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

Filing 111

ORDER granting ECF No. 110 Stipulation to Release Defendant Kaplan's Passports After Entry of Final Judgments and Transfer of Frozen Assets. clerk directed to return the passports to Defendant Kaplan (mailed to Defendant Certified Return Receipt No. 7013 1710 0001 6894 4987 on 02/02/2018). Signed by Judge Miranda M. Du on 1/31/2018. (Copies have been distributed pursuant to the NEF - KW) (Additional attachment(s) added on 2/2/2018: # 1 Certified Mail Receipt) (KW).

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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]

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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: [phone]
Facsimile: [phone]

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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 TO RELEASE DEFENDANT
DAVID B. KAPLAN’S PASSPORTS AFTER
ENTRY OF FINAL JUDGMENTS AND
TRANSFER OF FROZEN ASSETS

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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.

On May 20, 2016, the Court granted the Motion for Temporary Restraining Order by

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Plaintiff United States Securities and Exchange Commission and ordered Defendant David B.

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Kaplan to surrender his passports (USA and St. Kitts/Nevis) to the Clerk of the Court. (ECF No. 14

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§ VII.)

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2.

On May 27, 2016, the Clerk of the Court received Defendant’s 2 passports and

secured them in the Court’s vault. (ECF No. 18.)
3.

On June 9, 2016, the Court entered an Agreed Order of Preliminary Injunction,

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directing the Clerk of the Court to retain Defendant’s passports until the conclusion of this

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litigation. (ECF No. 23 § V.)

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4.

On January 8, 2018, the parties filed Stipulations for Entry of Final Judgments,

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which asked this Court to enter final judgments against Defendants and Relief Defendants pursuant

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to settlement agreements among the parties. (ECF Nos. 95-98.)

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5.

On January 8, 2018, the Court entered Final Judgments against Defendants and

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Relief Defendants. (ECF Nos. 103-106.) The Final Judgments directed various financial

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institutions to transfer the entire balance of certain frozen accounts to the SEC within three days

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after being served with a copy of the Final Judgments.

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6.

As of January 31, 2018, all identified financial institutions had transferred the frozen

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funds to the SEC.

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7.

The Final Judgments having been entered and the SEC having received the frozen

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funds, the parties now respectfully request that the Clerk of the Court be directed to return the

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aforementioned passports to Defendant David B. Kaplan.

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Date: January 31, 2018

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/s/ Alyssa A. Qualls
Alyssa A. Qualls (IL Bar No. 6292124)
175 West Jackson Blvd., Suite 900
Chicago, Illinois 60604
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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/s/ David B. Kaplan
David B. Kaplan
1314-B Cave Rock Drive
Glenbrook, NV 89413
Telephone: [phone]
Email: [e-mail]

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Counsel for Plaintiff United States Securities
and Exchange Commission
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Case No. 3:16-CV-00270-MMD-VPC

Clerk of the Court be directed to return the
aforementioned passports to Defendant David B. Kaplan.

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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 31, 2018
Dated: _____________________

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