Life Partners Holdings, Inc., Brian D. Pardo, R. Scott Peden, and ...

166. By reason of the foregoing, Pardo, Peden and Martin aided and abetted LifePartners’ violations, and unless restrained and enjoined will continue to aid and abet suchviolations, of Section 13(a) of the Exchange Act [15 U.S.C. § 78m(a)], and Rules 12b-20, 13a-1,and 13a-13 [17 C.F.R. §§ 240.12b-20, 240.13a-1, and 240.13a-13].FOURTH CLAIM FOR RELIEFViolation of the Books and Records and Internal Control Provisions of the Exchange Act (Sections 13(b)(2)(A) and 13(b)(2)(B)) [15 U.S.C. §§ 78m(b)(2)(A) and 78m(b)(2)(B)] [against Defendant Life Partners] through 145.167. The Commission realleges and incorporates by reference Paragraphs 1168. By engaging in the foregoing misconduct, from January 2007 through November2011, Life Partners, whose securities are registered pursuant to Section 12 of the Exchange Act[15 U.S.C. § 78l]: Failed to make and keep books, records, and accounts, which, in reasonable detail,accurately and fairly reflected the transactions and dispositions of its assets; and Failed to devise and maintain a system of internal controls sufficient to providereasonable assurances that: (i) transactions were recorded as necessary to permitpreparation of financial statements in conformity with GAAP or any other criteriaapplicable to such statements, and (ii) to maintain accountability of assets.169. By engaging in the foregoing misconduct, Life Partners violated, and unlessenjoined, will continue to violate, Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act [15U.S.C. §§ 78m(b)(2)(A) and 78m(b)(2)(B)].170. Pardo, Peden, and Martin knowingly or with severe recklessness providedsubstantial assistance to Life Partners in its failure to make and keep books, records, andaccounts, which, in reasonable detail, accurately and fairly reflected the transactions anddispositions of the assets of Life Partners.SEC v. Life Partners Holding, Inc., et al. Page 51Complaint