SEC v. JENNY E. COPLAN, No. 0:13-CV-62127, Southern District of Florida (Sept. 30, 2013) — Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

SECURITIES AND EXCHANGE COMMISSION, )
 )
 Plaintiff, )
 )
v. )
 )
JENNY E. COPLAN, )
 )
 Defendant. )
____________________________________________ )

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF

 Plaintiff Securities and Exchange Commission alleges as follows:
I. INTRODUCTION
1. The   Commission   brings   this   action   to   enjoin   Jenny   E.   Coplan,   from   further
violations of the anti-fraud and registration provisions of the federal securities laws.
2. From no  later  than  January  2009  until  at  least  October  2011,  Coplan, directly  and
through  her  company,  Immigration  General  Services,  LLC  (“Immigration  Services”),  operated
an affinity fraud and Ponzi scheme.  Coplan raised approximately $4 million from more than 90
investors,   many  of  whom  were Colombian-Americans  and  Colombians  living  in  Florida,  by
selling them securities in the form of promissory notes and investment contracts.
3. Coplan solicited  investments  in  Immigration  Services  promising from  five  to  nine
percent monthly interest.  Coplan told prospective investors this was a safe investment and their
money was FDIC insured.
4. To  lure  investors,  Coplan told them  Immigration  Services  operated through  an
investment  broker  that  would  invest  funds  in immigration bail  bonds.    These  statements  were

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false.  Coplan never placed investors’ funds with an investment broker to make a profit.  Instead,
she misappropriated approximately $878,000 of investors’ funds for her own personal use.
5. To  conceal  her  unlawful  conduct,  Coplan paid  purported  profits  to  earlier  investors
using  funds  from  newer  investors  in  classic  Ponzi  scheme  fashion.   Coplan also provided
fictitious investor statements indicating their investments were intact and profitable.
6. Coplan  also  provided  at  least  two  investors  a  statement  of  financial  condition
claiming it belonged to the bail bond investment broker.  In truth, however, these statements bore
no connection to any bail bond investment broker.
7. Through her conduct, Coplan violated Sections 5(a),  5(c), and 17(a) of the Securities
Act  of  1933  (“Securities  Act”)  [15  U.S.C.  §  77q(a)];  Sections  10(b) Securities  Exchange  Act  of
1934 (“Exchange Act”) [15 U.S.C. §§ 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5].  Coplan also
violated Section 15(a) of the Exchange Act [15 U.S.C. §§ 78o(a)].
8. The  Commission  asks  the  Court  to  enter:  (1)  a permanent  injunction  restraining  and
enjoining Coplan  from  violating  the  federal  securities  laws;  (2)  an order  directing Coplan  to
disgorge  all  ill-gotten  gains,  with  prejudgment  interest;  and (3) an order  directing  Coplan to  pay
civil penalties.
II. DEFENDANT AND RELATED ENTITIES
A. DEFENDANT
9. Coplan, age 54, resides in Tamarac, Florida.  Coplan was the managing member and
acting president of Immigration Services from July 2006 until September 2012.  Coplan was also
the managing member of Immigration General Services Center LLC (“Immigration Center”) and
president  of  Immigration  General  Services  Consulting  Group,  Inc. (“Immigration  Consulting”).
Coplan has never been registered with the Commission in any capacity.

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B. RELATED ENTITIES
10. Immigration  Services  is  an  inactive  Florida  limited  liability  company  organized  in
April 2006 and administratively dissolved in September 2012.  Its principal place of business was in
Lauderhill,  Florida.    Immigration  Services  has  never  registered  an  offering  of  securities  under  the
Securities  Act  or  a  class  of  securities  under  the  Exchange  Act,  and  has  never  been  registered  with
the Commission in any capacity.
11. Immigration Center is an inactive Florida limited liability company organized in June
2011 and administratively  dissolved  in  September  2012.    Its  principal  place  of  business  was in
Lauderhill,  Florida.    Immigration  Services  has  never  registered  an  offering  of  securities  under  the
Securities  Act  or  a  class  of  securities  under  the  Exchange  Act,  and  has  never  been  registered  with
the Commission in any capacity.
12. Immigration Consulting is an inactive Florida limited liability company organized in
October 2009 and administratively dissolved in September 2012.  Its principal place of business was
in Lauderhill, Florida.  Immigration Services has never registered an offering of securities under the
Securities  Act  or  a  class  of  securities  under  the  Exchange  Act,  and  has  never  been  registered  with
the Commission in any capacity.
III. JURISDICTION AND VENUE
13. This  Court  has  jurisdiction  over  this  action  pursuant  to  Sections  20(b),  20(d),  and
22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d), and 77v(a)]; and Sections 21(d), 21(e),
and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), and 78aa].
14. This Court has personal jurisdiction over Coplan and venue is proper in the Southern
District  of  Florida  because  the Coplan’s  acts  and  transactions  constituting  violations of  the
Securities Act and the Exchange Act occurred in the Southern District of Florida.  Immigration

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Services’  principal  place  of  business  during  the  relevant  period  was  in  the  Southern  District  of
Florida, Coplan solicited investors from Immigration Services’ office, and Coplan resided in the
Southern District of Florida during all times relevant to the conduct alleged herein.
15. In  connection  with  the  conduct  alleged  in  this  Complaint,  Coplan,  directly  and
indirectly, singly  or  in  concert  with  others,  made  use  of  the  means  and  instrumentalities  of
interstate commerce,  the  means  and  instruments  of  transportation  and  communication  in
interstate commerce, and the mails.
IV. COPLAN’S FRAUDULENT INVESTMENT SCHEME
A. Background
16. Coplan, who is herself a member of the Colombian-American community, developed
relationships  with  other  Colombian-Americans  and  Colombian  immigrants  through  a  business
she operated providing immigration services.  Coplan then offered individuals the opportunity to
invest in Immigration Services and the bail bond program.
17. In about  June  2009, Coplan  told  at  least  one  investor  that  this  was  an  investment
opportunity she offered to her friends and family initially, and then later opened it to everyone.
Coplan  also  told  prospective  investors  she  wanted  to  help  them  achieve  financial  stability.    To
cultivate  potential  investors,  Coplan  sometimes  mingled  with  investors'  friends  and  family
members at their social gatherings.  A large number of at least one investor's friends and family
members invested.
B. Coplan’s Offer and Sale of Securities
19. From  no  later  than  January  2009  until  at  least  October  2011,  Coplan,  directly  and
through  Immigration  Services,  offered  and  sold  securities  in  the  form  of  promissory  notes  and
investment contracts.

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20. No  registration  statement  has  been  filed  or  was  in  effect  with  the  Commission  in
connection  with  the  securities  Immigration  Services  offered.    Nor was  Immigration  Services
entitled to any registration exemption.
21. Coplan  actively  solicited  investors  and  marketed  the  investment  primarily  through
personal  discussions,   both in  person and in  telephone  conversations.     Many  of  these  potential
investors  were  Colombian-Americans  and  Colombians  living  in  Florida  who  had  little  or  no
investment experience.
22. Coplan paid investors for referring their family and friends to her if they invested in
Immigration  Services.    Investors  had  no  involvement  in  providing  prospective  investors  the
details or  soliciting  their  investment.   Investors  who  heard  about  the  investment  from  existing
investors did not have a prior relationship with Coplan.
23. In March 2010, Coplan told at least one investor she would give his investment funds
to a broker in connection with bail bonds.   Coplan also said she would serve as the middleman,
and the broker would invest the funds in bail bonds.
24. Coplan and Immigration Services also told prospective investors about the safety of
investment  principal.    Specifically, Coplan  told  one  investor  that  Immigration  Services  would
wire  transfer  his  investment  funds  to  the  supposed  investment  broker’s  escrow  account,  which
was FDIC guaranteed.
25. Coplan  told  another  investor  that  his  investment  was  very  secure  because  the
supposed  investment  broker  secured  all  investments  with  the  detained  immigrants’  collateral
property.    Coplan  also  told  this  investor  that  he  was  not  going  to  lose  his  money  because  if
detained  immigrant  failed  to  pay  their  bail  bond  the  broker  would  take  action  against  the
detainee’s property.

 6
26. Coplan, in her capacity as president of Immigration Services, entered into investment
contracts  with  investors.    Immigration  Services  and  Coplan  sold  the  notes  and  contracts  to
investors in Florida, California, Georgia, Texas, Canada, and Colombia.
27. Investors  signed  both  the  promissory  note  and  investment  contract  simultaneously.
Both  the  promissory  notes  and  the  investment  contracts  were  between  the  investor  and
Immigration Services, and Coplan signed both on behalf of the company.
28. The promissory notes, entitled “Unsecured Promissory Note,” were for a term of 180
days and reflected interest ranging from five to nine percent monthly.  The investment contracts
stated the same duration and return or “profit” rate as the corresponding promissory notes.
29. The investment contracts allowed investors to withdraw their principal at the end of
the  180-day  term  if  they  gave  prior  notice.    If  the  investors  failed  to  provide  such  notice,  the
notes automatically renewed for another 180 days.
30. Investors  regularly  allowed  their  promissory  notes  and  investment  contracts  to
automatically renew.  Coplan also offered some investors higher rates of return if they invested
additional funds, and Coplan then applied the new rate to the total amount invested.
31. Coplan  provided  some  investors  the  promissory  notes  and  investment  contracts
through U.S. mail and e-mail.
C. Misrepresentations and Omissions
1. Extraordinary Investment Returns
32. Coplan promised investors, orally and in writing, extraordinarily high rates of return
on  their  investments.    Coplan  promised  investors  fixed  interest  rates  ranging  from  five  to  nine
percent  monthly,  which  is  60  to  108 percent  annually.    Coplan  offered  some investors five

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percent  profits,   and  later  increased  their  rate  of  return  to  nine  percent  as  they  invested  more.
Immigration Services made the same promises in the investment contracts and promissory notes.
33. Coplan provided investors  false monthly  account  statements  showing  the  investors
were  earning  returns  on  their  investments.    These  account statements  were  on  Immigration
Services’  letterhead  and  reflected  the  amount  of  the  investors’  principal  and  their  purported
interest or profit earned.  Coplan mailed the account statements to investors.
34. Neither  Coplan  nor  Immigration  Services  invested  any  of  the  funds  as  promised.
Rather,  at  the  time  Coplan  and  Immigration  Services  made  promises  of  large  returns,  bank
records show they were engaged in a Ponzi scheme.
2. Investment Strategy
35. Coplan told  investors  Immigration  Services  would  invest  their  funds  with  an
investment  broker  for  the  purpose  of  providing  bail  bonds  for  detained  immigrants  to  make  a
profit for the investors.
36. In truth,  Coplan  and  Immigration  Services  made  no  investments  in  bail  bonds  or
otherwise and instead used investor funds to operate a Ponzi scheme and for Coplan’s personal
use.
3. Safety of Investment Principal
37. Coplan  and  Immigration  Services  told  potential  investors  their  principal  investment
was  safe  and  secure.    The  investment  contracts  also stated   that  Immigration  Services  provides
“security to all invested funds.”  Coplan also told investors Immigration Services provided FDIC
insurance,  and  the  investment  contracts  stated    that  Immigration  Services  “insures  the  funds
through the FDIC in order to watch over the administration of the invested capitals.”

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38. Coplan emailed  one  investor  two  purported  FDIC  statements  reflecting  insured
balances  of  $107,000  and  $250,000,  lulling  the  investor  into  continuing  to  think  his  investment
was  safe.    This  investor received  the  FDIC  statements  after  he  invested  and  did  not  make  a
further investment.
39. These  statements  were  false.    Immigration  Services  never  insured  investors’  funds
through the FDIC.
40. Coplan also  told  some  investors  the  supposed  bail  bonds  were  secured  by  the
detained immigrant’s collateral, including cash, homes, and automobiles.
41. These  statements  were  also  false.    In  truth,  Coplan  failed  to  invest  funds  in  bail
bonds.
4. False Statements of Financial Condition
42. Coplan  gave  at  least  two  investors  fictitious  financial  statements  she  claimed
belonged  to  the  purported bail  bond  investment  broker.    The  financial  statements  were  dated
December  31,  2009  and  December  31,  2010,  and  reflected  the  same  amounts.    The  heading  on
one financial statement had the name of the entity blanked out, and the other financial statement
identified  the  company  as  “XXXXXXXX,  Inc.”    The  notes  to  the  financial  statements  dated
December 31, 2009 stated that “BondsGms, Inc. is the broker and dealer.”
43. In  truth,  the  purported  bail  bond  investment  brokers  did  not  exist  and  the  financial
statements were fictitious.
Use of Proceeds

44. Coplan  told  investors  she  would  use  their  funds  in  connection  with  providing  bail
bonds for detained immigrants designed to make a profit for investors.

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45. In truth, Coplan used the funds to operate a Ponzi scheme, support her lifestyle, and,
to a smaller extent, pay commissions to sales agents and referral fees to investors.
46. Coplan  returned  more  than  $3.1  million  to  investors  as  purported  interest  or  profits
and  principal  repayments.    Coplan  misappropriated  at  least  $878,000  in  investor  funds  for  her
own  use  and  the  benefit  of  her  family  members,  including  cash  withdrawals,  debit  card
transactions, checks payable to herself and deposited funds in her personal bank account.  Coplan
signed  most  of  the  checks  with  the  purported  monthly  interest  payments  and  deposited  or  wire
transferred those funds directly into the investors’ bank accounts.
D.  The Scheme Unravels
47. Starting  no  later  than  May  2011,  the  Ponzi  scheme  began  to  unravel.     Coplan
maintained the ruse and continued to sell the promissory notes and investment contracts despite
failing to make monthly payments to investors.
48. Coplan  blamed  the  purported  investment  broker  for  the  delay  in  payments,  telling
investors  the  investment  broker  held  investors’  funds  to  cover  deficiencies  because  Coplan  had
failed to meet certain monthly investment quotas.
49. Starting no later than June 2011, Immigration Services had virtually no funds in its
bank accounts and was unable to honor investors’ increasing requests for monthly payments and
return  of  funds.    After  failing  to  make  payments  for  four  months,  Coplan  continued  the  sham
and,  despite  the  lack  of  any  profits, falsely  represented  in  a  letter  to  investors  that  Immigration
Services would resume making its monthly payments.
50. From no later than September through at least October 2011, Coplan tried to create a
false appearance that Immigration Services was back to business as usual, issuing non-sufficient
fund checks to investors purporting to be their monthly profits.

 10
51. Through Coplan’s  statements,  Coplan  and  Immigration  Services  were  able  to  raise
another $578,000 in investor funds from no later than June 2011 until at least October 2011.
52. All told, Coplan raised approximately $4 million from more than 90 investors.
COUNT I
Sale of Unregistered Securities in Violation of
Sections 5(a)   and 5(c) of the Securities Act

53. The  Commission  realleges  and  incorporates  paragraphs 9-  10,  16-31,  and  52-53 of
this Complaint.
54. No registration statement was filed or in effect with the Commission pursuant to the
Securities  Act  and  no  exemption  from  registration  exists  with  respect  to  the  securities  and
transactions described in this Complaint.
55. From  no  later  than  January  2009  until  at  least  October  2011, Coplan directly  and
indirectly, (a)  made  use  of  the  means  or  instruments  of  transportation  or  communication  in
interstate commerce or of the mails to sell securities, through the use or medium of a prospectus
or otherwise; (b) carried securities or caused such securities to be carried through the mails or in
interstate  commerce,  by  any  means  or  instruments  of  transportation,  for  the  purpose  of  sale  or
delivery  after  sale;  and  (c)  made  use  of  the  means  or  instruments  of  transportation  or
communication in interstate commerce or of the mails to offer to sell or offer to buy through the
use or medium of any prospectus or otherwise, without a registration statement having been filed
or being in effect with the Commission as to such securities.
56. By  reason  of  the  foregoing,  Coplan directly or  indirectly  violated,   and,  unless
enjoined, is reasonably likely to continue to violate,  Sections 5(a) and 5(c) of the Securities Act
[15 U.S.C. § 77e(a) and 77e(c)].

 11
COUNT II
Fraud in Violation of Section 10(b) and Rule 10b-5 of the Exchange Act

57. The   Commission   realleges   and   incorporates   paragraphs 1   through   53   of this
Complaint.
58. Coplan,  from  no  later  than  January  2009  until  at  least  October  2011, directly  and
indirectly,  by  use  of  the  means  and  instrumentality  of  interstate  commerce,  and  of  the  mails  in
connection  with  the  purchase  or  sale  of  securities, knowingly,  willfully  or  recklessly:  (a)
employed devices, schemes or artifices to defraud; (b) made untrue statements of material facts
and omitted to state material facts necessary in order to make the statements made, in the light of
the circumstances under which they were made, not misleading; or (c) engaged in acts, practices
and courses of business which operated as a fraud upon the purchasers of such securities.
59. By  reason  of  the  foregoing,  Coplan,  directly  or  indirectly  violated,   and,  unless
enjoined, is  reasonably  likely  to continue  to  violate  Section  10(b)  of  the  Exchange  Act  [15
U.S.C. § 78j(b)] and Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5]  .
COUNT III
Fraud in the Offer or Sale of Securities in Violation of
Section 17(a)(1) of the Securities Act

60. The Commission repeats and realleges paragraphs 1 through 53 of its Complaint as if
fully restated herein.
61. From  no  later  than  January  2009  until  at  least  October  2011, Coplan directly  and
indirectly,  by  use  of  the  means  or  instruments  of  transportation  or  communication  in  interstate
commerce  and  by  use  of  the  mails,  in  the  offer  or  sale  of  securities, as  described  in  this
Complaint, knowingly, willfully or recklessly employed devices, schemes or artifices to defraud.

 12
62. By  reason  of  the  foregoing,  Coplan,  directly  or  indirectly  violated  and,  unless
enjoined, is  reasonably  likely  to  continue  to  violate,  Section  17(a)(1)  of  the  Securities  Act,  15
U.S.C. § 77q(a).
COUNT IV

Fraud in the Offer or Sale of Securities in Violation of
Sections 17(a)(2) and 17(a)(3) Of the Securities Act

63. The   Commission   realleges   and   incorporates   paragraphs 1   through   53   of this
Complaint.
64. Coplan,  from  no  later  than  January  2009  until  at  least  October  2011, directly  and
indirectly, in the offer or sale of securities, by the use of means or instruments of transportation
or  communication  in  interstate  commerce,  or  of  the  mails:  (a)  obtained  money  or  property  by
means  of  untrue  statements  of  material  facts  and  omissions  to  state  material  facts  necessary  to
make  the  statements  made,  in  the  light  of  the  circumstances  under  which  they  were  made,  not
misleading;  or  (b)  engaged  in  transactions,  practices  and  courses  of  business  which  operated or
would operate as a fraud or deceit upon purchasers and prospective purchasers of such securities.
65. By  reason  of  the  foregoing,  Coplan,  directly  or  indirectly  violated,   and,  unless
enjoined, is  reasonably  likely  to  continue  to  violate,   Sections  17(a)(2)  and  17(a)(3)  of  the
Securities Act [ 15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)].
COUNT V
Unregistered Broker-Dealer Conduct in Violation of
Section 15(a) of the Exchange Act

66. The Commission realleges and incorporates paragraphs 9-  10, 16-31, 45-47, and 52-
53 of this Complaint.

 13
67. Coplan,  from  no  later  than  January  2009  until  at  least  October  2011, directly  and
indirectly by the use of the means and instrumentalities of interstate commerce, while acting as a
broker or dealer engaged in the business of effecting transactions in securities for the accounts of
others, effected transactions in securities, or induced or attempted to induce the purchase and sale
of  securities,  without  registering  as  a  broker-dealer  in  accordance  with  Section  15(b)  of  the
Exchange Act [15 U.S.C. § 78o(b)].
68. By  reason  of  the  foregoing,  Coplan directly  or  indirectly  violated,   and,  unless
enjoined, is  reasonably  likely  to  continue  to  violate,   Section  15(  a)  of  the  Exchange  Act  [15
U.S.C. § 78o(a)(1)].
RELIEF REQUESTED
  WHEREFORE, the Commission respectfully requests that the Court:
Declaratory Relief
  Declare, determine and find that Coplan committed the violations of the federal securities
laws alleged in this Complaint.
Permanent Injunctive Relief
Issue   a   Permanent   Injunction,   enjoining   Coplan, her   agents,   servants,   employees,
attorneys,  and  all  persons  in  active  concert  or  participation  with  them,  and  each  of  them,  from
violating, directly or indirectly: (I) Sections 5(a) and 5(c) of the Securities Act; (II) Section 10(b)
and Rule 10b-5 of the Exchange Act; (III) Section 17(a)(1) of the Securities Act;  (IV) Sections
17(a)(2) and 17(a)(3) of the Securities Act; and (V) Section 15(a) of the Exchange Act.
Disgorgement and Prejudgment Interest
Issue  an  Order  requiring  Coplan to  disgorge  all  ill-gotten gains,  including  prejudgment
interest, resulting from the acts or courses of conduct alleged in this Complaint.

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Civil Money Penalties
  Issue an Order directing Coplan to pay civil money penalties pursuant to Section 20(d) of
the  Securities  Act,  15  U.S.C.  §  77t(d);  and  Section  21(d) of  the  Exchange  Act,   15  U.S.C.  §
78u(d).
Further Relief
  Grant such other and further relief as may be necessary and appropriate.
Retention of Jurisdiction
  Further,  the  Commission  respectfully  requests  that the  Court  retain  jurisdiction  over  this
action in order to implement and carry out the terms of all orders and decrees that it may enter, or
to entertain any suitable application or motion by the Commission for additional relief within the
jurisdiction of this Court.

September 30, 2013          Respectfully submitted,

By: /s/ Amie Riggle Berlin
Amie Riggle Berlin, Esq.
Senior Trial Counsel
Florida Bar No. 630020
Direct Dial: (305) 982-6322
E-mail: [email protected]

Attorney for Plaintiff
U.S. Securities and Exchange Commission
801 Brickell Avenue, Suite 1800
Miami, Florida 33131
Telephone: (305) 982-6300
Facsimile: (305) 536-4154

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 

  
CASE NO.: 

 
 
SECURITIES AND EXCHANGE COMMISSION, ) 
 ) 
 Plaintiff, ) 
 ) 
v. ) 
 ) 
JENNY E. COPLAN, ) 
 ) 
 Defendant. ) 
____________________________________________ ) 
 

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF 
 
 Plaintiff Securities and Exchange Commission alleges as follows: 

I. INTRODUCTION 

1. The Commission brings this action to enjoin Jenny E. Coplan, from further 

violations of the anti-fraud and registration provisions of the federal securities laws. 

2. From no later than January 2009 until at least October 2011, Coplan, directly and 

through her company, Immigration General Services, LLC (“Immigration Services”), operated 

an affinity fraud and Ponzi scheme.  Coplan raised approximately $4 million from more than 90 

investors, many of whom were Colombian-Americans and Colombians living in Florida, by 

selling them securities in the form of promissory notes and investment contracts. 

3. Coplan solicited investments in Immigration Services promising from five to nine 

percent monthly interest.  Coplan told prospective investors this was a safe investment and their 

money was FDIC insured.   

4. To lure investors, Coplan told them Immigration Services operated through an 

investment broker that would invest funds in immigration bail bonds.  These statements were 

Case 0:13-cv-62127-XXXX   Document 1   Entered on FLSD Docket 09/30/2013   Page 1 of 14



 2 

false.  Coplan never placed investors’ funds with an investment broker to make a profit.  Instead, 

she misappropriated approximately $878,000 of investors’ funds for her own personal use.   

5. To conceal her unlawful conduct, Coplan paid purported profits to earlier investors 

using funds from newer investors in classic Ponzi scheme fashion.  Coplan also provided 

fictitious investor statements indicating their investments were intact and profitable. 

6. Coplan also provided at least two investors a statement of financial condition 

claiming it belonged to the bail bond investment broker.  In truth, however, these statements bore 

no connection to any bail bond investment broker. 

7. Through her conduct, Coplan violated Sections 5(a), 5(c), and 17(a) of the Securities 

Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)]; Sections 10(b) Securities Exchange Act of 

1934 (“Exchange Act”) [15 U.S.C. §§ 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5].  Coplan also 

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

8. The Commission asks the Court to enter: (1) a permanent injunction restraining and 

enjoining Coplan from violating the federal securities laws; (2) an order directing Coplan to 

disgorge all ill-gotten gains, with prejudgment interest; and (3) an order directing Coplan to pay 

civil penalties. 

II. DEFENDANT AND RELATED ENTITIES 

A. DEFENDANT 

9. Coplan, age 54, resides in Tamarac, Florida.  Coplan was the managing member and 

acting president of Immigration Services from July 2006 until September 2012.  Coplan was also 

the managing member of Immigration General Services Center LLC (“Immigration Center”) and 

president of Immigration General Services Consulting Group, Inc. (“Immigration Consulting”).  

Coplan has never been registered with the Commission in any capacity.   

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B. RELATED ENTITIES 

10. Immigration Services is an inactive Florida limited liability company organized in 

April 2006 and administratively dissolved in September 2012.  Its principal place of business was in 

Lauderhill, Florida.  Immigration Services has never registered an offering of securities under the 

Securities Act or a class of securities under the Exchange Act, and has never been registered with 

the Commission in any capacity. 

11. Immigration Center is an inactive Florida limited liability company organized in June 

2011 and administratively dissolved in September 2012.  Its principal place of business was in 

Lauderhill, Florida.  Immigration Services has never registered an offering of securities under the 

Securities Act or a class of securities under the Exchange Act, and has never been registered with 

the Commission in any capacity. 

12. Immigration Consulting is an inactive Florida limited liability company organized in 

October 2009 and administratively dissolved in September 2012.  Its principal place of business was 

in Lauderhill, Florida.  Immigration Services has never registered an offering of securities under the 

Securities Act or a class of securities under the Exchange Act, and has never been registered with 

the Commission in any capacity. 

III. JURISDICTION AND VENUE 

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

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

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

14. This Court has personal jurisdiction over Coplan and venue is proper in the Southern 

District of Florida because the Coplan’s acts and transactions constituting violations of the 

Securities Act and the Exchange Act occurred in the Southern District of Florida.  Immigration 

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Services’ principal place of business during the relevant period was in the Southern District of 

Florida, Coplan solicited investors from Immigration Services’ office, and Coplan resided in the 

Southern District of Florida during all times relevant to the conduct alleged herein. 

15. In connection with the conduct alleged in this Complaint, Coplan, directly and 

indirectly, singly or in concert with others, made use of the means and instrumentalities of 

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

interstate commerce, and the mails. 

IV. COPLAN’S FRAUDULENT INVESTMENT SCHEME 

A. Background 

16. Coplan, who is herself a member of the Colombian-American community, developed 

relationships with other Colombian-Americans and Colombian immigrants through a business 

she operated providing immigration services.  Coplan then offered individuals the opportunity to 

invest in Immigration Services and the bail bond program. 

17. In about June 2009, Coplan told at least one investor that this was an investment 

opportunity she offered to her friends and family initially, and then later opened it to everyone.  

Coplan also told prospective investors she wanted to help them achieve financial stability.  To 

cultivate potential investors, Coplan sometimes mingled with investors' friends and family 

members at their social gatherings.  A large number of at least one investor's friends and family 

members invested.   

B. Coplan’s Offer and Sale of Securities 

19. From no later than January 2009 until at least October 2011, Coplan, directly and 

through Immigration Services, offered and sold securities in the form of promissory notes and 

investment contracts. 

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20. No registration statement has been filed or was in effect with the Commission in 

connection with the securities Immigration Services offered.  Nor was Immigration Services 

entitled to any registration exemption. 

21. Coplan actively solicited investors and marketed the investment primarily through 

personal discussions, both in person and in telephone conversations.  Many of these potential 

investors were Colombian-Americans and Colombians living in Florida who had little or no 

investment experience.  

22. Coplan paid investors for referring their family and friends to her if they invested in 

Immigration Services.  Investors had no involvement in providing prospective investors the 

details or soliciting their investment.  Investors who heard about the investment from existing 

investors did not have a prior relationship with Coplan. 

23. In March 2010, Coplan told at least one investor she would give his investment funds 

to a broker in connection with bail bonds.  Coplan also said she would serve as the middleman, 

and the broker would invest the funds in bail bonds.   

24. Coplan and Immigration Services also told prospective investors about the safety of 

investment principal.  Specifically, Coplan told one investor that Immigration Services would 

wire transfer his investment funds to the supposed investment broker’s escrow account, which 

was FDIC guaranteed. 

25. Coplan told another investor that his investment was very secure because the 

supposed investment broker secured all investments with the detained immigrants’ collateral 

property.  Coplan also told this investor that he was not going to lose his money because if 

detained immigrant failed to pay their bail bond the broker would take action against the 

detainee’s property. 

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26. Coplan, in her capacity as president of Immigration Services, entered into investment 

contracts with investors.  Immigration Services and Coplan sold the notes and contracts to 

investors in Florida, California, Georgia, Texas, Canada, and Colombia.   

27. Investors signed both the promissory note and investment contract simultaneously.  

Both the promissory notes and the investment contracts were between the investor and 

Immigration Services, and Coplan signed both on behalf of the company.   

28. The promissory notes, entitled “Unsecured Promissory Note,” were for a term of 180 

days and reflected interest ranging from five to nine percent monthly.  The investment contracts 

stated the same duration and return or “profit” rate as the corresponding promissory notes.   

29. The investment contracts allowed investors to withdraw their principal at the end of 

the 180-day term if they gave prior notice.  If the investors failed to provide such notice, the 

notes automatically renewed for another 180 days.   

30. Investors regularly allowed their promissory notes and investment contracts to 

automatically renew.  Coplan also offered some investors higher rates of return if they invested 

additional funds, and Coplan then applied the new rate to the total amount invested.   

31. Coplan provided some investors the promissory notes and investment contracts 

through U.S. mail and e-mail. 

C. Misrepresentations and Omissions 

1. Extraordinary Investment Returns 

32. Coplan promised investors, orally and in writing, extraordinarily high rates of return 

on their investments.  Coplan promised investors fixed interest rates ranging from five to nine 

percent monthly, which is 60 to 108 percent annually.  Coplan offered some investors five 

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percent profits, and later increased their rate of return to nine percent as they invested more.  

Immigration Services made the same promises in the investment contracts and promissory notes.   

33. Coplan provided investors false monthly account statements showing the investors 

were earning returns on their investments.  These account statements were on Immigration 

Services’ letterhead and reflected the amount of the investors’ principal and their purported 

interest or profit earned.  Coplan mailed the account statements to investors.   

34. Neither Coplan nor Immigration Services invested any of the funds as promised.  

Rather, at the time Coplan and Immigration Services made promises of large returns, bank 

records show they were engaged in a Ponzi scheme. 

2. Investment Strategy 

35. Coplan told investors Immigration Services would invest their funds with an 

investment broker for the purpose of providing bail bonds for detained immigrants to make a 

profit for the investors.   

36. In truth, Coplan and Immigration Services made no investments in bail bonds or 

otherwise and instead used investor funds to operate a Ponzi scheme and for Coplan’s personal 

use. 

3. Safety of Investment Principal 

37. Coplan and Immigration Services told potential investors their principal investment 

was safe and secure.  The investment contracts also stated that Immigration Services provides 

“security to all invested funds.”  Coplan also told investors Immigration Services provided FDIC 

insurance, and the investment contracts stated that Immigration Services “insures the funds 

through the FDIC in order to watch over the administration of the invested capitals.”   

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38. Coplan emailed one investor two purported FDIC statements reflecting insured 

balances of $107,000 and $250,000, lulling the investor into continuing to think his investment 

was safe.  This investor received the FDIC statements after he invested and did not make a 

further investment.   

39. These statements were false.  Immigration Services never insured investors’ funds 

through the FDIC. 

40. Coplan also told some investors the supposed bail bonds were secured by the 

detained immigrant’s collateral, including cash, homes, and automobiles.   

41. These statements were also false.  In truth, Coplan failed to invest funds in bail 

bonds. 

4. False Statements of Financial Condition 

42. Coplan gave at least two investors fictitious financial statements she claimed 

belonged to the purported bail bond investment broker.  The financial statements were dated 

December 31, 2009 and December 31, 2010, and reflected the same amounts.  The heading on 

one financial statement had the name of the entity blanked out, and the other financial statement 

identified the company as “XXXXXXXX, Inc.”  The notes to the financial statements dated 

December 31, 2009 stated that “BondsGms, Inc. is the broker and dealer.”   

43. In truth, the purported bail bond investment brokers did not exist and the financial 

statements were fictitious.   

Use of Proceeds 
 

44. Coplan told investors she would use their funds in connection with providing bail 

bonds for detained immigrants designed to make a profit for investors.   

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45. In truth, Coplan used the funds to operate a Ponzi scheme, support her lifestyle, and, 

to a smaller extent, pay commissions to sales agents and referral fees to investors.   

46. Coplan returned more than $3.1 million to investors as purported interest or profits 

and principal repayments.  Coplan misappropriated at least $878,000 in investor funds for her 

own use and the benefit of her family members, including cash withdrawals, debit card 

transactions, checks payable to herself and deposited funds in her personal bank account.  Coplan 

signed most of the checks with the purported monthly interest payments and deposited or wire 

transferred those funds directly into the investors’ bank accounts. 

D. The Scheme Unravels 

47. Starting no later than May 2011, the Ponzi scheme began to unravel.  Coplan 

maintained the ruse and continued to sell the promissory notes and investment contracts despite 

failing to make monthly payments to investors.   

48. Coplan blamed the purported investment broker for the delay in payments, telling 

investors the investment broker held investors’ funds to cover deficiencies because Coplan had 

failed to meet certain monthly investment quotas.     

49. Starting no later than June 2011, Immigration Services had virtually no funds in its 

bank accounts and was unable to honor investors’ increasing requests for monthly payments and 

return of funds.  After failing to make payments for four months, Coplan continued the sham 

and, despite the lack of any profits, falsely represented in a letter to investors that Immigration 

Services would resume making its monthly payments.   

50. From no later than September through at least October 2011, Coplan tried to create a 

false appearance that Immigration Services was back to business as usual, issuing non-sufficient 

fund checks to investors purporting to be their monthly profits.   

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51. Through Coplan’s statements, Coplan and Immigration Services were able to raise 

another $578,000 in investor funds from no later than June 2011 until at least October 2011. 

52. All told, Coplan raised approximately $4 million from more than 90 investors.  

COUNT I 

Sale of Unregistered Securities in Violation of 
Sections 5(a) and 5(c) of the Securities Act 

 
53. The Commission realleges and incorporates paragraphs 9-10, 16-31, and 52-53 of 

this Complaint. 

54. No registration statement was filed or in effect with the Commission pursuant to the 

Securities Act and no exemption from registration exists with respect to the securities and 

transactions described in this Complaint. 

55. From no later than January 2009 until at least October 2011, Coplan directly and 

indirectly, (a) made use of the means or instruments of transportation or communication in 

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

or otherwise; (b) carried securities or caused such securities to be carried through the mails or in 

interstate commerce, by any means or instruments of transportation, for the purpose of sale or 

delivery after sale; and (c) made use of the means or instruments of transportation or 

communication in interstate commerce or of the mails to offer to sell or offer to buy through the 

use or medium of any prospectus or otherwise, without a registration statement having been filed 

or being in effect with the Commission as to such securities. 

56. By reason of the foregoing, Coplan directly or indirectly violated, and, unless 

enjoined, is reasonably likely to continue to violate, Sections 5(a) and 5(c) of the Securities Act 

[15 U.S.C. § 77e(a) and 77e(c)]. 

 

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COUNT II 

Fraud in Violation of Section 10(b) and Rule 10b-5 of the Exchange Act  
 

57. The Commission realleges and incorporates paragraphs 1 through 53 of this 

Complaint. 

58. Coplan, from no later than January 2009 until at least October 2011, directly and 

indirectly, by use of the means and instrumentality of interstate commerce, and of the mails in 

connection with the purchase or sale of securities, knowingly, willfully or recklessly: (a) 

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

and omitted to state material facts necessary in order to make the statements made, in the light of 

the circumstances under which they were made, not misleading; or (c) engaged in acts, practices 

and courses of business which operated as a fraud upon the purchasers of such securities. 

59. By reason of the foregoing, Coplan, directly or indirectly violated, and, unless 

enjoined, is reasonably likely to continue to violate Section 10(b) of the Exchange Act [15 

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

COUNT III 

Fraud in the Offer or Sale of Securities in Violation of  
Section 17(a)(1) of the Securities Act 

 
60. The Commission repeats and realleges paragraphs 1 through 53 of its Complaint as if 

fully restated herein. 

61. From no later than January 2009 until at least October 2011, Coplan directly and 

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

commerce and by use of the mails, in the offer or sale of securities, as described in this 

Complaint, knowingly, willfully or recklessly employed devices, schemes or artifices to defraud.  

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62. By reason of the foregoing, Coplan, directly or indirectly violated and, unless 

enjoined, is reasonably likely to continue to violate, Section 17(a)(1) of the Securities Act, 15 

U.S.C. § 77q(a). 

COUNT IV 
 

Fraud in the Offer or Sale of Securities in Violation of  
Sections 17(a)(2) and 17(a)(3) Of the Securities Act 

 
63. The Commission realleges and incorporates paragraphs 1 through 53 of this 

Complaint. 

64. Coplan, from no later than January 2009 until at least October 2011, directly and 

indirectly, in the offer or sale of securities, by the use of means or instruments of transportation 

or communication in interstate commerce, or of the mails: (a) obtained money or property by 

means of untrue statements of material facts and omissions to state material facts necessary to 

make the statements made, in the light of the circumstances under which they were made, not 

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

would operate as a fraud or deceit upon purchasers and prospective purchasers of such securities. 

65. By reason of the foregoing, Coplan, directly or indirectly violated, and, unless 

enjoined, is reasonably likely to continue to violate, Sections 17(a)(2) and 17(a)(3) of the 

Securities Act [15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)]. 

COUNT V 

Unregistered Broker-Dealer Conduct in Violation of  
Section 15(a) of the Exchange Act 

 
66. The Commission realleges and incorporates paragraphs 9-10, 16-31, 45-47, and 52-

53 of this Complaint. 

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67. Coplan, from no later than January 2009 until at least October 2011, directly and 

indirectly by the use of the means and instrumentalities of interstate commerce, while acting as a 

broker or dealer engaged in the business of effecting transactions in securities for the accounts of 

others, effected transactions in securities, or induced or attempted to induce the purchase and sale 

of securities, without registering as a broker-dealer in accordance with Section 15(b) of the 

Exchange Act [15 U.S.C. § 78o(b)]. 

68. By reason of the foregoing, Coplan directly or indirectly violated, and, unless 

enjoined, is reasonably likely to continue to violate, Section 15(a) of the Exchange Act [15 

U.S.C. § 78o(a)(1)]. 

RELIEF REQUESTED 

  WHEREFORE, the Commission respectfully requests that the Court: 

Declaratory Relief 

  Declare, determine and find that Coplan committed the violations of the federal securities 

laws alleged in this Complaint. 

Permanent Injunctive Relief 

Issue a Permanent Injunction, enjoining Coplan, her agents, servants, employees, 

attorneys, and all persons in active concert or participation with them, and each of them, from 

violating, directly or indirectly: (I) Sections 5(a) and 5(c) of the Securities Act; (II) Section 10(b) 

and Rule 10b-5 of the Exchange Act; (III) Section 17(a)(1) of the Securities Act; (IV) Sections 

17(a)(2) and 17(a)(3) of the Securities Act; and (V) Section 15(a) of the Exchange Act. 

Disgorgement and Prejudgment Interest 

Issue an Order requiring Coplan to disgorge all ill-gotten gains, including prejudgment 

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

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Civil Money Penalties 

  Issue an Order directing Coplan to pay civil money penalties pursuant to Section 20(d) of 

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

78u(d). 

Further Relief 

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

Retention of Jurisdiction 

  Further, the Commission respectfully requests that the Court retain jurisdiction over this 

action in order to implement and carry out the terms of all orders and decrees that it may enter, or 

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

jurisdiction of this Court. 

 

September 30, 2013         Respectfully submitted, 

 
By: /s/ Amie Riggle Berlin 

Amie Riggle Berlin, Esq.  
Senior Trial Counsel  
Florida Bar No. 630020  
Direct Dial: (305) 982-6322  
E-mail: [email protected]   

    
Attorney for Plaintiff 
U.S. Securities and Exchange Commission 
801 Brickell Avenue, Suite 1800 
Miami, Florida 33131 
Telephone: (305) 982-6300 
Facsimile: (305) 536-4154 

Case 0:13-cv-62127-XXXX   Document 1   Entered on FLSD Docket 09/30/2013   Page 14 of 14

mailto:[email protected]

	Sale of Unregistered Securities in Violation of
	Sections 5(a) and 5(c) of the Securities Act
	COUNT II

	Fraud in the Offer or Sale of Securities in Violation of
	Section 17(a)(1) of the Securities Act
	COUNT IV
	Fraud in the Offer or Sale of Securities in Violation of
	Sections 17(a)(2) and 17(a)(3) of the Securities Act