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20301 Grecia, Provincia de Alajuela, Costa Rica + (506) 8982-2029

Payday advances llc. SECURITIES AND TRADE COMMISSION

Payday advances llc. SECURITIES AND TRADE COMMISSION

Payday advances llc. SECURITIES AND TRADE COMMISSION

ACE PAYDAY PLUS, LLC D/B/A ACE PAYDAY PLUS II, LLC; ACE PAYDAY MANAGEMENT, INC; ACE MANAGEMENT, LLC.; AND JAMES BIANCO,

WHEREFORE , Plaintiff Commission respectfully requests that this Court:

A. Grant an Order temporarily and preliminarily, and a Final Judgment completely enjoining defendants, their officers, agents, servants, workers, lawyers, and all sorts of people in active concert or involvement using them whom get real notice associated with the injunction by individual solution or else, and every of these, from future violations of parts 5(a) and (c), 15 U.S.C. §§ 77e(a) and 77e(c), and 17(a) of this Securities Act, 15 U.S.C. § 77q(a).

B. Grant an Order temporarily and preliminarily, and a Final Judgment forever enjoining defendants, their officers, agents, servants, workers, lawyers, and all sorts of individuals in active concert or involvement using them whom get real notice associated with the injunction by individual solution or else, and every of those, from future violations of part 10(b) regarding the Exchange Act, 15 U.S.C. В§ 78j(b), and Rule 10b-5 promulgated thereunder, 17 C.F.R. В§ 240.10b-5.

C. Grant an Order directing defendants, and every of those, to register with this specific Court and provide upon plaintiff, within three company times, or within such expansion of the time while the Commission agrees, a confirmed written accounting, finalized by them under penalty of perjury, of:

1. All assets, liabilities and home currently held straight or indirectly by or even for the advantage of defendants, and every of these, including although not limited by bank reports, brokerage reports, opportunities, company passions, loans, personal lines of credit, and genuine and individual home anywhere situated, explaining each asset and obligation, and its own present location and quantity;

2. All cash, home, assets, along with other earnings gotten by defendants, and every of these, and for their direct or benefit that is indirect in or whenever you want to your date associated with the accounting, explaining the origin, quantity, payday loans Pennsylvania disposition and present location of each and every regarding the products detailed;

3. The names and final understood addresses of most bailees, debtors, along with other people and entities that are presently keeping the assets, funds or home of defendants, and every of those; and

4. All assets, funds, securities, genuine or individual home gotten by defendants, and every of those, or other person managed by them, from individuals whom offered cash to defendants relating to the offer, purchase or purchase of assets of any sort, additionally the disposition of these assets, funds, investments, and genuine or individual property.

D. Grant a Final Judgment directing defendants to disgorge their unjust enrichment through the conduct that is fraudulent in this grievance also to spend prejudgment interest thereon.

E. Give a Final Judgment evaluating charges against defendants pursuant to Section d that is 20( of this Securities Act, 15 U.S.C. В§ 77t(d), and Section 21(d)(3) of this Exchange Act, 15 U.S.C. В§ 78u(d)(3), when it comes to violations alleged herein.

F. Grant an Order directing that defendants, and their officers, agents, servants, workers, attorneys-in-fact, and all sorts of individuals in active concert or participation with every of those, whom get real notice of these purchase by individual service, facsimile solution, or perhaps, and every of these, hold and retain in their control, and otherwise prevent any withdrawal, transfer, pledge, encumbrance, project, dissipation, concealment, or other disposal of every assets, funds, or any other properties (including cash, genuine or individual home, securities, chooses for action or home of every type whatsoever) of defendants presently held by them or under their control, whether held in almost any of the names and for some of their direct or indirect useful interest anywhere situated, and directing all the economic or brokerage organizations, debtors, and bailees, or some other individual or entity keeping such assets, funds, or other properties of defendants, and every of those, to put on or retain within its control and prohibit the withdrawal, treatment, transfer, or other disposal of every such assets, funds, or other properties.

G. Grant an Order enjoining and defendants that are restraining anybody or entity acting at their way or for the kids from destroying, changing, concealing or elsewhere interfering utilizing the access associated with the plaintiff to your and all sorts of papers, publications and documents that are within the control, custody or control of defendants, their agents, workers, servants, accountants, economic or brokerage organizations, and solicitors that refer, reflect or relate solely to the allegations for the grievance, including, although not restricted to, papers, publications and documents referring, showing or associated with Ace Payday’s company operations, as well as its offer or purchase of securities while the utilization of profits therefrom.

H. Give such other and further relief as is simply and appropriate.

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