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

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e) ordering Defendants to disgorge all ill-gotten gains, with prejudgment interest;f) ordering Defendants to pay civil penalties under Section 20(d) of the Securities Act [15U.S.C. § 77t(d)] and Sections 21(d)(3) and 21A of the Exchange Act [15 U.S.C. §§78u(d)(3) and 78uA];g) prohibiting each Defendant, under Section 20(e) of the Securities Act [15 U.S.C. §77t(d)(4)] and Section 21(d)(2) of the Exchange Act [15 U.S.C. §78], from acting as anofficer or director of any issuer that has a class of securities registered under Section 12of the Exchange Act [15 U.S.C. § 78l] or that is required to file reports under Section15(d) of the Exchange Act [15 U.S.C. §78o(d)]; andh) in a form consistent with Fed. R. Civ. P. 65(d), ordering Pardo and Martin to reimburseLife Partners for bonuses and profits they received from Life Partners stock sales,pursuant to Section 304 of the Sarbanes-Oxley Act of 2002 [15 U.S.C. § 7243].i) granting such other relief as the Court may deem just and appropriate.SEC v. Life Partners Holding, Inc., et al. Page 56Complaint
Dated this 3 rd day of January 2012Respectfully submitted,__________________________Jason C. RodgersTexas Bar No. 24005540Toby M. GallowayTexas Bar No. 00790733Michael D. KingTexas Bar No. 24032634Attorneys for PlaintiffSECURITIES AND EXCHANGECOMMISSION801 Cherry Street, 19th FloorFort Worth, TX 76102Phone: (817) 978-3821Fax: (817) 978-2700SEC v. Life Partners Holding, Inc., et al. Page 57Complaint
Page 1:
UNITED STATES DISTRICT COURT FOR TH
Page 6 and 7: spreadsheet of the 300 “most rece
Page 9 and 10: 24. R. Scott Peden, age 47, has ser
Page 11: 32. Pardo hired Cassidy without con
Page 14 and 15: insurance. In fact, contrary to the
Page 16 and 17: E. Defendants Knew that Cassidy’s
Page 18 and 19: oker life settlement interests were
Page 20 and 21: 57. Contrary to Life Partners’ mi
Page 22 and 23: THE ACCOUNTING FRAUD 64. In fiscal
Page 24 and 25: agreement to sell the policy for an
Page 26 and 27: 76. Under GAAP, revenue can be reco
Page 28 and 29: therefore misleading. Based on the
Page 30 and 31: 88. Pardo, Peden, and Martin were a
Page 32 and 33: E. Life Partners Backdated Certain
Page 34 and 35: though all three of its internal cr
Page 36 and 37: Company made it a practice to keep
Page 38 and 39: 118. In a letter to the Company dat
Page 40 and 41: that affects our assumptions about
Page 42 and 43: ecommended that “[a] formal analy
Page 44 and 45: 136. Life Partners’ 2011 Form 10-
Page 46 and 47: 11/3/2008 $36.67 2,866 $105,096.221
Page 48 and 49: through 145.SECOND CLAIM FOR RELIEF
Page 50 and 51: through 145.THIRD CLAIM FOR RELIEFV
Page 52 and 53: 171. By reason of the foregoing, Pa
Page 54 and 55: through 145.SEVENTH CLAIM FOR RELIE
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Life Partners Holdings, Inc., Brian D. Pardo, R. Scott Peden, and ...

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