Securities and Exchange Commission v. Kaplan, Esq. et al

Filing 101

ORDER granting ECF No. 97 Stipulation for Entry of Final Judgment Against Relief Defendant Manna Investments, LLC. Signed by Judge Miranda M. Du on 1/8/2018. (Defendant Manna Investments, LLC terminated.) (Copies have been distributed pursuant to the NEF - DRM)

1
2
3

Alyssa A. Qualls (IL Bar No. 6292124)
Email: [e-mail]
Amy S. Cotter (IL Bar No. 6238157)
Email: [e-mail]
Raven A. Winters (IL Bar No. 6291077)
Email: [e-mail]

4
5
6
7
8

Attorneys for Plaintiff
Robert J. Burson, Associate Regional Director
Amy S. Cotter, Assistant Regional Director
Alyssa A. Qualls, Regional Trial Counsel
Securities and Exchange Commission
175 West Jackson Blvd., Suite 900
Chicago, Illinois 60604
Telephone: [phone]
Facsimile: [phone]

9
UNITED STATES DISTRICT COURT
10
DISTRICT OF NEVADA
11
Northern Division
12
13

SECURITIES AND EXCHANGE
COMMISSION,

14

Case No. 3:16-cv-00270-MMD-VPC
Honorable Miranda Du

Plaintiff,
15
vs.
16
17
18
19

DAVID B. KAPLAN, ESQ.,
SYNCHRONIZED ORGANIZATIONAL
SOLUTIONS, LLC,
SYNCHRONIZED ORGANIZATIONAL
SOLUTIONS INTERNATIONAL, LTD.,
and MANNA INTERNATIONAL
ENTERPRISES, INC.,

STIPULATION FOR ENTRY OF FINAL
JUDGMENT AGAINST RELIEF
DEFENDANT MANNA INVESTMENTS,
LLC

20
Defendants,
21
and
22

24

LISA M. KAPLAN,
THE WATER-WALKING
FOUNDATION, INC., and
MANNA INVESTMENTS, LLC,

25

Relief Defendants.

23

26
27
28

IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned parties, as
follows:

1

1.

The United States Securities and Exchange Commission (the “Commission”) and

2

Relief Defendant Manna Investments, LLC (“Relief Defendant,” and together with the Commission,

3

the “Parties”) jointly move this Court to enter final judgment against Relief Defendant. The Parties

4

have reached a settlement, and jointly move this Court to enter the proposed final judgment and

5

resolve this matter.

6
7
8
9
10
11

2.

The Parties have reached a settlement to resolve all claims against Relief Defendant.

The settlement includes: (1) disgorgement; and (2) prejudgment interest.
3.

A proposed final judgment as to Relief Defendant is attached as Exhibit A. Among

other things, the proposed final judgment orders Relief Defendant to pay disgorgement in the
amount of $483,417.52, plus prejudgment interest thereon in the amount of $38,119.61.
4.

Without either admitting or denying the allegations of the complaint in this action,

12

Relief Defendant has consented to the entry of the proposed final judgment, as reflected in the

13

Consent attached as Exhibit B.

14
15
16

5.

The settlement brings the litigation to a close, without the need for a trial, and thus

conserves the resources of the Court and the Parties.
6.

The Parties agree that entry of the proposed final judgment is in the public interest,

17

and is a fair and reasonable resolution of this matter. See SEC v. Citigroup Global Markets, Inc.,

18

752 F.3d 285 (2d Cir. 2014).

19
20

7.

The Parties respectfully request the entry of final judgment at the Court’s earliest

convenience.

21
22
23
24
25
26
27
28
2

Case No. 3:16-CV-00270-MMD-VPC

1

WHEREFORE, for the foregoing reasons, the parties jointly move this Court for entry of

2

final judgment against Relief Defendant.

3

Date: January 8, 2018

4
5
6
7
8

Manna Investments, LLC

/s/ Alyssa A. Qualls___
Alyssa A. Qualls (IL Bar No. 6292124)
175 West Jackson Blvd., Suite 1450
Chicago, Illinois 60604
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

By: /s/ David B. Kaplan
David B. Kaplan, Esq.
Managing Member
1314-B Cave Rock Drive
Glenbrook, NV 89413
Telephone: [phone]

9
10

Counsel for Plaintiff United States Securities
and Exchange Commission

11
12

IT IS SO ORDERED:

13

________________________________
The Honorable Miranda Du
United States District Judge

14

January 8, 2018
Dated: _______________________

15
16
17
18
19
20
21
22
23
24
25
26
27
28
3

Case No. 3:16-CV-00270-MMD-VPC