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

171. 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(b)(2)(A) of the Exchange Act [15 U.S.C. §§ 78m(b)(2)(A)].172. Pardo and Martin knowingly or with severe recklessness provided substantialassistance to Life Partners in its failure to devise and maintain a sufficient system of internalaccounting controls.173. By reason of the foregoing, Pardo and Martin aided and abetted Life Partners’violations, and unless restrained and enjoined will continue to aid and abet such violations, ofSection 13(b)(2)(B) of the Exchange Act [15 U.S.C. §78(m)(b)(2)(B)].through 145.FIFTH CLAIM FOR RELIEFCircumventing or Failing to Implement Internal Controls (Exchange Act Section 13(b)(5) and Rule 13b2-1) [15 U.S.C. § 78m(b)(5) and 17 C.F.R. §§ 240.13b2-1] [against Defendants Pardo, Peden and Martin] 174. The Commission realleges and incorporates by reference Paragraphs 1175. By engaging in the foregoing misconduct, from January 2007 through November2011, Defendants Pardo, Peden, and Martin violated, and unless enjoined will continue toviolate, Section 13(b)(5) of the Exchange Act [15 U.S.C. § 78m(b)(5)] by knowinglycircumventing or knowingly failing to implement a system of internal accounting controls at LifePartners, or by knowingly falsifying Life Partners’ books, records, or accounts subject to Section13(b)(2)(A) of the Exchange Act.176. By engaging in the foregoing misconduct, Pardo, Peden, and Martin violatedExchange Act Rule 13b2-1 [17 C.F.R. §§ 240.13b2-1] by, directly or indirectly, falsifying orSEC v. Life Partners Holding, Inc., et al. Page 52Complaint