Securities and Exchange Commission v. Kaplan, Esq. et al
Filing
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ORDER granting ECF No. 98 Stipulation for Entry of Final Judgment Against Defendant The Water-Walking Foundation, Inc. Signed by Judge Miranda M. Du on 1/8/2018. (Defendant The Water-Walking Foundation, Inc. terminated.) (Copies have been distributed pursuant to the NEF - DRM)
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Alyssa A. Qualls (IL Bar No. 6292124)
Email: quallsa@sec.gov
Amy S. Cotter (IL Bar No. 6238157)
Email: cottera@sec.gov
Raven A. Winters (IL Bar No. 6291077)
Email: wintersr@sec.gov
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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: (312) 353-7390
Facsimile: (312) 353-7398
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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Northern Division
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SECURITIES AND EXCHANGE
COMMISSION,
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Case No. 3:16-cv-00270-MMD-VPC
Honorable Miranda Du
Plaintiff,
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vs.
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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 THE WATER-WALKING
FOUNDATION, INC.
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Defendants,
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and
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LISA M. KAPLAN,
THE WATER-WALKING
FOUNDATION, INC., and
MANNA INVESTMENTS, LLC,
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Relief Defendants.
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IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned parties, as
follows:
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1.
The United States Securities and Exchange Commission (the “Commission”) and
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Relief Defendant The Water-Walking Foundation, Inc. (“Relief Defendant,” and together with the
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Commission, the “Parties”) jointly move this Court to enter final judgment against Relief
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Defendant. The Parties have reached a settlement, and jointly move this Court to enter the proposed
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final judgment and resolve this matter.
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2.
The Parties have reached a settlement to resolve all claims against Relief Defendant.
The settlement includes: (1) disgorgement; and (2) prejudgment interest.
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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 $599,012.34, plus prejudgment interest thereon in the amount of $45,363.74.
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Relief Defendant shall partially satisfy this obligation through the transfer of the
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balance held in the frozen account after entry of this Final Judgment, as set forth in section II of
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Exhibit A.
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5.
Without either admitting or denying the allegations of the complaint in this action,
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Relief Defendant has consented to the entry of the proposed final judgment, as reflected in the
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Consent attached as Exhibit B.
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6.
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.
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The Parties agree that entry of the proposed final judgment is in the public interest,
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and is a fair and reasonable resolution of this matter. See SEC v. Citigroup Global Markets, Inc.,
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752 F.3d 285 (2d Cir. 2014).
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8.
The Parties respectfully request the entry of final judgment at the Court’s earliest
convenience.
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Case No. 3:16-CV-00270-MMD-VPC
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WHEREFORE, for the foregoing reasons, the parties jointly move this Court for entry of
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final judgment against Relief Defendant.
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Date: January 8, 2018
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The Water-Walking Foundation, Inc.
/s/ Alyssa A. Qualls___
Alyssa A. Qualls (IL Bar No. 6292124)
175 West Jackson Blvd., Suite 1450
Chicago, Illinois 60604
Telephone: (312) 353-7390
Facsimile: (312) 353-7398
Email: quallsa@sec.gov
By: /s/ David B. Kaplan
David B. Kaplan, Esq.
Managing Member
1314-B Cave Rock Drive
Glenbrook, NV 89413
Telephone: (509) 263-4625
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Counsel for Plaintiff United States Securities
and Exchange Commission
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IT IS SO ORDERED:
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________________________________
The Honorable Miranda Du
United States District Judge
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January 8, 2018
Dated: _______________________
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Case No. 3:16-CV-00270-MMD-VPC
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