until Mata sold Wealth 

Advisors, and Pincheira also signed documents as Wealth Advisors's corporate 

secretary. Pincheira is a co-signatory, along with Mata, to SCI's primary bank 

account and several affiliated accounts. Pincheira has never held any securities 

licenses or registrations. 

18. Secured Capital Investments, LLC is a Nevada LLC headquartered in 

Rancho Cucamonga, California formed in 2008 and controlled by Mata. Neither SCI, 

nor any of its securities, have been registered with the Commission. SCI's operative 

private placement memorandum dated 1anuary 201 0 ("SCI PPM") describes SCI as a 

private equity fund. SCI was ordered by the Nevada Secretary of State to cease-and­

desist from soliciting Nevada investors to invest in unregistered securities. 

19. Logos Real Estate Holdings, LLC is a California LLC headquartered in 

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Rancho Cucamonga, California formed in 2010, also managed by Mata and Kayatta 

through their entity Logos Management Group, LLC. Neither LREH nor any of its 

securities are registered with the Commission. LREH's operative private placement 

memorandum dated August 2011 ("LREH PPM") describes LREH as a private 

investment fund. In addition to Mata controlling both SCI and LREH, there is 

extensive overlap between these two entities: SCI and LREH share common assets, 

and LREH has received loans and expense payments from SCI. 

20. Logos Wealth Advisors, Inc. is a California corporation headquartered 

in Rancho Cucamonga, California and was formed by Mata as a California registered 

investment adviser in 2009. Mata transferred Wealth Advisors to his administrative 

. 	 assistant in March 2012, but continued to exert control over the firm up to and 

following the administrative assistant's departure from the firm in February 2015. 

Wealth Advisors is listed in numerous documents as investment adviser or sponsor 

for SCI and LREH. 

21. Logos Lifetime Enterprises, LLC (dba "Logos Lifetime University") 

is a Nevada LLC founded and managed by Mata, which offers wealth management 

educational seminars and investment advisory services for fees ranging from several 

hundred to tens of thousands of dollars. 

OTHER RELEVANT ENTITIES 

22. Indestructible Peak Management, Inc. is a California corporation 

headquartered in Rancho Cucamonga, California. It was formed in 2002 and 

provides staffing and administrative support to certain Mata entities. Mata is its sole 

owner and President, and has caused money to be transferred to it from SCI. 

23. Renaissance Management, LLC is a Nevada LLC headquartered in 

Rancho Cucamonga, California. It was fanned in 2007. Mata has been its managing 

member from inception and has caused money to be transferred to it from SCI. 

24. 9327 Fairway View Place, LLC is a California LLC headquartered in 

Rancho Cucamonga, California. It was fanned in 2010 and until June 2015 held the 

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title to 38th Street, despite Defendants' representations to investors that 38th Street 

was owned by SCI. Mata has been its managing member since inception. 

25. Logos Management Group, LLC is a California LLC headquartered in 

Rancho Cucamonga, California. It was formed in 2010 and manages defendant 

LREH. Mata has been its managing member since inception, and has caused money 

to be transferred to it from LREH. 

26. Logos Insurance Group, Inc. is a Nevada corporation headquartered in 

Rancho Cucamonga, California. It was formed in 2010. Mata was its President 

from 2010 to May 2012, and he owns 100% of the company. 

27. World Gardens Cafe, LLC is a Nevada LLC headquartered in Rancho 

Cucamonga, California. It was formed in 20 11 as a mail order food delivery service. 

Mata's owns 70% of the company and has been its managing member since inception 

and has caused money to be transferred to it from SCI. 

28. ChefRavi's Recipes, LLC is a Nevada LLC headquartered in Rancho 

Cucamonga, California. It was formed in 2011 as a supplier for World Gardens Cafe. 

Mata owns 49% of the company and has been its managing member since inception 

and has caused money to be transferred to it from SCI. 

29. Destiny With a Purpose, LLC is a Nevada LLC headquartered in 

Rancho Cucamonga, California. It was formed in 20 11 to invest in second trust 

deeds. Mata has been its managing member since inception. SCI has an ownership 

interest in Destiny With A Purpose, LLC. 

THEFRAUDULENTSCHEME 

30. Since at least 2008 through the present, Defendants have raised 

roughly $14.5 million from approximately 102 United States investors through 

unregistered securities offerings of two private investment funds, SCI and LREH. 

Defendants' solicitations of investors for SCI are ongoing. 

A. The SCI Offering 

31. Mata formed SCI in 2008, while working for Ameriprise, and 

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subsequently hired Kayatta as the fund's manager and Pincheira as the fund's 

property manager. 

32. Wealth Advisors is the investment advisory firm or sponsor for SCI. 

Through Mata, it provides investment advice to SCI. 

33. Wealth Advisors and Lifetime University, through Mata, provide 

investment adviser services to investors who invested in SCI. Both firms also direct 

clients to invest in SCI. 

34. Between 2008 and the present, approximately 90 investors invested 

approximately $12.5 million in SCI. 

35. According to the SCI PPM, SCI is "a private equity firm that allows 

qualified investors to invest. ..." The PPM also states that the Fund was a "real estate 

investing program," and investing in "government backed tax liens," "asset backed 

deed certificates," and "distressed commercial and residential properties." 

36. For a minimum investment of $200,000, investors purportedly receive 

two promissory notes paying a 5% annual return and maturing in two years. The SCI 

PPM further represents that the annual return is "guaranteed" based on a seven-year 

reinvestment plan with the rate of return capped at 1 0%, and with principal repaid at 

maturity. 

37. The SCI PPM claimed exemption from registration pursuant to Rule 506 

of Regulation D of the Securities Act. The SCI PPM further indicated that the notes 

could be sold to no more than 35 non-qualified investors, yet at least 40 appear to 

have been issued to non-qualified investors. 

38. Mata directly solicits investments in SCI during meetings with his 

advisory clients, during which he performs analyses of their portfolios and then 

directs the clients to sell their existing securities holdings and invest in the Funds. He 

also attracted investors by using online videos, seminars, and church presentations. 

39. Mata disseminated the SCI PPM, promissory note agreements, and 

investor suitability questionnaires to prospective investors. Certain subscription 

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agreements were returned with incomplete investor suitability forms, and some 

investors did not complete the investor suitability questionnaires attributed to them at 

all. Mata relied on his purported familiarity with the clients to conclude they were 

qualified investors, rather than verifying their net worth. 

40. Defendants' solicitations for SCI are ongoing. 

41. SCI maintains an online presence where defendants solicit investors for 

the Fund, including a website and a Y ouTube channel on which Kayatta appears 

touting the SCI Fund. 

42. Mata and Kayatta appeared at a three-day seminar in Los Angeles, 

California in May 2015 called "Indestructible Wealth Bootcamp," where they 

solicited investors. 

43. A website managed by Mata advertises that he plans to offer another 

three-day "Indestructible Wealth Bootcamp" seminar in Los Angeles California on 

October 2-4, 2015. 

44. Kayatta participates in the Mata-led investment seminars, where Mata 

introduces him as the Funds' manager. Kayatta is also identified in the LREH PPM 

as that Fund's manager. 

45. Pincheira also participates in the Mata-led investment seminars, where 

Mata introduces him as the SCI's property manager. 

B. The LREH Offering 

46. In August 2010, Mata and Kayatta, through Logos Management Group, 

LLC, formed LREH as a private investment fund providing investors a variable 

return. 

47. Wealth Advisors and Lifetime University, through Mata, provide 

investment adviser services to investors who invested in LREH. Both firms also 

directed clients to invest in LREH. 

48. From 2011 through at least 2013, 12 investors invested approximately $2 

million in LREH. 

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49. For a minimum investment of $200,000, investors receive membership 

interests redeemable after a defined period. Like SCI, many of the investments were 

made through self-directed IRAs. 

50. According to the LREH PPM, LREH makes real-estate investments, 

including underperforming mortgage notes and asset-back deed certificates secured 

by real property. Wealth Advisors was listed as LREH's investment adviser 

responsible for reviewing assets prior to acquisition. 

51. Unlike the SCI PPM, the LREH PPM explicitly identified Mata and 

Kayatta by name as key personnel, touting their respective 22 and 25 years of 

experience in financial services. But the LREH PPM made no mention of Mata or 

Kayatta' s disciplinary history. 

52. As with SCI, Mata disseminated the LREH PPM, which indicated that 

the interests were exempt from registration pursuant to Rule 506 of Regulation D of 

the Securities Act and were purportedly limited to accredited investors. Mata did not 

verify whether the potential investors were accredited investors. 

C. Defendants' Misuse and Misappropriation of Investor Funds 

53. Mata, Kayatta, Pincheira, and Wealth Advisors have engaged in 

additional fraudulent conduct by misusing and misappropriating investors' funds. 

1. Misuse of Funds 

54. Mata, Kayatta, and Wealth Advisors are misusing investor funds in 

several ways. They used $250,000 of SCI investor money to make an equity 

investment in "ieCrowd," a crowdsource funding start -up where Kayatta is a director. 

This investment was a direct violation of the use of proceeds promised in the SCI 

PPM, which stated that SCI would invest in real-estate related investments. 

55. Mata, Kayatta, and Wealth Advisors have also dissipated SCI money and 

assets by commingling them with LREH and other entities controlled by Mata. 

Although SCI and LREH have separate bank accounts, Mata directed that SCI 

investor funds be used to pay LREH expenses. Over $1 million of SCI investor 

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monies have gone to subsidize LREH's operations. As of early 2014, when LREH's 

accounting firm resigned, LREH had not repaid SCI for any of the money advanced 

to it. 

56. Mata, Kayatta, and Wealth Advisors also misuse investor money to 

subsidize other entities that Mata controls. Mata is a managing member or principal 

of several businesses that operate out of the same office space as defendants. These 

entities '.ire identified at paragraphs 22 through 29 above. SCI investor funds have 

been used to pay the rent and expenses of several of these businesses. For example, in 

2013 alone, defendants authorized roughly $25,000 in payments to Lifetime University 

and over $120,000 combined in payments to Indestructible Peak Management, Inc., 

Renaissance Management, LLC, and World Gardens Cafe, LLC. The SCI PPM did 

not disclose that investor funds could be used for loans of any kind, and did not 

disclose that investor funds would be used to pay the expenses of other entities 

controlled by Mata. 

57. Mata, Kayatta, and Wealth Advisors have also encumbered or sold away 

Fund assets. For example, as recently as April2015, SCI claimed as an asset Superior 

Apartments, a four-unit apartment complex in Excelsior Springs, Missouri. But 

property records show that this property was sold to a third-party in a delinquent tax 

salein2014. 

58. Another example of asset dissipation is a property known as "38th 

Street," a condominium complex located in Jacksonville, Florida. Mata and Kayatta 

touted the 38th Street property online and in marketing materials as a central 

component of SCI's portfolio. In an April2015 asset summary, SCI stated that 38th 

Street comprised over 17% of SCI's purported value. 

59. SCI purported to have acquired 38th Street in November 2010, but since 

November 20 I 0, title to 38th Street has been held by 9327 Fairway View Place, LLC 

("Fairway"), a separate entity controlled by Mata, which itself had several investors, 

some ofwhom have separate direct equity interests in 38th Street. There is no evidence 

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that the fact that an entity controlled by Mata owned 38th Street was ever disclosed to 

SCI investors. 

60. In addition, in February 2011, LREH acquired the mortgage note to 38th 

Street for $650,000. Because LREH had insufficient funds to purchase the note, SCI 

lent LREH the funds. Kayatta represented to LREH's former accounting firm that 38th 

Street was, in fact, an asset belonging to LREH rather than SCI, and Mata conceded to 

the accountant that LREH owned the "note" on the property. In April 20 12, Mata 

described the situation to LREH' s accountant as follows: 

SCI has lent money to LREH to purchase a note from the bank that SCI owed 
on an apartment building in Flonda. So LREH owns the mortgage now, but 
SCI owes LREH $1,010,183.72. SCI is in default because it has notmtid 
LREH aJ:!Y mortgage payipents, after LREH bought the loan. But LREH still 
owes SCl, for the money it lent LREH to buy the mortgage (on the property 
that SCI owns). (HELP!). 

There is no evidence that the fact that LREH held the mortgage on 38th Street, and 

that SCI lent funds to LREH to purchase that mortgage, was ever disclosed to SCI or 

LREH investors. 

61. Then, in June 2015, Mata caused Fairway to borrow $500,000 from a 

third-party. Mata then caused Fairway to grant that third-party a $500,000 mortgage in 

38th Street and assigned all of the rent and lease payments from the property as security 

for the loan. 

62. Finally, LREH purports to own two assets, Villager North, aka Justina 

Court, an apartment complex in Jacksonville, Missouri, and Superior Park Residential 

Care Facility, located in in Excelsior Springs, Missouri. But according to county 

property records, LREH is not the title holder to either of these properties. In addition, 

LREH's accountant questioned the valuations defendants assigned to both properties. 

Moreover, SCI is also apparently also "invested" in both properties, which led Mata and 

Kayatta to seek LREH's accountant's opinion on whether the entities could serve as 

"co-owners." !d. Ex. 38. 

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2. Mata, Kayatta, and Pincheira's Misappropriation 

63. Mata, Kayatta, and Pincheira have also misappropriated monies invested 

in SCI for their personal use. 

64. Mata and Pincheira are the sole signatories to the SCI bank account 

where investor monies are deposited. 

65. Because Mata, Kayatta, and SCI had insufficient credit to open a business 

credit card account, Pincheira added Mata and Kayatta as authorized users on 

Pincheira' s personal American Express account. In return, Mata directed Pincheira to 

pay the card balances using SCI's funds. Mata did not set parameters for legitimate 

uses of the card, question any of the expenditures, or direct that SCI be reimbursed. 

66. Mata, Kayatta, and Pincheira use the American Express card for 

personal charges wholly unrelated to SCI business expenses. The personal charges 

include dinners, personal travel, entertainment, and cultural events. The personal 

charges also ranged from the extravagant (Pincheira's airplane tickets to Chile for 

$2,246.90) to the mundane (Mata's Netflix account charges). 

67. SCI Investor monies are used to pay the American Express balances that 

include the personal charges ofMata, Kayatta, and Pincheira. 

68. Between 2012 and 2014, Mata incurred at least $71,693.16 in personal 

charges that were paid for with SCI investor funds. 

69. Between 2012 and 2014, Pincheira incurred at least $57,169.33 in 

personal charges that were paid for with SCI investor funds. 

70. Between 2012 and 2014, Kayatta incurred at least $31,529.40 in personal 

charges that were paid for with SCI investor funds. 

71. In total, between 2012 and 2014, SCI investors paid for at least 

$160,391.89 in personal charges incurred by Mata, Kayatta, ad Pincheira 

72. In fact, this total may understate the misappropriation as they only include 

charges Mata, Kayatta, and Pincheira themselves characterized as personal expenses. 

The underlying American Express records from this time frame reflect numerous other 

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charges that appear to have no relationship to the operation of SCI's business. 

73. In addition, Mata, Kayatta, and Pincheira also each received monthly 

payments from SCI in purported consulting fees. 

74. Since 2013, Kayatta has received payments ranging from $7,500 to 

$8,500 per month for supposed consulting fees. 

75. Since 2013, Pincheira has received payments of$4,000 per month for 

supposed consulting fees. 

76. Since 2013, Mata has received sporadic payments as high as $25,000 for 

supposed consulting fees. 

D. Defendants' Fraudulent Lulling of Investors 

77. Mata, Kayatta, Wealth Advisors, and Lifetime University are lulling 

investors by claiming SCI is performing well in emails, oral communications, and 

account statements which give the impression that an investor's principal investment 

is safe, and that the investor's account continues to accrue at the "guaranteed" rate. 

78. In fact, SCI has not made a profit since at least 2011. SCI's bank 

records reflect that defendants are spending money as quickly as it comes in, and 

have not added any new revenue generating assets since 2013. Moreover, investors' 

requests to redeem out of the funds have been met with delay or unfulfilled. 

79. Mata, Kayatta, Wealth Advisors, and Lifetime University have also 

concealed from investors the concerns raised by the Funds' IRA custodian. 

80. Prior to resigning in July 2014, SCI and LREH's IRA custodian sent 

numerous emails regarding problems with accounts invested in the Funds, including 

insufficient balances and erratic account fluctuations. When investors asked why the 

IRA custodian had resigned, Mata fabricated reasons for the resignation. 

81. Mata and Kayatta also engaged in additional fraudulent conduct with 

respect to LREH by knowingly diluting the value of investments of the original LREH 

investors by allowing new investors after LREH's closing date of December 31, 2012. 

The accounts for six investors who had joined LREH prior to the closing date showed 

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dramatic reductions in the value of their investments exceeding tens of thousands of 

dollars during the first quarter of 2013. 

82. Mata and Kayatta failed to obtain the consent of the early LREH investors 

to these late-added investments, despite being aware of the detrimental impact adding 

investors would have on the initial investors. Rather than prevent the dilution by 

adhering to the fund's closing date, Kayatta sought to manipulate the asset valuations 

to minimize the visibility of the impact on the initial investors. 

83. Both LREH's accountant and attorney questioned LREH management 

regarding the additional investors, yet Mata and Kayatta took no steps to remediate the 

problem or notify the affected investors. 

E. 	 Mata, Kayatta, Wealth Advisors, and Lifetime University's 
Misrepresentations and Omissions 

84. Mata, Kayatta, Wealth Advisors, and Lifetime University have made 

numerous other materially false and misleading statements regarding the Funds to 

induce investments and to prevent investors from withdrawing their money. 

85. First, the SCI PPM falsely states that the Fund returns are "guaranteed." 

Specifically, it states that "[t]he yearly rate of return guaranteed under this Offering 

is based on seven (7) year reinvestment plan with a minimum maturity date of 

twenty-four (24) months, and a cap rate of return of 10%." The SCI PPM also 

provides a chart titled "Guaranteed Rate ofReturn Schedule," that indicated a 

$200,000 investment was guaranteed to generate a balance of$339,269.30 after 7 

years. None of this was true. Investments in SCI have significant risk of loss. 

Further, Mata knew that he, Kayatta, SCI, and Wealth Advisors had been sanctioned 

by the State of Nevada in 2009 for touting SCI's guaranteed returns. 

86. Second, the SCI PPM omits material information regarding Mata and 

Kayatta's control over the Fund. The SCI PPM also omits Mata's disciplinary 

history. Finally, Mata failed to disclose his control over SCI or his disciplinary 

history in meetings with clients. 

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87. Third, although the LREH PPM discloses Mata and Kayatta's 

involvement in the Fund, and touted that "Paul [Mata]'s 22 years of experience as a 

Financial Advisor gives him a unique perspective and expertise," it does not disclose 

Mata or Kayatta's disciplinary history. 

88. Finally, Mata, Kayatta, Wealth Advisors, and Lifetime University are 

making misrepresentations regarding the use of SCI offering proceeds. The SCI PPM 

and SCI's online marketing materials state that the fund invests in real-estate related 

assets. The SCI PPM does not disclose that the investor money would be used to pay 

the expenses of other entities controlled by management or that SCI would invest in 

businesses unrelated to real estate, such as ieCrowd. 

89. Mata, Kayatta, Wealth Advisors, and Lifetime University's 

misrepresentations and omissions are material, as they are central to investors' 

decisions to invest, and to their decisions to keep their money invested in the Funds. 

90. Mata, Kayatta, Wealth Advisors, and Lifetime University knew, or were 

reckless or negligent in not knowing, that these misrepresentations and omissions 

were false and misleading when made. 

F. 	 Mata, Ka__yatta, SCI, and LREH Offered and Sold the Funds 
Without Registration or Exemption 

91. Mata, Kayatta, SCI, and LREH did not register with the SEC any of the 

transactions or securities they offered or sold for either Fund, and the offers and sales 

were not exempt from registration. 

92. The SCI PPM stated that it would be offered to no more than 35 non-

qualified investors, but SCI's documents reflect that at least 40 actual investors were 

non-qualified. 

93. The LREH PPM also stated that it would be offered to no more than 35 

non-qualified investors, but defendants made no effort to verify that the investors 

were qualified. 

94. 	 In soliciting investors in the Funds, Mata completed investor suitability 

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questionnaires on the investors' behalf without their consent, failed to inquire 

regarding certain investors' financial condition or sophistication, and failed to 

maintain documentation of the investors' suitability. 

G. 	 Mata, Wealth Advisors, and Lifetime Universicy Acted As 
Investment Advisers To Fraudulently Obtain Investments in the 
Funds 

95. Wealth Advisors, Lifetime University, and Mata acted as investment 

advisers to individuals who came to Mata to analyze their investment portfolios and 

make recommendations. Mata established an investment advisory relationship with 

these potential clients, then directed them to sell their existing securities holdings and 

reinvest in SCI or LREH using the misrepresentations detailed above. 

96. Mata founded Wealth Advisors to provide investment advisory services 

to clients after his termination from Ameriprise in April 2009. Mata solicited his 

former Ameriprise clients to transfer their accounts to Wealth Advisors, without 

disclosing the reasons for his termination. 

97. Soon after forming Wealth Advisors in April2009, Mata was disciplined 

by regulators including the Nevada Secretary of State, FINRA, the California 

Department of Business Oversight, and from professional organizations including the 

Certified Financial Planning Board. 

98. In early 2012, Wealth Advisors's counsel advised the firm that Mata 

could not continue to provide financial planning services for a fee without being 

registered. In response, Mata "sold" Wealth Advisors to his administrative assistant, 

while still retaining actual control of Wealth Advisors. Mata continued to provide 

investment advice to new and existing clients of Wealth Advisors, including 

providing advice about market trends and the merits of investing in securities, in 

particular of investing in SCI and LREH. 

99. After he "sold" Wealth Advisors to his administrative assistant, Mata 

founded Lifetime University, which also provides financial planning seminars and 

investment advisory services. Through Lifetime University, Mata obtained new 

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clients by offering investment seminars. Seminar attendees become Mata' s clients 

through subsequent one-on-one financial coaching services that he offers. 

100. When meeting with advisory clients, Mata obtains the clients' current 

holdings and prepares individualized portfolio analyses for them. Although the 

portfolio analyses recommend that clients invest in publically-traded securities, Mata 

instead diverts their money to SCI and LREH. Mata did not always disclose his 

control over SCI to his advisory clients at Wealth Advisors or Lifetime University. 

101. Mata receives compensation for these unregistered investment advisory 

services in various ways. Clients pay Mata for financial planning packages ranging 

from $750 to $50,000 offered through Lifetime University. Mata also receives 

Wealth Advisors's client management fees. 

1 02. As set forth in detail above, in their capacity as investment advisers, Mata, 

Wealth Advisors, and Lifetime University make material misrepresentations regarding 

the Funds to clients who depended on them to allocate their portfolios and retirement 

savings. They mislead current and prospective clients by asserting that SCI offers 

guaranteed returns, misrepresent SCI's use ofproceeds, mislead clients about the 

profitability of their investment, and conceal Mata and Kayatta's connection to SCI and 

omit information about their disciplinary records. In addition, they have diverted client 

money to Mata, Kayatta and Pincheira and to other entities that Mata or Kayatta 

control. 

103. Mata, Wealth Advisors, and Lifetime University knew, or were reckless 

or negligent in not knowing, that their misrepresentations and omissions to their 

advisory clients were false and misleading when made. 

104. Mata, Wealth Advisors, and Lifetime University's misrepresentations 

and omissions were material, as they were central to investors' decisions to invest, 

and to their decisions to keep their moneys invested in the Funds. 

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FIRST CLAIM FOR RELIEF 


Unregistered Offer and Sale of Securities 


Violations of Section S(a) and (c) of the Securities Act 


(against Defendants Mata, Kayatta, SCI, and LREH) 


105. The SEC realleges and incorporates by reference paragraphs 1 through 

104 above. 

I 06. Defendants Mata, Kayatta, SCI, and LREH, by engaging in the conduct 

described above, directly or indirectly, singly and in concert with others, made use of 

the means or instruments of transportation or communication in interstate commerce, 

or of the mails, to offer to sell or to sell securities, or carried or caused to be carried 

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

securities for the purpose of sale or for delivery after sale. 

1 07. No registration statement had been filed or was in effect as to such 

securities, and no exemption from registration was applicable. 

108. By engaging in the conduct described above, Defendants Mata, Kayatta, 

SCI, and LREH, violated, and unless restrained and enjoined, will continue to violate, 

Section 5(a) and (c) of the Securities Act, 15 U.S.C. §§ 77e. 

SECOND CLAIM FOR RELIEF 


Fraud in the Offer or Sale of Securities 


Violations of Section 17(a)(l) and (3) of the Securities Act 


(against Defendants Mata, Kayatta, and Pincheira) 


109. The SEC realleges and incorporates by reference paragraphs 1 

through 1 04 above. 

110. Defendants Mata, Kayatta, and Pincheira, and each of them, by engaging 

in the conduct described above, directly or indirectly, in the offer or sale of securities 

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

commerce or by use of the mails: 

(a) with scienter, employed devices, schemes, or artifices to defraud; or 

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(b) engaged in transactions, practices, or courses of business which operated 

or would operate as a fraud or deceit upon the purchaser. 

111. By engaging in the conduct described above, Defendants violated, and 

unless restrain~d and enjoined, will continue to violate, Section 17(a)(1) and (3) of 

the Securities Act, 15 U.S.C. § 77q(a) (1) and (3). 

THIRD CLAIM FOR RELIEF 


Fraud in the Offer or Sale of Securities 


Violations of Section 17(a)(2) of the Securities Act 


(against Defendants Mata and Kayatta) 


112. The SEC realleges and incorporates by reference paragraphs 1 

through 1 04 above. 

113. Defendants Mata and Kayatta, and each of them, by engaging in the 

conduct described above, directly or indirectly, in the offer or sale of securities by the 

use of means or instruments of transportation or communication in interstate 

commerce or by use of the mails, to obtain money or property by means of any untrue 

statement of a material fact necessary in order to make the statements made, in light 

of the circumstances under which they were made, not misleading. 

114. By engaging in the conduct described above, Defendants Mata and 

Kayatta violated, and unless restrained and enjoined, will continue to violate, 

Section 17(a)(2) of the Securities Act, 15 U.S.C. § 77q(a)(2). 

FOURTH CLAIM FOR RELIEF 


Fraud in Connection with the Purchase or Sale of Securities 


Violations of Section 1 O(b) of the Exchange Act 


and Rules 10b-5(a) and (c) thereunder 


(against Defendants Mata, Kayatta, and Pincheira) 


115. The SEC realleges and incorporates by reference paragraphs 1 through 

104 above. 

116. Defendants Mata, Kayatta, and Pincheira, by engaging in the conduct 

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described above, directly or indirectly, in connection with the purchase or sale of a 

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

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

(a) employed devices, schemes, or artifices to defraud; or 

(b) engaged in acts, practices or courses of business which operated or 

would operate as a fraud or deceit upon other persons. 

117. By engaging in the conduct described above, Defendants violated, and 

unless restrained and enjoined, will continue to violate, Section 1 O(b) of the 

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

§ 240.10b-5(a) and (c). 

FIFTH CLAIM FOR RELIEF 


Fraud in Connection with the Purchase or Sale of Securities 


Violations of Section 1 O(b) of the Exchange Act and Rules lOb-S(b) thereunder 


(against Defendants Mata and Kayatta) 


118. The SEC realleges and incorporates by reference paragraphs 1 

through 1 04 above. 

119. Defendants Mata and Kayatta, by engaging in the conduct described 

above, directly or indirectly, in connection with the purchase or sale of a security, by 

the use of means or instrumentalities or interstate commerce, of the mails, or of the 

facilities of a national securities exchange, with scienter 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. 

120. By engaging in the conduct described above, Defendants Mata and 

Kayatta violated, and unless restrained and enjoined, will continue to violate, 

Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5(b) thereunder, 

17 C.P.R.§ 240.10b-5(b). 

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SIXTH CLAIM FOR RELIEF 

Prohibited Transactions by Investment Advisers 


Violation of Section 206(1) and (2) 


(against Defendants Mata, Wealth Advisors, and Lifetime University) 


121. The SEC realleges and incorporates by reference paragraphs 1 

through 1 04 above. 

122. Defendants Mata, Wealth Advisors, and Lifetime University, by 

engaging in the conduct described above, while acting as an investment adviser, by 

use of means or instrumentalities of interstate commerce, directly or indirectly: 

(a) employed a device, scheme, or artifice to defraud a client or 

prospective client; or 

(b) engaged in a transaction, practice, or course ofbusiness, which 

operates as a fraud or deceit upon a client or prospective client. 

123. By engaging in the conduct described above, Defendants Mata, Wealth 

Advisors, and Lifetime University violated, and unless restrained and enjoined, will 

continue to violate, Section 206(1) and (2) of the Advisers Act, 15 U.S.C. § 80b-6(1) 

& (2). 

PRAYER FOR RELIEF 


WHEREFORE, the SEC respectfully requests that the Court: 


I. 

Issue findings of fact and conclusions of law that Defendants committed the 

alleged violations. 

II. 

Issue orders, in a form consistent with Fed. R. Civ. P. 65(d), temporarily, 

preliminarily, and permanently enjoining Defendants Mata, Kayatta, SCI, and LREH, 

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 5, 15 

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U.S.C. §§ 77e, of the Securities Act. 

III. 

Issue orders, in a form consistent with Fed. R. Civ. P. 65(d), temporarily, 

preliminarily, and permanently enjoining Defendants Mata, Kayatta, and Pincheira, 

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. §§ 77e(a), and Section lO(b) of the Exchange Act, 15 

U.S.C. § 78j(b ), and Rule 1Ob-5 thereunder, 17 C.F.R. §§ 240. i Ob-5. 

IV. 

Issue orders, in a form consistent with Fed. R. Civ. P. 65(d), temporarily, 

preliminarily, and permanently enjoining Defendants Mata, Wealth Advisors, and 

Lifetime University 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 

Sections 206(1), 206(2), of the Advisers Act, 15 U.S.C. §§ 80b-6(1), (2). 

v. 
Issue orders, in a form consistent with Fed. R. Civ. P. 65(d), temporarily, 

preliminarily, and permanently enjoining Defendants Mata, Kayatta, and Pincheira 

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 soliciting, accepting, or 

depositing any monies from actual or prospective investors in connection with any 

offering of securities pursuant to Section 20(b) of the Securities Act and 

Section 21 (d) of the Exchange Act; provided, however, that such injunction shall not 

prevent Defendants Mata, Kayatta, and Pincheira from purchasing or selling 

securities listed on a national securities exchange for their own personal accounts. 

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VI. 

Issue in a form consistent with Fed. R. Civ. P. 65, a temporary restraining order 

and a preliminary injunction freezing the assets of each of the Defendants; prohibiting 

each of the Defendants from destroying documents; ordering expedited discovery; 

ordering accountings by each of the Defendants; and appointing a receiver over 

Defendants SCI, LREH, Wealth Advisors, and Lifetime University, and any entities 

controlled by them or by Defendants Mata, Kayatta, or Pincheira. 

VII. 

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

together with prejudgment interest thereon. 

VIII. 

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

Act, 15 U.S.C. § 77t(d); Section 2l(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3); 

and Section 209(e) of the Advisers Act, 15 U.S.C. §80b-9{e). 

IX. 

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 
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motion for additional relief within the jurisdiction of this Court. 

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

necessary. 

Dated: September 2, 2015 pectfully submitted, 

ltfAJLQ-GL-_ 
n M. Dean 

Attorneys for Plaintiff 
Securities and Exchange Commission 

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